Proposed risk assessment
methodology for hazardous substances
Submission Reference no: 4
Helen Black
Submitter Type: Not specified
Source:
Email
Overall Notes:
Clause
7. Are there alternative groundwater models that the EPA could consider as part of a revised groundwater risk assessment
framework?
Notes
Look for water tests that measure in parts per tril ion as hormonal changes can occur at these low levels.
Clause
I would like my personal information (other than my name) to be withheld from any publicly available response documents.
Position
No
Notes
How can a methodology such as using a cost effective analysis of hazardous
eco-toxic poisons to reach the predator free 2050 goal take precedent over
putting the health of the NZ population at risk? Or herbicides sprayed along
riverbeds, park settings or play grounds? My belief is that known eco-toxic
substances currently freely deposited around New Zealand, such as
compound 1080, brodifacoum (and other anti-coagulants), Thordon, Roundup
and other poisons, that are not target specific have no place in our society.
The end goal doesn’t not justify the means.
A real health threat for future New Zealand generations that needs to be
taken into account: For example, compound 1080 is known to cause male
reproductive toxicity (US EPA 1994) amongst many other health issues.
https://oehha.ca.gov/proposition-65/crnr/request-information-chemicals-
under-consideration-possible-listing-authoritative
A German Environmental and Resource Student highlight in his paper that
the ethical limitations of using the ‘cost-benefit analysis’ method become
apparent in areas of environmental, safety and health regulations.
The 26.5 tonnes of brodifacoum dropped alongside a Nelson neighbourhood
highlighted a raft of government departments and agencies passing the buck
when I inquired about the safety of this practice. The impact of mass
applications show in research papers a lot of knowledge gaps both in regards
to human health, impact on soil and eco-systems, what is deemed acceptable
by-kil of non-targeted species, the moral obligations we have to act in a
humane manner to al wildlife species (as we do have a law that
acknowledges that animals are sentient beings), the value and cultural
traditions many people and communities put on a diverse wildlife and plants
whether it is for a recreational purpose, the wellbeing of being safe in outdoor
areas with family, pets or domestic animals or for hunter-gatherers. I do not
believe poison warning signage reflect that adequate responsibility of the
dangers of highly toxic substances on our land by local and government
officials/departments/agencies are acceptable or that poisons in our
environment as a definition as something hazardous which can cause il ness
or death are taken seriously.
http://www.icrp.org/docs/6/11.%20Philosophical
%20Critique%20of%20Limitations%20of%20Cost%20Benefit%20Analysis-
Stuck.pdf
Steven Kelman writes “Finally, of some things valued very highly it is stated
that they are “priceless” or that they have “infinite value. Such expressions
are reserved for a subset of things not for sale, such as life or health.
Economists tend to scoff at talk of pricelessness. For them, saying that
something is priceless is to state a wil ingness to trade off an infinite quantity
of all other goods for one unit of the priceless good, a situation that
empirically appears highly unlikely. For most people, however, the word
priceless is pregnant with meaning.”
The ‘cost effective’ principle also does not take into the account the future
costs of turning children and adults into patriotic kil ers to achieve a goal such
as predator free 2050. The cost of devaluing species in especially a young
child has a potential to make for a very unsafe and uncaring society.
Research repeat again and again that the kil ing of animals at a young age
has a potential to cause negative effects in other situations later in life. It is an
effective grooming ground for psychopaths. What would the long-term cost be
for such a society?
Conflict of interest: MPI for example has the task of looking after animal
welfare and the same time their other task is to keep growing the export
industry. This is a conflict of interest within the same department. Another
example is DoC. This agency do not use brodifacoum which is an eradication
tool apart from on island setting due to its high eco-toxicity to many species
and its inhumaneness which Landcare Research has established. However,
DoC do not speak up and they even support community groups, local
councils to use these eco-toxins in bait stations al around the country. If this
predatorfree 2050 goal wasn’t being pushed, DoC in their capacity of
‘managing public land’ with access to al these studies ought to advocate for
this poison to be banned or only used in highly restricted ways with minimal
impact to any other outdoor users of land. Conflict of interests override best
environmental and humane practices.
What is viewed as a ‘cost-effective’ methodology short-term is indeed very
short sighted. I believe the only way forward is to adopt a pre-cautionary
principle to environmental, safety and health regulations.
Thank you for your time.
Helen Black
