Report of the Working Group of the Veterinary Products Committee on the Suspected Adverse Reactions Surveillance Scheme, July 2002

Comments to the review of the Suspected Adverse Reactions Reporting Scheme

Questions to the Working Group

• Is the Working Group still of the opinion that "At present there is no scientifically recognised and widely accepted clinical syndrome associated with low-level exposure to OP dips"? (Report of the SARRS Appraisal Panel)
• Does the Working Group accept that Suspected Adverse Reactions Reporting Scheme (SARRS) could provide essential and crucial evidence as part of the on-going scientific research into the effects of repeated low-level exposure to OPs?
• It is surely vital that such evidence is seen to be collected by objective and independent scientific and medical professionals. Does the group agree? Do they consider that the marketing authoritisation holders could be so described?
• It is widely accepted that the reporting rate of SARRS has been very poor and is indeed diminishing. Does the group seriously consider that 'reporters' (ie farmers and workers) are likely to trust the manufacturers of the chemicals to make an assessment of a relation between their illness and low-level repeated exposure to OPs?
• Has the group considered the criticisms of SARRS contained in the HSE report HSL/2002/26? ('Risk assessment for acute toxicity from sheep ectoparasite treatments, including organophosphates (OPs) used in plunge dipping', HSL/2002/26, M Trainor & H Mason et al, Health and Safety Laboratory) What response does the group have, and do they consider that the marketing authorisation holders will comply with the suggestions by the Health and Safety Executive on biomonitoring?

OPIN considers that the government-funded on-going OP research projects such as SHAPE and SHAW conducted by professionals should be taken very seriously in this important debate. To be expected to accept the assessment of evidence by bodies whose livelihoods depend on defending themselves against any suggestion that their products could cause chronic ill-health is beyond rationality.

The Working Group should reconsider the bizarre proposals now put before us and accept their serious responsibility inherent in taking evidence from hundreds of chronically sick people by putting the assessment of evidence into the hands of independent scientifically objective and qualified professionals.

June 2003