I’m concerned about the misuse of the of the HAIL register created by the Ministry for the environment (MFE) classification A10
My feeling here is that there will be a significant alignment of interests here from at leas three well organised affected parties:
- universities/high schools/primary schools and pre-schools,
- horticultural commercial activities of all kinds who rely on clean green products and more importantly processes
- residential land owners whose property has emerged from urbanisation over the last century – it will almost all have come from some for of argicultural or horticultural land use-
So, I’ve written to several trade and grower associationsto find out if their members are concerned (the New Zealand Winegrowers association, Horticuture NZ. and Soil and Health sponsored Organics NZ) Here is a general form of the letter . I’ll keep you posted on any responses….and will be sending it to ministry of education and student associations at uni’s , polytechs and colleges that have sports and recreation grounds (it’s the students who will take it seriously ).
I am currently doing research on the measurement and communication of health risks from soil contamination in category A10 of the ministry for the environment’s HAIL register. (Actually it is research on non-measurement and mis-communication about health risks)
The question I was (and am) asking is : are the active members in your nation wide association of wine growers/orchardists/market gardeners also concerned? If yes, then have you or your members made any organised, formal submissions to local or regional councils who have recently begun the systematic reclassification?
Why am I interested? I am recently “semi-retired” as an academic economist (mostly U of Canterbury, but also Queens, UBC, SFU in Canada ) with my Phd from Stanford, and I am information gathering for a research project I am working on that analyses and critiques the overall policy thrust at all levels of government here. The policy itself and the “research” underlying it flies against all recent economic and epidemiological research on health risks. The current methodology in health economics in particular demands credible quantitative evidence when making professional, commercial or policy claims about risks to human health. Evidence based medicine and evidence based policy is a focal point that is completely absent in recent HAIL classifications about land contamination that impacts on human health risks.
The real problem is Hail category A10, which is, quoting from the MFE HAIL documents 2015:
“A10: Persistent pesticide bulk storage or use including sport turfs, market gardens, orchards, glass houses or spray sheds”
It seems that nationwide, under central government pressure, every local/regional council around the country is formally classifying and registering both residential and commercial properties on the HAIL register that are or have been market gardens, orchards, and glass houses irrespective of whether actual owners operators and users persistently and in bulk (whatever that might mean quantitatively) use or store pesticides and without any evidence basis to make a claim of a “likely” risk to human health. The claim is not about “potential”, it is about likely risks to human health (again whatever that might mean quantitatively). Please note we are talking virtually every university, high school, primary school play centre, public recreational park – rugby soccer hockey…. at every amateur and recreational leveland at every age – in the most populous cities in our country as well as every sort of horticultural land and activity.
I am concerned on three fronts :
•impacts on residential or commercial property values and or land rents and contracts in horticultural activities on land so classified ,
•impacts on information gathering – expensive, unnecessary and widespread imperfect “testing” responses- to disprove these non-evidence based, but political, claims . Two examples here: – (1) the practises of excessive diagnostic testing, “defensive medicine”, that have little to do with health and everything to do with minimising professional medical liability; and (2) the dangers of self testing that have been documented about “investigating” and the trying to remove asbestos or lead in ones own home or place of business – “fixing” an alleged and sometimes real problem is what actually creates the health hazard!
•inefficient land use/re-use decision making based on misleading and non-evidence based health risk information : anecdote , bureaucratic subjective classifications, imperfect or non-existent sample testing information (false positives and false negatives) ranging from self administered sampling to highly professional – yet still imperfectly sensitive and specific – testing, and worst of all – fear driven behavioural responses about relocation choices, property sales, contracts, and about safety, or not, for children, student and adult users of school and public recreational and sporting land
thanks for any help you can provide.
What is the HAIL?
Sounds simple – here is what MFE says – a cut and paste from MFE site
What is the HAIL?
The Hazardous Activities and Industries List (HAIL) is a compilation of activities and industries that are considered likely to cause land contamination resulting from hazardous substance use, storage or disposal. The HAIL is intended to identify most situations in New Zealand where hazardous substances could cause, and in many cases have caused, land contamination.
The HAIL groups similar industries together, which typically use or store hazardous substances that could cause contamination if these substances escaped from safe storage, were disposed of on the site, or were lost to the environment through their use.
Here is a cut an pasted of the chemical section – emphasis added at item 10 – but item 10 is relevant for wine growers, market gardeners, and orchardists, look at its neighbouring classifications! The last thing New Zealand horticultural activities want to be associated in any way with!!
Hazardous Activities and Industries List (HAIL): October 2011
A. Chemical manufacture, application and bulk storage
- Agrichemicals including commercial premises used by spray contractors for filling, storing or washing out tanks for agrichemical application
- Chemical manufacture, formulation or bulk storage
- Commercial analytical laboratory sites
- Corrosives including formulation or bulk storage
- Dry-cleaning plants including dry-cleaning premises or the bulk storage of dry-cleaning solvents
- Fertiliser manufacture or bulk storage
- Gasworks including the manufacture of gas from coal or oil feedstocks
- Livestock dip or spray race operations
- Paint manufacture or formulation (excluding retail paint stores)
- Persistent pesticide bulk storage or use including sport turfs, market gardens, orchards, glass houses or spray sheds
- Pest control including the premises of commercial pest control operators or any authorities that carry out pest control where bulk storage or preparation of pesticide occurs, including preparation of poisoned baits or filling or washing of tanks for pesticide application
- Pesticide manufacture (including animal poisons, insecticides, fungicides or herbicides) including the commercial manufacturing, blending, mixing or formulating of pesticides
- Petroleum or petrochemical industries including a petroleum depot, terminal, blending plant or refinery, or facilities for recovery, reprocessing or recycling petroleum-based materials, or bulk storage of petroleum or petrochemicals above or below ground
- Pharmaceutical manufacture including the commercial manufacture, blending, mixing or formulation of pharmaceuticals, including animal remedies or the manufacturing of illicit drugs with the potential for environmental discharges
- Printing including commercial printing using metal type, inks, dyes, or solvents (excluding photocopy shops)
- Skin or wool processing including a tannery or fellmongery, or any other commercial facility for hide curing, drying, scouring or finishing or storing wool or leather products
- Storage tanks or drums for fuel, chemicals or liquid waste
- Wood treatment or preservation including the commercial use of anti-sapstain chemicals during milling, or bulk storage of treated timber outside
Category A10 on the list “Persistent pesticide bulk storage or use including sport turfs, market gardens, orchards, glass houses or spray sheds” opens the doors for a floodgate of claims for potential or likely contamination – without a shred of sampling ever to be done. This is happening across the country now as councils “comply” with central government directives to classify land as likely contaminated simply and only by historic use, no matter what the actual use was and without requirements to sample any suspected land. Bureaucrats protect their jobs, w/o risk to themselves financially, and w/o concert for or liability for false claims about land held by their constituents,I have only just discovered this as my perfectly safe land once had an orchard on it 70 years ago – despite the fact that that neither the trees nor the soil from 70 years ago no longer exists , and excavations on my property removed up to 2 metres of top soil! Sure, I and every other resident can get our soil “tested” professionally for a cost of $2000+ depending on the size of the section, but it doesn’t take long to do the math to realise that hundreds of thousands of dollars will be spent in one relatively unpopulated region to achieve compliance with a claim that has no evidence base in the first place.
But irrespective of actual sampling done and actual state of land, even a hint of growing grapes on contaminated soil in NZ could be disasterous for wine trade.
Does this concern you? Are you doing any research into the problem?