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”. 
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:
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“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.” 
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.Back to top
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.” 
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
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“the confidentiality placed on data submitted by manufacturers to the PSPS.” 
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”. 
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.”  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.” 
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).Back to top
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.Back to top
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:
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“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.” 
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”. 
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.Back to top
|1.||Ian Nisbet, Technology Review, August/September 1978.|
|2.||7th Report of Royal Commission on Environmental Pollution, HMSO, September 1979.|
|3.||Lappe and Collins, Food First. Penguin Books, London 1976.|
|4.||Industry’s Statistics, British Agrochemicals Association. London 1976.|
|5.||Report on Aldrin and Dieldrin in Food, HMSO 1967.|
|6.||The Non-Agricultural Use of Pesticides, Pollution Paper No 3, HMSO 1979.|
|7.||“Pesticides, the Environment and the Balance of Nature” in D L Gunn and J G R Stevens, Pesticides and Human Welfare, OUP 1976.|
|8.||Review of the Persistent Organochlorine Pesticides, HMSO 1964.|
|9.||Dr O. Schuhmann, in D. L. Gunn and J. G. R. Stevens, op.cit.|
|10.||Richard Doutt, “Debugging the Pesticide Law”. Environment, December 1979.|
|11.||New Scientist, 25/11/1976.|
|12.||Dr J. Busvine, “The Control of Trypanosomiasis”. In F. H. Perring and Kenneth Mellanby, Ecological Effects of Pesticides. Academic Press, 1977.|
|13.||J. M. Barnes, in Gunn and Stevens, op.cit.|
|14.||Mellanby, in Perring and Mellanby, op.cit.|
|15.||Jerome Goldstein, The Least is Best Pesticide Strategy. The J. F. Press, Emmaus, Pennsylvania, 1978.|