Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by The Pesticides Trust (HSE 26)

  The Pesticides Trust is a charity concerned with the health and environmental impacts of pesticides. We work in the UK, Europe and in developing countries, and are a member of the Pesticide Action Network which links over 300 groups in 60 countries. We have eight staff and have been established for over 12 years.

  We follow pesticides issues in agriculture, urban situations, food and fibre production and public health and other sectors. We produce the quarterly international journal Pesticides News which circulates in 90 countries, together with briefing papers and research abstracts. We produce information on pesticides for users and sit on the UK government Working Party on Pesticides Residues (WPPR), the joint MAFF/DETR advisory body Pesticides Forum, and the HSE body Biocides Users Group (BUG). We also carry out consultancies for the European Commission and attend a number of UN Expert Groups on pesticides issues. We also operate a "help" line for those who consider they have been adversely affected by pesticides.

  Below is a note of the points we would like to bring to the Committee's attention. I would add that we start from the premise that HSE performs a vital public function, often under difficult conditions, and we respect the work its officers do. We hope our comments may be taken as constructive.


  HSE has a staff of approximately 100 Agricultural Inspectors, responsible for perhaps 250,000 farm premises. Farms might receive visits approximately once every six to 10 years. MAFF literature notes that one tablespoonful of spilled pesticide concentrate could pollute the water supply of 200,000 people for a day, and that in one second, two sprayer nozzles can deliver enough pesticide to contaminate a 3km long brook. Given the potential impacts of pesticides we are concerned that the level of resourcing of the Inspectorate is not sufficient to assure safety.


  There is a conflict that needs to be addressed between the Agency's role in licensing non-agricultural pesticides, and its role in investigating incidents concerning such pesticides. There has also been a lack of clarity in the Agency's role in advising and supporting other regulatory agencies (even if HSE is not the licensing authority—eg sheep dips) and its investigations in those areas.


  We have contact with users and members of the public concerned at the potential impacts of pesticides. As a result of that contact we feel that there may be a need to review the training that field inspectors receive in interviewing witnesses and gathering evidence during an investigation.


  We participate in the Health in Agriculture sub-group (HIAG) of HSE. As a result of discussions in HIAG we are concerned that HSE may be hampered in its advisory and investigative role due to a lack of enforceable health and safety standards in pesticide application technology. In particular:

    —  Although there are British Standards for knapsack sprayer manufacture, there are apparently no manufacturers in the market who are prepared to manufacture equipment to those standards.

    —  Although the benefits of correctly calibrated spraying equipment—particularly tractor-drawn equipment—are accepted, it has not been possible to introduce mandatory sprayer testing. Mandatory "MoTs" for sprayers have been one of the introductions in Sweden that have contributed most significantly to reductions in pesticide impacts.


  The introduction of the Control of Substances Hazardous to Health Regulations (COSHH) and the Food and Environment Protection Act 1985 (FEPA) and the mandatory certification of operators were both foreshadowed in the Body Report. We are concerned that:

    —  Some 13 years after the introduction of FEPA approximately 30 per cent of the UK arable acreage is treated by operators with no formal certification or training in pesticide use, according to the Agricultural Development and Advice Service (ADAS). We ask if HSE is enforcing the mandatory training/supervision requirement.

    —  COSHH requires that a risk assessment be conducted before pesticides are used, and that the results are recorded. In the majority of cases, we believe advisers and agronomists are making the spraying decisions, and farmers are neither making the risk assessment nor recording the results. We ask if HSE has evidence that risk assessments are being made and recorded.


  COSHH lays duties on operators carrying out operations that involve chemicals that may be hazardous to human health. There is no equivalent duty to consider environmental safety. The parameters of human health are relatively constant, but environmental considerations vary greatly according to the nature of the particular site in question. We would like to suggest that the Environment Sub-committee might consider whether there is a need for a parallel "environmental" equivalent of COSHH which would require the carrying out of an environmental risk assessment.


  The publication of the revised guide Reporting Incidents of Exposure to Pesticides and Veterinary Medicines has been helpful. Nevertheless we continue to receive calls from members of the public who have found it difficult to obtain clear advice from agencies as to responsibilities for pesticides incidents. Examples concern the apparent abandonment on land of pesticide containers, and the use of space insecticides where it is alleged damage has been caused to livestock and/or human health. Whilst we recognise it is difficult to anticipate all eventualities, the problem remains that the public cannot be expected to analyse carefully the facts of an incident and ensure it is reported to the corrent agency.

  A "one-stop" shop such as a help line would facilitate co-ordination between agencies and engender public confidence in prompt investigation of incidents.

October 1999

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Prepared 26 October 1999