Balancing act: enhancing crop protection and regulatory processes for a sustainable future

Opinion: Andrew Pearson, Tonkin + Taylor

Crop protection tools are an essential component of modern horticulture. They are critical to food availability and affordability, ensuring we produce food of good quality that is not impacted by pests and diseases and that we limit crop losses that contribute to the high quantities of food wasted.

Regulation of these tools has to strike a balance. These are chemicals which are designed to kill or control pests, diseases, or weeds. It is critical they do not impact more broadly than that, on human or ecological health. We have come a long way in the 60 years since Rachel Carson’s Silent Spring and we don’t want to return to those days.

At the same time, regulation needs to be flexible and pragmatic, to support new actives being brought into the New Zealand market and to allow new chemistry to come through, incentivising products that are safer, less harmful to the environment, but still effective.

By the time a chemical reaches the Environmental Protection Authority (EPA) and New Zealand Food Safety (NZFS) for regulatory assessment, there is often millions of dollars of testing behind it. This testing helps inform what adverse effects it might have on humans, what residues it might leave in food, and how it might migrate and impact on the environment. This in turn helps inform what controls regulators have to put around its use, so it can be used safely and effectively. As well as processing new products, EPA and NZFS are also responsible for making sure that chemicals which may have been registered decades ago are still fit for purpose.

As a former regulator myself, I know the scientists completing regulatory approval processes are dedicated, highly competent and passionate about what they do to ensure the safety of these products for communities and the environment. They work in a field where the modelling and assessment required is increasingly complex, in order to keep up with the latest understanding of risk.

As an example, society is increasingly moving towards a circular economy, looking to rescue, reuse, recycle or upcycle waste and reduce the use of virgin materials. That has led to a need to better understand how chemicals are behaving in waste, and if they can lead to contamination – it’s no longer an assumption that they will disappear into landfills.

In 2022, the Parliamentary Commissioner for the Environment recommended that New Zealand regulators develop the tools and data gathering to model and record the use and life cycle of the chemicals they are approving. However, this means extra work, and a need to train and maintain the unique skills for completing these assessments.  Without sufficient funding, this could come at the expense of longer to attain regulatory approvals in New Zealand.

In 2023, the EPA commissioned a report by Sapere that identified that a lack of funding has led to longer timeframes for applications. Limited funding has also meant that some current models the EPA use to assess the environmental risk of chemicals are outdated, difficult to use, and no longer fit for purpose.

The Government has announced that the Ministry for Regulation will review the complex approval processes for new agricultural and horticultural products. Regulation Minister David Seymour has said the review will include looking at the ‘red tape’ around accessing products that have been approved by other OECD countries.

I personally hope that the approach to the review will also take into account the need to provide a greater budget for regulators in this space. Sustained ongoing funding is required to enable them to use the latest science and innovation to reflect current understanding and ensure a robust but timely assessment process, for example, by updating the ecological risk assessment models that they use.

To ensure long term sustainability these agencies will need to have more scientists working in toxicology, ecotoxicology, chemistry and risk assessment. We have come to rely on bringing in overseas experts (myself included at the start of my career), but it would be better for the long-term resilience of our industry to see more funding directed into New Zealand’s university system to train and develop our own experts.

The pressures on the agriculture and horticulture sectors are absolutely real, and the regulatory process must support these sectors to innovate and change through the use of new tools. At the same time, we have to consider the new and evolving challenges the regulators themselves face and support them to effectively use the most up-to-date science and assessment tools.

Alongside the aims outlined for the review, better resourcing of the work that regulators do would support innovation in crop protection tools and ease the process of getting these essential products that are available overseas into the New Zealand market.

Andrew Pearson is a Senior Environmental Consultant at Tonkin + Taylor. He is a Certified Environmental Practitioner leading work on toxicology and exposure from chemical contaminants in the environment and the agrifood system.