Supplementary memorandum submitted by
Georgina Downs (Z 37a)
1. GENERAL COMMENTS
(a) I would like to submit the following
additional written comments to the Environment, Food and Rural
Affairs Committee's inquiry into issues relating to "Progress
on Pesticides."
(b) I have attended all the oral evidence
sessions relating to this inquiry. Therefore the following comments
have been formulated as a response to some of the comments made
by various witnesses, especially as my evidence or "information"
was referred to directly in a number of sessions.
(c) First of all I have to raise concern
that the EFRA Committee has not received oral evidence from anyone
outlining the adverse health effects that are being reported in
rural areas following exposure to pesticides from crop-spraying.
Therefore this has resulted in a lack of true public representation
in EFRA's oral evidence sessions in relation to people directly
affected from crop-spraying activities, which includes impacts
on their health, environment, as well as costs and other financial
implications.
(d) I find this completely unacceptable,
as at present it is the public that subsidises intensive farming
at a cost of approx. £3 billion per year (External Costs
of UK Agriculture, Jules Pretty, 1996). However, despite this,
the taxpayer then has to pay again in both financial and human
terms for the damage caused to their health and the wider environment
and therefore the position of people directly affected from crop-spraying
activities should have been represented in oral evidence to the
EFRA Committee.
(e) I have sat through oral evidence sessions
where farmers, industry and Government officials, along with a
Government Minister have made misleading claims that definitely
does not portray the reality of the situation regarding the health
and environmental effects of pesticides, especially for people
who live in rural areas.
(f) The evidence presented by various witnesses
stressed that problems only occurred through the misuse or illegal
use of pesticides and that there is no (or very little) health
or environmental effects if pesticides are used in accordance
with the approval and abiding by label instructions.
(g) However, there is no way that a farmer/grower
or other pesticide user can prevent pesticides, once they are
airborne contaminants, from being in the air. The reality is that
once dispersed pesticide particles and droplets cannot be controlled,
they are airborne contaminants and can travel considerable distances.
Scientific studies have shown pesticides located miles away from
where they were originally applied.
(h) In an article in the Farmers Weekly
on 31 March 2004, Alan East who is the technical services and
registration manager from the company Interago stated "The
application of crop protection products is generally inefficient
with only 15% of applied pesticide reaching its target."
(i) Therefore this is a fundamental point,
as this is not simply about the issue of immediate spraydrift
at the time of application and misuse of pesticides or overspray,
but the wider issue of exposure and contamination as a result
of the actual release of pesticide particles and droplets into
the atmosphere/environment.
(j) As I have pointed out in my previous
written evidence, long-term exposure to residents and others in
the countryside from pesticides in the air after application (and
not as a result of immediate spraydrift), is currently not considered
in the current regulatory system for pesticides.
(k) Many farming and industry representatives
believe that the answer to managing and minimising environmental
contamination of pesticides can be found in advanced technology,
better nozzle design and improved training and this is reflected
in many of the targets of the VI. However, this is an unrealistic
portrayal of the real scope of the problem, as in relation to
volatilisation, precipitation etc. that can occur days, weeks,
even months after application, then it is immaterial how good
the nozzles of the sprayer may be at the time of application.
(l) Barry Dent said during his oral evidence
session on 21 February 2005 that there were nine chemicals that
were identified as most likely to pollute water. However, it should
be pointed out that you can only find what you sample for and
obviously tests are not carried out on every single drop of water
in the UK.
(m) A good example of this is when the Environment
Agency took some samples from the ground water in our ditch that
adjoins the field, in 2002. The results showed the presence of
four chemicals. Two of these were organochlorines that had been
banned in the early 1980's (Dieldrin and Tde (pp) which is a congener
of DDT) and this obviously shows their persistence to still be
there over 20 years on. The other two chemicals, Cyanazine and
Pirimicarb, had both been used on the field in the previous weeks
before the samples were taken and on questioning the Environment
Agency stated that these were not chemicals that were usually
found in groundwater.
(n) I have heard various witnesses, as well
as the EFRA Committee members themselves, in relation to environmental
costs, concentrate predominantly on the contamination of water,
which does not portray the overall external costs that exist from
the use of chemicals in agriculture. These external costs include
damage to human health (both acute and chronic) contamination
of air, water, soil, biodiversity and impacts on the wider environment.
Therefore the cost of removing pesticides from water is just the
tip of the iceberg in relation to all the health and environmental
costs, that are paid for by the public and this has not been adequately
covered in the EFRA oral evidence sessions.
2. COMMENTS RESPONDING
TO STATEMENTS
MADE BY
VARIOUS WITNESSES
REGARDING THE
HEALTH IMPACTS
OF PESTICIDES
(a) The EFRA Chair pointed out during the
oral evidence sessions that the EFRA inquiry was not set up to
look specifically at health. However, I cannot see how it would
have been possible to have an inquiry on the "Progress
of Pesticides," which assesses the environmental impacts
of pesticide use, without incorporating the effects of exposure
to pesticides on human health. The current system for agricultural
spraying legally allows mixtures of pesticides and other hazardous
chemicals to be sprayed, repeatedly and frequently throughout
every year, near to people's homes, schools, workplaces and other
places of human habitation. This has obvious impacts for people
living in agricultural areas in relation to the potential adverse
effects on their health, as a direct result of the release of
pesticides into their air and surrounding living environment and
therefore the two, health and environment, are inextricable.
(b) However, despite strong questions being
put to the various witnesses regarding the health impacts of pesticides,
I felt that the EFRA members did not really challenge the responses
that were given, which was disappointing.
(c) I would like to respond to the following
comments made by some of the witnesses during the oral evidence
sessions.
(d) Joan Ruddock asked the AIC about prostate
cancer and asked if exposure and measurements of exposure were
being addressed?
(e) In their response the AIC referred to
the labels on the products and that contractors take the appropriate
measures to reduce exposure, including the use of PPE. However,
this is obviously not something that the general public and in
particular rural residents can do.
(f) In the oral evidence session on 21 February
2005, David Forman from the Committee on Carcinogenicity stated
that "It is anticipated that any risks in those living
near to farms would be exceedingly small and not measurable by
any epidemiological techniques as exposures would be predicted
to be much lower than in individuals with occupational exposure
to pesticides."
(g) However, there have not to date been
any measurements in either the UK or the EU of the actual exposures
that people are receiving when they live in an agricultural area,
as it is all based on predictive models only. Therefore
the comments made by David Forman are based on pure speculation
and portray a lack of understanding of the true exposure that
people are receiving in this specific type of exposure scenario.
(h) Also it should be pointed out that regardless
of how small Government advisors, regulators or Ministers claim
a risk to be, pesticides are not supposed to be approved for use
if there are any risks to health from their use. It was interesting
to note that the Food Standards Agency initiated the withdrawal
of products containing the substance Sudan 1 as a "precautionary
measure" and stated that " . . . the risk is
likely to be very small, but it is sensible to avoid eating any
more. "
(i) I continue to receive reports from people
not only in this country, but from all over the world, as health
and environmental problems resulting from the use of pesticides
is an international problem and is not just confined to the UK
and the EU. Some of the illnesses and diseases that have been
reported to me include various forms of cancer, including prostate
cancer and breast cancer, Non-Hodgkins lymphoma, leukaemia, Parkinson's
disease, amongst other things.
(j) For example, in one area there is a
cluster of seven cancers in a row of approx. 10 houses that back
onto fields that are regularly sprayed. One of these cases involved
a man who was diagnosed with prostate cancer at the age of 52
and unfortunately by the time the cancer was diagnosed it had
already spread to his bones and he died within two years of diagnosis.
Years later the gentleman who had bought the same house was also
diagnosed with prostate cancer and again by the time it was diagnosed
it had already spread to his bones. The fact that both men had
lived in the same house that backed onto sprayed fields, at different
times (and where they would not have been wearing any protective
clothing) raises important questions. However, examples like this
that have been presented to Government scientific advisors, regulators
and Ministers have just been discounted as insignificant, without
any actual investigations.
(k) In the oral evidence session on 21 February
2005, David Coggon stated that "We have recommended that
further work be commissioned looking at the mechanisms of toxicity
that might underlie a link between chemicals and Parkinson's disease,
because if we had a clue that one particular pesticide or group
of pesticides might be responsible, then we might be able to commission
epidemiological research looking particularly at that group of
pesticides."
(l) This again highlights the uncertainties
and serious data gaps surrounding human exposure to pesticides
and the link with chronic disease.
(m) As highlighted in my previous written
evidence, the recent pesticides literature review from the Ontario
College of Family Physicians found consistent evidence linking
pesticide exposure to brain, kidney, prostrate and pancreatic
cancer as well as leukaemia, non-Hodgkin's lymphoma, neurological
damage, Parkinson's disease and other serious illnesses and diseases.
(n) The review found that children are particularly
vulnerable to the effects of pesticide exposure and identified
increased risks for a number of illnesses and diseases, including
kidney cancer and acute leukaemia.
(o) The Ontario reviewers' concluded that
the literature does not support the concept that some pesticides
are safer than others, it simply points to different health effects
for different classes of pesticides.
(p) The college's overall message to patients
is to avoid exposure to all pesticides whenever and wherever possible.
(q) Therefore exposure cannot be allowed
to continue unabated whilst any suggested research takes place
and therefore urgent action has to be taken to prevent exposure
and protect peoples' health.
(r) In the oral evidence session on 24 February
2005, Alun Michael picked up on the fact that the Chair, Joan
Ruddock had referred to the submission I made to the EFRA Committee
as "information" rather than "evidence.
" He stated that "Concern is not the same thing as
evidence of impact or a connection."
(s) This is a misrepresentation of the "information"
(evidence) that was provided to the EFRA Committee, a good proportion
of which the Minister has previously seen. The material submitted
includes references and quotes from international peer-reviewed
scientific literature in relation to the dangers of pesticides,
the risks inherent in their use and acute and chronic long-term
ill-health effects that can result following exposure.
(t) The Chair, Joan Ruddock asked the witnesses
if there were any investigations specifically looking into the
clusters of ill-health conditions that are being reported in rural
areas. The response from the PSD representatives was "no.
" Alun Michael then stated that "That would have
to be a response to evidence that there was something specifically
to address."
(u) Therefore it would appear from Alun
Michael's comments that if evidence does not fit the desired viewpoint
it is discounted as merely "information, " which
therefore does not need to be acted upon, as it isn't "evidence.
" However, it should be pointed out that the word "information"
is defined in the dictionary as "facts or knowledge provided
or learned as a result of research or study. "
(v) Therefore perhaps this may not have
been the word that Alun Michael had meant to use if he was trying
to minimise (or discount) the significance of my evidence!
3. COMMENTS ON
THE DRAFT
NATIONAL PESTICIDES
STRATEGY CONSULTATION
DOCUMENT
(a) There are a number of references in
the text of the document, as well as the accompanying cover letter
that the UK National Pesticides Strategy will be developed following
"close Consultation across DEFRA and with industry, environmental,
consumer and other Stakeholders."
(b) However, considering it is well acknowledged
by the Government that I represent people who live in agricultural
areas and who are therefore directly affected by pesticide spraying,
then I find it bizarre that I was not included in the list of
Consultees.
(c) There is no mention of the impact on
rural residents and communities from crop-spraying activities,
which includes impacts on their health, environment, as well as
costs and other financial implications. As the Consultation is
open to anyone to submit, I shall obviously be making representations
on behalf of people who live near sprayed fields. However, it
would appear that from my non-inclusion on the list of Consultees,
along with the nature of the text in the Consultation document,
the Government is mainly concerned with any burdens being placed
on farmers and industry rather than protecting the health of rural
residents and communities.
(d) On page 28 of the Consultation document
it states that "Legislation is often unpopular and unless
EU wide, can disadvantage UK businesses." I have to stress
that this issue should not be whether something is unpopular,
but whether the proposed measure is necessary and essential to
introduce!
(e) There is barely any mention at all in
the Consultation document of health effects, as it is centred
on the environmental effects of pesticide use. The regulators
continue to maintain that a robust system is in place to protect
public health. This is misleading and is not factually correct.
(f) Due to inherent uncertainties, serious
data gaps and fundamental flaws in the current risk assessment
processes and monitoring systems there does not appear to be any
evidence to support Defra's continued assertions that pesticides
are safe and that there are no health risks to people in the countryside
from crop-spraying. Therefore there is no evidence that the clusters
of acute and chronic long-term illnesses and diseases that are
being reported in rural communities are not related to pesticide
exposure.
(g) The National Pesticides Strategy Consultation
document repeatedly refers to the "sustainable use of
plant protection products" and in fact it is also stated
in the title. I cannot see how the use of pesticides could ever
be described as "sustainable," as it is a contradiction
in terms. As the Soil Association pointed out in the Memorandum
submitted to the EFRA Committee " . . . agriculture should
be sustainable; the application of complex chemicals designed
to kill plants or insects is not sustainable. "
(h) During the oral evidence sessions comments
were often made by various parties, including the EFRA members,
about how the public want to see a reduction in pesticide usages,
(which is not part of the VI) and the substitution of more toxic
pesticides for less toxic.
(i) However, as a representative of the
public it must be stressed that the people who contact me actually
want to see an elimination of pesticide use and other chemical
inputs in the production of food, rather than inadequate measures
such as reduction and/or substitution.
4. CONCLUDING
COMMENTS
(a) The Voluntary Initiative (VI) appears
to be little more than a PR exercise. It does not focus on health
and in fact very little is said on health at all. Voluntary and
self-regulatory measures have existed for decades, have not worked
and are completely unacceptable in this situation. Therefore the
introduction of statutory measures is essential.
(b) The origins of traditional farming methods
did not include reliance on chemical inputs for mass production.
The use of pesticides and other hazardous chemicals has resulted
in devastating consequences for public health, animals, wildlife,
air, water, soil, food and the wider environment. This has massive
economic and financial implications for all parties (with the
exception of the pesticide industry) that are impossible to quantify.
In my opinion, these issues were not adequately addressed in the
EFRA Committee's oral evidence sessions.
(c) Obviously a long-term approach is needed,
rather than inadequate measures aimed at addressing problems only
in the short-term. The impact of agricultural pesticides on public
health and the environment is not going to be solved by a little
"first aid" or by "papering over the
cracks" as the whole core foundations and structure on
which the current regulatory system operates is inherently flawed.
Neither the VI nor the National Pesticides Strategy consultation
document addresses the fundamental failings of the current system
to protect public health and the environment from exposure and
contamination of pesticides.
(d) The protection of public health has
to be the overriding priority and take absolute precedence over
any financial, economic or other considerations.
(e) Members of the public deserve to be
protected from avoidable and unnecessary exposures and risks to
their health. Substantive evidence already exists to demonstrate
a serious public health problem and therefore the significance
of these consequences requires the adoption of a preventative
approach.
(f) The only responsible course of action
for the EU and UK Government to take is an immediate ban on crop-spraying
and the use of pesticides near homes, schools, workplaces and
any other places of human habitation and direct access for the
public to all the necessary chemical information.
(g) The only overall solution to this problem
is through the widespread adoption of sustainable non-chemical
and natural farming methods to protect not only public health,
but animals, wildlife, air, water, soil, food and the wider environment,
for now and for future generations.
Georgina Downs
UK Pesticides Campaigner
March 2005
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