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BRAME & Food Standards Agency


Firstly we would like to thank you once again for allowing us to attend the open meeting held on 28 February 2002 at Dunstan Hall in Norfolk. We found the meeting to be very informative and also very encouraging that at last those who have raised concerns over the exposure and toxicity to various chemicals are being heard. We ourselves represent those suffering from ME/CFS, many of whom locate the source of their illness as due to the exposure and effect of pesticides, and many sufferers have developed multiple chemical sensitivities (MCS).

ME is an illness, especially for the severely affected, that affects the immune, neurological and endocrine systems, and for many the cardio-vascular system. The Chief Medical Officer’s (CMO) Report on ME/CFS (Jan 02), of which Tanya was a member of the key group, estimated almost ¼ million sufferers of ME in the UK.

We certainly welcome this action plan on risk assessment, and are very encouraged by the proposals outlined. We would however like to reiterate the particular concerns that we previously outlined to WiGRAMP in our response to the initial draft report, as we feel the following points are still valid, and urgently need to be considered, having read the draft action plan. Whilst we are representing those living with ME, these points are probably equally valid for other vulnerable groups, ie: those with long term chronic illness; cancer patients; the elderly; pregnant mothers and babies/young children.


  1. With ME the immune system has become compromised, and therefore continued exposure to pesticides and its residues, along with veterinary residues can be harmful.

  2. The toxicological effect of these substances on the genetic make-up and on the endocrine system.

  3. The cumulative effect of exposure to the same chemical, or those of a similar structure/toxic action.

  4. The effect of being exposed to multiple sources of pesticides and residues, even if individually felt to be within safe limits, the cumulative and ‘cocktail effect’ of such exposures, and their potential interaction, and not just for healthy individuals but also for the sick and vulnerable, whose body systems may already be compromised.

  5. The need to also investigate not only the exposure to such chemicals through the food chain in the consumption of food, but also through investigating the quality of air and water, and again the monitoring of the toxicology of multiple exposure and the cumulative and interactive effect of exposure through these various mediums in our daily lives.

  6. More thorough monitoring and investigations into single and multiple exposures and their possible effects and the need to set-up a public friendly database to give regular and up-to-date information.

  7. Reappraisal to possibly reduce Maximum Residue Levels and Acceptable Daily Intake and to assess the cumulative effects of such levels

  8. The need for a paper to be researched and written to present to the Department of Works and Pensions to inform and advise them of the effect exposure to eg pesticides can have on the body leaving some unable to care for themselves, let alone return to work, as many still have problems when trying to claim benefits.

  9. More support from the Government for farmers to produce more organic and consumer friendly products.

  10. More rigid guidelines and information for all those exposed to any of these pesticides, from seed suppliers, transport personnel, farmers and farm workers, to production line. Often these personnel are unaware of the treatments on these products and are unknowingly exposed.

  11. Greater awareness and information for all those who come in contact with, or use such chemicals, to have appropriate knowledge and training, and that full protective clothing, masks and goggles be provided. (We appreciate health and safety probably already recommend this, but we know from those affected by exposure, that this is not always the case).

  12. More thorough checking and testing of organic products to ensure that the supposedly ‘organic’ products – from the seeds to final products – have not been treated with chemicals.

  13. The 120 pesticides tested for in the UK, but about 800 in use in Europe, which still find their way into the UK on seeds to the final product – it is urgent that there are tighter regulations on this and more transparency on what products have been used during the various stages – not only for the consumer but for others who may have to handle the product and are again unknowingly exposed.

  14. There should be complete transparency and logged information on what treatments have been used on a product from the treatment of seeds, growth period, harvesting, transport to the final preparation of the product for the consumer. This should be available to the public.

Having outlined our overall concerns we would like to highlight particular statements in the action plan.


  • Covering letter – p1 and Action Plan Introduction p3 – no.2 – health hazard from exposure to mixtures – likely to be small – effects unlikely to be more than additive. We feel the concerns we have outlined in points 1 – 7 are valid.

  • Covering letter p2 – para 3We are pleased to read that the responsibility for the national legislation for the regulation of pesticides, veterinary medicines and biocides in the UK has not been devolved, although the UK is bound by EC regulatory frameworks. The UK also respects recommendations of the Codex Alimentarius Commission (CAC) in matters affecting international trade (unless there is some compelling scientific reasons not to do so). We feel the points we have highlighted are all valid here, but particularly 10 –14.

  • Action Plan – p3 - no.4 - In relation to the previous point, and that the UK cannot act unilaterally, but through the EC, and that standards of imported foods must be as rigorous as home-produced. We therefore fully support Stage 1 and 2 of the COT recommendations.

  • Stage 1 - to carry out necessary underpinning work highlighted by the COT recommendations and Stage 2 – to argue vigorously in the relevant bodies eg EC and CAC, for changes to EC legislation and international standards. We feel that these are essential for any real improvement in standards.

  • P3 – no.5 (I) – assess combined exposure for the highest priority groups. Whilst highest priority groups probably means those directly working with pesticides and similar substances we feel it should also include the risk assessment for the more vulnerable groups in society which may also be exposed directly or indirectly.

  • p3/4 – no.5 - We welcome all recommendations here, especially 5(v) funded by ILGRA to evaluate the suitability of current exposure methodology for use in combined risk assessment, and is the first step to developing a methodology for estimating the aggregate exposure for various population groups. Once again we hope that this will include the more vulnerable groups in society which may also be exposed directly or indirectly.

  • International Action p4 – no.6We are extremely concerned to read that the US Environmental Protection Agency (EPA) have recently published a combined risk assessment on organophosphates (OPs) for public comment, the results of which do not appear to indicate concerns or trigger any need for immediate regulatory action. There are many people in the UK who strongly feel that their often long-term illness and disability has been due to exposure to OPs. This is something which our patron the Countess of Mar has been highlighting within the House of Lords for some years now. We sincerely hope that the Advisory Committee on Pesticides (ACP) will also contact people who feel they have been damaged by OPs when carrying out the combined risk assessment on OP and carbarnate cholinesterase-inhibiting agricultural and non-agricultural pesticides in the UK. We are pleased that this work will be fed into recommendations 11.2 and 11.3.

  • International Action p4 – no.7 - We are delighted to read that the EC in a strategy report on pesticides has recommended further research and development into potential synergistic and antagonistic combinations of active substances and that focussing on single pollutants will lead to underestimation of health impacts because people are exposed to a combination of pollutants and that assessments will be rendered more efficient by taking into account cocktail effects, combined exposure and cumulative effects. We are pleased that the UK will take all opportunities to argue that combination effects must be taken into account in the future.

  • International Action p5 – no.8 - In this global society that we now live in we are pleased to see that products from third world countries will also be included in this research programme. Consumers would also like more information on product labelling including true country of origin as well as where the meat or other products have been processed, so that they are more aware of the choice they are making when purchasing products – this is even more important for the more vulnerable groups in society whose body systems may be weak or already compromised, and are therefore possibly more susceptible to any residues or additives that may be present

  • Reporting Back – p5 – no.9We would be pleased to receive any further reports which will be produced, or attend any further consultative meetings.

  • Conclusions p5 – no.10as already stated at the beginning of our feedback on the draft action plan, we are concerned that the effect of these substances is only thought to be small, and once again highlight our points of concern, particularly 1 – 7, and recommend that you do include these more vulnerable groups, and their direct or indirect exposure to these substances, in your research and assessments.



On reading the table of action to be taken to implement Stage 1 (S1) and Stage 2 (S2) of the recommendations overall we are pleased with the research and investigations to take place, the speed with which these programmes have been implemented, and the time-scale for them to give interim feedback and final reports. We sincerely hope that the research will look at the wider issue, and appreciate not only the effect on those directly involved with these substances, but also on the wider consumer group, and also take into consideration the effects these may have, whether cumulatively or synergistically, on those more vulnerable groups, whose body systems may be more sensitive or compromised.

  • S1 – 11.2, 11.3We are pleased to see this will include pesticides that give rise to residues in imported produce. Will the document to show a regulatory system based on assessment of mixtures from this research (mid 2004) be put in the public domain, as well as being presented to the EC and other regulatory bodies?

  • S1 – 11.4 – Pesticides and veterinary medicines - It is good that you recommend looking at combined toxic action or interaction due to addition of other substances, and to then consider the risk from the product not just the active substance. We are concerned over the comment on tank mixes being relevant to people exposed at the time of application, but not to residues in food as they do not differ from those arising from sequential applications.

  • S1 – 11.5We welcome the recommendation to analyse all sources of exposure and concurrent exposure to more than one pesticide, acknowledging change of methods used for risk exposure and probabilistic exposure assessment. To extend sources of exposure and combined risk assessment.

  • Surveillance – 11.6 - With dietary and food consumption surveys including social, age and ethnic groups – could we also suggest that in future surveillance projects some consideration is also given to possible effects on those who are long-term and chronically sick.

  • S1 – 11.8 and 11.9We welcome these recommendations for further investigation and actions for:- the aggregate exposure assessment; sources and all pathways of exposure to pesticides and veterinary medicine; probabilistic exposure assessment; residue surveillance programmes; and the nature of processing and preparation on the bioavailability and chemical nature of residues. For data on food and non-food sources of exposure to be collected from UK produced and imported products, and to identify where more data must be generated.

  • S1 – Research 11.9 to 11.12We particularly welcome this whole section and the fact that it is going to be a 5 year programme of study, which will hopefully give it the opportunity for the in-depth research and collection of data, including the human reactions to possible exposure, which is needed. If strong evidence is discovered from this research earlier than the 5 year programme report will these then be presented at the time and appropriate caution and guidance be implemented?

  • S1 – 11.9, 11.10We welcome the recommendation and action to develop effective biomarkers to show population exposure and body burdens of mixtures of pesticides and relevant veterinary residues and to develop markers to enable early and reliable detection of systemic responses and health effects arising from such exposures.

  • S1 – 11.11 - May we strongly recommend that in 11.11 that apart from children, the elderly and those with genetic susceptibility that another group be added, and that is those with long-term and chronic ill health, for as their systems may already be sensitive or compromised they may be more susceptible to exposure to these substances, either directly or indirectly.

  • S1 – 11.12The comments in 11.11 are also true for 11.12 when investigating additivity, independent and synergistic effects for combined actions of pesticides, veterinary medicines and similar substances. This research is of particular interest to patients with ME, especially those severely affected, where ME has become a multi-system, multi-organ illness. There are now many bio-markers which support the involvement of the immune, neurological, endocrine and cardio-vascular systems, and dysfunction has been found at a cellular level. The CFS Research Foundation is also showing changes in gene expression, and other research has shown that enzyme and hormonal activity have also been shown to be compromised. Some with ME feel their illness was triggered by exposure to OP or other chemicals, and/or ME patients have, since being ill, found themselves more sensitive to chemicals, developed allergies and food intolerances. ( Some of these points may also be relevant to those who suffer from other long-term chronic illnesses)

  • Stage 2 – Change to approval system such that pesticide and veterinary medicine authorisation considers mixtures from all sources of exposure. We support all the various groups which will be lobbying the regulatory bodies in the EC and CAC for international support to these changes and the concern over multiple exposures.

  • 11.13, 11.14We welcome the setting up of a central and accessible repository of information about all forms of human exposure to pesticides and similar substances – including the data collected under 11.8. Also under 11.14 the review of information for the domestic user on pesticides and veterinary medicines.


Coming from a farming community we are fully aware of the enormous pressure and financial burden already on farmers. We believe in the UK we have some of the best husbandry, farming quality and methods in the world, but with more support from the Government, and less cheap imports of more unknown origins, we should be trying to achieve a greater balance of quality food, whilst also maintaining an organic, or as near organically friendly environment as possible in future years. This would go a long way to reducing the quantity of residues to be found in the food, water and air.

In parallel to such measures in farming, whilst we appreciate laws are in force, factories, water and sewage companies would also have to be more tightly monitored for their own waste management and for air and water pollution.

We feel the draft action plan is extremely encouraging and for the first time the real concerns of consumers are being heard and identified. We have felt for some time that there is an urgent need to look at multiple exposure to these chemicals, and the cumulative and synergistic effect of such exposures on the systems and biology of the human body.

In conclusion we do welcome this draft action plan and look forward to receiving further drafts reports if possible, and copies of the final published reports when they are released. We would also be most interested in attending any further open meetings in the future regarding similar issues.

Thank you for inviting us to be part of this consultative group and we have enclosed our leaflets on BRAME and ME for your information and records.

Yours sincerely



Secretary and Chairperson BRAME

24 October 2003

To view the final report, please visit the FSA website.



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