This guidance informs Inspectors and Complaints Officers of the role of HSE's Pesticide Incidents Appraisal Panel (PIAP), and the subsequent use made of the information collected and contained in pesticide incident investigation/follow up reports and associated papers.
PIAP has been increasingly concerned for some years at the paucity of relevant and usable information contained in many of these reports.
The purpose of this guidance is to raise awareness of the role of PIAP and to remind Complaints Officers and Inspectors of the instructions contained in HSE's complaints procedures for dealing with pesticide related incidents which involve an allegation of ill health.
Inspectors and Complaints Officers should investigate all pesticide complaints in accordance with HSE's complaints procedure.
In the event of pesticides incidents where ill health is alleged, Complaints Officers and inspectors should:
Pesticides are biologically active substances and are subjected to a thorough screening process before being approved. No pesticide may be sold, supplied, stored or used unless it has been formally approved for each of these purposes.
This screening is intended to ensure that all pesticides are 'safe' when properly used i.e. used in accordance with the Conditions of Approval and Consent. However, a measure of uncertainty will always remain as no chemical substance can ever be declared to be absolutely safe, no matter how rigorous the screening process.
As part of the process of post-approval surveillance, all investigation reports of incidents of alleged ill health resulting from the use of pesticides are submitted to the independent Pesticides Incident Appraisal Panel (PIAP).
Post-approval surveillance of pesticide products is essential to detect any health effects that may not have been identified by the initial approval process. PIAP makes a valuable contribution to this process.
PIAP considers all reported incidents of ill health which are alleged to have been caused by exposure to pesticides used at work. It is informed of these incidents only when the investigation has been completed, at which time it is supplied with copies of the investigation/follow up reports. PIAP itself does not carry out any further enquiries or investigation and relies entirely on the information collected by FOD staff.
In many cases judgment cannot be made by PIAP members because of a lack of information to show that the person was actually exposed to a pesticide. The main shortfall continues to be the availability of corroborating medical information (from a GP or hospital) and the non-return of signed consent forms from the complainants concerned. In addition, many reports state the wind speed and direction but do not include information about the location of the person (alleged to be affected) in relation to where the spraying was taking place.
Key factors are
A sketch or map is a good way of presenting this information.
The main purpose of PIAP is ‘to provide an overview of alleged ill health attributed to pesticide exposure (as reported to and investigated by HSE) so that new issues and trends can be identified, and to inform the pesticides approval process’.
To fulfil this purpose, PIAP considers individual incident and case reports, not to establish the cause, but to consider the strength of the association between exposure and ill health. During recent years the panel has continued to assess reports based on the ‘balance of probability’ from available information and not, as before, ‘beyond reasonable doubt’. For further details see appendix 1 and 2.
PIAP reports its findings annually to the Government's Advisory Committee on Pesticides (ACP) which in turn advises Ministers and feeds back into the approval process.
PIAP also prepares an annual report of pesticides incidents that, again, relies entirely on information extracted from investigation/follow up reports. This report is published on the agriculture section of the HSE website.
All complaints that involve an allegation of ill health relating to the storage or use of pesticides (see step 3.3 of the complaints procedure) should be referred to a Band 2 inspector (Step 2.3 and 3.5 of the complaints procedure).
For all pesticide complaints, the date the complaint was received, the date the incident was alleged to have occurred and the substance sprayed or otherwise applied (if known), should be provided. Remember to select a Speciality Type of ‘Pesticides’ for all pesticide complaint and treat allegations of ill health as ‘RED’.
Refer the assessed complaint to a Band 2 for a decision on investigation and or follow up (Step 2.3 and 3.5 of the complaints procedure).
When all action has been completed send full details (i.e. complaint and duty holder proforma(s): ‘Form Pest A’ and ‘Form Pest B’ and associated medical papers; COIN reference numbers etc.) to the Agriculture and Food Sector at the Nottingham Office (Step 3.7 of the complaints procedure).
NOTE: COIN entries should not contain sensitive medical information on named/identifiable individuals. Further advice can be found in HSE’s information sheet ‘Confidential Medical Information and Consent' and 'Guidance on Medical Information Requests'.
Further information can be found in HSE's complaints procedures.
For further advice, Complaints Officers and inspectors should contact Agriculture & Food Sector - Health, Education & Employment Section, Operational Strategy Division (OPSTD), 1 Hagley Road, Birmingham, B16 8HS.