There are gaps in how we monitor chemicals in the environment and how we interpret their impact on living things, finds a report from the Parliamentary Commissioner for the Environment.
The report looks at neonicotinoid insecticides, antibiotics, and the trace metal zinc as case studies for how our regulations can overlook harmful environmental effects, and it also discusses other chemicals of interest like PFAS.
The SMC asked experts to comment on the report.
Dr Nick Kim, Senior Lecturer in Applied Environmental Chemistry, Massey University, comments:
“Globally, human activities are placing huge strains on the ecosystems which underpin them. There are few parts of the planet that are not now touched in one way or another by the imprint of chemicals that we use or release. For scientists and regulators, the fact that there are many tens of thousands of chemicals has posed a peculiar problem: in the face of finite resources, how can we ever hope to manage all the risks?
“The chemicals themselves vary widely – from naturally occurring heavy metals to synthetic pesticides, and from relatively non-toxic to highly toxic.
“Should we only focus on toxicity? That would be a mistake. Risks don’t only relate to toxicity – they also depend on context: where the chemical ends up after being released into the environment, how much of it there is, and what happens next. We know that some otherwise safe chemicals – when released en mass – can compromise or destroy entire ecosystems. As cases in point: carbon dioxide in the atmosphere; nitrogen and phosphorus in our streams, rivers and lakes. As a further problem: human activity releases so many substances – from personal to industrial scale, discrete chemicals to microplastics – that scientists can only ever hope to scratch the surface of characterising the many potential type of harms that may exist, let alone develop risk-based guidelines. And monitoring for everything is (literally) impossible. The best we can do, even with a sizeable budget, is monitor for a tiny target subset of the chemicals that are in use, in some places, some of the time. Despite our compulsion to know, in the area of chemical use there are many cases where everything is educated guesswork.
“That raises the very real problem that in focusing on managing the subset of things that we do know a lot about, we may miss the significance of larger events that are going on right under our noses.
“For the first time in New Zealand’s history, and possibly as a world-first, this report provides a rational way forward. To properly manage the environmental risks posed by chemical use, we need to think more widely. In parallel with toxicity and the potential for a chemical to cause ecological harm we need to incorporate environmental context along two additional axes: whether the chemical present in the environment, and (if so) at what scale.
“This report focuses on finding a better way to manage the potential environmental impacts of chemical use, and I find myself in full support of its recommendations. For me, Recommendation 1 is where it all comes together: “Require all agencies dealing with chemicals to develop a common framework based on scale, potential harm and environmental presence of chemicals to prioritise their efforts to consider, and manage, the environmental impacts of chemical use.”
“The perspective shift represented by development of a common New Zealand framework of this type would go a long way to dealing with gaps in our current range of approaches. I hope this report serves to catalyse that shift.”
Conflict of interest statement: I was one of the technical reviewers for the draft of this report.
Professor Rhiannon Braund, New Zealand Pharmacovigilance Centre, University of Otago; and President of the Pharmaceutical Society of New Zealand, comments:
“The choice of pharmaceuticals, and particularly antibiotics as a case study in the PCE report is welcome. Especially given the increased recognition of “One Health”, which brings together antibiotic use and resistance in humans, animals and the environment.
“Medicines are the most common intervention in health care and can enter the environment via excretion (in wastewater) or via disposal of unused or expired medicines. Pharmacists have been concerned about the disposal of medications in New Zealand/Aotearoa and particularly the different approaches used by different District Health Boards. This report highlights some of the concerns already noted and will be pivotal in developing and implementing a science based approach to environmental risk and consistency across New Zealand/Aotearoa.
“Of particular importance to New Zealand/Aotearoa is the implications of human health, antibiotic use in livestock, impact on waterways and the combination of all of these to antibiotic resistance.
“This body of work highlights the importance of a national medicines strategy that incorporates patient access, excess and disposal and stronger anti-microbial stewardship that incorporate the whole of system. These aspects cannot continue to be siloed.”
No conflict of interest.
Dr Jennifer Gadd, Aquatic Chemist, NIWA, comments:
“I welcome this report. New Zealand lacks a system for recording and reporting on chemical use, and without this, we don’t have the information needed to properly manage chemicals in a way that reduces risks to the environment and to people.
“Most of the methods that we use to investigate the amounts of chemical contaminants in the environment, whether in water, soil, sediment or biological organisms, rely on us first deciding what to target. When we do not know what chemicals are in use in different locations, we can waste time and resources targeting chemicals that were never there in the first place. For some substances, although this information is collected, it is held by industry bodies, and is not accessible to researchers or to the public.
“We can also miss the chemicals that are there, through lack of knowledge. In some cases, this could lead to the wrong conclusions – for example, that pesticides are rarely present in surface waters.”
Conflict of interest statement: I participated in a workshop related to this project and was a peer reviewer of several sections of this report. I am also a lead author of draft water quality guidelines for copper and zinc, under contracts from Ministry for the Environment, Environment Canterbury and Christchurch City Council.
Associate Professor Melanie Kah, School of Environment, University of Auckland, comments:
“While nutrients and bacterial contamination have received considerable policy focus over the last decades in Aotearoa NZ, we have not done a great job at regulating and monitoring thousands of chemicals for agricultural, industrial and household use. These include pesticides, pharmaceuticals and many other chemicals that are incorporated in everyday products. These chemicals often find their way to the environment, and there is an urgent need to limit their impact on our surface water, soil, groundwater and coastal environments.
“I have been looking forward to the publication of this report by the PCE. Four case studies relevant for Aotearoa NZ are analyzed in detail to highlight enormous gaps in our knowledge: from how much a chemical is used to how much is in our environment. I think that the concrete recommendations made by the Commissioner are excellent and will guide future activities at the interface of science and policy. The report provides a very timely and critical assessment of the current situation while highlighting many opportunities for improvements. As a researcher working on this topic, I hope that this report will help unlock some of the resources we need to tackle the challenges we are facing with chemicals.”
No conflicts of interest.
Magali Moreau, Environmental Chemistry Team Leader, GNS Science, comments:
“I support the recommendations made by the Parliamentary Commissioner in regulating the environmental fate of chemicals.
“This report identifies science opportunities that would assist in the challenge of addressing a growing list of chemical contaminants – such as baseline surveys or a consistent reporting framework for chemical contaminants. In particular the recommendations on streamlining efforts around empowering EPA to collate, collect, and report on the quantity and use of chemicals would be valuable.
“Right now, New Zealand relies on international literature for guidance on toxicity for a range of chemical contaminants in our environment. Better local data and reporting will support our understanding and management of emerging chemical contaminants, particularly where international literature is not available, and compounds could then be prioritised for research.”
No conflict of interest.
Professor Sally Gaw, Director of Environmental Science, School of Physical and Chemical Sciences, University of Canterbury, comments:
“The PCE report highlights that we do not know enough about the types and quantities of chemicals entering Aotearoa|New Zealand. This significant data gap limits our ability to be proactive in protecting taonga species and human health. Implementing the Parliamentary Commissioner’s recommendations of strengthening regulatory processes to include a common framework for assessing chemicals and an inventory of chemicals entering Aotearoa|New Zealand along with the development of environmental exposure limits would be a significant step forward in the management of chemicals.
“Our way of life is dependent on a vast array of chemicals including those present in manufactured products. Regulatory changes are urgently needed to protect our communities and ecosystems from adverse impacts associated with chemical use and to avoid leaving historic legacies of environmental contamination for future generations.
Conflict of interest statement: “I was a reviewer of the report.”