Royal Commission on Environmental Pollution again highly critical of the Advisory Committee on Pesticides approach

Royal Commission on Environmental Pollution again highly critical of the Advisory Committee on Pesticides approach to the risks to public health from pesticides in a response published today

The Royal Commission on Environmental Pollution (RCEP) has today published its response to the Advisory Committee on Pesticides’s (ACP) paper on the Commission’s special report on “Crop Spraying and the Health of Residents and Bystanders.”

The Royal Commission’s report published in September last year had concluded that crop-spraying is a potential health risk and that chronic illnesses and diseases reported by people in rural areas, including cancer, Parkinson’s and ME, could be associated with pesticide exposure.

The RCEP report was highly critical of the ACP and concluded that the level of confidence and assurance that had been given by the ACP to Ministers, as well as the public, regarding the safety of residents and bystanders exposed to agricultural pesticides, “represented too sanguine a view of the robustness of the scientific evidence.”

The RCEP report found significant unresolved issues in relation to the health and exposure elements of the current risk assessment. The RCEP concluded that they did not agree that the evidence could lead to unequivocal conclusions, previously given by the ACP, that the system provides adequate protection and that there are no scientific concerns or that it provides full reassurance to the Minister.

However, in the ACP’s response to the RCEP report, published in February, the majority of ACP members stood by the ACP’s previous advice to Ministers that the risk assessment used at present provides adequate protection. The ACP’s report, commissioned by Defra, argued that current regulatory controls already ensure a wide margin of safety and presented the problem of pesticide spraying as more of a social issue than a scientific one.

The RCEP’s response to the ACP, published today, states “It is clear that both the RCEP and the ACP agree that there are areas of scientific uncertainty and broadly on what those areas are. Our main difference relates to what action it is appropriate to take in the absence of scientific certainty, where human health may be at stake. This may well reflect an underlying difference in our assessment of the magnitude and significance of the uncertainties.”

The RCEP go on to state, “The RCEP concluded that a more precautionary approach to regulating the use of pesticides is needed.”

The RCEP point out that whilst they understand the ACP concern about the dangers of excessive precaution they do not see that as relevant where there is a level of uncertainty which they see as significant, particularly in the context of the stringent policy objective set in the EU Directive 91/414/EEC.

The RCEP point out that the ACP’s analysis did not appear to reflect the developing understanding of the very large variation within the human population in susceptibility to chemicals and questioned the emphasis laid in the ACP paper on just 2 conditions, Multiple Chemical Sensitivity (MCS) and Chronic Fatigue Syndrome (CFS).

The RCEP point out that their concerns in relation to human health issues “…are not so narrowly focused” and that a wide range of diseases had been reported to them during their study and refer to the concerns about other diseases, including asthma, autoimmune disease, lymphomas and leukaemia.

The RCEP point out that their recommendations stemmed from a desire to reduce the risks from pesticides in respect of all health impacts and state, “The ACP...has given insufficient recognition to the fact that our report dealt with a wider range of diseases.”

The RCEP question why other factors noted in the RCEP report are ignored in the ACP response and therefore why the ACP recommended focusing future epidemiological work only on occupational exposure.

The RCEP point out that this fails to address the point in that those working in agriculture do not represent the whole population potentially exposed. The RCEP state, “…the obvious exclusions are children, those with a pre-existing condition (eg asthma), the elderly and women in late stage pregnancy whose foetuses may be particularly susceptible.”

The RCEP conclude “We therefore persist in our concerns that the assessment of risk exposure, as well as the assessment of the potential impact of exposures on the full range of the human population, has not been fully addressed, and that there remain significant areas of risk and uncertainty. It is these concerns, rather than a particular view on the aetiology of specific syndromes such as MCS or CFS, which lead us to our conclusions that the risk assessment was insufficiently robust to meet the exacting standards laid down in the EU Directive.”

The RCEP conclude that “…while fundamental uncertainties remain, the response to public concerns of this kind should not seek to rest on scientific judgement alone. The Royal Commission has always recognised that ethical, social and economic considerations, as well as science, have significant bearing on environmental controversies. Policy must be informed by scientific evidence, but in complex situations such evidence may well not be conclusive. We accept that where an aspect of policy does not fall within the standard framework and precedent for risk management the ACP explicitly defers decision to Ministers. But we remain concerned that the ACP seems unable or unwilling to accept that most of its advice to Ministers is based on an implicit judgement, in a context of scientific uncertainty, about the relative importance of public concerns about human health and well being. Implicit judgements are being taken on the benefits of pesticide usage and consequent conclusions drawn about what is in the public interest. The four members who disassociated themselves from parts of the ACP response were evidently also uncomfortable with this judgement. This reinforces our conviction that there are still important questions in this area which need to be resolved, and that in the meantime further precautionary measures to reduce public exposure to pesticides are justified.”

The RCEP had been asked to examine the scientific evidence on which DEFRA had based its decision on the risks to people from crop-spraying, following a determined and relentless five year campaign by Georgina Downs of UK Pesticides Campaign, (www.pesticidescampaign.co.uk), the leading campaign highlighting the effects of pesticides on people in rural areas (referred to in the RCEP report as “residents” and “bystanders”).

Ms. Downs was the first to identify serious fundamental flaws in the Government’s “bystander risk assessment,” in early 2001 and started presenting a case to the Government for an overhaul of the regulations and legislation governing agricultural spraying.

This included the presentation of a video featuring people from all over the country reporting cases of cancers, leukaemia, non-Hodgkins lymphoma, neurological problems, including Parkinson’s disease and ME, amongst many other illnesses, in rural communities surrounded by sprayed fields. Despite that fact that the former Chairman of the ACP, Professor Coggon had repeatedly told Ms. Downs that the ACP needed to see the evidence of what was happening in reality to check if the current system was working, the video was only seen in full by a small handful of members and the ACP subsequently dismissed its content. In stark contrast, RCEP members all saw Ms. Downs’ video in full. The RCEP recommended in their report published in September 2005 that the ill-health effects reported by residents and bystanders need to be taken more seriously by Government advisors and regulators.

Ms. Downs states, “The ACP has continued to be complacent in relation to the impacts of pesticides on human health and the comments published today by the RCEP again raise the