For the Attention of the Advisory Committee on Pesticides.

Some observations on the draft "REPORT OF THE PESTICIDES ADVERSE HEALTH EFFECT SURVEILLANCE SCHEME WORKING GROUP (PAHES) "

It appears that whenever there is an indication of ill-health caused by exposure to approved pesticides, a "confounder" must be found that would explain those symptoms, even if the nature of that "confounder" is unknown.
In other words any adverse effects are explained away, even though it is known that the life processes of the target organism may well be identical to those in the humans adversely affected. (1.4)

WHO recommendations are assumed to be able to be ignored because our regulatory system is so excellent but experience demonstrates that this is far from the truth...(1.6)

Oddly the effects of single exposures are admitted but it is then suggested that long-term effects of exposure, which are simply the result of repeated, sometimes continuous, single exposures, are only said to be only "possible" (1.7 c)

Only "dose" is considered and not the vulnerability of the targeted process, which may be damaged by minute doses.(2.1)

"Odour" is suggested only as a means to recognise the presence of the pesticide when in reality it is exposure to the chemicals in the air. In some cases scientists have denied that pesticides have "odour" even when the affected individual has correctly identified the pesticide only by smell. (2.2)

Domestic pesticides are said to be the most commonly reported exposure and mostly affecting children but these are much weaker formulations often of the same chemicals used in agriculture where effects to children are denied (2.3 iii)

Ability to penetrate skin is mentioned. ADAS, when a government agency, reported that skin applications of OPs had the same effects as injecting them into the blood stream - more dramatic than simple penetration. (2.4)
Yet the larger surface area in the lungs is wrongly suggested here to provide low entry into the blood stream (2.5)

The definition of bystanders undermines the argument regarding comparing exposures to operators and bystanders since a bystander might be just passing or exposed for days on end after application due to the chemicals being released from the sprayed crop - even poisoning of operators is denied but countless numbers have been confirmed as poisoned.(2.7)

It seems that long-term effects such as cancer caused by a single exposure that targets a vital process does not even feature in the thinking. I suppose death would be represented by a plateau response. (2.8)

All the science regarding the toxicity of glyphosate (anticholinesterase, mitochondria, birth defects etc) is ignored (2.9)

Quite how all the required evidence for exposure linked health effects could be obtained without notification and access to chemical information is not explained, especially when reported incidents are ignored. (2.10 - 2.13)

PIAP failings are legendary with even diagnosed poisoning cases deemed as not even likely on more than one occasion with, it appears, no information provided or published on any pending cases. Given the above where are the blood and urine samples to be obtained when most if not all incidents are disregarded?
There is a glaring and serious flaw in the system that is causing that vital data to be lost.(2.14 - 2.19)

Most studies are based on calculations which are themselves based on incomplete and often incorrect information (as above) and this has been reported to all the regulating agencies. It seems that acute exposures include only those hospitalised but many are never treated for poisoning by pesticides as the symptoms mimic other diseases less controversially diagnosed.
Hospitalised patients given the correct treatments are the least likely to suffer long-term health effects when compared to those not fortunate enough to have the cause of their illness recognised quickly and the correct treatments given. (2.20 - 2.25)

With some pesticides the HSE has been on record as admitting that PPE offers little or no real protection. Again the dangers of domestic use are admitted but the effects from professional use are doubted. Passing a test does not result in compliance with advice or regulations in practical use once qualification is achieved. (2.26)

The resulting data from such studies would therefore also suffer sampling bias and from flawed assumptions. Again it is assumed that operators have greater exposure but in reality those living near treated crops continuously would obviously be those with greater exposure and a greater likelihood of the connection between ill-health and pesticides being missed both as a result of the false assumptions, on exposure levels and the amounts needed to trigger illness, and the potential delay in onset of effects in those where repeated exposures have induced the adaptation effect. (2.29)

The failings of the above tests are admitted at (2.31)

There is no recognition of the fact that serious reactions can be triggered at very low levels in those made susceptible either by their genetic makeup or as the result of previous exposures. There are no "standard" people. (3.1)

Residential exposures which can be long-term and to multiple chemicals do not even merit a mention. (3.2)

The dose makes the poison was proven wrong by the well tested GE drug TGN 1412 that triggered serious adverse effects in volunteers in drug trials at much lower doses than those tested on animals.
This is an outdated belief which suits the regulators but endangers those exposed. (3.3)

Animal tests are not comparable since people live longer, have higher consciousness of effects on their bodies and minds, and can describe their symptoms, even though their accounts are usually ignored. In any event (see 3.3 above) tests implying safety on animals and birds have been proven to give false assurances of safety (3.4)

No study or surveillance scheme will achieve any worthwhile results until the reports of those exposed who have been made ill are taken with the seriousness they deserve. (3.5 - 3.6)

A spontaneous reporting system is doomed to fail unless there is notification; contemporary and timely access to chemical records by the exposed and their GPs; and a quick reporting system for all suspected cases. There is a built-in assumption for both pesticides and pharmaceutical products that all products are tested and unlikely to induce adverse effects. That assumption alone creates the dangerous delays and failure to report all adverse effects but even when they are reported those at the next stage also assume safety and regularly ignore the reports. (3.7 i)

Poisons Services are proven to have dishonestly hidden even confirmed cases of poisoning. (3.7 ii)

Occupational reports are unlikely given insecurity of employment and often linked housing. HSE's failure to act on such matters is legendary and it has not gone without notice that published HSE articles about the dangers on farms now completely ignore the obvious dangers to employees, visitors, and children from pesticides. (3.7 iii)

Research papers confirming adverse effects are normally ignored with ways found to dismiss them. (3.7 iv)

NPIS failings are confirmed in (3.8)

Pesticide use is much more common and complex than single cause issues (3.9)

Poisonings are frequently missed even when hospitalised. (3.10)

The suggestion that there are "very small numbers exposed" ignores the fact that we are all exposed via food, air and water to varying degrees, even when walking, riding, or driving, through towns and cities or on aircraft and trains.(3.12)

Self-harm usually results in hospitalisation and will never therefore reflect outcomes in those not recognised or incorrectly treated. Results from such studies may be of interest regarding single dose effects but acute effects are already well understood and any data generated would not have relevance to long-term exposures. (3.13)

Pesticide users who have undergone training may or may not be exposed more than people such as residents. Their use of pesticides varies greatly from once or twice a year to daily depending on the circumstances and the exposure will also vary according to application methods, machinery used and PPE standards, both worn and provided. (4.2)

There are obvious problems as explained above when trying to link symptoms, serious illness, and cancers, to pesticide exposures when records of pesticide use may not be available and many years have elapsed (4.3 - 4.4)

Response rates for studies may well be low because of the refusal to recognised poisoning cases and the abuse suffered by those who have been poisoned with the added factor that many have suffered blatant deception by medical examiners who have ignored their own findings in order to either avoid criticism by their peers or to hide poisoning cases (4.5)

Again the weaker garden formulations are admitted to have cause harm but the very agencies that approve the chemicals are given the task of determining if those chemicals have caused harm. There is an obvious conflict of interest. (4.8)

Companies who provided the data for approval are also involved in determining poisoning cases and even though they test for the symptoms of poisoning during pre-approval phases those very same symptoms are denied as linked when those who have been poisoned report to them. Again the weaker garden formulations are admitted to give cause for concern and yet the much stronger agricultural versions are suggested as being much safer. Health professionals also take the symptoms from the patients but sadly even when serious symptoms and signs are present those same professionals often either fail to recognise them as resulting from exposure or deliberately ignore same. (4.9)

The THOR system also requires medical practitioners to both know the chemicals involved and to understand the symptoms induced not only by the declared active ingredient but also by the co-formulants and mixtures of pesticides.
This is impossible even in the best case scenario since all ingredients are not even declared, farmers do not have to provide timely information of mixes, and manufacturers admit to not knowing the toxic potential of mixes or the symptoms that may be induced by exposure to them. In addition once again these difficulties present with acute exposures and bear no relation at all to the much more complex chronic and long-term effects of exposure.(4.10-4.15)

Again hospital data is relied upon but few cases are actually recognised as linked to pesticides in time for the patient to obtain the correct hospital treatment. Again this is only relevant for acute exposures about which much is known. (4.17)

Other potential causes for reported symptoms will be highlighted causing a dangerous delay before pesticide involvement is admitted and acted upon by use of the treatments that may by then be dangerous in themselves. (4.18)

PIAP has proven itself to be both incompetent and dishonest on numerous occasions and it takes the lead from the HSE. Both have equally poor reputations when it comes to pesticide incidents,which are often denied even when confirmed by medical professionals. (4.19 - 4.24)

The NPIS is equally suspect, given its links to the industry and its track record of hiding poisoning cases by deception.
There is evidence to show that even when they have confirmed poisoning that fact has then been denied. Despite this the figures show that the number of poisoning cases has risen in the period for which figures are supplied with the suggestion made that only one units figures were previously reported, making the entire table uninformative. (4.29)

Poisoning cases have even been denied by the NPIS when cholinesterase evidence proves the case. (4.30)

Even pharmaceutical reactions are rarely reported, especially when they are the result of using contraindicated medicines in poisoning cases, or in error by the use of potentially dangerous drug combinations. (4.33 - 4.41)

I am unable to comment on the data held by The UK Pesticide Campaign but such information may well hold the key to the problem and should not be overlooked. (4.42 - 4.43)

The PEX group activity does not appear to have been supported or encouraged for some time. Some who have reported to PEX have had no response and been forced to give up attempts to report incidents. Both medical and legal advice have been offered in the past with lists of practitioners that offer to help poisoning cases having been published.
How much real assistance to the poisoned individual is available from that quarter is yet to be determined and although the group claims that reports to it are "anecdotal" many have sent details of confirmed poisoning cases.
Again the group has very close relationships with the regulatory and investigatory agencies which may weaken their position and counter their claim as being independent representatives of exposed people..(4.44 - 4.47)

The list of reporting schemes around the world (Table 3) demonstrates how weak the current systems are and how the information gleaned from them cannot be relied upon. Worker compensation schemes in the UK are proven to be corrupt with most cases denied compensation even when they have supporting diagnosis.

Again it is assumed that chemicals cause no damage even when metabolites are discovered in samples and yet simple biochemistry shows that serious damage can be done to vital organs and processes at much lower exposure levels. (4.50)

Again the much weaker amateur products are admitted to cause harmful effects. (4.54)

A serious weakness in the already poor UK system is seen in the failure to correctly identify the chemicals involved when recording pesticide exposures. This makes all other figures useless. (4.61)

By contrast the Washington scheme is much more powerful though it also has its limitations. (4.64)

The Canadian scheme is similar (4.68 - 4.69)

The WHO scheme does not appear to apply in the UK and seems to be only for acute poisonings. (4.70)

The German scheme is akin to the idea I suggested to the UK regulators some years ago with all suspected cases having to be reported so as to provide an early alert system in addition to collating pesticide incidents, although it seems that even in the German system not all cases follow that obvious course. (4.73 - 4.79)

None of the schemes will collect information about residential exposures or even long-term occupational exposures as they are all centred on acute or even hospital admission cases.
What is needed is a comprehensive reporting system for all suspected cases of ill-health resulting from pesticide exposure be that direct exposure or the result of vapour release from treated crops or equipment etc.
Any system requires that the affected person must have direct access to the information about the chemicals involved and most exposures, but not all given the release from treated crops, could be avoided by prior notification.
There is no way that dose level reporting could be possible in UK situations and blood samples for pesticides are rarely taken except in exceptional circumstances. (4.84)

Even recognised adverse health effects are rarely recognised or recorded as linked to pesticides. (4,85)

It is wrong ro insist on short time-lapse between exposure and onset of symptoms as this will avoid any recognition at all of delayed effects in chronic poisoning, which may result from an accumulation of exposures over time. The last exposure may be a relatively minor exposure deemed wrongly by medical professionals and investigators as not to be sufficient in itself to trigger symptoms.(4.87)

Even for serious and confirmed poisonings by the most dangerous pesticides there has never been any real follow-up of those cases by poisoning specialists or neurologists etc. (4.88)

Pesticide sales figures are no help at all but the incidents of ill health could potentially be linked to pesticide use data from farm records - always assuming that those records are accurate and that there is no incentive for false information on pesticide use to be recorded by farmers who either act in breach of rules or actually use illegal pesticides. It should be remembered that only the person actually using the pesticides knows exactly what chemicals are used and whether or not the regulations pertaining to use have been complied with. There is ample evidence regarding the provision of false records and the use of illegal pesticides and mixes for which no records at all will be admitted. (4.89)

Any data from models would presumably depend on data from manufacturers, which are known to be inaccurate - and grossly so with certain half-life figures which are assumed wrongly to be the same for the active ingredients as for the commercial formulations. (4.90)

Without notification of impending pesticide use and direct access to information about actual chemical use there will never be timely reports of health problems related to pesticide exposure. (4.93)

Long-term effect studies must take into account any changes of life-styles and residence since the exposures. All too many cases of pesticide-linked ill-health are lost because people change their jobs or move away from the areas in which they were exposed. (4.95)

Nor is it true that modern pesticides are removed rapidly from the body, as fat samples have shown. (4.96)

It is obvious who should pay for the surveillance. The companies that pollute and profit from the pollution should pay, as has been government policy for decades under the "Polluter Pays" rules. This is especially so if those companies are given vital information arising from the data that enables them to see adverse effects before large compensation bills would be required. (4.97)

The EU is right to require a reporting scheme for the adverse health effects of pesticides but it would be pointless without the intention to act on the data obtained. Currently we have products on the market that have been approved despite proven adverse effects and serious doubts over the accuracy of safety data.
Reporting is not a problem if there is someone to report to who will take the issue seriously. Once the report is made and the chemical is identified there is ample time to collect any further information required which is why I suggested that in the UK we have a two-stage reporting system, The first stage being the initial report of suspected adverse effects from exposure with details reported to the manufacturers and regulators. All reports must then be properly investigated, as all cases should be, and then the second tier of reporting would confirm or disprove the link to pesticides with a full report made to both the regulators and the manufacturers. This system would provide an early warning of problem chemicals or formulations giving the opportunity either to improve the product or withdraw it so as to avoid further cases. (5.2)

The current scheme is no where near as good as is suggested at (5.4)

As mentioned previously monitoring of hospital patients in the long-term will miss those cases of chronic poisoning that were not recognised as such and therefore did not receive the correct treatment for pesticide induced illness. (5.6)

The long-term follow-ups referred to are for acute cases only. (5.7)

PIAP is useless anyway and so a completely new but more efficient and comprehensive system with new members with no links to PIAP or to the approval agencies is required. (5.8)

It is vitally important that not only the public but also farmers and GPs should be made aware of the fact that pesticides can induce poisoning symptoms, even when used correctly. It is of interest that when the DoH Pesticide Poisoning publication was sent to all GPs in April 1996 few even bothered to read it. Farmers deny the dangers while their employees and the public are unaware of the very real potential for serious adverse effects on their health and are therefore duped into complacency by the inaccurate information supplied to them. (5.11)

The costs of any scheme would be recovered by the fact that manufacturers and the government would save legal costs and it is probable that fewer people would need medical attention for poisoning and the illnesses triggered in the long term if the scheme works effectively. (5.13)

It is important that those exposed MUST have direct access as early as possible to the information about the chemicals to which they have been exposed. Any delay is potentially life-threatening if GPs treat symptomatically with contraindicated drugs. This should present no difficulty to farmers who keep accurate records and many would be able to report what chemicals they used on what fields from 30 or more years ago! (5.14)

Unfortunately despite all the evidence and the obligation on governments to protect the health of the population the decision made denied the prior notification of pesticide use for residents and did not make it compulsory to provide pesticide information on request to those affected who still find that their reports of adverse effects are not recorded or officially recognised.