PAN UK - Pesticide News - Issue 94

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The journal of Pesticide Action Network UK An international perspective on the health and environmental effects of pesticides Biannual

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Pesticides News No 94 Editorial 2 European regulation

Locust Control

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12 Building community capacity for

UK’s disappointing National Action Plan is a missed opportunity

Ethiopia’s locust control

16 Biocide Regulation to come into force in

14 PAN International issues declaration on

Corporate influence

Latin American news

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2013

2012 Olympics tarnished by Dow sponsorship

Poisonings 6

OPs in sheep dip in the UK – the human legacy

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Paraquat – 50 years of human rights violations

UK news 7

UK government ignores call to review bee-toxic pesticides

Sustainable production

sustainable locust control

Brazil’s Public Health Agency suggests consumers switch to organic to avoid pesticides

16 Wetland birds poisoned by endosulfan and chlorpyrifos in Argentina

Factsheets 17 Bee declines and the link with pesticides – PAN UK calls for action

Book reviews 19 Earth-friendly gardening 19 Environmentalism since Silent Spring

10 MADE-BY: Fashioning sustainable pesticide-free clothing

Pesticide Action Network UK Development House 56-64 Leonard Street London EC2A 4LT, UK Tel +44 (0)20 7065 0905 Fax +44 (0)20 7065 0907 Email admin@pan-uk.org

www.pan-uk.org www.pan-international.org links to all PAN Regional Centres

Oilseed rape is one of the largest users of neonicotinoid seed treatments in the UK

Photo: Graham White

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Editorial

Pesticides News 94

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We were sadly forced to suspend publication of Pesticides News for a few issues in 2012. I would like to apologise to subscribers for this and reassure you that normal service has now resumed - albeit at slightly lower frequency: Moving forward, we will be publishing two issues per year.Your account has automatically been credited for the issues we owe you. In the meantime you can keep abreast of PAN UK's work at www.pan-uk.org, twitter.com/PAN_UK and www.facebook.com/PesticideActionNetworkUK.

Who’s who at Pesticide Action Network UK

As we enter 2013, the declining population of bees and other pollinators and the continued failure by the UK government to take seriously the role of neonicotinoids in this decline continues to top PAN’s agenda. Despite growing pressure from various quarters, including an open letter from the The Co-op, DEFRA has refused to commission an independent review of the science underpinning the risk assessment for neonicotinoid pesticides in the UK. PAN UK has produced a new set of fact sheets to cut through the confusion and provide an up-to date and balanced explanation of the role of pesticides in pollinator declines. We are also calling on the UK government and other stakeholders to commit to a 12 point action plan on bee toxic pesticides.

Dr Stephanie Williamson Staff Scientist

For many people the London 2012 Olympics were a resounding success.

However, its sponsorship by the Dow Chemical Company while victims of the Bhopal disaster still wait for justice, has brought shame on the Olympic movement. Colin Toogood of the Bhopal Medical Appeal tells us why.

Paraquat is the one of the deadliest pesticides on the market, estimated to be responsible for tens of thousands of poisoning deaths world-wide every year.

We have a report on why this situation persists, the latest possible regulatory developments, and the attempts to hold market leader Syngenta to account.

Locusts invasions are a major threat to agriculture in many parts of Africa.

Here we report on a new programme by PAN Ethiopia to increase awareness and promote involvement among local communities in tackling the problem.

A second article puts forward recommendations from PAN International on sustainable locust control.

We report on the UK government consultation on its National Action Plan on the Sustainable Use of Pesticides and on a new EU Regulation on biocidal products. In both cases real opportunities for improvement have been missed.

In a more positive development, the Brazilian National Agency for Public Health Surveillance has recommended consumers only eat food grown organically or using Integrated Pest Management. This follows a report showing both levels of pesticide residue in excess of permitted limits, and the use of illegal pesticides, in 18 different foodstuffs.

Online subscription Subscribers can now benefit from an online searchable version of Pesticides News (September 1993 to the current issue) with the following username and password (changed twice a year): Username: subscriber Password: carbaryl

We also bring you the lowdown on MADE-BY, a not-for-profit organisation aiming to make sustainable pesticide-free fashion common practice and to improve environmental and social conditions in the fashion industry.

Dr Keith Tyrell Director Nick Mole Policy Officer

Geremew Tereda Accounts Paul Lievens Communications Manager

Articles published in Pesticides News promote health, safety, environmental commitment and alternatives to pesticides as well as debate. The authors’ views are not necessarily those of the Pesticide Action Network UK. Initials at the end of articles refer to staff contributions to Pesticides News.

Abbreviations and acronyms used ACP Advisory Committee on Pesticides CRA Comparative Risk Assessment EA Environment Agency (UK) EC European Commission EPA Environmental Protection Agency (US) EU European Union FAO Food and Agriculture Organisation of the United Nations FFS Farmer Field School FSA Food Standards Agency HSE Health and Safety Executive ILO International Labour Organisation IPM Integrated pest management LD50 lethal dose for 50% of population µg/kg parts per billion MRLs Maximum Residue Limits mg/l parts per million NGO Non government organisation OECD Organisation of Economic Cooperation and Development OP Organophosphate (pesticide) PAN Pesticide Action Network PIC Prior Informed Consent PN Pesticides News UNEP United Nations Environment Programme

© Pesticide Action Network UK Please credit Pesticide Action Network UK when quoting articles ISSN 0967-6597 Printed on recycled paper

Pesticide Action Network – Regional Centres AFRICA PAN Africa BP 15938, Dakar-FANN Senegal Tel: (221) 33 825 4914 Fax: (221) 33 825 1443 panafrica@pan-afrique.org www.pan-afrique.org

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ASIA/PACIFIC PAN Asia and the Pacific PO Box 1170 10850 Penang, Malaysia Tel: (60-4) 657 0271 Fax: (60-4) 658 3960 panap@panap.net www.panap.net

EUROPE PAN Europe is facilitated

by PAN UK and PAN Germany www.pan-europe.info elliott@pan-europe.info PAN Germany Nernstweg 32 22765 Hamburg, Germany Tel: (49-40) 399 191022 Fax: (49-40) 390 7520 info@pan-germany.org www.pan-germany.org www.pan-international.org links to all PAN Regional Centres

LATIN AMERICA RAPAL (PAN Latin America) Coordinadora Regional Av. Providencia No365, depto. No41 Providencia, Santiago de Chile Tel/Fax: (56-2) 341 6742 rapal@rapal.cl www.rap-al.org NORTH AMERICA PAN North America 49 Powell St., 5th Floor San Francisco, CA 94102, US Tel: (1-415) 981 1771 Fax: (1-415) 981 1991 panna@panna.org www.panna.org

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European regulation

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UK’s disappointing National Action Plan is a missed opportunity for progress The UK Government’s second round of consultation on the Sustainable Use Directive represents a missed opportunity to introduce progressive policies and approaches that could have ushered in a more sustainable and safer approach to pesticide use, says PAN UK’s Policy Officer Nick Mole.

The UK Government has launched a second public consultation on the implementation of new EU pesticide legislation in the UK. The consultation, led by the Department for Environment Food and Rural Affairs (Defra) (the UK government department responsible for implementing the SUD) presents the draft UK National Action Plan on the Sustainable Use of Pesticides (NAP)1. The creation of a NAP is a key requirement under Article 4 of the EU Directive on the Sustainable Use of Pesticides (SUD) and each Member State (MS) in the EU is required to submit their completed NAP to the European Commission by November 2012.

Each NAP must outline the measures, existing or planned, the MS intends to take in order to implement the various Articles of the SUD and achieve the overall goal, enshrined in the SUD, of ‘reducing the risks and impacts of pesticide use on human health and the environment and to encourage the development and introduction of integrated pest management and of alternative approaches and techniques in order to reduce dependency on the use of pesticides.’ These targets can cover a range of areas such as worker protection, development of Integrated Pest Management (IPM), protection for the environment, and protection for rural residents.

In the preamble to the consultation document Defra states that the draft NAP has been developed following consultation with stakeholders, including the public as required by the Directive. Whilst this is technically correct in that there have been a number of stakeholder meetings and an earlier public consultation by the previous Labour government, it is also clear that very few of the recommendations supported by the public or put forward by a range of organisations, including PAN UK, have been included in the draft NAP. It looks like business as usual.

It seems that the NAP, and broader

implementation of the SUD, has fallen victim to the government’s drive to cut red tape and reduce regulatory burdens on business. The consultation shuns new regulatory measures and opts instead for voluntary measures and industry self regulation. This is an approach that is doomed to fail and will result in minimal reductions in pesticide use. There are no incentives whatsoever for industry, particularly those parts that have a less than perfect approach to adopting best practice or minimising pesticide dependency, to work towards the stated goals of the Directive.

And while the NAP is full of admirable objectives such as ‘Helping to enhance the environment and biodiversity to improve quality of life’, there are no measures in it that are likely to deliver these outcomes.

So what is missing from the draft NAP? If we take the two key targets for protection under the Directive, human health and the environment, we can see that the NAP falls a long way short of its goals.

Human health There are ● no plans to phase out or specifically target a reduction in the use of pesticides that are classified as being highly hazardous to human health ● no plan to ban the use of pesticides in places such as parks, playgrounds and hospitals frequented by groups that are deemed as most vulnerable to the effects of pesticides ● no mandatory requirement to inform residents prior to spraying taking place either in rural or urban setting ● no mandatory requirement that the public would have access to spray records

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no plans included that would phase out or implement use reduction targets for those pesticides that are toxic to bees and or other pollinator species ● no targets to phase out or ban the use of pesticides in conservation areas Another huge disappointment is the almost complete absence of any support for the development of a really robust system of Integrated Pest Management (IPM). This is one of the key areas of the Directive as a whole and would, if really promoted, help to significantly decrease the amount of pesticides being used in both the agricultural and the amenity sectors. The text of the Directive states that Member States should ‘take all necessary measures to promote low pesticide input pest management, giving wherever possible priority to non chemical methods’.

PAN UK has been calling for the inclusion of a progressive IPM regime in the UK that replaces the current ‘pesticides first’ approach with one that prioritises non-chemical pest control approaches and puts pesticides last. This should be bolstered by outreach and support as well as properly funded research into non chemical pest and disease control techniques that would assist farmers and others to experiment without risking their livelihoods. Sadly this has not been included in the NAP. Overall the draft that has been presented for consultation is very disappointing and is not in the spirit of the Directive.

Defra has missed a unique opportunity to introduce progressive policies and approaches that could have ushered in a more sustainable and safer approach to pesticides. While disappointing, it is not particularly surprising given the power of the agrochemical lobby and the cosy relationships that exist between government and vested interests concerned more with maintaining the status quo than introducing measures that protect the public and our environment from the harmful effects of pesticides.

The only silver lining is that the Directive makes it clear that the NAP is to be a living document so measures can be introduced as and when required. PAN UK hopes that perhaps the new Minister in Defra, the Rt. Hon Owen Paterson, might consider listening to the concerns of the public and others rather than the voices of the industry and include some measures that will deliver meaningful change.

PAN UK and others will be pushing for such measures and if you would like to add your voice to the consultation you can do so at: www.defra.gov.uk/consult (NM). ●

1. http://www.pesticides.gov.uk/guidance/ industries/pesticides/News/Collected-Updates/ Information-Updates-2012/July/Consultationn-UKNational-Action-Plan-for-pesticides

Environment The NAP also falls short of environmental goals. There are

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Corporate influence

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2012 Olympics tarnished by Dow sponsorship Colin Toogood of the Bhopal Medical Appeal explains why Dow sponsorship of the 2012 London Olympics undermines the concept of a sustainable Olympics.

The 2012 Olympics held in London were a resounding success. From filmmaker Danny Boyle’s opening ceremony, on through to the Paralympics, the organisers have basked in worldwide acclaim for a great Olympic Games. But for all of the sporting success, the Games were tarnished by the inclusion of the Dow Chemical Company (Dow) as one of the main sponsors. The acceptance of money from this company, while victims of the Bhopal disaster still wait for justice, has brought shame on the Olympic movement.

‘Olympism is a philosophy of life, exalting and combining in a balanced whole the qualities of body, will and mind. Blending sport with culture and education, Olympism seeks to create a way of life based on the joy of effort, the educational value of good example, social responsibility and respect for universal fundamental ethical principles.’

Thus reads the very first paragraph of the ‘Fundamental Principles of Olympism’ as enshrined in the charter of the International Olympic Committee (IOC).

Funny then that, amongst other questionable corporate sponsors, the IOC should have

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chosen to get in bed, for a decade-long sponsorship deal, with Dow. But how does Dow differ from some of the other questionable corporations associated with the Olympics? How, for instance, does Dow stand apart from, say, Coca-Cola or McDonalds when both of these companies have long-term Olympic sponsorship deals but could hardly be held up as paragons of healthy eating or corporate virtue? Or, perhaps more pertinently, how does Dow differ from British Petroleum - a ‘Sustainability Partner for London 2012’ and the ‘Official Oil and Gas Partner for the London 2012 Olympics’- after the 2010 Deepwater Horizon Disaster, in the Gulf of Mexico. Well, the answer lies, of course, with the Bhopal Gas Tragedy and with the terrible toxic aftermath of the Union Carbide Corporation’s (UCC) activities in this city stricken with multiple disasters.

Dow has been, for well over a decade, fully merged with Union Carbide but refuses to accept any of UCC’s liabilities in Bhopal.

On the night of 2–3 December 1984 methyl isocyanate and other gases leaked from the Union Carbide India Limited pesti-

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cide plant in Bhopal, India. The gas leaked into the city of Bhopal causing an immediate death toll of an estimated 8 - 10,000 people. Further deaths occurred in the following weeks and months and, to date, it is estimated that half a million people were exposed to the gas. Around 25,000 have died as a result of exposure to the gas and 120,000 people still suffer from ailments caused by the accident and the subsequent pollution at the plant site.

The site has never been properly cleaned up and it continues to poison the residents of Bhopal. In 1999, local groundwater and well water testing near the site of the accident revealed mercury at levels between 20,000 and 6 million times those expected. Cancer, brain-damage and birth defect causing chemicals were found in the water; trichloroethene, a chemical that has been shown to impair foetal development, was found at levels 50 times higher than the US Environment Protection Agency safe limits.

Dow acquired Union Carbide Corporation (which always retained the controlling interest in Union Carbide India) in 2001 after a civil settlement for the Bhopal tragedy had been reached with the Indian Government. This paltry settlement, of $470m dollars, was reached in 1989 and Dow continues to insist, throughout the media, that this it is a ‘full and final settlement’ and the London Organising Committee of the Olympic and Paralympic Games (LOCOG) shamefully refused to accept that this may not be the full story.

So, what are the facts? To begin with, Union Carbide Corporation (UCC) themselves agreed to the Indian courts as the correct forum to hear the Bhopal case and, in 1991, the courts decided that criminal charges must be re-instated against their exCEO, Warren Anderson, and the entire Union Carbide Corporation. These charges

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Corporate influence are hardly trifling, being of ‘culpable homicide not amounting to murder’, and Dow was clearly aware of them at the point of takeover. Dow has total control of UCC but it has not produced UCC in court - and this already seems astonishing enough a fact to preclude Dow from any involvement with the Olympics. But, worse still, Dow has actually used another wholly owned subsidiary, Dow Chemical India Private Limited, to obstruct a January 6, 2005 judicial summons, addressed to its Michigan headquarters, requesting Dow explain its non-production in court of UCC. For over ten years, therefore, Dow has been guilty of ‘harboring a fugitive from justice’, or ‘aiding and abetting an absconder’ and our fundamental spirit of Olympism seems now to have raced away with the speed of a hundred metres sprinter.

But this is far from the end of the story.

The Dow Chemical Company itself is a named respondent in a forthcoming ‘curative petition’ in India’s Supreme Court that aims to address inadequacies within the 1989 civil settlement. Hearings on the petition were granted on February 28, 2011 by a five-judge bench, including India’s Chief Justice. The Indian government (GOI) is seeking an additional amount (upper limit) of $1.24 billion. But Bhopal survivors are quoting the GOI’s own published figures and demanding that the sum should reflect those numbers. These figures, a more realistic tally of the dead and severely ill, would raise the compensation figure to $8.1 billion. Dow, despite denying any liability for the abandoned Union Carbide factory, is also the named respondent in public interest litigation in the Madhya Pradesh High Court (2004) seeking remediation of the site, and continues to resist the 2006 request for a £16 million deposit towards initial costs.

So by any reasonable reckoning it would seem that Dow did not exactly live up to the Olympic ideals and the Bhopal Medical Appeal made every effort to explain these issues to LOCOG. We received in return little more than the PR bluster that has been spun by Dow for many years - chiefly that the matter is ‘closed’!

But, even if the Bhopal case were closed, there would still be numerous other examples of Dow’s ‘questionable’ ethical performance that are clearly not a thing of the past and cannot possibly accord to the ideals of Olympism. For instance, Dow has recently been found guilty of serious business malpractice in relation to the registration of pesticides. In 2007 the New York Securities and Exchange Commission issued Dow a cease and desist order and a $325,000 fine for ‘improper payments’ relating to the registration of four pesticides in India. In September 2011, Dow AgroSciences India Pvt Ltd (another wholly-owned subsidiary) was consequently blacklisted by the Indian Agriculture Ministry, for five years. At least one of the pesticides improperly registered was the notorious ‘Dursban’. These issues run concurrently with the time that Dow would have

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Brazil’s Public Health Agency suggests consumers switch to organic to avoid pesticides ANVISA warns of cancer risk from residues in fruit and veg as testing uncovers widespread exceedences and use of illegal pesticides Peppers, strawberries and cucumber are the food items found to contain the highest proportion of pesticide residues, in a study published by the Brazilian National Agency for Public Health Surveillance (ANVISA).

‘These are worrying data’ stated ANVISA director, Mr José Agenor Alvares da Silva, ‘if one considers the daily intake of pesticides can contribute to the development of chronic disease such as endocrine disruption or cancer’.

The report presents results from the food residues analysis programme of ANVISA of data collected throughout 2010. Started in 2002, the national residue monitoring programme covers 18 different fruits and vegetables, collecting samples from food retail outlets across the country’s 25 states. Foodstuffs for analysis are selected not only in relation to their importance in the Brazilian household diet but also the pesticide use patterns for each crop.

Residue analysis is carried out in public sector laboratories using cutting edge methods capable of running multi-residue screening for 167 different pesticides, similar to analytical procedures used in Europe.

The 2010 data revealed residue levels above Brazilian maximum permitted levels and/or use of illegal pesticides in over 90% of pepper samples. The respective figures for strawberries and cucumber were 63% and 58%. The occurrence of residues of non-authorised pesticides was more frequent than that of permitted levels exceed-

ed. Other fresh produce in which over 20% of samples contained non-authorised pesticides included lettuce, beetroot, carrots, cabbage and pawpaw. Overall, 28% of fresh produce sampled contained non-compliant residues. The disturbing results generated significant interest in the national media and showed, yet again, that so-called ‘Good Agricultural Practice’ (GAP) remains a long way off in Brazil. ANVISA warned that the results are proof that pesticides are being used without adherence to label instructions or product authorisations with respect to application frequency, volume of active ingredient per hectare or stipulated pre-harvest interval (last permitted application).

The ANVISA report concluded with recommendations to Brazilian consumers to eat organic food and to choose seasonal fresh produce or produce grown under Integrated Pest Management (IPM) methods, which receives less pesticide use. The Agency also explained that washing vegetables and peeling or removing the outer leaves makes little difference and only reduces residues present on the skin. The ANVIDA Director stated that supermarkets can play a fundamental role in tackling the residue problem, by supporting and purchasing produce from growers who use GAP in food production.

been agreeing their deals with the International Olympic Committee (IOC) and with LOCOG. The Bhopal Medical Appeal wrote to LOCOG and asked some very specific questions: ● did Dow inform LOCOG of the ‘improper payments’ case, pertaining to the sale of dangerous pesticides, as a part of their briefing prior to the procurement process? If so, how was this reconciled with LOCOG’s own sustainable sourcing code? ● was LOCOG aware that Dow was the named respondent in the forthcoming ‘curative petition’? If so, how was this reconciled with LOCOG’s own sustainable sourcing code? ● was LOCOG aware that Dow was summoned by the Bhopal criminal court on 6 January 2005 to explain why it should not be asked to produce its fully owned subsidiary in court and was LOCOG aware that Dow never submitted the requested explanation?

what steps did LOCOG take, as a part of the due diligence process, to verify the information supplied by Dow? ● has LOCOG made any attempt to meet with any concerned civil society groups since concerns were first raised about the deal with Dow? If so, why was the Bhopal Medical Appeal not included? ● LOCOG never replied to this set of questions and Lord Coe never arranged, as promised, a meeting with the Bhopal Medical Appeal.

The Games have now moved on from London but Dow remains as a top line sponsor of the IOC. Is Dow really setting a ‘good example, (of) social responsibility and respect for universal fundamental ethical principles?’ The IOC may have some explaining to do.

Source: Adapted from Toxic Peppers: ANVISA warns of cancer risk from eating food contaminated with hazardous pesticides (in Spanish), RAPAL (PAN Latin America) Enlace journal no. 95, March 2012 pp. 15-16. Via: http://www.rapal.org/index.php?seccion=3&f=edicion.php&id_pub licacion=5&id_edicion=209 ●

Colin Toogood is Campaigns Manager at the Bhopal Medical Appeal, colintoogood@bhopal.org

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Poisonings

Pesticides News 94

OP sheep dip in the UK – the human legacy Over the years, the health of many UK sheep farmers and their families has been affected by organophosphate sheep dips. Liz Sigmund from the Organophosphate Information Network tells their story.

In 1976 the government passed the Sheep Scab Order, requiring farmers, in law, to treat their sheep in a ‘prescribed dip’. All but one of these dips contained organophosphates (OPs, which are from the same chemical family as neurotoxic chemical weapons).

Successive governments have avoided giving doctors and farmers the full facts about the medical effects of exposure to these chemicals, despite the fact that in 1951 the Zuckerman Committee, reporting to the Agricultural Committee on Toxic Chemicals in Agriculture, said of OPs that the main problems were their extreme toxicity and their chronic effects. It laid down recommendations for training of doctors and ‘regular weekly health monitoring of OP-exposed workers’. It said that doctors should be trained to recognise the symptoms of OP toxicity and be warned to look out for such symptoms if dipping was to take place in the locality. They also recommended that the labels of OP containers should be required to show the words ‘Deadly Poison’ in large clear type.

None of these recommendations have ever been implemented, despite the publication in the early 1950s of a UK government leaflet on how to apply for Industrial Injury Benefit. It listed under reasons for applying for this benefit, ‘Poisoning by phosphorus or an inorganic compound of phosphorus, or poisoning due to the cholinesterase or pseudo-anti-cholinesterase action of organic phosphorus compounds’. It lists the types of employment in which you may be exposed as: ‘The use of, or handling of or exposure to the fumes, dust or vapour of phosphorus, or a compound of phosphorus, or a substance containing phosphorus. For instance, pest control and agricultural workers’. However, only employees are entitled to apply for such benefits. Self-employed workers or farmers are not eligible.

In 1992 the Organophosphate Information Network (OPIN) was formed, with financial support from the Joseph Rowntree Charitable Trust. It had support and professional advice from scientists, doctors, politicians and journalists, and received

A potted history of organophosphates

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Organophosphates (OPs) are pesticides that poison the nervous system. They inactivate a key enzyme, acetylcholinesterase, essential for proper nerve function. They were brought in to replace the older organochlorine (OC) pesticides such as DDT which were more persistent in the environment. However, OPs are far more acutely toxic putting regular users at greater risk of developing the symptoms associated with OP poisoning.

OPs can be absorbed into the body by all routes including inhalation and through the skin, and so it is not surprising that people using them on a regular basis can develop both chronic and acute symptoms of poisoning. Some of the effects that have been associated with exposure to OPs include impaired memory and concentration, disorientation, severe depressions, irritability, confusion, headache and speech difficulties.

Prior to 1976, organochlorine insecticides had been used in the UK to kill the ectoparasites that caused sheep scab. But due to the persistence of OCs in the environment and the fact that France would not buy UK sheep meat because the OCs were being found in sheep meat, the UK, almost overnight, ordered a switch to the

use of OPs. In 1976 the UK government introduced the Sheep Scab Order, which obliged sheep farmers to dip flocks in organophosphate (OP) products to kill the ectoparasites (mites) which caused sheep scab.

However, the safety advice on the packaging remained the same as that for OCs despite the fact that the effects of OPs are very different and required much more stringent protective measures.

The legal requirement for farmers to use these new OPs coupled with the inadequate safety instructions provided to users has meant that hundreds and possibly thousands of people in the UK have been poisoned by these toxic nerve agents. The Organophosphate Information Network, set up by Liz Sigmund, has been contacted by 800 victims of OPs since 1992 but it is unknown how many others have died as a result of their exposure or continue to suffer in silence.

This article written by Liz Sigmund illustrates the total failure of the UK government to introduce measures that could have reduced or prevented exposure to OP pesticides and consequently avoided the damage that has been done to those affected and their families.

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reports of ill-health from hundreds of farmers and people who had been exposed to OPs in various ways. The database eventually contained 800 contacts, and OPIN wrote and circulated regular newsletters to them all.

In 1981 the Health and Safety Executive published a document ‘Biological monitoring of workers exposed to OP pesticides’, a Guidance Note in their Medical Series 17 (MS17). It stated that the main routes of exposure are via skin, respiratory tract and eyes. It stated that repeated small exposures to OPs could cause cumulative toxicity. It listed the symptoms of poisoning by OPs, which coincide closely with the reports coming to the OP Information Network from exposed farmers and others using OPs. OPIN obtained a copy of MS17 in 1992 (from an HSE officer) and it was published in the press and circulated via the OPIN newsletter. The Countess of Mar asked in the House of Lords for whom this document was intended, and she was told that it was for ‘biological assessors, not for doctors or farmers’. Many doctors and specialists asked OPIN for copies.

Why were all the facts contained in the Zuckerman report and MS 17 ignored and hidden from the very people who, if they had had this information, could have prevented most of the gross damage to the health of large numbers of farmers?

Despite conferences, parliamentary questions, articles in scientific journals and the farming press raising concerns about illhealth form OPs, government ministers took no effective action. The only changes that occurred were the announcement in 1992 by then Minister of Agriculture Nicholas Soames, that the 1976 Sheep Scab Order was rescinded, as it ‘was not working’.

Formulations of sheep-dip also contain phenols (organic solvents) which can penetrate protective clothing based on rubber. The HSE and Veterinary Medicines Directorate leaflets giving advice to sheep farmers on protective equipment and clothing recommended the use of rubber until 1995.

Changes were eventually made to the HSE advisory leaflets in response to challenges from OPIN about the use of rubber protective clothing and equipment: in 1995 HSE recommended the use of nitrile or PVC; and after years of denial that OPs could be absorbed via inhalation and advising dippers to wear a dust-mask (1995) the advice suddenly recommended, under certain conditions, that the ‘Respiratory Protective Equipment should be a full or half-mask respirator with a filter capable of removing particulates and gas/vapour’.

Many examples of changes in advice to sheep farmers can be cited, and always after scientific studies and publications have shown that the govenmental advice has been inadequate or plain wrong.

The use of OP pesticides in Gulf War 1 is suspected of causing much of the ill-health known as Gulf War Syndrome. A hygiene officer working in the Gulf provided OPIN with a list of pesticides he was instructed to spray in tents, latrines, medical treatment

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Poisonings Permanent Peoples’ Tribunal hears UK evidence of poisoning In December 2011 the Pesticide Action Network International organised a hearing of the Permanent Peoples’ Tribunal (PPT) in Bangalore, India charging the big six multi-national pesticide manufacturers with gross violations of human rights in all the areas of the world where they operate. Included in the evidence was that of UK sheep farmers who are suffering the effects of poisoning by organophosphate (OP) sheep dips.

Much of this evidence was supplied

by OPIN and focused on the suffering of the victims and families of OP poisoning.

It highlighted the legal requirement for farmers to use OPs to treat sheep scab and how this, coupled with a lack of clear information relating to the effects of OP use and the often muddled or misleading advice on how to handle these substances safely, has resulted in loss of life, health and livelihood for those affected.

The verdict passed down by the PPT jurors was damning of those companies indicted. It included recommendations on how similar offences could be prevented in the future and how the victims could get greater redress from the six companies and the regulatory bodies overseeing their activities. A number of these recommendations are of direct relevance to OP sufferers and include: ● that national governments prosecute offenders (pesticide manufacturers) under criminal law rather than civil law ● that the burden of proof be lessened for victims and that national governments fully commit to and legislate for the precautionary principle If both of these recommendations had been in full operation then it is likely that the OP poisonings could have been avoided in the first place or at the very least the victims would have had legal redress and recognition of their suffering.

tents and cooking areas, to kill sand flies and mosquitoes. He said that no protective equipment was provided for the sprayers, and many refused to continue to use them as they were experiencing severe symptoms. Many of these pesticides were OPs, in fact one was an actual sheep dip! The symptoms closely resembled those experienced by our farmers.

The sheep-dipping case is very important as it is the only example of the use of a chemical widely recognised as toxic being forced upon an agricultural community, by law, without any attempt to warn or prepare the farmers or their GPs of the risks involved.

Liz Sigmund coordinates the Organophosphate Information Network; www.opin.info

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UK government ignores call to review bee-toxic pesticides The Co-operative, supported by PAN UK has lobbied the Environment Secretary Owen Paterson, calling for an immediate review of the science that underpins the UK risk assessment procedure for neonicotinoid pesticides.

The Co-operative said in its letter ‘We are writing to you to ask for an urgent independent review of the science and regulatory assessment of neonicotinoid pesticides.... As a major food retailer serving over 14m customers each week, the health of bees and other pollinator species are of great concern to us, our growers and our customers.’

In addition, PAN UK has alerted all major UK supermarkets to concerns over the safety of neonicotinoids and to concerns that the current risk assessment regime ignores several potentially serious exposure routes for bees and other pollinating species to these harmful pesticides.

Recent independent studies by the University of Stirling1 and the French National Agricultural Research Institute2 have highlighted the effects of low doses of neonicotinoids in pollen and nectar to bees.

In May 2012, a report from the European Food Safety Authority3 (EFSA, the official body in charge of assessing pesticide risks to pollinators) highlighted glaring gaps in the way that neonicotinoid effects on bees have been evaluated leaving a major question hanging over the fate of neonicotinoid products on the EU market.

In June 2012, France suspended use of the neonicotinoid pesticide thiamethoxam as a seed treatment on oilseed rape, following research findings on its effects on honeybee homing behaviour4. And in April 2012, the European Ombudsman opened an investigation into whether the European Commission has taken adequate measures to combat increased bee mortality in Europe. This was prompted by a complaint from Austria that the Commission has failed to take into account new scientific evidence in favour of restricting the use of neonicotinoids.

A series of fact sheets, just published by PAN UK [p17], expose the risks to bee and pollinator species from pesticides and look at what the failings of the risk assessment means for bee and pollinator health5. Dr Stephanie Williamson, Staff Scientist at PAN UK, said ‘There is more than enough evidence to show that the current system is failing to address serious concerns about risks to pollinators from neonicotinoid pesticides.

Recent findings are more than enough to warrant a precautionary approach from Defra.’

PAN UK issued a 12 point call for action to protect bees from pesticides. PAN UK Director, Dr. Keith Tyrell commented ‘It is clear that the concerns of NGOs and the public are now being echoed by the retailers. The weight of evidence is growing and it is time for clarity. The UK Government needs to act on this as a matter of urgency.’

‘Other European governments have acted

to protect their bees and pollinators from neonics, but Defra continues to sit on its hands and do nothing even though the European Food Safety Authority says that the risk assessment process for these pesticides is not fit for purpose.’

1. Neonicotinoid pesticide reduces bumblebee colony growth and queen production. Whitehorn, PR, O’Connor, S, Wackers, FL and Goulson, D. (2012) Science Express 10.1126/science.1215025 http://www.sciencemag.org/content/336/6079/351.abs tract 2. A common pesticide decreases foraging success and survival in honey bees. Henry, M, Beguin, M, Requier, F, Rollin, O, Odoux, J-F, Aupinel, P, Aptel, J, Tchamitchian, S and Decourtye, A. (2012) Science Express 10.1126/science.1215039 http://www. sciencemag.org/content/336/6079/348.abstract 3. Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees (Apis mellifera, Bombus spp. and solitary bees). (2012) European Food Safety Authority. EFSA Journal 10(5) 2668. http://www.efsa.europa.eu/en/efsajournal/pub/2668.ht m 4. The decline of England’s bees. Policy review and recommendations. Breeze, TD, Roberts, SPM and Potts, SG. (2012) University of Reading, UK, and Friends of the Earth. http://www.foe.co.uk/beesreport 5. PAN UK fact sheets and a summary leaflet on Bee Declines and the Link with Pesticides are available at: www.pan-uk.org and www.bees.pan-uk.org

Update: In a statement issued on 18 September http://www.defra.gov.uk/environment/quality /chemicals/pesticides/insecticides-bees/) Defra announced that following an internal review - carried out largely by its own staff and related bodies - there is no need to change the approach to using bee toxic neonicotinoids in the UK and that we should carry with business as usual.

PAN UK is incredibly disappointed with the response from Defra. Defra has once again shown that when it comes to protecting the environment or protecting the profits of the pesticide industry the pesticide industry wins hands down!

With this decision, Defra is burying its head in the sand and ignoring the overwhelming body of scientific evidence. Other European countries that have implemented bans on neonicotinoids are seeing their bee populations recover.

This outcome is the exact reason that PAN UK and the Coop are calling for an independent review of the science that underpins the risk assessment for neonicotinoids in the UK. Defra is far to close to industry to allow for a completely unbiased opinion on the science. Some 60% of the funding for Defra's pesticide regulatory and approvals branch comes from the work that they do for industry. There is no question that the pesticide industry lobby is a very powerful voice in Whitehall.

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Poisonings

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Paraquat – 50 years of human rights violations The cause of innumerable loss of lives, companies which continue to sell the world's most deadly pesticide, paraquat, are failing to respect the human right to health according to François Meienberg, Berne Declaration, Lars Neumeister and Richard Isenring report.

Paraquat was first introduced in Malaysian rubber plantations in 1961 – exactly 51 years ago. Since then its use has become widespread making it one of the most widely sold weedkillers globally. As a broad-spectrum (or non-selective) herbicide, paraquat kills both broadleaved weeds and grasses. It is used on fruit and plantation crops (banana, cocoa, coffee, oil palm), field crops (maize), in direct seeding (or conservation tillage), in forestry and as a defoliant or desiccant to dry crop plants (such as cotton, pineapple, soy bean and sugar cane). The main product line is ‘Gramoxone’, marketed by Syngenta. In 2007, Syngenta stated that it had a 75% share of the paraquat market1. But since then this share has probably decreased due to increased production of generic brands, especially by Chinese companies.

Poisonings – a widespread public health problem From the time when it was first marketed until today, accidental and intentional drinking of paraquat as well as occupational (workplace) poisonings have caused innumerable loss of lives. Dawson and Buckley (2007) estimated that tens of thousands of deaths worldwide are due to paraquat poisoning occur each year2. New reports from China estimate 5000 paraquat fatalities annually3.

Among all commonly used herbicides, paraquat has by far the highest acute toxicity (Figure 1), and compared to all other pesticides it has the highest mortality rate.

Paraquat is currently the deadliest pesticide on the market. This is a result of its very high acute toxicity combined with the absence of

Figure 1. Herbicide lethality relative to glyphosate

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an antidote.

For the following reasons, paraquat can be rated as a ‘major suicide agent’5 in many countries: it is highly acutely toxic (one teaspoon is fatal) and can be absorbed through the skin; no antidote exists; it is readily available; and it is relatively cheap. The ingestion of a lethal amount of paraquat leads to an extremely painful and prolonged death.

Fatal poisoning at the workplace occurs mostly when paraquat absorption through skin is increased after prolonged contact with undiluted or diluted paraquat solution. Spray mist deposited in the nose may be swallowed and spray in the air can be ingested when workers breathe through the mouth. The level of exposure to paraquat that workers may experience when handling paraquat is high enough to lead to absorption of an amount that can result in acute poisoning. The symptoms of poisoning are often delayed. Damage to the lungs, for example, may not be evident until several days after absorption. Since there is no antidote against paraquat poisoning, the outcome can be fatal and in these cases death mostly results from respiratory failure.

Typical injuries, including skin problems ranging from mild dermatitis to severe chemical burns, eye injury, nail damage, and nosebleed, have been observed in proportions as high as 50% of exposed workers. Long-term and delayed health effects may occur, including Parkinson’s disease, lung effects, and skin cancer6.

In many countries paraquat is the active ingredient which leads to the most occupational poisonings. This has been shown in Costa Rica where between 1996 and 2001 paraquat was the cause of 35% of all notified poisonings7. New findings from Burkina Faso show that 54 of 296 pesticide poisonings are caused by Syngenta’s herbicide Gramoxone (active ingredient: paraquat)8.

Stakeholders taking measures to prohibit the use of paraquat

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Relative lethality of 15 common herbicides based on LD50 values published by the World Health Organisation4 compared to that of glyphosate (LD50 of 4,230 mg/kg body weight = 1).

Paraquat is banned in a number of countries.

A special process led to the ban of paraquat in the European Union. After paraquat had been authorised in the EU by the European Commission in 2003, Sweden, supported by Denmark, Austria and Finland, brought an action before the Court of First Instance for annulment of this decision. The Court annulled the decision (among other reasons) because it ‘failed to satisfy the requirement of protection of human health’12, with ‘the effect that this active substance is banned for pesticide use’ in the EU13.

Effective since December 1989, pesticides containing the active agent paraquat are no longer approved for use in Switzerland, the host country of Syngenta. The Swiss Government’s sanction at this early date was a response to the high acute toxicity for humans inherent in the use – and especially the misuse - of paraquat14.

In addition to the European Countries, paraquat is also banned in Sri Lanka, Russia, the Ivory Coast and other countries. It is like-

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Figure 2. Fatality of deliberate pesticide poisonings in Sri Lanka, Brazil and India

Case-Fatality Ratio (%) for deliberate poisonings with pesticides in Sri Lanka9, *Brazil10 and **India11.

WHO classification: Ib= Highly hazardous;II = Moderately hazardous; III = Slightly hazardous; U = Unlikely to present hazard in normal use. Pesticide without WHO classification = n. Only pesticides > 10 cases are presented.

ly that several other countries will join in the years to come. Burkina Faso recently proposed to add Gramoxone Super containing 200 g/L paraquat to the Annex III of the PIC Convention15. The Decision on this proposal will probably be made by the Conference of Parties in 2013.

But not only Governments react to the health risks posed by paraquat. Various initiatives promoting a more sustainable form of agriculture prohibit the use of paraquat: Fairtrade Labelling Organizations International (FLO), Rainforest Alliance, UTZ Certified, Forest Stewardship Council or the Common Code for the Coffee Community. Global food corporations such as Dole and Chiquita or Nestlé and Lipton in their Tea Production – all of these no longer allow their suppliers to use paraquat.

Supermarkets are following as the example of the UK-based Co-operative shows.

A violation of human rights?

The question of, and in which manner, the sale of paraquat contradicts fundamental human rights and, more specifically, if by selling paraquat the market leader Syngenta obeys its obligation to respect human rights, or not, has gained little attention so far. One clear answer has been given by the Permanent Peoples’ Tribunal held in Bangalore in December 2011, which has raised awareness about human rights abuse by agrochemical corporations.

Another approach to this question has been chosen by the Berne Declaration and the European Center for Constitutional and Human Rights by publishing a legal opinion16, using the Guiding Principles on Business and Human Rights developed by John Ruggie and adopted by the UN Human

Rights Council in June 2011 as a basis. With the Guiding Principles there is now a worldwide recognised standard which provides criteria to answer the question of corporations’ responsibility for violating human rights. The legal opinion analysed whether Syngenta is fulfilling its responsibility to respect human rights under the UN Guiding Principles when it produces and markets paraquat in the current way. For the first time, the Guiding Principles have been applied in a concrete case of violations of the rights to life and health that have taken place daily and globally during the past 50 years.

The verdict of the analysis is clear. By selling paraquat – particularly in developing countries – Syngenta violates its responsibility to respect human rights. The Guiding Principles – also endorsed by corporations and business associations – are not being adhered to. It is no longer sufficient for a company to emphasise that it follows national laws. If the activities of a corporation violate the human right to health the corporation must act. And this is exactly where Syngenta falls short.

‘In very many countries, particularly in the South, paraquat is used under high-risk conditions. Workers frequently are not provided with the necessary personal protective equipment (PPE), or they cannot use adequate PPE in hot climates due to heat stress.

The manufacturers and distributors of paraquat are well aware that in very many places this particularly hazardous chemical cannot be used safely under common working conditions. Workers who suffer ill health from paraquat exposure should be entitled to claim compensation from these companies which are liable for negligence.’

Despite these shortcomings there are no

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direct legal consequences for the Swiss agribusiness corporation, because the Guiding Principles are not legally binding.

They are nonetheless an important improvement in our opinion as they demand concrete measures to prevent, mitigate and remediate violations of human rights by corporations.

States as well as corporations have obligations and responsibilities under the Guiding Principles: states must ensure that corporations do not violate human rights, and when they do, the victims must be able to access effective remedies such as filing lawsuits in the corporation’s home country to make a claim for compensation. The corporations must systematically orientate themselves according to the Guiding Principles on Business and Human Rights. They must introduce human rights risk assessments in all of their activities and take precautionary measures and provide compensation.

References 1. Speech of the President of the board, Mr. Taylor, at Syngenta‘s General Assembly May 2nd 2007.

2. Dawson A & Buckley N (2007): Integrating approaches to paraquat poisoning.Ceylon Medical Journal 52: 45–47 3. Crop Protection China News (2011): Banning Paraquat Raises Dispute in China. www.prlog.org/11701572-banning-paraquat-raisesdispute-in-china.html 4. The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification 2010. World Health Organisation (WHO). Geneva. www.who.int/ipcs/ publications/pesticides_hazard/en/ 5. Dinham, B. 1996: Active Ingredient fact sheet, Paraquat, in: PAN UK: Pesticide News No32, pp 20-21. www.pan-uk.org/pestnews/Actives/ paraquat.htm 6. Wesseling C, van Wendel de Joode B, Ruepert C, León C, Monge P, Hermosilla H, and Partanen T, Paraquat in developing countries, International Journal of Occupational Health 7(4), 275-286, 2001. http://www.evb.ch/cm_data/para_dev.pdf 7. Intoxicaciones por plaguicidas en Costa Rica: Informe epide-miolögico 2001, San José, Costa Rica: OPS/Organizaciön Mundial de la Salud (OMS): Proyecto PLAGSALUD, Organizaciön Panamericana de la Salud (OPS), http://www.evb.ch/cm_data/Intoxicaciones_in_Cost a_Rica_1.pdf 8. Toe M. Pilot Study on Agricultural Pesticide Poisoning in Burkina Faso; http://www.evb.ch/cm_data/Report_Final_SHPF_B urkina_EN.pdf 9. Dawson AH, Eddleston M, Senarathna L, Mohamed F, Gawarammana I, Bowe SJ, Manuweera G, Buckley NA (2010): Acute Human Lethal Toxicity of Agricultural Pesticides: A Prospective Cohort Study. PLoS Medicine 7(10): e1000357. http://www.plosmedicine.org/article/info:doi/10.137 1/journal.pmed.1000357 10. Recena MCP, Pires DX, Caldas ED (2006): Acute poisoning with pesticides in the state of Mato Grosso do Sul, Brazil. Science of the Total Environment 357:88– 95. http://dx.doi.org/10.1016/j.scitotenv.2005.04.029 11. Srinivas Rao Ch, Venkateswarlu V, Surender T, Eddleston M & Buckley NA (2005): Pesticide poisoning in south India: opportunities for prevention and improved medical management. Tropical Medicine and International Health 10(6):581-8.

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Sustainable production

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MADE-BY: Fashioning Sustainable Pesticidefree clothing A pioneering initiative to improve environmental and social performance in the fashion industry is improving transparency in clothing supply chains and targeting pesticide use by cotton growers.

The negative environmental and social impacts of growing conventional cotton are well documented. Conventionally grown cotton uses more insecticides than any other single crop and each year cotton producers around the world use nearly $2.6 billion worth of pesticides - more than 10% of the world's pesticides, and nearly 25% of the world's insecticides. Pesticides used on cotton, even when used according to instructions, harm people, wildlife, and the environment. These pesticides can poison farm workers, drift into neighbouring communities, contaminate ground and surface water, and kill beneficial insects and soil microorganisms.

With 75 countries across the world growing cotton, resulting in 31.7% of the world’s fibre production, addressing the negative externalities of the cotton industry has been an on-going challenge for governments, civil society organisations, and the private sector.

MADE-BY (www.made-by.org) is an organisation which works with the private sector to increase transparency in the clothing supply chain, and as a result improve its clients’ performance on a number of envicontinued from page 9

http://onlinelibrary.wiley.com/doi/10.1111/j.13653156.2005.01412.x/full 12. Press Release of the Court of Justice of the European Union: http://curia.europa.eu/en/actu/ communiques/cp07/aff/cp070045en.pdf (11.07.07) 13. Commission Regulation (EU) No 15/2010 of 7 January 2010: http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:L:2010:006:0001:0005:EN: PDF 14. Statement of the Federal Council, November 11, 2002: http://www.evb.ch/en/p1832.html 15. www.pic.int 16. Grabosch R. The Distribution of Paraquat: Does Syngenta Respect Human Rights? 2011 (download at www.evb.ch)

François Meienberg is Co-Founder of the Berne Declaration, françois.meienberg@ evb.ch; Lars Neumeister is an Independent Pesticide Expert, lars.neumeister @pestizideexperte.de ; Richard Isenring is an Independent Environmental Consultant, r.isenring@postmail.ch

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ronmental and social indicators.

Founded in 2004 by the Dutch NGO Solidaridad, MADE-BY describes itself as: ‘A European not-for-profit organisation with a mission to make sustainable fashion common practice and improve environmental and social conditions in the fashion industry.

To achieve this, MADE-BY works with fashion brands of varying sizes and scope, and supports them in developing sustainable strategies to improve conditions across their entire supply chain’.

With much of the innovation in sustainable fashion focusing on industrial practices, waste management, workers' rights, or postconsumer issues (what becomes of a garment after it is discarded), it is MADE-BY’s attempt to introduce incremental but comprehensive changes across the entire supply chain (depending on an organisation’s needs) that makes its work pioneering.

Changing an industry from the inside, out MADE-BY may have started as a direct response by civil society to the fashion industry's record of social and environmental abuse or neglect, but its strategy is to partner with industry to bring about change.

Its approach to sustainable fibres is to consider all fibres holistically, rather than simply advocate a move away from conventional cotton.

MADE-BY is equipped with an in-depth understanding of the often conflicting pressures facing fashion businesses in today's market, (its CEO, Allanna McAspurn, has herself worked in sustainable business, marketing, and fashion sourcing) as well as an arsenal of tools to help its partner brands make steady progress along their sustainability journeys.

These tools include social and environmental benchmarks and scorecards, a certification selection tool, and others based on industry — and brand — needs. Scorecards promote a transparent assessment of a brand’s progress, requiring the brand to commit to documenting its social and environmental progress yearly. Not only does this encourage the brand to embrace transparency, it also provides an opportunity to reflect on process, and to highlight any hurdles encountered. The scorecards are based

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on MADE-BY’s benchmarks for social policy, social standards, and environmental impact, highlighting progress made towards sustainability.

MADE-BY’s environmental benchmark classifies the fibres most commonly used in the fashion industry based on their environmental performance. Using publically available information, the environmental benchmark compares the most commonly used man-made and natural fibres from origin to the point at which the fibres are ready to be spun. It enables buyers to understand the impact of their choices by grading the environmental performance of the fibres, from best in class (A) to the worst in class (E).

Cotton, for example, performs as follows: recycled cotton is in class A, organic cotton or cotton in conversion is in class B, while conventional cotton is in class E. The result of MADE-BY’s pragmatic approach (valuing an on-going progress report over a periodic ‘pass or fail’ assessment) is that companies are encouraged to share best practice and the transparency involved in reporting leads to sustainable change: ‘We believe that sharing best practice and encouraging progress is vital to success. Improving entire production chains and building bridges between the brands and suppliers takes time. It is therefore important that this process is transparent and communicated clearly’.

Partner brands cottoning on This pragmatism has found a growing audience among brands wanting to improve their ethical performance and policy makers looking to understand how to change the business of fashion. According to its 2011 annual report, MADE-BY worked with 34 brands in eight countries as well as running projects for government bodies.

In terms of its partner brands, despite a 5% fall in the worldwide production of organic cotton in 2011, MADE-BY reported a 20% increase in the use of organic cotton by its clients in the same time period.

Forecasting fashion's future While MADE-BY encourages businesses to take a closer look at their behaviours and

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Sustainable production MADE-BY partner brands case study: Jackpot Maryam Azmayesh Terp, Jackpot’s Corporate Social Responsibility manager, talks about the company's sustainable cotton sourcing activities When did you start using organic cotton in your collections?

The first organic cotton product Jackpot ever sold was in our Spring/Summer collection 2007, where we had four t-shirt styles, in three colours per style, produced with organic cotton. Although the collection was launched in 2007, the project started in 2006. We didn’t know how big of a step it would be, but we felt introducing organic cotton was the first step towards becoming more sustainable, as cotton is one of the main fabrics we use in our collections. This has now expanded into incorporating other sustainable fibres, such as organic linen, Tencel, recycled wool and recycled polyester, into our collections.

Generally our Spring/Summer collections are easier to incorporate sustainable fibres into, as opposed to heavier fabrics used in Autumn/Winter.

What work have you done to date to reduce pesticide use in your supply chain?

In addition to introducing organic cotton into our collections, wherever possible, we work actively towards reducing pesticide use in our supply chain by supporting organic cotton farming and we were introduced to Chetna Organic1 through MADE-BY and Solidaridad.

We wanted to help wherever we could, and we were able to support Chetna’s organic seed plot development to increase the yield on their organic fields. We also pay a fair price for the organic cotton, which is set by Solidaridad and the farmers. The project also ensures the farmers themselves invest their own money so they feel ownership of the project.

In addition, we also joined the Better Cotton Initiative (BCI)2, because when we heard about it, we believed very much that this was the future, and we felt it complemented our existing organic cotton strategy. Our aim is to replace our conventional cotton with BCI cotton, and reduce the overall use of pesticides, fertilisers and water.

What challenges have you faced so far?

At the beginning it was difficult to get the organic cotton from Chetna Organic to our suppliers, who already had specific cotton farmers they sourced from. MADE-BY helped us overcome this by helping to link up our supply chain.

Pricing has also been a challenge. We always aim to make our products as sustainable as possible, but sometimes we have to compromise if the costs become too high or the quality isn’t as good as we’d like it to be. But we do what we can, and for us it’s our whole company that needs to be in balance – it’s not just about making one product sustainable.

BCI cotton was also difficult to source in the beginning, but as supply is growing, this is now becoming easier.

How have Solidaridad/MADE-BY supported you in the work you’ve done around organic cotton consumption?

As I've said, MADE-BY helped us connect Chetna organic cotton to suppliers in our supply chain, and they also verify our organic data and translate this into scorecards.

Solidaridad supports us by managing our organic cotton purchases from Chetna Organic.

What words of wisdom or lessons learnt can you impart on companies looking to become more sustainable?

Begin by sourcing organic, because this is relatively easy at the moment. Organic cotton is also easy to communicate and raise overall consumer awareness with. Your sourcing strategy will then develop depending on what kind of company you are, but I do believe it’s very important to source transparently. From our sustainable fibre sourcing experience, we’ve gained a lot of insight on the importance of transparency, and we believe this stretches across the supply chain, not only fibre sourcing, but also for instance the wet processing field, where we also feel transparency is key.

1. Chetna Organic is an association of small scale cotton farmers in India – the first to receive Fairtrade Certification from FLO who own the international FairTrade mark. The cotton is cultivated by small and marginal farmers without any use of child labour, synthetic pesticides, fertilizers and GMOs. 2. The Better Cotton Initiative is a voluntary programme which invites members of the global cotton supply chain to collectively address the negative impacts of conventional cotton production. It is backed by big brands such as Levi Strauss, Marks & Spencer, IKEA, H&M and Adidas.

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minimise their impact, it would be naïve to assume the pace of change in the fashion industry is not inextricably linked to external environmental, social and economic pressures.

McAspurn sets out the context in which the fashion industry in the past year has been attempting to green its supply chain: ‘2011 onwards has seen significant challenges and developments within both fashion and sustainability. Due to climatic pressures, resource constraints and increased demand from emerging markets, brands were facing 150 year highs in the price of cotton, 80 year highs in the price of wool and subsequently, polyester was up 60% on the previous year.

This put real pressure on margins at a time when spending on the high street was significantly down. At the same time, the spotlight was firmly put onto the washing and dyeing parts of textile supply chains as Greenpeace publicised their Dirty Laundry investigation into hazardous substances being found in the waterways of China’.

Elsewhere, she forecasts what the impact of these externalities will be: ‘the key trends over the next five years will be around supply chain efficiency, reducing environmental impacts throughout the whole supply chain, design innovation, traceability and a developing dialogue between consumers and brands on their sustainability progress’.

It seems that the combination of a more aware, yet financially constrained consumer is forcing industry to both set processes in place to guarantee the ethical credentials of the products it markets, but also find how to do so at a price consumers can afford. These seemingly contradictory pressures, and fashion’s contribution to the UK economy, make the need to find sustainable ethical solutions an imperative.

According to research commissioned by the British Fashion council in the UK, the fashion industry contributes more than £20bn to GDP, more than publishing and car manufacturing.

Yet there are many issues which remain outside the control of industry which have a bearing on ethical performance. The regulatory environment (not just in the UK but across all the regions and nations where fashion brands work) is one such factor.

According to sociologist Steve Yarley, the ambiguity of regulations results in companies becoming ‘environmentally inactive or even destructive’.

So the fate of cotton farmers and indeed all the other stakeholders in the supply chain rests with many actors, with no one actor able to single-handedly address the multiple challenges of cotton garment production.

Still, the tools MADE-BY provides give proactive brands the confidence to address those issues within their supply chain over which they have control (or can exercise an influence) and in turn minimise the social and environmental risks from their activities.

For further information contact Keith Tyrell at keithtyrell@pan-uk.org

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Locust control

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Building community capacity for Ethiopia’s locust control The ability of Ethiopia to prevent devastating locust plagues is limited by lack of involvement of stakeholders. Tadesse Amera describes PAN Ethiopia’s new programme to promote local community involvement.

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Ethiopia is often attacked by the African Migratory locust (Locusta migratoria migratoriodes) and the tree locust (Anacridium melanorhodon melanohodon). In 1958, a locust invasion of Ethiopia resulted in losses of 50-150 thousand tonnes of cereals in less than six months, equivalent to the annual cereals requirement of about one million people1. Ethiopia has several locust breeding areas in territories bordering the Sudan, Djibouti, Eritrea and Somali. Swarms and plagues of locusts from breeding sites can spread widely and even reach the mid-highlands. Weather conditions, mainly temperature, are key restrictions. The projected changes in temperature as the result of climate change may favour the spread of locust outbreaks beyond zones where locusts used to be limited by low temperature conditions2.

Despite the multiple efforts to prevent locust outbreaks on the part of the government and the Desert Locust Control Organisation based in Addis Ababa, the problem still remains and there is an urgent need for clear and sustainable management options to be developed. Although many factors such as locust behavior, weather and control approaches have contributed to the weaknesses in preventing outbreaks, it is clear that a failure to involve stakeholders is a key factor.

The lack of strategies to properly identify and include stakeholders from grassroots level to higher levels has led to a lack of awareness and hindered early reporting of locust outbreaks. This undermines monitoring and delays response allowing swarms to develop and making it more difficult to deploy non-chemical control options. What is more, this lack of involvement makes it difficult to assess the environmental and human health impacts of the aerial application of organophosphate locust control chemicals.

With this in mind, PAN Ethiopia launched a project in 2011 to involve Ethiopian non-governmental organisations (NGOs) in the national locust control programme and build the capacities of communities in the country’s locust breeding and outbreak regions.

As the involvement of NGOs in locust control was a new development in Ethiopia the project began by: ● identifying obstacles to community involvement in decision-making and involving relevant NGOs as stakeholders in locust

control efforts at grassroots levels mainly from locust breeding and outbreak regions; ● organising awareness raising campaigns on impacts of locust pesticides on grass roots communities ● identifying challenges in the application of environmentally sound locust control alternatives to chemical pesticides and ● organising a national workshop to initiate collaboration of stakeholders Furthermore, the project aimed to promote environmentally benign management options towards locust outbreaks (invasions) and minimise any unnecessary pesticide accumulations which would finally end up being obsolete requiring more resources for disposal than the original purchase value.

The project obtained financial support from the UK Department for International Development (DFID) and technical support from PAN UK and PAN Africa. The project was also implemented in close collaboration with the Ministry of Agriculture of Ethiopia and the Desert Locust Control Organization for Eastern Africa (DLCO-EA).

Project areas In consultation with the Ministry of Agriculture (MoA) and the DLCO-EA, the community of Diredawa was selected as a consultation centre for the Eastern Ethiopia region while Mekelle was selected for the Northern Ethiopia region. A team of experts from MoA, DLCO-EA, Addis Ababa University (AAU) and Pesticide Action Nexus Association (PAN-Ethiopia) was formed and held consultation meetings with representatives of the Bureaux of Agriculture of the Diredawa and Somali regions in Diredawa and with representatives of the Bureau of Agriculture of Tigrai in Mekele.

Initially, the project aimed at reaching two locust breeding and /or outbreak areas but the consultative meetings revealed that the neighbouring regions should also be involved because locusts are a migratory pest and should be handled with proper information exchange with neighbouring regions.

In Eastern Ethiopia, the project incorporated representatives of two woredas (districts) each from Diredawa and Somali, Agriculture Bureaux of Diredawa, Somali, Hareri and East Harargie, and four NGOs recommended by local agriculture offices.

In Northern Ethiopia, where Mekele was

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the consultation centre, seven woredas from Tigrai, four woredas from Afar, one woreda from Amhara and two major NGOs working in these areas were identified to be involved in the process of the project.

Implementation Identifying obstacles to involvement Major NGOs involved in agriculture and rural development were identified and contacted in the selected regions so that they could be actively involved in the project. A key aim was to build their capacity to feed into the national locust control program and to facilitate contacts between them and the relevant officials responsible for locust control. Key informant community members and potential actors of community mobilisation were also identified, and discussions were conducted in the project areas.

Gaps that could be filled out by NGOs at grassroots levels by mobilising communities were mapped out with DLCO-EA, the Animal and Plant Health Regulatory Directorate (APHRD) of MoA at Federal Level and the Bureaux of Agriculture of Diredawa, Harari, East Harergie, Somali, Tigrai and Afar Regions.

The research and consultations uncovered that communities in the Afar and Somali Regions would regularly hide information about early locust outbreaks because they feared that aerial spraying of pesticides would take place if they reported locust breeding. They were worried that the pesticides would harm their cattle and bees.

However, locust outbreaks happened in 20072008 which damaged crops and the DLCOEA responded with aerial application of conventional pesticides. Hiding information, therefore, leads to both locust outbreaks which damage crops and cattle pasture and aerial application of pesticides which may damage environmental and human health.

Awareness raising campaigns Through the active involvement of NGOs, the project provided information on communitylevel impacts of pesticides bought or donated or both for the purpose of locust control. This process was also supported by the involvement of local media outlets like radio for better dissemination of information. The executed project attempted to fill a gap by sharing research evidence and awareness raising campaigns. Civil society groups were also mobilised in project areas to get involved and contribute to efforts so far handled mainly by the Government and DLCO-EA.

Obstacles to sustainable control The project also aimed to identify and promote effective alternatives to conventional pesticides. A fungus based bio-pesticide, Green Muscle® has been tested by DLCOEA and Addis Ababa University in Ethiopia and its effectiveness is documented. But its use was prevented because the national pesticide legislation does not include a provision for registering bio-pesticides. This obstacle

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was removed in 2010. A new proclamation was issued and a regulation is under formulation which may allow registrants to import Green Muscle®.

Organise a national workshop A national workshop which brought together six of the project regions, relevant Federal Government Ministries and Agencies, Intergovernmental Organisations such as DLCO-EA and WHO; Universities, NGOs, media and private sectors was conducted in Addis Ababa in the spring of 2012.

During the workshop, the participants agreed to collaborate in the locust control programme of Ethiopia and an idea of organising an international workshop following the celebration of the 50th year of DLCO-EA is also taken as an assignment to work on the link and networking between International and National efforts of locust control.

The main theme of the project, its process and the impact of locust control pesticides on human health and the environment as well as how to mitigate this problem were also given four days, half an hour each radio air time coverage by an environmental journalist.

Next Steps Following the recommendations at the national workshop, an international workshop will be organised to: ● encourage donors to support prevention, not just control, of locust outbreaks ● promote monitoring of the health and environmental impacts of locust pesticides ● promote non-chemical alternatives to be used in future locust control campaigns and ● call for strategic participation of civil society organisations in control programmes.

Lessons learnt This project was the first time that civil societies/NGOs were actively engaged in the locust control programme of Ethiopia, and this approach was appreciated by the Ministry of Agriculture and DLCO-EA. It was noted that women, children and infants are more vulnerable to pesticide impacts and more focus should be given to environmentally benign locust control options in order to prevent severe environmental and human health damage.

It was also noted that pesticides used in locust control may affect the productive age group which hinders the fight to reduce poverty and may moreover lead to a reduced quality of life for people living with HIV/AIDS and for those with disabilities.

References 1. Bidochka, MJ and Khachatourians, GG. (1991).

The implication of metabolic acids produced by Beauveria bassian in pathogenesis of the migratory grasshopper, Melanoplus sanguinipes. Journal of invertebrate pathology 58, 106-117.

2. Emiru S, unpublished data.

Tadesse Amera coordinates PAN Ethiopia, PO Box 7706 Addis Ababa, Ethiopia; atadesse2002@yahoo.com

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PAN International issues declaration on sustainable locust control PAN International has issued a series of recommendations on how to control locusts without endangering local communities and the environment. Keith Tyrell and Eloise Touni report.

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Locust invasions are a major threat to agriculture in the Sahel region of Africa.

Swarms can contain 40 million or more insects each eating their own weight in vegetation every day. The damage to crops and vegetation can be sudden and severe enough to destabilise rural communities and cause famines.

Once they swarm, locusts are very difficult to control and synthetic pesticides have become the main weapon used.

During invasions, huge amounts of pesticides – usually older, non-specific insecticides – are sprayed at high concentration over a wide area. The environmental and health risks associated with chemical control operations are significant.

Communities are rarely warned about spraying and the pesticides kill beneficial insects – such as bees – as well as locusts.

All too often, instead of supporting long-term prevention activities, which are both cost-efficient and effective, donors only support control operations once a locust outbreak has occurred. And then the response tends to focus on chemical control. PAN’s research has found that such responses are often poorly co-ordinated with large amounts of pesticides delivered too late or to the wrong place. Nearly 8 million litres of unused and obsolete pesticides were left over following the Sahel invasions of 2004/5.

Between 2009 and 2012, funded by the UK Department for International Development, Pesticide Action Network (PAN) partners in Ethiopia, Mali and Senegal conducted a series of activities to promote sustainable locust control to communities affected by outbreaks, and seek their input for future directions to better protect people from locust impacts.

Speaking to the communities across East and West Africa uncovered a series of useful lessons that can – and should – be used as the basis for effective locust control strategies that protect health and the environment as well as crops. The communities identified a double risk posed by locust outbreaks – directly to crops and thus food security and livelihoods – but

also to their health and the environment from the aerial spraying of highly toxic insecticides.

The resulting recommendations focus on four areas: ● involve communities and Civil Society Organisations ● recognise and deal with problems caused by over-reliance on chemical options ● use non-chemical alternatives first ● prioritise long term support to prevent locust problems

Involve communities and civil society organisations Involving local communities is essential to successful locust control. Local communities are especially important as a source of information about when and where locust outbreaks occur – well trained and supportive communities provide an effective early-warning mechanism to allow outbreaks to be caught early and controlled.

Local organisations can also be mobilised to provide resources quickly and cheaply to speed up response times and keep costs down. In spite of this, a PAN Africa study on the 2003-2005 locust invasions in Mali and Senegal identified only a modest contribution by local civil society organisations in locust control operations e.g. provision of vehicles and fuel, and helping form village brigades. Farmers asked for better involvement of NGOs and associations of producers in the locust fight.

On the other side of the continent, PAN Ethiopia reached out to NGOs and local communities to generate data on community-level impacts of locust pesticides, through awareness raising workshops and media coverage. Contacts with different stakeholders revealed interest and willingness to contribute to efforts that have so far been handled mainly by the Government and Desert Locust Control Organisation – East Africa (DLCO-EA) As well as employing traditional physical means to fight locusts, community

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roles identified included community based forecasting, which has also been trialled for armyworm in East Africa, promoting alternatives to public and policy makers alike.

Recognise and deal with problems caused by overreliance on chemical options Communities routinely reported frequent and severe poisoning incidents caused by the use of chemical pesticides to fight locusts. Farmers, representatives of civil society and officials in Mali and Senegal clearly highlighted the negative impacts of pesticides on health, while in Ethiopia communities held off informing the authorities about locust outbreaks because they had experienced negative effects from control activities in the past.

In spite of these problems, PAN partners found little evidence of post control monitoring to assess the impact of such intensive pesticide use on health and the environment. One notable exception attempted to measure the external (health, environmental, production and damage) costs of locust control and estimated a previously invisible cost of $8 million for the 2003/5 West African campaign (Leach, 2008). The lack of systematic measurement leads to unsustainable choices in the selection of control options and favours the use of toxic chemicals over alternatives.

Obsolete pesticides are a major indirect cost associated with over-reliance on chemicals.

Use non-chemical control first Lab and field trials of alternatives to chemical insecticides have demonstrated efficacy and these alternatives seem ready to be used for preventive and active control.

A commercial product produced in South Africa and Senegal (Green Muscle®) has been successfully trialled in eastern Ethiopia and several countries in West Africa, e.g. Senegal, Mali and Burkina Faso against Desert Locust hoppers. It has also been used satisfactorily since 2008 in Senegal against jacks and in Mauritania as part of routine control operations over an area of 40 ha, with satisfactory results.

The DLCO-EA bio-pesticide laboratory in Addis Ababa has collected over 107 isolates of entomopathogenic fungi (Beauveria and Metarhizium spp), and some performed as well as Green Muscle®. Other alternatives include Neem, Phenylacetonitrile, and insect growth regulating hormones and are described in PAN Africa’s publication on alternatives.

Green Muscle® is registered in CILSS countries, but in Ethiopia a framework for registration of bio-pesticides is currently under formulation so no registrations are possible until this process is complete.

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Recognise and deal with problems caused by over-reliance on chemical options The external costs of chemical-based strategies on health and environment are largely un-quantified and ignored, leading to unjustified economic decisions against more sustainable options. ● Monitor the effects on human health and the environment, using participatory methods which involve communities ● Share the results of monitoring with affected people to try and limit exposure ● Develop new partnerships to dispose of obsolete stockpiles of unwanted chemicals in an environmentally sound manner

Use non-chemical alternatives first The first step in reducing reliance on pesticides must be to correct the idea that these products are a panacea. Placing undue reliance on toxic chemicals to stop a plague of locusts is utopian. ● governments can fast track registration of proven alternatives, and actively encourage and support industries to produce them locally. ● technical agencies and donors can increase training and information dissemination of viable alternative technologies to on-the-ground teams and provide technical support.

Prioritise long term support for preventing locust problems

Senegalese children run from locusts swarming in the capital Dakar Photo: Reuters/Pierre Holtz

Prioritise long term support for preventing locust problems Addressing the conditions that lead to outbreaks – for example through effective monitoring, and rapid response – avoids the need to use large amounts of expensive and dangerous chemical pesticides. It also reduces the likelihood of unused pesticide stockpiles. Non-chemical control methods such as fungi, are particularly effective at preventing outbreaks from growing.

The 2007-2009 invasions in Ethiopia were successfully controlled by the close collaboration of DLCO-EA and the Ministry of Agriculture, Animal and Plant Health Regulatory Directorate. Limited and targeted quantities of pesticides were delivered within two weeks of notification to the local pesticide formulation company.

PAN International Declaration on Protecting People from Locust Impacts PAN’s work with experts and communities affected by locust invasions in Africa has

led to four key suggestions in order to reorient locust control toward reducing locust risks for people. We urge donors, technical agencies, governments and other stakeholders to:

Seek strategic participation of communities and Civil Society Organisations Involvement of civil society and public interest groups in locust control efforts, for example to: ● share information on the movement of swarms and their geographical situations ● develop greater awareness of the harmful effects of pesticides ● monitor the effects of pesticides on human health and the environment by the grassroots communities ● engage in advocacy with states and regional and international institutions to encourage them to increase use of alternative control methods against locusts

Early action to prevent build-up of lost swarms is the most effective way of tackling the problem - it is also far cheaper and less damaging than trying to control a full blown outbreak. However routine monitoring and control operations are too often underfunded. ● adequate and increased donor support for both innovative but also routine preventive action ● locusts do not recognise national borders, so strong regional control of operations is essential - especially in cases where civil unrest may constrain national government efforts for systematic monitoring and early control, such as the current situation in a key desert locust breeding area in Mali ● ownership of obsolete pesticides as a locust-programme problem, not a government one, and increased focus on prevention measures in operating procedures and training programmes.

Eloise Touni is a freelance international consultant on pesticide management; eloiset@gmail.com; http://gr.linkedin.com/in/eloisetouni

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European regulation

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Biocide Regulation to come into force in 2013 A new Regulation on the placing on the market and use of biocidal products in the EU comes into force in 2013. It will deliver some measure of improved protection for people and the environment from the potential negative effects of biocidal products but is by no means perfect, missing out some real opportunities for improvements. Nick Mole reports.

Biocidal products are used to combat harmful or unwanted organisms but because of their inherent properties, they can be considered as non-agricultural pesticides, their use may pose a threat to human health, animals and the environment. However, the current Directive has failed to establish a harmonised framework for the use of biocidal products and has failed to register and approve the estimated 50 000 biocidal products that are currently in use in the EU. It was clear that the Directive was too complicated and inadequate in many respects. Following pressure from industry and other concerned stakeholders the European Commission presented a draft revision in June 2009.

The new Regulation will include a number of improvements over the previous

legislation. In particular, the move from a risk based approach to a hazard based approach in the authorisation phase has brought the legislation into line with the new Regulation on the placing of plant protection products on the market. The new authorisation requirements mean that, at least in principle, any substance that is: carcinogenic, mutagenic or toxic to reproduction; persistent, bio-accumulative and toxic; very persistent and very bio-accumulative; or defined as an endocrine disrupting substance, will fail to meet the new exclusion criteria. This is without doubt a step forward and, depending on the outcome of the development of criteria for defining endocrine disrupting substances due in December 2013, could lead to many products being withdrawn from use and significant reductions in human exposure

Wetland birds poisoned by endosulfan and chlorpyrifos in Argentina

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A serious and highly visible mass bird kill occurred in Argentina in February 2012, linked to use of the insecticides endosulfan and chlorpyrifos. More than a hundred dead and dying Southern Screamer birds (Chauna torquata) were found around the edge of La Picasa lake, in Santa Fe province, to the north-west of Buenos Aires. The Southern Screamer is a large, goose-like bird that inhabits swamps and wetlands and feeds mainly on plant materials.

Toxicological analysis by the provincial Environment Department discovered endosulfan and chlorpyrifos in the digestive tract of the affected birds, leading to a conclusion of acute poisoning. Both insecticides feature on PAN International’s Highly Hazardous Pesticide (HHP) list and endosulfan was included in the Stockholm POPs

Convention in 2011, with global bans due to start this autumn. The insecticides are currently subject to severe restrictions on use in Argentina.

Environment Department officers have been investigating the pesticide storage, distribution and use patterns in the area to find out how the birds were exposed. The agency has advised the Ministry of Agricultural Production to assess the trade supply chains involved in order to find out who was responsible for the mass deaths.

Source: Argentina: Los plaguicidas endosulfán y clorpirifós causan la muerte a más de un centenar de aves chajás en La Picasa. RAPAL (PAN Latin America) news webpages 06/04/2012. Via: http://www.rapal.org/index.php?seccion=8&f=news_view.php&id =536

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to potentially hazardous chemicals throughout the EU. One of the other most significant elements of the Regulation is a labelling requirement and measures to ensure greater access to information for the public. Under the new Regulation all biocidetreated articles must be labelled if they claim to have biocidal properties or if contact with humans or release to the environment is a possibility. Upon request by a consumer, suppliers of treated articles will be required to supply information on the properties of any biocidal treatments within 45 days free of charge. Every five years, Member States will be required to publish reports on the implementation of the Regulation that detail environmental risks, poisoning incidents and the hazards associated with the use of nano-materials.

The new Regulation will also introduce controls on the use of nano materials in biocidal products such as nanoscale silver compounds that are used for anti bacterial and anti fungal purposes in a range of products that include fridges, washing machines and clothing items. Because of the unique behaviour of nano particles and their potentially toxic properties there has been concern about the effects on human health from their use. The Regulation will bring in a new system of risk assessment for such items and new labelling and reporting requirements.

The main disappointment and missed opportunity in the new Regulation is the lack of any meaningful attempt to address issues related to the use phase of biocidal products. PAN UK and its colleagues had been lobbying hard for the inclusion of a legislative framework for the use phase similar to the EU Directive on the sustainable use of pesticides. But in spite of this, there will be no requirements for the use of biocidal products to be sustainable and minimise associated risks from use.

Neither will there be a requirement for the industry to provide information and statistics on the sales and use of their products.

However, three years after the new legislation has taken effect, possibly 2016, the EU Commission must present a report on the areas that, in the opinion of environmental NGOs, require a harmonised framework. This could include the introduction of measures to reduce and minimise the use of biocides, the development and implementation of integrated pest management and for the development of common monitoring strategies across the EU. This is an area that PAN UK will be working on over the coming years.

On the whole the new Regulation is a forward step but it is far from perfect. And of course the key to its success will be in how well it is implemented across the EU.

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Factsheets

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Bee declines and the link with pesticides – PAN UK calls for action Populations of bees and other insect pollinators have fallen dramatically. The reasons for these declines are complex and wide ranging, but there is little doubt that pesticides are playing a key part.

PAN UK has produced a new set of fact sheets to cut through the confusion to provide an up-to-date and balanced explanation of the role of pesticides in pollinator declines. We are calling on the UK government and other stakeholders to commit to 12 different actions to help conserve our pollinators.

There is no doubt that pesticides that are harmful to bees and other pollinators are being used in ever increasing amounts.

Even the companies that make such pesticides do not deny their direct toxicity to bees, if sprayed or released into fields when bees are foraging or if high levels contaminate hive food sources.

What is less clear and more controversial is the role of repeated bee exposure to very low doses of pesticides, especially the neonicotinoid family of insecticides, now routinely used to treat the seeds of many crops before sowing. Neonicotinoids are a relatively new type of insecticide, increasingly used since the 1990s to control a variety of pests, such as aphids, leaf-feeding beetles and root-feeding grubs. Unlike contact pesticides, which remain on the surface of the treated foliage, neonicotinoids are taken up by the plant and transported to the

leaves, flowers, roots and stems, where the toxin remains active for many weeks, protecting the crop throughout the growing season. It is not just farmers that use these insecticides - more than 25 products containing neonicotinoids are available to the public as treatments for lawns, houseplants and greenhouse fruit and vegetables (see http://www.pan-uk.org/home-garden/listof-home-and-garden-pesticides-containing-neonicotinoids).

Neonicotinoids pose different and poorly understood risks to bees and other non-target insects due to their unintended presence in pollen and nectar, persistence in the soil, potency at extremely low concentrations and widespread use in many cropping systems. These factors build up a worrying picture of low level but continued exposure for pollinators, which governmental risk assessment for pesticides has

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failed to take properly into account.

Acutely toxic by direct contact Like many other insecticides, neonicotinoids are acutely toxic to bees and other pollinator species by direct contact or by mouth. Furthermore, they are many hundreds of times more toxic than most other insecticides, meaning that small amounts in the wrong place can have devastating consequences. Mass bee kills have occurred in several countries at maize sowing time, due to high concentrations of neonicotinoids in the particles of treated seed coating and dust released by the seed drilling equipment. Droplets of water ‘sweated’ by crop seedling leaves can contain very high levels too and may pose a risk to bees collecting these for drinking water.

Sub-lethal effects in contaminated pollen and nectar Given the scale of neonicotinoid use, pollinators now face widespread exposure to residues in their food and water. While these very low doses generally do not kill them outright, they can lead to serious, sub-lethal effects.

Residues may reach the levels known from lab studies to impair social insect health, including disruption to foraging behaviour, navigation, communication, reproduction and larval development.

Neonicotinoid toxins can persist in soil and water and be taken up by untreated plants for up to two years after the original application. Some of their breakdown products can be more toxic than the original compounds, posing a risk to hive bees and larvae.

Low level poisoning effects on individual bees can build up to colony-level harm, especially if exposure continues for several weeks. The hive can only survive and prosper if all its members can perform their various tasks effectively. Recent studies show that exposure to these insecticides at very low doses can negatively affect the immune system of bees, making them more susceptible to the impact of parasite and disease infections. Interactions within the hive between the ‘cocktail’ of different pesticides bees encounter in their environment can make sub-lethal damage even worse.

Uncertain science and vested interests lead to bad decision making

Bee foraging on dandelion

Photo: Stephanie Williamson

The pesticide industry has responded to emerging evidence from the science by questioning the results and claiming that adverse effects reported in the lab are from ‘worst case’ scenarios that don’t happen in the real, field situation. One of the problems is that very few of the handful of honeybee field studies published to date are adequately designed or conducted for long enough to properly understand the risks to

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Factsheets honeybees from low dose neonicotinoid exposure, or large enough to ‘prove’ statistically any adverse effects observed. Even less is known about impacts on other pollinators. However, two recent and robust field studies have now demonstrated that repeated exposure to very low neonicotinoid doses can stunt the growth of bumblebee colonies and dramatically reduce the production of new queens (research by Stirling University) and disrupt the homing ability of forager honeybees (research by French Agricultural Research Institute, INRA).

The toxicity tests on bees required of pesticide manufacturers are totally inadequate to assess the risks that neonicotinoids pose to pollinators. The tests focus on short term, acute toxicity to adult worker bees and mainly ignore chronic toxicity and sub-lethal effects on bee behaviour, on larvae and on hive overwintering. Pollinator exposure routes via contaminated nectar and pollen or seed drilling dust are not properly considered in the risk assessment.

Neither the ‘cocktail effect’ between different pesticides contaminating hive materials and stored food nor the interactions between neonicotinoid exposure and bee immune defences against infection by diseases and parasites feature at all.

Unfortunately, the European Commission has delegated revision of the bee testing protocols to external expert bodies, on which numerous pesticide company employees sit, constituting a clear conflict of interest.

Reflecting differences in opinion across Europe, four EU countries have imposed partial restrictions on certain neonicotinoid and other systemic insecticides in recent years.

France, Germany, Italy and Slovenia have made temporary suspensions of neonicotinoid approvals on seed treatments for maize and, in some cases, for oilseed rape and sunflower. Despite calls for similar action from 77 British MPs and a coalition of 14 environmental organisations, including PAN UK, the British government and regulatory officials continue to state that neonicotinoids pose no unacceptable risks to bees if used properly.

Can restrictions on systemic insecticides help restore bee health?

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This is a valid question raised by farmers and others in the food supply chain. The pesticide industry claims that the restrictions imposed in France from 1999 onwards did not stop losses of honeybee hives and therefore losses must be due to other factors. However, bee declines have multiple causes so it is hard to judge the impact of neonicotinoid restrictions alone on bee health. In addition, bees continue to be exposed to neonicotinoids via unrestricted applications on other crops, while bee monitoring data is often unsuitable for drawing useful conclusions.

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Clearer, convincing evidence has come from Italy, which first banned neonicotinoid seed treatment for maize in 2008.

Collecting data via a special national bee health network set up precisely to measure whether the bans have been effective, Italian researchers have documented that mass bee kills at spring sowing have now stopped and winter hive losses have declined following suspension of neonicotinoid maize seed treatments. They found no evidence that the restrictions are causing economic problems for farmers [see PN 93 p.19].

crop rotations, especially with bee favoured legumes, leaving more uncultivated areas on the farm and sowing special floral field borders for bees all help improve farmland habitat for pollinators and other wildlife.

It is not just farming practices that affect pollinators. Avoiding use of pesticides in private gardens should be encouraged and there are plenty of products and advice available for organic gardening.

Planting bee-favourite plants in gardens, parks and open spaces can expand pollinator foraging in urban and rural landscapes.

What could farmers do to rely less on neonicotinoids?

Action needed on bee-toxic pesticides

Routine seed treatment with neonicotinoids, without field monitoring of actual pest levels, has become common in Europe and the US, driven by market signals and industry propaganda. This kind of ‘insurance policy’ pest control runs counter to the basic principles of Integrated Pest Management (IPM), where decision making should be based on demonstrated need or accurate forecasting of pest attack and in which biological control and other methods are prioritised over chemical treatments.

Improved field monitoring of pest numbers and better decision support could help reduce the perceived need for neonicotinoid use. Building an ecologically-based IPM strategy, based on diversifying crop rotations, using crop varieties more tolerant of pests and encouraging natural predators of pests, can help farmers move away from reliance on neonicotinoids. More research into alternatives and investment in farmer training is needed from the government and the farming and food sectors, while agricultural suppliers could help by offering a wider range of untreated seed varieties.

EU experts now admit that the risk assessment for neonicotinoids to date has been totally inadequate – but will this prompt regulators to take these bee-toxic pesticides off the market? Growing numbers of voices among parliamentarians and academics are calling for action to address the issue and more countries are re-thinking their pesticide approvals. France has increased its restrictions further, withdrawing use of thiamethoxam on oilseed rape seed in June 2012. The European Ombudsman opened an investigation in April 2012 into whether the European Commission has taken the appropriate measures to combat bee declines across Europe, following complaints from Austria.

PAN UK is spearheading the UK NGO coalition working on bee-toxic pesticides and in Spring 2012 we coordinated a letter to the Defra Minister from 14 organisations, demanding an immediate, independent review of the science and a moratorium on UK neonicotinoid approvals and use. We support Friends of the Earth’s BeeCause campaign and their call for a National Action Plan for Bees. PAN UK is now calling for the following specific actions from the government and other sectors on bee-toxic pesticides.

PAN UK have a 12 point call for action on bee-toxic pesticides:

Improving and expanding pollinator habitats Farmers can reduce direct and indirect harm to pollinators by avoiding the use of bee-toxic pesticides and cutting back on herbicide spraying which eliminates flowering plants in field margins. Expanding

UK government: 1. Immediate and urgent independent

Bee Declines and the Link with Pesticides Factsheets:

1. Different routes of pesticide exposure 2. Sub-lethal and chronic effects of neonicotinoids on bees and other pollinators 3. Serious shortcomings in assessing risks to pollinators 4. Different regulatory positions on neonicotinoids across Europe 5. Can restrictions on systemic insecticides help restore bee health?

6. What could farmers do to rely less on neonicotinoids?

7. Opportunities for improving and expanding pollinator habitats 8. Action on neonicotinoid and other bee-toxic pesticides References for the information in this article can be found in the relevant fact sheets. The fact sheets and summary leaflet can be downloaded via PAN UK’s bee webpages at: http://bees.pan-uk.org/

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Book reviews Earth-friendly gardening John Walker is a lifelong gardener and allotmenteer, as well as being an awardwinning British gardening and environment writer with over 30 years combined experience in professional gardening, horticultural teaching and the garden media.

His book, How to Create an Eco Garden, is timely in many ways. At the moment biodiversity in the UK is suffering from huge declines; being hit hardest are some bird species, bees and other key pollinator species, butterflies, and some mammal species such as hedgehogs. Gardens can play an important role in providing habitat for these species in decline. And of course we are all trying, or supposed to be trying, to reduce our carbon footprint.

The first picture you come to upon opening the book is that of a honey bee on a verbena plant. This neatly illustrates what this book is for and why it could be so important in creating habitats for bee and other pollinator species.

The book is not just about creating wildlife habitats but covers a wide range of topics including: how to reduce your garden’s carbon footprint; how to harvest and store rainwater; worm composting; how to sow and grow vegetables; and of course how to control pests and weeds without the use of pesticides.

The author looks in depth at a number of non-chemical pest and weed control techniques that PAN UK would certainly urge any home gardener to adopt. The creation of pest barriers to stop birds and other larger pests from invading your crops has a look at the use of insect meshes, fleeces, review of the latest science and recent conclusions about the flawed EU risk assessment of neonicotinoids currently on the market.

2. Moratorium on UK approvals and use of neonicotinoids in agricultural, ornamental and amateur garden sectors until proven not to be causing harm to pollinators.

3. Commit to and support Friends of the Earth’s call for a National Bee Action Plan.

4. Build more options into entry-level agrienvironment schemes to encourage farmers to adopt more Integrated Pest Management (IPM) methods, especially biological control, which will reduce dependency on pesticides – especially as an ‘insurance’ treatment.

Food and farming sector: 5. Food retailers to put neonicotinoids onto ‘restricted’ lists within their own company standards and phase in safer IPM and organic strategies while ending the use of neonicotinoids across their global supply chains.

6. Practical research with farmers on IPM and organic strategies for replacing neonicotinoids, with a focus on oilseed rape, fruit and vegetables.

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plastic netting and fruit cages amongst others.

With 15 billion slugs in the UK they are always going to pose a problem for the home gardener and there is a whole chapter dedicated to this very subject. It starts off with a most informative paragraph on when slugs and snails are most likely to cause damage in the garden. As before he looks at a range of non-chemical techniques that can be used to deter them from your plants.

Apart from the advice on beer traps which are a personal favourite the author shows how to attract natural predators into your garden – which of course is all part and parcel of an eco garden.

When it comes to weeds the advice follows our own exactly – get digging. Not only does it get rid of unwanted weeds but is also great exercise! What is also pointed out is that weeds may be desirable plants to have in your garden: they attract insects that help with pollination and seed production, and the larvae of these same insects also feed on aphids. And freshly pulled weeds can be used as mulch and compost.

So he really asks the question; should I be getting rid of my weeds at all? There are many more informative section that covers just about everything you could want to know from flower, tree and vegetable types that are the most eco-friendly to making eco-friendly paths and compost areas. And there is a whole section on planning your garden - what the author has neatly called ‘Garden Greenprints’ - that offers outlines and ideas for different types of eco garden.

Whether you are looking to create an intensive food garden, a city courtyard garden, an eco allotment or a garden that will attract and help feed a range of different 7. Training and advice for farmers and crop consultants on effective IPM strategies based on agroecology and smarter cropping system design.

8. Collaboration between farming, retail, research and advisory, government agencies, beekeeping and civil society organisations to reduce reliance on pesticides and phase in ecologically-based Integrated Production approaches.

Ornamentals and amenity sector: 9. Ornamentals and garden supply sector to end the use of neonicotinoid treatments on pot plants.

10. Parks, local authorities and other amenity users of neonicotinoids to end their use and replace them with ecologically-based IPM strategies.

Amateur Gardening Sector: 11. Immediate suspension of sales to the public of garden products that contain neonicotinoids.

12. Offer gardeners alternative, organic products and advice for managing insect pests.

Spring 2013

wildlife this stunningly illustrated book is the one for you.

How to Create an Eco Garden – the practical guide to greener, planet-friendly gardening, John Walker, Aquamarine November 2011, 160pp, ISBN-10: 1903141893, £10.49 Available from: http://earthfriendlygardener.net/

Environmentalism since Silent Spring Silent Spring Revisited is a lovely book and is a must for bird lovers and for anybody interested in the environment. It tracks the history and development of environmental policy and nature conservation since the publication of Rachel Carson’s famous book 50 years ago. This may sound rather dry but it’s a fascinating, engaging and easy read, authored by a British environmental journalist who has worked in conservation, including with the Royal Society for the Protection of Birds (RSPB). He breaks the book up into yearly chapters of 2-4 pages each, describing not only the landmark environmental events of each year, disasters, such as the Torrey Canyon oil spill in 1967, but explaining how these events and our growing ecotoxicological understanding of the impacts of pesticides or crude oil and other environmental pressures on wildlife helped to trigger change. Jameson is particularly good at explaining how the media and public concern have been instrumental in influencing the attitudes and decisions of policy makers and politicians.

The book serves as an absorbing story of the milestones in environmental legislation, the successes and failures of different policy initiatives and practical measures, along with the increasing efforts of civil society to preserve wildlife and raise awareness of environmental threats. Between the discussion of key environmental events, Jameson weaves threads from his personal life, his growing interest in natural history as a boy, his student research, his birdwatching adventures and his professional experiences as commentator and practitioner in conservation issues. While the focus is on British events and British wildlife (not only birds but otters, voles, fish and insects), key events from other parts of the world also feature including anecdotes from the author’s time in the US and the Pacific. We get to meet key heroes and heroines of environmentalism, along with the naysayers and opponents of change. We also learn the history of how the RSPB has evolved from its 10,000 members at the time Silent Spring came out, to its million and more members today. Silent Spring Revisited should be on the bookshelf of every student of environmental sciences and obligatory reading for NGOs and policymakers, plus it works as a great Christmas present!

Silent Spring Revisited, Conor Mark Jameson, Bloomsbury Press, London, 2012, 288pp, £16.99.

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Pesticide Action Network UK PAN UK – Making a difference Pesticide Action Network UK works to eliminate the dangers of toxic pesticides, our exposure to them, and their presence in the environment where we live and work. Nationally and globally we promote safer alternatives, the production of healthy food and sustainable farming.

Pesticide Action Network UK is an independent, non-profit organisation.

We work around the world with likeminded groups and individuals concerned with health, environment and development to: Eliminate the hazards of pesticides ● Reduce dependence on pesticides and prevent unnecessary expansion of use ● Increase the sustainable and ecological alternatives to chemical pest control ●

You can subscribe to Pesticides News, donate to PAN UK and buy our publications at www.pan-uk.org

Pesticides News 94

Spring 2013

Recent publications and food insecurity for African farm families, 2010, available at www.pan-uk.org/ foodAfrica/index.html African partner leaflets 2010, about PAN’s partners in Africa, OBEPAB, Enda Pronat and the Yakaar Niani Wulli Organic Farmers Federation, available at www.pan-uk.org/ foodAfrica/index.html My Sustainable T-shirt, 2010, an updated version of PAN UK’s definitive guide to organic cotton and eco-labelling, available at www.wearorganic.org

Bee Declines and the Link with Pesticides, 2012, Fact sheets and summary leaflet can be downloaded from: http://bees. pan-uk.org/ Communities in peril: Global report on health impacts of pesticide use in agriculture, 2010, www.panuk.org/publicatio ns/communities-in-peril Paraquat: unacceptable health risks for users, 2011, http://www.evb.ch/ en/p10285.html Organic cotton systems reduce poverty

Periodicals Pesticides News – the most comprehensive quarterly source of information on pesticide problems and alternative developments. Extensive articles, resources, book reviews and news on UK, European and global issues.

Current Research Monitor – an invaluable resource for researchers. This lists up-todate scientific and specialist research covering the impact of pesticides on health and the environment. Includes abstracts, research lists and conference details.

PEX Newsletter – quarterly information and news sheet for people whose health has been affected by pesticides or who are concerned about the health effects of pesticides.

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