The NZ authorities do not practice the precautionary principle with the spreading of 1080 poison. In fact they are now legally allowed to drop it into your waterways without the previously required consents, even though the manufacturer’s warning says take care not to drop it into the waterways. Whilst they continue to claim it is harmless, there is much independent research that says otherwise. (See 1080science for further independent info). In light of that, in my opinion it is safer to follow the precautionary principle, that is, proceed as if there were a possible risk to your health rather than assume there is none. Since 1080 is a known teratogen I believe it is particularly important for pregnant mothers or even those who think they may be or who could be pregnant, to distance themselves from an area where 1080 is being distributed, particularly aerially because of the drift of the dust over long distances.  I believe these are the concerns being raised here, and particularly also with regard to warning tourists of the risks of drinking the water, who may not be able to read the signs (if there indeed are any). Finally, of particular concern is the topography of Milford Sound. When it rains as per the above image, “all of the steep landscape can be considered a streambed”.  EWR.

Read the first Milford Sound article here.

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By Sacha Stevenson

Aug 2nd 2019

To: the Community of Milford Sound.

Re: Response to email on 31st July 2019 from John McCutcheon (MSI) to the community and stakeholders, regarding the impending 1080 drop into the public water supply water catchment area of Milford Sound

The key issue:

DOC has issued its intentions to drop a VTA (1080) between Aug 1st and Dec 2019 in the Cleddau/Milford Sound area, including the Bowen River valley, which is the water catchment for the public water supply of Milford Sound.

• How might this affect the public water supply and its consumers in the Milford Sound area?
• It won’t, if the drop is aborted in the Bowen River valley water catchment area.

However, if the drop in the catchment area goes ahead, I believe that – on reading the information and links below, both DOC & Milford Sound Infrastructure (MSI –the local public water supply company) should act in good faith, and with the prudent exercise of ethical responsibility, to make sure that an alternate water supply is arranged during and after the 1080 drop. Also, adequate signage should be supplied about the drop –which seems to be the responsibility of Workplace NZ.

Why?

The alternative supply should be offered until testing is carried out and levels of 1080 found to be below the government standard for tests (set at 2 parts per billion, though under 3.5 parts per billion is deemed safe by the EPA.) Note: No human trials have been carried out to know if this level is indeed correct)

Failing the delivery of an alternate water supply, responsibility lies with us – the end operators and consumers, along with WorkSafe NZ – to place signs at all water outlets where human consumption could reasonably be expected to take place. For example, all tourist vessels, port and airport facilities, and all lodgings should have 1080 danger signs erected where water (including tea or coffee) is to be offered during and after aerial operations in the Bowen River catchment area, until post-drop test results are available.

I have now received an email (dated 1 Aug 2019) from Renee Cubitt (Health Protection Officer Public Health South, Southern DHB) where she states:

“… Mitigation measures are discussed between the water supplier and the applicant and monitoring includes testing the water before consumption. Water samples tested for 1080 toxin residue in New Zealand are tested to a very low level of detection. Alternative supplies are arranged before results are cleared (highlight added). In our view the risk to those consuming drinking water is extremely low – and most likely nil.”

But as recognised in this statement, some risk – however small – exists, so an alternative water supply should be offered.

What regulates these requests to drop 1080 and relevant mitigation of risk?

The Ministry of Health is responsible for ensuring that the provisions of the HSNO Act are complied with where it is necessary to protect public health. The Public Health Unit (PHU) is empowered by the Ministry of Health to approve permission and attach conditions to interested parties applying a VTA (Vertebrate Toxic Agent) in a public place. This applies especially to drops into (or near) a public water supply. Public Health South (PHS) processes and approves permissions for VTA use in the Fiordland area, in so doing, sets minimum standards for the intended dispersal area in the Milford Sound public water supply catchment area.

Permission is required because VTAs (of which 1080 is one) are toxic to humans through acute poisoning and chronic exposure. 1080 is considered a hazardous substance, for good reason. (See link to 1080 effects at p7.)

The PHU have issued a Model Permission Statement (see p32 onwards) with examples – one of which focuses on a VTA to be dropped into a public water supply. (Case study 2 at p63.)

Some things that stand out for me with the model PHU permissions:

• Full disclosure to users is expected, with signs and warnings – which would logically be placed at the point of possible consumption. (See conditions 19 & 20 p47 of VTA permission guide.)
• An alternate water supply should be offered, if requested, until testing has been completed. (See Case example – Condition 25 p68 note ii and conditions 25 – 32 of VTA permission guide.)

I see the above two points as meeting a legal and moral duty to protect tourists (and locals) from potentially drinking contaminated water.

It should be noted that, according to the opening segment of condition 30 (p57) of the VTA permission guide:

Mitigation shall be mutually agreed in writing between the applicant and water supply managers and involve either or both of the following [emphasis added]:

• No 1080 shall be applied within 200 m of the water supply intakes. For flowing surface watercourses, the 200 m exclusion shall be extended to 400 m upstream of the point of intake. (p57)
• If an interim water supply is available, the affected water supply shall be temporarily disconnected until such time as water testing finds no VTA contamination above 50 percent of the Ministry’s PMAV*, in accordance with the requirements of the Drinking-water Standards of New Zealand. (p57)

The first point above is modified (example given in condition (30 pg57) by:

In steep areas, the exclusion area may need to be increased to avoid bait falling in to the waterway [emphasis added].

Local conditions affecting the toxicity of any drop in this area

Let’s be honest, the whole Milford Sound area has extremely steep gradients.

Bowen River valley and public water supply catchment area (see red circled area)

Fiordland is a unique area in terms of its topography and rainfall. The Bowen River catchment valley is rather like a giant granite bath, with very little top soil, and average rainfall of 7000mm per annum.

During rainfall, all of the steep landscape can be considered a streambed.

Contrasting the 2D nature of the 2017 GPS flight path map for the 1080 drop in this area with the reality of the length of the Bowen River and its many, many feeder streams (via a camping map) also gives perspective to the special nature of this landscape and its potential for major 1080 runoff into the waters feeding our drinking water supply.

Figure 3: Flight path for 2017 drop (from EPA Report) Figure 4: Topography (from Camping Map)

This unique topography, together with winter temperatures, ice and snow melt, will likely increase the risk of 1080 arriving at the intake area intact, and at the same time and breaking down much more slowly. According to TBFree: “How 1080 Breaks Down in Soil and Water”:

“Biodegradation of 1080 is faster in warmer conditions (20degC), but still occurs at 5degC. At cooler temperatures rates of degradation are slower…..”

Imagine the perfect storm: A huge rain soon after the drop and all the aerially dispersed 1080 pellets wash straight into the streams and make their way to the public water supply intake around the same time. This poison then, being a deadly toxin at single digit parts per billion, arrives to be consumed by a pregnant woman, above the levels that the mother and child can metabolize safely.

Is it possible that 1080 might get to the intake before it breaks down? Considering the nature of the topography here, the winter temperatures and the international exposure of our iconic location, ALL options of mitigating risks should be enacted.

The 2017 DOC report (at p6) reported a positive 1080 test at 1ppb for the Bowen River (ie a fairly small risk). However, as discussed above, different conditions (eg heavy rain around the time of the drop) may adversely affect that risk level.

Timing of water samples

Landcare Research, in its “Guideline for Sampling and Testing of Water” states (at 3.1) that:

“Urgent samples for 24-hour turnaround testing may be sent unfrozen to the testing laboratory, but they must be chilled to 4°C and placed on ice as soon as possible after collection.”

Looking closer at Landcare’s testing regime (at 4.0): “Results will be available no later than 9.30 a.m.

on the following day.” This means, at a minimum, no water should be drunk in Milford for 24hrs.

The precautionary principle

The HSNO Act (at s7) is predicated on a precautionary approach, especially where there is uncertainty about the effects of a course of action, which there must be in this case.

This precautionary aspect is reflected in the PHU Guidelines for VTAs:

• “The specific characteristics and risk profile of each VTA operation is different, depending on the VTA being used, the terrain and factors such as public use patterns and/or proximity to dwellings and water supplies. The Model Permit Conditions may need to be modified in order to adequately manage the level of the risk to public health.[From page iii, emphasis added]
• “The Model Permit Conditions are intended as a starting point. They should not be applied as a generalised standard ‘set’ of conditions. They provide a framework that officers can adjust in order to meet local needs. However, officers need to ensure that they fully consider the various risks and characteristics of each specific proposed VTA operation in order to determine the appropriate Model Permit Conditions to be used and how such conditions might need to be modified to adequately manage the public health risks posed by that particular operation.” [From page 2, emphasis added]

Guidelines are not the law. They are a mechanism for giving effect to the law – and to its precautionary approach.

Milford Sound – a major tourist attraction

Milford Sound is one of NZ’s iconic tourist locations. We have somewhere between 500 to 5,000 guests per day visiting the Fiord, hosted by various companies across the different seasons. The large majority of tourists are foreign nationals, many of whom don’t speak or read English very well.

Until at least the 24th July 2019, Milford Sound Infrastructure acknowledged they hadn’t been notified of the impending drop. Since the community was notified by MSI on the 31st July, we can assume we now have at least 2 months until the scheduled drop begins, as per the guidelines:

The notice must be given sufficiently prior to, but within two months of, the proposed application of the VTA (PHU VTA Permission – condition 27 Notification)

I understand that some of the companies here are planning to make bottled water available for their staff, but none of them (as far as I know) are planning to offer bottled water to the tourists, or even to put notices up in the terminal or on the vessels to warn them of the 1080 drop – so they can at least make an informed choice as to whether they will consume the potentially contaminated water or not.

I believe in ‘free will’ and I can understand some people believe the Government/DOC scientists when they say the water will be safe to drink.

However, around 3% of 1080 tests in water have come back positive for 1080 over the years, with at least 4 positive tests in drinking water, albeit in low concentrations. (See TBFree, p3.)

Knowing that 1080 is teratogenic (may cause birth defects) and with my partner being pregnant, I wouldn’t wish her to have any exposure whatsoever to 1080. I assume no foreign national in her position would wish to be exposed to that risk either. (See MOH Guidelines p7 re known 1080 effects.)

I am disappointed that neither DOC, MSI Milford Sound Infrastructure, or MST Milford Sound Tourism NZ (the port operational company that operate the terminal and dock facilities) are planning to at least inform the tourists that the water they may drink in the terminal and on board the vessels may potentially have a birth defect causing agent in it.

It is probably true that signs will likely be erected along the road into Milford, as we have seen done in various locations around NZ. But it is wrong to conclude that because those signs are at rest areas etc, that foreigners will equate that with the drinking water supply inthe terminal and on the vesselsetc, as being also potentially contaminated. One must remember that many visitors can’t read English for a start, plus many come from areas where it is obvious that one doesn’t drink from any tap water.

Is it obvious here?

I would expect the duty of care and a minimum standard would mean that we’d firstly err on the side of caution. I would also assume that foreign governments would want us to set the minimum standard bar rather high when it comes to looking after the health and welfare of their citizens. As we would hope they do for our citizens when they’re abroad.

We know that the US and China for example, among others, take the safety of their citizens travelling overseas very seriously.

Do we need reminding that there is no antidote to 1080 poisoning?

It really seems easy to avoid the vast majority of the risks in this case. Just don’t drop 1080 in the water catchment area: meaning no 1080 to be aerially dropped in the Bowen River valley area of Milford Sound.

If DOC is so determined to go-ahead with the poison drop in the catchment area, then full disclosure to tourists should be made and an alternate drinking water supply offered (as per the model PHU statement example of 1080 in a public water supply).

It’s embarrassing that we call our country ‘Open and Inclusive’ ‘Clean Green’ etc and yet treat foreigners with this sort of disrespect.

I would like to add, I have no issue with the normal supply and delivery of water in Milford Sound. As long as I’ve worked here, MSI and MST have both operated with professionalism and worked to fix any issues with the greatest of haste.

A final point

If the aerial drop in the Bowen River catchment area is aborted, there would be no risk to the public water supply.

If you are concerned, please speak up and send your concerns to DOC and MSI.

Kind regards,

S Stevenson

Skipper – Milford Sound

Here is a link to the 1080 data sheet: Associated Information

 

Addendum

(Photo: S Stevenson on 31 July 2019)

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RELATED: EWR links to articles on 1080 in water. Search for other articles on 1080 poison at the categories drop down box at the left of the news page.

If you are new to the 1080 poisoning program, here is a good article to start with …

WHY ARE PEOPLE SO CONCERNED ABOUT 1080?

A must watch also is Poisoning Paradise, the doco made by the GrafBoys (banned from screening on NZ TV, yet a 4x international award winner). Their website is tv-wild.com. Their doco is a very comprehensive overview with the independent science to illustrate the question marks that remain over the use of this poison. There are links also on our 1080 resources page to most of the groups, pages, sites etc that will provide you with further information.

Check out the 1080 pages at the main menu, particularly the sub tab, ‘suspected 1080 poisoning cases’. Finally, remember what the retired MD Charlie Baycroft said recently …‘if you die from 1080 poisoning, nobody will know  because the Ministry of Health is bullying NZ Doctors into not testing for 1080′. EWR