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Responses to 2003 consultations on pesticide use
YOU will no doubt note the less-than-temperate tone of some of my contributions to these two consultations. This can perhaps be excused in the light of my long struggle to report my own pesticide exposure which I believe contributed to my becoming permanently disabled. The struggle is referred to briefly in the 'buffer zone' consultation response, but I believe that the additional information provided here will help to illustrate the disgraceful inadequacy and incompetence in the monitoring and control of the use of these toxic chemicals in the United Kingdom.
IN 1996 (and possibly before – due to my illness I cannot remember) I reported to the UK's Health and Safety Executive (HSE) my exposure in 1995 to the organophosphate (OP) compound dichlorvos via the house flea spray Nuvan Staykil, and my subsequent illness. Following advice from various bodies, including the HSE, I also reported it to the Veterinary Medicines Directorate, the Agricultural Development and Advisory Service (ADAS), the Pesticides Safety Directorate (PSD), the Department of Trade and Industry (DTI), my local environmental health department and my GP. Everyone seemed of the opinion that it was not their remit, and referred me to one of the others. It is important to try to appreciate the difficulty of carrying out all these actions when one is ill and already struggling to cope with the tasks of everyday life.
In my letter to the PSD dated 3rd February 1997 I asked when organophosphates were first used in a range of products, including flea sprays. To my astonishment, their reply dated 22nd April stated “No record has been found of any flea sprays having contained OPs...”
On 16th May 1997 I pointed out that I had a list supplied by the Ministry of Agriculture, Fisheries and Food (MAFF) listing 28 OP-containing products for use on cats and dogs, including a flea spray called Nuvan Top, and that I had used the house flea spray Nuvan Staykil containing dichlorvos. On 12th June, the PSD responded:
“The Veterinary Medicines Directorate supplied me with information on OP flea collars and flea sprays and I have consulted them again with reference to your question on Nuvan Top. They have now had time to make a thorough search of their archived files and can confirm that Nuvan Top, which does indeed contain the organophosphate dichlorvos, was first authorised in 1972. I apologise for not being able to supply you with this information in my letter of 22 April.”
So finding this information required 'a thorough search of their archived files'; yet I, a sick individual on benefit, had obtained this information and more, even without access to a resource like the internet.
They made no reference to the product which I had actually used – Nuvan Staykil - however, I had already advised them that this contained dichlorvos. I – a member of the public seeking information – had to advise the body regulating pesticide safety...
In 2002, on hearing that the main active ingredient in the flea spray – dichlorvos – was under review, I e-mailed the HSE to try to make sure that my exposure report was on record and would be examined during the review, and was advised to contact my local environmental health department again. This I did, and again they insisted that domestic poisoning incidents were nothing to do with them. They also stated that they had no record of my previous report.
A number of times I came across claims that there were few or no reports of adverse effects from domestic products containing OPs. In view of the extraordinary difficulty I had when trying to report my own exposure - and I am pretty persistent even when ill - it is perhaps surprising that any reports got through at all.
There must be a huge number of unreported incidents resulting from this mess over who is responsible for recording them.
A wide range of products containing dichlorvos are now banned. See
Sadly this is too late for the many people whose lives have been irrevocably blighted (not to mention those who have died), and there is probably little chance of obtaining compensation. Yet as long ago as 1951, scientists headed by Professor Solly Zuckerman had advised that the words DEADLY POISON should be printed on organophosphate product labels.
Professor Zuckerman also warned that chronic low-dose exposure was likely to be the cause of most OP-related illness.
See opin.info/download/OPReport.doc [100 kbs]
Yet since then, the official line has continued to be that acute high-dose exposure is necessary to cause long-term neurological damage.
Is this a case of the power of big business overriding public safety? There is certainly evidence that information has been suppressed. See
Before 1995 I was fit, strong, healthy and very active, but since then I have been unable to work full-time, and was diagnosed as suffering from Chronic Fatigue Syndrome (CFS, which is often regarded as synonymous with myalgic encephalitis/encephalomyelitis or M.E.) in 1999. I spent ten years on Incapacity Benefit studying part-time for degrees with the Open University in the hope of eventually being able to support myself with home-based work on the strength of my qualifications.
I hope, therefore, that my angry tone in these consultation responses can be understood and forgiven.
The consultation documents can be found at
Dear Sir and Madam,
I am responding to your informal consultation document on disclosure of agricultural spraying and your formal consultation document on buffer zones between spraying and people.
The references on these documents are AAHL/20/2003/Consult1 and AAHL/20/2003/Consult2.
I was given copies of these documents by PAN-UK, who consider, as do I, that such consultation should be much wider than your target population.
I will start with criticisms of the documents, after which I will give my responses to the consultation questions (which I hope you will consider, despite my not being a target consultee).
A general criticism is your misleading, indeed often dishonest, statements that there is a generic 'scientific view' that existing legislation is adequate and that there is no evidence to the contrary. These are leading statements which will inevitably bias responses from non-organic growers. I will quote these statements as I address the sections in which they are featured.
Related to this criticism is the highly patronising nature of references to 'allaying concerns' and 'social unacceptability' regarding pesticides, which give the impression (undoubtedly intended) that these are the only problems with the existing systems of control; in other words, human physical health is not actually at risk. Along with the misrepresentation of scientific opinion, this emphasis too will bias responses.
Public Access to Information on Pesticide Use
“ISSUES FOR CONSIDERATION
Farmers and growers in England and Wales to notify those in surrounding houses of timing of spray operations and the pesticides to be used”
I was astonished to discover that notice of aerial spraying is only given to occupants of properties up to 25 metres of the land to be sprayed. Any meteorologist can tell you that spray can be carried much further than this.
The phrase "this may help allay any concerns" appears in this section. This effectively dismisses genuine scientific concerns about the health hazards of exposure to pesticides.
CONSULTATION FOR THE INTRODUCTION OF NO-SPRAY BUFFER ZONES AROUND RESIDENTIAL PROPERTIES
3. Here you state that spraying adjacent to residents' properties might be 'socially unacceptable' and that further controls might 'increase public confidence'. This is treating people with well-founded health concerns as children to be reassured and comforted, and is patronising. You are effectively saying to farmers, "We know that you know there's no risk but we have to pretend to be listening to these silly people" and is thus a kind of brainwashing. I make no apology for my strong language, and consider that it is entirely merited. I speak as someone who has clear, consistent adverse physical symptoms on exposure to pesticides, such as when walking past a local smallholding when spraying is being carried out. I am also aware of how such chemicals accumulate in the body.
Consultation on the introduction of no-spray buffer zones around residential properties
Here you use the insidious phrase "the scientific view is that pesticides controls are robust and sufficient to protect nearby residents" and "reassure the public". There is no such thing as 'the scientific view'; there is a wide range of views, and you are ignoring those which disagree with a particular agenda. This will bias responses, as will the 'reassure' phrase (see above).
3. I am alarmed that failure to follow the guidance in the 'statutory Code of Practice for the Safe Use of Pesticides on Farms and Holdings' is not an offence, and look forward to this being rectified.
4. You state that The Advisory Committee on Pesticides (ACP) is an independent scientific advisory body and remains of the view that current techniques for assessing the risks from crop spraying are 'robust and sufficient to prevent adverse effects in nearby residents'. I trust that this committee is not dominated by people with interests in the agrochemicals industry. As the adjectives 'robust and sufficient' are the same as those used to describe the 'scientific view' I must conclude that you are basing claims for 'the scientific view' on the consensus view of the ACP. This is not made adequately clear in the document and gives the misleading impression that it is the ONLY scientific view. It will bias responses.
In the preamble to your question here, you state: "The imposition of no-spray buffer zones is not justified solely on scientific grounds." The question then asks the growers to state what 'public interest justification' they believe there is for introducing them. This is an outrageous piece of dishonesty and bias, and I hope that some growers with scientific knowledge will take you to task in no uncertain terms.
6. You state: "Scientific opinion, including the view of the ACP, is that all the information currently available points to the risk assessment for bystanders used at present as providing adequate information." Again, this gives the impression that no scientists disagree with the statement and, if some do, it is misleading and will bias responses.
You state that only a dozen or so cases of pesticide exposure are reported to the HSE every year. Is this true, or is this the number which they accept as genuine and for which they create a record? I ask this because in1995/6 I spent a huge amount of time, paper and energy trying to report an exposure, and was passed from one government department and organisation to another, eventually ending up back where I started. No one would accept responsibility for recording the incident. This includes the Pesticides Safety Directorate.
10. In your list of suggested buffer zones, I believe that '50 metres' should be included. 10 metres is definitely too low, and many farmers will be unwilling to accept the next size, which is 100 metres. The omission of this size category, and the consequent omission of calculations for areas affected by a buffer zone of this size, may bias responses.
PARTIAL REGULATORY IMPACT ASSESSMENT
3. You repeat the phrases "the scientific view is that (pesticides controls) are robust and sufficient to protect nearby residents" and the reference to whether spraying adjacent to residents' boundaries might be considered 'socially unacceptable'. This will bias responses. See my comments above.
6. You repeat the statement that "scientific opinion is that the current risk assessment for bystanders is satisfactory." See my comments above. You go on to place the emphasis on fears that ministers may be "accused of ignoring concerns of those who believe they may have been adversely affected and those who consider spraying immediately adjacent to their properties to be socially unacceptable" rather than accepting that these concerns may be well-founded. These statements will bias responses.
7. You state that there is 'no scientific case' to back the introduction of buffer zones and that is it 'unlikely that there would be any safety gains'. I find these statements extraordinary. You appear to be saying that there is no evidence that ANY people or other species are being harmed by pesticide drift. I challenge you to back up these statements, which will strongly bias responses. They will also lead to insult being added to the injury of people who have been harmed, as they will be treated with disbelief and hostility when trying to report their pesticide-related illnesses. (Indeed, this is already the case.)
8. You claim that "the available evidence points to the current risk assessment as providing an acceptable level of exposure". I disagree with this statement - it is biased and will bias responses.
9. You repeat the claim that buffer zones will be unlikely to involve any safety gains. This will bias responses. You make the feeble statement that it is 'possible' that no spray zones could aid biodiversity and thereby have the potential to benefit birds and other wildlife. I would suggest that they are CERTAIN to aid biodiversity. The zones will be at field-edges, often adjacent to hedges. These are places with extremely high potential biodiversity, and hedgerows are of course corridors which enable populations of wild species to have large enough territories and gene pools to remain viable.
Why do you not list more of the potential benefits? Are your scientific experts not aware of them?
My responses to the consultation questions:
I do not believe that the present risk assessment adequately addresses the risks posed by pesticide spraydrift. To my knowledge they do not adequately allow for differences in individual susceptibility, for the 'cocktail effect' of many different pesticides, for the fact that these chemicals accumulate in the body over a lifetime or for the fact that they can be passed to future generations via genetic damage, exposure in the womb and breast-feeding. Sprayed chemicals can travel considerable distances, which is not properly acknowledged.
I regret that I do not have a copy of the 'Green Code' so cannot comment on its content.
I reject out of hand your leading statement attached to the next question, that the imposition of no-spray buffer zones is not justified solely on scientific grounds. I consider that the imposition of no-spray buffer zones IS justified on scientific grounds, and this is the reason why I am in favour of them - not to 'allay the fears' of foolish people such as myself who imagine a non-existent risk from pesticides.
I am personally totally opposed to the use of pesticides (including herbicides), so for me the ideal size for a buffer zone would be the size of the planet on which pesticides were used. However, until this becomes an option I would support the largest possible buffer zone, with the overriding determinant being the precautionary principle as applied to protect the health of humans and other species (NB not to prevent fear or to prevent ministers being accused of ignoring concerns).
Although I do not have a direct financial interest in the issues addressed by the next question, I will answer anyway. Yes, losses of cropping land are warranted by the health and environmental benefits of introducing buffer zones. As a large proportion of crops are fed to animals - a practice which wastes about 90% of the crops' nutritional benefit - there is no real shortage of farmland to feed our population. Any apparent shortage is artificially created by the excessive consumption of meat and dairy products (which has the added disadvantage of being unhealthy).
I do not have any data/information to support or refute the crop-loss estimates which you provide.
I do not have any information to support or refute PAN-UK's estimates of the rural population or of those at risk of pesticide exposure.
The next question appears to be identical to an earlier one about the size of buffer zones, so see my earlier answer.
Direct and indirect benefits from no-spray zones:
Reduced damage to the health of humans and other species, the former leading to reductions in costs to health service, working days lost to illness and losses in tax revenue due to inability to work (my own case being an example of all three)
Reduced costs of pesticides used
Increases in pollinating insects and natural predators
Less cost to water companies who have to remove pesticides from water, hence less cost to consumers
I am not aware of areas which may be disproportionately affected by the introduction of buffer zones. I am a little puzzled by the tone of the accompanying text, as it seems to indicate that you are talking about ADVERSE effects, although this section is called 'Benefits'.
Right - NOW we are in the 'Costs' section!
I cannot provide any cost estimates of the likely impact on growers of the introduction of no-spray zones.
I do not have any information on the possible effects on small businesses.
Re the competitive effects on UK growers in relation to EU counterparts: adverse effects would be mitigated by the ending of the 'Great Food Swap' in which identical and near-identical food products are both exported and imported. If laws and/or fiscal instruments were used to prevent or discourage this, competition would not be an issue for the foods concerned.
Vivien Pomfrey, BSc (Hons) (Open), Dip. Nat. Sci. (Open), current medical science Masters student
Pesticide Action Network UK's (PAN-UK) responses to the consultations can be viewed at
PAN-UK re RCEP 26th Oct 04 final.pdf [270 kbs]
Information about The Great Food Swap can be viewed at
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