TL: GREENPEACE NEW ZEALAND SUBMISSION TO THE PESTICIDES BOARD ON THE REGISTRATION OF CHLORDANE AND PENTACHLOROPHENOL (GP) SO: Meriel Watts, Greenpeace New Zealand DT: 4-JUN-92 Keywords: toxics pesticides greenpeace new zealand australasia greenpeace chlorine groups gp reports / Below is a submission to the pesticides Board (Australia) on pentachlorophenol and chlordane. There is already massive contamination of NZ with PCP (cleaning up 1 site alone for the next 100 hundred years(!)is estimated to cost $28million) but they have just re-registered it, partly on the basis of an industry video fronted by David Bellamy. A recent spill of chlordane has killed ducks and contaminated humans, dogs and a waterway. And the reason we should do this to the NZ environment and people? So we can send pine timber to Australia, timber that is so prone to insect and fungal attack it should never be grown for that purpose. Greenpeace New Zealand requests an immediate ban on chlordane and an immediate re-instatement of the ban on pentachlorophenol. We request that both these chemicals be removed from the pesticides register, that no further importation of these chemicals be allowed, that existing stocks be immediately withdrawn from any further use and that stocks be placed in long- term, above-ground, monitored, retrievable storage until such time as environmentally acceptable methods of disposal or detoxification can be established. Both of these chemicals are hazardous to the health of New Zealanders and are persistent environmental contaminants that have already caused extensive problems in the New Zealand environment. Below we provide information backing up the need for this submission: Chlordane : Chlordane is persistent and bioaccumulative in the environment (marine and terrestrial) and in humans. (1) It has been found to contaminate shellfish and marine sediments in both the Waitemata and Manukau harbours. (2,3,4) A number of surveys, undertaken by both the United States Environmental Protection Agency (US EPA) and independent organisations, have demonstrated the accumulation of this fat-soluble chemical in the fatty tissues of humans. (5) "... chlordane ... is known to pass through the placenta (6) and to be excreted in breast milk. (7) Consequently, both the developing fetus and breast-fed infant are at a high risk of exposure. Chlordane residues also have been found in fetal blood and amniotic fluid, in some cases at levels several times higher than in maternal blood. (8)" (9) Chlordane is one of the organochlorines implicated in mass mortality of cetaceans. (10) It is a known animal carcinogen and the US EPA considers it a probable human carcinogen. (11) Chlordane is also a suspected teratogen and nervous system toxin. Exposure to chlordane has been linked to the development of blood system disorders, such as aplastic anaemia and leukaemia. (12) Chlordane is easily absorbed through the skin and acutely toxic effects involve a substantial impact on the central nervous system - acute symptoms including: headaches, blurred vision, disorientation, muscle twitching, lack of coordination, weakness, nausea and diarrhoea and, in extreme cases, convulsions, ventricular fibrillation and respiratory failure. (13) Epidemiological studies indicate that those who work with chlordane are at increased risk of health problems such as cerebrovascular disease and cancer of the lung, skin and bladder. (14,15) We refer you to pages 10 - 13 of the accompanying Greenpeace report, `Exporting Banned Pesticides: Fueling the Circle of Poison', for further information on the toxicity and environmental fate of chlordane. In New Zealand chlordane continues to leak into the environment as a result of inadequate disposal procedures. One such recent example is the contamination of a West Auckland stream and the death of a large number of ducks, as a result of the release of TBT and chlordane from timber treatment tanks. (16) Chlordane has also been identified in the 1990 Ministry for the Environment report on contaminated timber treatment sites as one of the offending chemicals. (17) Chlordane has been severely restricted in the United States, because of it's toxicity to humans, birds and the aquatic environment. (18) It has been totally banned in the following countries: All EEC countries, Switzerland, Finland, Ecuador, Kenya, Bangladesh, Papua New Guinea, Tonga, Fiji, Laos, Vietnam, Spain, the Netherlands, Liechtenstein, Singapore, Sweden, Turkey and Yugoslavia. Furthermore, it is ironic that New Zealand should register chlordane solely for the purpose of treating timber for export to Australia when it is is not registered for this purpose in that country. Pentachlorophenol : Pentachlorophenol (PCP) is similarly persistent and bioaccumulative in the environment and humans. In New Zealand it has been found, along with the chlordane, in both the Waitemata and Manukau harbours. (3,4,19) A report from Brett Fisher of the USA's Northwest Coalition for Alternatives to Pesticides (NCAP) states: "... the National Centre for Health Statistics found penta in 79% of urine samples from the general population. (20) In a study of 179 Arkansas children, 100% of the urine samples tested positive for penta with an average level of 14 ppb. (21) Penta is also present in human fat tissues and human breast milk. (22,23)" (24) The US EPA has determined that PCP poses oncogenic, fetotoxic and teratogenic risks. Chronic exposure effects include: anaemia, chloracne, dermatitis, hepatic damage, leukopenia, metabolic rate elevation, peripheral neuropathy, pulmonary damage, renal damage and weight loss. Acute exposure effects include: abdominal pain, acidosis, anorexia, cardiac dilation, damage to the CNS, coma, convulsions, cyanosis, dehydration, chloracne, dermatitis, eye irritation, liver and kidney damage, heat sensitivity, hyperthermia, mental deterioration, muscle weakness, nausea, respiratory problems, sweating, thirst and vomiting. (25) PCP is contaminated with hexachlorodibenzo-p-dioxin, one of the group of chlorinated dibenzo-p-dioxins. US EPA information, recently made public, indicates that dioxin is even more damaging than previously thought and that the EPA is considering additional regulation of it. The report confirms that it is a potent carcinogen and that even at extremely low levels it has subtle immunological, developmental and neurological effects that may actually pose the greater public health threat. (26) It has been totally banned in the following countries: Denmark, India, Japan, Luxembourg, Switzerland, Liechtenstein and Sweden. PCP is, of course, the major contaminant of the timber treatment sites described in the 1990 Ministry for the Environment report. (17) Up to 800 such sites are thought to be contaminated with PCP. In a recently conducted study on just one site, that at the Waipa sawmill, the expected costs for the first three years for decontamination are estimated to be in the vicinity of $3 million, with a projected one-quarter of a million dollars in ensuing years. The cost to New Zealand of cleaning up this, and the other 799 sites, will be astronomical. That the Pesticides Board should sanction the possibility of further contamination of the environment through the re-introduction of PCP is outrageous. Even with theoretically closed systems there is always the possibility of leakage and accidents. Any leakage at all, no matter how "minimal", cannot be countenanced given the already heavy environmental loading of PCP. There will eventually also be the problem of disposal of wastes from the PCP treatment system - no adequate method exists for this at present. Greenpeace reiterates its request for a complete ban of both chlordane and pentachlorophenol to take effect immediately. We can provide any of the referenced material or speak to this submission if requested. Meriel Watts Gordon Jackman Pesticides campaigner Pulp and paper campaigner Greenpeace New Zealand Greenpeace New Zealand 4 June, 1992. REFERENCES: (1) Kawano, M. et al. Biological Accumulation of Chlordane Compounds in Marine Organisms from the northern North Pacific and Bering Sea. Marine Pollution Bulletin, Vol. 17, No. 11. 1986. (2) R J Wilcock, et al. Chlordane in Manukau Harbour. 1989. Proceedings of the Symposium on the Wood Preservation Industry and the Environment (attached). (3) Kingett Mitchell & Associates. Ports of Auckland Environmental Studies. 9: Environmental Assessment of the Disposal of Dredged Material at the Hauraki Gulf Disposal Site. Part 2. September, 1990. (4) Auckland Regional Water Board. Tamaki Estuary Water Quality Survey, 1987-88. Technical Publication No. 54. November, 1988. (5) Statement of Ian C. T. Nisbet, Ph. D. to the Subcommittee on Health and the Environment, Committee on Energy and Commerce, U.S. House of Representatives on H.R. 2622, June 24, 1987. (6) Curley, A. Copeland. M.F. and Kimbrough R., Chlorinated Hydrocarbon Insecticides in Organs of Stillborn and Blood of Newborn Babies, Archives of Environmental Health, 19:628-632, 1969; Polishuk, Z.W. et al, Organochlorine Compounds in Mother and Fetus During Labor, Environmental Research, 13:278-284, 1977; Polishuk, Z.W. et al, Effect of Pregnancy on the Storage of Organochlorine Pesticides, Archives of Environmental Health, 20:215, 1970. (7) Stacey, C.I., Tatum, T., House Treatment with Organochlorine Pesticides and Their Levels in Human Milk, Perth, Western Australia, Bulletin of Environmental Contamination and Toxicology, 35:202-208, 1985; Al-Omar, M.A. A Follow-Up Study of Maternal Milk Contamination with Organochlorine Insecticide Residues, Environmental Pollution (Series A), 42:79-91, 1986. (8) Polishuk, Z.W. et al, Organochlorine Compounds in Mother and Fetus During Labor, Environmental Research, 13:278-284, 1977. (9) Marquardt, S. Exporting Banned Pesticides: Fueling the Circle of Poison. A Case Study of Velsicol Chemical Corporation's Export of Chlordane and Heptachlor, A Greenpeace Report, August, 1989. (10) Simmonds, M. School of Biological Sciences, Queen Mary and Westfield College. Cetacean Mass Mortalities and their Potential Relationship with Pollution. Presented at the Symposium on Whales - Biology - Threats - Conservation, Brussels, 1991. (11) US EPA. Guidance for the Reregistration of Pesticide Products Containing Chlordane as the Major Ingredient. December, 1986; and US EPA. Guidance for the Reregistration of Pesticide Products Containing Heptachlor as the Major Ingredient. December, 1986. (12) Associated Press. Checks for Pesticide Increase in Arkansas at Processing Plants. New York Times, May 10, 1989. (13) US EPA. Recognition and Management of Pesticide Poisonings, 1989, page 19. (14) Wang, H.H. and MacMahon, B., Mortality of Workers Exposed in the Manufacture of Chlordane and Heptachlor, Journal of Occupational Medicine 21:745-748, 1979; Public Data Access, Mortality and Toxics Along the Mississippi River: A Greenpeace Report, August, 1988. (15) MacMahon, B. et al, A Second Follow-Up of Mortality in a Cohort of Pesticide Applicators, Journal of Occupational Medicine, 30:429, May 1988. (16) NZ Herald, Spill compound highly toxic, page 1, May 27, 1992. (17) Shaw, C. P., Cawthron Institute. Timber Preservation Chemicals in the New Zealand Environment. 1990. Report for Ministry for the Environment. (18) US EPA Office of Pesticide Programs. Report of the Restricted Use Product File. 3/11/91. (19) Hamilton, E. I., Organochlorine Contaminants in Surficial Sediments of Manukau Harbour, New Zealand. Marine Pollution Bulletin, Volume 19, (20) Murphy, R.S. et al. 1983. Selected pesticide residues or metabolites in blood and urine specimens from a general population survey. Env. Health Perspect. 48:81-86. (21) Hill, R.H. et al. 1989. Residues of chlorinated phenols and phenoxy acid herbicides in the urine of Arkansas children. Arch. Env. Contam. Toxicol. 18:469-474. (22) Ryan, J.E. et al. 1985. Chlorinated dibenzo-p-dioxins and chlorinated dibenzofurans in Canadian human adipose tissue. Chemosphere 14:697-706. (23) Noren, K. 1988. Changes in levels of organochlorine pesticides, polychlorinated biphenyls, dibenzo-p-dioxins and dibenzofurans in human milk from Stockholm, 1972-1985. Chemosphere 17(1):39-49. (24) Fisher, B. Pentachlorophenol: Toxicology and Environmental Fate. Journal of Pesticide Reform, Vol. 11, No. 1 Spring 1991. (25) Hannenbeck, W.H. and Cunningham-Burns, K.M. School of Public Health, University of Illinois, Chicago. Pesticides and Human Health, Springer-Verlag. (26) Schmidt, K.F. US News and World Report Inc. April 6, 1992. =end=