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16 December 2016

Hazardous Substances

Environmental Protection Authority

Private Bag 63002

Wellington 6140

Submission on application for the reassessment of chlorothalonil formulations

Introduction

1. The Soil & Health Association of New Zealand Inc. (‘Soil & Health’) was incorporated

under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s

objectives broadly include soil health and the promotion of organic gardening and

farming. It has approximately 3000 members, chiefly composed of home gardeners

and consumers, organic farmers and growers, secondary producers, retailers and

restaurateurs. Its age and membership make it the oldest and largest representative

organic organisation in New Zealand.

2. Soil & Health is opposed to the use of harmful pesticides in Aotearoa New Zealand.

As an organisation we advocate for farmers and growers to adopt natural, organic,

non-harmful methods of pest and disease management. We believe that

researchers, farmers and growers should be encouraged to develop and implement

nonchemical alternatives to pesticides that foster soil microbial life instead of

destroying it.

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3. Soil & Health is opposed to the use of fungicides containing chlorothalonil in New

Zealand. A number of independent scientific studies have raised serious concerns

about the effects that chlorothalonil has on human health and the environment.

4. Soil & Health therefore strongly supports the EPA’s recommendation to revoke the

approval of four (HSR000480, HSR000147, HSR000586, HSR100872) non-

professional use chlorothalonil formulations and to dispose of the existing stocks of

these formulations within the next 6 months. However Soil & Health considers that

the fifth outstanding (HSR00618) non-professional use chlorothalonil formulation

considered in the application should also have its approval revoked.

Detailed submissions

Adverse effects on humans

5. We strongly agree with and support the EPA’s statement that “the high toxicity of

chlorothalonil means that serious human health effects can develop from even small

exposures to chlorothalonil.” Chlorothalonil is listed on the Pesticide Action Network

International list of Highly Hazardous Pesticides for global phase out.1 Chlorothalonil

is a known carcinogen, mutagen and an environmental toxin and it is thought

responsible for aggravating the health effects of other pesticides. The application

itself points out that the hazard classification of the substances are all classified as

suspected carcinogens while several are classified as acutely toxic by inhalation,

corohesive to the eye and/or as suspected mutagens. The carcinogenic classification

in the application is based on findings of kidney tumours in male rats and mice and

in female rats following administration in long-term toxicity studies. In a study

released by the US government health staff it was found that exposure to certain

pesticides, chlorothalonil increased the risks 5.6 fold and 2.4 fold respectfully, of a

blood disorder that can lead to multiple myeloma.2

1 PAN International List of Highly Hazardous Pesticides, Pesticides Action Network International 2011,

page 15. 2 American Society of Hematology Journal, Blood, June 2009 (2,3).

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Adverse effects on the environment

6. According to the Environmental Health Criteria 183 of the International Programme

on Chemical Safety chlorothalonil is considered by the World Health Organisation

and to be highly toxic to fish and aquatic invertebrates.

7. In a study by the University of Florida it was found that chlorothalonil killed nearly

every amphibian at the approximate expected environmental concentrations to

which humans are commonly exposed. The study concluded that future studies

should be carried out that directly quantify the effects that chlorothalonil has on

amphibian populations and human health.3

8. In an article published in the peer-reviewed scientific journal ‘Archives of

Environmental Contamination and Toxicology’, it was stated that despite the low

water solubility of chlorothalonil it has been detected in Australian waterways, and

while chlorothalonil can be readily removed from the water column by binding to

sediment or suspended solids in the water, the ecotoxicological data from the

literature show that it is acutely toxic to nontarget organisms at concentrations

much lower than reported environmental concentrations.4

9. Research as shown that children are the most vulnerable, up to 108 times, to fatal

aerosol effects of chlorothalonil. The home use of the product increases the risk of

exposure to children and adolescents.

Adverse effects of Black Spot and Fungus Spray and Watkins Fungus and Mildew Spray

(HSR00618)

10. We consider that due to the harmful effects of McGregor’s Black Spot and Fungus

Spray and Watkins Fungus and Mildew Spray, the approval for these substances

should also be revoked. The hazard classifications that these products fall into are

fatal, suspected human mutagen, toxic to human organs, skin sensitiser, and

corrosive to the eye. They are also very toxic to the aquatic environment, persistent

and harmful to soil and terrestrial vertebrates (6.1B, 6.3B, 6.5B, 6.6B, 6.9A, 8.3A,

9.1A, 9.2C, 9.3C).

3 The Fungicide Chlorothalonil Is Nonlinearly Associated with Corticosterone Levels, Immunity, and

Mortality in Amphibians, Environmental Health Perspectives, vol 119, number 8, August 2011, pp 1098 4 Assessing the Chronic Toxicity of Atrazine, Permethrin, and Chlorothalonil to the Cladoceran

Ceriodaphnia cf. dubia in Laboratory and Natural River Water, Archives of Environmental Contamination and Toxicology (2013) 64 pp 420.

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Failure to meet requirements under HSNO Act

11. Due to the adverse effects of chlorothalonil listed above, we consider that if the

decision-making committee decides to reject the EPA’s recommendations and

continues to allow the non-professional use of chlorothalonil formulations in New

Zealand it would be failing to recognise and provide for the life-supporting capacity

of air, water, soil and ecosystems, as required to do under section 5(a) of the HSNO

Act.

12. Section 28 (2)(a) of the HSNO Act requires each application for approval to include

the unequivocal on all the possible adverse effects on of the substance and its

properties. We consider that this has not been met due to the EPA failing to identify

the adjuvant properties of the McGregors and Watkins formulations, which increase

the toxicity of pesticides.

13. Section 28 (2) (b) requires that each application for approval include information on

all the possible adverse effects of each substance. We consider that the EPA has also

failed to meet this requirement as the EPA has not assessed the cumulative and

synergistic effects of the two chemicals contained in the McGregor Watkins

products, and whether they increase the hazardous rating, making this compound

even more eco toxic than if applied singly.

Alternatives to chlorothalonil formulations and other toxic pesticides

14. Conventional agriculture relies on pesticides to protect crops from pests and

diseases, including synthetic herbicides to control weeds, and synthetic fertilisers to

promote crop growth. Over time this heavy use of synthetic chemicals reduces the

soil biota and the productive capacity of the soil, and creates increased resistance by

pests to the chemicals used, as well as the resurgence of secondary pests. These

chemicals are also dispersed in the environment, polluting waterways and damaging

ecosystems.

15. Numerous studies on the adverse impacts of pesticides and chemical fertilisers have

raised awareness about the use of synthetic chemicals in agriculture, how effective

they actually are in treating pests and diseases, and the impact they are having on

human health as well as the wider environment. People are turning to more natural

forms of pest and disease control that are more effective, sustainable and healthier

in the long term.

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16. Organic agriculture has a holistic approach to pest and disease management that

avoids the need for pesticides by instead focusing on building healthy fertile soil

with abundant microbial life, fostering natural predators and using natural remedies.

Truly well-nourished plants do not attract pests or provide a suitable conditions for

pests and diseases to develop. Farmers and producers try to create healthy soil so

that plants and animals can be healthy, and build up good natural defenses against

pests and diseases. The long-term health of the soil is taken into consideration,

rather than trying to deal with the immediate problem with synthetic sprays.

17. The application itself points out that there are several alternatives for use in a home-

setting available on the market in New Zealand. The application states that several

fungicides with lower hazards are available, including horticultural oils, sulfur, and

the biological fungicide (Bacillus Subtilis).

18. We consider that even those fungicides currently available can easily be replaced by

non-chemical biological controls that do not have an adverse effect on the

environment. We therefore consider that chlorothalonil formulations do not provide

any extra advantage.

Conclusion

19. Due to the many adverse effects associated with the use of chlorothalonil

formulations as well as the lack of convincing evidence of both its need and safety

the Soil & Health Association consider that the decision-making committee should

accept the recommendations of the EPA to take a precautionary approach as

required under section 7 of the HSNO Act, and revoke the approval of four non-

professional use chlorothalonil formulations (HSR000480, HSR000147, HSR000586,

HSR100872) and to dispose of the existing stocks of these formulations within the

next 6 months.

20. We further request that the fifth (HSR00618) chlorothalonil formulation also have

their approval withdrawn for any importation, storage, sale, copating, or dispersal,

until international scientific evidence exonerates this fungicide from any linkage with

human health impacts.

21. Soil & Health wish to be in heard in support of our submission.

Yours sincerely

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Name: Mischa Davis

Position: Policy Advisor

The Soil & Health Association

PO Box 340002

Birkenhead

Auckland 0746

Phone: 06 8775534

Mobile: 0212667754

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

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