For Information

Official Group on OPs Report to Ministers. A review.

The Group appear to have done a thorough review of the information upon which they make judgements but it is clear that they have either ignored or not had access to vitally important information which may well have affected both their thinking and the conclusions of the report.

It is not clear from the document who was actually responsible for providing research papers.

Nor is it possible to understand from the report why such vital information was not provided.

The report refers to the paper "Organophosphorus esters: An evaluation of chronic neurotoxic effects" which can be criticised for the same reasons as will be explained later at the appropriate point.

The general view appears to be that existing safeguards are adequate. This may well be true in theory but in practice the failure to adequately enforce existing safeguards is cause for concern.

Page 5 of the document refers to the catalogue of CURRENT Government funded R&D relevant to OP compounds. The question that must be asked is why the research carried out over the last 50 years has not been documented in such detail. 1,2,3,4,5

Page 6, section 5 refers to the current state of knowledge about OPs but refers to the review by the Institute for Environmental and Health, claiming it should be considered by all advisory committees.

The Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) is said to have begun the process but it is clear that the document does not represent a true evaluation of the known dangers to human health presented by OPs. COT is already implicated in the problem since it has allowed the deliberate and undeclared addition of OPs to grains used for human consumption.6,7

Page 8 refers to the advisory committees and the difficulty in obtaining independent expert members.

It is unfortunate that the influence of the chemical manufacturers over scientific training and research has resulted in this situation. Training methods may determine inappropriate attitudes to risk. Assumptions made may go unquestioned and may be based on taught perceptions advantageous to the company.

Public safety appears to be reliant on the ability of such experts to separate duty and allegiances.

Page 9 refers to the Pesticide Incidents Appraisal Panel and the key part the panel plays in assessments.

This panel is also not independent and it is clear that certain members help to set the safe exposure levels and determine if those exposures have resulted in harm to individuals.8 The conflict of interest is obvious.

Page 10 illustrates the precautionary principles which apply and it is clear that many uses of OPs do not pass the standards said to be used in Precautionary principle B. There is for example no uncertainty regarding the risk of harm from an OP commonly used in grains for human consumption.9 The likelihood of harm from the chemical has been assessed on the lower side of predictions for effects other than those on cholinesterase and, despite international calls for an immediate ban, no control measures have been introduced.10,11 It is clear that despite proclamations made proven risk has often been ignored.12

Page 11 illustrates how the Sheep Dip problems have assumed greater importance than other equally important issues in this review. The use of sheep dip is an avoidable hazard but other uses of OPs are impossible to avoid and may present additional dangers to those already exposed to toxic levels.

Section 23 suggests that Certificates of competence have resulted in improvements in the situation.

The truth may be that the introduction of certification has made users realise that there is a recognised danger and many may therefore have taken more care or changed, as is evident, to "safer methods".

Certificates of competence do not ensure safe practice. No more than a Driving Licence prevents miss use of vehicles. Drivers holding similar "Certificates of Competence" cause road-traffic deaths and it is clear that training does not ensure safe working practices.

It is unfortunate that all suspected adverse reactions have not been both reported and recorded for trends would have shown themselves many years ago. It would then have been possible to foresee and prevent the harm now seen in the population in general and the farming community in particular.

Possible adverse reactions to specific chemicals would show themselves before ant real harm was done.

It is likely that reporting would also be free of the fear of prosecution and court action if the known dangers were admitted and details of any adverse reactions actively sought. A second database could then be produced detailing any confirmed cases of serious illness caused for licensing purposes.

Page 12 refers to such a database but it is clear that currently only a very small proportion of cases are recognised due to the difficulty in gaining diagnosis, investigation and a proper adjudication.

Mention is also made on page 12 of recent court cases but the difficulty presented to victims who attempt to have their cases heard in a court of law is not appreciated.

Page 13 refers to the potential risk to the government’s disease control strategy should OPs be banned.

It is possible that the withdrawal of the compulsory sheep dipping orders because of the likelihood of legal action against the government may have left the disease uncontrolled. This may have been due to the need to reduce costs by cutting non-essential actions in the absence of compulsory inspection.

The removal of Compulsory Dipping indicates an admission by government that the chemicals did indeed present a danger to health. This is supported by the requirement to wear ever-greater protection.

It is interesting to note that no conclusions could be offered on the likely effectiveness of the proposed economic instruments to protect ground water. If, as is claimed, chemicals are tested as safe, and present little risk to the user, the treated animal or the environment such instruments should not be necessary.

The manufacturer, and not the user, should be responsible for ensuring that the products he sells are safe and can be used and disposed of without endangering life or the environment.

Page 14 indicates concern over "whether" OPs damage human health. There is no question. Government has recognised that they do for almost half a century, if not longer.1,2,3 Page 15 explains that the group intended to "draw together all scientific evidence from UK and international sources" but fails to mention bans called for, or introduced, and the serious health effects caused by OP use in such countries as Africa.

Again on page 17 the report mentions work on the "possible harmful effects of OPs" yet even the manufacturers and their product labels admit that the effects described are already KNOWN.12

Despite this the report states that the views if organisations and individuals were taken into account and promised to make it clear where different conclusions were drawn. Where this is done is not clear.

It is clear however that certain groups or individuals do have the ear of ministers but may have failed to properly inform them of the known actions of OPs on humans. Ministers may not have listened of course.

Page 19 examines the action of OPs and their toxicology but fails completely to mention that OP agents are known to have their main action at the phosphorus atom and that the real mechanism employed in insecticidal action is not known. (Insects have survived OP action with cholinesterase systems completely neutralised and yet died with that system intact.13 – B J Walker) There is also no mention of the inhibition of enzymes other than cholinesterase and NTE, as has been reported in animal experiments.9

Page 20 does report that recovery requires the elimination of OPs from the body and the regeneration of vital enzymes but makes no mention of the lipophilic action which stores OP in the fatty tissues.

These stores of dangerous toxins may be released back into the blood stream causing further damage.

While similar actions may occur in other poisonings such pesticides as the carbamates mentioned do not undergo the process of "ageing" and neither do they act at the vital phosphorus mediated sites in the body.

The paper states that some OPs do not cause OPIDP in humans. This is a statement based entirely on theory. The theory is based on experiments, often involving the prophylactic protection 9 of the bird or animal to be tested with the known antidotes both before and after exposure. They are therefore unreliable and it is clear that some chemicals, which have passed that test, actually have caused OPIDP in humans.14

The paper explains on page 21 that the reasons for the development of intermediate syndrome are not clear. This is an admission that the toxic effects of OPs are not fully understood and therefore condemns those who declare that the chemicals are safe. After some 50 years of study these basic effects should be known, as should those involving the calcium phosphorus ratio, magnesium, copper and other systems.

In fact cholinesterase inhibition is not a sufficient marker for the other known risks such as reproduction disorders and genetic mutation. 9

It is interesting to note the dismissal of Malathion as the only OP product used in medicine since it is used for controlling head lice where proven risk has been shown. Not surprisingly since the skin, eyes and mouths of children are all routes into the body for the poison.

Interesting too that chemical warfare agents are mentioned. Such agents are said to be dangerously persistent if they remain active in the open air without regeneration for more than 10 minutes.15

Many pesticides remain active for years after dilution.25

The quantities of pesticides used are merely estimates but even so it is unclear if the figures quoted are for ingredient or for final product. Figures provided for Actellic in grain alone have been questionable.16

Perhaps it is the use of OPs against wheat Orange Blossom Midge that has reduced the number of insect eating summer visiting birds. Some OPs are known to be extremely hazardous to bird reproduction.9

The use of skin penetrating OPs on beaches and mattresses for bed bugs 12 could also be harmful.

On page 23 further note is made of the neurological action of OPs but again no other mechanisms are referred to and it is also noticeable that no mention whatsoever is made concerning the known and recognised effects of the solvents and surfactants used in pesticides and in sheep dips.17 Many of these have been used in the past as insecticides themselves and are known to cause long term health effects.

Any controversy regarding long-term exposure risks is due to the financial risk to the companies involved and to the government who were duped into allowing the widespread use of OPs.

It appears that the co-ordination between departments mentioned on page 25 has been used not to further knowledge about OPs, and their action, but to co-ordinate responses intended to hide the truth about OPs from victims. On page 26 research at Porton Down is referred to briefly but it is clear that the compounds used for warfare are not the same as those used commercially. They are designed to act rapidly and to disperse quickly, unlike pesticides that require a long period of protection. In addition it is clear that much of the testing is done in the absence of the solvents which enhance their activity and effects.

On page 27 it appears that the group admits that it is subservient to the advisory groups and intended to merely survey current scientific evidence. Much, if not all of that evidence, appears to have been supplied by those very groups.

On page 28 the VPC is said to have been unable to find a specific syndrome related to OP exposure but this flies in the face of reality. There is surely already a recognised syndrome resulting from repeated low dose exposures which typifies all the symptoms reported by OP sufferers whatever their employment.

Government itself produced an Act to cover the syndrome and named it as Industrial Injury,3 Prescribed Disease C3, Causative Agent 4 - Poisoning by agricultural Organophosphorus pesticides. In making this statement they also ignore the detailed papers produced by the Health & Safety Executive, MS17.2

Section 3.16 refers to the paper David Ray, Organophosphorus esters: An evaluation of chronic neurotoxic effects" This paper too fails to address the known effects caused by OPs and concentrates only on the cholinesterase and NTE effects and it does not cover immune system damage it seems. Sheep dip again seems to dominate the report. Despite the fact that Lord Zuckerman gave the MRC the task of investigating OP damage in 1951 1 they still say they need more research which implies incompetence.

Is it possible that they do not know how important phosphorus is in the body and how many functions, which depend on it, can be destroyed by the action of OPs? Interestingly he too makes no mention of MS17 or of the Industrial Injury PDC3 papers and only makes brief occasional incidental references to Solvents which can on their own explain many of the long term symptoms including sensitisation. 17

Many references are made to the "stress" factor either at work, during work or as the result of the stress of the toxic exposure itself. "It is not possible to conclude whether the stress effects were specifically Organophosphorus pesticide related or generally work stress related" is one comment he makes [page 46.]

He also writes on [page 18] regarding mention the smell of OPs. Apparently it is not the highly toxic, volatile solvents and OPs which victims smell, but the "minor breakdown products, such as mercaptans, which in themselves represent little threat to health" and "can be both very odiforous and very volatile. Hence smell can be disassociated from exposure" Solvents are know to be both volatile and highly toxic and, because they are solvents they may well carry the OP in the air with them. The PIAP have confirmed many cases of poisoning caused by drift often noticed only by smell in the first instance. 18

The Ray paper dismisses and criticises many of the studies which confirmed the very types of long term damage which are known to be the result of OP exposure. His reasons for doing so are not given apart from his criticism of methods used and the obvious inability to quantify the degree of exposure.

The paper has not been peer reviewed and should not be regarded as a true study into OP research.

It is clear that a great deal of government (public) funded research has been hidden from the public.

The issue is said to be controversial on page 29 but the controversy has been caused by official denials, which are not founded on fact. If the evidence is not clear Prescribed Disease C3, Causative Agent 4 3 would never have been introduced especially at that time when Government finances were in difficulty.

Dr Ray’s views that low exposures are not likely to cause long-term effects ignore the action of the solvents and the effect of phosphorus substitution. He admits however that the mechanism of toxicology is not currently understood and calls for more research. They have been researching this for 50 years.

The group raises an important query over his reasons for selecting or rejecting research papers on page 30 and suggests that COT address the issues but fails to answer the questions raised.

The group does however point to other long term effects on page 33 but again asks COT and the other groups who have failed to properly research the issue to date to consider the issues raised.

On page 35 they briefly address the issue of residue monitoring but fail to mention that higher than recommended levels of OPs are found in a percentage of the mere 250 or so loaves of bread tested annually by the Working Party on Pesticide Residues.9,19

Regarding Wildlife Incidents it is clear that the incident must first be accepted as an incident but even then it only "may" be investigated. Regulations are therefore not always enforced.

A similar situation exists in regard to the Control of Pesticides Regulations where incidents are not recognised unless investigated by the Health and Safety Executive who are not obliged to act.20

Page 42 examines the sharing of information between departments. This must mean that all departments are aware of the known dangers from OP use and yet there is still a reluctance to impose restrictions.

The implication of this is that all government departments are knowingly failing in their duty to protect public health, especially given recent publication of research in America regarding the risk to children.10

The law regarding disclosure is referred to as a reason for keeping secret certain confidential information.

It must be said that Parliament can and does draft all legislation and can change the law if it so wishes.

International law can also be influenced if the will to do so is there but there is an apparent reluctance to make a stand against the financially powerful multinational businesses.

Public Health, within our own country at least, should be the priority.

Almost any information can be declared as commercially sensitive and it is simply astounding that the manufacturer of a potential poison capable of sub-clinically damaging the health of the entire population of the world can request a bar on disclosure. The need for such a bar suggests potential danger.

Page 46 suggests a reason for the restricted list of research papers as it states that there is a restriction on disclosure of raw data obtained before 1986. This is dangerous because many of the currently used OP chemicals were licensed long before that date and the details must be vital to an honest appraisal of risk.

Chemical company lobbying may well prevent success of the Bradshaw Bill mentioned on page 47.

However it seems from the report that Ministers are free to release evidence if it is in the public interest.

There is therefore no reason in law why information, such as that upon which the Act introducing PDC3 for example was based, could or should not be released to the general public.

Despite this, although "disclosures may be made to any person (both public and private) there is a deep seated reluctance on the part of Government officials to release any information which may help victims.

Even when the Law specifically gives individuals right of access that access is often denied.21

Strangely this has been evident even with supposedly confidential Medical Records when it seems that every person bar the patient has the right to receive full copies of information held and passed to others.

It is not an "impression of secrecy" but a situation in which secrecy and even misinformation is the norm.

Page 50 refers to the regulatory system in which the approval criteria is said to be based on safety, quality and efficacy. Here we discover that the approval process has become centralised in the EU but that member states can authorise "products containing active ingredients cleared centrally".

Effectively Member States can therefore restrict the use of certain formulations and conditions of use.

Again on page 52 the group illustrates complete faith in the ability of individual committee members to make decisions independently of their interests in companies which might be adversely affected by any restrictions that might be imposed on a chemical by the regulatory body of which they are a part.

Simple declarations cannot be strong enough. Nor can the absence of a member from a meeting since advice may have been given to other panel members that might serve to protect the company concerned.

Page 53 shows how few committee members are independent of government. Since government has a financial interest in declaring the safety of licensed products they are no more likely to give totally independent views than are company representatives.

Page 55 illustrates the false impression given regarding the appraisal of pesticide incidents.

PIAP is described as playing an essential role and states that the panel investigates the "fine details of incidents of exposure to pesticides" This does not relate to the written comment that the PIAP do not have to be right in every case that they examine.22 The Group is quite wrong that there has been no criticism of PIAP. On the contrary. It is apparent that PIAP merely rubber stamps information provided by the Health and Safety Executive and that they are quite prepared to give false information in order to avoid confirming cases which might prove embarrassing to the government and/or chemical companies.22

Cases with supporting medical evidence have even been set aside by the panel on spurious grounds.21,22

Page 56 begins to look at procedures for revoking and suspending licences and gives the main grounds as the product having been proved harmful under the conditions of use. This may well explain the reluctance to diagnose poisoning cases and the determined refusal to recognise experiments that have shown proof that harm has been caused to human or animal life. 23

Even if the chemical was admitted to have caused harm then an appeal procedure exists as reported on page 55 which by its very nature will give the company concerned the right to ignore evidence of harm.

Currently it appears that even proven harm to the health of children does not present sufficient grounds for urgent action to restrict use of a pesticide as suggested on page 56. Procedures are available but it seems they are rarely used and in some cases the product returns to the market place at a later date.24

Although the precautionary principle is not clearly defined as reported on page 60 and 61 and earlier on page 10 of the paper it is clear that the law allows licenses to be withdrawn. "if examination of the documents and particulars…establishes that… the…product is harmful under the conditions of use stated at the time of the application"

Page 62 refers to the safety factor included in the calculation for Maximum Residue Levels but it has been shown that the information provided for active life of certain OPs is itself underestimated by a factor in excess of 200 or more.25 Effectively this means that all MRL figures are completely unreliable and the safety margin claimed for individual products may already be compromised. Recent papers show that the combined effect of the multitude of OP products to which we are all exposed already grossly exceeds the maximum acceptable daily intake levels even if the MRL figures are assumed to be correct. 10

Page 63 declares that the law does not prevent application of the precautionary approach and does not set scientific criteria to be observed in determining applications.

Specifically on page 64 the authorisations can be withdrawn if:

  1. The requirements for obtaining the authorisation are not or are no longer satisfied;
  2. False or misleading particulars were supplied concerning the facts on the basis of which the authorisation was granted.

The group suggests on page 65 that a more precautionary approach may wish to be adopted.

However, on page 66 and again on page 67, it is repeated that there is no evidence of OP sensitivity or the after effects of exposure. This is contradicted later with the quote that those advised by their doctor should not use OPs.

Such advice would not be given if there had been no evidence of lasting effect or sensitisation.

Again the Group examines the Certificates of Competence touched on earlier and again refers to VPC evidence that protective clothing could have prevented problems experienced. The COSHH assessment is used to pass the blame for any experienced effects back to farmers on page 68 but it is clear that if a COSHH assessment was properly conducted OP dips would be excluded by the reported dangers to health because safer alternatives are available. 26

The report again refers to COSHH on page 70 where it is claimed that HSE enforces the Regulations.

This is not the true picture. HSE acts on a discretionary basis.20 There is no obligation on them to enforce the regulations and there is in practice reluctance to prosecute offenders presumably for financial reasons.

It should be noted that the procedures outlined on page 73 only come into effect when the HSE actually do investigate thoroughly. It is apparent that only those cases for which an HSE investigation has confirmed a pesticide exposure related illness are recognised. Only a small proportion of those reach PIAP and of those only rarely are confirmed results given. Even with Confirmed Medical opinion cases have been denied by PIAP. A recent Evaluation document 9 claimed only two confirmed cases by PIAP but PIAP records showed detailed reports during the same period of 3 Confirmed and one Likely case with a "Decision not known" tag against a further 4, "Pending" against 2 others and "Not Confirmed" against another 5 cases.18 It is clear that all is not as we are intended to believe.

A further weakness in the system is found on page 75 where reports from GPs are mentioned. Most GPs are not trained in toxicology. They are not privy to the local actions of spray operators as was suggested they should be by Lord Zuckerman in 1951. Neither do they have the time to investigate local activities.

Delay between the operations, exposure and subsequent symptoms is recognised as being up to a month and it is therefore extremely difficult for GPs to link exposure to the symptoms presented. 3 Their difficulties are compounded when they approach expert toxicologists for advice only to be misdirected and confused by those with vested interests who seek to deny symptom consistency with poisoning.21

Clearly the PIAP is not the intended source of accurate information for the advisory bodies.

Some criticism is made on page 76 of the link between those who approve products and those who assess human Serious Adverse Reactions but as already mentioned a similar situation exists within the PIAP.

Although the opinion of the PIAP that their brief is not to determine causality in individual cases is stated as fact on page 77 there is no doubt that statistics are merely a compilation of individual cases.

The assumption that the accuracy of individual assessments is of no real importance inevitably means that the accuracy of any assessment is not important. This in turn means that all figures quoted are unreliable.

It is reported on page 80 that various groups should be approached in order to retrieve data for research.

This raises several important issues. First, the accuracy of the information may not be as good as might be thought. Secondly, the information may have been provided in confidence in order to help boost the moral of fellow sufferers or even to help aid recognition of the problem. It is understood that some data has already been passed to third parties without the permission of those involved.

Court Judgements are reviewed starting at page 81 and it is clear that British Law as found in Hong Kong, and Australian Law, recognised the written evidence of the dangers of OPs especially via inhalation.

The Hill case shows how difficult it is for victims in this country.

The Shepherd case indicates the same problem and it should be no surprise to anyone that he accepted an out of court settlement rather than become a victim of dubious science inside the courtroom in addition to his experiences of it outside in the workplace.

The precedent has been set in Hong Kong and is relevant in Sheep dip and other cases where inhalation of OPs has occurred, or in other words in almost every case of exposure to OPs.

Page 87 refers once more to the COSHH regulations but they are not properly enforced.20,22

The approved code of practice suggests avoidance of the risk where possible and the keeping of any such use to a minimum. When used "measures must be considered for protecting operators and other people exposed". How is it possible to protect anyone from the drift of vapour lifting from crops sprayed days earlier? Such exposures can never be controlled. Government advice warned many years ago of the risk causes at great distances by chemicals lifting from the sprayed crop.27

Page 89 suggests that protective clothing can protect against OPs. Perhaps the group has forgotten the publicity caused by the discovery that OPs penetrate almost all the available protective clothing. In fact a broadcast comment by a protective suit manufacturer in 1992 suggested that Agricultural OPs were more dangerous than the chemical weapons his suit was designed against.28

Training and advice mentioned on page 91 cannot prevent misuse but merely reduces the incidents of such occurrences. Trained operators regularly use sprays to control growth on footpaths despite the obvious warnings about the accidental spraying of these rights of way.

It is clear that the regulating authorities are controlled by EU legislation as stated on page 92. However this is only, it seems, if the authorisation was lawfully issued and would not prevent warning against the use of dangerous products.

Sheep dip again seems to dominate the issues approached but on page 96 the statement about individuals advised not to use OPs is repeated. Many sufferers wonder how any individual has managed to be given the advice that OPs should not be used. Such advice is an admission of diagnosis that is apparently rarely given even when specifically requested by those who know their symptoms are related.

Toxicologists have even suggested that a renewed exposure may even confirm causation by OPs.

It is clear that some have been refused a diagnosis because they neglected to give a full list of symptoms.

Others have been refused because their reported symptoms "were not consistent" with OP poisoning despite almost perfect correlation with known symptoms.

Others refused to give detailed symptoms but were told their reported symptoms were still "not consistent with the known symptoms of poisoning".

There have even been reports similar to those found in the Hill case that the symptoms reported were so perfectly consistent with the textbooks that diagnosis was refused on the grounds that the patient was unduly influenced by the details read.

In short the system evolved has encouraged a mentality of denial by those trained and often also employed by the very companies which manufacture the chemicals concerned.

Page 98 begins the Environment section on Ground water. The responsibility for the release of pollutants into the environment lies with the manufacturers since it is a combination of recommendations for use provided by them and by government which determines disposal methods. In fact recommendations have changed considerably over the years 27 and are an indication of the failure to give proper information to users. It is clear that all considerations are given to disposal of manufactured toxins after use instead of the more sensible approach which would be to prevent the manufacture and sale at source or to ensure that some form of neutralising agent was provided at the time of sale.

It is far easier to prevent a disaster than to clear up after the event.

It should be noted that on page 101 within the copy of the Sheep Dipping information the risk from inhalation is clearly stated. Despite this there are no recommendations for the habitual wearing of a suitable breathing apparatus and there is no warning given on the specific danger caused by the solvents.17

It should not be the duty of the user to determine safety of the chemicals he is sold. That should be proven in the approval process heralded as the first defence for health and safety.

No mention is made of the danger from vapours in the section on controls required on page 103 or even when handling concentrated dip on pages 105 and 106. The possible contamination of ground and surface waters should heavy rain wash the chemical from the sheep after dipping is not considered.

Although no warning is given to others who may contact the sheep or fleece after dipping the wearing of a mask is suggested when working in a confined space or still air although the definitions are not given.

In such circumstances specific types of mask are recommended indicating a known danger to health.

No details are given regarding the time at which it is deemed safe to handle sheep after dipping.

The advice to wash chemical from the skin on page 109 also ignores the fact that tests have shown that very little is removed. It is likely that the lipophilic action of the OPs combined with the action of the surfactants used may even drive the chemical deeper into the skin by washing with water.

The advised disposal methods for used dip appear to eliminate all but the most expensive methods requiring the services of a specialist contractor. In fact I understand that one firm of solicitors found disposal of washed and empty sheep dip containers in a proper manner to be a very difficult task.

No matter how diluted the chemical it is clear that the recommendation to spread used dip over the land presents a considerable risk to both surface and ground water. Hill farmers must find the task of disposal onto flat land away from watercourses and without access to wildlife or animals extremely difficult.

How soakaways were ever considered a safe and recommended disposal method for OPs is not known.27

Page 111 refers to the treatment of empty cans but does not recommend disposal methods.

Health Surveillance advice appears to suggest that every person who shows signs of illness should be referred to a doctor. The employer is expected to know the symptoms to expect from such exposures even though trained toxicologists seem confused on the subject. It would appear that at one time the routine monitoring of workers regularly exposed was a legal requirement although the report indicates that blood and urine sampling might be necessary.2,26 Stopping work as suggested may not be possible on holdings run by one man and is often not possible on stock farms run by two men except in emergencies.

As mentioned earlier recommendations to avoid use of OPs are uncommon even in sufferers.

Lord Zuckerman recommended approaches to health monitoring in 1951.1

To suggest as on page 113 that anyone who feels unwell should see a doctor is sending two messages.

Firstly, that the symptoms are likely to be caused by OPs and secondly that the doctors will recognise the symptoms and offer treatment. The former is more than likely but the latter is found only in dreams.21

Page 141 mentions Porton Down experiments but does not detail them presumably for reasons of National Security. The Ministry of Defence should be protecting our people and their health. Therefore all information pertaining to OPs should be made available. It is probable that only the active ingredients and those with short active life have been tested at this establishment. Nerve agents used in warfare have a relatively short active life and are therefore deliberately difficult to detect. It is reported that most testing is with single doses and cannot relate to commercial use.

It would appear that this report deals with only those aspects of the OP problem that those who wish to retain their use have allowed to be examined. There are tremendous gaps in the information provided.

The conclusion must be that this is intentional but the hope is that the situation will be rectified soon.

References :

    1. The Zuckerman Report 1951
    2. The HSE Publication MS17 1987 and MS17 1980
    3. Notes on the Diagnosis of Prescribed Diseases, C3, Department of Social Security 1992.
    4. DSS recognise introduction date as 5.7.1948. MS17 1980 refers to the Act of 1965.

    5. Mechanisms of Organophosphorus ester-induced delayed neurotoxicity: Type I and Type II
    6. Mohamed B. Abou-Donia and Daniel M. Lapadula . Pharmacol.Toxicol 1990. 30;405-40

    7. Recognition and Management of Pesticide Poisonings, 4th Edition. Donald P. Morgan 1989.
    8. E for Additives, Maurice Hanssen and Jill Marsden 1988.
    9. Department of Health correspondence.
    10. Membership lists for PIAP and Working Party on Pesticide Residues.
    11. Evaluation Document for Pirimiphos-methyl, Pesticide Safety Directorate October 1997.
    12. Overexposed: Organophosphate Insecticides in Children’s Food, by Wiles, Davies and Cambell January1998.
    13. Pesticide Action Network Press Release January 1998.
    14. Various manufacturers’ own Product Use Instruction and Warning Labels.
    15. Organophosphorus Chemistry. Phosphorus in Biological Processes. B J Walker. Page 208.
    16. Organophosphorus Poisoning. Timothy C. Marrs. 1993.
    17. Encyclopaedia Britannica 1959. Chemical Warfare. Page 355.
    18. Pesticide Safety Directorate correspondence.
    19. Notes on the Diagnosis of Prescribed Diseases, C7&8, Department of Social Security 1992.
    20. DSS recognise introduction date as 5.7.1948. MS17 1980 refers to the Act of 1965.

    21. HSE PIAP Reports from years 1986, 1987, 1989/90, 1990/91, 1991/92, 1992/93 & 1993/94
    22. Annual Report of the working Party on Pesticides Residues: 1996.
    23. Health & Safety at Work etc Act 1974 gave only discretionary powers in Agriculture.
    24. Correspondence with NHS Trust and Department of Social Security.
    25. Correspondence with Health & Safety Executive and Pesticide Incidents Appraisal Panel.
    26. Organophosphate esters: An evaluation of chronic neurotoxicity effects. D. Ray 1998.
    27. RoseClear withdrawal. Thalidomide withdrawal.
    28. Correspondence with MAFF, PSD, PIAP, DOH and the Prime Minister.
    29. Plain Man’s Guide to COSHH, British Agrochemical Association 1989.
    30. MAFF ADAS advice leaflets to farmers 1978 - 1981.
    31. Countryfile programme BBC TV October 1992.


Dated 16/9/2000

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