Extracts fromOrganic Federation of Australia.

Submission – to the green paper on National Food Plan

Andre LeuChairman of OFA

Australian Pesticide Regulation

– A growing credibility gap

Serious questions need to be asked about our current regulatory system.A review published by the World Wildlife Fund and the National Toxics Network showed that Australian farmers use around 80 chemicals that were banned in other countries because they pose risks to human health and the environment.

The report authors stated: ‘The list includes 17 chemicals that are known, likely or probable carcinogens, and 48 chemicals flagged as having the potential to interfere with hormones. More than 20 have been classified as either extremely or highly hazardous by the World Health Organisation yet remain available for use on Australian farms.’

Why does Australia permit 80 chemicals in our food supply that would be illegal if used in the European Union and other countries? An example is Atrazine. This is widely used in Australia, however it is illegal to use it in the EU and Switzerland. (Atrazine is a herbicide used in cropping)

This sort of slow response has enormous impact on the perceptions of Australian products, and in the advent of Social Media campaigns can have immediate affects to industries operating internationally.

Why is Australia usually amongst the last countries in the world to ban toxic chemicals, sometime decades after publication of peer reviewed science that other countries used as the basis to withdraw chemicals from food production? Endosulfan is a good example. Australia was one of the last countries in the developed world to withdraw it from use. The USEnvironmental Protection Authority ended all food uses of Chlorpyrifos (an Organophosphate) after studies linked it to a range of negative health outcomes.  

The Australian Pesticides and Veterinary Medical Authority did not act at all on these studies or on the USEnviromental Protection Authority review to restrict it to non-food uses. Based on the latest published research the USEPA is now reviewing whether to withdraw all uses of this pesticide.

The special needs of developing foetus and the new

born• The 20th Australian Total Diet Survey,

published by Food Security ANZ acknowledged that young children have greater pesticide exposure levels due to their size and weight ratios to the amount of residues they receive from food. ‘In general, the dietary exposure to pesticide residues was highest for the toddler age group. This is due to the high food consumption relative to body weight.’

Endocrine Disruption

•  • The growing body of published science on

endocrine disruption, where very small amounts of some types of synthetic chemicals can act like hormones, has many scientists stating that the current methods of assessing the toxicity of synthetic chemicals in our diet and environment are inadequate.

In the 1940s scientist began to notice that some pesticides produced hormonal changes in test animals.

By the 1980s there were numerous studies showing that many chemicals, including pesticides were causing significant hormonal changes in living species, especially with the reproductive hormones.

As an example, researchers have now found that there are many chemicals that act like estrogen and they were causing a range of reproductive and other problems in numerous species including humans.

These xeno-estrogens were implicated in lowering sperm counts, increasing the number of offspring born with genital-urinary tract abnormalities and also with the increase in cancers of the sexual tissues (breast, ovarian, uterine, testicular, prostate and vaginal cancers).

Cocktails /Mixtures of Chemicals

•  • Most pesticides are applied as mixtures. The current

regulatory system does not require any testing of these mixture on the assumption that because each of the active ingredients is below the ADI that the cocktail is also safe.

• • The APVMA does not test for the safety of these

combinations of chemicals – the chemical cocktails that are ingested every day.

Several studies raise serious concerns.The emerging body of science demonstrates that many chemical cocktails act synergistically. This means that instead of 1+1= 2, the extra effect of the mixtures can mean 1+1= 60 or even 1000 in toxicity.

The Need for Scientific Tests to fill Data Gaps

• It is the opinion of the OFA that the Australian Government and its designated regulatory authorities such as the APVMA and FSANZ have a legal duty of care to ensure that Australians are not exposed to harm or potential toxic insult from chemicals that they permit in our food, water or environment.

Based on the current state of published scientific peer reviewed science there are serious data gaps due to current chemical regulatory system having inadequately tested the permitted chemicals used in our food supply for the effects of cocktails /mixtures of chemicals, endocrine disruption and the special needs of developing foetus and the new born.

This has resulted in many scientific experts stating in numerous published peer reviewed studies that the current regulatory systems have no basis to state that the current levels of exposure to these permitted chemicals is safe.

New Technology and Biotechnology Adoption

The OFA is particularly concerned about the misrepresentation of the data the Green Paper presents to justify the adoption of GMOs, especially the following statement in the breakout titled ‘GM technology in food production’ on page 152:

‘ However, in the 2010 European Commission report analysing EU-funded genetically modified organism (GMO) research, the report concluded that biotechnology and in particular, GMOs were not intrinsically more risky than conventional plant breeding techniques (EU 2010).This was based on more than 130 research projects covering a period of more than 25 years of research and involving more than 500 independent research groups.’

The quoted report was prepared by the Directorate-General for Research and Innovation, Directorate E —Biotechnologies, Agriculture, Food, Unit E2 — Biotechnologies. It mostly consisted of papers on the various research projects that were funded by the EU. The vast majority of the projects had absolutely nothing to do with evaluating whether GMOs were more risky than conventional breeding techniques.

Lack of Research• Professor Seralini and his colleague have expressed great

concern over the lack of scientific testing for the adverse health effects associated with GMOs.

• • They stated: '...that it is unacceptable to submit 500

million Europeans and several billions of consumers worldwide to the new pesticide GM-derived foods or feed, this being done without more controls (if any) than the only 3-month-long toxicological tests and using only one mammalian species, especially since there is growing evidence of concern...' (Seralini et al 2011)

•  

GMO regulation• The OFA is concerned with the

strong bias shown in the green paper to GMOs without due consideration been given to the emerging body of science showing a range of problems with these technologies.

History shows that there has been a consistent failure of regulatory authorities to prevent the contamination of the environment and human health by products previously said to be safe such as Asbestos, Lead, Mercury, Dioxins, Tobacco smoke, PCBs, DDT, Dieldrin and other Persistent Organic Pollutants.

The Australian government has the opportunities of avoiding past mistakes by properly considering the scientific data that shows problems with new technologies such as GMOs, rather than just ignoring or dismissing these studies.

The Need for Scientific Tests to fill Data Gaps

• It is the opinion of the OFA that the Australian Government and its designated regulatory authorities have a legal duty of care to ensure that Australians are not exposed to harm or potential toxic insult from GMOs that they permit in our food, water or environment

This means that the government needs to fully assess all the scientific data, and where there is uncertainty in the potential biosafety issues for the use of GM products in food, that adequate independent scientific testing must be conducted and published in a peer reviewed journal.

The Australian and State Governments should not approve the commercial release of GM crops until this new testing methodology has been developed and the GM crops have been shown to be safe after the testing procedures

Conclusion

The Organic Federation of Australia supports the drafting of the National Food Plan and acknowledges the complexity of drafting a document that meets the needs for all concerns, both commercial and social.

The development of strategies and programs that encourages the development of all sized enterprises will maintain the diversity of food sectors and supply chains, building resilience of the Australian Food Sector to domestic and international pressures.

The National Food Plan must recognise the new environment in which both industries and Government now operate with the “trials” by social media having a real and immediate effect.

Where can you find out more?

• www.ofa.org.au – • www.who.org• www.choice.com.au• www.apvma.gov.au• www.foodstandards.gov.au• Www.daff.gov.au/nationalfoodplan• www.greenleft.org.au• www.ewg.org.

What can we do• Water• Buy LOCAL (not imported from overseas) Organic Food• Grow you own• Use natural cleaning products – Bi carb and Vinegar• Cosmetics – check contents – buy organic• Beware of Pesticides, Herbicides Garden – ant killers• Beware of Pesticides in homes – surface sprays • Read the labels • Buy products from an Enviromentally conscience retail stores