Dear Mr Goodacre,

The Chemical Safety and Toxicology Division of the Food Standards Agency have made me aware of your special study examining the scientific evidence relied upon by DEFRA in making its decision on bystander exposure to pesticides and access to information about those pesticides.

It is of concern to read in the Press Release that “This Special Study has been carried out over a much shorter time scale than full reports, but it is based on reports that the Royal Commission has published in the past, together with some new material” What is becoming clear is that a clean and new look at these issues is demanded by the new facts now entering the public domain.
Past reports may have been founded on biased and dangerously flawed information.

The Commission must ask DEFRA and other major contributors several questions.

1. Why is the surveillance scheme failing to recognise cases of pesticide poisoning?
2. Why was the COT able to report that the National Poisons Information Service had failed to provide
detailed information about poisoning cases?
3. Why are the data on safety for the pesticide formulations not independently checked before approvals for use are given?
4. Why, when serious doubts about assumed safety data are raised, is no action taken to establish the true situation?
5. How can regulators write letters for publication and publish them on Government web sites in which they claim to know the fate of all pesticide molecules when even feed trials using radioactive-marked molecules can “lose” up to 42% of the active ingredient?
6. How is it possible for those currently controlling the regulatory system to deny science used to establish an Act of Parliament which recognised that very science some 50 years ago?
7. Given the increasing evidence linking pesticide exposure to neurological, cardiac, respiratory, immune, ophthalmic, and cell damage how can science be used to justify the failure to act on the vital need to protect public health?
8. In 2003 a large percentage of chemicals commonly used in Agriculture and horticulture were withdrawn from the market due to lack of safety data and yet we were repeatedly informed that all pesticides are thoroughly tested before being permitted for commercial use. Who was responsible for that false information?
9. Why is it that animals and bees are protected but humans are not?
10. Why are the testing procedures in place for poisoning wildlife but are not correctly used for humans?
11. Why are the laws covering pesticide, use, disposal, and information release, rarely enforced?
12. Is there any truth in the claim that DEFRA based its decision on all available scientific evidence?
13. Why do scientists who admitted the dangers decades ago now claim that there are none?
14. Why has the term “Bystander” replaced “Residential” in this exposure consultation?
15. Why are “third parties” required as intermediaries for obtaining pesticide use information?
16. Why test notification with a “pilot area”? Exposed people across the UK also require notification.

These are just a few of the questions which have not been adequately addressed by the authorities involved but answers are vital if a proper assessment of the risks to the public is to be made.
The questions come from an individual who has had a lifetime’s experience as a user, promoter, and in recent years, as a victim of pesticides. More importantly they follow a history of direct correspondence with numerous Government departments and the chemical manufacturer’s themselves in attempts to seek out the true facts.¹ Scientific testing of the chemicals involved and contact with research scientists and other pesticide victims has backed that correspondence.²
Far from offering reassurance that all is well the opposite is true and it is now clear that we have all been grossly misled by the culture of trust and mutual support between the regulators and the manufacturers.

It is necessary for the Commission to examine the reasons for those questions in great detail and to challenge those responsible for the deception involved to explain themselves.
Failure to do this will be seen as yet another Government whitewash designed to protect the Civil Service at the expense of the safety of the public as a whole.

The following comments are intended to assist the Commission

1. Why is the surveillance scheme failing to recognise cases of pesticide poisoning?
On the Isle of Wight there was a major case involving pesticide abuse and unlawful use by a farmer³ reported as being “an advisor to Government”. Local members of the public tried all means possible to persuade the Health and Safety Executive to investigate the actions of the farmer because the pesticides used were inducing adverse effects in the local residents. All efforts were rebutted by the Government officials involved who claimed that they had “fully investigated” the farm and found nothing wrong.
Similar denials were made in respect to poisonings by the illegal actions of another Isle of Wight farmer and the victims were made out to be time-wasters by the HSE in a written reply to the House of Lords when questions about two linked cases were asked in Parliament in 1996. ⁴
In the former case the farmer became over-confident and sacked his pesticide operators resulting in the reporting of numerous offences to the supermarkets supplied by the farmer. Only then did the HSE properly investigate and the farmer was fined almost a quarter of a million pounds for eleven serious breaches of pesticide regulations. What is strange is that the reports of ill health caused by those actions, which in themselves directly triggered the investigation, are still not officially recognised.
During the investigations by local people it became apparent that the official adverse reaction surveillance schemes are simply not working, with thousands of UK cases every year going unrecognised.
The other farmer reported above escaped legal action completely and was assisted by perversion of justice by the HSE staff involved who worked to undermine his victim’s case.⁵ There is evidence available which supports that comment beyond all doubt and further evidence proving that the accepted science relied upon by the HSE in their actions is dangerously inaccurate.
What is unacceptable is the influence that the HSE has5 over the National Poisons Information Service, the Pesticide Incidents Appraisal Panel, and over the Benefits Agency, all of which have a duty to those suffering as the result of exposure to pesticides.
There is ample evidence that false information provided by the HSE has resulted in the denial of both the diagnosis of poisoning and the rightful benefits entitled for those who have been poisoned.
The National Audit Office is aware of this problem1 and it is hoped that they will take steps to end the injustices but it is suspected that the above agencies are acting in the best interests of Government and the chemical and insurance industries, and not to protect the health of the population of this country.

2. Why was the COT able to report that the National Poisons Information Service had failed to provide detailed information about poisoning cases?^{(page 61in 15)}
The NPIS is the controlling factor in diagnosis and treatment of poisoning. All GPs are referred to the NPIS for information on suspected poisonings and yet it is clear that all is not quite right with the system.
In several cases senior members of the NPIS have stated that those suffering from the effects of exposure to pesticides have not actually been poisoned but merely imagine the effects.⁵ This is a disgraceful view but it is widely held within the officials responsible for regulating pesticides.⁶ The claim is always that the patients knew about the symptoms of exposure and then imagined that they had those symptoms when in the vast majority of cases the symptoms are experienced long before the patient ever discovers that the symptoms they suffer are in fact those caused by the pesticides. In most cases even the GPs have no idea what symptoms pesticides can cause until they contact the NPIS.
The explanation for this is becoming clear. The NPIS, and senior staff within it, have direct links with the chemical companies who make the poisons and are often financially backed or even directly employed by the very companies that would prefer that the true nature of the poisons remains hidden.
There have been numerous reports of poisoned patients being referred to the NPIS and who have the diagnosis confirmed only to force them through experimental testing, which merely collects data for the chemical companies, after which the diagnosis is withdrawn. In some cases the vital medical records proving physical harm are then “lost” or on occasion deliberately falsified⁵ so that any evidence of links between exposure and the illnesses is rendered almost impossible to prove. It is an utter disgrace but worse than that the false information so gained is then used to deny poisoning in any new cases and to distort the international safety data in favour of the chemical companies.
Some of the doctors involved make sweeping statements about patients they have never examined or of those in whose cases they have not been involved for years if it means that they can undermine a second opinion obtained by GPs from more honest doctors. Again all this can be supported by evidence.⁵

3. Why are the data on safety for the pesticide formulations not independently checked before approvals for use are given?
In correspondence over the last 12 years it has become clear that the regulators in the UK simply “rubber-stamp” data supplied by the chemical companies in support of applications. In fact they seem to assist the chemical companies to obtain approvals as seen when the Pesticide Safety Directorate suggested that too many experimental animals were dying in safety tests.⁷ Rather than treat the chemical as suspect the PSD actually recommended using a different strain of rat, which was likely to survive the onslaught of toxins better than those currently used. What sort of madness is this? If too many people die from the effects of pesticides will the companies suggest breeding a new genetic subgroup of humans so that they can continue selling their poisons? It is already known that a certain genetic group of humans is susceptible to the damage caused by specific pesticide chemicals⁸ but, true to form, the regulators allow such chemicals to be used without allowing that susceptible group to be warned of the dangers.
The BSE Inquiry was given details of many years correspondence with various government departments over the dangers of pesticides used on food crops in which warnings were given that the pesticides were effective as poisons for far longer than the data suggested.⁹ It was all ignored and every department repeated the false data as if it were accurate. Despite the opportunity given no checks were made.
In July this year, 2004, scientific tests, supportable in a court of law, proved beyond any doubt that not only does the commercial product not breakdown as claimed but it actually doubles in strength during storage.² This confirms reports that chemical levels in treated grain actually rise during storage but despite this new information the regulators are still determined not to admit their dangerous mistakes.
That chemical is not the only one for which there are concerns. In the Hill v Tomkins case in 1997 international experts expressed concern about the safety testing procedure for that and another chemical but still the regulators refuse to act. Furthermore there are serious doubts about the safety of a commonly used herbicide, which also retains both insecticidal and herbicidal action a decade after dilution. The regulators have known about the concerns for years but they refuse to check the facts.¹
This is a scandal of enormous proportions. These people are paid to protect us but instead they are protecting the wealthiest and most powerful companies on the planet.

4. Why, when serious doubts about assumed safety data are raised, is no action taken to establish the true situation? As seen in 3 above when doubts are raised the first action is to deny and to criticise those who report the doubts. This is madness. If people report doubts to the regulatory bodies they do so out of genuine concern and not because they are deluded. The first action should be to report the concerns to a central laboratory, which should then automatically take steps to check the reports for accuracy.
The cost of such a mechanism would be far less than the cost of maintaining and treating victims of poisoning for the rest of their lives and far cheaper than the attempts currently made to hide the true causes of disease and illness. In the case of one of the chemicals in section 3 above there has been considerable correspondence in which the accepted half-life claims for the chemical were constantly repeated by regulatory bodies and the chemical manufacturers alike. They were all wrong and that fact was proven by a scientific test costing a fraction of the cost of the correspondence.²

5. How can regulators write letters for publication and publish them on Government web sites in which they claim to know the fate of all pesticide molecules when even feed trials using radioactive-marked molecules can “lose” up to 42% of the active ingredient?
The Chairman of the Advisory Committee on pesticides actually wrote to the press suggesting that the fate of all pesticides is known.¹⁰ In the Evaluation Document¹¹ for pirimiphos methyl, published after the Hill v Tomkins trial cast doubt over the safety of that pesticide - and after the Pesticide Safety Directorate had been informed that the chemical remained active for years after dilution – it was reported that in a feed trial using a goat fed radioactive pirimiphos methyl only 58% was recovered. ^{(page 47 in 11)}
In that document alone there are many comments relating to unknown metabolites and it is clear that the true fate and toxicity of pesticide molecules is not known even when they are added to our food.
When it comes to pesticides used in the open air the comment is shown to be a gross deception because air currents, volatisation and physical transport by wheels, clothing and wildlife can result in the pesticides being transported for miles. Studies have shown that the chemicals contaminate homes in areas where pesticides are used with a great quantity transported into those homes on shoes¹².
Given that in many cases the regulators assume that the chemicals break down rapidly,when in reality they do not, it is clear that the risk of transport is increased proportional to the active life of the chemical.
Even the true toxic potential of breakdown products is unknown.^1,5 Either the Chairman of the ACP and those who agree with him are fools or they set out deliberately to deceive. I do not believe they are fools.

6. How is it possible for those currently controlling the regulatory system to deny science used to establish an Act of Parliament which recognised that very science some 50 years ago?
The current head of the Health Protection Agency provided information1 that stated that the Industrial Injury known as PD C3 causative agent 4, poisoning by organophosphorus pesticides,¹³ was entered on to the statute books in 1958. That Act of Parliament recognised that repeated low-dose exposures to organophosphorus pesticides could result in long-term adverse health effects. The Health & Safety Executive publication in the Medical Series for advice to doctors¹⁴ also stated clearly that repeated low-dose exposures could have long-term effects. Despite this vital supporting information for those regularly exposed to OP pesticides the Committee on Toxicity claimed that there was no evidence of such harm.¹⁵
The current head of the Health Protection Agency was asked by letter¹ to supply the raw data upon which the PD C3 paper was enacted. She refused.
It is internationally recognised that there are serious dangers when individuals are exposed to OPs before their enzyme systems have recovered fully from previous exposures. Since at least 1975 it is officially recognised that if an individual is poisoned by one form of pesticide then exposure to another form must be avoided¹⁶ because the combined damage to vital enzyme systems could be extremely dangerous.
How then can the scientists within DEFRA and the other regulatory authorities now deny that knowledge or deny the risk which has been recognised for decades? Rural residents are exposed to many pesticides.

7. Given the increasing evidence linking pesticide exposure to neurological, cardiac, respiratory, immune, ophthalmic, and cell damage how can science be used to justify the failure to act on the vital need to protect public health? The arguments used by DEFRA are not science based. They are political views expressed as science.
There are important scientific papers from around the world that recognise the effects of pesticides on the health of people living in agricultural areas.^{12, 22} Saku Disease has from 1965 represented ophthalmic damage in children found in areas of Japan where organophosphorus pesticides were widely used.
The paper¹⁷ was written in 1971. More recent papers have shown that children suffer neurological effects in such areas and that their drawing skills are adversely affected by the repeated exposures to pesticides.¹²
Such exposures are not occupational but result only because the children live in spraying areas.
Nor are they simply “bystander” exposures but they are the result of repeated exposures to pesticides which are almost constantly present in the environment in which they live.

8. In 2003 a large percentage of chemicals commonly used in Agriculture and Horticulture were withdrawn from the market due to lack of safety data and yet we were repeatedly informed that all pesticides are thoroughly tested before being permitted for commercial use. Who was responsible for that false information?
For decades the users of pesticides, the consumers of food treated with pesticides, and the occupiers of homes treated with pesticides, were repeatedly assured that all those products were fully tested for safety before approval. It is perfectly obvious now that those claims were false.
This matter should be investigated at the highest level to determine how the false claims came to be so widely accepted and who is ultimately responsible for that failure. Was it the chemical manufacturers who deliberately provided false information, or was it Government officials who failed to require sufficiently high standards of evidence? Given that the dangers of such chemicals as organophosphorus pesticides were known in the 1950s¹⁸ and those of pyrethroids were known in the 1800s¹⁹ it would seem that denying scientific knowledge cannot be accepted as the reason.

9. Why is it that animals and bees are protected but humans are not?
Regulations state that bees and Sites of Special Scientific Interest must be protected and there are numerous offences under the Protection of Wildlife Acts to ensure that pesticides are not used to harm animals and birds.²⁰ Those laws are rigorously enforced and offenders are given prison sentences.
There are even laws protecting certain plant species and they are also enforced.
In contrast, when those same chemicals poison humans, the first actions of the authorities are normally to attempt to hide the truth and to avoid recognition of the laws and regulations that should protect humans. The Control Of Substances Hazardous to Health regulations came into force in the 1980s and yet the basic rules within those regulations are ignored. Even workers poisoned by pesticides are unable to obtain details of the pesticides to which they were exposed1 despite legal rights to that information.²¹

10. Why are the testing procedures in place for poisoning wildlife but are not correctly used for humans?
In order to make successful prosecutions officials must test wildlife if poisoning is suspected.
Those tests are also used if poisoning is suspected in domestic animals and are a requirement if the correct treatment is to be given by Veterinary Surgeons.
It is also vital for human health that the correct testing procedures are used but it is clear that this is not common practice. Even in occupational exposures those poisoned by pesticides are told either that there are no tests or that there is no need to perform them. If the patient is lucky enough to be offered tests then they often find that the wrong procedures are used, (e.g. testing for organochlorines when it is known that exposure was to organophosphates⁵), or that the results are deliberately misinterpreted or falsified.⁵
A residential exposure case ^{(in 3)} was found to have metabolites of OP compounds in urine samples and the HSE informed the patient that he should be tested again and that if there were no metabolites present then the results would prove OP exposure. The second test was reported to be free of OP metabolites but the patient was then told that this was proof that his symptoms were not due to OPs and it was suggested that the levels found earlier were simply the result “background levels”. Neither claim is true.
The authorities use such methods to prevent recognition of almost all cases of pesticide poisoning reported to them. It is a disgrace but it is also unlawful and a breach of Human Rights since these actions deny the patient proper diagnosis and the correct treatment as required in law.

11. Why are the laws covering pesticide, use, disposal, and information release, rarely enforced?
There are wide-ranging laws and regulations covering all aspects involving pesticides, from manufacture to release into the environment. The government has taken the time, trouble, and expense, to formulate those laws and regulations, often in concert with international laws, and yet they are rarely enforced.
In cases mentioned above a whole host of regulations were blatantly breached and yet there was a determination on the part of the enforcing authorities to avoid taking any action at all.
It is impossible for those falling victim to bad practices to understand this reluctance to recognise the need to prosecute those who breach so many regulations. Often they are told that the reason for the inaction is a matter of cost¹ but the reality is that the cost of hiding the failure to investigate is more often than not higher than the cost of a proper investigation. In any event if those regulations were properly enforced then the regulatory authorities would recover all the costs of the action from the defending guilty party.
There are numerous excuses for the failure to enforce the law but there are precious few reasons.
The conclusion many will reach is that the failure to investigate and to prosecute are means used to avoid damage to the chemical and insurance companies and a useful method to reduce incident numbers so as to effectively bolster the false claims of regulatory control over pesticide safety.

12. Is there any truth in the claim that DEFRA based its decision on all available scientific evidence?
Research groups, universities and scientists around the world have produced a constant stream of peer- reviewed papers demonstrating the effects of pesticides and drift on human health.²² Those papers have been published in recognised scientific journals and they have been widely reported and quoted in the press. That great volume of research and scientific evidence has been dismissed as unimportant by those involved in this consultation in favour of their own opinions which they self-determine to be “science”.
Opinions are not science. Theories are not science. Science is science, and it must be accurate and proven.
The calculation of residential and occupational exposures makes use of the reported half-life of pesticides. Obviously the longer the half-life then the greater is the exposure.
With one commonly used organophosphate the recognised half-life is just 4.2 days. With activity reduced over time it is quite reasonable to think that within a week or two exposures would be reduced to nil.
The problem with that scenario is that the recognised half-life figures¹¹ are based only on experiments using the active ingredient but the commercially available formulations act entirely differently.
With this particular organophosphate the active ingredient actually doubles in strength in solution over five years after dilution.² Of more concern perhaps is that half-life in sunlight is given as hours and yet it has retained rapid insecticidal activity for years when stored in sunlight.¹ That is not the only pesticide for which this is true. When these extended half-lives are transposed into the residential exposure settings it is clear that residents could be almost continuously exposed to pesticides given off by volatilisation and such exposures can have serious consequences for human health and development.
The afore-mentioned organophosphate was one of those used in various forms including use as field and orchard pesticides. That form was one not supported when so many chemicals were withdrawn in 2003 but it remains approved for use in food and in grain stores, despite warnings of the risk from ingestion.

14. Why has the term “Bystander” replaced “Residential” in this exposure consultation?
The reason for the consultation was not in regard to simple “bystander” exposures. Such exposures are of limited term and normally of low-level although the Pesticides Incidents Appraisal Panel has confirmed poisoning on numerous occasions from such single, one-off exposures.^{23, 15} Residential exposure is the main point of concern and the residents living in areas where pesticides are frequently applied are exposed to those same bystander exposures but on a daily and almost continuous basis. It is understood that little or no research has been performed on the true exposure levels in such cases and when it has been done it has merely been a mathematical exercise based on single applications and accepted half-life figures. Normally it is assumed that the exposures persist merely during the application process and the true nature of the continuous vapour release, upon which the action of the pesticide often depends, appears to have been ignored in those mathematical exposure models.
Dursban (chlorpyrifos) use can off-gas for two weeks after application confining residents indoors.
The concern is not over mere “Bystander” risks. Residential exposures are considerably higher and they are cause for genuine concern in respect to the development of human life and its maintenance.
The consultation was “on the introduction of no-spray buffer zones around residential properties”

15. Why are “third parties” required as intermediaries for obtaining pesticide use information?
It is absolutely vital that those exposed to pesticides can obtain accurate information about the chemicals to which they have been exposed as soon as possible. The exposed person can then report to their GPs or to hospital staff the exact nature of the chemicals to which they have been exposed and the medically trained doctors would not then have to face dangerous delays in obtaining that vital information.
If third parties are required to obtain this information there will inevitably be delays, even if the medical staff do not first have to be convinced that there is a need to obtain that information by their patients.
Delays can be fatal or may result in the use of inappropriate intervention or long-term illness, both of which could be easily avoided if the exposed person could obtain the information soon after contact with pesticides. Some vital treatments and body fluid tests are ineffective after 24 hours and speed is of the essence. If a third party has to be found and then required to request the details via some convoluted process the opportunity for correct testing and timely treatment will be lost.
Perhaps this is simply another way to reduce the numbers of recognised cases of pesticide poisoning?

16. Why test notification with a “pilot area”? Exposed people across the UK also require notification.
It is understood that DEFRA is to set up a “pilot area” where a system of notification whenever pesticides are to be used is to be tested for effectiveness. What is really interesting is that in 1951 Lord Zuckerman suggested that all hospitals should be notified whenever the “Deadly Poisons” in the organophosphorus group were to be used¹⁸. This recommendation does not appear to have ever been implemented.
Likewise the COSHH regulations advise that farmers should consider the risks in using pesticides before they are used and these regulations are also not enforced.
The much quoted Green Code, suggesting best practice when using pesticides, is not legally binding on farmers and can therefore be ignored in its entirety in the full knowledge that no action can be taken if those recommendations are not adhered to.
In the COSHH regulations²¹ there is a specific requirement that workers have the right to access to the information on pesticides to which they are exposed. There are documented cases that demonstrate that even this legal requirement is ignored and that, even when specifically requested to assist, the Health & Safety Executive also fails to enforce that regulation.^1,5
Vulnerable people have a right not to be exposed to dangerous chemicals.²⁴ All pesticides are dangerous chemicals, both by design and content. Therefore those who are old, or sick, or already exposed and especially children in their developing years, including the unborn, have a fundamental right to be able to avoid exposure to pesticides. Few of us can move for safety to Wales during the spraying season.
If the Government is to permit the use of these chemical toxins then they must give those residing in the areas of use the rights to be informed when applications are taking place and to notification of the types of pesticide to be used. It may be that individuals suffer effects from specific pesticides and that they may be able to take appropriate action to avoid exposure. Obviously the ideal situation would be to ensure that no approved pesticide created adverse effects in man and then there would be no need for such controls but in the real world this would be highly unlikely and the Government has a duty to protect human life.²⁴
Notification of impending use is the very least that the Government could impose and it would be quite wrong to give some areas prior notification and make the rest of the country continue to suffer.
A similar “pilot area” was established years ago in respect to the reporting of incidents and demonstrated gross under-reporting but no action was taken to extend the idea nationally. Why, if not to hide the truth?

The Commission should be aware that all Government departments have repeated false information about the half-life of commonly used chemicals for over a decade. They have published that data knowing it to be under question without ever taking the necessary steps to ensure accuracy. When dangerous chemicals remain in the environment for considerable periods of time those living in sprayed areas are likely to have repeated and prolonged exposures and those exposures can explain all the adverse health effects reported. Those advising Government rely upon those false half-life figures when they ridicule members of the public, who report poisoning, and suggest that the symptoms reported are imagined.
Now we know that their claims are entirely suspect, and proven false for at least one form of pesticide in common use. If one active ingredient is protected from breakdown in the formulation then it is highly likely that ALL are protected to improve efficacy thereby increasing residential exposures and explaining the scientific reports indicating that rural housing becomes contaminated with pesticides.¹² Government advisers have got this wrong. They should admit it.
The Royal Commission must take this matter extremely seriously and not simply rubber-stamp the flawed work of those who advised the Minister.

References

1. Personal correspondence over 12 years.

2. Scientific analysis July 2004 (performed by methodology supportable in court). See below.

3. Boswell Case. Newchurch, Isle of Wight. October 1999

4. Hansard. House of Lords. 6 February 1996 and written reply.

5. Internal documents released under the Data Protection and Medical Records Acts.

6. Organophosphorus esters: An evaluation of chronic neurotoxic effects. David.Ray.MRC. May 1998.

7. Pesticide Safety Directorate letter “Longevity of rats in carcinogenicity bioassays” 12 Oct 2000.

8. Genetic Variation in Susceptibility to Chronic Effects of Organophosphate Exposure. 2002
NM Cherry, P Durrington, AC Povey, B Mackness, M Mackness, AE Smith and WM Dippnall

9. Submission to the BSE Inquiry 17th March 1998 and others.

10. Advisory Committee on Pesticides website - Prof. Coggon letter to the Observer April 2003

11. October 1997 Pesticide Safety Directorate Evaluation Document on pirimiphos methyl

12. Numerous but see attached Pesticide drift (Arizona) 1998 indicating mandatory buffer zones of up to ¼ mile and “How children Are Exposed and Harmed When Pesticides Are Used at Schools” 2000.
The Risks that Pesticides Pose to Children - by Becky Riley (October 2000)

13. Notes on the Diagnosis of Prescribed Diseases (Industrial Diseases) ISBN 1 85197 770 8

14. Health & Safety Executive MS17 versions 1980, 1987, 2001.

15. Committee On Toxicity Working Group Report on Organophosphates and submission to the Working Group 18th July 1998 and others

16. “The Safe Use of Poisonous Chemicals on the Farm”, MAFF 1975

17. Eye Injury by Organic Phosphorus Insecticides, Japanese Journal of Ophthalmology, Vol.15 (1) 60-67, (1971) by Satoshi Ishikawa, and the Journal of Applied Toxicology, Vol.14 (2), 119-129 (1994).

18. Zuckerman “Toxic Chemicals in Agriculture” Report 1951

19. William Rae, Journal of Nutritional & Environmental Medicine (1996) 6 p81

20. British Crop Protection UK Pesticide Guide 2003 “Campaign Against Illegal Poisoning of Wildlife”

21. Control of Substances Hazardous to Health Regulations 1998 includes worker access to information

22. A quick search of the World-Wide-Web will reveal thousands of references to scientific reports.

23. Pesticide Incidents Appraisal Panel reports 1986 -1996 and others.

24. Human Rights Act. 1998. Article 2; Right to protection of life, Article 3; Requirement for proper medical help, and, Article 8; the right to protection from life affecting pollutants.