According to estimates one to 1.5 million people in the UK live next to sprayed fields, and some of these people report ill health they attribute to pesticide exposure. Many report similar symptoms ranging from rashes, tremors, liver disorders, ME, multiple chemical sensitivity and other disorders of the nervous system. Of prime concern is the extreme difficulty in determining whether a pesticide could be causing the types of chronic conditions reported. Current official protocols for testing pesticides before placing them on the market are almost certainly unable to predict these adverse health effects. It is quite possible that pesticides which lead to these symptoms are being licensed and sold in the UK. The health problems experienced by some rural residents have been exacerbated over the years by a lack of appropriate medical treatment. Doctors have minimal training and farmers do not have to disclose which pesticides they are spraying, making decisions on appropriate medical treatment extremely difficult. Overall assessment of the extent of the problem has been impossible as the UK has had no effective centralised system for recording incidents of pesticide poisoning. This has been compounded by an institutionalised skepticism towards the concerns of these people.

Public and NGO action
The RCEP consultations were held after campaigns by Georgina Downs1, PAN UK and others, which were concerned with the inadequacy of the bystander exposure and risk assessments, the human health effects of exposure to pesticides and the need for immediate access to information on pesticides sprayed next to where people live. In 2003 the Pesticides Safety Directorate (PSD), the UK government department responsible for assessing risks from pesticides, consulted stakeholders on these two issues. The then Minister for Rural Affairs, Alun Michael, announced, following the consultation, that he was fully reassured that the existing system was protecting human health and therefore that no-spray buffer zones were unnecessary. However, he did recommend access to farmer spray records. Despite the conclusion that current procedures were robust the Minister requested an independent study to be carried out by the Royal Commission on Environmental Pollution (RCEP) on whether the current UK risk assessment for pesticides was protective of human health in general, and in particular to assess whether people living next to farms were adequately protected. The RCEP is an independent body of scientists set up to advise government and the public about environmental pollution. Over three decades its reports have proved influential. 

Royal Commission’s findings
The Royal Commission deliberated for around a year considering oral and written evidence and finally produced its report in September. Their most striking finding is that, ‘Based on the conclusions from our visits and our understanding of the biological mechanisms with which pesticides interact, it is plausible that there could be a link between residents and bystander pesticide exposure and chronic ill health. We find that we are not able to rule out this possibility. We recommend that a more precautionary approach is taken with passive exposure to pesticides.’ The Royal Commission is critical of existing systems for the detection of pesticide-related disease. ‘We have been unimpressed by the arrangements for monitoring human health … It is hardly surprising to hear residents and bystanders describing their experience of reporting arrangements ... as highly unsatisfactory. We believe that this system needs to be radically reformed, by the introduction of detailed clinical investigation, and extended to cover chronic cases.’The hard information and the breadth of the Royal Commission’s overview is welcome and is in marked contrast with the limited information issued to the public by the PSD’s 2003 consultation. The Royal Commission expresses serious concerns about a lack of response of the medical profession to the issue: ‘There has been almost no effort to develop a systematic approach to deal with the complaints from residents and bystanders of ill health that they have associated with pesticide spraying.’ However, the report appears to have had a galvanising effect. Sir Liam Donaldson, the UK’s Chief Medical Officer, after his evidence session with the Royal Commission, has undertaken to create a new working group within the Department of Health, to be chaired by the Royal College of General Practitioners, which will produce a module on toxicology to be integrated into the curriculum for general practitioners. Sir Liam has also proposed a number of other measures to improve the standards of care for members of the public concerned that their health has adversely been affected by pesticides. The report also recommends that the surveillance of ill-health effects from pesticides should pass from the UK’s Health & Safety Executive (HSE) to the new Health Protection Agency (HPA). The HSE is responsible for all risks to health and safety arising in the workplace and runs the Pesticide Incident Appraisal Panel (PIAP). However, this system has been grossly inadequate in collecting and assessing information on pesticide-related ill health. It only considers acute incidents and conducts no clinical investigation. In contrast the recently created Health Protection Agency has a broad remit to protect health from chemical hazard (currently not including pesticides), specifically aiming to take account of long-term low dose exposures. The HPA has estimated that it would cost between £5-10 million to run the new surveillance system, and the Royal Commission indicated that a levy on pesticides sales could be raised to pay for it consistent with the ‘polluter pays’ principle rather than the burden falling on the taxpayer.

The Royal Commission identifies the key obstacle to any successful surveillance or epidemiology: ‘the paucity of information concerning what it is that people have been exposed to. Either this information is simply not known or the affected person cannot access the data readily.’ The Commission recommends that we should have the right to know this information: neighbours and residents should be given prior notification of which pesticides are to be used, and signs should be placed on site at potential access points. Walkers and everyone who uses the countryside, and health researchers, should be able to find out which toxins have been applied to the land and are contaminating our bodies. The Royal Commission criticised the UK authorities for their lack of openness regarding the possibilities that pesticide exposure could cause disease. After the BSE scare in the UK when a disease affecting cows (Bovine Spongiform Encephalitis) was found to have passed to humans Lord Phillips was requested to conduct an inquiry. In his report2, Lord Phillips observed: ‘Throughout the BSE story, the approach to communication of risk was shaped by a consuming fear of provoking an irrational public scare. This applied not merely to the Government, but to advisory committees … To establish credibility it is necessary to generate trust. Trust can only be generated by openness. Openness requires recognition of uncertainty, where it exists.’ Five years later, the Royal Commission has had to recommend, commenting on the operation of the Advisory Committee on Pesticides, that ‘Areas of scientific uncertainty, ignorance and indeterminancy need to be recognised and their nature described explicitly … The effect of uncertainty on the estimate of risk should be made clear’ rather than downplaying the level of uncertainty present in assessments of health risks posed by pesticides. Of the PSD’s risk assessment for bystander exposure, the Royal Commission say ‘We have ... been disappointed to find that the current approach has not been rigorously evaluated under field conditions and has largely been assessed in relation to experiments done on a limited scale over twenty years ago and reassessed on the basis of other data often collected for different purposes in Germany and the US.’ The Royal Commission has identified that ‘the PSD combines both delivery of the pesticide approval process and policy advice to Ministers on pesticides’, and that ‘there is a danger of a conflict of interest, which may be greater where funding is derived from outside government.’ ‘An executive agency of the government, the PSD is funded by government for its policy work, however the full costs of evaluating applications for pesticides approval are recovered from the industry through fees and levies. In the year 2003/04 the PSD received £4.363 million from the levy for regulatory work which includes monitoring and compliance and £2.791 million in industry fees for evaluating applications … [In the same year the PSD received] £5.379 million ... from Defra for policy-related activities.’ The Commission has in earlier reports concluded that government bodies should not hold responsibility for policy and for the execution of such policy. The Royal Commission observes how little progress there has been, over decades, in protecting public health from pesticides, and in accessing information. Referring to the British Medical Association’s (BMA) 1990 report (see box) on the same issue the RCEP notes that ‘The BMA emphasised that the lack of information on how to gain access to data was perhaps the single greatest deficiency identified with regard to pesticide safety and … greater efforts [should be] made to obtain more complete comprehensible and validated toxicological, epidemiological and other scientific data on chemical pesticides and their effects on human health. It is disappointing that some fifteen years later these criticisms remain largely unaddressed.’ 

Monitoring exposure
Despite the existence of a comprehensive official biomonitoring programme in the United States and a number of smaller high profile biomonitoring studies, the UK government has still not undertaken such studies. Monitoring biomarkers for pesticide exposure in residents and bystanders could provide valuable information on how pesticides are affecting rural residents regularly exposed. The PSD has commissioned a very limited pilot study of biological monitoring, which will involve only 30 rural residents and one pesticide, cypermethrin. A much more ambitious programme of research is needed, as recommended by the Royal Commission: ‘We believe that it is important to develop national databases of information from sample surveys and large-scale longitudinal studies, so that baseline information on the exposure of the UK population to pesticides and other environmental chemicals can be derived and used for comparison with selected biomarkers in individuals who are concerned about their personal level of exposure.’

Limitations
There are at least two limitations in the RCEP report. Firstly, the Royal Commission has not identified the crucial point that unless and until there is a national pesticide use reporting system – not just a sample survey, as exists currently – it is impossible for epidemiologists to carry out systematic studies of the incidence of chronic disease including cancer in relation to pesticides used in any area. Secondly, in some circumstances pesticide spray will travel much further than five metres and so the recommended five-metre no-spray buffer zone will not always be adequate to protect residents. In some cases even a much larger buffer zone would not protect people from exposure. Reducing overall pesticide use will be another valuable tool in reducing people’s exposure to pesticides. PAN UK has set a target of a 50% reduction in pesticide use over the next ten years.

However, implementation of the RCEP’s conclusions would represent a quantum step forward in reducing risk to human health from pesticide exposure.PAN UK urges the government to act on the Royal Commission’s recommendations and to:

These measures would begin to address the decades of governmental neglect in relation to pesticide-related disease, including multisystem disease. The government has one year from publication in which to respond formally to the RCEP report. The Department for the Environment Food and Rural Affairs will be considering the report and will weigh the evidence and consider the options for practical action over the coming weeks and months. A government response will be coordinated by next summer. For recommendations in the RCEP report requiring statutory changes, the evidence will be set out in an Initial Regulatory Impact Assessment (RIA) which identifies the pros and cons of each option. Based on this Ministers will decide on an outline for the way forward. The government's response to the RCEP report will reflect the outcome of this initial process.

References
1. www.pesticidescampaign.co.uk
2. The BSE Inquiry, Volume 1, Findings and conclusions, October 2000, The Stationery Office.The Royal Commission on Environmental Pollution Report ‘Crop spraying and the health of residents and bystanders’, 22 September 2005, is available online at www.rcep.org.uk/cropspraying.htm

A summary is available on PAN UK’s website at www.pan-uk.org/rcepintro.htm