Select Committee on Agriculture Fifth Report


III. EFFECTS OF THE WITHDRAWAL OF OP SHEEP DIPS

11. The Farmers Union of Wales told us that "organophosphate compounds provide the most effective insecticide for the treatment and prevention of the major ectoparasitic infections in sheep".[50] MAFF countered this with the argument that "There are ... other products available (synthetic pyrethroid (SP) dips and injectables) for the control of ectoparasites including sheep scab. Pour-on products are also available for parasites other than scab".[51] Professor Aitken commented that "each of these alternatives has been through the regulatory process ... and they are only available if efficacy can be demonstrated".[52] Nevertheless, a number of concerns were expressed about the animal welfare, economic and environmental impact of the unavailability of OP sheep dip and/or the use of alternatives. The impact of OPs on human health was also raised. We discuss these issues in the following paragraphs.

Animal welfare and health

12. The Tenant Farmers Association believed that "There are few viable alternatives to dipping using OPs that can be used on a wide spread basis", with the consequence that "sheep health could suffer" from the OP ban.[53] Other organisations agreed, with the National Sheep Association arguing that the alternatives do not have "the same broad spectrum activity on ecto parasites",[54] and the Farmers' Union of Wales adding that pharmaceutical companies "have also expressed concern that the incidence of scab resistance to synthetic pyrethroids is likely to accelerate substantially if there is increased usage".[55] These concerns led to calls for fast-tracking approval of new packaging or to the National Farmers' Union proposal for "some sort of derogation to use OP dips under supervision in exceptional circumstances ".[56]

13. Asked what advice had been given to farmers on the control of sheep scab in the wake of the withdrawal of OPs, Professor Aitken told us that industry figures showed that "OP dips were used for about 50 per cent of the sheep in the country" and the remaining 50 per cent were subject to other treatments, so "there is an armamentarium of specific products ... to treat ectoparasitic infestation".[57] (MAFF later clarified these figures as referring to percentage of sheep dipped, not the whole UK flock.[58]) Nevertheless, he accepted that "OP dips have the advantages of being broad-spectrum in their activities" and "are very effective".[59] Fast-tracking would depend upon the "plans that the manufacturers have for improving container design and thereafter it is a matter of generating stability data", testing for which "could be done in the short term in three months".[60] Baroness Hayman confirmed that "it might be that an interim solution could be provided more quickly because it did not need such long stability trials as a long-term solution".[61] However, any derogation looks unlikely since Baroness Hayman assured us that "it is not that it is impossible to find an effective mechanism for dealing even with a large-scale outbreak" in the absence of OPs.[62] We are concerned about the lack of an acceptable, effective alternative to OP dips. Whilst we welcome the fact that "the state veterinary service has set up a working group to look at welfare issues"[63] and the £1.6 million research programme for alternative strategies to control sheep scab,[64] we believe that there should be a 'Plan B' in case of a major outbreak of sheep scab during the period of time farmers are without OPs. We recommend that MAFF consult on and publish such a plan as a matter of urgency.

Economic issues

14. The sheep sector, as with the rest of agriculture, is currently in serious economic difficulty which makes additional demands on farm budgets hard to bear. Farmers find OP dips are attractive not just for their superior performance but for their lower costs compared with alternative products.[65] Longer withdrawal periods for alternatives such as injectibles make them unsuitable for use on sheep destined for early slaughter, thus restricting the marketability of the sheep where they are applied.[66] Allied to these concerns is that of the economic impact of poor quality sheep skins, i.e. those that had suffered from lice and scab, beyond the farmgate. The British Leather Confederation highlighted the increased number of damaged skins following the progressive "relaxation and abolition of compulsory sheep dipping".[67]

15. Mr Anderson of MAFF countered that "Compulsory dipping was ended in 1992 ... [because] the policy was not working in terms of having any success in eradicating scab",[68] although Baroness Hayman was aware of "anecdotal evidence" that the incidence of scab is increasing.[69] She also assured us that the economic impact of the withdrawal of OP dips had formed "part of the context in which the decision was taken".[70] Nevertheless, she believed that "we have a responsibility to take the appropriate action to ensure that we minimise the risk that people then choose to take or not take".[71] We recognise that in the situation where a properly quantified risk to human health can be demonstrated, it should be remedied where possible. But economic factors must be considered in any impact assessment. The balance between these two considerations could be weighed more effectively if the real level of incidence of sheep scab were known, as well of course as the real risk to human health of OP dips. We recommend that the Government assess the level of scab and evaluate the economic impact upon farmers of alternative approaches to eradicating sheep scab from the UK. We further recommend that the likely economic cost to farmers of the withdrawal of OP sheep dips be assessed and published.

Environmental impact

16. Witnesses generally agreed that OPs have a further advantage over alternatives in that they have "the least cumulative negative side effects on the environment".[72] Synthetic pyrethroid (SP) dip compounds, for example, "are typically 100 times more toxic to many forms of aquatic life, than are OP dips", according to the Environment Agency.[73] The Agency had found that "The number of recorded pollution incidents match the usage of SP dip compounds. There were 34 incidents in 1997 and six in 1999, and the quantity of SP's as a percentage of total sheep dip compounds for the relevant periods was 38 per cent and 10 per cent respectively".[74] Questioned about the environmental impact of SP dips, Professor Aitken accepted that "the fact they are particularly toxic to aquatic environments and aquatic invertebrates is well-established and well-known".[75] The Minister agreed that "There are down sides to all the alternatives",[76] but she placed her reliance on "the environmental impact study that had been made to allow SP dips on the market".[77] She added that "I am sure as statutory advisers the Environment Agency are concerned about the growing use of SP dip and its effect on the environment and they will alert Ministers to that".[78] We are concerned that the impact of the increased use of SPs as a consequence of the withdrawal of OP sheep dips was not sufficiently acknowledged in reaching the decision, a point that closely relates to the failure to consult the Environment Agency. The Agency will no doubt monitor pollution incidents and SP usage over the period that OP dips are unavailable and we await the results with interest.

Human health implications and risk assessment

17. Organophosphate compounds have long been linked to human health problems.[79] Although this was not the main concern of our inquiry, we did raise certain aspects of the issue. On one side of the argument, we were told that "the threat of exposure lies beyond simply opening the container",[80] whilst the National Association of Agricultural Contractors' experience suggested that "OP sheep dip concentrates handled by trained operators are not a risk to the user".[81] The advice on the effects of OPs on human health makes a distinction between the effect of the concentrate and low level exposure. The Institute of Occupational Medicine's report suggested that "exposure to concentrates was associated with an increased likelihood of ill-health in the groups of subjects studied".[82] Baroness Hayman interpreted it thus: "I think the weight of scientific evidence is that there is no doubt that exposure to the concentrate can be dangerous to human health and have very bad effects on human health".[83] The Committee on Toxicity reported that "the effects of long term exposure at low levels were still not certain".[84] We hope that while the use of OPs is prohibited the research into their effects will continue apace, and that the concerns raised about human health are properly examined, including any effect on those handling dipped sheep.

18. Nonetheless, we were more than a little concerned that the risk of OP contamination associated with dipping sheep had not been quantified more carefully before the withdrawal was announced. For example, we accept that the existing containers are "a source of potential contamination"[85] and that "exposure to concentrates is the greatest hazard to human health"[86] but for the Government's advisers to find it "extremely difficult to quantify" the impact of wearing protective clothing and then to provide a qualitative assessment that the risk "is very substantially reduced"[87] if it is worn seems hard to justify in this context. It is important that the action taken by Government is seen to be proportionate to the risk and this can only be done in terms of a proper risk assessment made freely available to all interested parties. We acknowledge the strength of opinion on both sides of the debate as regards a complete ban on OPs but we believe that the risk of OP concentrate to human health should have been made more explicit in the Press Release from MAFF where the message was blurred by the stress on official advice against any general withdrawal of OPs from the market.

Conclusion

19. There are strong environmental, economic and animal health and welfare arguments in favour of OP sheep dips. However, there are potential human health effects and we accept that these must carry a considerable weight in deciding whether a product should be withdrawn from the market. In this case, both sides of the argument should have been presented to the industry in a clearer fashion.


50  Ev. p. 25, para 17. Back

51  Ev. p. 2. Back

52  Q 93. Back

53  Ev. p. 31. Back

54  Ev. p. 45. Back

55  Ev. p. 26. Back

56  Ev. p. 30. Back

57  Q 91. Back

58  Ev. p. 21. Back

59  Q 90. Back

60  Q 92. Back

61  Q 87 Back

62  Q 93. Back

63  Ibid. Back

64  Q 92. Back

65  Ev. p. 35. Back

66  Ev. p. 45. Back

67  Ev. p. 39. Back

68  Q 119. Back

69  Q 113. Back

70  Q 111. Back

71  Q 109. Back

72  Ev. p. 45. Back

73  Ev. p. 54. Back

74  Ev. p. 56. Back

75  Q 101 Back

76  Q 98. Back

77  Q 99. Back

78  Q 100. Back

79  Ev. p. 37. Back

80  Ev. p. 37. Back

81  Ev. p. 54. Back

82  Ev. p. 1, para 3.1. Back

83  Q 10. Back

84  Q 2. Back

85  Q 35. Back

86  Q 36. Back

87  Q 38. Back


 
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