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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 258-iii House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE ENVIRONMENT, FOOD AND RURAL AFFAIRS committee (sub-committee on Progress on Pesticides)
Monday 21 February 2005 PROFESSOR BARRY DENT PROFESSOR DAVID COGGAN and PROFESSOR DAVID FORMAN Evidence heard in Public Questions 245 - 316
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Environment, Food and Rural Affairs Committee Sub-Committee on Progress on Pesticides on Monday 21 February 2005 Members present Joan Ruddock, in the Chair Paddy Tipping Mr Bill Wiggin ________________ Memorandum submitted by Professor Barry Dent
Examination of Witness Witness: Professor Barry Dent, Chairman of the Voluntary Initiative Steering Group, examined. Q245 Chairman: Welcome to everybody. This is our third session of the inquiry into the Progress on Pesticides. As our first witness today, I am delighted to welcome Professor Barry Dent, who is the Chairman of the Voluntary Initiative Steering Group. We are grateful to you for the written submissions you have made. You will know we have questioned some members of the group already on the Voluntary Initiative, not the Steering Group, but the participants. Obviously we are delighted that you are able to come and answer our questions orally this afternoon. I thought it might be useful if you were to begin by giving us a view of your role as the Chairman of the Steering Group. Professor Dent: Thank you, Chairman. It is a pleasure to be here. My role is simply to co-ordinate the activities of the VI. Essentially, my remit was to make sure the various projects which made up the VI were implemented on time to quite a tight time schedule and were implemented within the resources that were available; to report to the Minister from time to time and to provide appropriate reports. In fact, it has turned out to be quite a challenging operation, I guess partly because the Steering Group itself has been fairly disparate in its view. That has been a strength because we have had people from all aspects of interest - environment and agriculture and so on - everybody has made a really solid contribution. I think we have been able to create a very good feeling within the organisation. It has been a privilege to set this thing going and to have got this far. Q246 Chairman: You have mentioned resources, tell us something about how it has been resourced? Professor Dent: The whole of the VI is resourced from the signatories; they provide the funding for the various projects. That is collated at the end of every financial year so that we produce an annual financial statement. Often times there are internal adjustments according to the funding which is available on any one project, but essentially it is totally an industry funded operation. Q247 Chairman: No Government money, in other words? Professor Dent: Sadly no, Chairman. We might talk about that later. Q248 Chairman: You say it is a daunting task, a privilege and all the other things and you say you have had to try to get them to meet their targets, to do it on time and all the rest of it. How has that been possible in eight days a year? Professor Dent: It has not been possible in eight days a year. You must understand that is a token payment for my services. I guess I put in four or five times more than that during the course of the year. Q249 Chairman: You have not sought any adjustment of the fact that the Chairman is being paid for eight days only and this is a task that cannot be done in that time. Professor Dent: I do not let it constrain my activities, at least too much, but, on the other hand, I think there is more I could do if there were more days. By and large I have been able to do all I feel I ought to do within my timeframe, not within the eight days, that is quite possible. Q250 Chairman: Do you want to say if there is something very particular you might have wished to do if you had more time? Professor Dent: Attend more sub-group meetings. The Voluntary Initiative Steering Group operates not only as a full group but also by way of sub-groups which work on particular problems and I do not get to all of those meetings. I get the minutes and I interpret from that, but I do not get along because I cannot afford the time to do that. Q251 Chairman: You will probably know that in the evidence we have taken so far there is quite a range in terms of the appreciation or not of what the Voluntary Initiative has achieved. We have had your written evaluation, you think it is doing very well, but where are the weaknesses as you might perceive them? Professor Dent: The thing which strikes me as the most important weakness is that I have failed to establish what I consider to be a real partnership with Defra. I take some of the responsibility on that myself. I have to say, right at the very beginning of the Voluntary Initiative it was made fairly clear to me, at the first meetings, that the Voluntary Initiative is on its own and is not going to be supported in any way by Government and one felt it was very much a cold shoulder. I think the VI, the way it was conceived in the joint agreement between Government and the signatories was that it would be a bottom-up process and involve lots and lots of farmers and others in the process. Over time I think we came to realise this was going to be difficult without a commensurate top-down meeting, a kind of context in which the VI could operate. If we want to achieve maximum environmental improvement, which is my goal anyway, we need to surround the Voluntary Initiative activities within some assistance from Government. That has been difficult to achieve. I have to say, linkages with Defra - personnel and Ministers - have got a lot better as time has gone on and arrangements are very cordial at the moment. I am trying to make a distinction between my sort of talking at the Minister and the Minister talking at me and a kind of collaborative view of things. We hear each other but we do not necessarily work things out together. The Minister has always challenged me and said: "The targets for the VI are not challenging enough", you see that frequently in the correspondence. On the other hand, I am saying: "Minister, I need some support from Government. It is there, if you can direct it towards me". Q252 Chairman: Why would you need support from Government to make your targets more challenging? Professor Dent: I think there are two separates things. On the one hand, it is pushing for more challenging targets and, on the other hand, I am saying there are issues which could be achieved which require a little bit of additional input. Q253 Mr Wiggin: What I understood that to mean was the carrots and sticks the Government could be offering you are not there, is that what you are saying? Professor Dent: Exactly. The stick was there - and we might talk about that - but the carrot could have been quite simple. We have a national register for sprayer operators. Usually these are farm staff and it seems entirely right and proper that the Government should make some contribution towards the training necessary to keep them on the professional register, to upgrade their professional skills. We have always thought that ERDP funding would be a very good way of achieving this. What we find, in the kind of operation we have, the national picture, it is extremely cumbersome and bureaucratic to get the money out of the ERDP to do it effectively. That would be one area where I think an easier carrot could be achieved. Another area which I have always tried to pursue is we have this project dealing with Crop Protection Management Plans and, essentially, these plans are self audit by farmers to try and engage their farming practice against environmental standards. The VI is responsible for signing farmers up to such an initiative, but it becomes pretty clear that it would be very desirable to move farmers through from average practice to better practice to best practice to excellent practice within those Crop Protection Management Plans. We would very much like to achieve that and we think agri-environment money would be highly appropriate for that slight carrot. We think the payoff would be enormous because there would be farmers moving through the Crop Protection Management Scheme towards better and better environmental practice. Those are two examples of things where I think relatively small amounts of not new money can be directed towards the Initiative and it would make a big difference. Q254 Chairman: Basically what you are saying is the Voluntary Initiative is just not integrated into the overall thinking of the Department or the direction which is being pursued? Professor Dent: It is certainly getting better, I think that is true, but we have not planned together. Q255 Chairman: I think we understand that. Is it a case that you just plod on until 2006, you meet your targets and that is the end of the matter? Is that how you measure success, if you have done all the things you said you would do by 2006, finish? Professor Dent: I think there are some things we will find difficult to achieve without some commensurate action from Government. Q256 Chairman: Even within the existing targets, you say you may not meet those by 2006? Professor Dent: There are some elements which will hinder us in meeting targets, whether we will meet them is another matter. One area, if I can mention, is dealing with the amenity sector. The amenity sector is within our remit but, quite honestly, we do not have any leverage in the amenity sector at all. We have an operation which is very patchy in the way that sector functions. There are some elements of that industry which are really excellent - Network Rail, for example, are very good - but what you have to understand is you are dealing with a chemical, mainly diuron, which is a particular chemical the amenity sector uses. This chemical is being sprayed, by the amenity sector, often on to hard surfaces and that is where quick run-off from hard surfaces into drains and rivers causes problems. For the rest of that sector, I should not and I probably do not need to use the word "cowboy", but there are some responsible elements in there, but the local authorities treat this as a cost reducing exercise. It is quite clear - we have put out a report on this matter - that local authorities let contracts which are managed by people who have not had appropriate training and who are under pressure to reduce the cost of the contract. Therefore, they are taken up by contractors who are looking to cut costs, who use a lot of temporary labour, who are not trained, who do not have, in many cases, a professional register status and who are not using equipment which is well geared up to the job. The amenity sector is subject to a code of practice, which is a Government drawn up code of practice, called the Orange Code. That is being amalgamated with the Green Code, which is the agricultural code. It is not with us yet because it is a very difficult job to update codes of practice but I think it is something that I would like you to think about in terms of how we manage such documentation and such function of Government in terms of setting up statutory codes of practice. In any case, I do not think codes of practice are going to create the kind of environment within the local authority sector that we need. I think there is a route for ministerial steerage, if not regulatory input. There is an example where we have a major chemical over which we have precious little control and may well cause us to at least not exceed the targets by as much as we might have hoped to. There are other examples. Q257 Chairman: Let me just ask in light of what you have just said, in the studies that have been undertaken, of which you are aware, is it possible to say which of the chemicals end up in the watercourses? You have just given us quite a lot of detail about local authorities and the amenity sector and one particular chemical, do you know that this chemical is disproportionately ending up in watercourses or not? Professor Dent: I think it is important to understand that as far as the Voluntary Initiative is concerned we have a situation where we are dealing with nine major chemicals that are likely to cause pollution within the river system. We have to set that against 500/550 products marketed by members of the Crop Protection Association. We are talking about a small number of chemicals, so one of them is important, and that one is. A similar situation which I would like to draw your attention to is a chemical called IPU, which you have probably heard of. Q258 Chairman: That is why I am asking you what I am asking you because we were dealing with Isoproturon last time and we were dealing with that as though that was a major problem and I am wondering how that compares with the chemical that you have just referred to. Professor Dent: The issue really is that they vary according to the region. Isoproturon is very important in some regions and less so in others. We do not have a blanket situation and that is part of the problem. You have some chemicals that are extremely awkward and difficult in some regions. Our approval system, and I am sure you will talk to Dr Coggon about this later, is blanket in nature. If a chemical is approved then it is approved. Some of my colleagues and myself would like to see a much more flexible approach to approvals to give an opportunity perhaps within a region to create a time window for a chemical to be approved and it cannot be used outside that time window. I think this would help to solve issues such as the IPU problem that we have talked about. Chairman: That is interesting, thank you. Q259 Paddy Tipping: We can measure the success of the VI by the number of people taking part but it is more difficult to measure success by environmental indicators. We are told the weather, for example, plays a major part in this. What is your thinking? How could we develop the environmental indicators a bit more? Professor Dent: I think this is really a very difficult area. The first thing I would like to say, and it impinges on the material we have just talked about, is that VI does not exist in isolation, it is part of a massive change that is going on in agriculture and there is more and more to come in the next months. It is very difficult to say we do this job with the VI and, therefore, these environmental improvements will take place; it just is not like that. I think the most sensitive indicator that we have in an environmental improvement context is water purity, water pollution, and I think we need to review the databases that we have for monitoring water quality in relation to chemicals. There are two sources of data. One is the database established by the Environment Agency which was set up as not anything to do with chemicals but it was to do with drinking water standards. That is the database that we actually use. It has its drawbacks but the EA have worked quite considerably to try and refine that. The only other sorts of data available, in fact, are private data that belong to the water companies. The beauty about that data is that the water companies are monitoring continuously, always, so they pick up every spike of pollution that there is and that is really the strength of the work that we are doing in the catchment areas because we are learning to interpret spikes of pollution in river waters and trying to relate it back to activities of farmers within that catchment. Q260 Paddy Tipping: Are all the water companies co-operative? Do they use the same data? Is it consistent across the field? Professor Dent: I am not able to answer that directly because we have not worked with all the water companies, but the water companies that we have worked with we have had good co-operation with and I think there would be opportunities for that kind of collaboration, but I have not explored it at this point in time. Q261 Paddy Tipping: Finally, Newcastle University have been commissioned to do some work around environmental indicators, what is the work that they have been commissioned to do? What are you looking for from it? Professor Dent: When it was commissioned it seemed to be a project that was to assess the effectiveness of the VI. You know the history behind all this, it was a project that was set-up and I did not know anything about it and was not brought into. I found out from colleagues and obviously I was a bit cross when it happened. Q262 Paddy Tipping: Just expand this a bit more. Defra have commissioned this research, have they, without any consultation with you? Professor Dent: Yes. It was an unsatisfactory thing. I think it is well appreciated within Defra now and certainly I found it difficult to manage at the time but, however, we did bring the team into the steering group and asked them to give us a pitch on what they were doing. To be honest, I have not actually seen any of the results since that time, so I do not know how well the project has gone. I think the steering group felt at the time they reported things to me that it was not going all that well, the team was relatively inexperienced. Q263 Paddy Tipping: Just help me a bit more on this. This sounds incredibly naïve. Why would Defra commission some research into a VI without talking to the people involved in the VI? Professor Dent: I think at that time and before there was not very much co-ordination between Defra and the VI and there were instances of the VI not being mentioned in pesticide publications by Defra, for example, when we were in full flight doing things. At that time the relationship was not too good. I hasten to say it is very much better now. Q264 Mr Wiggin: I am glad to hear the relationship is a great deal better but I do not know why the targets for the Voluntary Initiative were not ever agreed with Defra. Why not? Professor Dent: May I explain the nature of the water quality targets which are slightly complicated. They relate to the European Drinking Standard quality of ten parts per billion. Every time there is an exceedence picked up in the Environment Agency data, that represents a bad mark. The number of exceedences which were to take place was to reduce by 30 per cent by the end of the VI. That is the nature of the thing. I do not know where this 30 per cent came from, it is a figure and it is a complete mystery how it applied. I think it came from a study which was done for Defra by some consultants who were looking at the possibility and the impact of a tax when they were saying something like if a tax of about 40 per cent was applied to all pesticides then we might get a 30 per cent reduction in exceedences of these nine chemicals in the way I have spoken about. I have never been too happy about taking that on. I really do not know whether that is an important, significant reduction or not; it may be or it may not be. Clearly successive ministers have felt that it was not challenging enough but I have resisted changing it until recently. Since Christmas, we have sent a new set of data to the minister in which we have accepted that a 30 per cent reduction in exceedences will be the minimum that we would hope to achieve and in a conditional sense, if certain things are in place, we would hope to get nearer to a 50 per cent reduction. In a way, I feel that has been squeezed out of me and I have not been too keen to move in that direction for exactly the reason I have mentioned, that we have been uncertain about how that figure was ever established. Q265 Mr Wiggin: I am sorry, I am a little perplexed by this. You have changed some of your targets, and I am going to ask you how many in a moment, but I do not understand why because you have not been supported by Defra, you have got council amenities, which mean councils spraying outside the VI of essentially one of the nine chemicals at least that you are targeted to reduce. It looks like you are just being kicked around a bit here. It does not sound like it is as serious as it should be and I do not understand. Professor Dent: Certainly I got that feeling when we started. As I say, I felt very much a cold shoulder at the beginning. The impression I got was that the minister at the time wanted to test whether the VI would function and was less concerned about the overall impact on the environmental parameters. Q266 Mr Wiggin: Do you think that is just because they want to bring in a tax? Professor Dent: At the time I did, yes, but I think now the situation is different. Q267 Mr Wiggin: So how many of your targets have been revised? Professor Dent: We have moved a few. As I say, we have moved the water pollution target upwards, which I think is a measure of the success of the VI. Q268 Mr Wiggin: If you achieve it, I would definitely agree. Do you think you will? I hope so. Professor Dent: By March 2004, which was our last accounting period, we had met every single indicator target that we had set up and I felt really very confident at that time. Equally that applies for water quality as it does for some of what we call change of behaviour targets. I think that is worth saying. At the last accounting point we had met every target that we were required to. The targets were not agreed in a formal sort of sense where we sat round a table and knotted out an agreed position, what we did say is "This is where we are and we have modified some of the targets a little bit because we have more information". For example, one of the things that is now becoming important is that in this change in agriculture the number of farmers, the number of farms have got smaller, have got bigger, the equipment has got bigger and there is less equipment, so we set ourselves a target for March 2005 of 10,000 tested spraying machines. We felt that because of the information we had, and it looks as if there is about 20 per cent less in the way of machines in the field, it was much better to talk about the area covered by spraying machinery and we would attempt to cover 50 per cent of the area by this March. It was that sort of modification that we were concerned with rather than trying to make the target softer. If anything, we are trying to make the targets a little bit harder. Q269 Mr Wiggin: Perhaps some written evidence might be helpful on which ones you have moved. Certainly the critics will pick on that and it sounds to me as though you have given ground but you are actually trying to deliver a more effective reduction in the nine target chemicals. Professor Dent: Exactly. Q270 Mr Wiggin: What worries me is that if you are not successful then a number of farmers could be affected by the actions of the county councils. Professor Dent: I take that point entirely. Q271 Mr Wiggin: What proportion of farmers is involved in the Voluntary Initiative and how do you bring in the ones that are not? Professor Dent: Farmers are involved in different ways. One of the things I want to leave with you is how successful the VI has been in meeting the targets which relate to the way in which farmers change what they do. I think that we have now got the broadest based change for the better in the environment ever within the UK. It has been a big change with thousands of farmers who have been involved and they are involved in various ways. They are involved in terms of the professional register for sprayer operators and that is locked into the framework, the infrastructure of agriculture, now because it is part of the food assurance operation. Now we have in principle exactly the same agreement with insurance companies for the sprayer testing scheme. We have two major planks of behavioural change firmly locked into the farming environment, the infrastructure. We have Crop Protection Management Plans as part of the entry level scheme. We have major improvements in the training programmes for agronomists. Professional agronomists need to be on the professional register too and to do that they need to go through a programme which has now been revamped to be very strongly environmental and there is a new programme called the Beta Programme which is optional but a lot of agronomists are on it. What I really want to say is that with those I have mentioned, and others, we have created a new infrastructure around crop production and horticulture within the UK and that is there, it is firm, it is locked in, it cannot be changed in the foreseeable future. We have got a total cultural change completely locked in and in that sort of situation I cannot see why anybody would still worry about a tax. A tax cannot achieve any more than that and, in fact, it could do more damage than good in that sort of situation. Chairman: We are going to come to the question of a tax in a moment. Q272 Mr Wiggin: Can I just finish on this because the final part of my question is how much advantage would be gained from underpinning the measures contained in the Voluntary Initiative with, on the one hand, legislation or, on the other, a stricter code of practice? How do you draw in the non-farming sectors who are not particularly tax sensitive anyway? Professor Dent: In relation to the non-farming sectors, I think that has got to have ministerial input. Q273 Mr Wiggin: Legislation? Professor Dent: One way or another I think it has to have, I do not think we can deal with it in any other way. It is important. Sorry, I missed the first part. Q274 Mr Wiggin: The other thing is if you are going to have ministerial intervention to get the amenity sector in, what are you going to do about the farming sector when the Voluntary Initiative finishes? Should it be legislative or should it be a stricter code of practice? It sounds as if you are going to legislate for amenities, you might as well legislate for the whole thing. Professor Dent: I do not think that is desirable. As I have said, we have changed the infrastructure in which farming operates now for the better from an environmental perspective. I do not think we need to think about that. I hope we do not need to think about a finish of the VI absolutely in March 2006. I would like to see a strong role for something like the VI with a different remit, obviously, in there to monitor and to bring on new projects and so on. I think parts of the amenity sector are really different but there are strong reasons to believe that what we have achieved within VI will stick. Q275 Chairman: I just want to tackle that issue of what you have achieved in the VI because I think you have given us a very clear view of how processes have been changed, how the sprayer operators have the machinery, farm management plans, all of those things, and you say they are embedded and all the rest of it, all of which is highly commendable, but I think we, as a Committee, are really concerned to know whether, as you have suggested, it was better for the environment because I do not think we have found the evidence at all convincing that the environment has shown significant change that can be attributed to the VI. Professor Dent: Chairman, I do not think that it will either. It is not something that is as black and white as that. I could say to you that the most sensitive parameter we have got as far as the environmental improvement is concerned is improvement in water quality and I could say to you, but I am not, that we have achieved a 23 per cent improvement in reduction in exceedences at the last recording stage which sets us in very good stead for meeting this. I do not want to say that and I do not want you to think that is a solid achievement because, as you well know, other factors have been involved. How much they have been involved, I cannot really respond to that because I do know. What I do know is that within the catchment projects, which also have had difficulties since we last recorded things, we have also had a very major reduction in exceedences measured in a very thorough way by water quality data. There are still problems popping up there but we think we have got a very much better chance now looking at the catchments in a way that is very focused to try to get a better input/output relationship, a cause/effect relationship. I could point to an overall England and Wales situation where we have had a 23 per cent reduction in exceedences, where we have had a 50 per cent reduction in exceedences in catchments, but I feel if I did that I would not be giving you a straight answer and I cannot in all conscience do that. There are some improvements that have taken place which have been recorded and I think are illustrative of the difficulties. With other environmental parameters we have talked about biodiversity and another plan. On the whole, biodiversity is measured by populations and things ---- Q276 Chairman: I think we will accept that is something else and we have not taken a great deal of evidence on that. Just on the water issue, when we were questioning the NFU in one of the catchments, I think it might have been the Leam catchment, there were around 600 farmers participating in that programme but you would have to roll it out to about 60,000 farmers, I understand, if you were to get that intensity of working that is surrounding the projects which might conceivably be ones where one could relate the practice that is being undertaken by the VI and the results that are being given in terms of improvement in water quality. Professor Dent: There are many catchments in the country for which there are no problems at all, the problems do not exist, but there are catchments where there are severe or average problems, whatever. Our learning in each catchment is different, the problems and issues in each catchment are different: soil type, type of farming and all those kinds of things. We need to learn general principles. We are very much aware of Defra's responsibility in the Water Framework Directive to look at catchment sensitive farming. We think that we are learning lessons here. We have certainly set up some tools in this programme and we have done some research in this programme which we believe will be of generic value to catchment sensitive management for the future. I think that is where we are at this point in time. We do know that we can make a difference but we have not had a big sample of input on that. It is costly research and it is costly effort because you are working really quite closely with quite a number of farmers. Q277 Paddy Tipping: You mentioned taxation earlier on and I think you were advocating the threat of the tax being taken away now. Initially it was a driver that brought the VI in and now you think it is counterproductive. Professor Dent: I was really very disappointed by the way in which the draft National Pesticide Strategy while being inclusive of the VI, and I was very pleased to read that, at the same time maintained the words that the threat of a pesticide tax should apply. I feel that there is now no need for that. As I said to you, we have got embedded in the infrastructure of farming a set of procedures which are locked in by the insurance companies and locked in by policy through the entry level scheme and so on, and locked in by the professional background of farmers, agronomists and farmers themselves and so on, and it is better than anything that we could achieve with a tax. I know that countries within Europe have experimented or have already got a tax and I do not know what the overall impact of that tax has been, I know it has not been all that terrific. In France, of course, it has been nothing because they have set the pesticide tax at a zero rate, which is very French I guess. We have a situation where a tax is a totally unknown quantity for us at this point in time. I have read that hypothecated tax would provide for training and would provide for advice. That may or may not be the case, hypothecated taxes are difficult things to manage in government, I imagine. Q278 Paddy Tipping: How is the threat of a tax affecting farmers' behaviour? Professor Dent: If you are with me on that, I am a total believer and it is part of my philosophy that the polluter pays. I very strongly adhere to that principle. The flipside of that is that the non-polluter does not pay. When you are dealing with a diffuse pollution like pesticides and nutrients, as you will be doing in the future, it seems to me to be highly inequitable, unfair, that everybody should pay for the errors or the lack of ability of the few. I am very much against tax on this inequitable nature and its untried functioning. What we have done is to replace anything that a tax would do in, I guess, a British kind of way which says let us do it our way, let the industry make the pace, let them fit a voluntary framework into place which is embedded, as I say, which will control the way farmers function in the future and anyone who needs to sell through an assurance scheme will need to adhere to the protocols of the insurance companies and that will be for professional register membership and proper testing of machines, an MOT, if you like, for machines. Q279 Chairman: I wonder how it is possible to produce enough money to work, as I said earlier, as intensively as the VI has worked with the small numbers of farmers in the catchment areas, if it is necessary to do some of that work to really drive down pesticide pollution. Where will the money come from to do the work that is required and to take in the other sectors which you have acknowledged yourself are not even involved at the moment? Professor Dent: As you know, the catchment work is going to be expanded. We are going to double the number of catchments that we are going to be working in and we will be looking at better tools to get better information to farmers. I would like to see the future VI in one of its roles acting as a kind of information centre whereby those who are dealing with catchments, other than the ones that have been part of our study, will go for information, will go for guidance about how they might advise farmers in those areas. I do not think that we can be all things to all farmers. What we have to do with this kind of study is be generic in nature and use that generic information because we have been carefully selecting catchments to conform to one characteristic or another and we will have built up a lot of information by the time we get to the end of the VI about catchments and we will be able to use that and extend that through the professional agronomists who are advising farmers so that they will understand some of the issues and be able to apply both the information and the tools to make it happen on a wider scale. Q280 Chairman: It still costs money. The quite successful continental pesticide tax regimes have ploughed the money back into the farming community, into the support that is required to really drive down pesticide levels. Professor Dent: I do not think that sort of money is needed. In this country we are already equipped. We have training money from ERDC, it is there and we can use it if we can tap into it properly. Also, we have an Agronomist Advisory Service which is in place which farmers employ themselves, they are very well trained and on a national professional register. We already have those things in place, we do not need to re-fund them. Q281 Chairman: We are going to have to vote, but if colleagues will not mind waiting for a minute or so, I think it might be more appropriate if we let Professor Dent conclude and then we can call our other witnesses. I want to ask you, you spoke about not being involved sufficiently with Government and you spoke about the Newcastle research begun without your knowledge and now, as I understand it, you were not even consulted or involved in the drafting of the Pesticide Strategy. Professor Dent: That is not quite true. I had the opportunity to comment on the first draft of that strategy as a person, not necessarily representing the VI, so I was able to make comments on that first draft. You can be absolutely certain that the VI will be making an evidential response to the current draft. Q282 Chairman: Even though you are not on the list of people to be consulted? Professor Dent: Yes. Q283 Chairman: You will do it? Professor Dent: Yes. Q284 Chairman: Do you see a role for the VI within the Pesticide Strategy? Professor Dent: Absolutely. I think the strategy document sees an integrated role for VI. I think we should see that as an opportunity now to re-evaluate or re-work our position with Government, which I think both sides are much more ready to do now. Q285 Chairman: I am very grateful to you for being willing to speak through the bells but I think it is going to make it easier for everybody else that we are able to release you. Thank you very much for coming and if, on reflection, there is anything you want to add or change, please do let us know. Thank you very much indeed. Professor Dent: If I may respond to the earlier request. Chairman: Yes, indeed, Bill Wiggin's request for further information. Thank you very much. The Committee suspended from 4.17pm to 4.36pm for a division in the House. Memorandum submitted by Professor David Forman Examination of Witnesses
Witnesses: Professor David Coggon, Chairman of the Advisory Committee on Pesticides, and Professor David Forman, Epidemiologist on the Committee on Carcinogenicity of Chemicals in Food, Consumer Products and the Environment, examined. Q286 Chairman: My apologies for the delay in starting this second session. I would like to welcome Professor David Coggon, who is the Chairman of the Advisory Committee on Pesticides, and Professor David Forman, who is the Epidemiologist on the Committee on Carcinogenicity of Chemicals in Food, Consumer Products and the Environment. Thank you to both of you and for the written evidence that we have had from Professor Forman, and of course we have had the benefit of seeing the minutes of Professor Coggon's Advisory Committee, which are pertinent to this inquiry. We had not set out to involve ourselves in any sense in looking at progress on pesticides in health issues, however just as we were about to start the inquiry we came across a number of press articles that indicated that new work was under way and that some new conclusions perhaps were being made about health issues related to pesticides, thus we thought it would be wrong to ignore that there were topical issues around, so that is why we have asked you to come. We are grateful to both of you for joining us this afternoon. I want to start with the Committee on Carcinogenicity and its review of epidemiological research which seemed to indicate that there could be some link between pesticides and particularly an increased incidence in prostate cancer amongst those farm workers who were potentially working with these sorts of materials. I just want to ask Professor Forman about those findings. Perhaps you can explain to us the extent to which you think there could be a link and how certain or uncertain the conclusions of this review of material are. Professor Forman: Thank you, chairman, for inviting us this afternoon. The Committee on Carcinogenicity was tasked to look at prostate cancer from many different aspects in the light of quite dramatic increases in the overall incidence of this disease in the UK. Amongst men it is one of the most rapidly increasing cancers. Because of that, there was obvious concern that there might be some new environmental exposure or some previously unmonitored environmental exposures to which that increase could be wholly or in part attributed. That was the background for the review. We looked at a wide variety of studies that set out to examine the causes of prostate cancer but really I suppose the most important conclusion from the review overall, before I get to pesticides, is that by far and away the predominant factor explaining the increase in incidence is due to the way in which men are "screened" for prostate cancer or its precursors. In other words, a lot of prostate cancer which previously had been undetected was now being unearthed either through operative procedures where biopsy samples were taken or through the intervention of the PSA - prostate specific antigen test - which was bringing a lot of men with some small degree of malignancy to medical attention and as a result of subsequent diagnostic procedures they were given a diagnosis of prostate cancer. This is a problem of concern in many different countries, how to handle medically the increasing numbers of men being diagnosed with prostate cancer whose diagnosis has been brought about solely as a result of screening activities and there is something of a conundrum in how to manage and treat such men anyway. To an enormous extent, the increase can be explained as a result of changes in the way the disease is diagnosed. In terms of explaining what I term the dramatic increase in incidence, we do not have to think of new environmental causes, there is no a priori necessity for seeking some change in the environment which might have led to an increase in incidence. I think that background is really very important. We took on board the full range of, in particular, occupational exposures that have been suggested as having an association with prostate cancer and you will see a reference in the submission to a suggested association with workers in the rubber industry, for example. By and large, we were unable to substantiate those findings. The one occupational group where there remains a residual element of uncertainty is employment in the farming industry and employment in occupations which might lead to utilisation of pesticides as a result of employment. Q287 Chairman: May I just interrupt. Would that include workers in factories that are handling large quantities of pesticides, putting them into the boxes? I imagine most of it is machine driven. Professor Forman: There have been very few such studies, but one particular study we paid attention to was a systematic review of all the literature published up until 2001. They considered employment in the farming industry, or any other industries involved in the utilisation of pesticides. I am not sure if they may have missed some pesticide manufacturing industry studies that might have been published but did not meet their criteria. Professor Coggon might want to comment on that. By and large, and as is unfortunately the case in this sort of systematic evaluation, the results were variable from different studies, and different studies at different times in different countries gave different answers. But the systematic review that we paid most attention to because it summarised the evidence to date indicated that overall there was what in epidemiological terms would be a very small risk associated with employment in these pesticide-related occupations. In the language of epidemiology they said there was roughly a 9 per cent increase in risk in men in such occupations, in comparison to the level of prostate cancer in the general population. That is a risk, albeit meeting just the conventional criteria for statistical significance on which we tend to judge these things, which is so low that it is very difficult to say with certainty that the risk represents a real, small causal association or whether it is an elevated risk that might be explained by other factors that have not been measured properly in the context of these studies. Certainly risks of that order of magnitude are extremely difficult to interpret and reach firm decisions on in relation to causality. That is the state of play at the moment. We looked at that 9 per cent increased risk from a number of different perspectives. The risk increases if you look just at studies that have been conducted in North America. The risk disappears altogether if you look at studies that have been conducted in European countries. That is just symbolic of the heterogeneity, the different outcomes that are observed looking at these studies in different contexts. The conclusion of the committee was that there was insufficient evidence for it to be identified as a causal risk; it was a risk that needed to be noted, and as further evidence accrued it needed to be brought into the overall context and consideration of the committee, but at this moment in time we did not feel that the evidence was sufficient to reach a judgment on the causality. Q288 Chairman: Presumably, it was enough to justify a watching brief. Professor Forman: Indeed, and that was the conclusion we reached. Q289 Mr Wiggin: One of the other groups of people that perhaps you could have looked at was people who lived nearby - bystander exposure, I think. Has any work been done for people like that? Professor Coggon: Perhaps one could say first, on a theoretical basis, if there were a risk, one would expect the risk to relate to cumulative exposure to pesticides or more accurately to one or more specific pesticide. In general, the cumulative exposure to pesticides of operators is much higher than that of bystanders, and there is a range of different sources of evidence that support that conclusion. On a theoretical basis, one would not expect a problem in bystanders on the same level that one might see in operators if there really is a causal association. There has been one study fairly recently, within the last three or four years, here and in Wales, looking at geographical distribution of cancer of the prostate, and that study failed to demonstrate any excess among men living in rural areas or any significant clustering in rural areas; so in so far as people have been able to look by observation or studies, there is not evidence of a problem there. Q290 Mr Wiggin: Obviously, taking this further, if there is, I think we heard from previous evidence that there are about nine chemicals that cause the problems in the water. How easy would it be for you to identify which the chemicals were that are within the pesticides that are the problem, because it may not be the case that every pesticide has the same impact? Professor Coggon: That is exactly the nub of the problem. Pesticides pharmacologically are very diverse chemicals. It is a bit like medicines; they have all sorts of different effects. The reason why so many studies have looked at the pesticides at a class is because where you are relying on people's memory to find out about exposure many years in the past, they have great difficulty in recalling exactly what they have been exposed to. Pesticides have all sorts of funny long names, generally, and they are often trade names, and it is even more confusing because what goes under the same name can change from time to time as well. However, if there is an effect of pesticides, then it is likely to be one specific pesticide or a class of pesticides that act in a similar way, and the challenge in this situation is really to try and find out whether there is evidence for that. That was something that the Committee on Carcinogenicity alluded to in their conclusions; that in future epidemiological research we need better indices of exposure of subjects to specific pesticides. It is not that easy to do in practice, but that would be the aim. One of the things we have recommended on the advisory committee on pesticides is that in addition to the review that has been done of rates of prostate cancer in farmers and people exposed to pesticides and their use, there should also be a systematic review of the evidence on prostate cancer from studies of manufacturers. Many of these studies will not be listed as studies of prostate cancer, but there have been quite a large number of studies done looking at patterns of mortality in pesticide manufacturers, both here in the UK and in other countries as well; and they provide information on rates of prostate cancer. The advantage of looking at those groups is that in a factory you tend to make a rather smaller range of products than a farmer might use, so it is easier to link an individual to exposure to specific compounds, and that information is already in the public domain and we need to look at it to see if there is anything that would point to a specific pesticide. Otherwise, it is a question of trying to collect information in the longer term on what happens to users, but it is a challenge to get good information on individual exposure to specific pesticides. Q291 Mr Wiggin: Friends of the Earth said that although the conclusions of the COC were based on farm-workers, many more people could have a reason to worry. I think that from your evidence that is not the case; am I right? There is no evidence that that is the case. Professor Coggon: There is no evidence that that is the case. If there is a problem, it depends on what the mechanism is whereby the pesticide concerned causes cancer, what the shape is of the relationship between exposure and risk, because in general risk will get higher as you expose more, but it may well be that there is no risk until you are exposed at a certain level; but in general the exposures of people other than operators will be lower than those of operators themselves, and therefore you would not expect the same risk in them as in operators. Q292 Mr Wiggin: My understanding is that these chemicals are approved, and therefore if the approval process has not identified this potential harm to the farm-worker or whoever is a pesticide user, then perhaps that is the area that needs addressing - I do not know. Professor Coggon: The approval for pesticides entails an extensive review of safety information, and in this context we are talking particularly about human-health safety. There is a large scientific evidence base, mostly toxicological, that is considered. In particular we look at the potential of a chemical to cause cancer in long-term studies in animals. We look at its potential to cause genetic damage to cells in mutagenicity testing. A pesticide these days only gets on to the market if it passes those hurdles, and if it is an older pesticide that has been used for a long time, then it has to go through those hurdles at review, and also any epidemiological data that is available will get looked at as well. One of the things in considering this is whether there is toxicological evidence that suggests that one or more pesticides might be a cause of prostate cancer/ and that is something which the Committee on Carcinogenicity looked at as part of their review. It is not something that we have been aware of on the ACP; and if we had a concern, then we would have acted upon it at the time that the chemical came forward for review. Q293 Chairman: One of the concerns that environmental campaigners often have - and there is one called Georgina Downs who has sent a lot of information to us - is that sometimes the bystander does not have the protective clothing and is not equipped to safeguard his or herself against the chemical being used. I suppose there probably are not any studies that are considering what has happened to boy children who live on farms and play in farm areas and clearly could be subject to spraying for which they are not being protected. Professor Coggon: I am not aware of studies of cancer of the prostate in relation to being brought up on a farm, although there are studies looking at other health outcomes in relation to being brought up on a farm. For example, there seems to be a low rate of atopic disease, asthma and hay fever in people who have been brought up on farms, and there is speculation as to why that might be. There has also been a study in the United States that looked at exposures of families living on farms, including children. That found that the major determinant of exposure in the families was whether they themselves were involved in pesticide application activities or were very close geographically to the process when it was operating. Just living on the farmhouse on the farm did not have a major impact. I think you are right that particularly with a disease like cancer of the prostate, which might be influenced by exposures at a critical period of development - and we do not have evidence for that, but it is a theoretical possibility - that is a sensible question to be asking. Q294 Paddy Tipping: Professor Coggon, you have mentioned the need for a cohort study of pesticide manufacturers, and I think, Professor Forman, in your evidence at the end you say that Defra is going to fund this. What is the current state of play on this? Professor Coggon: I am a bit reluctant to speak for Defra, but I understand that Defra are putting out to tender - it is not a new cohort study; it is a review of published cohort studies of pesticide manufacturers. The advantage of that is that you have a much bigger database, and the answers come rather quicker. Q295 Paddy Tipping: All the work that is going on through both your committees is a review of existing studies; there is no original work taking place. Professor Forman: As far as the Committee on Carcinogenicity is concerned, that is the normal style in which we operate. Very occasionally the Committee reaches a conclusion that certain pieces of research ought to be undertaken, and even more rarely they seek ways of commissioning it themselves, but the committee is a review body rather than an executive body in terms of commissioning new pieces of work. Q296 Paddy Tipping: Which would that body be? If there were felt to be a gap in knowledge here, which of the executive bodies would commission research? Professor Forman: It could be either Defra or the Department of Health, or some sort of collaboration between the two government departments. I guess on occasions the Medical Research Council could also be invited to take on the brief for such pieces of work. Professor Coggon: The position is a bit different on the ACP, which is a regulatory committee, because before a pesticide can be approved, we have to have adequate assurance that the use will be acceptably safe; and the evidence to support that is provided by the approval-holder. If we do not have adequate evidence to support approval of pesticide, then we will put an onus on the approval-holder to demonstrate that the product is adequately safe, otherwise it will not get approval; or if it is at review it will not get continued approval. That is relevant where you have a concern about a specific product. In this situation we do not have anything pointing at a specific product, so that does not come in. In that situation we may suggest to Defra that they should fund specific generic research that would help the approvals process, and we have done in the past. For example, there is a study being conducted at the moment looking further at the exposures of bystanders to pesticides because we are aware that there is a lot of public concern about that, and therefore it would be helpful to have additional information. Generally, where the ACP recommends that further research be conducted, it is either commissioned by Defra or by the Health & Safety Executive. Q297 Paddy Tipping: So far you have found no linkages at all. Professor Coggon: There is a statistical association in the studies that have been reviewed; the question is whether that association is causal; and, if it is causal, which pesticides are causing it. It is not a strong suspicion at the moment or a big risk, but it is enough of a concern that we should not forget about it, and we need to look into it further insofar as we can. Q298 Paddy Tipping: I do not come from a technical background, but I get letters from campaigners saying, "there is a problem here". What kind of research would we need to undertake to reassure people that there was no problem, or is that impossible? Professor Coggon: What sort of a problem - a cluster of cases? The management of clusters is quite a difficult problem because they are very obvious. They get noticed because they are unusual. By definition they are going to be statistically abnormal, otherwise people do not notice them. Most of the time, however, experience tells us - and this is not just in relation to pesticides - I get involved a lot in occupational clusters of disease - most of the time they are chance phenomena. If you got everybody in the country to throw a dice at the same time, there would be places where there were clusters of sixes, just by chance, and they would be very unusual, some of them. So they can occur in that situation, but just occasionally they are an indication of some previously unrecognised problem, or a problem that people did not know existed in that place. The trick of trying to manage them is to sort out, if you can, the very few cases where there is something going on from the vast majority where there is not. To do a study that will prove a negative in so far as you could possibly could, is very expensive, and it is not something that we can afford to launch into every time somebody sees a cluster of disease - there would be no epidemiologists left in the country; they would all be doing that all of their time. You have to adopt a staged approach to management, trying to assess how strong the suspicion is in advance, and what exactly the people have in common that have the disease, how unusual it is and what is known about the cause of that disease and the things the people have been exposed to. Depending on the level of suspicion, you may then need to go in and do further studies, either in that group of people, or quite often somewhere else where people have similar exposures; but it is a difficult area to manage and there are not simple answers. Professor Forman: I would agree with everything that Professor Coggon has said, and he has experience of occupational clusters. One of my responsibilities is running one of the regional cancer registries in the north of England, and very frequently we get asked to provide data relating to environmental type clusters. I would certainly agree that after investigation one usually finds that cluster is a chance observation rather than representing anything meaningful. Usually, the real difficulty in cluster investigations, and indeed in other types of epidemiology investigation, which would really help disentangling some of these cause and effect relationships, is good measurements on exposure. That really bedevils this particular question of the association with pesticides and prostate or other forms of cancer. How do we know who are the real highly exposed individuals in a population, even a population of farm-workers? How do you know which ones have been following advice regarding the wearing of protective clothing and so on? Usually, the only way one can get information on that sort of level, that fine detail of exposure information, is through biological measures, so looking at substances in blood samples and so on. Where that is possible, that has certainly helped these types of investigations in other fields in the past. Q299 Paddy Tipping: So you can never give people absolute assurances in this area. Professor Coggon: I do not think we can. We cannot guarantee that anything in life is safe, can we? But you can narrow down the range of uncertainty quite a lot. Q300 Chairman: There is another area of uncertainty, is there not, and that is the ACP's medical and toxicology panel, which considers the review of literature concerning an association between Parkinson's Disease and pesticides. Professor Coggon, would you like to take us briefly through your conclusions of that review? Professor Coggon: Yes. In many ways, the situation parallels that for prostate cancer. We have a systematic review and in this case actually commissioned at the request of the ACP, carried out by the Institute for Environment and Health in Leicester, looking at epidemiological studies of the relationship between Parkinson's Disease and exposure to pesticides and also briefly reviewing the relevant toxicology. There are quite a number of studies in the literature, more than 40, and as we suspected when we commissioned the work there are more showing a positive association between Parkinson's Disease and pesticides than you would have expected if the whole thing was left to chance. Again, the relative risk is not that high if you look at them overall. The pattern is not entirely consistent. There are a surprising number that show positive relationships, but it is not entirely consistent. There are some that show inverse relationships with a lower risk of Parkinson's Disease in people exposed to pesticides. There is not any evidence pointing consistently to a problem with any single pesticide or class of pesticides. The question is, is the association a causal relationship with one or more specific pesticides? Is it due to biases in the way in which studies have been carried out? A particular problem in this context is that many of the studies are case-control studies, where you start with a group of patients who have Parkinson's Disease, and a group of controls that do not have the disease, and ask them about their past exposure to pesticides. When you do studies like that, quite naturally the patients that have the disease that is under investigation are more motivated to recall past exposures than the controls are, and so you can get a spurious association between exposure and disease when you do that sort of study. You can also get biases from selected publication, because people do a case-control study of Parkinson's Disease and look at a whole lot of different environmental, dietary, lifestyle exposures, but then they only publish the ones that look interesting and positive and not the ones that do not look so interesting; so when you just look at the information that is in the published literature, you get a biased view. That is a possible explanation; or there could be one or more pesticides there that are causing Parkinson's Disease, and it has not been picked up on the extensive toxicological screening that is carried out for pesticides. When you look at the toxicology and neuro-toxicity that is assessed as part of the registration process for pesticides, you do not find indications of pesticides causing damage to that part of the brain that is affected in Parkinson's Disease. You have to keep an open mind on this. In a way, it is more difficult to investigate further than prostate cancer because in prostate cancer you can use mortality from the disease as an outcome measure. It is fairly reliable as an index of prostate cancer; whereas for Parkinson's Disease, as you know, many patients die of other causes, and Parkinson's Disease does not get on to the death certificate necessarily. It may get on differently in some people than others, and that can give rise to misleading results when you do epidemiological studies. There is in this case quite a lot of ongoing research both in this country and in other parts of the world. We have decided that while it is not appropriate to take any regulatory action at this stage in relation to Parkinson's Disease and pesticides, there is again a need to keep a watching brief on what is coming out in this area. 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. Q301 Chairman: Who will pay for any research, of whichever kind you might undertake? Professor Coggon: If it is generic, then it will come from government, by Defra. If it is specific to a single product and it is required in order to support the approval of that product, then it will come from the manufacturer. It is unusual for us to request epidemiological studies from approval-holders, but we have done it in the past where there was a particular concern that could be addressed by an epidemiological investigation. Q302 Chairman: Are you making specific request now, or is it a recommendation? How far have you got in regard to nailing down future work? Professor Coggon: We have made a recommendation, and my understanding is that that work is being commissioned, but I think you would need to ask Defra where they have got to with that. Q303 Chairman: We will have that opportunity! In the light of the diseases we have spoken of, does all of this suggest to you that there ought to be the application of a cautionary principle in the use of pesticides because of these uncertainties? Professor Coggon: We already apply a very precautionary approach in the regulation of pesticides, and by that I mean that we make allowance for uncertainty. We do not wait until there is evidence of an adverse effect before we react to restrict the use of a pesticide; the reverse is true. There has to be positive evidence that there will not be adverse effects before a pesticide is allowed on the market. The regulation of pesticides is much more precautionary than the four other chemicals in the environment and in the workplace. The comparable one would be medications, and there are very good reasons for that; of their nature, pesticides and medicines are biologically active, and therefore intrinsically they are more hazardous materials than most other chemicals. The approach to regulation has become increasingly precautionary over the years, which is the main reason why a lot of the older products have disappeared from the market; either they do not meet current standards, or more often because the manufacturers make a commercial decision not to generate the information that would be needed to meet modern standards. Q304 Chairman: Perhaps because we know they have been causing problems. Professor Coggon: I do not think it is because of an awareness that they are causing problems; I think it is a commercial decision, that if you want to retain approval for this chemical, you will have to provide the following studies in addition to the ones you already have, and that will cost you a lot of much money, so how much profit can you make from this chemical, and is it worth the effort? I cannot recall any pesticide being withdrawn from the market in the time that I have been involved in the Advisory Committee on pesticides because there was evidence that it was causing harm to people. Q305 Chairman: I am thinking about before you were in your job, about DDT and things like that. Professor Coggon: DDT and the organochlorines have gone principally because of concerns about the environment and about the systems in the environment, not because they have been shown to be causing adverse health effects, or not as far as I am aware anyway. Chairman: I think we might dispute that, but we will not do so now. Q306 Paddy Tipping: I want to ask you about the incidence breast cancer in the UK. In most industrial countries it seems to be rising and there have been suggestions that pesticides are associated with this. What is the evidence? Professor Forman: Breast cancer has increased. It is not increasing as fast as you might sometimes believe from some of the media stories, especially when one takes into account the impact of mammographic screening, which we have now had in this country for 15 years or so. The causes of breast cancer are a little bit better understood than those of prostate cancer, which does not actually indicate a lot. However, we do know that a number of reproductive factors like the number of children, age of menarche and so on influence the risk of breast cancer quite profoundly. I would agree with you that there has been a concern that pesticides might be involved in the aetiology of breast cancer. Most work has been conducted on the organochlorine insecticides. In fact, there has been a large volume of research on that particular class of pesticides. The Committee on Carcinogenicity has looked at that evidence on a number of occasions and reported most recently, in the middle of last year. That included substances such as DDT and its derivatives. Although we were discussing earlier what it takes in order to provide absolute reassurance, the evidence on DDT and breast cancer, when you consider it in the round, is about as reassuring as it could be in the sense that if you take all the studies together there is absolutely no evidence of hazard associated with exposure to DDT, and that is using very good indicators of exposure, not the memory recall type of information, but blood measures of the substance and its derivative, which is long-lasting in the circulatory system. The Committee on Carcinogenicity looked at a number of the different organochlorine insecticides, and although not all of them had a lot of evidence associated with them, by and large there was relatively little cause for concern. There was one particular organochlorine, dieldrin, for which there is only a small amount of evidence available - from memory only two or three studies have been conducted. Those studies conflicted amongst themselves. The evidence around DDT and its derivative DDE certainly showed in aggregate a large body of data that came down to a conclusion of no evidence of harm. Q307 Mr Wiggin: To what extent would a government admission that pesticides had been causing health problems lead to claims for state compensation? Professor Coggon: The grounds for state compensation, I guess, would be that the government had required people to use pesticides - so it might be an issue in relation to sheep dip, which does not get regulated as a pesticide but gets regulated separately - or that the regulatory process, and my committee, had not done their job properly. Certainly, I have been approached in the past by lawyers who were thinking about taking action against the Committee for Safety of Medicines because they felt they might have acted earlier in relation to a concern about a drug. Those are two mechanisms whereby people might make a claim against the Government. Q308 Mr Wiggin: To what extent does the legal liability rest with the manufacturer for ensuring their products are safely used? Professor Coggon: I am not a lawyer, so I would hesitate to answer that question - I would probably get it wrong. Q309 Mr Wiggin: One of the reasons for pushing you on this is because legal measures will be introduced requiring farmers to keep records of pesticides and to make those records available to the public via a third party, and so you can see that that is likely to generate this type of inquiry. Professor Coggon: I am not a lawyer, but I guess for the farmer the parallel would be the doctor who prescribes a medicine that is approved for use. If a farmer uses a pesticide in an approved manner and is then subject to a claim from a member of the public because it turns out that the pesticide is not as safe as everybody thought it was, I would have thought the farmer was in the same position as the doctor. I am not a lawyer, as I say. Q310 Mr Wiggin: I think that is a very helpful answer though, because obviously we are looking at the voluntary initiative and what scope there is for improving it and addressing these health concerns, and whether or not that is one of the things that would be helpful we value your views on. Professor Coggon: Any improved training of operators has potential benefits in terms of minimising mishaps when pesticides are being used. We know that a small number of accidental pesticide poisonings do occur each year. In fact, we are doing an investigation of them at the moment sponsored by the Department of Health. From the initial findings, a substantial proportion of them - it is based on rather small numbers - seem to be from mishaps that occur while people are handling pesticides and they get splashed or something like that. If people are better trained and know how to use the equipment that they are provided with, then the risk of that sort of thing happening should be reduced. Q311 Mr Wiggin: From what you have said, which I am sure the Committee is very grateful for, it seems to be that because of your committee the products are safe. If people do not use them properly and do the right thing, then potentially there are serious repercussions, whether it be a type of cancer or other sorts of damage. In which direction should we be pushing the operators? Training is one thing, but legislation would not necessarily stop you getting splashed. Professor Coggon: It is a question of balance. First of all, I should correct you - we cannot say that pesticides are safe, and we should avoid that term. We can say that pesticides are adequately safe, and we go through a stringent process to assess them, but we cannot guarantee that they are safe. We have to keep the situation under review all the time, in case new evidence comes to light that suggests our previous decisions were wrong. In terms of how you improve operator safety, it is a bit like safety on the roads. On the one end of things you can improve the engineering, the design of roads and cars, to make them more crashworthy and less dangerous to pedestrians, and you can also try to train people to be better drivers. You have to look and see where the most gains can be made. The evidence we have at the moment is that in this country, compared to what we had in the past and compared with what we have in many other parts of the developing world in particular, the handling portfolio pesticides on farms is pretty good, but that is not to say it could not be better. We are always looking for ways of improving it, and engineering controls have the advantage that they do not rely on somebody's effort to make them work. If you can have a system for diluting pesticides that does not involve an individual coming into contact with a concentrate, which is a major determinant of individual exposure, that is an advantage, and it is better than relying on good behaviour by the worker. We are all the time looking for ways of improving things. Q312 Mr Wiggin: Obviously, one of the motivators behind the voluntary initiative was a tax, and, going back to your analogy, increasing road tax does not make people drive better. Professor Coggon: It might make them drive less - a few people! I am not an economist either. Q313 Chairman: I will attempt to conclude our proceedings by asking you about Economic Directive 91/414, which I am sure you are entirely familiar with. Professor Coggon: Every word of it! Q314 Chairman: Some of our colleague were recently in Brussels and heard that a negotiation on a major revision of this Directive is to begin later this year. Clearly, that is a matter of interest to all of us because it could result in the most toxic of pesticides being banned. Is that the conclusion that you might draw from the likely direction of a revision? Professor Coggon: I cannot answer with authority because I do not know what the direction of the revision is. What I will say is that there have been some pressures from some countries in Europe to regulate on the hazard associated with pesticides, in other words the potential for them to cause damage. That has the advantage of simplicity. You can classify a chemical according to its hazard, and this one is much more toxic weight for weight than another, and therefore we will regulate it more strictly. However, at the end of the day what really matters is the risk to the person, and the risk depends not only on the intrinsic hazard of the material, but the way in which it is being handled and the amount to which people get exposed. There is the possibility if you start regulating on hazard that you will end up in a paradoxical situation where something gets replaced by another material which, although less hazardous, because of the way in which it is used poses a greater risk. It is not a simple situation and there has to be a lot of careful thought about the best way forward. Q315 Chairman: What you have said are the reasons why what we might deem the more toxic of the pesticides are currently not banned. That is the logic, because you take it in the round. Professor Coggon: Yes, because in the regulatory process we carry out a risk assessment; we do not just regulate on the basis of hazard. We first have to identify the potential adverse effects, and what the relationship is of those adverse effects to levels of exposure. That comes largely from animal experiments initially, although it may come from human data as well once a pesticide has been in use. We then have to look at how much people might get exposed, given the way in which the pesticide is going to be used, and decide whether the levels of exposure will be acceptable, given what we know about its toxicity. Q316 Chairman: Professor Forman, do you want to add anything at all? Professor Forman: On the EC Directive, absolutely not! Chairman: I meant in general. I was concerned that we have left you out of this discussion for the last few moments. Thank you both very much indeed for what you have said this afternoon and for being willing to answer our questions. As usual, if there is anything you wish to add on reflection, please contact us in the usual way, or if there is anything you want to amend or correct once you have left this room, we will be glad to hear from you. |