FORMAL DEMAND FOR FUNDING AND DISCLOSURE OF THE EVIDENTIAL BASIS FOR GOVERNMENT SAFETY ASSURANCES

To the Minister responsible for Science, Innovation and Technology
Cc: Minister of Health; Minister for the Environment; Minister for Māori Development; Minister for Women; Minister for Children; Minister for Seniors; Minister for Disability Issues; Environmental Protection Authority; Ministry of Health; Ministry for the Environment

Dear Minister,

FORMAL DEMAND FOR FUNDING AND DISCLOSURE OF THE EVIDENTIAL BASIS FOR GOVERNMENT SAFETY ASSURANCES

I previously requested the scientific evidence relied upon by the New Zealand Government when asserting that the public and environment are safe from cumulative and combined exposure to chemicals, contaminants, medicines and other potentially harmful substances.

The issue cannot lawfully or scientifically be answered by producing a separate permitted limit for each individual substance.

People do not encounter one substance at a time. They are simultaneously exposed through drinking water, food, soil, air, household products, workplaces, medicines, vaccines, agricultural chemicals, industrial discharges, wastewater, plastics and other environmental pathways.

The relevant question is whether the Government has measured and assessed the combined, cumulative and long-term effects of those exposures in real people and real environments.

If that work has not been completed, the Government does not have an adequate evidential foundation for making comprehensive public-safety assurances.

Accordingly, I formally request that the Government fund an independent national cumulative-exposure and toxicity research programme, undertaken or overseen by our Science Council and supported by laboratories and researchers who are demonstrably independent of the agencies, manufacturers and industries whose products or decisions may be examined.

SCOPE OF THE REQUIRED RESEARCH

The programme must examine:

cumulative exposure to multiple chemicals and contaminants;

mixture effects, including whether substances interact, amplify one another or produce effects not identified when they are tested separately;

bioaccumulation in humans, animals, plants, soil, sediment and waterways;

low-dose exposure over months, years and generations;

endocrine, neurological, reproductive, developmental, immune, cardiovascular and metabolic effects;

drinking-water contaminants, including treatment chemicals, agricultural runoff, industrial contaminants, pharmaceutical residues and other substances entering water supplies;

pesticides, herbicides, fertilisers, veterinary products, PFAS, microplastics, heavy metals and industrial chemicals;

prescribed medicines and repeated or combined pharmaceutical exposure;

medical interventions, including COVID-19 vaccines, where long-term safety outcomes, repeated doses, different products, dose timing, known adverse-event signals and possible interactions with other medicines or environmental exposures require independent examination;

relevant post-market safety and pharmacovigilance information, including adverse-event reports, hospitalisation data and appropriately controlled health-outcome studies;

occupational exposure affecting agricultural workers, industrial workers, healthcare workers, cleaners, transport workers and others experiencing elevated or repeated contact with relevant substances; and

environmental effects on livestock, wildlife, pollinators, aquatic life, food production and ecological systems.

POPULATIONS WHO MUST NOT BE EXCLUDED

The research must be designed to determine whether exposure, susceptibility or outcomes differ according to:

age, including unborn children, infants, children, adolescents and older people;

biological sex and sex characteristics;

pregnancy, breastfeeding and reproductive status;

disability, chronic illness and immune status;

ethnicity and genetic or population-related differences;

socioeconomic circumstances and deprivation;

geographic location, including rural, coastal and isolated communities;

occupation and workplace exposure;

housing conditions and access to safe water and food;

gender identity, including transgender, non-binary and gender-diverse people;

medication use, hormone treatment and possible interactions between medicines and environmental exposures; and

other factors capable of producing unequal exposure or unequal health outcomes.

MĀORI RIGHTS, KNOWLEDGE AND PARTICIPATION

Māori must not merely be included as a demographic category after the programme has been designed.

The programme must provide for meaningful Māori participation in governance, research design, environmental sampling, interpretation and publication. It must recognise relevant mātauranga Māori, Māori relationships with whenua and wai, and the Crown’s obligations concerning Māori health equity, participation and protection.

Funding must be specifically available for Māori-led and kaupapa Māori research components, including research into whether Māori communities experience disproportionate exposure through location, occupation, water quality, land use, housing, deprivation or barriers to healthcare.

Pacific peoples and other ethnic communities must likewise be appropriately represented, with research capable of identifying distinct exposures and outcomes rather than concealing them within national averages.

FUNDING EQUITY

The Government routinely funds research according to health equity, ethnicity, culture, disability, sex, gender, age, geographic disadvantage and other stated public-policy priorities.

Cumulative chemical and environmental exposure potentially affects every one of those groups.

The Government must therefore explain why an independent programme examining a risk that crosses all of those categories should not receive commensurate funding.

This is not a request for token consultation or a small contestable grant incapable of performing the required work. It is a request for sufficient funding to establish:

an independent scoping and study-design stage;

a national baseline-testing programme;

properly selected population cohorts;

longitudinal health monitoring;

environmental and biological sampling;

secure access to relevant Government health and exposure data;

independent laboratory analysis;

Māori-led and community-led research components;

transparent peer review; and

complete public reporting of methods, results, limitations, conflicts of interest and raw data, subject only to legitimate privacy protections.

FORMAL INFORMATION AND FUNDING QUESTIONS

Please provide:

Every current Government funding stream under which this programme, or any component of it, may be funded.

The responsible department, Crown entity, research fund or decision-maker for each funding stream.

The applicable eligibility requirements, assessment criteria, available amounts, opening dates and closing dates.

Details of funding presently allocated to research concerning environmental exposure, toxicology, Māori health, Pacific health, women’s health, children’s health, disability, ageing, ethnicity, reproductive health, transgender health, vaccine safety and health equity.

An explanation of how an independent cumulative-exposure programme can access equivalent or combined funding across those portfolios.

Confirmation that the Government will fund an initial scoping study followed by a properly resourced national programme.

Confirmation that officials will meet with representatives of our Science Council to establish the research scope and funding pathway.

Identification of any Government-held datasets, biological samples, monitoring programmes or laboratory resources that can be made available.

The scientific evidence presently relied upon to exclude or control for cumulative exposure when establishing regulatory limits or issuing public-safety assurances.

All assessments addressing whether COVID-19 vaccination, repeated dosing or vaccine-related adverse outcomes have been studied alongside pharmaceutical, hormonal, occupational and environmental exposures.

The safeguards that will prevent interference by government agencies, manufacturers, funders or industries whose decisions, products or conduct form part of the investigation.

The Government cannot reasonably claim that these exposures are safe while withholding the underlying evidence, failing to study their combined effects, or leaving independent researchers without the funding needed to establish the facts.

Absence of research is not proof of safety.

A regulatory limit for one substance is not proof that numerous substances, acting together over time, are safe.

This correspondence is therefore:

a formal request for identification and disclosure of the relevant scientific evidence;

a formal request for disclosure of all applicable funding opportunities;

a demand for adequate Government funding of an independent national research programme; and

a request for an urgent meeting with the responsible Ministers, officials and research-funding bodies.

If any recipient is not responsible for part of this request, that recipient must promptly transfer it to the appropriate agency or decision-maker and advise me where it has been transferred.

Please acknowledge receipt, identify the coordinating official and provide proposed meeting dates within five working days.

I require a substantive written response within 20 working days. Any refusal to provide information or funding must identify the decision-maker, the statutory or policy basis for the refusal, the material considered and the available review or complaint process.

Yours faithfully,

Tracy Lynch
NOT A LAWYER
We Review the Crown