Submission to the UK National Action Plan for the Sustainable Use of Pesticides

16th October 2012

Kerry Hutchinson
National Action Plan Consultation
Room 214
Chemicals Regulation Directorate
Kings Pool, 3 Peasholme Green
York YO1 7PX

Dear Kerry Hutchinson,

I write as a former farm manager who was responsible for purchasing, storing and applying pesticides over many years but who, through unlawful actions of trained staff on another holding, was made disabled and seriously ill by exposure to an illegal mix of pesticides. Since that time I have been made susceptible to further chemical exposures and to prescribed medication, which restricts treatment options.
I therefore have an interest in all aspects of pesticides including the approvals process since investigations triggered by my exposure experience uncovered serious flaws in the regulatory system.
My views are therefore born out of direct experience with all aspects of the problems involved.

Although this consultation is said to result from earlier consultations with stakeholders, including the public, it is clear to many of us that the experiences of the public have largely been ignored.
We still hear the fraudulent claims that symptoms are “all in the mind”, even when evidence has been given to various regulators and committees proving that the symptoms were induced by pesticides and that those symptoms are actually indicators of toxic effect looked for during pre-approval testing.
There has recently been much controversy over the effects of pesticides on bees but once again the official line has been to deny knowledge of a link when in fact government committees and government agencies have admitted that pesticides kill bees since at least 1955 1. MAFF itself sent out detailed information listing a number of pesticides that kill bees or were suspected to kill bees in the 1980s.2.
But we can add to that list today and I sent detailed information to our then Prime Minister Tony Blair in 1997 when I discovered that glyphosate killed insects more rapidly that proprietary OP insecticides.
The information was ignored but it was also sent to the German rapporteur when they reviewed glyphosate safety where checks were clearly made as in 1999 German scientists were reported as also finding the insecticidal property of the chemical. At the time there was a suggestion that the chemical would have to be banned if bees and other essential insects were to be protected but instead the use of the chemical has increased with more increases planned should the GM crop policy be introduced.
In addition a local farmer last year managed to kill hives of bees by spraying pyrethroid insecticide.

What use are any consultations if those in control have a pre-determined policy?
Our views are ignored, just as operators ignore application rules. As an example glyphosate should not be used on non-porous surfaces where the product can enter drains, ditches streams, or rivers and yet the chemical is the most used on city streets.
More importantly rules and criteria for approval of pesticide active substances leave much to be desired.
Are those rules also ignored so that products that are suspected of causing harm remain in use?
The enforcing methods are themselves failing all too frequently and because those responsible for enforcing the regulations have pre-conceived ideas of safety warning signs are being missed all too frequently. How then can any guidance on risk assessment be of any use at all if even proven adverse effects and data flaws are ignored by the responsible regulatory authorities?
Likewise Maximum Residue Levels (MRLs) for foods treated with pesticides are based on commercial data, which in itself may not even relate to the commercially used products and may therefore completely understate the risk to public and environmental health. Calculations are mostly based on data for the active ingredients in isolation but such calculations do not take into account the changes to the properties of those chemicals by other compounds in the formulations which may themselves be toxic, or mixes.
In fact eventually in Parliamentary answers it was admitted that chemicals in the formulations protect active ingredients from breaking down as rapidly as data suggests and therefore any data based on those figures will be completely unreliable and under-estimate true exposures well beyond the built-in suggested safety factors. In reality for some chemicals there is no exposure level at which there is no adverse effect and for those chemicals a complete re-think is required.

The quoted aim of "reducing the risks and impacts of pesticide use on human health and the environment and promoting the use of integrated pest management and of alternative approaches or techniques such as non-chemical alternatives to pesticides" may sound laudable, but the reality is that Integrated Pest Management is a tool invented to retain pesticide use and to artificially allay concerns, since reported adverse health effects caused by pesticides have been hidden for decades.
In addition the UK regulators have already shown their true colours on these issues by actively working against the EU proposals to restrict even the most dangerous pesticides. It is clear that those attempts demonstrate that human health is not given the claimed importance by the UK decision makers.

The Sustainable Use Directive includes the use of pesticides and pesticide residues in foods and other areas affected by pesticide degradation and disposal and yet the simple request that food treated post-harvest with some of the most dangerous pesticides on the market should carry labels declaring that use was met officially with the suggestion that they did not need to be declared “because they are pesticides”.
Given that many people affected by these chemicals, or susceptible to them due to illness etc., will need to avoid adding toxins to their daily diet, the refusal to label treated foods is disgraceful but my suspicion is that this is because there is a policy to allow GM crops to be grown and admissions of the potential harm would damage that policy. However hiding the truth does not solve the increasing problem.

It is suggested that the Directive takes account of the health, social, economic and environmental impacts of pesticides to protect the health of operators who apply pesticides, other workers, residents, bystanders and consumers in addition to the environment, but when we report problems the information is not only ignored but is deliberately hidden – in effect protecting those who do not act responsibly or lawfully.

Sometimes the goals of "Improving the productivity and competitiveness of food and farming businesses, with better environmental performance" and "Helping to enhance the environment and biodiversity to improve quality of life" cannot be compatible. Nor is it possible to forget when “removing unnecessary burdens" of regulation that the regulations themselves were introduced in attempts to prevent abuses.
I respectfully suggest that our problem is not “over-regulationbut the failure to enforce even the most basic regulations and laws, which then results in problems that require further regulation.
As an example much of the red tape associated with farming followed directly from the BSE crisis when it was realised that more detailed restrictions and records were required if another disaster was to be avoided. By all means help farmers free up time for farming but make sure that when the bad things happen we have the means to bring them to a speedy end.

Even the proposals to deliver the UK plan are fraught with dangers since the Chemicals Regulation Directorate (CRD) and the Health and Safety Executive have been involved in the failures that have caused both the environmental and human health problems that this Directive seeks to address.
This is not new. For decades there have been serious criticisms of the failures and cosy relationship between the regulators and those who investigate and prosecute in poisoning incidents.
Defra has itself been secretive over chemical information, choosing to protect commercial interests above those of human and environmental health. Big savings can be made for both the NHS and the Department for Work and Pensions if only a more responsible and open attitude was shown as regards pesticide safety and the adverse health effects triggered by pesticides in the general population.
Sadly the Committee on Toxicity has been all too willing to abdicate its responsibility for the safety of human health, but perhaps this should be no surprise given that its chairman believes in Voodoo but not the toxic effect of the chemicals in pesticides which may induce chemical sensitivity in humans.3
It is interesting to note that with very few exceptions the list of consultees for this consultation is made up mainly of companies who have an interest in continuing as they are with the hope for fewer regulations.
I suggest that this may well prove to be a dangerous route to take since the adverse effects already being seen are likely to become even more evident in the future if corrective steps are not made very soon.
Perhaps those involved should take a look at the findings of the Permanent People’s Tribunal as released early this year and I would suggest that the UK was lucky to escape criticism only because none of the chemical companies censured are now based in the UK. 4

It is suggested that the UK Plan can only be delivered through Government working in partnership with a wide range of stakeholders including the crop protection industry and the wider agriculture, horticulture and amenity interests and other non-government organisations but I suggest that it will fail if a true account of reports of adverse reactions from members of the public is not given sufficient weight.
While this Government is determined to reduce or remove regulatory burdens they must not be blind to the fact that people do not always stick to the rules and therefore they will be even less likely to use best practice with non-regulatory approaches. It was failure to protect that caused the regulations to be introduced initially and, even with regulation, agriculture is still one of the most dangerous occupations – and that is without official, recognition for many of the illnesses and deaths that can be attributed to pesticide exposure or the effects of pesticides on the mind and body that can result in accidents.

The Voluntary Initiative for pesticides in agriculture and horticulture was a reaction to the problems faced by people living near areas where pesticides were applied, but, as with most voluntary things, much was made of the promises but little has improved. Local farmers know all too well of my condition and susceptibility to pesticides but I am never informed when even the most dangerous pesticides are used close to where I live. In short the Voluntary Initiative was a tool used to avoid required regulation.

It is right that “All pesticide users, and especially professional users, have a key role to play in ensuring the success of the Plan in reducing the risks and impacts from pesticides on human health and the environment by: adopting an integrated approach, drawing on all available techniques to tackle pests, diseases and weeds; complying with all relevant regulations and record keeping requirements for pesticides; complying with any Codes of Practice and following guidance – including that from industry groups such as the "VI - for using pesticides; supporting the measures in this plan relevant to their sector.
BUT they do not always adhere to best practice, and never will unless forced to by fear of large fines or worse when things go wrong, as they surely will.

Sadly the UK Pesticides Forum has proved its lack of reliability and scientific credentials by its recent claim that pesticides have no effect on human health or the environment 5. That is patently untrue.
Perhaps such a statement is a reflection on the makeup of the Pesticide Forum, being mostly formed from representatives of the industry with few if any representing the public interest. If even they say that amenity and amateur users are not operating to the same high standards employed in agriculture, and we know that those in agriculture cut corners and take risks knowing that the chances of discovery and prosecution are slim, then I suggest that there is need for serious concern.

It is said that the UK NAP will keep the impact of pesticide use under review but this was promised in the 1950s when early concerns about chemicals and the impact on human health, food and the environment were proven to be justified by the three reports from the Zuckerman Committee but we have not progressed very far as those concerns are still evident, and many of the same chemicals are still in use.
As the consultation document admits the entire process depends on the premise that pesticides are used responsibly but it should be added that even before pesticides are used their approval also relies on the provision of accurate and reliable data based on the actual formulations used and there are serious dangers in reliance on calculations based on assumptions of equivalence to active ingredients. Furthermore few if any checks are made on the accuracy of information supplied and even when evidence comes to light that demonstrates flaws in the data even that evidence is ignored. How can the system be declared as “robust” when even the basics are unreliable?
Perhaps this explains why so many have suffered adverse effects from pesticides and why so many chemicals have had to be withdrawn when those effects are finally realised after decades have past and the damage has accumulated. In such cases risk has only been removed when those chemicals have been withdrawn but in many cases, because of the delays, the environmental harm persists for generations, as with the organochlorines. This is also the likely result of the delay in dealing with the DNA toxins such as organophosphorus compounds but for some strange reason the Government still suggests that reducing use will not minimise the risks. This is an obvious and blatant untruth and although it is claimed that “surveys of pesticide usage and practice in the agricultural and non-agricultural sectors (including non-professional use); results of inspections of agricultural users; cropping statistics and availability of methods of control; rates of adoption and impact of industry initiatives; monitoring of the impacts of pesticide use on human health, water quality and wildlife” have been employed in order to establish the risks it is clear to anyone outside of the Government and its allied industries that there have been serious problems and that those problems have been systematically hidden from the public.

At last it is admitted that ”it is not possible to understand changes in the impacts of pesticide use solely on the basis of mathematical calculations/ modelling from the chemical properties of pesticides, but that information is also needed on user practice”. This has been said by those outside of the regulatory system for decades but those observations have been denied by false assurances that the calculations offer protection when they plainly do not. Even the manufacturers of pesticides have admitted to having no idea of the toxicology of combinations and the regulatory bodies themselves admit to having no information of the toxicity of stored and diluted chemicals “because they would not ask for it6
Again there is no point in arguing that efforts to understand the scale of risks and trends are made if the risks themselves are not properly understood or are denied. For example for chemicals such as OPs it is widely recognised that there is no level at which some damage is not done, for example proteins are altered by way of the phosphorus atom which may or may not in turn be bonded in an OP molecule, but it is impossible in the short term to know if any of that damage may or may not result in serious illness at a later date – as is known to occur when proteins are incorrectly formed and then replicated in the body.

Training of users, distributors and advisors

It is quite wrong to think that ensuring those who use or advise on the use of pesticides are trained will ensure that chemicals are used sustainability. I was poisoned by trained people who none-the-less mixed an illegal combination of two anticholinesterase chemicals and then stored that diluted mix for many months, only to dispose of it again contrary to the rules and regulations for disposal.
I suggest that training is akin to learning to drive. Once the Driving License is obtained people still drive recklessly or illegally and innocent people are still killed. Awareness of legal obligations does not ensure that laws will not be broken and operators will push the boundaries and often ignore the rules to get the job done. Even when professionally advised, mixes of pesticides have triggered unexpected results. Training programmes are a plaster over the cracks designed to make dangerous chemicals appear to be safe and used safely when in fact they do nothing of the sort.
Non-statutory industry initiatives such as on-going training programmes will also not ensure safety in the field. The only people able to control the safe application of pesticides are the men applying the chemicals and if they continue to be given false suggestions of safety they will see nothing wrong in the corner cutting that we see regularly and which can result in adverse reactions in those exposed.
One of the most worrying aspects in the system is that operators can gain points for the spraying qualifications simply by buying a subscription to a farming magazine – even if they never actually read it – and that the magazine in question has run campaigns to prevent the withdrawal of even the most dangerous pesticides. This does nothing to improve safety and much to induce complacency.

Advisors are often the suppliers of pesticides used on farms and are therefore unlikely to advise measures that do not require chemical controls, despite the guidelines as to the level of pest, weed or disease deemed necessary to trigger chemical intervention. The system is flawed from the outset.

Regulatory and non-regulatory measures

As far as training is concerned, as stated above, training does not ensure compliance with best practice or regulations. Human nature will ensure that even with the best training some people will try and cut corners or simply ignore the rules especially if under pressure to complete tasks or in difficult weather conditions. It is foolish to suggest that training will make dangerous chemicals safe and without enforced regulations there are no sanctions to encourage operators to follow the rules. Even with road users there are regulations that must be adhered to and legal sanctions for those who do not comply. How much more important is it for sanctions to be available should sprayer operators harm food and those around them?
Tinkering with a voluntary approach and continuing to suggest that pesticides do not pose a serious risk to health will only lead to more problems as time goes on. As mentioned above it is quite wrong that a subscription to a farming magazine can provide points towards NRoSO registration since it is not even a requirement to read the magazine, which itself has campaigned to retain even the most dangerous pesticides for use in UK agricultural practice.

Sales of pesticides

One of the issues that is difficult to understand is why such tight regulation is required for agriculture if the pesticides really are as “safe” as is claimed.
Historically operators were told that the chemicals were tested and proven to present no harm before approval, but this is plainly untrue.
Another issue is that although pesticide storage on farms is tightly regulated those in supermarkets can be stored and sold with food to people who are completely untrained and have no idea of the risks they may take when using the products. While it is true that the formulations are often weaker than those used in agriculture they are still poisons and capable of doing great harm, especially if bought in ways to accumulate a bulk of product sufficient to do harm.
How pesticides were ever permitted by the regulators to be stored and sold with food is a mystery.

This aspect makes a mockery of the claim that “any person who purchases a pesticide must ensure that the end user will hold a certificate or work under the supervision of someone holding such a certificate; distributors selling products for non-professional use to provide general information on risks, good practice and low-risk alternatives; and that anyone who stores pesticides takes ‘reasonable precautions’ to ensure that storage does not endanger human health and the environment.

It is of interest that many product labels no longer give a comprehensive list of the symptoms to be expected if accidental poisoning occurs. This takes away that vital early warning system, which many who experience symptoms will rely upon before contacting their doctor. “If you feel unwell” is a phrase which is of no use at all since some early symptoms mimic minor illnesses and may well be ignored by those who are actually suffering the effects of poisoning and lead to delayed, inappropriate and ineffective treatments. Many drugs commonly used to treat symptoms are contraindicated in poisoning.

Information and awareness-raising

Although it is claimed that “Government and other stakeholders employ a variety of measures to share general and specific information on the risks and benefits of pesticide use with the general public” it is clear to many of us who have experience of this that the only information currently promoted is the suggestion that the symptoms experienced are induced by a “fear of pesticides” or even “a belief in poisoning” or are “of psychological origin” or merely “,i>triggered by smell”.
This is not the required attitude from responsible bodies that have a duty to protect human health.
A much better approach was taken in 1996 when the Government’s Department of Health issued the “Pesticide Poisoning” booklet to all GPs and listed the symptoms, tests to be used, and possible treatments, but sadly few GPs had the time or the inclination to actually read the information.
Worryingly the information for some chemicals given even in that publication was misleading.
Most people affected by pesticides used by others would not even be aware of what chemicals were used and so the information on the CRD’s website would be of no use to them, which is why open access to records of pesticide use is essential if doctors are to successfully prevent long-term adverse effects.
Interestingly since moving from a postal service and signing up to the updates from CRD via email there has been no further contact or information sent from them - so much for an open, informative service.

What is interesting is that since the Control of Substances Hazardous to Health Regulations came into force in the 1980s they have not been properly enforced. Those regulations demanded that users should first “consider if the use of a pesticide is really necessary, and if so, what risks may arise from pesticide use and how to mitigate these.” But when obvious breaches of those regulations are seen on investigation no action at all has been taken. Workers have a legal right under COSHH to be told what pesticides have been used but because so many have been denied that information they have not been given the correct medical treatment and remain disabled for life instead of being cured in the early stages.

The National Farmers Union’s ‘Good Neighbour’ Initiative is another con-trick designed to reassure the regulators but the reality is that even those most affected by pesticides are never informed of any pesticide use in their immediate vicinity, not even when the farmers involved know very well that their neighbours are at risk. There is a need to provide accurate information on what chemicals are used but this has proven to be an impossible task for many who require that information, even when doctors and lawyers have been involved and have made specific and repeated requests for that information. As for reducing spray drift it is frequently seen that pesticides are allowed to drift across roads and on to neighbours’ fields – and damage often results, but things are kept quiet to avoid prosecution and/or costs.

With current attitudes the ‘Good Neighbour’ initiative is not even an achievable wish in England.

Inspection of application equipment

Obviously there is scope for profitable privately run schemes for inspecting application equipment but the end result is what matters and the problem is that the system is likely to be less reliable, as far as ensuring safety is concerned, than the annual MoT certificate for vehicles. Like that system the certification is only really valid on the day the test is performed. It may at best ensure that sprayers are annually checked and any faults found at the time are repaired but equipment damage or failure could occur the very next day, especially in agricultural settings, and that would make the test findings completely useless.
Most operators would ensure that equipment is properly maintained anyway but as with all rules some see them as a challenge to find ways around them and others ignore them anyway.
The period of 5 years between inspections demonstrates how weak that system really is and 3 years is little better, especially considering that pesticides wrongly applied, either through faults or operator error, can drift for large distances, as admitted in official information sent to farmers many years ago.7
It is interesting that handheld equipment and knapsacks are to be exempt from inspection as there have been incidents of them leaking down operator’s backs after developing unexpected faults and leaking into grain when they have been used to apply insecticide, a practice apparently banned but which is reportedly still employed by some farmers or their employees.

Some years ago a family reported suffering adverse health effects from the aerial application of pesticides used to control bracken, and it was clear that they had no warnings and had been over-sprayed but they could get no help or recognition for their problems. It would seem that there is a need for tighter control over this application method and the types of pesticides that are permitted for this use. There must be a greater risk of water contamination and drift issues from aerial applications and this must be looked at in comparison to the much tighter regulations applied to ground-based application equipment where buffer zones around water courses and ditches can be more accurately identified and achieved.
Sadly when Local Councils apply pesticides to the non-porous surfaces of roads and pavements the risk of run-off into drains and watercourses appears to be ignored.

Research and development

While it is reassuring to read that the Defra pesticides R&D programme works “to develop an understanding of the fate and behaviour of pesticides in the environment so that procedures for approval of pesticides and the regulatory and administrative guidance and instructions for their safe use, storage and disposal on farms and holdings take the potential risks to humans, wildlife or the environment into account” this was a recommendation of Lord Zuckerman’s Committee in 1955 but we are still seeing problems in both human health and the environment caused by approved pesticides.
Likewise when considering the reduction of risk in specific areas such as “public spaces; conservation areas; and areas recently treated with pesticides which are accessible to agricultural workers” such proposals have been made repeatedly over the years with little progress and there appears to have been no real consideration at all until recently of the exposure risks to rural residents, where once again evidence provided by those residents and doctors has been ignored or dismissed as unimportant.
Legislation that exists is rarely enforced as operators often work alone and in isolation and are therefore the only people able to oversee the actions that they take, be they within or in breach of the regulations.

Industry Initiatives are not going to be satisfactory until the industry is given the full facts about reported adverse reactions and unexpected events. Currently more effort is given to the art of persuading those suffering from adverse reactions that what they experience is not related to their exposure than is made in reporting suspected cases to the industry so that early warnings are received, remedial action can be swiftly taken, and suspect chemicals removed before too much damage is done.

Handling and storage of pesticides and treatment of their packaging and remnants

In 1993 I personally raised concerns with my then MP about the disposal of pesticides and packaging both in municipal waste and via the sewer system.
The answers obtained by the MP were reassuring but inaccurate since it was claimed that there was no problem when it is known that there was no alternative way for people in towns and cities to dispose of such product wastes.
In addition when those wastes are incinerated the chemicals may be converted into even more toxic substances, which is another important issue that has been overlooked for many years, while the danger to aquatic life caused by disposal to the sewers should be obvious to all involved in the regulatory process.

The suggestion that non-professional products are developed with low toxicity is itself misleading since my first questions on the false half-life claims for pesticides were based on such products and it is written into the Industrial injury legislation that "the disease should be presumed to be due to the nature of the occupation unless there is evidence to the contrary. Such evidence might be, for example, that the claimant was a gardener who used organo-phosphorus pesticides on his or her garden at home." From that it can be seen that it is officially admitted that such products are not as “safe” as claimed but perhaps more importantly those weaker products are used to deny the adverse health effects in professional users exposed to the formulations used in agriculture, which are admitted to be of greater toxicity.

As I know to my great cost regulations that require those who use, store or dispose of pesticides authorised for professional use to “take reasonable precautions when handling, storing and disposing of pesticides in order to ensure that such operations do not endanger human health or the environment; refrain from mixing two or more anticholinesterase products unless this is expressly permitted by an authorisation; refrain from mixing two or more products unless the conditions of authorisation and product label can be complied with; ensure that storage areas are constructed in a way as to prevent unwanted releases“ have been in force for many decades but those regulations have been ignored and not enforced. My own case is the perfect example and yet the authorities rejected my accurate account of events and preferred instead to ignore my detailed records from over 20 years and instead referred sarcastically to what they called in writing my “elephantine memory” dismissing the recorded exposures as fantasy - but senior toxicologists had identified extremely dangerous chemicals in my records.
The Environmental Protection Act 1990 made it an offence to dispose of controlled waste in a way likely to pollute the environment or harm human health while grain store pesticides had to be disposed of at the time on barn structures. Disposal to ground drains was also ignored. No enforcement action was taken.

Industry Initiatives

The Voluntary Initiative is just that – it is voluntary. No one actually has to do anything.
There are no legal sanctions should even the basic safety requirements not be met.
Historically all pesticide use has been under voluntary control at operator level and it is all but impossible for anyone other than the operator to know if the chemicals are mixed properly, applied at the correct rate or height, or even to the right crop. As with so many things all is based on trust and assumptions.
I worked on that basis and the result is that two trained operators exposed me to chemicals that ended my working life. It is dangerous to rely on the assumption that people will use pesticides safely, just as it is dangerous to assume that all drivers will abide by the rules and drive safely.

Any initiative designed to reduce reliance on pesticides must be welcome but it is regrettable that market forces are not encouraging the move in this direction.
As a family we eat as organically as possible, first to reduce further damage to my own health, but also on advice since my wife’s environmentally induced cancer. It seems to us that supermarkets tend not to stock as much organic produce currently and that because such products are not readily available sales figures artificially indicate a drop in demand.
Defra could do much to promote healthy eating and encourage a move towards low pesticide use but it seems that most research is diverted to the pesticide dependent genetically modified crop project which, as has been seen in the USA, results in far greater need for pesticides with resistant weeds and insects.
If as much research had been put into understanding efficient pest, disease and weed control under organic systems we would be leading the world by now and our crops would gain a market premium.

Pesticide Residues in food.

In 1939 the cross-border trade of food contaminated with toxins was illegal in International law.
For reasons of expediency, because it was impossible to obtain zero levels of contamination once widespread pesticide use was the norm, the EU repealed those laws and calculated maximum residue levels in food were permitted.
With allowable residues it then became possible to add the toxins to the food as a precautionary measure to prevent insect infestation. Those non-food admixes were then exempted from the food additives legislation “because they are pesticides”.6
The problem with this approach is found in the application methods. For many years reports have been made to the authorities that application methods can result in “hot spots” of massively excessive applications. Although the residue-testing programme is given as a reason for lack of concern it is clear that only a minute fraction of food is actually tested and if by chance a sample from a “hot spot” is discovered the result may well be rejected as a “testing anomaly”.
Sadly for the people eating that excessively treated food there could be very serious consequences.
In any event the Maximum Residue Levels are calculations based on assumptions, which have long been challenged, as for example by scientists in the USA in 1997 who called for an immediate ban on all OP insecticides because of the cumulative residue danger to children 8, but they were ignored of course.

Monitoring adverse effects.

Despite the number of programmes in place in the UK to capture any human health effects of pesticides it is clear that in the majority of cases the reports made by the public are ignored completely or excuses are used so as to deny any link between induced symptoms and pesticide exposure.9
My own case has been confirmed by specialists and scientific analysis on numerous occasions but was deemed not even likely to be caused by pesticides on many occasions, despite repeated requests for official reconsideration.10 Reports from sufferers in this village and in others have all been dismissed despite some having blood test results proving exposure and pets with them having died.
The statistics must therefore be grossly flawed and there is need for urgent improvement in the data collecting process and in its interpretation before any conclusions can be drawn.
It must be assumed that any review of Pesticides Adverse Health Effects surveillance by the Advisory Committee on Pesticides will not present an accurate view of the reality if based on those statistics.
As above even "companion animal" deaths have been diagnosed as caused by pesticides but then go unrecognised in official statistics while bee deaths have also had the link to pesticides denied.

I have long suggested in various submissions that there needs to be a comprehensive and all encompassing recording system for all adverse effects linked to pesticides. This should be the task of an organisation completely independent of the HSE, CRD, ACP, PIAP, NHS, COT, DWP and Defra etc.
Those suspected adverse effects, be they in humans, mammals, plants, birds, insects, or the environment, should all be recorded. Initially the county in which the incident occurred, the name of the pesticide(s) involved and the adverse effects suspected should be obtained, recorded and notified as suspected cases to the manufacturers. (Early chemical identification is important in any cases of human adverse reactions and so users must have a duty to supply that information immediately on request.)
Those incidents should then be referred to the area HSE/VMD/DoH etc. offices for investigation.
Any confirmed cases should then be recorded in a separate database with all anonymised information then supplied directly to the product manufacturers and those who approve the pesticides for use.
In this way early warnings of potentially serious adverse effects will be achieved and remedial action quickly and quietly taken without waiting for ever-increasing damage to be done or giving time for the denial processes to kick-in as we currently see.
Any individuals who may have been affected by those incidents should then be supplied with a full copy of all the investigations and reports made and they should have the right to challenge any errors or false conclusions. The results of those challenges and the reasons for the challenge should be published openly.
Currently there is over-reliance on calculations, which are themselves reliant on data that is rarely if ever checked for accuracy. It is foolish to carry blindly on and to claim that we have strong regulation.

If, as we all want to see, we are to develop sustainable methods in agriculture and horticulture it is of vital importance that adverse reactions are not overlooked as they may be building both in the environment and in the often serious effects on our health. The “Holy Grail” that is suggested we will find in “new technology” is already looking decidedly unlikely but once again the adverse effects are largely ignored in the race for “progress” when in reality we are not progressing. We need seed variety, not standardisation.
The weather is still the greatest limitation to advances in yield and we have no control over it so developing drought resistant varieties will be no use in floods, or salt tolerant varieties in drought, and total weedkillers soon induce problems of resistance, as does the continued use of insecticidal varieties.
Nor is it possible to obtain something for nothing and yields still rely on a good supply of nutrients, minerals, trace elements etc. The higher the yield the more nutrients are required and aside from nitrogen fixation, which was employed for centuries without genetic engineering, crops are unable to conjure them up from the air. Good soil structure and protection of vital organisms in the soil is essential and that is often the first casualty with modern methods of farming.

It seems to me that we are at an important point in history where we have a choice.
Either we surrender to the multi-nationals who wish to control seed supply and chemical use under their terms and conditions no matter what the result, or we move towards a truly bio-diverse cropping regime in which some varieties fair better than others, no matter what the weather, so as to ensure sufficient supply in difficult years such as the one we have just had, and still experience. There is no easy fix.
The UK has an opportunity now to pave the way for others to follow since, so far, we remain GM free and have not yet had the escape of genetically engineered material into the cropping and weed system as has happened elsewhere to the detriment of agriculture and hopes for true sustainability.

I can only hope that those who make these decisions will take the correct path because the consequences if they do not could be very serious indeed, not only for the UK but for the world.

Yours sincerely,


1. Lord Zuckerman Committee report to Government 1955.

2 (i) MAFF warnings on pesticides and Bees 1979

2 (ii) MAFF list of chemicals dangerous to bees

3. Video evidence during the BBC2 programme Close Up “Allergic to Life” Broadcast in the late 1990s (relevant section attached in accompanying email)

4. Permanent People’s Tribunal Bangalore 2011 see

5. Pesticide Forum “Pesticides in the UK – The 2011 report on the impacts and sustainable use of pesticides”

6. Personal correspondence with the regulators.

7 (i). ADAS publication 1984

7 (ii). ADAS publication 1986

8. "Overexposed – Organophosphate Insecticides in Children’s Food" US Environmental Working Group. Washington D.C. 1997

9. Numerous local cases as frequently reported to County Council and HSE direct.

10. Considered twice by the Pesticide Incidents Appraisal Panel, and many times by the Department for Work and Pensions, but scientific confirmation(s), plus several GP and specialist opinions were all dismissed or ignored with no real explanation given as required in the regulations.

Despite all the information to hand the regulators STILL claim that pesticide poisoning is "all in the mind" - a "nocebo" effect - and that their pesticides are not responsible for the destruction of bee colonies around the world.

Dated 16/10/12 - Uploaded to website 04/03/2015

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