Past ICOH activity on pesticides has tended to reflect an industry orientation rather than a broader agenda in this field. Industry is directly or indirectly involved in the decision-making process about pesticide testing, approvals, and regulation, and is the source of primary toxicity data through its own or contracted laboratories.

Subject:   Why is it so Hard to Promote Environmental Health-------
 Date:      Sun, 05 Dec 1999 18:57:33 -0500
From:     Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)
To:     Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>

Dear Lyndon, I thought you might like to read a report authored by: Andrew Watterson, Ph.D., Centre for Occupational and Environmental Health, De Montfort University, Scraptoft Campus, Leicester, LE7 9SU, United Kingdom 44-116-2577735, FAX 44-116-2577708, and his E-mail address is: aew@dmu.ac.uk - (as always I have added a little "clarity" in parenthesis.)

THE ROLE AND FUNCTION OF ICOH  - past problems, future solutions

The movement from information and debate to advocating policy in the field of occupational health is often fraught and complex. Not all occupational health organizations espouse a clear policy role, but the International Commission on Occupational Health (ICOH) does. A leading ICOH official in 1998 declared that ICOH principles emanating from the 1900s were "to influence national and international policies in developing prevention of occupational hazards, to promote workers’ health, to assert professional ethics…".(1) The application of these principles by the ICOH, especially in terms of what policies to influence, by whom, for whom, and on what basis, using ethical and transparent methods, presents major and important challenges for the organization.

The generation of chemical toxicity data, data categories, their interpretation and meaning have always been problematic although industry considers that such data are usually extensive and comprehensive enough to ensure high levels of user or consumer safety. The difficulty for industry has been that complete risk assessments of many of their product (POISON) categories have been incomplete – sometimes very incomplete – as was the case with ethylene dibromide, DBCP, and DDT. The additional problem with pesticide toxicity assessments relate to their necessary use outside the ‘controlled’ setting of the factory. Nonetheless, agrochemical companies argue that their products (POISONS) are more rigorously and carefully vetted than any other group of chemicals. This in itself presents no guarantee that either approval for active ingredients or (the ignored) inert ingredients are adequate in terms of occupational health and safety.

Past ICOH activity on pesticides has tended to reflect an industry orientation rather than a broader agenda in this field. Industry is directly or indirectly involved in the decision-making process about pesticide testing, approvals, and regulation, and is the source of primary toxicity data through its own or contracted laboratories. The problems associated with global corporate policies and their adverse effects on occupational and environmental health standards have been documented and can inform current debates about pesticide risk management.(2)

Bodies such as ICOH have, in workshops and conferences, and even in organizational funding, worked closely with the agrochemical industry on occupational health and safety issues. Yet other interest groups with a different perspective have not been actively encouraged to involve themselves if they were ever aware of ICOH work in this field.  Even now such groups may find many hurdles in the way of effective participation in ICOH’s policy process: such obstacles include the costs of travelling to international meetings. Yet ICOH has identified a central role for itself in "the development of occupational health, including for agricultural workers",(3) and hence on pesticide hazards through the ICOH Scientific Committee on Pesticides and other committees on agriculture and education and training in occupational health.

The ICOH has acted as a major forum for discussion, debate and information on chemical health and safety, including the risk assessment and risk management of pesticides for many years.(4)   Such work has entailed some debate in ICOH publications about ethical issues relating to research on chemicals.(5) The ICOH identified the task of ‘strengthening ICOH links with the ILO and WHO through the participation of ICOH members in technical working groups of these international bodies’ in the 1990s.(6)  The selection, role, function, responsibility, and accountability of such members is of vital importance. The position is complicated further by the fact that ICOH members will almost always have multiple roles: as employees in industry, universities or research institutes, professional functions, or as ‘nominees’ or ‘representatives’ of ICOH. Teasing out these roles will be important in any advice or information provided to ILO and WHO committees or through commentary on or authorship. The ICOH Code of Ethics in recent years has attempted to address some of these tensions and conflicts but it is difficult to identify how precisely the Code has been implemented, monitored, and by whom.

An analysis of ICOH membership by country and by company in 1999 shows that at least some members come from a large number of major companies which either now or in the recent past produced or marketed agrochemicals or from companies with agrochemical interests.(7)   BASF, DuPont, Dow, Union Carbide, Rhone Poulenc, Roussel Uclaf, BP, Scherring, Akzo Nobel, Bayer, ICI, Zeneca, Unocol, Enichem, Ciba Geigy, PPG Industries, Otsuka, Mobil, Shell, WR Grace, Monsanto and Rohm and Haas all have ICOH members in 1999.(8)   The ICOH members in these chemical companies come from 18 different countries. Chemical industry and agrochemical industry staff have legitimate, open, and bona fide membership in ICOH.  However, industry influences extend much further and it has been noted that "private sector interests take hold in organizations such as ICOH because these groups allow members to represent vested interests under the guise of academic neutrality".(9)   Unfortunately, in the absence of organizational transparency, conflicting interests may not emerge or become clear.

It would therefore be of value if the research and consultancy interests of all ICOH members were declared or perhaps recorded in register as a step towards greater openness and transparency in the organization. Without such a registry of potential conflicts of interest open to all it, will be impossible to assess the extent or the limits of direct and indirect agrochemical industry influence on the ICOH. It would be equally beneficial to ICOH in terms of its credibility and balance if it actively encouraged NGOs working for instance on pesticides and trade unions to participate in ICOH workshops and conferences in the way that pesticide companies have clearly been involved.

ICOH membership by company and country related to pesticide/chemical marketing, 1999.
 

COUNTRY	COMPANY
ARGENTINA	BASF, DOW, DU PONT
BRAZIL	DU PONT
CANADA	UNION CARBIDE
DENMARK	AKZO NOBEL
FRANCE	RHONE POULENC(2), ROUSSEL-UCLAF, SHELL,BP
GERMANY	SHERING AG, DOW, BASF
HONG KONG	SHELL
INDIA	BAYER
INDONESIA	ZENECA, UNOCAL
ITALY	SOLVAY, PPG INDUSTRIES, ENICHEM, CIBA GEIGY
JAPAN	OTSUKA
MEXICO	ZENECA
NETHERLANDS	DOW, SHELL(2)
NIGERIA	MOBIL
SINGAPORE	SHELL
SPAIN	BP
UK	SHELL(2), ICI(2), ZENECA
USA	WR GRACE, ROHM & HASS (2), UNION CARBIDE (3), BASF, MONSANTO

 

[Sources: The Pesticide Index: Marketing Company Index1995, ICOH Membership Directory 1999]

A brief historical perspective illuminates some of the issues surrounding the past work of ICOH on pesticides.

Since the early 1970s a great deal of international work has been conducted on pesticide use reduction strategies, and integrated pest and crop management programs using biological, cultural and chemical means to control pesticide abuse. (9-11) These approaches for many are the major starting points for improved occupational health and safety in both international food production and public health programs. To some extent the agrochemical industries themselves have acknowledged the value of such approaches. Yet such approaches have been neglected if not ignored by virtually all ICOH meetings and conferences. This may partly reflect the fact that ICOH has recruited physicians and scientists whose primary work has been in the diagnosis and treatment of disease. It also may reflect the fact that research which is funded by agrochemical industries in academic institutions tends to answer questions about the use of their products (POISONS) rather than the reduction or removal of their products (POISONS) from sale. This emphasis is understandable but is surely no longer desirable in an international organization which purports to advise the WHO and IPCS.

Between 1971 and 1986, the ICOH Scientific Committee on Pesticides organized 6 workshops. Five had themes relating to issues surrounding the toxicology, epidemiology, biological monitoring, classification of pesticides, and the exposures of pesticide workers. One meeting explored education and safe handling in pesticide application.(12)   None of the ICOH workshops explored the issues of pesticide reduction and integrated pest management schemes as a means of cutting pesticide poisoning incidents. (Doesn't this sound familiar Lyndon?)

In 1986 there were 8 listed members of the ICOH Scientific Committee on Pesticides, and one observer. Of the 8 members, 2 either worked for or had worked for major agrochemical companies. The workshop on pesticides organized that year by ICOH had 33 participants. Eleven were from agrochemical companies (FBC, ICI (2), Dow, Shell (4), CibaGigy, Bayer (2): none came from the ILO, and none represented NGOs or trade unions. The research funding and consultancy interests in agrochemicals of the academic and governmental representatives was not available. Clearly the workshop could only explore a partial picture on biological monitoring in practice when it excluded physicians and occupational hygienists working for or with NGOs and trade unions who were aware of and increasingly concerned about pesticide (POISON) exposure.

Between 1993 and 1996, Dow Chemicals Europe were listed as sustaining members of ICOH. (13-15)   Prior to 1995 the ICOH Scientific Committee on Pesticides was chaired by an agrochemical company staff member and in 1994/5 the secretary of the group worked for the agrochemical company Zeneca UK. At this time, the ICOH Scientific Committee on Pesticides was a prime mover in producing a manual on the health surveillance of pesticide workers and organized a workshop on the health protection of workers exposed to pesticides at a major conference.

The 1994 conference workshop at the 14th Asian Conference on Occupational Health in Beijing, China focused on health protection of workers exposed to pesticides. The pesticides workshop contained contributions from academics, government scientific researchers, Zeneca Agrochemicals, and a representative from the International Agrochemical Industry Group (GIFAP). There were no papers from non-industry NGOs, and there were no papers from worker groups or their representatives directly involved with pesticide (POISON) hazards that would have provided a very important and different perspective to the event.

In 1995 the ICOH committee had 24 members and 2 officers. Of the members, one came from Bayer and one from Shell. However, the extent to which other members received research and consultancy grants from the agrochemical or agricultural industry remains unclear. In 1996, the ICOH offered guidelines for its scientific committees and stated that "Scientific Committees must remain scientifically objective. When a conflict of interest occurs with meetings, sponsorships, publications, etc., the officers of the ICOH will require full disclosure of the conflict and the authority to properly intervene".(16)   How precisely this has been and will be implemented in terms of ensuring that participants in ICOH meetings, for instance on pesticides (POISONS), and readers of ICOH published reports and conference proceedings are aware of the affiliations or funding of contributors is unclear. Many organizations and medical journals have been able to disclose conflicts of interest without closing down debate or discussion. The ICOH should ensure that similar practices occur in 2000 to provide transparency in all their various committees.

In 1997 the ICOH Scientific Committee on Pesticides had 37 members. Four came from agrochemical companies and a number of other members had worked for the industry in the past. In 1998 the ICOH Scientific Committee on Pesticides proposed a workshop on Chronic Neurotoxicity of Organophosphorous Pesticides. The organizers sought the participation of the European Union, and once again to "secure the participation and support of industry". Contacts had already been made with the European Association of Agrochemical Manufacturers (ECPA) as possible partners in the initiative. No mention is made of the need to forge partnerships also with other NGOs and their representatives working in the field of pesticide (POISON) health and safety – bodies like PAN and the trade unions organizing agricultural workers who might well have a different but valuable perspective on the research, diagnosis, and solutions to organophosphate poisoning.

The ICOH could be strengthened by addressing these matters further in terms of its membership, events, and recruitment strategy, and in its scientific committees where there may be difficulties for workshops and conferences to ensure a wider participation than now occurs at the major ICOH events. A wider, more balanced, and more open debate is needed within ICOH about issues central to occupational health as well as the diagnosis and treatment of workers affected by pesticide (POISON) usage. The ICOH is committed in its constitution to "the development of occupational health in all its aspects" through a wide and multi-disciplinary membership.(17)   Its committees must develop a broader and less industry-focused membership, and sponsor meetings that have as their major objective the prevention of occupational disease.

REFERENCES

1. ICOH. Editorial by J-F Caillard ICOH. Quarterly Newsletter. 4 December 1998;17:5-8.

2. Castleman B. Global corporate policies and international "double standards" in occupational and environmental health. Int J Occup Env Health 1999;6:61-64.

3.  Jeyaratnam J. (ed) Occupational Health in Developing Countries. Oxford, Oxford University Press, 1992.

4.  World Health Organization. Occupational Health in the Chemical Industry. WHO, Copenhagen, 1992.

5.  Soskone CL. Ethical, social and legal issues surrounding studies of susceptible populations and individuals. Env Health Perspectives 1997;105:Supplement:4837-841.

6. ICOH. Triennial Report of the International Commission on Occupational Health 1993-1995. ICOH, Singapore, 1996.

7. Copping LG, Kidd H, Tomlin CDS (eds). The Pesticide Index. 3rd ed. British Crop Protection Council/ Royal Society of Chemistry, Farnham, Surrey, 1995.

8.  ICOH. Membership Directory - 1999. ICOH, Singapore, 1999.

9.  LaDou J. ICOH caught in the act. Arch Environ Health 1998;53:247-8.

10. Debach P. Biological Control of Natural Enemies. London, Cambridge University Press, 1974.

11. Bull D. A Growing Problem: Pesticides and the Third World Poor. Oxford, Oxfam, 1982.

12. ICOH. Biological monitoring of workers manufacturing, formulating and applying pesticides. Proceedings of the 7th International Workshop of the Scientific Committee on Pesticides of the ICOH. Szeged, Hungary. Toxicol Lett 1986;33:1-236.

13.  ICOH. Sustaining members of ICOH.  ICOH. Quarterly Newsletter. 1994;13:53.

14.  ICOH. Sustaining members of ICOH.  ICOH. Quarterly Newsletter. 1995;14:73.

15. ICOH. Sustaining members of ICOH.  ICOH. Quarterly Newsletter. 1996;14:53.

16.  ICOH. Guidelines for ICOH Scientific Committees. ICOH Quarterly Newsletter 1996:15:17-18.

17. Hernberg S. The International Commission on Occupational Health. Past and present. Scand J Work, Environ Health 1993;19:66-67.

18.   Watterson A. Pesticide Users’ Health and Safety Handbook: An International Guide. Gower Technical Press, Basingstoke and Van Nostrand Reinhold, New York, 1988/89.

Well Lyndon, when will it be "legal"  (in your opinion) to stop poisoning people, pets and the environment with your "registered" POISONS and to safely and effectively control pests in California with any of the thousands of unregistered Safe/GRAS/Food Grade alternatives?  Do you want to Promote Environmental Health or the use of "registered" POISONS in California?

Respectfully,  Stephen L. Tvedten
 

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