Translation of UIPP document “Q/R et messages clés sur l’inscription de la maladie de Parkinson (MP) provoquée par les pesticides au tableau des maladies professionelles en agriculture) July 2012 Q&A and key messages on the listing of Parkinson’s Disease (PD) caused by pesticides in the table of agricultural occupational diseases Replaces and cancels the document on the decree of 16 05 2012 The tables of occupational diseases concerning agriculture have been completed through the decree n°2012-665 of 4 May 2012 by the new table (n°58) “Parkinson’s Disease caused by pesticides”. “Table n° 58 – Parkinsons’s Disease caused by pesticides (1) DESIGNATION OF THE DISEASE TIMELINE INDICATIVE LIST OF MAIN TASKS susceptible to cause the disease Parkinson’s Disease confirmed by an examination conducted by neurologist. 1 year (provided there is an exposure of 10 years) Tasks generally exposing to pesticides: - Handling or use of these products, through contact or inhalation; - Through contact with crops, surfaces, treated animals or during the maintenance of machinery/equipment used to apply pesticides (1) The term “pesticides” concerns agricultural and amenity products, as well as biocides and veterinary parasite treatments, whether these products are authorised or not at the moment of the request. Why a listing on the occupational disease tables? After several requests of recognition as “occupational disease”, the regional committees for the recognition of occupational diseases (CRRMP – Comité Régional de Reconnaissance des Maladies Professionelles) have made different decisions on a case-by-case basis. This resulted in unfair manners of dealing with dossiers of patients in similar situations. In order to remedy that situation the COSMAP (Supreme Commission of occupational diseases in agriculture – Commission Supérieure des Maladies Professionelles en Agriculture) has taken over the dossier at national level. Two options were possible for an equitable treatment of each dossier with regard to Parkinson’s Disease in agriculture: The formulation of a national recommendation to the CRRMP The listing on the table of occupational diseases The decision to list on the table of occupational diseases has been taken after a vote1 within the COSMAP (following a compromise of social consensus), “to ensure the compensation of exposed employed workers and farm managers concerned by the disease”. It was also convened that the listing conditions on this table would be reviewed within 5 years. It shall be noted that the state counsellor made the remark on a former meeting2 of the COSMAP: “for a judge, the presumption resulting from the report established by experts would be sufficient to conclude on the causality link”. In other words, in case of doubt on the cause-effect link the judge would logically decide in favour of the sick person requesting compensation. How to read the table? Designation of the disease: Parkinson’s Disease The diagnosis of the disease is complex, it must be conducted by a physician specialised in neurology. Timeline to be considered: 1 year (provided the exposure was 10 years). This means that the maximum time between the last exposure and the risk of the disease at the 1st medical observation is 1 year AND the minimum exposure time is 10 years. Indicative list of main tasks: as indicated by the name this list is of indicative character. In other words, other, similar tasks can be considered too. Why the term “pesticides” in the table? In the table the term “pesticide” refers to agricultural and amenity products, as well as biocides and veterinary products used to treat parasites; whether they are authorised/on the market or not at the time of the request. 1 2 2 Footnote missing in original document See minutes of the COSMAP meeting of 1 June 2011 Epidemiological studies conducted in France or internationally in the agricultural domain usually cover very diverse applications/uses and exposure conditions, which are rarely described in detail. Very often these are covered by a simple question such as “have you been exposed to pesticides?”. As a consequence, the COSMAP has decided to link Parkinson’s disease to “pesticides” in general, without any detail on chemical family or individual molecules. “The recurring difficulties to document correctly with necessary detail the exposure of populations to pesticides result in bias and/or difficulties to interpret results”.3 “[The identification of a substance] in the occurrence of Parkinson’s disease is often difficult. Under these conditions the establishment of evidence of a dose-response relationship remains limited”4. Is there a causality link between Parkinson’s Disease and pesticides? No. According to the report presented to the COSMAP, “if the data generated in epidemiological studies indicated a link between the exposure to pesticides and the occurrence of Parkinson’s Disease, and if these various mechanistic studies confirm the biological plausibility of a chemical induction of the disease, they remain insufficient to establish with certitude this causal relationship.”5 The mail of the ministry of agriculture (15 June 2012) to UIPP emphasises: “{The ministry} does not conclude on the causal link between pesticides and Parkinson’s Disease, but will add to the dossier all elements/epidemiological data indicating the existence of a link between exposure to pesticides and the occurrence of the Parkinson’s disease, and that these various mechanistic studies confirm the biological plausibility of a chemical induction of the disease.” If there is no causality link between Parkinson’s Disease and pesticides why does the decree refer to it? Indeed, the Decree of 4 May 2012 in it paragraph “Note”6 specifies that “Table n°58 {…} has been created given the knowledge in humans allowing the establishment of a causality link between the Parkinson’s Disease and pesticides”. From a strictly scientific point of view this statement is not exact. It would have been more correct to write: “It (the table) has been created based on the knowledge concerning humans allowing to suspect a link between Parkinson’s disease and pesticides.” Key messages from UIPP 3 See minutes of the COSMAP meeting of 1 June 2011 See minutes of the COSMAP meeting of 1 June 2011 5 Report on the revision or set up of a table of occupational diseases on the use of pesticides – the case of neurodegenerative diseases. Pr Gérard Lasfargues, March 2010 6 footnote? 4 3 Concerning the listing of Parkinson’s Disease caused by pesticides on the table of occupational diseases UIPP understands that farmers organize themselves to have their difficulties of having their diseases taken in charge recognised. UIPP regrets the excessive generalization to all pesticides, which have different functions, belong to different chemical families with very different modes of action. UIPP reminds that those cases of Parkinson’s Disease that could be caused by pesticides reflect the exposure, the products, and the uses that have not ceased to evolve over the past 50 years: Today’s agriculture is no longer the agriculture of the 1960’s. Since 50 years, industry and public authorities based on the development of scientific knowledge have continuously worked to improve product profiles in terms of safety and support of good use practices. UIPP reminds that to date, there is no sufficient proof to confirm a causal link between the exposure to PPPs and the Parkinson’s Disease. “The origin of Parkinson’s Disease remains difficult to understand but is likely to be multifactorial, associating environmental and genetic characteristics” (report of Prof Lasfargues COSMAP, March 2010). In any case it is critical to maintain the research on the long-term effects of exposure to PPPs but also to work on the exposure reduction while handling PPPs. On the prevention of risks for farmers: UIPP reminds that user safety is part of the authorisation procedure prior to marketing. However, this safety depends on the correct handling as defined in the authorisation and on the label. To date, the MSA notes the insufficient awareness on chemical risks on the field. Indeed, user safety is not always within the user’s priorities. Getting the message across on risk prevention often implies changing current practices. For example, in terms of protection, the MSA emphasises that protection measures are not sufficiently taken into account: only 52% of users declare putting on gloves to prepare their mixes or when they fill their tanks (Report Phyt’attitude 1997-2007): http://www.msa.fr Phyt’attitude. UIPP’s and UIPP member’s actions to reduce user exposure 1. Product improvement, thanks to research and development o Improvement of toxicological profiles and of marketed molecules (improved safety: lower dosage/ha and improved toxicological profiles/ADI) o Development of product formulation: hydrosoluble bags, micro-encapsulation, progressive disappearance of wettable powders, reduction and ceasing of the use of solvents where possible… o Improved packaging: anti-splashing devices, no caps when possible o Better readability of labels 4 2. Raising awareness with farmers on good practices o Since several years UIPP has established awareness raising initiatives (School for Good Phytopharmaceutical Practices, River Basins, Training…): 15,000 farmers already trained. o Awareness raising campaigns with regard to risks linked to pesticides (“Hand” campaign (“Main”, in French). o Certain member companies also work on the field, analyse situations of most important exposures, in close cooperation with ergotoxicologists, tackling chemical risks during work (e.g. Improvement solutions for back sprayers etc.) 3. Observation and contribution to epidemiological studies o Scientific observation of epidemiological projects and studies describing the interactions between exposure to phytopharmaceutical products and health issues. o On certain health issues UIPP provides data on the use of these products with certain French epidemiological groups, such as the GRECAN (Groupe Régional d’Etudes sur le cancer/Calvados – Regional group of cancer studies) and within the Agrican framework. These will help to better understand cancer risk factors in the French agricultural environment. To know more: Conditions for the recognition of an occupational disease (see UIPP document “Occupational Health and PPP 0712”) The state of knowledge on Parkinson Disease (see UIPP document “Parkinson disease and PPP nov 2010") 5