Scoop today publishes for the first time the full text of the confidential Dioxin report prepared for the Ministry For the Environment leaked last week to the New Zealand Herald newspaper.
Attached below the report itself are two Cabinet Papers, one in draft form, from the Office of Marion Hobbs Minister For the Environment concerning the Government's planning to respond to the report.
The Ministry For the Environment responded to the publication of extracts from the report last week with the following press release.
In the release they say they plan to release an updated version of the report in mid-March.
FULL TEXT OF MINISTRY FOR THE ENVIRONMENT REPORT.... SEPTEMBER VERSION
Evaluation of the toxicity of dioxins and dioxin- like PCBs: A health risk appraisal for the New Zealand population
Allan H Smith, MB, ChB, PhD Peggy Lopipero, MPH
A report to the New Zealand Ministry for the Environment
About the authors: See inside back cover
Evaluation of the toxicity of dioxins and dioxin- like PCBs: A health risk appraisal for the New Zealand population
Published by Ministry for the Environment PO Box 10-362 Wellington
ISBN 0-478-09091-9 ME number 351
Printed on elemental chlorine free 50% recycled paper
This report is submitted to the Ministry for the Environment as an independent appraisal of the health risks posed to the New Zealand population by polychlorinated dibenzo-p-dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs) and the dioxin-like polychlorinated biphenyls (PCBs). Collectively, these three groups of closely related chemicals are generically referred to as ‘dioxin-like compounds’.
The Ministry for the Environment has collected information on the sources and environmental levels of dioxin-like compounds in New Zealand, and on population exposures to these chemicals, including data on dietary intakes and concentrations in serum. These, and other data collected by the Ministry of Health on PCDD and PCDF body burdens of New Zealanders, have been used in this health risk appraisal. This report also presents a concise review of our current understanding of the health risks associated with exposure to dioxin-like compounds, and reviews various health guidelines that have been established by other jurisdictions.
From consideration of the New Zealand exposure data, and a review of the published scientific literature on dioxin-like compounds, the following observations and conclusions can be made.
ES1 New Zealand exposure data
For the general population, over 90% of exposure to dioxin-like compounds is through the diet, with foods such as meats, dairy produce and fish usually the predominant source. Unborn children are exposed to dioxin-like compounds in utero, and nursing infants are exposed to these contaminants present in breast milk.
Based on a dietary study for dioxin-like compounds (Buckland et al., 1998c), the level of dietary intake of these chemicals for the New Zealand population would appear to be lower than exposures reported for any other country where a comparable study has been undertaken. For adult males with a median energy diet, the intake is estimated as 0.37 pg TEQ/kg bw/day, and for adolescent males with a high energy (90th centile) diet, the intake is estimated as 0.84 pg TEQ/kg bw/day, where the toxic equivalents (TEQ) are based on the toxic equivalent factors (TEFs) developed in 1997 for dioxin-like compounds by the World Health Organization (WHO) (Van den Berg et al., 1998). Similarly, the results of the study of dioxin- like compounds present in serum (Buckland et al., 2000a) would indicate that levels for the general New Zealand population are at the low end of the scale of levels reported internationally. The mean serum concentration across the population aged 15 years and older was determined as 19.7 ng TEQ kg-1 on a lipid- adjusted basis (range: 9.71–38.5 ng TEQ kg-1). From these serum data, body burdens and average lifetime daily exposures (ALDE) were calculated. The mean ALDE for all data was estimated as 1.4 pg TEQ/kg bw/day (minimum of 0.35 for the population aged 15–24 years; maximum of 3.4 for the population aged 65+ years). The higher ALDE estimate compared to the estimated dietary intake is because the ALDE includes historical exposures, which are likely to have been higher than current exposures, as well as intakes from non-dietary exposure pathways.
A study undertaken in the late 1980s measured concentrations of PCDDs and PCDFs in New Zealand mother’s milk in the range 6.1–40 ng TEQ kg-1 of milk fat. The preliminary indications from a second study currently underway is that over a 10-year period from 1987/88 to 1997/98, concentrations of PCDDs and PCDFs in breast milk have fallen by about two-thirds.
Whilst noting the comparatively low levels of PCDD and PCDF emissions relative to most other industrialized countries, as documented in the New Zealand dioxin inventory (Buckland et al., 2000b), there is no clear evidence to show that the emissions of PCDDs and PCDFs from known sources correlate proportionally with general population exposures. Although the inventory estimates the relative contribution of the various sources to total emissions, the uncertainties in these estimates mean it cannot be assumed that these sources make the same relative contributions to human intakes as calculated. Although unlikely, it is even possible that the major sources of PCDDs and PCDFs in foods are not the sources with the largest fractions of estimated total emissions in New Zealand. However, it is clear that to prevent or minimise general population intakes of dioxin-like compounds, protection of the quality of New Zealand’s agricultural lands and aquatic environments used for food production is paramount.
Higher-level exposures, such as may occur in the work place, are normally restricted to smaller groups of people. In New Zealand, historical occupational exposures to PCDDs and PCDFs would probably have been restricted to individuals involved in the handling and use of the pesticides pentachlorophenol and 2,4,5- trichlorophenoxyacetic acid. These chemicals are no longer used in New Zealand.
More detailed information on the New Zealand exposure data is provided in Section 3 of this report.
ES2 Toxic effects of dioxin-like compounds and health risk appraisal considerations
The most widely studied of all the dioxin-like compounds is 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD). It has been shown to effect a wide range of organ systems in many animal species, it can induce a wide range of adverse biological responses, and it is extraordinarily potent. Recent animal studies suggest that the most sensitive endpoints of TCDD exposure relate to immunotoxicity, and reproductive and neurobehavioral effects.
Our current knowledge of the mechanisms of TCDD toxicity clearly suggests that binding of TCDD to the aryl hydrocarbon receptor (Ah receptor) is the first step in a series of events that manifest themselves in biological responses, including changes at the biochemical, cellular and tissue level. Binding to the Ah receptor occurs in humans and also in monkeys and rats – the two animals used most in experimental studies. This being the case, it is reasonable to use the results of the animal studies to predict health effects that may not yet have been demonstrated in human studies.
2,3,7,8-TCDD is an extremely potent animal carcinogen. It has been shown to cause both benign and malignant tumors at multiple sites in several animal species. Increases in lung cancer and all-cancers combined have been observed in highly exposed cohorts of workers in industrial settings. From the occupational studies, and an understanding of biological plausibility as shown by animal studies, the International Agency for Research on Cancer has concluded that TCDD is carcinogenic to humans. Although the mechanisms of TCDD carcinogenicity are not fully known, the available evidence suggests that they do not involve direct damage to cellular DNA. Whatever the precise mechanism of TCDD carcinogenicity, no threshold for effects has been established. It is therefore plausible to include low-dose linearity in the range of possibilities, and for regulatory considerations we believe that the linear model should be the first choice unless it can be shown that it does not adequately fit the data.
The available epidemiological data indicate that dioxin-like compounds produce a variety of biochemical responses in humans, some of which occur at relatively low exposure levels. Enzyme induction, changes in hormonal levels and reduced glucose tolerance are examples of subtle changes that may occur at comparatively low exposures. However, these subtle effects are of unknown clinical significance, and may or may not indicate a toxic response or potential for a toxic response.
Despite the lack of data for toxic effects from dioxin-like compounds other than 2,3,7,8-TCDD, there is reason to infer that biochemical, cellular and tissue-level effects that are elicited by exposure to TCDD are also induced by other chemicals that have a similar structure and that bind to the Ah receptor. There is widespread agreement within the scientific community that the use of TEFs to estimate the relative toxicities of dioxin-like compounds has an empirical basis, is theoretically sound, and is a useful procedure. Furthermore, agencies such as the WHO and the United States Environmental Protection Agency (US EPA) have noted that the derivation and use of TEQ levels is a pragmatic and feasible approach for assessing human health risks from exposure to dioxin-like compounds. We concur with this approach, and endorse the use of the most recent (1997) WHO TEFs (Van den Berg et al., 1998), applying the concept of additivity for the PCDDs, PCDF and dioxin-like PCBs to provide total TEQ estimates.
There are a number of key studies that document a variety of health effects of TCDD toxicity in laboratory animals, and these have been instrumental in establishing human health guidelines for exposure to dioxin-like compounds. Some of these studies are summarized in Table ES.1.
Table ES.1 Key studies used in the derivation
of human health criteria Species Biological effect Reference Sprague- Dawley rats Cancer Kociba et al., 1978 Long Evans Hooded rats Decreased sperm count in offspring; increased genital malformations in offspring Gray et al., 1997a Gray et al., 1997b Rats Immune suppression in offspring Gehrs et al., 1997; Gehrs and Smialowicz, 1998 Rhesus monkeys Neurobehavioral effects in offspring Schantz and Bowman, 1989; Schantz et al., 1992 Rhesus monkeys Endometriosis Rier et al., 1993 From these studies, the WHO, the United Kingdom, Germany, Japan and the Netherlands have all set a tolerable daily intake (TDI), and the United States Agency for Toxic Substances and Disease Registry (ATSDR) has set a minimal risk level (MRL) on the basis of the lowest observable adverse effect level (LOAEL) and the application of safety factors. In most cases, based on the non-cancer effects data, the TDI or MRL value set by these jurisdictions is, or falls within the range, 1–4 pg TEQ/kg bw/day. However, we note that the margins of safety used in deriving these values are very small, and we can have no assurance that some people with the highest exposures may not have deleterious effects even when the overall New Zealand population average intake, based on ALDE estimates, is approximately 1.4 pg TEQ/kg bw/day. The cancer study of Kociba et al. (1978) using Sprague-Dawley rats has been used to assess the carcinogenic risk from exposure to 2,3,7,8-TCDD. From the findings of this study, the US EPA has determined a risk-specific dose (RsD) of 0.006 pg TCDD/kg bw/day for a one in a million lifetime cancer risk. This was derived from an upper bound unit risk estimate of 1.6 x 10-4 (pg/kg bw/day)-1 (US EPA, 1985). Further analysis of the Kociba data has derived an oral intake RsD of 0.01 pg TEQ/kg bw/day, corresponding to a unit risk estimate of 1 x 10- 4 (pg/kg bw/day)-1 (US EPA, 1994b). Although the evidence has limitations, more recent epidemiological studies in humans have led to TCDD being classified as a human carcinogen, and it is now possible to derive the cancer potency directly from human studies of exposed industrial workers. The cancer potency turns out to be much higher than initially estimated from the rat studies. However, recent reassessment of the Kociba rat study including incorporating the half-life differences between rats and humans has shown that the estimates for human cancer risks derived from this animal study come quite close to those that can be estimated directly from the four pertinent studies of TCDD-exposed workers. This information adds to our confidence in recommending the use of the cancer potency estimates derived directly from the human studies to appraise the risks to the New Zealand population from exposure to dioxin-like compounds.
In Section 5, a critique is provided of the following risk assessment methodologies that are applicable to the current study: safety factor approach low-dose extrapolation benchmark dose or point of departure public health risk assessment.
The public health risk assessment approach, which takes into account current background exposures as well as allowing for consideration of single point sources of exposure adding to background, is considered to be the most appropriate means by which ongoing sources of dioxin-like compounds to the environment can be managed and exposures to the population reduced in the medium to long term.
Further discussion of the toxic effects of dioxin-like compounds and health risk appraisal considerations is provided in Sections 4 and 5 of this report.
ES3 Appraisal of the New Zealand population
exposure data The New Zealand serum data can be used to estimate exposure to dioxin-like compounds by relating body burden to an equivalent human daily intake, or ALDE estimate. Such intake estimates will include dietary intakes and other exposure pathways, such as inhalation. Because of the representative nature of the New Zealand serum study, both in terms of the large number of samples analyzed, and the incorporation of demographic, geographic, age, gender and ethnicity variables into the study design, it is a reasonable assumption that the ALDE estimates derived from the serum data are an accurate reflection of intakes across the population. Furthermore, these estimates of exposure are likely to be more reliable than the intake estimates derived from the comparatively smaller dietary study that were based on model diets.
The New Zealand intakes can be compared against the TDI target value established by the WHO and the MRL set by the ATSDR of 1 pg TEQ/kg bw/day. The average current dietary intake may be somewhat lower than this value (perhaps two times lower). However, the more reliable estimate of intake based on serum concentrations suggests that during approximately the last 25 years the average intake was probably close to 1.4 pg TEQ/kg bw/day. This being the case, about half the population would have exceeded this intake. It should also be noted again that these health criteria set by WHO and ATSDR involve very small margins of safety. Therefore, there would appear to be only a small margin of safety, if any, between New Zealand intakes and some non-cancer effects in animal studies; in particular, effects on the offspring of exposed mothers.
Cancer risk has been assessed by low-dose extrapolation, using both animal and human data. The cancer estimates from the human studies are similar to those from animal studies when the long human half-life is taken into account, and emphasis should therefore be placed on cancer risks derived from the human data. Thus, based on a time-weighted average daily dietary intake for a male New Zealander of 0.50 pg TEQ/kg bw/day, the lifetime added cancer risk is approximately one to three additional cancers per 1000 individuals. Similarly, based on the ALDE estimate of 1.4 pg TEQ/kg bw/day, the lifetime added cancer risk is approximately three to seven additional cancers per 1000 individuals. Of course, if there were a threshold above current exposures the actual risks would be zero. Alternatively, they could lie in a range from zero to the estimates actually given, but are unlikely to be higher than this.
When assessing cancer risk using a benchmark dose derived from human data, the margin of safety between the average intake of dioxin-like compounds for the New Zealand population and the concentration estimated to result in a 1 in 100 cancer risk is found to be very small (less than an order of magnitude).
The exposure of breast-fed infants also warrants mention since after about six months of breast feeding, the body concentrations of dioxin-like compounds in infants exceed those in the mother as a consequence of the presence of these contaminants in breast milk. Whether adverse effects will result from this exposure is not known, although it is clearly known that breast feeding is in general beneficial. The concern about dioxin-like compounds in breast milk adds to the reasons for taking a prudent and precautionary approach concerning population exposures to these chemicals.
On the basis of these findings, the current background exposures to dioxin-like compounds for the New Zealand population has, in our opinion, an insufficient margin of safety, and steps should be taken to further reduce human exposure.
More detailed information on the health risks to New Zealanders from exposure to dioxin-like compounds is provided in Section 7 of this report.
In the light of ever-increasing scientific information concerning the toxicity of dioxin- like compounds, and data on body burdens present in the New Zealand population, we make the following recommendations:
1. A precautionary approach should be adopted concerning dioxin-like compounds in New Zealand.
2. A goal of ongoing reduction in population body burdens of dioxin-like compounds should be stated.
3. Identifying a tolerable daily intake is not recommended.
4. A health exposure criterion (HEC) should be established to regulate point sources of exposure.
5. Application of the HEC should involve consideration of the plausible maximally exposed person from the point source activity.
6. The New Zealand population burden of dioxin- like compounds should be monitored periodically, perhaps every 5–10 years.
7. Policies and the HEC should be reviewed after consideration of trends revealed by future population monitoring.
Further information on each of these recommendations is provided in Section 8 of this report.
This report represents work undertaken by Dr Allan Smith and Ms Peggy Lopipero for the New Zealand Ministry for the Environment. The work has been carried out as a component of the Ministry’s Organochlorines Program. This publication, in particular the Executive Summary along with Sections 4, 5, 7 and 8, represents the final report for Dr Allan Smith and Ms Peggy Lopipero to the Ministry for the Environment.
Sections 1, 2, 3 and 6 of the report were prepared by Dr Simon Buckland of the Ministry for the Environment for incorporation into the report. These sections provide supporting information on dioxin-like compounds relevant to the current risk appraisal.
Every effort has been made to ensure that the information in this report is accurate. The Ministry for the Environment and the authors of this report do not accept any responsibility or liability whatsoever for any error of fact, omission, interpretation or opinion which may be present in this report, however it may have occurred.
The report has been peer reviewed by scientists from the Ministry for the Environment, Ministry of Health and the Institute of Environmental Science and Research. The publication of this report by the Ministry for the Environment does not constitute any endorsement of the conclusions made in the report, and, furthermore, there is no commitment whatsoever to adopt any policy recommendations that the report contains.
DRAFT and CONFIDENTIAL. NOT FOR RELEASE OR DISTRIBUTION
CABINET PAPER NO. ONE...
CABINET FINANCE, INFRASTRUCTURE AND ENVIRONMENT COMMITTEE
Persistent organochlorines and an appraisal of the health risk to New Zealanders
This paper reports on the work undertaken by the Ministry for the Environment to assess the risks to New Zealanders and our environment from persistent organochlorine chemicals, and recommends that Cabinet agree to the release of the report ‘Evaluation of the toxicity of dioxins and dioxin-like PCBs: A health risk appraisal for the New Zealand population’.
Persistent organochlorine chemicals, which include the dioxins, polychlorinated biphenyls (PCBs), and pesticides such as DDT and dieldrin, are a group of environmental contaminants that are toxic, do not readily breakdown and which bioaccumulate in wildlife and people.
In 1995, the Government allocated $3.5 million to the Ministry for the Environment to undertake a national Organochlorines Programme, which would: Assess the risks persistent organochlorines pose in New Zealand; Develop risk-based environmental acceptance criteria for discharges to air, soil and water and for the clean-up of contaminated sites.
A Consultative Group for the Organochlorines Programme was established with representatives from industry, territorial authorities, public interest and environmental groups. These members have participated in the design and ongoing research of the programme. The findings of the research undertaken have been publicly released and disseminated over the past two years.
The Organochlorines Programme has undertaken national surveys to identify the sources of dioxins in New Zealand, measure the levels of organochlorines in our atmosphere, terrestrial and aquatic ecosystems, and the levels in our foods and the bodies of New Zealanders.
The dioxin inventory shows that there is a broad range of dioxin sources in New Zealand. The burning of waste material, wood and coal, and metallurgical processes are identified as the major sources of emissions to air. Solid residues (e.g. ash) from these processes are an important source of dioxins discharged to land.
Industry is estimated to account for only approximately 60% of total dioxin emissions, with domestic sources (38%) and natural sources (e.g. scrub and bush fires) (2%) accounting for the remainder. Compared to inventories from the northern hemisphere countries, New Zealand’s emissions are low, consistent with our comparatively limited industrial base.
The environmental survey found that, overall, the background levels of dioxins and PCBs in New Zealand are generally low. An assessment of the New Zealand data indicates that there is minimal risk to wildlife from background exposures to persistent organochlorines.
Very low levels of dioxins and PCBs were measured in retail foods, indicating that the current level of exposure for the population is low. In contrast, higher levels of exposure have occurred in the past, as indicated by the levels of dioxins and PCBs present in people’s bodies. New Zealand dioxin serum concentrations are, on average, half those measured in populations from Europe and North America.
The average lifetime exposure to dioxins and PCBs for the New Zealand population is estimated to be at, or marginally exceed, the World Health Organization and the US Agency for Toxic Substance and Disease Registry tolerable daily intake. Cancer risk estimates are as high as seven additional cancers per thousand New Zealanders.
Some members of the population may experience high exposure at some stage in their lifetime.
A recent study undertaken by the Ministry of Health indicates that nursing infants’ intake of dioxin appears to have reduced to about a third of that which was estimated a decade ago, but that intakes may still exceed by approximately 50 fold [check number] the World Health Organization’s Tolerable Daily Intake.
Although dioxin levels are believed to have fallen in New Zealand over the last decade, the margin of safety to protect New Zealanders health is judged to be small. This finding is detailed in the report Evaluation of the toxicity of dioxins and dioxin-like PCBs: A health risk appraisal for the New Zealand population. Cabinet agreement is sought for the release of this report.
Persistent organochlorines are a group of chemicals that break down only very slowly in the environment. Once released, they may remain in soil and sediment for tens to hundreds of years. They are highly toxic substances that accumulate in the fat and tissue of wildlife and people, and are known to cause serious health effects in a variety of animal species, including cancer, birth defects, reproductive and developmental problems. It is generally considered that these same effects may occur in humans at sufficient levels of exposure.
Persistent organochlorines are among the group of chemicals known as persistent organic pollutants (POPs), and which are the focus of international concern. They include: Dioxins. These are unintentional products of processes that use or burn chlorine. The combustion of wastes, chlorine bleaching of pulp and paper, and certain types of industrial processes can all release dioxins. They may also be formed from natural sources such as forest fires; PCBs. Industrial chemicals that were widely used, particularly within the electricity sector as insulating fluids. They were also used as plasticisers and flame retardants, and added to printing inks and paint. Some PCBs are referred to as ‘dioxin-like PCBs’, because their toxic effects are similar to those of the dioxins.
Chlorinated pesticides such as aldrin, dieldrin, chlordane, DDT, hexachlorobenzene, heptachlor, lindane, and pentachlorophenol (PCP).
Over the last 30 years, there has been a growing international awareness of environmental and health problems associated with persistent organochlorines. Examples of known sources of organochlorines in New Zealand that have raised public concern, and for which environmental interventions have occurred or are justified, include: Dioxin emissions from industrial activity, primarily within the pulp and paper sector in the production of bleached pulp, and in the disposal of medical, pathological and quarantine wastes through incineration; The manufacture of the herbicide 2,4,5-T by a New Plymouth based company, which resulted in localised offsite dioxin contamination.
An estimated 286 sawmill and timber treatment sites are contaminated to a variable extent by PCP (and associated dioxin). These include the Waipa sawmill near Rotorua and the ex-Forest Service sawmill near Hanmer.
Contamination of aquatic sediments by dioxin associated with past use of PCP, and past pulp and paper manufacture, including contamination of Lakes Rotorua and Maraetai, and the Tarawera River; Surplus dieldrin stocks and wastes, which were buried on ex-Lands and Survey block land. Three dieldrin contaminated sites in Southland are shortly to be purchased by the Crown; A pesticide manufacturing site at Mapua, is contaminated by dieldrin and DDT, with contamination migrating into the surrounding estuary; Some New Zealanders have, or believe they have had, higher exposures to dioxins than the general population. These include Timber treatment workers who were potentially occupationally exposed form the use of PCP.
Some initial data shows that this group does have higher dioxin levels in their bodies, consistent higher past exposures.
New Plymouth residents who lived nearby a 2,4,5- T manufacturing plant. No dioxin data is available to show whether or not these residents had higher exposures. A 1986 Ministerial Committee of Inquiry could find no substantial evidence that the manufacture of pesticides at this plant had any ill-effect on the health of the residents of New Plymouth.
Vietnam veterans who may have been exposed from the use of dioxin contaminated chemical defoliants dioxin during the Vietnam War. An inquiry into the health status of children of Vietnam veterans could find, with the possible exception of spina bifida, no evidence to link exposure of Service personnel to defoliants and their children’s health.
The Organochlorines Programme
In 1995, the Government of the day allocated $3.5 million to assess the risks posed by dioxins, PCBs and persistent organochlorine pesticides in New Zealand. The Organochlorines Programme was initiated in recognition of the need to minimise ongoing emissions of dioxins, clean-up sites contaminated with organochlorines from historic activities, and manage the safe disposal of waste stocks of organochlorines such as the PCBs and pesticides.
Process and Consultation The Organochlorines Programme has comprised clearly defined phases of research, assessment, policy development, and communication and consultation, incorporating: A dioxin emissions inventory (research) Measurement of environmental, dietary and population exposures to organochlorines (research) An appraisal of risk posed to wildlife and human health (assessment) An integrated management strategy, including proposals for national environmental standards for dioxin emissions to air, land and water (policy).
A Consultative Group was established, with representatives from central and local government, industry, public interest groups and iwi. The role of the group is to advise the Ministry for the Environment on the programme, represent key stakeholders and a diversity of community interests, to contribute individual expertise and to facilitate and coordinate information gathering and dissemination. A Maori Focus Group was established to ensure issues important to iwi were taken into account.
The Organochlorines Programme publishes the Organochlorines Programme Bulletin, which provides regular updates of the work of the programme. The bulletins and the programmes research findings are distributed to stakeholders and the interested public through a database of over 1,500 people and organisations.
Two rounds of national consultation meetings have been held to provide information on the Organochlorines Programme and obtain feedback on the issues raised.
There are four areas of New Zealand specific research that have been completed and which form a sound scientific basis to develop national environmental standards for dioxins. This research has mirrored what is generally considered to be the transport and fate model for organochlorines, from releases to the environment (the dioxin inventory), environmental accumulation (the environmental survey), human dietary exposures (the dietary survey) and accumulation within humans (the serum survey).
Dioxin emissions inventory
The dioxin inventory was undertaken with the support and cooperation of industry, which ensured privately held data and knowledge were incorporated.
The inventory estimated that dioxins are emitted predominantly to air (47%) and land (50%). Only 3% of dioxins released in New Zealand are discharged to water. The burning of waste material, either in incinerators (7%), or uncontrolled fires at landfills (29%) and domestic backyard fires (13%), together with the burning of wood (22%) and coal (9%), and metallurgical processes (6%) are the major sources of emissions to air. Residues from these processes, such as ash, slag and filter fines are important sources that discharge to land.
The levels of emissions identified are at the low end of the scale compared to emissions in the northern hemisphere. These lower emissions are due to the lower level of industrialisation in New Zealand, rather than, necessarily, better environmental management practices.
The inventory estimated that industrial sources account for only approximately 60% of the total emissions to air, with domestic sources (e.g.
backyard burning of waste and accidental building fires) and natural sources (such as scrub and bush fires) accounting for the remainder.
Dioxin reservoirs of contaminated soils, waste dumps, and landfills may pose an ongoing risk to human health and the environment via the redistribution and circulation of this contaminant. The relative overall significance of dioxin reservoirs compared to current ongoing dioxin emission sources is not known.
Environmental Survey The environmental survey measured the levels of organochlorines in our atmosphere, terrestrial (soil) and aquatic (riverine and estuarine) environments. Study sites were chosen to be representative of the broadscale New Zealand environment. These included ‘reference’ sites, agricultural centres and urban and industrial areas. This data has provided a comprehensive picture of the state of our environment and its organochlorine contamination.
The survey has shown that, overall, the New Zealand environment is comparatively clean with respect to dioxins in comparison with overseas environmental data. The information from the environmental survey is one of the most comprehensive datasets on countrywide environmental contamination from organochlorines in the world, and is of international interest.
Significant observations of the environmental survey were: Domestic wood burning is an important source of dioxins in ambient air in urban centres; The low levels of dioxins in agricultural soils is consistent with our apparent low dietary intake of these contaminants; The study of biota, such as eel, trout and shellfish shows no evidence of severely contaminated rivers or estuaries.
A few isolated “hot spots” were identified, including elevated dioxin air levels at a South Auckland industrial site, and dioxin contaminated soil in a New Plymouth site adjacent to a chemical manufacturing plant.
Risks to wildlife from persistent organochlorines Because of the low overall environmental levels, risks to wildlife are primarily limited to species at the top of the food chain into which organochlorines bioaccumulate. In New Zealand, this means that ecological risk is primarily limited to inshore marine mammal species such as Hector’s dolphin.
An ecological risk assessment of the New Zealand exposure data has concluded that: Overall, the current background concentrations of most organochlorines in the New Zealand environment are significantly less that threshold effects for most wildlife species; Whilst most organochlorines do not appear to be a concern, there are indications that dioxins require further assessment and management.
Specifically, the concentrations of dioxins and PCBs that have accumulated in some marine mammal species, such as Hector’s dolphin, are near to or above concentrations suspected to cause adverse effects in other species.
Dietary Survey People are exposed to organochlorines primarily through their diet. Contaminant levels in food produce can be used to estimate current population exposures.
The dietary survey found only low levels of dioxins and PCBs in meats, dairy products, fish and other foods purchased from retail outlets in New Zealand. These levels are generally lower than levels found in foods from Europe and North America, and consequently our dietary intake is approximately two to five times lower than intakes reported in countries form these regions.
Nonetheless, an estimation of the dietary intake of dioxins and PCBs for adult and adolescent New Zealander shows there is only a small margin of safety (less than a factor of three) between current intake levels and the World Health Organization and the US Agency for Toxic Substance and Disease Registry tolerable daily intake for dioxins. Further, the New Zealand dietary intake exceeds by approximately 70 fold the US Environmental Protection Agency’s dioxin health exposure criterion.
The preferred way to assess human health risk from persistent organochlorines is to consider the level of contaminants actually present in a person’s body (i.e. their ‘body burden’). Body burdens can be estimated by measuring the levels of organochlorines in a body tissue, such as blood serum.
For the Organochlorines Programme, a serum survey was undertaken that measured levels of organochlorines in a cross-sectional sample of New Zealanders aged 15 years and older (approximately 0.05% of the population). This survey found: Organochlorine serum levels increased with increasing age.
Although dioxin levels were similar between the sexes, women had higher body burdens than men because of their higher body fat content.
There was little difference in levels between Maori or non-Maori, or between New Zealanders living in different regions of the country.
Serum dioxin levels were, on average, half the levels measured in Europe and North American populations. This is not considered to be a marked difference.
Risks to human health from dioxins and dioxin- like PCBs New Zealander’s dioxin body burden shows that during approximately the last 25 years, the average dioxin intake was at, or exceeded, the World Health Organization and the US Agency for Toxic Substance and Disease Registry tolerable daily intake for this chemical. There would appear, therefore, to be only a small margin of safety, if any, between New Zealand intakes and some non-cancer effects in animal studies, in particular effects on the offspring of exposed mothers.
A 1998 World Health Organization Consultation on dioxins has recognised that subtle effects might already be occurring in the general population in developed countries at current background levels of exposure. The US Environmental Protection Agency, in its latest (September 2000) draft assessment of the toxicity of dioxins has reaffirmed this finding of the World Health Organization.
As New Zealanders dioxin serum levels are only marginally lower than levels found in the United States or Europe, a similar conclusion could be made here.
Current body burdens for the New Zealand population are therefore considered to be too high, and a programme of action is justified to reduce exposures and body burdens over time.
However, despite the current potential risks, there is no clear indication of increased disease in the general population attributable to dioxins. This may be due to limitations of current data and scientific tools, rather than indicating that dioxin exposure is not causing adverse effects.
For cancer, estimates for the general New Zealand population indicate potential risks between 1 in 1,000 and 7 in 1,000 additional persons dying from cancer associated with dioxin exposure. These cancer estimates are significantly larger than (by over 100 fold) the yardstick for identifying ‘acceptable ’ environmental exposure to carcinogenic chemicals normally followed in New Zealand. Although the actual rate of occurrence of cancers directly attributable to dioxin exposure is not known, it is unlikely to exceed the current estimates, and may be substantially less.
Exposure by nursing infants to dioxins present in breast milk is of particular concern due to the level of dioxin intake a breast-fed infant may receive.
Although this intake may last for only a short period (few New Zealand babies are breast fed for more than 12 months) it is at a time when a child may be more sensitive to the effects of dioxin because of their rapid growth and development.
A recent Ministry of Health study, in a repeat of an earlier 1988/89 study, has found that whilst dioxin levels in breast milk have fallen over the last decade, intake by a breast fed infant may still exceed by approximately 50 fold [check number] the World Health Organization and the US Agency for Toxic Substance and Disease Registry tolerable daily intake. Although breast milk is a significant source of dioxin exposure for nursing infants, the overwhelming body of evidence supports the health benefits of breastfeeding despite the presence of dioxin.
The findings of the health risks from dioxin exposure are reported in ‘Evaluation of the toxicity of dioxins and dioxin-like PCBs: A health risk appraisal for the New Zealand population ’, and Cabinet approval is sought for the release of this report.
Overall, the report concludes that although the long-term health risks to New Zealanders from background exposures to dioxin over a lifetime are uncertain, they are not considered to be negligible.
The publication of the health risk appraisal, which will be released concurrently with the Ministry of Health ’s report on their breast milk study, is likely to be of special interest to the public, and communication of the findings will need to be carefully managed between the Ministries of Environment and Health to avoid any public alarm. A joint communication strategy will be prepared between Environment and Health.
A proposal to reduce dioxin exposure The above findings on health risks justify a programme of action to reduce dioxin exposures and ensure that an acceptable health safety margin is established for the New Zealand population over the next decade and beyond.
The policy would institute control measures and set targets to minimise risks to people and the environment from dioxins. This policy is proposed in the accompanying Cabinet paper ‘Proposal to Develop a National Environmental Standard to Regulate Dioxins from Industrial Facilities ’.
The views of Health, Treasury, DPM&C, MFAT, MED, Te Puni Kokiri, Agriculture and Forestry, Conservation, Labour, LINZ, MORST, Defence and Veteran ’s Affairs have been sought in the preparation of this paper.
There are no financial implications for the Crown. This paper does not seek a commitment of expenditure.
There are no inconsistencies between the proposals presented in this paper and the Human Rights Act 1993.
There are no legislative implications.
Regulatory impact statement
A regulatory impact statement is not required for the purposes of this paper.
Persistent organochlorines are controversial environmental contaminants.
Concern arises because of their toxicity, bioaccumulation in people and intergenerational transfer. Release of the dioxin health risk appraisal is likely to receive interest from the media, the general public, especially nursing mothers, and environmental interest groups. A communication plan, that will include media and public information, will be prepared in conjunction with Health. Public health groups, such as Plunket, will be consulted prior to the release, to allay any fears that may arise. Proposals for action to continue to reduce dioxin exposures are likely to be supported by the community.
It is recommend that the Cabinet Finance, Infrastructure and Environment Committee:
note that dioxins and the PCBs are extremely potent environmental pollutants that have been shown to cause a range of toxic effects in animals, and have the potential to cause similar effects in humans.
note that in 1995 the Government allocated funding for the Organochlorines Programme to address risks to New Zealanders and the environment from dioxins, PCBs and other organochlorines;
note that a Consultative Group was established to advise on the running of the Organochlorines Programme, and that public communication has occurred throughout the programme, including the release of findings from the research undertaken.
note that the Organochlorines Programme has collected data on the sources of dioxins in New Zealand. This dioxin inventory has shown that domestic emissions account for approximately 38% of total dioxin emissions in New Zealand, and that by international comparison our total emissions are at the low end of emissions estimated overseas note that a nationwide environmental survey of organochlorines in our atmosphere, terrestrial and aquatic ecosystems has shown that, for the most part, dioxin and PCB levels in our environment are low, and that, with the possible exception of some inshore marine mammal species, these is minimal risk to wildlife from background exposures to persistent organochlorines.
note that a dietary survey has shown low levels of dioxins and PCBs in our foods. Nonetheless, the estimated dietary intake of these contaminants for New Zealanders is only marginally below the target World Health Organization and the US Agency for Toxic Substances and Disease Registry tolerable daily intake.
note that blood samples collected from New Zealanders contained dioxin and PCB levels that were only marginally lower than levels found in populations from other industrialised countries.
Older people had higher levels in their bodies, but there is no difference between Maori and non- Maori. Women had higher amounts of dioxins in their body than men.
note that the Ministry of Health have measured the levels of organochlorines in breast milk, and that, in line in line with overseas data, dioxin levels appear to have declined significantly over the last decade; Health assessment
note that, despite apparent falling dioxin exposures, the safety margin to protect New Zealanders health at current body burdens is judged to be small when assessed against international criteria.
note that breast-fed infants may have higher exposures in the early months of their life, when they may be more susceptible to the effects of dioxin; agree to the release of the report ‘Evaluation of the toxicity of dioxins and dioxin-like PCBs: A health risk appraisal for the New Zealand population’;
note that the Ministry of Health’s report on dioxin levels in breast milk will be released concurrently with this health risk appraisal; note that breast feeding mothers and community health agencies such as Plunket will be expected to take particular interest in the release of the health risk appraisal. A communications plan will be prepared, jointly with the Ministry of Health, to accompany the release of this report.
note that other groups, such as those who consider they may have had higher dioxin exposures in the past, will also be interested in the findings of the health risk appraisal.
note that a strategy is being developed to address the problems from persistent organochlorine chemicals in New Zealand, comprising environmental standards and guidelines. This strategy will be reported separately in the Cabinet paper ‘Proposal to Develop a National Environmental Standard to Regulate Dioxins from Industrial Facilities’.
Hon Marian L Hobbs Minister for the Environment
CABINET PAPER NO. TWO...
[Draft 14 Nov 00]
Office of the Minister for the Environment
Chairperson Cabinet Finance, Infrastructure and Environment Committee
Proposal to develop a National Environmental Standard to regulate dioxins from industrial facilities.
1. Dioxins are highly toxic and environmentally persistent pollutants that accumulate in animal and human tissue. Small quantities of dioxins are released by burning and by some industrial processes. Most dioxins are emitted into the air and/or deposited to land. Dioxins and related chemicals are currently a focus of international concern as persistent organic pollutants (POPs).
2. Current body burdens of the New Zealand population are judged to be unacceptably high. Therefore a programme of action is needed to reduce dioxin exposures to ensure that a satisfactory health safety margin is established.
3. The Ministry for the Environment proposes to develop measures to protect human health and the environment by reducing exposures to dioxins. As a priority, a National Environmental Standard (NES) would be developed as a regulation under the Resource Management Act 1991. The regulation would apply to any industrial facility emitting dioxin emissions to the environment above threshold levels, and control the use of land contaminated with dioxin. A dioxin regulation is consistent with actions taken or now being considered by governments internationally in response to a forthcoming UN treaty on POPs presently being negotiated.
4. The purpose of this paper is to seek Cabinet agreement to a (draft) dioxin policy to protect human health and the environment from immediate and long term risks posed by dioxins through implementing regulatory and non regulatory measures in order to ensure that exposures to the New Zealand population continue to trend downwards and that dioxin exposures to nursing infants is minimised.
5. Cabinet agreement is also sought to implement the first measure to achieve this goal by developing a draft national environmental standard for dioxins ready for promulgation in December 2001.
6. Dioxins are extremely potent environmental pollutants having the potential to cause adverse health effects in animals and humans. Based on current body burdens of the New Zealand population relative to effects demonstrated in animal studies the health risk to the general population would appear to have an unacceptably low margin of safety [Cab (00) M …(Persistent organochlorines and an appraisal of the health risk to New Zealanders) refers]. This finding is consistent with the most recent dioxin health risk assessment by the US Environmental Protection Agency.
7. While infant exposures via in utero exposure and breast milk are not a proven cause of harm, and breast feeding remains the recommended best option, steps to reduce dioxin emissions and intakes generally, will over time reduce infant exposures too.
8. Therefore, a policy and a programme of action is proposed to reduce dioxin exposures and ensure that an acceptable health safety margin is established for the New Zealand population over the next decade and beyond. The proposal is to develop control measures and set targets for dioxins to minimise risks to people and the environment from dioxins, mindful that exposures may take several decades for dioxin levels to lessen substantially.
9. A policy to reduce dioxin emissions would enable the Government to assure the public that action is being taken in line with best international practice, and that population exposures and body burdens will reduce over time. The policy would: protect New Zealand’s baseline quality of air, soil, water, and ensure safe land-use in respect of dioxins; protect agricultural soils over the long term and safeguard the health and well being of New Zealanders from exposure to dioxins via food. . help underpin New Zealand’s international trade advantage and reputation for “clean and green” and as a producer of high quality agricultural and dairy products;
10. The success of the policy would be monitored by measuring the rate by which dioxin levels in human tissue (the body burden) trended downwards over the next decade and beyond. As dioxins arise from both industrial and domestic activity, the policy objectives would need to be achieved by a mixture of regulatory and non regulatory approaches.
11. These actions would be consistent with likely international and legally binding obligations under a forthcoming United Nations treaty on persistent organic pollutants currently being negotiated.
Proposed dioxin policy goal
12. The proposed goal of the dioxins policy is to protect human health and the environment from immediate and long term risks posed by dioxins through implementing regulatory and non regulatory measures in order to ensure that exposures to the New Zealand population continue to trend downwards.
13. It is proposed that a National Environmental Standard (NES) on dioxins be developed under the Resource Management Act 1991 (RMA) as a first priority. The NES regulation would apply to industrial facilities identified as major emitters of dioxins, and to contaminated land. The NES would set limits on dioxins being emitted to air, land and water from major industrial point sources, and would develop landuse rules to ensure that any land contaminated by dioxins is safe for existing and intended uses. .
14. It is proposed that the next steps will be to develop non regulatory measures to minimise dioxin emissions from minor industrial sources, and from non industrial sources such as the domestic sector.
15. This paper specifically outlines the proposal to develop an NES for dioxins.
NES regulation on dioxin
16. The dioxins NES (draft) objectives proposed are: to regulate dioxin emissions from existing and future industrial facilities in accordance with specified limits; to control the use of land contaminated by dioxins by specifying clean-up and acceptable landuse standards such that an unsafe use of that land is avoided.
Proposed scope of the NES
17. The NES would prescribe standards and/or methodologies to: limit emissions to air from industrial point sources (e.g. landfill fires, incineration; metallurgy processes), limit emissions to receiving water from industrial point sources (e.g. pulp and paper industry, leachates), limit emissions to land (e.g. disposal to landfill; land application of wastes such as biosolids); set clean-up standards for contaminated sites consistent with land uses (e.g. agricultural, residential, commercial/industrial).
18. The NES proposal would take account of:
scientific acceptance that dioxins are highly toxic, environmentally persistent, and bioaccumulative; the epidemiological judgement that New Zealand dioxin body burdens should be reduced, including the particular concern to protect breast-fed infants from exposure to dioxins ; the general public and international concern over dioxin exposures. International experience in managing dioxin exposure reduction.
The process to develop a NES
19. The RMA sets out the s requirements of the Minister for the Environment in the making of any NES regulation. The requirements (described in s.44) are:
“establish a process that - The Minister considers gives the public adequate time and opportunity to comment on the proposed subject matter of the regulation; and Requires a report and recommendation to be made to the Minister on those comments and the proposed subject matter of the regulation; and Publicly notify that report and recommendation”.
20. Consistent with these requirements it is proposed that the dioxin NES would be developed according to the following sequence:
Task Achievement Date Collection of background data environmental surveys (soil, rivers, estuaries, air) NZ population studies: dietary intake, human serum Dioxin emissions inventory ( ( ( Assess the significance of the data – publish reports on Ecological risk assessment Human health risk appraisal 1 Mar 01 1 Mar 01 Policy response to 1st priority issues: NES proposal on dioxins prepared, including the Government’s preferred standards to protect human health Technical reports on proposed environmental standards (air, land and water), and international reference standards The Draft dioxins NES RMA s. 32 report on alternatives to regulation, and costs and benefits 30 April 01
30 April 01
30 April 01 30 April 01 Public consultation (RMA s.44 statutory requirements) Stakeholding industries, iwi, community 31 July 01 NES proposal revised 20 Oct 01 NES report and recommendation submitted to the Minister for the Environment and publicly notified 20 Nov 01 NES promulgated as RMA regulation 20 Dec 01
21. An internationally legally binding instrument (to be known as the POPs Treaty) is being negotiated by governments under the auspices of the UNEP Governing Council. Under this treaty, all signatory countries will be expected to eliminate and/or reduce emissions of POP contaminants. Commitments to minimise dioxins emissions will be a priority.
22. Dioxin levels in Europe have fallen significantly in the last 10 years. This has been achieved by imposing strict limits on industrial processes that emit dioxins to air and by regulating the production and use of POP chemicals containing dioxin contaminants.
23. New Zealand has also responded to international concerns: the Pesticides Board deregistered PCP; the herbicide 2,4,5-T is no longer manufactured; PCBs are banned under the Toxic Substances regulations; and leaded petrol is no longer used in NZ’s vehicle fleet. Notwithstanding consent conditions on some waste incinerators, there is no consistent regulation of dioxin emissions from industrial sources, and this is at odds with international best practice in the northern hemisphere.
24. New Zealand is often promoted as a “clean- green” country in selling primary produce to northern hemisphere markets. As the international market is very sensitive to food contamination scares involving dioxin it is important that our regulatory regime for dioxins at least matches international best practice standards. The importance of this point is clearly reinforced by the measures imposed on Belgium by importing countries concerned that food products had potential to be contaminated by dioxins. The cost to Belgium as a result of the global import restrictions was estimated at several billion NZ dollars. If a similar dioxin incident occurred in New Zealand the financial impact would be severe.
25. New Zealand is well placed to develop a dioxins policy that is conservative yet affordable in reducing health exposure risks. The cost effective achievement of the proposed dioxin policy will depend on identifying dioxin sources and applying appropriate controls. Industrial sources of dioxin emissions have been identified, such as waste incineration and landfill fires, and these sources can be regulated by an NES as a first priority in establishing a regulatory regime.
26. Emissions generated by non industrial sources (e.g. domestic activity) are also important to identify and reduce, but non regulatory measures are indicated and initiatives in this area need further consideration. Non regulatory approaches could include (i) best practice industry guidelines, (ii) guidance to regional councils on levels that will protect the quality of ambient air, sediment, and fish tissue, (iii) actions for adoption by households and the public.
Government Environmental Policy
27. The proposal for a dioxins policy is consistent with the Government’s Environment 2010 broadscale policy goal in this area to reduce risk to the environment, people and the economy.
28. The proposal is also consistent with the Labour and Alliance Party’s environmental policies to develop environmental standards, manage toxic wastes, protect New Zealand’s clean and green image, commit to sustainable development, protect ecosystems, adopt a precautionary approach in the control of hazardous substances, prioritise contaminated sites and act to remedy them.
Legal framework 29. The proposed NES for dioxins would be the first standards developed and promulgated under the RMA. The NES has the force and effect of a regulation under the RMA.
Previous Cabinet decisions
30. There is no previous Cabinet decision relating to the control of dioxin emissions.
Evaluation of the NES proposal
31. A full evaluation of the dioxin NES proposal, including a consideration of costs, benefits and alternatives to the NES (as required under s.32 RMA) will be included in the proposal reported to Cabinet by 30 April 2001. For the purposes of obtaining Cabinet agreement to its preparation, the main arguments for and against the NES proposal are summarised below.
32. Regulatory options under the RMA are: An NES Rules in a regional plan (to control discharges to air and water) and rules in a district plan (to determine clean-up criteria for land uses) Conditions on individual resource consents
Arguments for a dioxins NES
33. The effect of an NES, as a national prescription, is to place a mandatory requirement on local authorities at regional and district levels to either incorporate the standard into plans, or to apply conditions on resource consents. An NES is therefore a reliable way to implement a nationally important measure. There are several reasons why national consistency is needed on the issue of dioxins: For New Zealand to be a signatory to the UNEP POPs convention, a national policy and legal framework for dioxins reduction will be needed; As the main route of human exposure to dioxins is through the food chain, levels of dioxins on agricultural lands potentially affects the whole population. Dioxin issues are technically complex and controversial and it is more efficient to resolve these policy issues at a national level, including a process involving public comment.
Limitations and alternatives to a dioxins NES
34. Reasons that might weigh against the use of NES will be evaluated in the full proposal and initial considerations are: that the utility of NES could be limited to a few major dioxin emission source categories for which a mixture of non regulatory alternatives might achieve the same or similar outcomes; NES are not effective for non industrial activities that also emit dioxins.
35. NES alternatives potentially include a national policy statement, the provision of information and guidelines, the application of economic instruments, and a continuance of the status quo. A preliminary examination of these alternatives indicates that individually they are likely to be less reliable and effective or not as efficient in achieving the objective of an NES. It is concluded that firstly, no alternative means would, by itself, guarantee an acceptable outcome. Secondly, if alternative means are taken collectively, the resulting mix would be difficult to administer.
36. The views of Health, Treasury, DPM&C, MFAT, MED, TPK, MAF, Labour, LINZ, MORST, DOC, Defence, and Veteran’s Affairs, have been sought on this paper.
37. There are no financial implications for the Crown in the development of an NES proposal beyond baseline expenditure in Vote Environment to consult, complete and promulgate the regulation. This paper does not seek a commitment of expenditure.
38. On completion, the NES on dioxins would be promulgated as a regulation under the Resource Management Act 1991.
Regulatory impact statement
39. A regulatory impact statement is not required at this point. It cannot be prepared until the subject matter of an NES is further developed. Industry will continue to be consulted during the development of an NES proposal and in the assessments of costs. A regulatory impact statement will would accompany the final NES recommendation to Cabinet.
Consultation with iwi.
40. The NES will protect kai moana and be supportive of iwi/Maori cultural and spiritual concerns in protecting the environment. Iwi views will be sought on the NES proposal.
41. Organochlorine chemicals generally, and dioxins and PCBs in particular, are controversial environmental contaminants. In running the Organochlorines Programme, the Ministry for the Environment has, from the outset, invested heavily in informing the community about this work. Public meetings have been held in the metropolitan and provincial centres, summaries of reports have been made widely available, information bulletins circulated, and scientific papers have been made accessible electronically through the Ministry’s web-site. This approach to keeping the community informed will continue.
42. A proposal to develop NES for dioxins should be broadly supported by the community although some environmental interests will want the standards to be more precautionary than industry. Health and Environment will collaborate in preparing public information to address health and environmental concerns raised by the NES proposal.
43. It is recommended that Cabinet:
note that the Organochlorines Programme has researched the background level of organochlorine contamination of the New Zealand environment, including dioxins which are extremely potent environmental pollutants.
note that current dioxin body burdens of the New Zealand population are judged to be unacceptably high, and therefore a programme of action is needed to reduce dioxin exposures and establish an acceptable health safety margin in the future.
note that such a programme of action will also reduce dioxin exposure to breast- fed infants.
agree that a proposal be prepared comprising measures to reduce the health and environmental risk from dioxins including: draft government policy on dioxins; draft NES regulation.
agree that the (draft) goal of the dioxins policy is to protect human health and the environment from immediate and long term risks posed by dioxins through implementing regulatory and non regulatory measures in order to ensure that exposures to the New Zealand population continue to trend downwards.
note that the dioxins NES would address industrial but not domestic emissions.
note that the dioxins NES proposal would limit dioxin emissions to air, land and water from existing and future industrial facilities; limit the use of land contaminated by dioxins; evaluate possible alternatives and assess costs and benefits to the NES proposal (as required under s.32 RMA).
note that the process to develop the dioxins NES proposal involves a statutory obligation to consult the public, and will therefore involve: release of the draft NES proposal described in para (g) for public comment; a 3 month public consultation phase; revision and preparation of the final NES proposal approval of the Final NES promulgation of the NES as a regulation under the RMA implementation of the NES by local government through rules in plans or as conditions on resource consents.
direct officials to prepare and report back to FIN with the draft NES proposal package to release for public comment by 30 April 2001.
note that the above process will result in an NES on dioxins being promulgated as a regulation by approximately December 2001.
note that these measures will form part of New Zealand’s commitment to a United Nations treaty being negotiated to protect human health and the environment from persistent organic pollutants.
Hon Marian L Hobbs MINISTER FOR THE ENVIRONMENT