Under Control?

In the last 30 years there has been a veritable explosion in the use of synthetic organic pesticides. Over 800 formulations are now used in the UK alone. They include insecticides, nematocides, fungicides, herbicides, and rodenticides. They are sprayed on cereals, fruit, vegetables and grassland. They are used on golf courses to kill weeds, in paints to ward off fungi, on building timber to prevent wood-worm, on woollen carpets and clothes to kill moths and in our larders and kitchens to kill beetles, flies and other insects.

Some of these chemicals such as DDT, have now become global contaminants. Traces are to be found in the bodies of Antarctic penguins, in the rain, in our drinking water, and in just about all commercially produced food. Each one of us has, in his body fats, traces of hundreds of different pesticides. They are in human milk, they even find their way into fertilised eggs and contaminate foetuses in their mothers wombs.

Very few efforts are made in Britain to find out the precise biological effects of these chemicals, though in the light of available objective knowledge, they undoubtedly make a considerable contribution to our disease-load and are probably responsible for many cancers and child malformations. Government and industry try to assure us that their use is under control, but it is increasingly clear that this is untrue.

In the USA, attempts by the Environmental Protection Agency (EPA) to regulate the use of hazardous pesticides have been systematically sabotaged by the chemical industry. In 1972 major amendments to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) were passed which would theoretically have permitted the proper testing of new pesticides and the re-registration of existing ones. As Ian Nisbet points out, they were never implemented: [1]

• Although the amendments stipulated that all existing pesticides should be re-registered within two years, four years after the statutory deadline not one of the 33,000 registered pesticides had met new approval.
• Although in 1969, a Commission of the Department of Health and Welfare (HEW) singled out 26 pesticides as health hazards and recommended that their use be controlled, nine years later, the use of only nine of these dangerous chemicals had been restricted and only about half of the others had been examined.
• Although too, in 1972, the EPA published a list of a further 100 pesticides which it termed "suspect" and which it regarded as requiring priority action, of these only a couple of dozen have been examined, and only a bare handful regulated.

The EPA has proved incapable of acting effectively against the chemical companies. As Nisbet notes, however toughly the EPA acts against a suspect pesticide, "the wrath of the agro-industrial community descends upon key congressional leaders, who lose no time in conveying their displeasure to the Agency." Thus the EPA is always under pressure to postpone decisions - and nothing gets done.

Yet the Congressional Committee on Oversights and Investigations tells us that at least 25 percent of all pesticides on the market have shown cancer-causing potential. Every day the entire population of America is exposed to these pesticides in the air they breathe, the water they drink and the food they eat - and the cancer rate continues to soar.

Increased Use of Pesticides

Unfortunately information on the use of pesticides in the UK is not as easily available as in the US. Even the Royal Commission on Environmental Pollution [2] was unable to obtain all the information required to draw up its recent Report on Pollution from Agriculture. "The data we have obtained to illustrate growth in the production and use of pesticides in either financial or tonnage terms", writes the Commission, are "without as much meaning as we would have wished."

The British Agro-Chemicals Association (BAA) appears to have no data at all on sales before 1974 and has only conducted two surveys of the quantities of active ingredients sold, one for 1966 and one for 1975-76.

These figures suggest that sales have increased dramatically in this country, from about £10 million worth in 1940 to £148 million worth in 1975. About 50 percent of sales in 1976 were for export and 90 percent for horticulture and agricultural use. The BAA sees the trend as continuing into the future: if they are right this means that pollution by pesticides can only get worse unless controls are tightened - assuming of course that such controls can be effective.

Policy

If one considers how dangerous these chemicals are one would suppose that it would be Government policy to minimise their use by every possible means. Such a policy has indeed been adopted by the US Government, though as we have seen, it has proved very difficult to implement, as it has in the Netherlands and in some prefectures of Japan. However as the Royal Commission notes,

"there is ... no such policy in the UK, nor does the possible need for it appear to have been considered, notwithstanding the great increase in the use of these chemicals."

The official view of the Ministry of Agriculture, Fisheries and Food (MAFF) is that pesticides are quite safe so long as they are properly applied and that their high cost discourages excessive use. The members of the Royal do not accept this view:

"We have considerable misgivings ... Farmers feel themselves to be on a treadmill with regards pesticide usage, compelled by circumstances to depend on chemicals to an extent that they, as countrymen, intuitively find disturbing."

Also,

"in the great majority of cases there was incorrect perception of the likely losses, due to pesticide damage and the effectiveness of the pesticide applications in reducing the losses was overestimated."

The Commission also deplores the practice 'calendar spraying', i.e. of spraying systematically at different times of the year in anticipation of possible pest attacks, a practice which the chemical industry encourages in every possible way.

Spraying crops for cosmetic purposes is also condemned by the Royal Commission. To ensure that carrots are unblemished, it points out, an amount of pesticides "well beyond what would be needed to protect essential crops" is used. It is not even Government policy to discourage this practice which would seem almost impossible to defend. Yet MAFF defends it, and insists that it is not possible to separate the protection of appearance from that of the crop - which is obviously quite untrue.

The agro-chemical industry, on the contrary, seems to be under the impression that it is Government policy to encourage the maximum use of pesticides. Thus in Industry's Statistics (1976), it complains about the recent fall in the use of herbicides

"in a period when Government is actively trying to encourage greater productivity from grasslands. It is obvious that education programmes to this end are not achieving full success, and the potential value of herbicide usage in contributing to improved profit is not being taken up within the industry. This causes some concern, particularly in view of the past and continuing investment in research and development into the use of herbicides in grassland systems."

At all Agricultural Colleges in this country students continue to be taught to spray crops with pesticides of hundreds of different varieties on the slightest possible provocation, though it is encouraging that the students themselves are beginning to doubt the sanity of what they are being taught and the objectivity of their lecturers. At Cirencester Agricultural College, they have formed the William Cobbett Society, of which there are almost 100 members, and they periodically invite critics of modern agriculture to address their meetings.

The Scale of Spraying

In the US, contrary to what one might suppose, only a relatively small proportion of food crops are actually sprayed; 5 percent with insecticides, 15 percent with herbicides and 0.5 percent with fungicides. Of the 543,600 tons of pesticides - 30 percent of the world's production - that was used in America in 1977, 50 percent was sprayed on golf courses, parks and lawns. Of the amount used for agricultural purposes nearly half (47 percent) was used on cotton. [3] In Britain, on the other hand, practically all food crops are sprayed with one pesticide or another.

Multiple Spraying

Worse still, crops are often not only treated with one pesticide but with many at different periods of the year (calendar spraying). Thus according to the Agro-Chemical Industry [4] of the 367,000 acres of potatoes grown in this country in 1976, 310,000 are treated with herbicides, 114,000 with granular insecticides and nematocides, 218,000 with foliar insecticides and 265,000 with fungicides.

In order to protect potatoes from pests, the normal procedure that is tacitly advocated by the industry, is to:

• spray the soil with an insecticide/nematocide before planting the potatoes,
• spray it once again with herbicides before the potatoes emerge,
• spray the crops from 2-6 times with a 'protectant' fungicide to prevent potato blight;
• spray them again with foliar insecticide against late aphid attacks,
• and then spray them a final time with desiccant herbicide so as to burn off the tops in order facilitate mechanical harvesting.

In this way one acre of potatoes, the industry boasts, can be treated from 2-11 times with different pesticides. It must be pointed out, of course, that the potato will retain residues of each of these different pesticide which means that a portion of potato chips is likely contain a veritable cocktail of dangerous poisons.

The agro-chemical Industry of course insists that the levels are so low as to be of no consequence, but this is a purely gratuitous statement based on no satisfactory evidence of any kind. On the contrary, the evidence suggests that exposure to very low levels of pollutants over a long period, to be as biologically damaging as exposure to very high levels over a short period.

Aerial Spraying

What is particularly shameful in Britain is the prevalence of aerial spraying. One million acres of agricultural land are sprayed each year, which involves 34,000 flights. Controls on this practice are practically non-existent. Admittedly operators are required to give advance notice, but only, as the Royal Commission points out, in so far as this is 'practicable', which means, 'when it does interfere with economic priorities'.

Often the police are not even warned. Nor are bee-keepers, and let us not forget that the bee population of this country has been very seriously affected by spraying. In some areas bee populations have been almost annihilated.

Moreover, farmers whose land adjoins an area being sprayed often find it impossible to obtain the information and advice that would enable them to know how to protect themselves or their livestock. Nor, as the Royal Commission points out, does there appear to be any controls on the type of spraying equipment use as is the case in other EEC [now EU] countries.

The Types of Pesticides Used

Even more worrying is our continued reliance on the use of the most environmentally harmful pesticides, in particular the organo-chlorine and organo-phosphorus compounds.

Many of the organo-chlorine pesticides - the highly persistent ones that have had such a devastating effect on our wildlife, such as DDT, aldrin and dieldrin - have now been banned from most uses in the USA, and it is generally assumed that their use has been more or less phased out in the UK as well. However, this is no so. There has been a voluntary limitation on their use, which has had some effect, but 132 tons are still used every year in agriculture and horticulture.

In addition, the effectiveness of the voluntary limitation on the use of dieldrin and aldrin, [5] which came into effect in 1965, is limited by the fact that a large number of special uses are still approved. In certain circumstances, they are still allowed on winter sown wheat, on sugar beet seed, on potatoes, brassicas, narcissus bulbs, hop roots, barley, strawberry seed, bean seed, onion seed, ornamental plants and spinach. This of course covers a considerable proportion of the uses to which dieldrin and aldrin were put in the first place.

Nor is there a method of assuring that farmers only use these pesticides in the special circumstances allowed. On winter sown wheat, for instance, they are only supposed to be used up until the end of December when there is a real danger of attack from wheat bulb fly. But who is to check that farmers do not use these pesticides in January or February? The answer is nobody. How too can one determine whether the danger of attack by wheat bulb fly is real or imaginary? The answer is that one cannot.

Non-agricultural Use

What the public doesn't realise is that larger amounts of many of the most dangerous pesticides are used for non-agricultural purposes, more so, in fact, than for agricultural ones.

Thus whereas in 1974, 7 tons of dieldrin were being used in agriculture, 22.2 tons were used for non-agricultural purposes, in particular in the woollen industry. Most woollen carpets and woollen garments sold in this country are in fact impregnated with this cancer causing substance.

So too, in the same year, only 1 ton of malathion was used by farmers; whereas 10.3 tons were used for non-agricultural purposes, mainly by public authorities who tipped 7.6 tons of this poison on refuse tips and used it for 'public health and hygiene purposes' and also as a wood preservative.

In a recent Department of the Environment report on the non-agricultural use of pesticides in this country [6] it was stressed that little is known of the implications of using hazardous pesticides in this manner. We do not know for instance what is the fate of dieldrin that is volatised in the house from recently treated timber, nor do we know what is the significance of the volatisation of dieldrin from industrial moth-proofing.

No effective mechanism exists for providing users with advice, though it might be pointed out that the manufacturers of Dielmoth, of which 15,600 kilogrammes of active chemical (dieldrin) are used every year in the textile industry, advises against treating children's clothing and underwear with this poison.

Since the DOE report came out, the use of pesticides for wood preservation has been examined and is now covered by the Pesticide Safety Precautionary Scheme (PSPS) applied by the Advisory Committee on Pesticides (ACP), though as we shall see this means precious little.

Pesticides in the Home

It is when pesticides are used in the home that human exposure is maximised. If levels of DDT in human fat are 4-5 times higher in certain tropical areas, including parts of India, than they are in temperate areas, it is as a result of WHO's anti-malarial spraying programmes, during the course of which the inside of peoples' houses or huts were systematically sprayed at regular intervals.

Needless to say this doesn't happen here, although about 40 different pesticides found in 230 different products are used in the home, 75 percent of which are insecticides of some sort. A survey carried out by the DOE, for instance, found that 51 percent of households made use of at least one of the 93 different fly killers currently sold in British shops and a considerable proportion of households (between 6 and 31 percent) also used ant killers, general insecticides, wood preservatives, moth-killers, rodenticides, fungicides, etc. [6]

Wildlife

The general view today, fostered by the British agro-chemical Industry, is that the reduced use of organo-chlorine pesticides has permitted decimated bird populations to recover.

Professor Mellanby tells us, for instance, that bird-kills caused by aldrin and dieldrin in the 1950s are over. He tells us that "once stricter controls of insecticides had been introduced the process has been reversed". [7] The Royal Commission does not share this view. It notes,

"The evidence suggests that the decline in the level of organo-chlorine compounds in the environment has not been as rapid as envisaged." [2]

Studies on the eggs of sparrow hawks from 14 areas of Britain from 1971-77

"have not demonstrated a marked decline in organo-chlorine residues and in some cases there has been some evidence of increase."

How does one explain this? Either the effect of these chemicals is greater than one thought or the use of these chemicals is more extensive than is generally admitted. Both may well be true.

Pesticides in our Food

Practically all the food eaten in this country, as in America, contains pesticide residues. In the last available survey, [8] levels of different pesticides in different foodstuffs that were regarded as being of any significance (reporting levels) were noted. Only one foodstuff - 14 samples of honey - was free of residues of organo-chlorine pesticides.

A large percentage of foods had levels that contained residues above reporting level - 41 percent of samples of hard cheese for instance, 28 percent of soft cheese, 45 percent of butter, 33 percent of infant food, 65 percent of strawberries. The average daily intake of organo-chlorine pesticides from the consumption of 1.7kg of food was 56 microgrammes.

With regards organo-phosphorus residues, 11 percent of peaches, 19 percent of grapefruits, 17 percent of strawberries contained residues above reporting levels.

A working party on pesticide residues at MAFF is supposed to carry out monitoring. However, it does not publish detailed studies of chemicals in different foodstuffs, only a periodic estimate of the total amount of pesticides in the average diet. The Royal Commission comments on its inability to obtain information on monitoring activities:

"We find it difficult to establish how much monitoring ... is carried out. MAFF was unable to estimate readily the resources allocated to it because many laboratories are involved and the work is linked with other activities."

What is certain is that it is not done at all systematically. Routine sampling of foodstuffs on the market is not carried out as it is in other EEC countries, nor are consignments of food found to contain residues exceeding prescribed limits, removed as is again done in other EEC countries. As the Royal Commission notes, "successive UK Governments have resisted the EEC approach." The excuses given are as usual vague and totally unconvincing.

The Control of Pesticides

We are all led to believe that the use of pesticides is already under strict control. Dr. Schuhmann, in an industry-sponsored book, Pesticides and Human Welfare, writes:

"I wish to emphasise here that legislation in all advanced countries has reached a standard which, given the proper use of pesticides, ensures that the consumer of agricultural products suffers no risk to his health or well being." [9]

In Britain, the only control on the safety of pesticide use is that provided by the Pesticide Safety Precaution Scheme (PSPS).

When a manufacturer wishes to produce or import a new pesticide, he must get prior official agreement from the Advisory Committee on Pesticides (ACP), which is part of the Ministry of Agriculture, Fisheries and Food (MAFF).

To obtain this, he must submit test data relevant to the safety of the product to independent expert scrutiny. The data, together with the opinion of the experts, are then examined by appropriate Government departments with the assistance of the ACP, supported by its Scientific Sub-Committee (SSC). The ACP is regarded as the principal source of advice on the use of pesticides and to assure its objectivity, none of its members have any commercial interests in the agro-chemical Industry.

This body, with the help of the SSC, if they judge fit, give a product limited clearance for use in a limited area and for a couple of years only. During this time long-term tests are carried out after which the product is cleared for general use.

The procedure appears to function smoothly. That is the impression of the Royal Commission. It is also the impression I obtained from conversations with the scientists who work it. They are very helpful and appear highly competent. But if this system really works, the use of dangerous pesticides would not go on increasing as it is doing today. What then is wrong with the system?

Industry Provides the Data

Most of the data used for judging the safety of pesticides is provided by industry itself and quite obviously the industry cannot be expected to be objective about the safety of an individual pesticide that may have cost them £10-15 million to develop. The data are likely to be biased in some way.

In America it has now become public knowledge that much of the data provided by industry are false, indeed fraudulent. This was revealed in 1976 when the Food and Drug Administration (FDA) did an audit of records kept by the Industrial Biological Test Laboratory of Northbrook, Illinois.

This laboratory, which as it happens was owned by a chemical company, had been widely used by pesticide manufacturers to conduct tests and collect data for submission to the Environmental Protection Agency (EPA) in support of applications for registration and to determine residue tolerance levels. The FDA audit covered 4,300 tests involving 123 pesticides and 160 applications for residue tolerance levels. The audit disclosed that

"false reporting and great discrepancies between test results and the data submitted to the EPA". [10]

In March 1978 EPA officials confirmed that the test results had been deliberately distorted. That scientists cheat in this country is also well established. A survey, conducted by Dr Ian St. James Roberts and published in New Scientist magazine, shows that cheating is fairly current:

"The most frequent kind of cheating is data 'massage' (74 percent of the total) where findings are eased and stretched to fit the desired result." [4]

Independent Experts

As far as can be gathered the scientists, to whose independent expert scrutiny test data relevant to the safety of products is submitted, are chosen by the chemical industry itself. It is unlikely that they would choose scientists who, in the past, have been critical of pesticide usage in this country. One can take it for granted that they will be carefully chosen from among those who can be counted upon to back up the manufacturer's claims.

Secrecy

The ACP and its SSC might well be able to tell the difference between true and false data, though then again they might not. The EPA in the US was taken in for a long time. In any case there is no way of checking the value of the data.

The reason is that all the information provided in connection with the PSPS, is strictly confidential. Commercial interests must be protected at all costs and the costs are considerable. Indeed as the Royal Commission remarked, there is evidence that scientists trying to determine the effects of pesticides on living things can be:

"hindered in their scientific work by this confidentiality being carried to unnecessary lengths." [2]

The Royal Commission itself was refused information by a manufacturer on the effects of pesticides it produced on the grounds that

toxicological data when quoted out of context could easily be used to mislead the public and create unnecessary concern."

This is the sort of argument we have heard from the nuclear industry, the asbestos lobby and all the other principal industrial polluters.

The Royal Commission also informs us that a member of the SSC is also a member of the National Water Council, but as the Royal Commission points out, he is not allowed to discuss the potential risks of chemicals with expert colleagues in the water industry because of

"the confidentiality placed on data submitted by manufacturers to the PSPS." [2]

Objectivity of the APC and SSC is Questionable

Although the members of the ACP can have no commercial interests in the chemical industry this does not assure their objectivity. The objectivity of Dr James Busvine who is currently a member of the ACP is clearly in doubt when one reads the following words from one of his recent articles:

"Sensitive, and perhaps emotional, individuals in temperate climates may call for the abolition of pesticides, but the double need of protecting crops and reducing disease transmission will override their anxieties for most people". [12]

These are not the words of a person likely to apply pressure to control the use of hazardous pesticides in our environment.

The objectivity of Dr J M Barnes, currently a member of the SSC, is clearly also in doubt when he tells us that

"the minute traces measured in parts per million that are sometimes found in food are of no toxicological significance, even in the case of the poorly biodegradable organo-chlorine compounds." [13] He clearly talks the same language as Professor Mellanby who tells us that the levels "cannot be called pollution for they are so low as to cause no detectable effects on living organisms." [14]

Both these statements we know to be totally gratuitous and contrary to all the currently available literature on the sub-lethal effects of pollutants (See "Can we Control Pollution", The Ecologist November-December 1979).

Duration of the Tests

The final decision to authorise the use of a pesticide is given after 'long term' tests, that are carried out over a period of two years. But two years, of course, is hopelessly insufficient. Cancers tend to appear 20-30 years after exposure to a carcinogenic agent, mutations can appear generations after exposure to a mutagen. Relevant information on the long-term effects of a pesticide can only be obtained in such a short period from the results of laboratory tests on animals with a very short lifespan, such as insects or bacteria.

Such information could be of value in predicting likely effects on the human population because the genetic material, whose modification by a chemical agent is the main cause of cancer and infant malformations, is the same throughout the animal world. But the chemical industry has always refused to admit that a chemical shown to be carcinogenic or mutagenic to a laboratory animal can be considered to be so to humans. Unless this is admitted, these very short 'long-term tests' cannot yield any usable information.

Safe Levels?

The control of pesticide use both in the US and in Britain is based on the notion that there is a safe level below which a chemical causes insignificant biological damage. It is becoming increasingly evident that such a threshold doesn't exist. Also vulnerability to specific poisons varies from person to person. Children, even more so foetuses, are very much more vulnerable than adults.

What is more, people are not exposed to a single pesticide but to a vast number of different ones - 800 in this country alone - and these in turn, make up a small proportion of the three million or so chemicals that have been introduced into our environment, very few of which have been tested for their ability to cause cancer and other long term damage.

All these chemicals are likely to affect us differently in different combinations. Apart form their additive effects, synergic effects are likely to be present more often than not. As Dr. Von Rumker, an EPA consultant notes

"surprisingly little information is available on the inter-action between different pesticides and between pesticides and all other elements of the crop."

WHO publishes lists of tolerable levels for several hundred different pesticides in our food. One can be certain that nobody has ever examined the biological effects of eating food containing the acceptable levels of all these different pesticides. Yet it is this knowledge that is relevant, not knowledge about the biological effects of a single pesticide used in isolation from all others.

The scientists from the ACP to whom I talked did not even seem to understand the critical importance of this consideration which makes absolute nonsense of all the figures they publish on this subject. In addition we know little about the impurities that are often associated with specific pesticides, still less about their decay products, and let us not forget that it is the decay products of DDT more than DDT itself that seems to be so damaging to wildlife.

This means that there is simply no scientific way of establishing a level of any specific pesticide that can be regarded as causing negligible biological damage. The acceptable levels published by WHO in fact are fixed largely on economic grounds. They tend to be the minimum ones that can be achieved without compromising economic priorities. This could not be better illustrated than by the following passage from the Report of the Food Additives and Contaminants Committee on Aldrin and Dieldrin Residues in Food:

"We should like to recommend that no aldrin and dieldrin be permitted in milk and baby foods but we are aware that with the great sensitivity of analytical methods it has become possible to detect very low residues of aldrin and dieldrin in food and also that at present it would be impossible to produce milk or baby foods that were entirely free from aldrin and dieldrin. For these reasons we reluctantly decide against a zero tolerance and recommend that a limit of 0.003 ppm. be placed on aldrin and dieldrin in liquid milk, this being the lowest practicable limit of analysis. We recommend a corresponding limit of 0.02 ppm: in baby foods (including dried milk) which would take account of the difference in residues likely to be found in liquid and dried products. We also recommend that all ingredients for baby foods should be chosen by manufacturers with a view to keeping the aldrin and dieldrin content to the lowest possible level. While these limits seem to us realistic, we do not accept them readily or with equanimity. With greater restraint in the use of aldrin and dieldrin, significantly lower statutory limits should be feasible in two years' time." [5]

Statutory Testing

In addition it is important to note that the PSPS - the only body operative today for controlling the safety of pesticide use in this country - is purely Voluntary. There is no law which forces a manufacturer to test the pesticides he proposes to put on the market; no law which forces him to submit them for examination to the ACP and the SSC; no law which obliged him to have them examined for their long term effects on living things.

The Royal Commission pointed out just how anomalous it was that

"at a time when there is concern about the hazards posed by toxic chemicals in the environment and when statutory controls designed to ensure adequate testing of new chemicals have been introduced or are envisaged in most industrial countries, the control of pesticides (in this country) should continue on a non-statutory basis."

It is difficult to see how this argument can be countered. Indeed it seems incredible that no law has been passed to control the use of the thousands of tons of dangerous chemicals that are systematically sprayed on all the food crops in this country, when at least a quarter of them are suspected, on good grounds, of being carcinogenic and mutagenic.

Yet such legislation is feverishly opposed by the ACP and the agro-chemical industry. They assure us that it would be too costly, too time consuming, that it would involve engaging too many new civil servants, and that it would lead to decisions being taken on "political as opposed to scientific considerations". [2]

This matter is soon due for consideration by the Government. The debate on the Royal Commission Report began a short time ago in the House of Lords, but the chances are that the ACP and the agro-chemical industry will prevail and that, in spite of the Royal Commission's recommendations, pesticide use in this country will remain in effect uncontrolled by law.

But even that would be grossly insufficient. It would just bring us into line with the USA, and as we have seen, pollution control in that country is not much more successful than it is here. Contrary to the Royal Commission's recommendations, it is the standards themselves that must be improved, not just the way they are implemented. Also very severe punishments - not just fines but prison sentences - must be imposed on those who violate the law and in particular on those who subvert it.

What is more, standards must be set increasingly high as the use of these dangerous poisons is slowly phased out and safer and more effective methods are gradually introduced to control potential pest populations.

References