Supplementary Memorandum by The Pesticides
Trust (HSE 26(a))
I refer you to the evidence from The Pesticides
Trust already submitted to the Committee[1].
As discussed, the following supplementary evidence (which includes
a response to Mr Brake's Q191) comprises information gathered
from a questionnaire survey of our members, and from a meeting
with Mr Graham Walker, HM Principal Inspector of Health &
Safety, Agriculture (lead Principal Inspector for pesticides),
with Alison Craig, on 17 November 1999, at the Pesticides Trust
office.
I also attach notes on the pesticide incident
reporting system in California (in response to Mr Donohue's Q177).
Full details of the questionnaire survey method
are attached.
The results we have obtained support our evidence
in the following respects.
Inadequate resourcing of the HSE
Seven of the 15 key questionnaire respondents
report that the HSE appeared to be short of staff or time when
they reported a pesticide exposure incident to their regional
HSE office.
Although we understand from the HSE that 84
HSE Field Operations Inspectors are "ring-fenced" for
inspecting incidents in the Agriculture, Wood and Forestry Sector,
and in their view this is adequate, we do not agree.
Need for emergency "one-stop shop" for
reporting incidents (like Environment Agency's)
Ten of the 15 key questionnaire respondents
believe that this would help to make the reporting of incidents
easier.
Quality of HSE response to, and field investigations
of, pesticide exposure incidents
Only one of the 15 key questionnaire respondents
report that the HSE Inspector seemed to have the technical competence
to investigate the incident proficiently.
Only seven of the 57 questionnaires returned
in all report that the HSE Inspector seemed to have the technical
competence to investigate the incident proficiently.
Seven of the 15 key questionnaire respondents
report that evidence about the incident was lost because of a
delay in the HSE response.
Not one of the 15 key questionnaire respondents
report that samples were taken (to gather evidence about the incident).
It is HSE policy that only Scientific Officers
are permitted to take samples, and they are only taken when there
is very strong evidence anyway that there has been a contravention
of pesticide regulations. The time taken to make this decision
may mean that samples are taken too late to reveal the presence
of pesticide residues.
In the view of the Pesticides Trust, vegetation,
soil, water, clothing and body metabolite samples, as appropriate,
should be taken routinely at an early stage in the investigation
of a pesticide exposure incident.
Training of HSE Field Operations Directorate Inspectors
We understand from the HSE that this comprises
one year of formal probation, at the end of which the recruit
should know about how the industry works, occupational health
issues, law, induction; they do four modules of the NVQ, and learn
how to issue Improvement Notices (but not Prohibition Notices),
and about prosecution. Then they do a six-month diploma course
in Health and Safety at Aston University (the only place in the
UK that does the course). There used to be a third year in which
recruits were on probation, but that's now gone.
There is little detailed information about pesticides
in this course. The Agriculture Inspectors can subsequently attend
(on a non-compulsory basis) an Agriculture Appreciation five-day
course. In this, some industry literature and British Agrochemicals
Association videos are used.
In the opinion of the Pesticides Trust, this
training is inadequate with respect to pesticides and pesticide
exposure. It cannot be possible to cover over 400 active ingredients
and their effects within this framework. It explains the inconsistent,
sometimes poor, responses reported by our members. In our view
the need for improved training in the HSE should be addressed
as a matter of urgency.
Conflict of interest between the HSE Inspectorate
role and licensing of pesticides role
Six of eight key questionnaire respondents,
asked about the HSE's attitude to the pesticide involved in the
incident, and who answered the point, report that HSE acted as
an advocate of the pesticide.
FURTHER ISSUES
OF CONCERN
We understand from the HSE that callers alleging
ill-health from pesticide exposure incidents, when they first
telephone their regional HSE offices, are always told to see their
GP as soon as possible, and to tell the GP that they have been
exposed to a pesticide.
— Not one of the key questionnaire
respondents report that they were told by their regional HSE office
to see their GP, let alone as soon as possible.
— Eight of the eight key questionnaire
respondents who give an answer on this point report that they
were not told to see their GP.
This is a finding of great concern.
The HSE and the protection of public health regarding
OPs
Farmer Mr Jim Candy has raised the concern with
the HSE that many farmers are exposed to OP sheep-dip at livestock
auctions, when handling sheep. He has been assured by the HSE
that they have informed farmers and auctioneer professionals about
the health risks, and advised them on the correct protective equipment.
He has made enquiries among these groups, and claims that they
have received no such guidance from the HSE.
Attitude of the HSE towards pesticide exposure
incident complainants
There is no evidence from the questionnaires
of HSE bias towards pesticide-users.
Four of the 15 key questionnaire respondents
report the following attitudes of the HSE inspectors: positive,
excellent, sympathetic, helpful.
However, the following reported attitudes are
of concern:
— dreadful, arrogant, disinterested,
patronising, "on farmer's side—hostile".
Alison Craig
PEX Project Coordinator
1 Ev. page 73 (HSE 26) HC 828 Session 1998-99. Back
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