Submission to the MAFF review of Anticholinesterase Compounds
6th October 1998
I am deeply concerned that this may simply be a cynical exercise on the part of Government designed to discover the true extent of knowledge available to the public rather than as a means to protect our health.
It is unfortunate that the Organophosphorus herbicide glyphosate escapes review since it is clear that it is known to have adverse effects on human health and that its full toxic potential is not known. Since it acts systemically it is likely to affect similar processes as other OP compounds, even if not cholinesterase.
If the Government was being honest there would be no need for a review for much of the information they hold was gained by human experimentation in the early quarter of this century. Those experiments were part of the war effort both in this country and abroad, from Russia and the USA to the Nazis, and it is of some interest that many of the Agrochemical companies now dominating the world markets were themselves born out of the Nazis war machine. Many of the others had close links to allied Governments.
I am certain that this is the real reason for the duplicity found at all levels and in all the professions involved with monitoring the effects of such chemicals on the population. The power and influence of these companies has extended into the very heart of Government itself and a dangerous mentality of denial has been allowed to flourish. So much so that reality itself is now being denied and even individuals who have firm medical evidence of poisoning are not recognised as sufferers. If these opinions are challenged then the individual finds the entire system of government in opposition.
Meanwhile the health of our children deteriorates and diseases once thought to be due to ageing are found even in the new-born. Those children are the future and while Government proclaims their education as a priority many will never have the opportunity to benefit because their health is destroyed before birth.
This review is 50 years too late. Lord Zuckerman himself requested urgent action in 1951 and later the Civil Service is reported to have requested urgent controls on the dangerous pesticides in an 80 page document rejected by the Heath Government in the 1970s.
The first priority for Government is to protect its people. Successive Governments have failed us all.
As I have already mentioned in correspondence the review places pirimiphos methyl in the same category as the other Organophosphate Insecticides. Apart from Malathion, for which I believe approval was withdrawn, it is the only chemical in the list which is deliberately added to the food we eat. [there are others apparently not listed]
This indicates the urgent need for a priority review of pirimiphos methyl. All the others may be present in food but only as the result of residual levels from chemicals applied during growth.
Oddly, even with pirimiphos methyl, the regulations determine a withholding period after treatment of up to 3 weeks before harvest is permitted, in order to reduce residual levels, and yet post-harvest treatments require no withholding time whatsoever. The dangers of this illogical advice can easily be illustrated.
In the case of Actellic Dust (2% w/w pirimiphos methyl) the product is recognised as hazardous to health in the transport laws which declare the need to warn against contamination of food by the chemical. So much so that food may not be stored, or transported, with the bags containing the chemical. Were this a concentrated form there would be some logic to this but the chemical is transported as the final product which in that very form is permitted to be tipped in bulk onto the surface of grain and mixed in by hand.
That grain and the chemical contained in it can then be eaten immediately. Some grains are eaten in the raw state together with the chemical – the equivalent of eating the chemical direct from the bag.
The manufacturers themselves warn of the risks to health through ingestion and yet toxicologists whose work involves Government sponsored studies on victims have declared that no such risks exist.
Appendix II Section 1 indicates the reason for this inconsistent approach.
The review is to consider "information on the identity and mode of action of the active substance."
This is where the safety standards adopted fail completely because it has and still does enable the manufacturers to quote test results on the active ingredient as a means to gain approval for the commercially available formulations which are rarely if ever tested in the same way.
Again pirimiphos methyl provides the perfect example of reviews which have failed to address the safety issues for currently available commercial formulations. This is admitted in the review document.
Furthermore it is clear from that document that pirimiphos methyl in its "pure" form failed to pass the Ames test but was still permitted as an undeclared food additive despite the obvious danger.
Other potentially more serious effects were dismissed almost as irrelevant in the review and include the observed damage to sperm, the reproduction effects in birds and the "loss" of almost 50% of marked chemical in feed trials. Such trials are essential to trace the path and fate of these dangerous chemicals and yet such a vital sign that their true fate is not known was allowed to pass without comment.
Users are warned that those affected by the chemical should not use it again. It is known that the effects are cumulative to a point where serious and irreversible health problems arise yet this factor was also dismissed by the review with the apparent assumption that low levels present less risk.
That determination assumes that the effects other than the cholinesterase depression, which forms the basis for safety calculations, are of no vital importance to human health.
It also assumes that the figures claimed for rapid chemical breakdown are accurate. Here again there is conflicting evidence. The review confirmed that the chemical does not break down rapidly in grain.
In fact it states on several occasions that the chemical breaks down slowly if at all.
In fact the review document was produced by the Pesticide Safety Directorate almost a year after they had been sent evidence supporting the fact that the chemical does not even break down as claimed in water.
Again this may be the result of inadequate testing requirements for commercial formulations.
Almost no data is provided concerning the ingredients added to the active ingredient in such formulations.
This provides both an enormous gap in the safety data and a possible reason for the long-term health effects since many of the so-called "inert ingredients" have also, in the past, been used as insecticides.
Appendix II Section 2 may well go some way to making amends for this oversight but it is too late.
This call for information should have been made when the first reports of ill health resulting from the use of pesticides were made. The instinctive reaction to hide or to invalidate those reports was a big mistake.
The risks posed by such chemicals as benzene and naphtha have been known for decades. Benzene and its derivatives have their own Industrial Prescribed Diseases recognised as such by Government and it is perfectly clear that the Health and Safety Executive are aware of the risks presented by the solvents.
In fact they are referred to as being the most likely cause of any illness produced by pesticide exposure in the Medical Series MS17 paper but toxicologists and the HSE themselves rarely acknowledge the fact.
Leukaemia and sensitisation are just two of the reported consequences of benzene exposure. Benzene has been used as a solvent in the liquid form of pirimiphos methyl added to grain for decades and it has been recognised that lymph cancer, a form of leukaemia, is common in grain workers. In fact it is reported as an Occupational Hazard for Agricultural workers in the United States.
Appendix II Section 3 may reveal the extent to which test animals have been bred for their lack of susceptibility to certain effects, known to be caused by chemicals, and their subsequent use in testing procedures designed to determine the dangers presented by pesticides. It is interesting to read articles on tests for endocrine disruption and cancer where animals with known traits have been used. How much this aspect has been used to provide favourable data for the regulators is a question which must be addressed.
Appendix II Section 4 refers to "the metabolism and toxicology of the active substance and products".
It is perfectly clear that the recent review of pirimiphos methyl found gaps in the data which should have resulted in a restriction in the use of the chemical, especially as an undeclared food additive, and yet nothing was done. Of even more concern is that despite calls from the USA for an immediate ban on the chemical, due to evidence of damage caused to children even though the USA does not permit its use in the adulteration of wheat, there was still no action taken.
It has been known for most of this century that the toxic action of OP agents is at the phosphorus atom.
The "in phrase" intended to confuse this basic fact seems to be "the surrogate-substrate effect" which is claimed to be a "new" mechanism of action. It cannot be new since government papers have repeatedly stated that many enzymes are inhibited by OP action, often with irreversible effect.
It is clear that the Evaluation document for pirimiphos methyl recognises that a variety of enzyme processes are influenced by the presence of OPs and many of the testing procedures reported actually measure the changes in the levels and concentrations of a variety of enzymes other than cholinesterase.
This effect must be the result of the bonding by the enzymes to the OP chemical as a surrogate for the phosphates normally acquired through diet or by the demineralisation of bone.
Any soldier who has trained as a combatant in the modern army is informed that he should be able to recognise the effects of nerve agents. He is informed that exposure to different parts of the body may cause initially different symptoms but as the chemical is absorbed symptoms become more classical.
This may well be the result of the differing predominant enzymes in the various exposure sites and the subsequent transfer by the enzymes of the agent to the more vital organs in the body where other enzyme systems become victims of a second surrogate action. Thus the exposure by skin, respiratory or digestive routes initially show different signs but later all show similar symptoms. It is interesting to make comparisons between the symptoms soldiers are trained to associate with nerve agent exposure and those listed by pesticide manufacturers as associated with pesticide exposure. As with the antidotes, and other treatments available, the similarities are so great that the two lists are indistinguishable.
It should be remembered that, deadly as wartime nerve agents are, they are designed to be short-lived and rapid acting whereas pesticides have been developed to be active over long periods measured in years.
Furthermore the ingredients used to prolong the action may also make the active ingredients more readily acceptable to the human metabolism with increasing risk to the vital enzyme processes.
It should be remembered that the hormone system is itself extremely vulnerable to enzyme disruption and that a whole host of ailments can result if that system is even slightly disrupted. Phosphorus deficiency symptoms may well indicate problems which may result when the enzymes which depend upon it are inhibited by Organophosphorus substitution for phosphates.
The different effects initially observed as caused by varying types of OP pesticide may simply be the result of the molecular shape which is known to be a greater influence on toxic potential than chemical formula. Some pesticides may contain molecular structures more readily accepted by the enzyme systems or may bond more readily to receptor sites in vital organs than others. Fat metabolism may be an indicator of this process since some OPs are more lipophilic than others. There is a possibility that the enzymes are unable to break down the OP bonded fat molecules and that this may cause them to store the fat for a later and more complex break down process. This may explain why sufferers who may have undergone a period of recovery consequently suffer a relapse if they attempt to lose weight. The OP bonded fat is released once again into a much more complex breakdown system and may be utilised in vital organs.
The immune system itself is enzyme dependent and it has been reported on many occasions that those exposed to OP pesticides become vulnerable to disease and the recurrence of virus infections.
Since enzyme processes also form antibodies it is probable that an improperly functioning immune system is the result of miss-shaped antibodies which are unable to bond to the intended antigen.
This would not only result in a weakened immune system but failure to ensure the presence of the correctly shaped antibody for previously overcome viruses or bacteria will allow them to multiply unchecked and could therefore lead to a recurring and apparently resistant viral or bacterial infection.
Appendix II Section 5 seeks information on exposure and risk to operators, bystanders and workers but the laws covering these aspects have never been properly enforced. Workers are inevitably at greater risk of exposure than the general public but there are important exceptions. In many cases workers may live many miles from the application site whereas members of the public may live in or near the area sprayed and be subject to almost continuous exposure for weeks or months after the worker has cleaned his equipment and ceased contact with the chemical. The worker may even have been supplied with the full range of protective clothing not available to the public and which would have reduced his exposure level.
Both these groups are however placed at greater risk than are the greater proportion of the public for dietary considerations made by the regulators may already have underestimated the Acceptable Daily Intake in the food we eat, the air we breathe and the water we drink. Any further exposure will inevitably be in addition to that Daily Intake and Occupational Exposure is mystifyingly set at the same daily level. Even without any dangerous exposure workers are therefore permitted by law to be exposed to twice the "safe" level. Worker exposure levels are based on assumptions, some of which have already been indicated, which may be grossly inaccurate such as concentration, exposure times, efficiency of protective clothing, health and exposure history of the individual, and the possible presence of other chemicals etc. These same factors must be appreciated when considering the risk to bystanders who may introduce an additional risk factor. Some bystanders may be children whose immune systems are not fully formed and already under the natural stresses by way of exposure to childhood diseases. Research already mentioned in the USA has found that children already exceed the recommended Daily Intake levels of OP pesticides and it is obvious that since safety factors assume rapid breakdown, which does not in reality exist, then even the safety levels set considerably underestimate the danger.
Bystanders who happen to be children are therefore at greatest risk but despite this several local incidents have not been given the importance they deserve or been properly investigated by the authorities.
Appendix II Section 6 refers to residues in or on treated products, food and feed and the risk to consumers which was touched on early in this submission. Again it must be emphasised that pirimiphos methyl is specifically applied to harvested grains unlike any others on the list of chemicals in the review.
Its presence can be in addition to residues from spraying operations on the growing crop.
It is assumed that regular monitoring will protect the public but that is a simplistic approach relying completely on the accuracy of the chemical company data and accurate incorporation methods.
Both are wholly unreliable. The claim for rapid breakdown has already been shown to be a gross distortion of fact. Incorporation methods have been criticised even as long ago as 1992 by the British Medical Association who suggested that the presence of pirimiphos methyl in barley might give beer an unexpected extra kick. The "bucket and shovel" application method is approved by the manufacturers and yet accurate incorporation methods are impossible by such hand mixing methods. The Pesticide Safety Directorate has been informed that even the purpose built applicators have their faults and have resulted in incorporation rates some ten times that recommended in a single application. It must be realised that farmers and growers are not the only people to treat grain. It was reported in the review document that some bakers are adding the chemical to flour during the baking process. This must inevitably be a second application with the same risks for over incorporation and may lead to "hot spots" considerably in excess of any pre-set safety limit. Similar problems may exist in spraying applications for flow rates set for full conveyors will still apply the same quantities when the conveyors are running with reduced capacity.
In manual applications it is quite common for bags to be spilled and it is almost impossible to then evenly distribute the chemical. The resulting overdosed grain would in turn cause the Acceptable Intakes in the diets of hundreds of individuals, human or animal, to be exceeded many times.
The chance of such incidents being picked up in the testing procedures which have been limited to a few hundred loaves per year taken from the millions of tonnes of grain sold annually are negligible.
It was interesting to see the publicity generated by the regulators when OPs were found in organic bread.
How is it that conventionally produced crops are said to show negligible levels despite the common use of the chemicals by farmers, hauliers, grain stores and millers? Perhaps the sampling is biased?
What must not be forgotten is that this chemical is incorporated into the grain we eat every year and that many tonnes of active ingredient are involved. This is a poison with cumulative effects, with known dangers to health presented by ingestion, and with effects which are known to be irreversible.
It would seem that the risks of continued use are obvious – except to the regulating authorities.
Appendix II Section 7 whilst covering the fate in the environment will also cover many of the issues already raised. One of the strangest comments on the instructions provided by the manufacturer of pirimiphos methyl is that, despite the dangers presented by the capability of the active ingredient to be absorbed through the skin, it is permitted to be used to spray beaches. Beaches, as anyone with any sense will understand, are the places where children sit almost naked and in direct contact with the sand.
Only where there is a conservation beach dedicated to wildlife must permission be sought when proposing to spray beaches. This indicates the known risk to the reproduction of birds and yet the same chemical is approved for use on growing crops all summer when birds visit the fields for food.
This is likely to be covered in more detail in Appendix II Section 8 under the risk to non-target organisms but it is clear that spray drift presents a risk. The Ray Organophosphorus Esters document attempts to give the impression that drift presents no risk. Perhaps he should review the Pesticide Incidents Appraisal Panel reports for the last 20 years and he will see several confirmed cases of poisoning by spray drift. Every organism which is inadvertently exposed is a non-target organism and spray drift does not discriminate between people, pets or wildlife. Perhaps a single exposure due to drift may not have lasting effects but regular exposures will have cumulative effects.
Even with the use of solid chemicals such as rat bait and slug pellets there is the possibility of death for non-target species. Poisoning rats has resulted in the deaths of cats, dogs and even weasels that follow, kill and eat weakened and poisoned vermin. Spreading slug pellets over the soil of fields has caused the deaths of birds and small rodents while accidental spillage has killed dogs and even cattle.
Perhaps the most important non-target organism is the future generation of man. It is known that OP compounds can adversely effect both RNA and DNA and that the egg of the foetus is viable. Perhaps this should be the warning for us. How many generations are we putting at risk by delaying action?
Appendix II Section 9 covers the effects of combined exposures by chemicals with the same mode of action and it is perfectly clear that the effects of potentiation, or synergy as it is now referred, have been known for decades. As detailed earlier it is known that OP compounds can inhibit enzyme systems and that toxicity depends more on molecular shape than chemical formula. Each OP agent has a slightly different though essentially similar structure and so it follows that each may affect one enzyme process more than another and it is obvious that combined exposures will therefore do more harm than will single exposures. It is also known that some 3% of the population do not have sufficient detoxifying enzymes to deal effectively with OP agents and that some may be suffering liver damage due to previous exposures or as the result of other unrelated diseases. Some chemicals such as mercury, which was widely used as a seed dressing until recently, are also known to enhance the toxic action of other chemicals. My own experience and reports from friends who have used other chemicals suggest that in addition to the sheep dip problems, which this review does not cover despite the risk of combined exposures, there have been serious problems with numerous pesticides in common use. I have spent much time on pirimiphos methyl because this has been considered to be an OP which so safe that we can eat it in its parent form despite a mass of information to the contrary. Others for which I have personally had adverse reports are demeton-s-methyl and fonofos which I understand are soon to be withdrawn, chlorpyrifos for which, like pirimiphos methyl, there is a call for immediate ban, and the organochlorine lindane for which use has been restricted in many countries. Perhaps these are chemicals for which there are certain potentiating effects and this is why they have come to my attention.
There are a great many papers which detail the effects of combined exposures but it is known that such combinations have never been studied in detail. Some that have been tentatively examined have often been tested in conditions which do not accurately portray the use of the products in the field.
Here once again we come back to the testing procedures accepted by the regulators. There is a world of difference between injecting short-lived animals with chemicals and a lifetime’s human exposure.
Unfortunately the chemical companies have virtual monopoly over laboratory work and it is becoming increasingly obvious that they are prepared to obtain the results which they wish to see at whatever cost.
Why they cannot see that any false information will have a detrimental effect on their own lives and those of their families, friends and even future generations is a mystery to us all.
Much of this information was passed to the National Poisons Unit, Guy’s hospital in 1992 but they apparently failed to inform the Government but chose instead to hide the information they obtained. Many of us have been duped into believing that the Government needs our information in order to ensure the safety of others only to find that our information is all that was required. That information is then twisted and used against other victims in a cynical attempt to hide the truth. Had the regulators acted properly when the first indications of health damage in the farming population were reported the problem would not have escalated to the damaging position we now experience. Instead victims have been the subjects of repeated experiment and deliberate misinformation designed it seems to gain information for the chemical companies and to hide the real truth regarding the dangers of pesticides.
Some of us have devoted many painful hours in our attempts to persuade the authorities to recognise the facts but we have been met with what I call the "Nelson’s Eye" syndrome. Those we contact simply refuse to see what is presented before them and would rather twist and lie their way out of what is a potentially embarrassing situation. There is little doubt that the American and United Kingdom defence establishments have an interest in this problem. I have reports from a reliable source that Guy’s NPU worked on an OP study in 1993 in which a member of staff from Fort Detrick, USA, was involved.
That member of US staff informed me without questioning the words he spoke that radiation was safe.
How low can these people sink in their efforts to hide reality? On the same occasion an NPU toxicologist, reportedly employed by the discoverer and manufacturer of pirimiphos methyl, claimed that ingesting Organophosphates presented no risk to health and that the eye was not a route into the body for OPs.
Since eye drops are used in experiments on animals as a means to get OPs quickly to the brain without injection it would seem that this too was a blatant lie. Why the need for such lies?
Despite repeated requests to Government they refuse to detail the links between the toxicologists employed by the NHS and the companies against whom action must be taken should they confirm poisoning. There is without doubt a strong communications link between the Health and Safety Executive, and its various departments including the Pesticide Incidents Appraisal Panel, and the chemical companies and that link also encompasses various staff members within the NHS and the Department of Social Security. It is surprising therefore that Government claims that little is known about the effects of OP compounds especially given that its own publications have described in detail the exact effects, both short and long-term, acute and chronic, for almost 50 years.
I have today had a most distressing telephone conversation with a fellow victim of pirimiphos methyl who, as it happens, won a legal case a year ago. I know of very many others ranging from 24 years of age to retirement age but many will not come forward. This should be no surprise.
Today’s telephone conversation is explanation enough and shows how corrupt Britain has become.
Here we have a man disabled, his active life ruined because he was never told how dangerous the chemicals he was using could be – we are still being told it is safe. Persuaded by activists and his conscience that it was important to expose the dangers so that others would not fall victim he approached a firm of solicitors recommended to him. That firm proved to be less than honest but did rather well out of his case. He moved to another firm. His own side and the defendants, who were not the chemical company but they involved themselves in order to protect their chemical, sent him from one end of the country to another for "Tests" because little was said to be known about the problem. He won his case in the High Court but the Judge reduced damages saying he had suffered as the result of the tests performed on him by his own side. A year later and he hears the defendant’s insurers are boasting about how they intend to bankrupt him. Meanwhile his solicitors send him the bill for the case. Many of the costs incurred were deemed unnecessary and they say he will have to pay. The lawyers have, as usual, made small fortunes out of his case. He needs compensation. His means to earn a wage has gone and his life has been made almost unbearable, made worse even by his own legal representatives.
He fears that when he can finally escape the clutches of the lawyers he will have lost everything including his home. Meanwhile the defendant is insured and has not suffered. The chemical companies still claim that the pesticide is safe. The Insurance company involved has paid not a penny to the victim.
The Government maintains its dishonourable position and prolongs its period of inaction by calling for information it already possesses. Meanwhile our children are being slowly poisoned every day.
Dated 16/9/2000