Greetings:

I received this report today and thought it might be a wake-up call, particularly for those members of parliament who receive this email, to seriously think about the continual flow of untested chemicals into the environment. Surely there is enough combined intelligence in today's humanity to realise that now is the time to stop putting new chemicals into the environment until they have been fully proven to be benign to all life.

There is also the need to fully evaluate chemicals already in the environment but this is a difficult task as witness the problems the EU is having with its REACH proposal. Government has it in its power to prevent harmful chemicals entering the environment but has it the courage to actually do that. Certainly chemical companies exert power by virtue of political donations and other arm-twisting methods but why should they be allowed to decide what we humans and the rest of the environment have to accept.

This is a tough call and I am optimistic enough to believe that there are politicians, somewhere, that are aware of the need for action.

Are they in Australia? in one or more of the States? Or are we to increase spending on IVF treatments to counter the growing infertility. The attached report is not the only one to point out the problem and the causes. (Health report #398 was attached)

If it is believed that this matter is all hot air I give my address so that you can tell me so, and why.

Arnold Ward
82 Bonython Avenue
Novar Gardens SA 5040

With my regards

Arnold Ward

Australian Government

Mr Arnold Ward
82 Bonython Avenue
NOVAR GARDENS SA 5040

Dear Mr Ward

Thank you for your email correspondence of 8 November 2006 to the Minister for Health and Ageing, The Hon Tony Abbott, MP, concerning the responsibility of Government in ensuring chemicals are safe to use. The Minister has asked me to reply on his behalf.

The role of government is to provide a policy and regulatory framework to ensure the safe and sustainable use of chemicals. In this respect it is important that the health and environmental risks posed by chemicals are identified and adequately communicated and effectively managed:"

In Australia, a system of chemical safety assurance is achieved via a national regulatory framework that covers industrial chemicals, pesticides, medicines and food. The Office of Chemical Safety is responsible for human health risk assessment policy and practice within this framework.

For all chemicals new to the Australian market, there are extensive safety data requirements as well as a rigorous risk assessment process undertaken before they are approved for use. This process looks at identifying risks to human health and/or the environment and only allows access to chemicals that can be used and disposed of safely. Chemicals that are already in use (existing chemicals) are subject to priority review.

The Office acknowledges that some chemicals already in use can pose concerns due to insufficient knowledge about their risks to human health and/or the environment. This has called for a more proactive approach to achieve a higher standard of risk management. For example, the industrial chemicals regulator has recently completed a major review of the assessment program for existing industrial chemicals.

This review focussed on identifying new tools and approaches to identify and manage those chemicals that pose risk. The review recognised that biomonitoring and exposure information are integral to identifying risks posed by these chemicals. Further, the importance of public access to reliable chemical safety information was highlighted. These findings are supported by the Office of Chemical Safety and will form a valuable platform for us to continue to ensure chemicals remain safe for use in Australia.

In addition, Australia is signatory to a number of chemical treaties aimed at global control of toxic and persistent chemicals. These activities complement our national programs in eliminating those chemical that pose unacceptable risks.

Yours sincerely
Dr Margaret Hartley Director

Address: PO Box 100 Woden ACT 2606 Website: www.tga.gov.au/chemicals/ocs/
Telephone: 02 6289 3200 Facsimile: 02 6289 3299
8 December 2006

S.A. & M.A. Ward
82 Bonython Avenue
Novar Gardens SA 5040
29th January 2007

The Hon. Tony Abbott MP
Minister for Health and Ageing
Parliament House
Canberra ACT 2600

Dear Mr. Abbott:

Chemicals and Human Fertility

Although Dr. Margaret Hartley responded, on your behalf, to my email of 8th November, 2006, I appreciated receiving her letter dated 8th December. My purpose in again addressing yourself is that the nature of the reply is not satisfactory as it fails to take into account a number of factors which are within the competency of good governance to deal with. As Minister for Health it is your responsibility to ensure that the health of the Australian people takes precedence over most other matters since without a healthy population we cannot give of our best. I therefore submit the following for your consideration and comment.

Silent Spring by Rachel Carson was first published in 1962 and caused great indignation from the chemical industry such as "If man were to faithfully follow the teachings of Miss Carson", complained an executive of American Cyanamid, "we would return to the Dark Ages, and the insects and diseases and vermin would once again inherit the earth." Monsanto published and distributed 5,000 copies of a brochure parodying Silent Spring entitled "The Desolate Year" And 45 years later not much has changed, the chemical industry is still spewing out millions of tonnes of old and new chemicals and governments still refuse to accept that strong regulations are needed and that chemical companies must prove safety before marketing present, and new, chemicals. Referring to the executive quoted above, we still have the diseases, both more prevalently and in new forms.

From my knowledge of the situation, the only attempt at remedying the situation is the EU's REACH which has already been watered down because of protestations of the chemical industry.

The Coalition Government is certainly not ahead of world practice based on its present policies. One example is the Maximum Residue Limits set by the Australian Pesticides and Veterinary Medicines Authority (APVMA) for food and animal feedstuffs. As at December, 2006, there were 283 chemicals listed for use on foods - those used for animals and cotton have been excluded from that figure. Of the 283 there are 116 (41%) listed on the Pesticide Action Network site classified as Pan Bad Actor. That signifies one or more of the following for each one: - Known or probable carcinogen, Reproductive or developmental toxicant, Neurotoxic cholinesterase inhibitor, Known groundwater contaminant, Pesticide with high toxicity.

Two of them belong to the dirty dozen which are slated for removal on a world-wide basis. Aldicarb is one and the other, Parathion Methyl is noted by the APVMA as being phased out or experiencing further experimental work.

What I suggest is of concern in the letter from Dr. Margaret Hartley are the reassuring words that if chemicals inimical to health have not been taken off the market (is there a list?) work is progressing to achieve that. The bureaucracy and relevant government ministers are surely not that lacking in knowledge that people and the environment are allowed to be contaminated by harmful chemicals, on a regular basis. It must be a lack of will and lack of concern about those people and the environment that allows this situation to continue. There is a similarity here to the situation as it existed in the tobacco and asbestos industries until the health concerns finally reached breaking point. In all three cases governments were, and are, aware of the true situation but prefer to do little, if anything, to bring matters to a head. There is no excuse, whatsoever, in putting the health of the chemical industry ahead of ours and the environment in general.

Attached is Appendix "A" which contains a number of items of information on the results of contamination by chemicals. Arising out of those notes are a number of pertinent observations which the government should comment upon. Copies of any of the reports noted can be supplied upon request although it is quite likely that most, if not all of that information is already available within government sources.

Contamination of Water

It is reasonable to say that all chemicals put into the environment and that includes pharmaceutical drugs, personal care products etc., eventually enter into the earth's water. (1,11)

Chemicals in People's Blood

It is understandable that with the proliferation of man-made chemicals in the environment and over a very long period of time it is no wonder that our bodies are becoming polluted by them. Information arising from US studies indicate that more than 90% of US residents carry a mixture of pesticides in their bodies with children having higher levels of some pesticides.

The extreme prevalence of these mostly toxic chemicals, and perhaps they all are as they synergise with each other and are also additive in their effect in the body, can be verified by reference to the articles in the parentheses. (2,3,4,7,10,11,12,18,19)

Human Health

Rates of disease in the US have escalated since the mid 1980's ranging from 26% to 1,000%. As the chemical load is increasing it is not surprising that increases in ill-health have also occurred. Setting maximum residue levels in foods is an attempt to minimise the intake of chemicals but it can well be stated that government bodies that set the levels are most likely governed by the needs of chemical companies to sell their products rather than the need to protect human health.

There is enough research in the public domain to make it evident that some chemicals can affect the immune and hormonal systems even if the trace is as small as mere parts per trillion.

Setting maximum residue levels for individual chemicals is woefully inadequate because it is possible for two or more chemicals together to considerably increase their capacity to cause harm to the body. (2,5,6,7,9,13,14,15,17)

Obesity and Overweight

Fat cells perform the function of taking out of body tissues any chemicals which are not eliminated by the normal body functions. If bodies are subjected to increasing quantities of chemicals then it is a sine qua non that more fat cells will have to be created to remove them. Children are especially vulnerable in this regard because their smaller bodies and not fully developed systems would seem to indicate the need for a more rapid formation of fat cells. (8)

Hormone Disruption

Our bodies rely on hormones being in a healthy state and in a relative balance with each other. Unfortunately there is a class of chemicals known as hormone disruptors which can mimic natural hormones such oestrogen and testosterone. These then interact with the endocrine system, the resulting toxic effects having the potential to lead to reproductive and developmental abnormalities and cancer. (13, 14, 15, 17)

Chemical-free Foods

As would be expected, because organic foods are not contaminated with chemicals, which are allowed on most other foods, particularly those that are fresh, children who eat them have fewer chemicals in their bodies. (16)

If you are still unconvinced about the chemical problem I suggest you read the following, at least: -

• Silent Spring - Rachel Carson
• Our Stolen Future - Theo Colborn et al
• The Feminisation of Nature - Deborah Cadbury
• Quick Poison, Slow Poison - Kate Short

Closing Comments

In my opinion it is incumbent upon you to: -

1. State whether the information in this letter, plus the Appendix, is reasonably correct.
2. If the tenor of what is written is not factual then the errors should be identified.
3. Provide information that will indicate what steps you intend to take to remove those products that are at the root of the problem.

Trusting that you will provide a complete response concerning this very important factor in our lives.

Yours sincerely

S. A. Ward
Phone/Fax: (08) 8376 4445
Arnold1@chariot.net.au

Appendix A

A Selection of Various items of Information on Chemicals in General

1. Stuart Khan - looked at drugs prescribed in Australia in high enough concentrations - included antibiotic compounds, blood lipid regulators and non-steroidal anti-inflammatory compounds plus common analgesics. Western Sydney sewage treatment plant - checked what went in: primary treatment revealed significant concentrations in output - up to secondary treatment found variable removal. [Health #317]
2. Mount Sinai School of Medicine - evaluated nine adult subjects not working with chemicals - found 167 industrial compounds (average of 91 compounds) in the blood and urine. Included were breakdown products from organochlorins and organophosphate pesticides, PCB's , dioxins, furans and pthalates. These chemicals are associated with cancer, brain damage, hormonal disruption, birth defects, developmental abnormalities. Rates of disease in the US with potential links to chemical exposures have increased since mid 1980's - asthma(under 5's) 160%; autism 1,000% (1985-2002); hypospadias 100% (1968-1993); cancer in children 26% (1975-1999); testicular cancer in young men 85% (1973-1999). The American Cancer Society states only 5-10% of all cancer can be attributed to inherited factors. Survey notes that low-level exposures can be more harmful than high-level. [Health #348]
In 2005 Centers for Disease Control (US) found that more than 90% of US residents carry a mixture of pesticides in their bodies. Children had higher levels of some pesticides. Environmental Working Group tested foetal cord blood of 10 healthy infants born in various locations around the US. It revealed exposures to a total of 287 chemicals. [Health #357]
3. The Wall Street Journal, in a 4-part series in 2005 stated 1,800 brand-new chemicals released through commercial channels each year with no regulation. Series pointed out that some chemicals with traces as minutes as mere parts per trillion have biological effects. [Health #365]
4. Evidence that low levels of chemicals can cause greater effects than high levels at certain stages in life. [General #273]
5. A chemical mixture can be dramatically more harmful than an active ingredient. [General #273]
6. Synergy profoundly challenges traditional risk analysis calculation. [General #273]
7. Excess chemical build-up beyond what the body's detoxification pathways can cope with is diluted by creating fat cells to store them in. This could be one explanation of increasing obesity. [Ecologist Dec 2006 p40]
8. The National research Council of the National Academy of Sciences issued a report in August 2004 which contained this - "….studies of wildlife, laboratory animals, and humans, that many industrial chemicals, at levels already present in the environment, are currently interfering with hormones, causing problems in reproduction and development, the nervous system, and the immune system. Harm is happening now." [Health #094]
9. Express Newspapers 1999 contained this in a news report. "Express writer Lucy Johnston was shocked to discover that a single cell of her body fat contains hundreds of toxins….." Lucy's tests were only for pesticides. [Health # 107]
10. New Scientist 3/4/99 reported that most of the rainwater contains such high levels of pesticides that it is legally unfit to drink - the chemicals appear to have evaporated from fields. [Health #160]
11. A study released by the US Centers for Disease Control reviewed 27 chemicals found in a general sample of 5,000 men, women and children. [Health #162]
12. Environmental Health Perspectives (Vol 109. No 9, pg A420) contained this - "Endocrine-disrupting chemicals are among the most complex environmental health threats known today. By mimicking natural hormones such as oestrogen and testosterone, these chemicals can interact with body's endocrine system and exert toxic effects that may lead to reproductive and developmental abnormalities or cancer." [Health #238]
13. Cavieres et al. report in Environmental Health Perspectives (111:1081-5) that a commonly-used commercial mixture of 2,4-D reduces the litter size of mice exposed to low, environmentally-relevant doses. They found the largest reduction in litter size at the lowest dosage level used, which corresponded to the EPA's "reference dose", the concentration calculated on the basis of experiments to be sufficiently low to avoid adverse health effects. This was one-seventh of the "maximum contaminant level" allowed in drinking water by EPA Standards. NOTE: 2,4-D is an APVMA allowable chemical. [Health #239]
14. Extract from Proceedings of the National Academy of Sciences (US) 99:pgs 5476-5480 - "A vivid recent example is the discovery that a widely used herbicide, atrazine (permitted by APVMA), causes tadpoles to develop into hermaphroditic adults at a level of exposure approximately 30,000 times lower than traditional toxicological work had identified as toxic to frogs. [health #250]
15. "….new evidence shows that children who eat more organic food have fewer chemicals in their bodies PANUPS, January 31, 2003) [Health #254]
16. While paediatric endocrinologists have implicated pharmaceutical or personal care products for causing pubertal problems in children, some environmental scientists also claim that some widespread industrial and pharmaceutical pollutants harm the normal sexual development of fish and animals. By extension, they may also contribute to earlier or disrupted puberty in children, these scientists contend. Robert Kavlock, a senior reproductive toxicologist at the Environmental Protection Agency (US), said these concerns "caused a shift in worry from cancer to non-cancer" effects of environmental pollution over the past decade. [Health#399]
17. World Wildlife Fund (UK) National Biomonitoring Survey 2003 took blood samples from 155 volunteers in 13 locations. Tested for 78 chemicals - 12 organochlorines, 45 PCB congeners, and 21 PBDE flame retardants.
    Extract from findings: -
    • Every person tested is contaminated by a cocktail of known highly toxic chemicals which were banned from use in the UK during the 1970's and which continue to pose unknown health risks.
    • One conclusion was that UK and EU legislators and chemical regulators have not learned the lesson from past experiences of the adverse effects of persistent and bioaccumulative chemicals on people and wildlife. Current legislation is not adequate, since the use of such chemicals is still allowed. [Index #147]
18. The US Centers for Disease Control and Prevention issued its Second National report on Human Exposure to Environmental Chemicals in January, 2003. The report reflects the results of testing 9,282 people for the presence in their bodies of 116 chemicals, including pesticides. A 60 page report analysed these findings. It is noted that "Risk Assessment Doesn't tell the Whole Story". [Index #152]

S.A. & M.A. Ward
82 Bonython Avenue
Novar Gardens SA 5040
12 March 2007

Department of Health and Ageing
Office of Chemical Safety
GPO Box 9848
Canberra ACT 2601

Attn: Dr. Margaret Hartley

Dear Dr. Hartley:

Chemicals and Human Fertility

Thank you for your reply of 27th February which enclosed a copy of the Final Report December 2006 titled "Promoting Safer Chemical Use"

With regards to that report I would appreciate answers to the following:

1. What is the status of that report now?
2. Has, or is it, to be referred to another body for consideration and possible action? If so, which body?
3. If the recommendations are to be dealt with at some stage will the public be involved in the decision making?
4. Is there a timetable which will indicate what will happen and when?
5. Is there any ongoing testing of chemicals both individually, in mixtures, and in the product marketed? Glyphosate, for example, acts much differently in its status as a chemical and when it is included in a proprietary brand such as Roundup.

Your assistance in this regard will be much appreciated.

Yours sincerely

S. A. Ward

Australian Government

S.A. Ward
82 Bonython Avenue
NOVAR GARDENS SA 5040

Dear Mr Ward,

Thank you for your correspondence received on 16 March 2007 regarding Chemicals and Human Fertility. In response to your queries regarding the NICNAS Existing Chemicals Program Review report, I advise as follows.

Status of Report

The report by the Review Steering Committee was accepted in full by the Acting Director NICNAS and in-principle policy approval of all 23 recommendations was received from the Parliamentary Secretary to the Minister for Health. I am advised that NICNAS will now develop an implementation plan and strategy to assist in the process of putting the review findings into practice. The report has not been referred to another body. However as some of the recommendations were referred for action by the proposed COAG Ministerial Task Force on Chemicals and Plastics, the report will be sent to them when a decision is announced about the commencement on the Task Force meetings, noting that although the Task Force was in announced early 2006, they are yet to sit. Key stakeholders, including the community, will be involved in finalisation of the Implementation Strategy currently being drafted by NICNAS. The Implementation Strategy will include a timetable for implementation of the recommendations. The strategy will also indicate how the recommendations are to be implemented, eg impact on stakeholders, consultation etc.

Testing of chemicals

Whilst NICNAS does not test chemicals per se it does assess the health and safety information about a chemical in a desktop evaluation. Under Australian Chemicals regulation, all new chemicals and pesticides must have safety evaluations before they are introduced into Australia. Further, the regulatory system maintains an ongoing safety evaluation process through the formal review (or re-evaluation) of chemicals and pesticides already on the market. This process can be triggered through community concerns, the publication of new safety research and other information that may give cause for concern.

Should you have any further enquiries about the NICNAS Review, the contact at NICNAS is Bob Graf who can be contacted on 02 8577 8850 or 1800 638 528.

Yours sincerely

Dr Margaret Hartley Director
Office of Chemical Safety

3 April 2007
Cc: Mr Bob Graf; Team Leader Reform, NICNAS