Comments on the Royal Commission on Environmental Pollution Meeting of 25th September 2004.

10th January 2005

To the Royal Commission on Environmental Pollution

I am probably far too late to make comments about the meeting on 25th September but I have only just received the audio recordings and I feel that I should comment.

I will not refer to the names of those who made statements to avoid giving the impression that I am criticising any individual.

1. “No one wants to use pesticides”
I have already suggested that this statement is not true. Modern agriculture and horticulture are both addicted to pesticide use. Certain techniques for growing crops such as the much advocated but flawed “minimum tillage” system are designed around pesticide use. Good ploughing was always considered as the way to control weeds and diseases from the previous crop. Unless the residues from that crop are buried properly there will always be a greater need for pesticides in the following crop.
Farmers and others are also hoping to introduce GM crops into the UK and these are designed to ensure pesticide use. Reports suggest that pesticide use increases with GM crops because resistance to both insecticides and herbicides develops.

2. Pesticide users are regulated and are responsible
The problem here is that because the regulations are rarely enforced operators “take chances” in order to get the work done. I was surprised to hear contractors say that they always stop work in adverse weather conditions. Way back in the 1960s I worked on an 1100-acre arable and stock farm and even then it was hard to find enough days when conditions were absolutely right for spraying. In those days far fewer pesticides were used and yet we needed a sprayer with booms 60 feet in width. They were mounted on a tractor with no cab and the drivers were never offered or provided with protection even though the booms folded back over the rear wheels on either side of the driving seat. The chemicals, we were told, had been tested and proven to be “safe” and so there was no need for any protective clothing.
We had our own sprayer and could take every available day to do the necessary work and yet in some years it was still difficult to find sufficient time.
The comment that contractors do not push the barriers of safety stretch credibility because contractors cover the work of many farms and apply far greater quantities of pesticides, more frequently, than ever before. The time available to do all that work in suitable conditions must be restrictive and perhaps that explains why I have seen them working in strong winds and even in the rain on waterlogged fields.
Interestingly at this very time I understand (and this is in confidence) that a local farmer has received letters from the Health & Safety Executive regarding a problem with over spraying of a crop. What is interesting about this is that it is thought that the reference is actually to crop damage on the same farmer’s land caused by drift from contractors on neighbouring fields owned by another farmer.

3. Things have improved in recent years - and we have the sprayer MoT test
When I heard this said the comment reminded me of a criminal who protests that he has changed his ways only when his collar is being felt by the Police.

The cumulative effects have damaged most of those injured by pesticides over decades of exposure.
It is simply not good enough for claims to be made now that methods are improving, especially when they are doing nothing of the kind. There is a propaganda campaign at work to imply improvement.
A yearly MoT test means nothing – especially with sprayers covering ever more acres in a year.
Even on the Dairy, Beef and Arable farm that I managed we used a small sprayer with booms 24 feet wide and maintained it far more than once a year. As with cars the MoT is worth nothing except on the day it was issued. After that certificate is issued pipes can be damaged, control systems can become faulty, chemicals and operators can change and nozzles can wear. All these can lead to problems with pesticide application and can have a detrimental affect on drift and the safety of neighbours.

4. Boom height is carefully controlled to reduce spray drift
When we first saw the 60 feet width of that first large spray boom we said that it was never right and that it would never work because it would be difficult to maintain the correct nozzle height above the crop.
Despite the fact that the booms had special “skids” to prevent them hitting the ground there was nothing preventing the other end from rising many feet in the air on uneven ground.
In practice that is precisely what happened and there is very little difference with the modern machines, which often have even wider booms.

A further complication is the height of the field when compared to local dwellings and the roads where bystanders may be exposed. Locally many of the fields are several feet above the roads with high banks that can place the booms at roof level to houses not a hundred yards away.
Many villages are in valleys with sprayed fields many feet above them. It is inevitable that the spray drift, and the vapours released many days after spraying has taken place, will move down the slopes and that levels of those contaminants will build-up around and within the dwellings.
I have reported an experience I had in our local church when I attended the funeral of a good friend who had died with cancer. I remained in the Church while the family went to the graveside and I could taste pesticide on my lips. Later that day I discovered that spraying operations were taking place on the hills a mile and a half from the village. I have had reports that some people sensitised to pesticides have experienced effects of the exposure some 11 miles from the operation and have traced the source in order to confirm their suspicions.
No testing in wind tunnels on level ground will ever indicate the correct level of drift from sprayers applying pesticides in field conditions. Theory is one thing but reality is something else.

5. The Public’s “Perception of Risk”
What intrigues me is how the risks have been so easily dismissed by those who do not wish to have pesticide use restricted. As sprayer operators various employers repeatedly told us that the pesticides were proven to be safe and that there was no risk at all to our health. We were, in those early days, never provided with any protective equipment. In fact a friend who had worked for a major spraying contractor during an earlier employment moved here to work for another contractor. His duties again included pesticide application and he asked for a mask to protect his lungs only to be given a Perspex face shield. He laughed about it but clearly the provision of the correct safety equipment is a serious matter.
Amazingly the requirements for protective equipment for those “safe” pesticides has increased dramatically in recent decades to the extent that modern applicators use induction systems that allow them to handle large quantities of chemical without any risk of exposure from either the concentrates or the task of rinsing the containers. The risk of exposure to the sprayed pesticide is still the same however and I know of some cases were farmers sensitised to pesticides have become ill simply through entering recently sprayed fields. I wonder why it is assumed that the pesticide is dangerous before, during and even at the nozzles in spraying operations but suddenly is said to be “safe” when it reaches the crop where the main toxic action is intended to take place or when it drifts in the air before reaching that target?
I understand that sprayer operators are now being advised to wear blue protective clothing rather than the normal white in an attempt to persuade the public that there is no risk. Such deception should be discouraged because if there were truly no danger there would be no need for any protective clothing.

We are told that workers and public alike see chemicals being used and then imagine the symptoms.
While there may be some small measure of truth in the fact that many who do not understand farming see a sprayer in the field and become fearful of what might be being used this is usually because they have already had bad experiences following exposure. Why else would they be afraid since all say it is “safe”?
A case in point concerns sprayer operators who are given data sheets which supposedly list the expected symptoms. Most report that there should be no adverse health effects in normal use. The operator is therefore under the impression that the chemicals are perfectly safe and present no risk.
In my own case I experienced symptoms on every occasion that I used the organophosphorus insecticide Actellic D (active ingredient pirimiphos methyl) in grain stores and barns. I could never understand why I suffered with headaches, respiratory problems and accompanying diarrhoea when using it and simply put it down to a summer “bug” of some sort. As years passed the association with the chemical began to appear obvious but the symptoms began to involve tachycardia and visual disturbance, running eyes, streaming nose and cold sweats. They didn’t last long and never resulted in time off work but suspicions grew even though the data sheets reported bradycardia rather than the rapid heart rate experienced.
Only years later after my health was destroyed completely did I discover that all the symptoms I had experienced, including the tachycardia, were known to be caused by the chemical.
At least four other sprayer operators locally have suffered similar problems. One has bone density problems – another known result of exposure not listed on the labels. Another has late onset diabetes and left agriculture before the pesticides worsened his health still further. The symptoms of diabetes are also not listed on the labels but there is official acknowledgement of a link with pesticides in MS 17.
Another sprayer operator had a stroke and suffers serious heart problems. He also had to leave farming.
Another is a very young man who became very ill after spraying as a contractor a couple of years ago.
He was warned to avoid using pesticides. He has a particular problem with some potato blight chemicals.
After avoiding these chemicals for years he then treated a grain store with pesticides and became very ill.
Apparently his character has changed. This is yet another known symptom of pesticide exposure, which is never reported in the data sheets. Amazingly many of us are trusted to recognise and treat the symptoms in hundreds of animals under our care but when we report symptoms in ourselves we are never believed.

6. Workers are better protected than the Public
From the above it should be clear that it is wrong to suggest that workers are better protected than the public. In theory they should be – and they should have the right to know what pesticides they are exposed to by law. In practice, because the regulations are rarely enforced the workers are no better protected than the general public. Many live in the same villages and most eat the same sort of food and drink the same water and as a result those workers who live near fields regularly treated with pesticides are often exposed to higher levels of toxins than the general public.
It is therefore likely that operators are more at risk of poisoning and that is perhaps why the authorities are so determined to deny poisoning in agricultural workers.
I can almost hear those who would suggest that this means that there is less of a risk to the public giving out cheers of relief in the assumption that the suggestion indicates safety to the public.
I am afraid that they could not be more wrong. Workers are adults and usually very fit. I certainly was before pesticides poisoned me. Members of the public may be elderly, and many will be taking contraindicated prescription drugs, which can trigger dangerous reactions in combination with pesticides. Many will be pregnant women and exposure to pesticides presents known risks to the unborn and developing child. Children are also more vulnerable to much lower doses of pesticides and they do not understand the risks of playing in recently sprayed fields or eating food with contaminated hands.
How are they to know what risks they are taking when they are not permitted to be told what chemicals surround them in the fields and in the air they breathe? How will they prove exposure and causation?

At this point I would remind the Commission that I am personally still trying to gain official recognition for a poisoning diagnosis that has stood for over 12 years. I was denied access to information about the chemicals involved, denied copies of the full medical records and denied the required funding to prove my case in the Courts because to do so would have demonstrated the deception involved in numerous Government departments. In fact an Employment Medical Advisory Service doctor was encouraged by a senior Health & Safety Executive staff member to undermine my legal action. There is written evidence.

7. Pesticide related ill-health is monitored
If only this was true. In my experience and that of many other people every effort and every excuse, no matter how feeble, is used to avoid recognition of any ill-health caused by pesticides.
It would appear that this is the combined result of the system used to finance those in key positions and the close relationship between the medical profession and the chemical industry.
I asked the Department of Health many years ago to confirm which toxicologists they employed directly and which were sub-contracted from the chemical and drug companies. They refused to answer.
My understanding was, and is, that no toxicologist in the NHS is independent of the chemical industry.
That perhaps explains the reluctance to answer the question.

As a speaker at the meeting said we have had serious problems with pesticides here on the Isle of Wight but it is very rare for any case of ill health to be officially recognised as caused by pesticides.
My own experience, as one of the more exposed groups, appears to be typical of that found in numerous other cases across the UK, if not internationally.
If workers exposed on a daily basis, and exposed to illegal pesticides, cannot get official recognition for the true cause of their disabilities then what chance does a member of the general public have?
There are obviously serious flaws in the procedures used in the post-marketing monitoring of pesticides.
I understand that the Pesticide Safety Directorate and the Health & Safety Executive have the responsibility for reporting adverse effects to the manufacturers. It is fairly obvious that if the manufacturers receive no reports of adverse effects then they will assume that their products are safe.
In attempts to improve efficacy of pesticides it is very likely that they will assume greater safety margins than actually exist and increase the strength of their products. The likely result is that there will be increasing reports of ill health in the public and more suspicion that the authorities are hiding the truth in order to protect the reputation of the regulatory bodies, which licensed the products as “safe”.

Many years ago I suggested that there should be a two stage reporting system for all chemical related ill health but it seems that it was not thought practical. My suggestion was that all suspected cases in which chemicals were possibly a cause should be reported as a first-stage of the monitoring process.
That first stage should include a short report giving the situation of exposure, (e.g work, domestic, public place), the suspected source of the chemical, the use of the chemical involved,(e.g. household, at work, or applications in public spaces or in agriculture), the type of chemical involved. and the initial symptoms.
If exposure and the cause of the symptoms are confirmed the case would then enter a second stage where more details and any developing symptoms are also recorded. At that stage the regulatory authorities should take steps to ensure that any prosecutions for regulation breaches that might be necessary are enacted and that the manufacturers are informed of the adverse reactions to their product.
I suggest that the next phase should be to monitor the health of all the confirmed cases in order to establish any long-term effects of the exposures and to ensure that any chemical confirmed to have caused lasting effects on health should be immediately withdrawn from the market.
It was good to hear a speaker at the meeting suggest that the first stage could be done at the press of a button. This is certainly true now that most GP surgeries are linked to the National Health Service database and the records of the patient have been stored on computer systems.
Automatically any suspected pesticide related illness can be added to a central database and this can give an early indication of trends with the most dangerous pesticides peaking obviously at a very early stage.
Currently - as a speaker suggested at the meeting - farmers are literally dying to produce our food.

At this late stage monitoring will not protect the public. The damage has already been done and continues to be done. Until we can ensure that no pesticide can cause ill-health even at very low exposures with subtle damage to cells that takes place at levels far below the No Observable Effect Levels then the public should be protected from all spraying operations near their homes, schools and places of work.
If regulators had ensured that pesticides were safe before they were approved we would not be going thorough this expensive and time-consuming process now. There would be no need.

8. Can epidemiology be used to determine pesticide related illness?
I fear this process is fraught with danger because:
a) we are not referring to a static population,
b) the number of chemicals used is large,
c) the type of chemical is often unknown and damage can be caused even before birth,
d) There is not even a recognised level at which unobservable but dangerous changes are caused within the exposed person. Such effects could happen with a single exposure to a visitor to the area who may never visit again or they could be triggered by repeated low dose exposures to a resident who may then move from the area, or may even move before they become unwell.

When I collected my list of people linked to this village and to farming it very soon became obvious that people who had lived here but had then moved on had also suffered with adverse health effects. In fact some who had been ill when they lived here had their health actually improve after they moved away.
I am not an expert in epidemiology and I do not have the access to official statistics that such people would have but I cannot at present see any means by which the historical connections between pesticide exposure and ill-health can be established by this method. It has for example failed to link pesticide with reported ill-health in the famous Boswell case here on the Island even though it was the reports of ill health caused by pesticide use that triggered the investigation in the first instance. This despite the use of blood and urine tests in one case that showed the presence of pesticide metabolites after the exposure.
It seems to me that those who promote epidemiology as a reliable indicator are often already of the opinion that pesticides do not cause injury and that the safety levels are adequate.
Such built-in bias is very unlikely to find the root cause of any problem and the involvement of these individuals should be discouraged. It was claimed for many years for example that antidepressants did not induce suicidal tendencies but only recently papers have been produced in which the manufacturers admitted to knowing the truth. Similarly papers were published showing that the regulators had written to the manufacturers of Sheep Dip warning that their products had not been properly tested and that they should be withdrawn from the market but those papers were not released for many years during which the risks were rigorously denied and increasing numbers of shepherds were harmed.
Epidemiology requires accurate figures if it is to produce meaningful statistics but we know from the admissions of the Committee on Toxicity that the reporting system is grossly flawed and that pesticide poisoning is underreported. Even if we are lucky enough to get a diagnosis, and some form of treatment, it is highly unlikely that our cases will appear on any official record of poisoning. The Pesticide Incidents Appraisal Panel reports many cases as undecided but we are not to know if those cases are ever followed up or if errors in their conclusions are ever corrected. There are no checks and balances to ensure accuracy or the honest appraisal of any case. My own case has had the diagnosis of poisoning since 1992 and yet the PIAP refused to recognise that diagnosis by using false information from the HSE.
All officials involved refuse point blank to recognise the facts of the case. Mine is not the only case in which the facts have been twisted to allow the poisoning diagnosis to be ignored.
Without accurate data epidemiology is useless.

9. Scientific modelling
It seems to me that most exposure limits are based on calculations which are themselves formed from assumptions which may not be founded in reality. There are theoretical levels of exposure, theoretical absorption and excretion rates, theoretical half-lives, and theoretical levels at which damage occurs.
In some cases the safe level is measured from the level at which symptoms may be observed but serious, invisible, harm can be done at levels much lower than those that cause measurable effects. In addition animal tests will never establish points at which humans feel different effects which they can describe but for which no physical testing procedures are available. The scientific data for the chemicals themselves may be flawed, as I discovered with the commercial formulations of pirimiphos methyl. The science of any mixtures used may not be known at all – as I discovered in my own case.
We should hope that if the modelling predicts that no harm will be done but practical experience suggests that there are cases of poisoning then someone would re-think the model, but that is exactly where we are today and, instead of questioning the model, officials claim that the public is mentally ill and imagines the symptoms experienced after exposures. That is a disgraceful stance to take on such a serious issue.

10. Legal issues
When I was sent to the toxicologists in London for testing in 1993 I was handed a questionnaire in which I was asked if pesticide regulations needed strengthening. My written comment was that they did not but what was required was for the current regulations to be enforced. Sadly even today, some 12 years later, we are still in the position where there are a whole host of regulations and legal requirements backed up by voluntary codes - and those using pesticides can freely ignore most of it.
It was interesting to hear the speaker who said that the lady whose prized trees had been killed by pesticide drift should be compensated. I hope that the Commission members noted that there was no doubt in the speaker’s mind that the drifting pesticide had been toxic to the plants, that it was wrong to have allowed the drift, and that it was correct to compensate for the damage.
I hope too that the Commission will, as I did, wonder why plants are more important than human health.
Are we seriously expected to believe that pesticides that can and do harm human health are freely allowed to drift into homes and on to other people’s property but those that can harm plants must not cross field boundaries?
Should we believe that chemicals hazardous to humans become less hazardous in drift than do herbicides?
Do we really feel that people who are injured should not be compensated but that any losses due to dead plants in their gardens should be made good? Presumably the dead plants did not imagine the exposures?
Why is it that there is more chance of being prosecuted if pesticides are used to harm wildlife or other people’s plants than if a neighbour’s or worker’s health is adversely affected?
All comments assume that farmers and operators always comply with regulations. They don’t.

From my standpoint it seems as if property and investments are considered more important than human health. The legal system is not protecting the victims of pesticides. The law is being used by the most powerful companies in the world to protect their deadly but profitable toxins. They are aided and abetted by key personnel within the regulatory bodies, the medical profession and within the legal profession.

If a car manufacturer produces a dangerous vehicle that company is responsible for the recall of all faulty vehicles and their repair, and for any compensation due to any victims of harm caused by those vehicles.
I have often wondered why it is that when pesticides kill people the companies involved escape their liability and are reported to be paid for any unsold stock and potential loss of market for banned products.
The reason for this situation appears to be in the licensing and approvals system but it is now clear that the regulatory bodies rarely, if ever, insist on independent checks being made on the data supplied by the chemical companies. As with pirimiphos methyl the failure to check data has resulted in serious and embarrassing errors, which have been promoted in official and legal documents.
Changes to this system are urgently needed and this is evidenced by the removal from the market by the European Union in 2003 of up to half of the active ingredients used in pesticides. Many more remain which should be removed from the market place on safety grounds but if Europe had not acted I am sure that the UK would never have taken any action alone.

The Human Rights Act and the Control of Substances Hazardous to Health Regulations demand that the health of bystanders and residents is protected.

We need the correct and determined enforcement of the regulations in this country.

I hope that this assists the Royal Commission in its work


Dated 10/1/2005   Updated 29/10/2005

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