Organophosphates like Dichlorvos have been linked with causing breast cancer, obesity and diabetes (sound like common NZ epidemics?). Do something! Make a submission to ERMA (http://www.ermanz.govt.nz/news/erma-media-releases/Pages/Dichlorvos-submissions-sought.aspx) to ban Dichlorvos.
The following is the submission Doctors Enviro Voice has made. Please feel free to copy it/ add subtract/ make your own one.
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Submission to: ERMA New Zealand
Subject: Application HRC08004 – Reassessment of Dichlorvos
By: Dr. Elizabeth Harris Representing the group Doctors EnviroVoice
Contact: Dr Elizabeth Harris
Date: 17th February, 20101
I wish to be heard at a public meeting
Decision sought:
(i) Immediate revocation of all domestic use, use in hospitals, schools or other residential or public buildings
(ii) Immediate revocation of all outdoor uses including glasshouses, mushrooms houses, commercial and industry premises
(iii) Phase out within 1 year all indoor uses
(iv) Retain use in impregnated strips for Biosecurity traps until less harmful alternative is found – review this use within 5 years
(v) Disallow manufacture in New Zealand
Doctors EnviroVoice agrees with ERMA that all outdoor uses should cease.
However our group is of the view that the use of dichlorvos indoors should also cease because of risks to human health, and especially to children through domestic and public use. ERMA’s assessment shows that it poses very high risk to children from exposure to treated surfaces so it is unacceptable to allow any further use in areas in which children may be exposed.
Reasons for seeking this decision:
1. Research supporting a link between Dichlorvos and obesity.
Dichlorvos has been shown in research to be linked with increased rates of obesity. As NZ – along with other western nations faces an epidemic in this area, it is important for us to address all possible causes. In the e-mail to which this submission has been attached, the references to back this position have been included.
ERMA has not assessed the risk of diabetes and obesity. Organophosphate exposure has been shown repeatedly to be associated with hyperglycemia in animal models (Montgomery et al 2008; Rezg et al 2010). Dichlorvos specifically has been shown to disrupt glucose homeostasis in male Wistar rats. Applicators exposed to dichlorvos had increased odds of diabetes and the odds increased with increasing cumulative days of use (Montgomery et al 2008). Organophosphates have also been shown, both in laboratory studies and epidemiological studies to increase the risk of obesity (Rezg et al 2010)
2. Research indicating a link between organophosphates such as Dichlorvos and breast cancer.
Increasing research supports the concept that environmental exposures at an early age may contribute to increased breast cancer risk in adulthood. Organophosphates have been linked to increased rates of breast cancer. In a country where the risk of breast cancer is presently around 1:8, any potential exposure to organophosphates must be taken seriously. The concept of having these substances allowed in indoor environments where children and women will be exposed needs to be addressed and Doctors EnviroVoice calls for ERMA to ban the use of Dichlorvos in any setting.
A number of laboratory studies have shown elevated rates of mammary tumours in rodents (Gandhi & Snedeker 1999). These findings have not been taken into account in determining carcinogenic risk to humans.
P222 of the assessment reports ATSDR (1997) as saying dichlorvos has not been found in breast milk. However Gandhi & Snedeker (1999) report that it has been found in breast milk in Taiwan.
3. High acute and chronic toxicity including other forms of cancer
Dichlorvos is highly acutely toxic, and mutagenic and carcinogenic in animals, with reasonable certainty that it is also mutagenic and carcinogenic in humans.
ERMA’s assessment did not take into account epidemiological studies that have indicated increased risk of leukaemia, non-Hodgkin’s lymphoma, multiple myeloma and childhood brain cancer from exposure to dichlorvos.
3. Alternatives
Although ERMA evaluated alternative plant protection products, pesticides, it failed to evaluate alternative plant protection methods. All of the crops for which ERMA is proposing continued use of dichlorvos are grown without the use of this pesticide under organic management systems – but ERMA has not evaluated these systems and their practices.
There are a multitude of methods for management of insects indoors without using dichlorvos, including yellow sticky paper strips, sticky board cockroach traps and many other environmental management techniques none of which have been evaluated by ERMA, but which are found effective by those who use them.
Concluding remarks:
The assessment acknowledged that ERMA is obliged by its own published Methodology to take into account the need for caution in managing the adverse effects of the substance, where there is scientific and technical uncertainty. There is sufficient certainty that dichlorvos is highly toxic to humans.
It has only been in the last 1-2 decades that the field of environmental medicine has seen a rapid rise in the research supporting the concepts that environmental exposures may be playing a much larger part in public health than we previously realized.
The research linking organophosphates like Dichlorvos to both obesity and breast cancer – present New Zealand health epidemics costing our health system millions of dollars- can not be ignored and as a group of doctors we wish to make the stand that we need ERMA’s assistance. Simply put – we can not fight the battle of these twin epidemics alone and request legislative protection for the patients we, and other doctors in New Zealand treat.
The only uncertainty evident here is whether or not there are sufficient alternatives currently available, and this uncertainty exists partly because ERMA failed to assess alternative non-chemical methods of management. Thus the apparent paucity of chemical alternatives for some uses is not sufficient reason to allow continued use of this highly dangerous pesticide and no further use can be countenanced.
References:
Gandhi R, Snedeker SM. 1999. Critical Evaluation of Dichlorvos’ Breast Cancer Risk. Critical Evaluation # 7. Program on Breast Cancer and Environmental Risk Factors in New York State (BCERF), Cornell University. http://envirocancer.cornell.edu/criticaleval/criticaleval.cfm.
Montgomery MP, Kamel F, Saldana TM, Alavanja MCR, Sandler DP. 2008. Incident diabetes and pesticide exposure among licensed pesticide applicators: Agricultural Health Study, 1993–2003. Am J Epidemiol 167(10):1235-46.
Rezg R, Mornagui B, El-Fazaa S, Gharbi N. 2010.Organophosphorus pesticides as food chain contaminants and type 2 diabetes: a review. Trends Food Sci Technol