APPENDIX 18
Memorandum submitted by the Environment
Agency (B 19)
1. INTRODUCTION
The Environment Agency's primary aim is to protect
and improve the environment and to make a contribution towards
the delivery of sustainable development through the integrated
management of air, land and water. The Agency does this through
regulation and enforcement but also by influencing and educating
industry, landowners, farmers and others to reduce environmental
impacts of their activities.
The Agency supports all necessary measures to
protect farmers from harm arising from the use of sheep-dip chemicals.
It also recognises the necessary use of veterinary medicines to
maintain sheep health. However, these chemicals can also harm
the environment and therefore the Agency is concerned to ensure
that full account is taken of this, when policy decisions are
being made on their availability and use. This memorandum provides
a commentary on the actual and potential impact of sheep-dip chemicals
on the environment, the work the Agency is doing to ensure that
this is minimised and suggests how organophosphate (OP) sheep-dip
use can be managed to protect the environment.
2. AVAILABILITY
AND TOXICITY
OF SHEEP-DIP
COMPOUNDS
At present the only cost effective substitutes
for OP dips are synthetic pyrethroids (SP) dips. Whilst these
are less toxic to humans, SP dip compounds are typically 100 times
more toxic to many forms of aquatic life, than are OP dips.
3. IMPACT ON
THE WATER
ENVIRONMENT FROM
SHEEP DIPPING
ACTIVITIES
Prior to 1996, when SP dips were not used widely,
the Agency recorded relatively low numbers of water pollution
incidents (less than 15 per annum) and there was no apparent widespread
damage to the water environment from sheep-dips. After 1996 and
because of human health concerns, there was a switch to SP compounds.
Following this switch there was an increase in the number and
the severity of water pollution incidents and in 1996 about 200km
of rivers, including very valuable salmonid fisheries, were damaged.
In 1997 and in 1998 this damage continued. Of
the 61 sheep-dip related pollution incidents that occurred in
these two years, 38 were confirmed as involving only SPs and a
further 16 were due to a mix of OP and SP dips. Surveys in Wales
suggested that at least 750km of watercourses were impacted in
1997 and 1,200km in 1998. In particular, impact was noted on invertebrates,
which are a vital part of the food chain for salmonid fish, mammals
and bird life. Similar findings on a smaller scale were recorded
in North West England.
In 1999, there was a large reduction in the
use of SP dips. The National Office of Animal Health and Entec
UK (a consultancy) have estimated that in 1999 OP dips were used
for about 50 per cent of treatments and SP dips for less than
10 per cent. Other treatment options, including injected compounds,
made up the balance.
The Agency is completing the collation and analysis
of the pollution incidents that occurred in 1999. Preliminary
results indicate that there has been a marked reduction in pollution
incidents from sheep dipping. Only six incidents were confirmed
in 1999, and all of these were from the use of SP compounds. Monitoring
in Wales during 1999 has shown that the environmental impact of
sheep-dips on rivers was less than in previous years.
Thus there is clear evidence over a number of
years that SP dips pose a significant risk to the environment
and that the risk from other options, including OP dips, is much
less.
4. AGENCY ACTIONS
Although there is strong evidence that SPs present
a high risk to the environment, the Agency has not sought the
withdrawal of licenses for SP sheep dips, because of the human
health concerns associated with OPs.
Instead, it has concentrated on:
— raising awareness of the hundred
fold greater environmental toxicity of SP as compared to OP dips;
— investing how changes to flock and
dipping management can reduce the need to dip sheep and, where
this is still required, what practical steps can be taken to reduce
the risks to the environment.
In 1998 the Agency developed a sheep-dip action
plan and in 1999 it published a sheep-dip strategy that contains
29 recommendations and actions to minimise the environmental impacts
of dipping sheep.
The Agency has also commissioned Entec UK Ltd
to prepare a guide for farmers on better flock management, in
liaison with a wide range of individuals and organisations involved
in sheep dipping. This guidance could have wider benefits to sheep
welfare (less sheep infested), farm business (reduced costs of
treatments), benefits to the environment (less dipping and less
used dip for disposal) and operators (less exposure to sheep dip
compounds).
5. THE
WAY FORWARD
The Agency understands the industry view that
OP compounds have a role to play in the effective control of sheep
ectoparasite infestation at the present time.
In the short term, the Agency considers that
the continued availability of OP dips is required if damage to
the environment from SP dips is to be contained. In the longer
term, it is essential to develop alternatives to both OP and SP
dips in order to reduce the risks to both human health and the
environment.
The Agency supports and extension of the Certificate
of Competence for sheep dipping to include proper disposal of
used dips. However, this certificate relates to the purchase and
not the use of sheep dip chemicals. There is no requirement for
the holder of the certificate to be present during the dipping
operations. The Agency will be discussing this issue further with
the Veterinary Medicines Directorate with a view to ensuring that
the competence requirements relate to those carrying out the dipping
activities rather than to the purchasers of dip.
The Agency is concerned about the lack of consultation
that took place prior to the suspension of OP dip licenses in
December 1999. The Agency has statutory responsibilities for both
environmental protection and waste handling and yet was not involved
or consulted in anyway before the decision to suspend OP dips.
The Agency does not think that there is adequate
consideration of the environmental risks posed by veterinary medicines
under the current authorisation procedures. The membership of
the Veterinary Products Committee (VPC) could be usefully extended
to include a further environmental scientist.
The Agency believes that there is a requirement
for further research into a number of issues relating to sheep
dipping activities. It supports the proposals for a targeted research
programme and will participate as appropriate. This should not
delay implementation of current best practice wherever possible.
6. CONCLUSIONS
6.1 The Agency supports the Government's
proposals to provide greater protection for sheep dip operators.
6.2 Agency investigations have confirmed
sheep dipping to be a serious risk to water quality. Sheep dip
chemicals can have a significant impact on the water environment.
6.3 Practices involving sheep dip compounds
have been poor, but there is evidence they are improving. Nevertheless
the Agency believes that dipping as currently practised is unsustainable
and cost effective alternatives need to be developed in the medium
to long term.
6.4 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.
6.5 This suggests that whilst improved management
by farmers may be sufficient to deal with the risks to the environment
from OP compounds, it is not sufficient when using SP compounds.
6.6 The Agency was not consulted over the
OP dip suspension. Given our statutory responsibilities to protect
the environment it is imperative that we are fully consulted in
future.
6.7 The Agency thinks that the environmental
risks posed by veterinary medicines are not adequately considered
by the authorisation process. The membership of the Veterinary
Products Committee (VPC) could be usefully extended to include
a further environmental scientist.
6.8 The Agency supports the proposed targeted
research programme and will participate as appropriate. This should
not delay implementation of current best practice whenever possible.
23 March 2000
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