Letter written to the UK Committee on Toxicity in 2011 for their latest review of organophosphate science

The following is the text of a letter written for the attention of the Committee on Toxicity intended as evidence for their renewed review of the scientific papers that refer to organophosphate toxicity.

Interestingly via a Member of Parliament the writer was informed that the Committee members would not have sight of the letter until AFTER they had published their draft report.
That draft report suggested that the evidence was not conclusive and that further research was needed and yet many of the members were part of the Medical Research Council, the very body that advised Lord Solly Zuckerman's Committee before they reported on the dangerous nature of the "Deadly Toxins" to the then government in 1951.

The following was addressed to the Committee on Toxicity "Review of the Literature on Organophophorus Compounds and Effects" and was sent by email to the COT Secretariat at the Food Standards Agency to cot@foodstandards.gsi.gov.uk on 3rd March 2011

Dear Sir/Madam,

Please ensure that all members of the Committee on Toxicity, and not merely the Chairman, have sight of this correspondence. Thank you.

I understand that the Committee on Toxicity is currently undertaking another review of the publications regarding the effects of the organophosphorus chemical group on human health.
I sincerely hope that on this occasion any resulting report will not shirk the duty to confirm the long-known long-term adverse effects of such chemicals. I suggest that these effects have long been known and understood, as admitted by the former Chairman of the COT in a recorded interview with one of a number of people still suffering from exposure to OP Sheep Dips.
His admission should come as no surprise since publications intended for use by students as they are being taught biochemistry have been employed by Universities for decades.
In addition, no less a person than the then Deputy Chief Medical Officer herself confirmed in personal communications that when the COT last deliberated on this issue they were in possession of the raw data upon which the Industrial Disease pension known as Prescribed Disease C3, Causative Agent 4 (Chemical group 3, poisoning by organophosphorus pesticides) was based when it was introduced into law in 1958.
I am aware that the Chairman of COT has taken part in a review of Industrial Diseases with the intent to limit the criteria for granting the pension to only Phossy Jaw and Peripheral Neuropathy and has himself, in personal correspondence, denied that the paper states as it does under “Irreversible inhibition of acetyl cholinesterase. At high doses the action of other enzymes may also be impaired. Organic phosphorus compounds may be ingested, inhaled or absorbed through the skin. Absorption through the skin is rapid. Repeated absorption of small doses is cumulative to a point where a slight additional uptake is sufficient to cause an attack of poisoning” and under “Exposure to organophosphorus pesticides. This may be as a single high dose or repeated low dose exposures.” and further that “Exposure to toxic doses of organo-phosphorus pesticides. Normally recovery after acute poisoning is complete but in some cases there are late onset neuropathic and neuro-behavioural disorders. They are not inevitable and they seem not to occur without previous cholinesterase inhibition.” Those who receive the timely antidote are lucky.

But, as every well-trained student will know, cholinesterase inhibition is a relatively minor adverse effect of these chemicals and measurements of cholinesterase levels merely indicate that there has been exposure or that the person tested is genetically susceptible, and that again indicates the failure of the COT to properly address this vitally important issue.
In the publications mentioned above on “Organophosphorus Chemistry” provided to students, (I will quote from just one by B J Walker, who has published many articles on the subject), it is clearly stated that not only do the chemicals interfere with energy production as controlled by the mitochondria but they also damage the various forms of RNA and DNA. This should be unsurprising as the structure of DNA is based on naturally occurring phosphates and the OPs are known to act at the phosphorus atom where they replace the naturally made substrates and cause their dependent essential processes to fail, potentially resulting in cascade effects that may cause serious illness many years later.
The COT should address the question as to who was responsible for deliberately ignoring all the above knowledge when they produced the earlier report, which was then used by the manufacturers and others to undermine a £multi-million legal action in the High Court.
This sets a very dangerous precedent, as I am sure the Cot will understand.

But the problems with these chemicals do not stop there. As the above mentioned legislation states OPs can trigger the following symptoms -
Early. Headaches, giddiness, nausea, fatigue, blurred vision.
Late. (2-8 hours) abdominal pain, cramp, vomiting, diarrhoea, sweating, sphincter paralysis leading to urinary and faecal incontinence.
SIGNS - Hot dry skin, constricted pupils, tachycardia, pulmonary oedema, muscular fibrillation.

Please note again that these symptoms and signs are admitted to be caused by single high dose or repeated low dose exposures, and that not all those so exposed may recover.

It would be easy for the COT to simply state that such effects are merely due to acute poisoning but that again ignores the far greater, and known, cumulative dangers from this chemical group.
All processes in the body depend on the basic and relatively simple, but highly efficient use of, specifically shaped chemicals that fit only in the intended receptor sites. Protein creation, and enzyme blocking or bonding mechanisms are the basis for all these reactions and there are few, if any, chemicals that have only one effect while impurities and isomers may be even more dangerous.
Proteins carry information in their shape and chemical structure: change either of these and you change the information carried by the protein… Nature’s favourite way of changing the shape or chemical structure of a protein is to stick a phosphate group onto its surface or to remove one …

Poisons such as the OPs contain chemicals that are so similar in molecular shape to those vital natural chemicals that they can also bond to key receptors potentially causing serious failures.
The following list illustrates just a few of the hundreds of substances that may be adversely affected by organophosphorus chemicals. By far the majority of those are dependent on, or are themselves compounds that contain, oxygen and phosphorus bonds and are therefore extremely susceptible to substitution in vital processes by organophosphorus compounds. Such chemicals can break down to release stored energy, often as heat, and harm further essential processes. Once the vital building processes are damaged the result can be abnormal protein formation and imbalance in vital substrates within the body, including hormones, the action of which is dependent on cAMP (cyclic adenosine monophosphate), which is in turn dependent on ATP/ADP energy transfer.

There are literally hundreds of natural targets of OPs including arginine, arsenate, aspartate, biotin, carbamoyl phosphate, carnitine, choline phospholipids, cobalamin, creatine phosphate, cytidine diphosphate, cytidine triphosphate, dimethylallyl pyrophosphate, diphosphoglycerate, dopamine, erythrose phosphate, farnesyl pyrophosphate, fructose diphosphate, galactose phosphate, glucagon, glucosomine phosphate, glucose phosphate, glutamine, glyceraldehydes phosphate, glycerol phosphate, glycine, glycogen phosphorylase, glysine, guanosine diphosphate, hexose phosphate, histidine, inosine monophosphate, insulin, isopentenyl pyrophosphate, lactase, lecithin, methionine, mevalonate pyrophosphate, niacin, nicotinamide phosphoribosyl transferase, norepinephrine, nucleoside diphosphate, ornithine, orotidine monophosphate, pentose, peroxidase, phosphatidate, phosphatydilglycerol, phosphoenolpyruvate, phosphogluconate, phospholipids, porphyrin, proline, phosphoribosyl pyrophosphate, prolactin, proteolitic enzymes, purine, pyridoxal phosphate, pyrimidine, pyrophosphate, pyruvate, retinol, riboflavin phosphate, ribose phosphate, secretin, serine, serotonin, somatotropin, sorbitol, squalene, testosterone, thiamine pyrophosphate, thymidine, triose phosphate, ubiquinone, uracil, uridine diphosphate, xanthine, xanthosine monophosphate, xylulose phosphate and a host of other intermediate substances.

Once bound to the correct receptors the next process can take place and other chemicals may be added to form whatever product is required by the particular body function upon which the process depends. There are complex interactions and back-up processes that protect from damage to those systems - up to a point.
From that position it is necessary to ask why the COT failed to acknowledge the serious risks from the chemicals that damage the vital mitochondria, as the regulators themselves confirmed in personal correspondence many years ago. This time the chemical in question was yet another organophosphorus compound, the phosphonic acid glyphosate, and the information supplied to me stated that the chemical damaged the mitochondria at all dose levels tested. Why did those who provided that information not realise the harm to human health caused by such damage?

The mitochondria, as the COT must know all too well, are vital for our survival and involved in all cells and all processes in the body including protein, RNA and DNA transcription. Just a few of the illnesses that have been linked by science to mitochondrial damage are included in the following quote

Since the first mitochondrial dysfunction was described in the 1960s, the medicine has advanced in its understanding the role mitochondria play in health and disease. Damage to mitochondria is now understood to play a role in the pathogenesis of a wide range of seemingly unrelated disorders such as schizophrenia, bipolar disease, dementia, Alzheimer's disease, epilepsy, migraine headaches, strokes, neuropathic pain, Parkinson's disease, ataxia, transient ischemic attack, cardiomyopathy, coronary artery disease, chronic fatigue syndrome, fibromyalgia, retinitis pigmentosa, diabetes, hepatitis C, and primary biliary cirrhosis. Medications have now emerged as a major cause of mitochondrial damage, which may explain many adverse effects.

I would add autism and cancers to that list since the former has been confirmed by the Courts in the USA and the latter is linked to failure of apoptosis (programmed cell death), which itself is dependent on properly functioning mitochondria. The COT will surely have noticed the correlation between the symptoms and illnesses listed above and those of OP poisoning. The link is obvious and numerous published scientific papers have demonstrated those links. It is certain that the COT, both now and earlier, has been given free access to all those papers so the denials of knowledge and calls for more research are at odds with the fact that all these issues have been known for decades – and reported to the COT.

But the problem with organophosphates does not stop there because the chemicals are known to be highly lipophilic and to target the brain and its functions via the so-called blood brain barrier,which is actually no barrier to such chemicals. The damaging effects on proteins and the mitochondria should be enough to send warning shock waves through the regulatory system but for some reason complacency rules - but there is a potentially even more serious problem, again supported by scientific investigation.

The poisons may cause serious changes in the proteins and enzymes of the Cytochrome P-450 system and there is ample evidence to show that chemicals that are detoxified by this system can actually render the human body in excess of a 40-fold increased susceptibility to other toxins and prescription drugs. Although “experts” will dismiss the effects of chemical sensitivity this serious health problem is known to be triggered by these chemicals and others. High on the list of the products that pose a danger to those exposed to the OP chemicals are the anti-psychotic, heart, certain pain relieving, and anti-asthma drugs, which have been admitted to worsen symptoms in those poisoned by OPs. The very system that is there to protect the human body may even make the OPs more toxic especially when the person exposed has one of the recognised “Genetic Flaws”, which may actually be simply errors in protein coding triggered by earlier exposures.

In failing to recognise these risks the COT and the regulators have condemned many thousands to worsening health outcomes and expensive treatments that may make matter worse, despite awareness of this effect dating back decades. How did the COT overlook these matters in its earlier deliberations, especially when untrained individuals like myself were able to point them in the correct direction?

Furthermore it has become clear since the last COT review that the claim that organophosphates break down rapidly in the environment is simply not true for the formulations used for commercially available products. Parliamentary answers admitted that the active ingredients are protected from degradation in the formulation. If the issue is examined carefully it will be realised that the data supplied by the companies in regard to safety are mostly based on the almost pure active ingredient and that no authority bothers to check that data for accuracy. The system is open to abuse and has been encouraged in the past by the regulators themselves who have suggested to the manufacturers that they should use less susceptible genotypes of animals in tests because too many died before testing is completed. >p> Surely that alone should warn of problems to come but no.

Even when independent analysis by laboratories, who clearly state that their techniques would hold up in any court of law, demonstrate that rapid breakdown claims are entirely misleading, there is still no attempt by those responsible for safety to check the figures.

This represents a gross breach of duty - but the COT was informed at the last review.

The above refers mainly to the active ingredient, the organophosphate itself, but as mentioned already other chemicals in the formulations may be exceedingly toxic in their own right and may have equally dangerous combined effects with prescription drugs. Again many of these have been linked to causing serious illness such as leukaemia and Non-Hodgkin's Lymphoma. In fact a paper from the USA from the 1970s listed the illnesses as being recognised occupational hazards for grain workers in US agriculture. This may well be due to mitochondrial damage but it has been known since the 1950s that Benzene is a chemical that causes this problem, probably because once in the body it migrates to the bone marrow in which it may reside for a very long time. Even from that period in scientific history it was known that the key to toxicity of any chemical is NOT the chemical formulation but the molecular shape of the toxin. With organophosphorus insecticides the human body has to face a dual attack from both the oxygen and phosphorus bonds in the chemical and the benzene rings, making them even more acceptable to the metabolism. The COT must be aware of this since the drug and pesticide manufacturers have used these properties for a very long time so as to enhance efficacy. The information is to be found in standard text and reference books and so it is difficult to see how the COT was able to deny that knowledge.

The long held suspicion by those who have suffered the dreadful effects of these chemicals on their health, their lives and that of the families, friends and even their employers, is that the COT deliberately found excuses to enable them to dismiss any scientific paper that confirmed the effects of the poisons.

Since the last report every effort has been made to limit the chances of the truth escaping to the public, which is fed these poisons daily, with concerted attempts to imply that the symptoms have been induced by state of mind, fear even of pesticides and veterinary products that the users were happy to handle for many years until they finally succumbed – the very repeated exposures recognised to cause such effects.

Such efforts are in fact grossly fraudulent, as described in the Fraud Act of 2006. It is an offence to imply mental illness so as to cause the victim loss. It is more of an offence when the victims have scientific evidence of exposure and the physical damage caused and yet that very damage and evidence is dismissed in favour of a suggestion of mental illness. I submit also that this situation is not limited to organophosphorus chemicals but is seen in cases of poisoning by many other approved products.

I would further suggest that the COT must act in the Public Interest, which requires of it to act on issues that include but are not confined to:
exposing or detecting crime.
exposing corruption or injustice.
disclosing significant incompetence or negligence.
protecting people's health and safety.
preventing people from being misled by some statement or action of an individual or organisation.
disclosing information that allows people to make a significantly more informed decision about matters of public importance.

I have every confidence that I have not supplied in this correspondence any information that is not known by the COT, either at this time or during the earlier review.
However the COT has the opportunity now to put matters right and to admit to the vast volume of research from all around the world that supports those who have expressed serious concerns about the terrible effects on their own health and lives and those of their friends and family and I would respectfully suggest that the COT ensures that what they know is broadcast to the regulatory bodies around the world so as to undo the damage done to so many innocents who have believed the false propaganda found in numerous publications since the last COT report on Organophosphates and related chemicals.

Yours sincerely,

Dated 3/10/2013

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