Today the Royal Commission on Environmental Pollution published their report “Crop Spraying and the Health of Residents and Bystanders.” So, what will the Royal Commission's recommendations really mean for rural residents and communities?
By Georgina Downs, UK Pesticides Campaign
Four and a half years after I first identified serious fundamental flaws throughout the existing system for approving, regulating and monitoring pesticides, the Royal Commission on Environmental Pollution, (RCEP), the UK's most influential environmental body, has today published a report concluding that there are serious fundamental flaws throughout the existing system for approving, regulating and monitoring pesticides.
Therefore do I feel vindicated by the Royal Commission's findings and what will their recommendations really mean for rural residents and communities?
My family and I have lived next to crop fields that are regularly sprayed with pesticides for over 21 years. From around 1993 onwards we made repeated approaches to the Health and Safety Executive and the local Environmental Health Department for assistance regarding the lack of any protection for our health and safety, property and land from repeated exposures to innumerable mixtures of hazardous chemicals, many of which have neurotoxic, carcinogenic and hormone-disrupting capabilities.
However, we were always told that the farmer wasn't doing anything illegal and in relation to requests for prior notification before any spraying application, we were informed that there was no legal obligation for a farmer to provide it or any information on the chemicals being used.
I found this astonishing and realised that if this practice was in fact legal, then the problem had to originate at Government Policy level. Following extensive investigations and research into the existing regulations, it became apparent that there was an inherent fundamental failure at all levels to protect people in the countryside from exposure to pesticides. I therefore started to present a case to the Government in early 2001 to highlight the lack of regulation, including the serious inadequacies of the current risk assessment processes.
The current method of assessing the risks to public health from crop-spraying is based on the predictive model of a 'bystander.” This model assumes that there will only be occasional, short-term exposure from the spray cloud at the time of the application only, and furthermore, to only one individual pesticide at any time.
This model is clearly inadequate to address the real-life long-term exposure for rural residents and communities, where they will be repeatedly and frequently exposed to mixtures of pesticides and other hazardous chemicals, throughout every year and in many cases, like mine, for decades.
The current system does not address long-term exposure to pesticides in the air, chemical fumes and volatilisation after application, as well as precipitation, reactivation, mixtures and long-range transportation. Yet once dispersed, pesticide particles and droplets cannot be controlled, they are airborne contaminants and can travel considerable distances. A reputable study in California found pesticides located up to 3 miles away from pesticide treated areas. Studies have also shown that very low doses of pesticides, in concentrations as low as parts per trillion can have effects, especially to the unborn child.
In July 2002 I gave a presentation regarding the inadequacies of the “bystander risk assessment” to the Government's Advisory Committee on Pesticides (ACP) at their annual Open Meeting. I produced a video with mannequins to illustrate the inherent health risks of crop-spraying near human habitation. I chose mannequins that resembled some of the more vulnerable groups, including a pregnant woman, two babies and a young child. When I asked the attendees to raise their hands if they thought that the video had shown an acceptable system for protecting public health, not a single hand went up!
I subsequently met with former DEFRA Ministers, Lord Whitty and Michael Meacher, in December 2002 to show them the video and present the case for a ban on crop-spraying near homes, schools, workplaces, as well as prior notification before any spraying application and direct public access to information on the chemicals being used. The Ministers stated that I had made a powerful case and that they would need to await further advice from the ACP, which they stated was critical, before making any decisions.
The Ministers eventually decided to launch 2 Consultations' on crop-spraying in July 2003 that were proposing the introduction of the measures that I had been campaigning for and which resulted in the highest number of responses since DEFRA records began.
I submitted a second video to the Consultation that featured individuals and families from all over the country reporting acute and chronic long-term illnesses and diseases in rural communities surrounded by sprayed fields.
The most common illnesses that have been reported to me throughout the campaign include various cancers, leukaemia, non-Hodgkins lymphoma, neurological problems including ME, along with many other medical conditions. Reports of this nature have gone on for decades and yet in relation to the UK there does not appear to have been any monitoring for chronic effects and acute effects are commonly dismissed by Government agencies and advisors as being unrelated to pesticides. Therefore the Government's official figures do not give a true representation of the real scope of the problem relating to the adverse effects of pesticide exposure.
The result of the Consultations' was announced by the former DEFRA Minister for Rural Affairs, Alun Michael on 16th June 2004. He stated that on the basis of the scientific advice he had received from the ACP and DEFRA's Chief Scientific Advisor, he was confident that the existing system provided full reassurance. However, he requested the Royal Commission study to re-examine the evidence regarding the risks to people from crop-spraying.
In addition to all the written evidence I submitted to the RCEP study, I was also invited to make a presentation at the RCEP public meeting held on September 25th 2004 and then to give oral evidence to the Commission members a few months later. Considering my involvement on the issue, I was also asked to peer review 4 chapters of the draft report.
So, 4 and a half years after I launched my campaign, do I feel vindicated by the Royal Commission's findings? On the one hand yes, as the fact that the RCEP has recognised that there are serious inherent flaws throughout the existing regulations and called for a complete overhaul is obviously a positive outcome, although not entirely new. A number of previous reports have also “heavily criticised” the existing system and warned that public health was potentially at risk from pesticides, including the highly regarded British Medical Association's 1990 report “Pesticides, Chemicals and Health” and the Commons Agriculture Select Committee report in 1987.
The RCEP have agreed with many of the arguments I highlighted in my evidence, including those relating to the potential conflict of interest when policy and delivery functions are managed within the same agency. This applies in particular to the Government regulators, the Pesticides Safety Directorate (PSD), an executive agency of DEFRA. The PSD receive approx. 60% of their revenue for the licensing of pesticides. This is broken down into the levy charge and the fees for applications. The figure for the year 2003/04 for income generated from the agro-chemical industry is Â£7,155,000 and PSD are required to achieve full cost recovery for its operations.
However, the PSD is also responsible for advising UK Ministers on the development and enforcement of pesticides policy and legislation. Therefore, PSD's principle role is supposed to be the protection of public health, which should take absolute precedence over any financial, economic or other considerations. This cannot possibly happen under PSD's current structure and has been fully recognised by the RCEP.
The RCEP's findings were critical of both the Government's key advisors on pesticides, the PSD and the ACP. In a somewhat bizarre turn of events the RCEP's report exposes the fact that on 2 occasions the PSD did not pass on to Ministers the ACP's formal written advice regarding the bystander issue, (advice nos. 297 and 301) labelled as “Advice to Ministers.”
Having been a peer reviewer towards the latter stages of the RCEP's report, I was astonished to discover this had happened, especially considering it was repeatedly stated by both Lord Whitty and Michael Meacher during the meeting in December 2002 that they would need to await further advice from the ACP, which they stated was critical, before making any decisions.
The ACP members themselves must be surprised to learn that their own independent advice to Ministers didn't actually get to where it was intended. The detailed record of ACP meetings that I managed to obtain under the Freedom of Information Act revealed a letter written by the ACP Chairman, Professor David Coggon to the Chief Executive of the PSD, Kerr Wilson, in January 2004, explaining that a number of members of the ACP had reservations about the confidence that could be placed in the scientific evidence that the bystander risk assessment provides adequate protection. Within this letter Professor Coggon referred to “…the advice given to Ministers following meeting 301” and “In formulating our advice to Ministers.”
It is clear from the comments made by Professor Coggon that he was under the impression that previous ACP advice had been forwarded for Ministers attention.
It was actually the confusion surrounding this very issue that resulted in the RCEP having to delay the publication of their report from June to September, as even though the whole purpose of the RCEP study was to examine the scientific evidence behind DEFRA's policy decisions, the PSD had not passed on the ACP's advice to the RCEP either.
The RCEP also had difficulties obtaining from PSD the advice they gave to Ministers following their analysis and consideration of all the submissions to the 2 DEFRA Consultations and were even forced to consider invocation of the Royal Warrant. It appears the RCEP were unsuccessful in obtaining this information and therefore there are now question marks as to whether any formal written advice even exists!
However, disappointingly, despite the RCEP's strong criticisms aimed at practically all the Government agencies involved with pesticides and coming to the conclusion that there is a case that needs to be answered concerning the possibility of a link between agricultural use of pesticides and ill health in residents and bystanders, the report then manages to completely contradict itself by making recommendations that won't actually prevent exposure to pesticides for people in the countryside from crop-spraying applications.
Considering the evidence that was submitted to the RCEP in relation to the distances that pesticides have been shown to travel in the air and the calculated health risks for rural residents and communities living within those distances, the recommendation of a 5 metre buffer zone is quite frankly farcical and I remain at a loss to understand how the RCEP could have considered this to be acceptable and protective.
Many pesticides commonly used in California have been detected far from the site of application, some as far as 25 to 50 miles. Studies in America consistently find pesticides in the air, rain and even fog as a result of the repeated and frequent use and release of pesticides on a large scale in agricultural areas.
One study of Californian women showed that living within a mile of farms where certain pesticides are sprayed, during critical weeks in pregnancy, increased by 120% the chance of losing the baby through birth defects. Another study showed that living within a mile and a half of the cranberry fields of Cape Cod increased a child's risk of developing a particular type of brain tumour.
A recent study from America that confirmed acute illnesses in children and employees from pesticides sprayed on farmland near schools pointed out that 7 US states require no-spray buffer zones of up to 2.5 miles around schools.
Even data that was presented to the ACP by the PSD during the deliberations on the bystander issue highlighted that a study in California had shown high levels of a particular pesticide associated with an application 300 metres from the sampling station.
So, after accepting that there is a potential risk to health from pesticide exposure and stating that they could not rule out the possibility that crop-spraying may be responsible for the ill-health reported, where did the RCEP's wholly inadequate 5 metres come from?
I asked a member of the Royal Commission secretariat this very question and it appears to have come from one source, Silsoe, a research institute who have previously received funding from DEFRA and whose work is predominantly related to immediate spraydrift and application technology issues, in particular nozzle design. The RCEP relied heavily on their expertise for the modelling and exposure sections of the report. However, having previously spoken with employees at Silsoe, it was clear during discussions that they do not address the long-term exposure factors that I have been raising regarding rural residents and communities. For example, considering volatilisation can occur days, weeks, even months after application then it is immaterial how good the nozzles of the sprayer may be at the time of the application.
Many people who contact me have been affected by the inhalation of chemical fumes after application, which again is not something that would fall into Silsoe's area or work and has not been sufficiently addressed in the RCEP report. Yet the safety data sheet for each pesticide product shows how hazardous these chemicals are with warnings like “Very toxic by inhalation and do not breathe fumes; do not breathe vapour; harmful; possible risk of irreversible effects through inhalation; may cause cancer by inhalation.”
Therefore the recommendation of 5 metre buffer strips will be unable to protect people in the countryside from the overall and complex exposures they will be receiving as a result of pesticide spraying in the complete sense rather than exposure related solely to that of immediate spraydrift.
In another bizarre turn of events one of the representatives from Silsoe, who was involved with recommending this distance to the RCEP, now works for the organisation PAN-UK, an organisation supposedly working to eliminate the hazards of pesticides for the protection of public health and the environment. PAN-UK recently stated in a radio interview that 6 metres could be appropriate. (So it went up a metre!) This does not appear in line with their international counterparts Pesticide Action Network North America (PANNA) who clearly state on their website that “Pesticides can travel long distances and have been found as far as 50 miles away from where they were applied.”
The RCEP's 5 metre recommendation will only overwhelmingly disappoint rural communities who will see this as yet another independent inquiry that was filled with such promise, but in relation to the overriding key recommendation, has simply failed to deliver.
Therefore, once the dust settles and the morning-after arguments begin from all sides regarding the RCEP's findings, what will the RCEP's recommendations actually mean for rural residents and communities?
If not implemented by the Government, not a lot. If implemented, then we will now be able to obtain direct access to the information on what chemicals are being sprayed and when, which of course is a fundamental right that should never have been denied. However, it is all well and good to finally know what you are being poisoned by, but surely the fundamental point is not to be poisoned in the first place.
The UK Pesticides Campaign will continue to press the Government for immediate action and will be writing to Tony Blair to request an urgent meeting.
The only way to protect public health and prevent any illnesses and diseases that may be associated with pesticides is to avoid exposure altogether through the widespread adoption of sustainable non-chemical and natural methods as an alternative to chemical pest control.
If left to rely on the Royal Commission's recommendations then it looks like our long-awaited “breath of fresh air” may still be a long way off!