APPENDIX 12
Memorandum submitted by the Organophosphate
Information Network (OPIN) (Scotland) (B 13)
INTRODUCTION
OPIN (Scotland) has been set up to look after the
health interests of those individuals suffering ill health as
a consequence of exposure to organophosphate chemicals. We estimate
that approximately 500 people in Scotland have had their health
affected by such exposure.
Regretfully at no stage of the time OPs have
been under licence has there been available proper diagnosis or
treatment of patient's symptoms. The symptoms listed in the Health
and Safety Executive MS 17 are those common to OPIN (Scotland)'s
Members.
It is quite grotesque that this neglect of farmer's
ill health has been allowed for so long. The Royal Colleges of
Physicians and Psychiatrists Report clearly identifies this problem
and recommends the setting up of centres with experts in various
medical disciplines to care for suspected OP patients.
I enclose a copy of OPIN (Scotland)'s recent
Petition (Annex 2) to the Scottish Parliament for your information.
OPIN (Scotland), and its members, are concerned
that OP Sheep Dip will be re-licensed before proper and acceptable
diagnostic and treatment facilities are in place to deal with
possible future victims of accidental or careless exposure.
Furthermore OPIN (Scotland) is concerned about
the legal implications for litigation for any ill health caused
by future exposure through spillage or inhalation from the re-designed
containers. OPIN (Scotland) wishes to know who or what agency
will be approving the re-designed container for use.
As the VPC, HSE and VMD failed to ensure a safer
container was produced by the manufacturers in 1994 when the problem
was first identified it will not be appropriate for them to be
associated with the approval procedure. It is not known how many
workers have had their health damaged through exposure since the
failure of these agencies to have a safer container produced.
However the threat of exposure lies beyond simply
opening the container. OPIN (Scotland)'s members have revealed
other areas of exposure not considered. Under new regulations
regarding the preparation of animals for abattoirs lambs and sheep
have to be cleaned. The area in question is the crotch high in
lanolin. OPs by their very nature hold onto fat. Most lambs are
dipped 14 days before going to the abattoir. The contact shearers
have with OP residue in the wool is a constant threat to their
health. No guidelines have been laid down for this exposure threat.
In addition workers in the abattoir (including MAFF vets), when
skinning the carcasses, handle the wool. Several OPIN (Scotland)
members health is attributed to their contact with OPs in this
way. There are no guidelines in effect for these workers. Until
this is properly investigated it is important OP dips are not
re-licensed. Unless this issue is resolved ignorant workers' health
will be under threat. The re-designing of a container will not
help them.
OPIN (Scotland) is taking this matter up with
the Trade Unions representing farm and abattoir workers.
THREAT TO
HEALTH
The Committee is no doubt aware of the recommendations
of Lord Zuckerman in 1951 and HSE MS17 in 1980 that workers exposed
to OPs on a regular basis should have their blood cholinesterase
levels measured pre and post exposure. The Committee is also probably
aware that these recommendations were never enforced. They must
be before any re-licensing of Ops is even considered. Every worker
coming into contact with OPs should have their cholinesterase
levels tested prior to any re-licensing of OPs.
LICENSING PROCEDURES
It is also vital that the licensing procedure
must be examined. It does not work towards assuring users that
a product is safe to use. As previous Committee Reports state
the aim of the licensing practice is to ensure the "safety,
efficacy and quality of the product towards human beings and animals".
No one, apart from producers, has faith in the present system.
We submit that a system that relies solely on
the data of producers is unacceptable towards enforcing these
aims of "safety, efficacy and quality".
The evidence is there for all to see:
1. it is alleged epichlorohydrin, a carcinogenic,
was removed in 1981. No studies were carried out then or since
on users to see if any individuals had been affected by exposure
to the mixture. A system that allows companies to include such
a toxic chemical and to withdraw it without any investigation
is unscientific and unacceptable;
2. it is claimed phenols were withdrawn from
the OP dips in 1993. The circumstances are incredible:
(i) the VPC request data from the producers;
(ii) the producers, en masse, withdraw phenols
from the dips;
(iii) the producers do not submit the data;
(iv) the VPC does nothing, it does not:
(a) ask the producers for data;
(b) ask the producers why they all
did this together;
(c) ask why the phenols were removed;
(d) research the effect phenols were
having on the OP (diazinon); and
(e) research the effects of phenols
and OP as a mixture on users.
A licensing system which allows producers to
dictate the rules is not a competent licensing system. A product
cannot be safe because the producers claim it is. It can only
attain the standards of "safety, efficacy and quality"
if it has undergone rigorous safety checks by an effective licensing
authority.
A persistent theme of all the reports of the
nineties is the recommendation that additives in OP dips be researched
to discover whether the toxicity of the OP product is increased.
This recommendation by respected scientists and included in the
recent COT Working Party Report has never been put into action.
All kinds of chemical additives are used to ensure OP products
are stabilised and yet are never researched to analyse their toxicity.
This is unacceptable and must be rectified before any re-licensing
of OP products takes place.
ADVERSE REACTION
REPORTING
The COT Working Party Report was highly critical
of the lack of substantive data on OP patients submitted by the
various Adverse Reaction Schemes. It was held to be of no value.
Sufferers could have advised this. They have absolutely no faith
in the various schemes and have no wish to co-operate with them.
A proper and independent adverse reaction scheme
must be set up to competently, clinically investigate the reports.
It cannot be right that the VPC are responsible for both the licensing
and the assessing of ill health. On an ethical basis it is suspect
that such a scheme is still in operation. Who on earth is going
to find evidence that the product they have licensed is a threat
to health of those using it?
Until a proper effective scheme is set up OPs
should not be re-licensed. Furthermore representatives of sufferers
should have a seat on the panel for sufferers to have faith in
the operation of any scheme.
ALTERNATIVES TO
OPS
It is not imperative that OPs should be re-licensed.
I enclose a letter (Annex 1) from an OPIN (Scotland) member who
is a contract dipper and shearer as well as a substantial sheep
farmer. His is the common sense approach which has been missing
from the debate. The entirely safe alternatives should be used
that are no threat to health. The submitting to the whinings of
the chemical companies and various other bodies demanding the
re-licensing of OP dips must be avoided.
Decisions taken by officials and scientists
who have never witnessed sheep being dipped, never experienced
the debilitating ill health as a result of exposure to OPs and
never seen a loved one deteriorate physically, emotionally and
intellectually are desperately suspect. It is time the defence
of the OPs be looked at and sufferers listened to.
No one has ever proved OPs are safe to use or
that they do not cause ill health. Until they do, which will be
never, OPs should not be re-licensed until all the recommendations
of various committees, groups and officials are properly assessed
and put into practice to protect the health of future users.
CONCLUSION
The recommendations that have been avoided are:
1. the toxicity of additives and their influence
on the toxicity of OPs should be researched;
2. a competent Adverse Reaction Reporting
Scheme should be set up separate from the VPC/VMD;
3. an acceptable diagnostic and treatment
arrangement should be set up separate from the NPIS;
4. the licensing system should be investigated
and re-organised to ensure it is not the producers dictating the
system;
5. a statutory testing system should be instituted
for all workers using OPs as recommended by Lord Zuckerman and
the H&SE; and
6. GPs should be given training in the diagnosis
of OP related ill health.
These recommendations should be instituted prior
to any re-licensing of OP dips to ensure farm workers and dippers
are properly protected from exposure to OP dips. The health of
workers is far more important than the health of sheep whose welfare
can be efficiently managed with alternative methods.
However, the most important issue is the way
in which the VPC licenses medicines such as OPs. It cannot be
allowed to continue to base its decisions on the basis of data
submitted by the producers. There has to be greater scientific
analysis of the products by independent scientists prior to licences
being granted. With the widespread availability of Gas Chronograph
machines it would not be difficult or delay the decision on licensing.
I would like the opportunity to address the
Committee on this issue.
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