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Gaps in testing different studies are significantly variable and the ten-fold uncertainty factor between species is barely adequate in the case of some pesticides, for example, chlorpyrifos. In the case of diuron, there is a ten-fold variability within studies. For lambda-cyhalothrin, there can be a three or four-fold variability up to a 30-fold variability, depending on which study is selected. There is currently no regulatory mechanism to ensure that human dose-effect data held by the National Poisons Information Service (and equivalent organisations internationally) from human poisonings, are fed into the pesticides approval process, although PAN UK welcomes new initiatives of ECVAM, which recognises the critical importance of human data: ‘ … Validation – the proof that a test accurately predicts a specific effect in humans – is the biggest challenge for alternative methods … One of the 40 or so tests now going through validation is the new cytotoxicity test to help replace the animal lethal dose (LD50) test. It was the first validation study to involve both US and European groups from the start. It is also the first to use data from the records at national poison centres. The predictions of the in vitro test provided a better match than the rat LD50 test when compared with the toxicity information on 42 chemicals listed has having poisoned people.’ 48 There are serious ethical concerns about laboratory animal testing, and the inefficiency and wastefulness of the current system is referred to in the Prague Declaration: ‘It is regrettable that commercial pressures and property rights often stand in the way of making publicly available the data gathered by New concern has been expressed recently about shortcomings in the testing regime in relation to the supposedly non-active ingredients in pesticide formulations. According to French scientist Gilles-Eric Seralini 49 : ‘Scientific problems do exist in the registration of pesticides today, when chronic toxicity tests are conducted with the active ingredient alone – which is generally the case. First of all, chemists from companies may work hard for several years to find the formulation which best amplified the effects of the active ingredient. This formulation will allow penetration and stability and/or bioaccumulation of the active ingredients within plant, fungi or insect cells, for instance, to reach the best toxicity. If there are any side effects in other animal or human cells, these will be also amplified by adjuvants, and thus not measured in chronic toxicity tests with the active ingredient alone. The active compound absorption by skin is generally calculated in the presence of formulated adjuvants, but this is clearly a short-term study and not sufficient to detect, for example, endocrine disruption or carcinogenesis, possibly promoted in vivo by the described synergy. This should even necessitate further care in the use of formulated products such as glyphosate-based herbicides on tolerant, edible plants.’ 16 industrial companies for the purposes of hazard identification. We propose that the relevant data from animal testing should be made publicly available whenever possible. This would avoid costly duplication of experiments, and take account of ethical issues ensuring that the best use can be made of animal data for the development of alternative tests.’ Secret practice: human pesticide testing Over the last year there has been considerable high level debate initiated in the US about this issue. There is pressure on the agrochemical industry globally to conduct these studies ‘to reduce uncertainty’ because there is increasing demand for more sophisticated safety assessment. In the US, since 1996, the Food Quality Protection Act requires the Environmental Protection Agency to add an additional uncertainty factor of between 2 and 10 to account for the special susceptibility of infants and children to toxic substances, unless there are data to the contrary. PAN North America has now launched a campaign with Earthjustice and the Natural Resources Defense Council challenging the practice 50 . Human pesticide testing is unregulated in the UK. For historical reasons it is exempt from new stringent regulation imposed on experimental trials of medicinal pharmaceuticals. However, there is considerable public concern. The internationally accepted legal instrument controlling human pesticide testing is the Declaration of Helsinki 1964, which introduced an ethical framework to be applied to all biomedical research on human beings, to prevent the reoccurrence of the evils of Nazi experimentation. Current 51 human pesticide testing is conducted in complete secrecy within the private sector, and the lack of scientific and ethical scrutiny to which trials of pharmaceutical drugs are subject is a matter of concern. Your daily poison
5 Conclusions and Recommendations The need for a more precautionary approach to the approvals and use of pesticides is now imperative, and a national strategy for a government-led, coordinated reduction in the use of these toxic substances is urgently needed to protect human health and the environment. People continue routinely to be exposed to pesticides in food, water and the environment, reflecting the lack of progress in reducing dependence on these toxic compounds in agriculture. Despite the trend towards lowerdose pesticides that are used in smaller quantities than previously, the total amount of pesticides used in the UK in agriculture in 2004 rose to over 31,000 tonnes. The new national strategy must set clear targets for a coordinated reduction of use. The costs to human health cannot currently be accurately assessed. A new surveillance system is needed which is quick and easy to access, and provides prompt and efficient investigation and biochemical analysis. Medical outcomes should be monitored. The existing government schemes should be analysed and amalgamated so numbers of people whose health has been affected by exposure to pesticides can be accurately assessed. It is currently not possible to estimate how many exposures occur because each scheme does not indicate whether or not cases have also been reported to the others. The health effects of chronic exposures to low doses of pesticides, to which we are all subject, are uncertain. PAN UK urges the government to make the following changes to achieve a reduction in people’s pesticide exposure; improvements in the governance of pesticides; the strengthening of post-approvals human health surveillance for pesticide-related disease; and the provision of public information. We want to see a reduction in use of 50 per cent by 2015, and major reductions in exposure via food, water and the environment. The government should: REDUCE PEOPLE’S PESTICIDE EXPOSURE 1. Include in the national pesticides strategy an action plan for the protection of public health. High levels of pesticide use inevitably result in continuing exposure of people through residues in food, water, and in the environment. The national strategy should include clear targets for reduction. A comprehensive national pesticide usage reporting scheme should be incorporated and there should be disclosure of sales and usage records. 2. Press for a lowering of the European Commission legal limit for pesticides in water in line with the current advances in scientific limits of detection and application of precautionary standards. 3. Adopt and implement fully the recommendations in the Prague Declaration (Appendix 8, page 44, Shortcomings of the current regulatory framework, and Proposed measures and actions to be taken) in its own policy and practice and through its civil servants, employees, consultants, contractors and others as relevant. IMPROVE THE GOVERNANCE OF PESTICIDES 4. Carry out an independent review, possibly through the current Hampton review process, of the ACP and PSD, involving the Department of Health and the Health Protection Agency, and open up their procedures to public scrutiny. Complete restructuring of the regulatory authorities should be considered. Public health must be prioritised above chemical pest control, and the Department of Health/HPA should be given a more powerful remit in relation to pesticide-related disease. 5. Prevent conflicts of interest in the decisionmaking process on pesticide testing and approval by separating the functions of pesticide policy making from the pesticide approvals procedures, which receive a proportion of its funds from the agrochemical industry. the second UK pesticide exposure report 17
Page 1 and 2: YOUR DAILY POISON: THE SECOND UK PE
Page 3 and 4: EXECUTIVE SUMMARY . . . . . . . . .
Page 5 and 6: 1 Pesticide exposure in the environ
Page 7 and 8: ◆ A baby girl of 9 months was fou
Page 9 and 10: Exposure to spray-drift, pesticide
Page 11 and 12: 2 Food residues PAN UK has conducte
Page 13 and 14: David Mason, ‘official laboratori
Page 15 and 16: environment in the cycle of precipi
Page 17: conference that a Europe-wide biomo
Page 21 and 22: APPENDIX 1 Pesticide usage trends i
Page 23 and 24: APPENDIX 3 The regulatory testing a
Page 25 and 26: APPENDIX 4a ‘The human health inc
Page 27 and 28: APPENDIX 4c PAN UK survey: pesticid
Page 29 and 30: Local authority Number and nature o
Page 31 and 32: APPENDIX 5b Food residues (UK testi
Page 33 and 34: Food Pesticide WHO hazard OP WHO Cl
Page 41 and 42: APPENDIX 6a Pesticides in the publi
Page 43 and 44: APPENDIX 6b PAN UK survey: pesticid
Page 45 and 46: APPENDIX 7 Members of the All Party
Page 47 and 48: development in the womb. As a resul
Page 49 and 50: pollution stems from steroid hormon
Page 51 and 52: APPENDIX 10 Copies of PAN UK questi
Page 53 and 54: the second UK pesticide exposure re
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Page 57 and 58: References 1. Craig A, People’s P
Page 59 and 60: 57 Your daily poison:

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