Dear Institute of Environmental Science and Research Limited,

Re: The Priority 2 Chemical Determinands Identification Programme (P2) assesses drinking water zones for chemical contaminants (which include organic determinands - cyanotoxins and pesticides) of potential health concern. These then become P2 contamininants - 'determinands' and require monthly testing. P2 is administered by ESR and funded by the Ministry of Health.

I would be grateful if ESR would supply the following data:-

1. Results from the P2 Chemical Determinands Identification Programme for the 10 years 2006-2016 - or otherwise from when the P2 Programme commenced.

2. As this is a regional testing programme please include results by New Zealand region in order to understand which regions have been tested.

3. The pesticides (including fungicides/miticides/herbicides/insecticides) and their breakdown products that have been tested for under the P2 Identification Programme over the years 2006-2016 (and if this varies by region please include regional sampling data).

4. Testing methodologies used and LOD, LOQ, LOR for the pesticides that ESR has tested (this may be limited to the years 2013-2016).

5. All ESR authored analytical papers or reports concerning group-transgression of chemically-related groups that have common mechanisms of toxicity (Eg. not limited to but as an example, papers concerning the N-methyl carbamate, organophosphate, triazine, chloroacetanilide classes).

6. Information as to which water suppliers have separately undertaken reassessments to identify which contaminants should be tested for in the water, following guidance from ESR.

7. A copy of the questionnaire used in assessment on behalf of the Ministry of Health to help ESR identify those supplies where significant levels of a particular chemical are likely to be present - as per description in Priority 2 determinands section on http://www.drinkingwater.esr.cri.nz/gene... .

8. A list of all documents held by ESR that concern the Priority 2 Chemical Determinands Identification Programme.

9. Recent papers concerning emerging issues which may or may not include information concerning antibiotic resistance genes,

10. A list of all documents/reports held by ESR that concern testing of persistent organic pollutants (POPs) in drinking water

Yours faithfully,

J Bruning

Dear Dr Nokes

Thank you for your questions. It appears from your response that the Priority 2 Chemical Determinands Identification Programme operated from 1995-2004.

However I understand that responsibilities altered slightly but that the program still continues. For example the 2016 Guidelines for Drinking-water Quality Management for New Zealand document, on - Page 356 Chapter 9 advises ‘Priority 2 determinands are usually identified through the Priority 2 Chemical Determinands Identification Programme’.

Additionally, the Drinking Water Standards of New Zealand (revised 2008) (DWSNZ) advises that surveillance is based on the Priority 2 Determinands programme (Section 3.3.2 Page 20) and that the ‘assignment of a determinand to Priority 2 in a given drinking-water supply is based on surveillance monitoring and knowledge of the sources of health-significant determinands in the catchment.’

Perhaps I am incorrectly interpreting this?

Therefore, please can you consider that this OIA is a request for any data held with ESR related to screening New Zealand drinking water for pesticides and their metabolites. (The request is not limited as data/analysis/reports may contain information concerning chemicals other than pesticides and their metabolites.) Information may directly relate to The Priority 2 Chemical Determinands Identification Programme or a later iteration used by water suppliers and ESR.

To address your question concerning Request 1:
We interpret “results” here to mean all test results from the Programme during its period of operation 1995 to 2004. [“Results” in this context could also mean the “identification results”, that is, which water supply zones were assigned Priority 2 determinands and which determinands these were.]

Neither comment in the above paragraph conforms with my request. I request results after 2006 which may include raw data and analysis of drinking water sampling for pesticides and their metabolites used in New Zealand as per my original questions.

Results include data which may confirm that a pesticide or its metabolite is not present – but demonstrates that the pesticide and its metabolite have been tested for, and the frequency and levels of testing as per my original questions.

Request 8: “A list of all documents held by ESR that concern the Priority 2 Chemical Determinands Identification Programme.”

We interpret “documents” here to mean scientific reports to the Ministry of Health concerning the Programme, which are the only documents issued by ESR in relation to the Programme.

I consider my request to include scientific reports, papers, policy related information/emails and analysis (for example but not limited to: analysis of combined toxicities of an active ingredient and its metabolites or to understand combined toxicities of a group of pesticides in the one class that act through like pathways that may pose a potential health threat or to understand which new chemicals are present that are not listed in the DWSNZ - at environmentally relevant levels considerably below the MAV - which may have the potential to disrupt the endocrine system) performed in relation to the programme (or activities after 2006 based on the programme) that relate to the screening of pesticides and their metabolites in New Zealand drinking water.

I understand that ESR provides the data and analysis to the Ministry of Health concerning the Annual Report on Drinking-water Quality and that the ESR are the relevant party to make this request with in order to obtain data and analysis.

I understand that as a consequence of this information the Ministry of Health that specifies which determinands become Priority 2, requiring more frequent monitoring. This also in theory should enable the Ministry of Health to understand emerging chemical risks in New Zealand drinking water.

(The MoH Annual Report appears limited to reporting results from sampling of existing P2 determinands and does not appear to report on results from surveillance monitoring of health significant determinands in New Zealand catchments that may be potentially be of health concern.)

Finally, the 2016 Guidelines for Drinking-water Quality Management for New Zealand advises that ESR produces the Priority 2 and Priority 3 Chemical Determinands Identification Guide for the Ministry of Health. Please may I have a copy as the document does not appear available on the MoH Publications site.

I thank you for your help in this matter.

Best regards

Mrs J Bruning

Dear Jenny Beale,

I look forward to receiving this information on the 9th of May 2017.

Best Regards

J Bruning