Dear Ursula,

It is our policy here that all OIA requests are managed by the legal team.
I acknowledge receipt of your email.  We will reply as soon as we can.

Regards

Annabelle Watson
Senior Legal Counsel

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour,
Auckland | [1]www.niwa.co.nz

[2]NIWA

To ensure compliance with legal requirements and to maintain cyber
security standards, NIWA's IT systems are subject to ongoing monitoring,
activity logging and auditing. This monitoring and auditing service may be
provided by third parties. Such third parties can access information
transmitted to, processed by and stored on NIWA's IT systems.

-----Original Message-----
From: Ursula Edgington
[mailto:[FYI request #4865 email]]
Sent: Friday, 28 October 2016 5:44 p.m.
To: Enquiries <[email address]>
Subject: Official Information request - Ethics application and approval

Dear National Institute of Water and Atmospheric Research Limited,

With regard to the original experiment that resulted in this research
output:

Suren, A.M.; Lambert, P. 2006. Do toxic baits containing sodium
fluroacetate (1080) affect fish and invertebrate communities when they
fall into streams? New Zealand Journal of Marine and Freshwater Research
40: 531-546.

please supply a copy of the Principal Investigator's Research Ethics
Application, plus the accompanying approval from the NIWA Committee, and
any relevant correspondence.

thank you.

-------------------------------------------------------------------

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Please use this email address for all replies to this request:
[FYI request #4865 email]

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requests to National Institute of Water and Atmospheric Research Limited?
If so, please contact us using this form:
https://fyi.org.nz/change_request/new?bo...

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ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

-------------------------------------------------------------------

References

Visible links
1. http://www.niwa.co.nz/
2. http://www.niwa.co.nz/

hide quoted sections

Hi Ursula,

Please see attached letter.

Regards

Annabelle Watson
Senior Legal Counsel

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour,
Auckland | [1]www.niwa.co.nz

[2]NIWA

To ensure compliance with legal requirements and to maintain cyber
security standards, NIWA's IT systems are subject to ongoing monitoring,
activity logging and auditing. This monitoring and auditing service may be
provided by third parties. Such third parties can access information
transmitted to, processed by and stored on NIWA's IT systems.

-----Original Message-----
From: Ursula Edgington
[mailto:[FYI request #4865 email]]
Sent: Friday, 28 October 2016 5:44 p.m.
To: Enquiries <[email address]>
Subject: Official Information request - Ethics application and approval

Dear National Institute of Water and Atmospheric Research Limited,

With regard to the original experiment that resulted in this research
output:

Suren, A.M.; Lambert, P. 2006. Do toxic baits containing sodium
fluroacetate (1080) affect fish and invertebrate communities when they
fall into streams? New Zealand Journal of Marine and Freshwater Research
40: 531-546.

please supply a copy of the Principal Investigator's Research Ethics
Application, plus the accompanying approval from the NIWA Committee, and
any relevant correspondence.

thank you.

-------------------------------------------------------------------

This is an Official Information request made via the FYI website.

Please use this email address for all replies to this request:
[FYI request #4865 email]

Is [NIWA request email] the wrong address for Official Information
requests to National Institute of Water and Atmospheric Research Limited?
If so, please contact us using this form:
https://fyi.org.nz/change_request/new?bo...

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://fyi.org.nz/help/officers

If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

-------------------------------------------------------------------

References

Visible links
1. http://www.niwa.co.nz/
2. http://www.niwa.co.nz/

hide quoted sections

Dear Ursula,

I acknowledge receipt of your email below. We will respond as soon as we
can.

Regards

Annabelle Watson
Senior Legal Counsel

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour,
Auckland | [1]www.niwa.co.nz

[2]NIWA

To ensure compliance with legal requirements and to maintain cyber
security standards, NIWA's IT systems are subject to ongoing monitoring,
activity logging and auditing. This monitoring and auditing service may be
provided by third parties. Such third parties can access information
transmitted to, processed by and stored on NIWA's IT systems.

-----Original Message-----
From: Ursula Edgington
[mailto:[FOI #4865 email]]
Sent: Monday, 28 November 2016 3:55 p.m.
To: Annabelle Watson <[email address]>
Subject: Re: Official Information request - Ethics application and
approval

Dear Annabelle Watson,

Thank you for supplying the Animal Ethics Application and approval letter
for these research studies. However, I needed to see ALL the ethics
applications. Please therefore clarify that no Human Ethics Application
was completed for these studies - if that was indeed the case (?) And if
there WERE no Human Ethics Applications, please supply the name(s) of the
person(s) who was qualified to make this decision, and the full,
scientific, peer-reviewed rationale upon which it was based.

With the above in mind, I draw NIWA’s attention to their social
responsibility in using highly toxic substances, which include the
following 3 issues:

1)The fact that during the experiment, up to eighty 1080 toxic poison
baits per stream were added – 10 times the approx. amount distributed
during a typical aerial 1080 application. The manufacturer of this poison
in the US specifically warns against using this poison in or near any
waterways, because of its acute toxicity. This experiment was only carried
out for four days - a very limited time-frame considering its potentially
harmful effects - and therefore any longer-term potential consequences of
the toxin contamination – whether histological or generational or other –
to aquatic life and/or humans – was not recorded. For instance, Compound
1080 is a powerful insecticide (registered in NZ e.g. to kill wasps).

2)It appears the longer-term monitoring of the study site was not
considered - for the wildlife or the humans. This was concerning
considering there has been no research into how long 1080 poison persists
in treated areas. In the ERMA documents it was recognised that it might
persist indefinitely at low concentrations. It has been found to persist
in many varied situations including dry places, cool water, water lacking
aquatic plants, some types of soil, in carcasses and concrete water pipes
(Eisler, 1995). The rate of breakdown of 1080 poison in New Zealand
forests and streams is unknown, but it is extremely slow at around 5
degrees Celsius. Thus ERMA’s Agency warned that “No studies have been
conducted using standard international guidelines to assess the route and
rate of degradation of 1080 in soil. The rate of such degradation under
New Zealand conditions is uncertain.” And regarding water:  “Overall, the
relevance of the aquatic plant/water studies to the degradation of 1080 in
water in NZ is not clear.” (Pollard, 2011)

3)In the Animal Ethics Application you have sent me, it states clearly
that both the fish and the crayfish were returned to these (publicly
accessible) streams after being subjected to the 1080 poisoning (those
that survived after 4 days), and that it also clearly acknowledges that
these fish and crayfish are common sources of food for New Zealanders.
 MoH have acknowledged that no public health studies exist into 1080
despite numerous scientists pointing out how crucial this is (e.g.
Scanlon, 2010)

Please note that on page 534 of Suren’s (2006) published article he states
that one of the fish cages were stolen. Clearly then, this study site was
accessible to the public and other residential areas were nearby and
downstream from the site. The crucial need for a Human Ethics Application
for this experiment therefore seemed obvious, especially when there are no
known epidemiological studies of the potential impact of Compound 1080 on
public health. This concern applies to individuals directly drinking the
contaminated water and/or eating of contaminated vegetation, fish
and/invertebrates involved in the study  -  or otherwise become part of
the food-chain that evolved from it (Eason et al., 2013).

I await your response with interest.

References
Eason, C.T., Ross J. & Miller, A. (2013) Secondary Poisoning risks from
1080-poisoned carcasses and risk of trophic transfer – a review. NZ
Journal of Zoology Vol 40 (3) pp 217-225
http://dx.doi.org/10.1080/03014223.2012....
Eisler, R. (1995) Sodium Monofluoroacetate (1080)Hazards to Fish, Wildlife
and Invertebreates: a Synoptic Review. Available at:
https://www.pwrc.usgs.gov/eisler/CHR_30_...
Pollard, J. (2016) Aerial 1080 poisoning in New Zealand: Reasons for
concern. Scientific Reviews:
http://1080science.co.nz/aerial-1080-poi...
Scanlon P. (2010) Letter to Parliament, available at:
https://www.parliament.nz/resource/mi-nz...

-----Original Message-----

Hi Ursula,

Please see attached letter.

Regards

Annabelle Watson
Senior Legal Counsel

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour,
 Auckland | [1]www.niwa.co.nz

[2]NIWA

To ensure compliance with legal requirements and to maintain cyber
 security standards, NIWA's IT systems are subject to ongoing monitoring,
 activity logging and auditing. This monitoring and auditing service may
be  provided by third parties. Such third parties can access information
 transmitted to, processed by and stored on NIWA's IT systems.

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #4865 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://fyi.org.nz/help/officers

If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

-------------------------------------------------------------------

References

Visible links
1. http://www.niwa.co.nz/
2. http://www.niwa.co.nz/

hide quoted sections

Dear Ursula,

 

Please see attached letter.

Regards

 

Annabelle Watson
Senior Legal Counsel

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour,
Auckland | [1]www.niwa.co.nz

[2]NIWA

To ensure compliance with legal requirements and to maintain cyber
security standards, NIWA's IT systems are subject to ongoing monitoring,
activity logging and auditing. This monitoring and auditing service may be
provided by third parties. Such third parties can access information
transmitted to, processed by and stored on NIWA's IT systems.

-----Original Message-----

From: Ursula Edgington
[[3]mailto:[FOI #4865 email]]

Sent: Monday, 28 November 2016 3:55 p.m.

To: Annabelle Watson <[4][email address]>

Subject: Re: Official Information request - Ethics application and
approval

 

Dear Annabelle Watson,

 

Thank you for supplying the Animal Ethics Application and approval letter
for these research studies. However, I needed to see ALL the ethics
applications. Please therefore clarify that no Human Ethics Application
was completed for these studies - if that was indeed the case (?) And if
there WERE no Human Ethics Applications, please supply the name(s) of the
person(s) who was qualified to make this decision, and the full,
scientific, peer-reviewed rationale upon which it was based.

 

With the above in mind, I draw NIWA’s attention to their social
responsibility in using highly toxic substances, which include the
following 3 issues:

 

1)            The fact that during the experiment, up to eighty 1080 toxic
poison baits per stream were added – 10 times the approx. amount
distributed during a typical aerial 1080 application. The manufacturer of
this poison in the US specifically warns against using this poison in or
near any waterways, because of its acute toxicity. This experiment was
only carried out for four days - a very limited time-frame considering its
potentially harmful effects - and therefore any longer-term potential
consequences of the toxin contamination – whether histological or
generational or other – to aquatic life and/or humans – was not recorded.
For instance, Compound 1080 is a powerful insecticide (registered in NZ
e.g. to kill wasps).

 

2)            It appears the longer-term monitoring of the study site was
not considered - for the wildlife or the humans. This was concerning
considering there has been no research into how long 1080 poison persists
in treated areas. In the ERMA documents it was recognised that it might
persist indefinitely at low concentrations. It has been found to persist
in many varied situations including dry places, cool water, water lacking
aquatic plants, some types of soil, in carcasses and concrete water pipes
(Eisler, 1995). The rate of breakdown of 1080 poison in New Zealand
forests and streams is unknown, but it is extremely slow at around 5
degrees Celsius. Thus ERMA’s Agency warned that “No studies have been
conducted using standard international guidelines to assess the route and
rate of degradation of 1080 in soil. The rate of such degradation under
New Zealand conditions is uncertain.” And regarding water:  “Overall, the
relevance of the aquatic plant/water studies to the degradation of 1080 in
water in NZ is not clear.” (Pollard, 2011)

 

3)            In the Animal Ethics Application you have sent me, it states
clearly that both the fish and the crayfish were returned to these
(publicly accessible) streams after being subjected to the 1080 poisoning
(those that survived after 4 days), and that it also clearly acknowledges
that these fish and crayfish are common sources of food for New
Zealanders.  MoH have acknowledged that no public health studies exist
into 1080 despite numerous scientists pointing out how crucial this is
(e.g. Scanlon, 2010)

 

Please note that on page 534 of Suren’s (2006) published article he states
that one of the fish cages were stolen. Clearly then, this study site was
accessible to the public and other residential areas were nearby and
downstream from the site. The crucial need for a Human Ethics Application
for this experiment therefore seemed obvious, especially when there are no
known epidemiological studies of the potential impact of Compound 1080 on
public health. This concern applies to individuals directly drinking the
contaminated water and/or eating of contaminated vegetation, fish
and/invertebrates involved in the study  -  or otherwise become part of
the food-chain that evolved from it (Eason et al., 2013). 

 

I await your response with interest.

 

References

Eason, C.T., Ross J. & Miller, A. (2013) Secondary Poisoning risks from
1080-poisoned carcasses and risk of trophic transfer – a review. NZ
Journal of Zoology Vol 40 (3) pp 217-225
[5]http://dx.doi.org/10.1080/03014223.2012....

Eisler, R. (1995) Sodium Monofluoroacetate (1080)Hazards to Fish, Wildlife
and Invertebreates: a Synoptic Review. Available at:
[6]https://www.pwrc.usgs.gov/eisler/CHR_30_...

Pollard, J. (2016) Aerial 1080 poisoning in New Zealand: Reasons for
concern. Scientific Reviews:                
[7]http://1080science.co.nz/aerial-1080-poi...

Scanlon P. (2010) Letter to Parliament, available at:
[8]https://www.parliament.nz/resource/mi-nz...

 

-----Original Message-----

 

Hi Ursula,

 

Please see attached letter.

 

Regards

 

Annabelle Watson

Senior Legal Counsel

 

+64-9-375-2087 | +64-21-035-2994 | 41 Market Place, Viaduct Harbour, 
Auckland | [1][9]www.niwa.co.nz

 

[2]NIWA

 

To ensure compliance with legal requirements and to maintain cyber 
security standards, NIWA's IT systems are subject to ongoing monitoring, 
activity logging and auditing. This monitoring and auditing service may
be  provided by third parties. Such third parties can access information 
transmitted to, processed by and stored on NIWA's IT systems.

 

-------------------------------------------------------------------

Please use this email address for all replies to this request:

[10][FOI #4865 email]

 

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:

[11]https://fyi.org.nz/help/officers

 

If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

 

-------------------------------------------------------------------

 

References

Visible links
1. http://www.niwa.co.nz/
2. http://www.niwa.co.nz/
3. mailto:[FOI #4865 email]
4. mailto:[email address]
5. http://dx.doi.org/10.1080/03014223.2012....
6. https://www.pwrc.usgs.gov/eisler/CHR_30_...
7. http://1080science.co.nz/aerial-1080-poi...
8. https://www.parliament.nz/resource/mi-nz...
9. http://www.niwa.co.nz/
10. mailto:[FOI #4865 email]
11. https://fyi.org.nz/help/officers

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