Memorandum by Pesticide Action Network
UK (PAN UK) (WP 31)
ABOUT PAN UK
Pesticide Action Network UK aims to eliminate
the hazards of pesticides, to reduce dependence on pesticides
and prevent unnecessary expansion of use, and to increase the
sustainable and ecological alternatives to chemical pest control.
PAN UK was formed (as the Pesticides Trust) in 1987 by organisations
with trade union, environmental and development affiliations.
These organisations were concerned about the national and global
risks posed to health and the environment from pesticides, and
agreed that an independent organisation was essential to provide
information, advice and policy input.
There are subscribers to our journal, Pesticides
News, in ninety countries, and our supporter base has been built
up over 15 years. Our extensive website, www.pan-uk.org, now receives
an average of 70,000 hits a month, and our new e-library www.pesticidelibrary.org
comprises over 5,000 references on pesticides, health and the
environment. Pesticide Action Network is a global network with
five regional centres: PAN Europe (facilitated by PAN UK and PAN
Germany), PAN Africa (based in Senegal), PAN Asia/Pacific (based
in Malaysia), PAN Latin America (based in Chile), and PAN North
America (based in the United States).
We provide inputs to key UK pesticide policy
fora, for example, the joint working party of the Royal College
of Physicians and Royal College of Psychiatrists on organophosphate
sheep-dips in 1998, the Committee on Toxicity Working Group on
the Risk Assessment of Mixtures of Pesticides and similar substances
(WiGRAMP) in 2002, and, currently, the Pesticides Forum, and the
Minister's stakeholder group on the "bystander" issue
on 22 July. The PAN Europe network, in which PAN UK plays a leading
role, is recognised as a key stakeholder in pesticides policy
by the Environment, and Health and Consumer Protection (SANCO),
Directorates of the European Commission.
CHOOSING HEALTH:
THE PUBLIC
HEALTH WHITE
PAPER
— Will the proposals enable the Government
to achieve its public health goals?
— Are the proposals appropriate, will
they be effective, and will they represent value for money?
We are very concerned that there are no proposals
at all in the White Paper for protecting public health from the
effects of environmental pollutants. This may mean there is only
limited progress on the "more intractable issues and conditions"
such as cancer and neurological disease.
May we draw your attention to the work by Pritchard
et al on changing morbidity and mortality in respect to
cancer malignancies in the UK, compared with the major Western
world countries (Pritchard and Evan 1996, 1997, Public Health).
The studies show rises in incidence of various cancers, especially
amongst the under 34 year olds, especially young women. As there
are marked differences in gender, this has to be environmental
and not a diagnostic artifact. The improved cancer survival rates
in the West have never been better, and this may have masked the
serious increases. Nonetheless, up to the mid-1990s England and
Wales had the lowest improvement in cancer survival times amongst
the countries reviewed (Evans and Pritchard 2000 Public Health).
Over a 30-year period, Pritchard et al
showed that from 1963, when there was very little statistical
link between malignancy mortality and density of population, this
grew stronger over the next 30 years. Female cancer, especially
amongst young women, grew considerably faster than mens, again
another indication of environmental factors (Pritchard and Evans
1997).
Perhaps even more alarming is their recent work
(Pritchard et al, 2004, Changing patterns of adult (45-74
years) neurological deaths in the major Western world countries
1979-97, Public Health, 118, 268-283) showing marked changes in
"neurological" morbidity and mortality in most of the
major Western world countries, particularly England and Wales.
Again the findings, after correcting for age, is an increase in
mortality in the under 74 year olds in conditions which are recognised
to have a genetic weighting. Moreover the conditions are occurring
earlier and there is a significant increase in dementias in the
late 40s and mid-50 year olds.
This research can not say what has specifically
caused these serious changes, but a number of clinical studies
point to the association of the use of multi-chemicals and pesticides
and the development of some cancers and some neurological diseases.
Again the time span is too short for the changes to be due to
genetic factors . These results are not a diagnostic artifact,
even though there may be a slight influence, but the reality of
the changes is demonstrated by the differences in gender incidence
and mortality over the period.
These are just a few of the studies indicating
that there is a major and urgent public health issue which is
ignored in the White Paper.
We believe that a national programme of biomonitoring,
which would become a possibility if the UK Biobank project www.ukbiobank.ac.uk
is set up to do it, is essential for research into the effects
of chemicals on the body. The current lack of baseline data prevents
any action on this crucial problem.
We also believe that close scrutiny of the cost-effectiveness
of prevention programmes, in relation to the costs of NHS treatment,
should be at the centre of public health policy. We are sceptical
about the potential effectiveness of "health promotion"
programmes which ignore environmental pollution as a factor in
disease causation. We note, for example, the recent study by the
International Agency for Research on Cancer which found that the
consumption of vegetables and fruit does not protect against breast
cancer.
For this reason we ask the Health Committee
to consider commissioning the National Audit Office to carry out
a long-term audit of prevention programmes conducted by government
agencies, including the Health Development Agency, the Health
Promotion Agency, the Department of Health and the Food Standards
Agency. This would inform decision-making about future programmes.
January 2005
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