Risk assessment and risk control of OP pesticides in animal husbandry with particular reference to Scotland

Scottish research relates to two projects:

• one on crofting (with some exploration of sheep dipping) that began 12 months ago and will be completed for publication/peer review in 12 months. This includes detailed work on occupational health and safety records.
• one on reporting of Scottish pesticide poisoning which aims to examine all official data available over last 10 years. This should also be complete in about 12 months for peer review and publication.

Assumptions are made about the strength of the evidence base for regulating and then continuing to approve pesticides such as OPs in the UK. Recent important research by Dr Clare Fairclough from Sussex University has shown how the basis for OP regulation and risk assessment in the UK often lacked rigour and drew conclusions about low level risk that were not justified either by the literature or the absence of literature in some areas.

The UK still lacks a proper, transparent and truly open pesticide regulation system that can be scrutinised. OP regulation illustrates this very well despite protestations to the contrary by scientific civil servants, politicians and industry. The current official reasoning for approving or continuing to approve OPs is not fully available. There is still a fragmentation of OP risk assessment and control: evidence about usage problems apparently fails to influence stricter regulation ‘upstream’ in terms of approvals. Some public groups are highly sceptical of the regulation, pesticide poisoning reporting and enforcement activity in the UK based on their personal experiences. This is observational and not anecdotal evidence and so should form part of the risk assessment and risk management decisions relating to OPs.

Opportunities for regulators to explain fully why they have accepted data and papers that indicate OP safety and apparently fail to act on papers that continue to document evidence about human health, have been avoided. This avoidance tends to confirm public suspicions about the OP chemical group. Very recent studies from the USA National Cancer Institute, from Manchester University, Liverpool University and Plymouth University have all recently provided evidence for growing concern about OP exposure beyond just narrow neurological effects because of links with certain cancers, susceptibility after OP exposures, effects on the immune system, and possible adverse environmental effects.

Information on the Scottish experience of OP usage provides examples and evidence of:

• a mismatch in a number of cases between users’ reports of suspected exposures and official recording of exposures. Hence there are indications of under-reporting of OP cases
• a wide gap between the regulators’ perceptions of how OPs are or were used and how they are or were in fact being used. This applies to past usage of OPs such as phosmet on cattle and current usage of OPs in sheep dipping
• an inability of the ‘system’ to investigate some reported cases of possible sheep dip poisoning and hence the lack of meaningful and useful early biological monitoring, tracking and support for those exposed
• a reluctance and sometimes refusal by officials to pursue cases of OP exposure reported to them linked to major and serious breaches of health and safety regulation by employers.