Measuring and concealing: the risks of occupational pathologies caused by pesticides

8Just like medications, pesticides are chemical substances for which commercialisation is subject to prior administrative authorisation, which aims both to verify their agronomic effectiveness and to control their potentially harmful effects on human health and the environment. The homologation framework, created in France by the Vichy regime in 1943, was progressively formalised over the second half of the twentieth century, in particular at the instigation of the European Union. It means that every industrialist who seeks to commercialise a phytosanitary substance must submit an application to an evaluation commission, in which all the toxicity data for the substance are provided in detail, regarding both the environment and human health – in particular, addressing consumers of fruit and vegetables and workers exposed to the substance. In France, this evaluation was initially entrusted to an expert body within the Ministry of Agriculture, the Commission for the Study of Toxicity (frequently called Comtox), made up of appointed experts and Ministry representatives. This Commission was active until 2005, when it was dissolved, at which point the evaluation of files relating to the toxicity of pesticides was entrusted to the French Agency for Health and Food Security. From 2010 on, it was then transferred to the French Agency for Food, Environmental and Occupational Health and Safety.

9One of the aspects of homologation consists in avoiding damage to the health of agricultural workers by commercialised pesticides. Although formal requirements for pesticide manufacturers have been strengthened over the years, their rationale has not changed very much, and remains the same today as when Comtox was dissolved. Any industrialist seeking approval for a pesticide must provide the results of in vivo toxicity tests which determine the “LD 50”, [31] or the dose at which half the test population of animals died. The lower the LD 50, the more toxic the substance. By reducing the dose of exposure, the manufacturer is required to find the “no-impact dose” for which no negative effects occurred in the population of animals exposed to the product for a period between one month and two years. By applying a security factor of 100, supposed to account for the biological differences between humans and animals (inter-species variability), to the no-impact dose, the manufacturer thus determines the Acceptable Operator Exposure Level (AOEL), or the “acceptable” level of exposure for those who use the substance. As far as the protection of workers is concerned, approval is granted if under normal conditions of use, the routine exposure of workers does not exceed the AOEL.

10The evaluation of workers’ exposure in the context of this homologation has been progressively formalised. Made compulsory from 1991 by European Directive 91-494, it was then codified by the guidelines of the OECD. Most often, evaluations are conducted using models that estimate exposure according to a number of different parameters: type of crop, maximum quantity produced per hectare, mode of treatment (application by spray, powder, tractor, airplane, portable sprayer, seed treatments), etc. If the level of exposure estimated is inferior to the AOEL, then the requirements of the industrial hygiene aspect of approval are essentially fulfilled. If this is not the case, the manufacturer may attempt to prove that the wearing of protective equipment that is either individual (gloves, masks, suits) or collective (tractor cabins) means that the product can be used without exposure to doses exceeding the AOEL. In any event, once approval is granted, the “agricultural best practice” supposed to guarantee the user’s safety is detailed on product labels.

11The industrial hygiene dimension of approval helps bring to light certain effects of pesticides on workers’ health. But the instruments upon which this approval is based only give – by design – limited access to the observation of the illnesses provoked by occupational exposure to pesticides. This limitation is linked to the fact that, because of the methodological constraints they are subject to, these instruments contain certain assumptions concerning the nature of agricultural workers’ exposure to pesticides. These premises establish a particular way of conceiving the causal links between agricultural use of pesticides and workers’ health. Like any form of laboratory modelling, the in vivo toxicity tests used by the approval process work on the basis of “reduction and transfer”, [32] well documented by studies of the evolution of industrial hygiene and its transformation into regulatory science over the course of the twentieth century. [33] This form of knowledge indeed “transfers” its object (the study of the effects of a toxic substance on human organisms) from the field to the laboratory. The experimental conditions in which these tests take place cannot reproduce the real conditions of occupational exposure to pesticides. Instead of fields, the tests use exposure chambers in which the products are isolated; instead of agricultural workers they use laboratory animals genetically selected to offer low physiological variability to the substances in question. This way of acquiring knowledge about the toxicity of the pesticides that workers are exposed to is therefore limited. Toxicologists are materially limited to working over relatively brief timescales (the vast majority of tests enabling the establishment of a no-impact dose take place over 28 days), and with doses that are relatively high. The quantity of animals necessary to observe statistically significant effects with low dose, long-term exposure would be phenomenal. In practice, toxicologists are obliged to operate with extrapolation in order to evaluate the effects of pesticide exposure on agricultural workers.

12The protection of agricultural workers via the homologation process is thus based on information that primarily identifies the effects of occupational exposure to relatively high doses of the identifiable phytosanitary product over a short period of time. Yet the real exposure of real workers to real pesticides takes place “in the wild”: the experimental conditions of the in vivo tests conducted in “confined” laboratory [34] conditions do not reflect the true complexity of exposure. Although the actual process of treating plants with phytosanitary products in itself (the preparation of the product, the application and cleaning of material) may incorporate exposure to high doses of the product, agricultural work also leads to many other situations of occupational exposure to pesticides. Once the application of phytosanitary products has taken place, the substances take time to be absorbed by the plants, to permeate the air, the ground or the water. The physiochemical destiny of a given phytosanitary substance varies depending on factors that are characteristic of the space and time of application: humidity, rainfall, sunlight, soil composition, wind speed, plantation type, [35] etc. Workers may be exposed after treatment, when they work in the fields (irrigation, pruning, etc.) and in the days and weeks after the application of the product. Effects of this kind of repeated low-dose exposure are barely “perceptible” [36] by the instruments upon which homologation is based. These instruments enable the administration responsible for agricultural policy to see the harmful effects of pesticides on workers’ health whilst simultaneously “limiting their vision” [37] of the problem.

13Yet these effects, often imperceptible to in vivo tests, differ from those occasioned by sporadic high-dose exposure. The high toxicity of pesticides most often provokes effects that are relatively benign (headaches, diarrhoea, skin irritation, etc.), if occasionally spectacular, and are reversible. Repeated low-dose exposure, on the other hand, is more likely to provoke serious pathogenic effects: cancer, neuro-degenerative disorders, non-Hodgkin’s lymphoma, reproductive disorders, [38] etc. The reliance of homologation policies on in vivo toxicity tests tends to neglect these types of occupational pathologies. [39] Other forms of scientific testing are better suited to document these kinds of effects. In particular, this is the case for epidemiological studies, several of which have shown over the two last decades the prevalence of certain pathologies among agricultural populations exposed to pesticides. For a long time, however, there were no studies of this type in France, and it is only over the last ten years or so that the first among them (including the most important, which has yet to publish its results) have appeared.

14In spite of these lacunae, in vivo toxicity tests rapidly became and still remain today “indispensable instruments of prescription” [40] to ensure the protection of agricultural workers exposed to pesticides. They do present the advantage of expressing the pathogenic effects of these substances according to a quantifiable variable, the exposure dose. In so doing, they allow the government to consider occupational illnesses caused by pesticides as a measurable risk – and as a result, a manageable one – by using the exposure limits, rather than as a threat to be eradicated through the use of prohibition measures. This way of bringing to light the danger of pesticides for workers is in fact in strict conformity with the productivist direction of agricultural policies in the post-Second World War period, and the promotion of the mass use of synthetic chemicals to guarantee harvests. In allowing for the risk of occupational illnesses due to pesticides to emerge, the homologation process constitutes a powerful vector of “acceptability” for the threat that phytosanitary treatments can pose to the health of agricultural workers. Although over the course of its history, Comtox came to take a stand against the approval of certain pesticides due to the danger they posed for workers, most refusals for approval of products were linked to their low levels of effectiveness rather than their harmfulness for workers, [41] which had long been considered a manageable threat.

The birth of a desire for knowledge

15However, the testing of pesticides during the homologation process does not guarantee their harmlessness in occupational use, even if we only take into account the effects of intense poisoning. Acceptable doses of exposure can be surpassed in real use conditions, just as the recommendations regarding the use of protective equipment may be only imperfectly followed. Professional use of pesticides may thus provoke pathologies amongst agricultural workers. The prevention of these pathologies is part of the mission of the Mutualité sociale agricole (MSA), the private joint [i.e. managed by both employers and employees] organisation responsible for the management of the agricultural sector’s social security requirements since the beginning of the 1950s. However, for a long time the MSA did not pay much attention to this issue, as we can see by the near-absence of clinical tables of occupational illnesses relating to this question. [42] Out of the fourteen first clinical tables of occupational illness in agriculture created in 1955, only two concerned the most dangerous pesticides. These tables mention only those pathologies related to high-dose exposure. [43] Following this, even the best established data on chronic toxicity have consistently struggled to make it into these tables. For example, it was only in 1986 that Table 10 recognised the occupational origin of certain cancers caused by arsenic and its derivatives, the carcinogenic nature of which had already led Comtox to recommend their prohibition at the beginning of the 1970s.

16Within the MSA, two categories of staff concentrate on work relating to the prevention of occupational illnesses. The first consists of occupational physicians in agriculture, whose status was outlined in the law of 26 December 1966, twenty years after the establishment of occupational medicine as part of the general framework of French social security provision. The second is made up of prevention consultants, which the MSA began to employ in the 1970s to conduct training and information missions with those working in agriculture. For a long time these actors played a very limited role with regard to knowledge about illnesses linked to the occupational use of pesticides. [44] At the end of the 1950s, the National Institute of Agricultural Medicine (INMA) was established in Tours, and thus began a reflection on the links between pesticides and workers’ health. Ultimately, however, this reflection was short-lived and was neglected throughout the 1970s. [45] However, at the beginning of the 1980s, a small group of occupational physicians specialising in agriculture and working for the MSA, along with leaders from the INMA, began to be more concerned about this problem. [46] Their thoughts on the subject led to a 1984 investigation of agricultural workers using pesticides, under the auspices of Jacques Fages (who was then responsible for occupational medicine at the central body of the MSA) and Jacques Bonderf (director of the INMA and an MSA occupational physician in Tours). This investigation consisted of a questionnaire distributed to 2,000 agricultural workers in around ten different départements [administrative areas] in France. The questionnaire was very concise, containing only six questions, most of which concerned their use of pesticides during the previous year (names of products, quantities, combinations, length of treatment etc.) and the use of protective measures (gloves, masks, suits, showering after treatment). It also included a range of questions related to possible occurrences of illnesses caused by pesticides. These questions revealed the overwhelming contamination of agricultural workers by pesticides: close to one in five respondents mentioned problems that occurred following exposure to a phytosanitary product during the previous year.

17This tool for drawing attention to the effects of pesticides on workers’ health was permanently established at the beginning of the 1990s in the form of a toxicity surveillance network set up by the same group of doctors. This network, initially established in two agricultural areas (Indre-et-Loire and Sarthe) and then extended to the rest of France in 1997, still operates today with the aim of collecting and processing reports of pathologies linked to the use of pesticides. These reports must be addressed to an MSA agricultural occupational physician. The reports can be made directly by the workers who have been the victims of poisoning, whether they are farm owners or employees. The latter are required to undergo a compulsory medical examination; this provides the opportunity to report a poisoning incident that may have occurred in the previous year. Third parties can also make these reports to the occupational physician: the employer, if the victim is an employee, or their general practitioner or specialist, or the MSA’s prevention consultant, if s/he becomes aware of a poisoning incident. The occupational physician must then transmit the report to one of the toxicologists working in the poison control centres associated with the toxicity surveillance network, which are responsible for deciding whether the problem reported can be imputed to the product used by the victim. For the last twenty years, this framework has constituted the main form of “post-homologation control” for pesticides, after the latter have been authorised for commercial use. It produces data regarding the poisoning of agricultural workers using these pesticides, which is aggregated in databases containing information about the circumstances of contamination, the products involved, the crops most at risk, the age of the victims, etc. Between 1997 and 2007, the toxicity surveillance network collected 1,909 reports, 1,554 of which were confirmed and integrated into the database. [47]

The normalisation of pathology

18The toxicity surveillance network is closely linked to the homologation process. It is not designed to contribute to considerations on the creation of clinical tables of occupational illnesses linked to pesticides, but instead aims to improve – by collecting information on the ground – the control of the pesticides already present on the market. This framework is part of what Nicolas Dodier, in his work on workplace accidents, calls “a functional perspective”. [48] The poisoning incidents that are reported are considered by the members of this network not so much as a medical problem but as the sign of possible malfunctions in the system of pesticide control and their pathogenic effects on workers. This is how a series of poisoning incidents reported after workers had re-entered recently treated fields led the Ministry of Agriculture to review the models for the evaluation of exposure used during the approval process, and to include effects after phytosanitary treatments, particularly during harvest time. These considerations led to the adoption of the decree of 12 September 2006, which modified the homologation of products and added legal delays for re-entry into treated areas, ranging from several hours to several days depending on the toxicity of the products in question.

19

“On its functioning [of the toxicity surveillance network], it collects information but not for public health purposes […] Some people in the network don’t understand its fundamental philosophy. They say, ‘we collect symptoms; we know that a given product produces these symptoms.’ No, that’s the starting point that enables us to say there has been a poisoning incident, and we analyse the incident’s environment to try and understand why it happened.” [49]

20The toxicity surveillance network shares an epistemic basis with the industrial hygiene dimension of the homologation process, a similar approach to determining what constitutes occupational poisoning by pesticides. It sees the latter as the consequence of sporadic, high-dose exposure to products that can be identified by the user. The way the questions were framed in the 1984 survey conducted by the MSA is revealing on this point: “Did you experience any health problems during these treatments? If yes, which ones? Due to which products, in your opinion? During the application process? After the application process? How long afterwards did they appear? How long did they last?” [50] This series of questions implicitly constructs the type of poisoning likely to be reported and identified. It assumes that the problems caused by pesticides only emerge “during treatment activities” and that the agricultural worker who is the victim can precisely identify the products responsible. Consequently, poisoning that occurs after repeated long-term exposure to a wide variety of products is de facto excluded from the study. The institutionalisation of this approach through the toxicity surveillance framework reproduces this focus on situations of short-term, high-dose exposure, which generally occurs during treatment.

21

“Those who use phytosanitary products in an occupational context can report problems that seemed to be linked to these treatments (headaches, difficulty breathing, vomiting, skin irritations, etc.) either during the preparation of the solution, or during the application of the product, or during the cleaning of spraying material.” [51]

22The central role of toxicologists in the toxicity surveillance network makes it structurally dependent on data acquired through in vivo toxicity tests. In order to pass judgement on the responsibility of pesticides for a particular problem “arising in connection with a phytosanitary treatment”, toxicologists use the Agritox database, which is comprised of the results of tests provided by manufacturers during the homologation process. If an agricultural worker who is the victim of a poisoning incident that appears to be linked to pesticides cannot provide the name of the product(s) they used, the toxicologist cannot use the database to verify the claim; most likely, it will thus not be confirmed. For this reason the toxicity surveillance network is not really set up to accept reports of severe poisoning linked to repeated exposure – which occurred outside standard treatment activities – to pesticides which are difficult to identify. When pathologies of this nature are reported, toxicologists in the network often lack key elements that would allow them to determine its link to pesticides. When in doubt, and due to lack of funding to properly investigate the possibility of occupational aetiology, they often decide against the responsibility of pesticides for the reported pathology. As a result, these incidents are not counted as poisoning by the toxicity surveillance network.

23

“Dear Madam and honoured colleague,
Following your report n° […] here is some information concerning the toxicity of the phytosanitary products used on grapevines and cereal crops by M.L., a farm manager aged 36 years and currently under your surveillance. Two years ago this individual presented with various myalgias and effortrelated fatigue […] The – very comprehensive – list of products incriminated that you sent me includes active substances, insecticides, fungicides, and herbicides belonging to numerous chemical families of phytosanitary products. A review of the toxicity of each of these is clearly beyond the limits of this response. To the best of my knowledge however, there is no publication […] documenting muscular toxicity in workers exposed to these various substances […] With regard to your employee, his occupational exposure does not seem to me to explain his pathology.” [52]

24The MSA’s cognitive dependency on toxicological knowledge from the laboratory thus fosters the lack of institutional recognition of chronic occupational illnesses provoked by pesticides. Instead it creates a powerful normalisation of the pathologies that the toxicity network uncovers, as the latter are generally benign and reversible. The institutions for the prevention of occupational risks in agriculture can thus recognise the existence of these pathologies, and even their enormous impact on the populations the most exposed to pesticides, without interpreting this as a problematic and “pernicious situation” [53] requiring urgent measures. This is the conclusion of the study conducted in 1984 for the MSA which specifies that “in one out of five cases, the pesticides seem to be responsible for side effects but these appear to be nonspecific and not immediately serious, as in this study no serious cases needing significant medical help were reported”. [54] This observation was also made in the toxicity surveillance network’s publication of its assessments, which underlined that “the undesirable effects observed were essentially acute and benign symptoms”. [55] This is a kind of tautology, given that the toxicity network is organised in such a way as to block the reporting of chronic pathologies resulting from long-term poisoning. This tautology does, however, legitimate the status quo of the cognitive instrumentation of policies for the prevention of occupational illnesses resulting from pesticides, in the eyes of the actors responsible. This is particularly true for the MSA’s occupational physicians who may consider the pathologies provoked by pesticides as a reversible period in the life of a worker, with few serious, long-term consequences.

25

“There is something that I’ve always wondered about, it’s both a good thing and a bad thing, it’s that the phyto products are kind of all or nothing. That is to say that either it’s really serious and someone might die, it’s happened hey […] or it’s kind of serious but the organism restores itself fully. So there are never any intermediary effects. Funny huh… And in fact there are no consequences. So you say ‘this guy, he wasn’t well the other day so he went to the hospital in a helicopter’, and then three days later you see him in the same situation, back working because everything has gone back to normal. So there’s this idea that acute is never serious, or even if it is serious it gets better. And that is at least partly reassuring for the farmers.” [56]

26The lack of recognition of pesticide-linked occupational illnesses thus cannot be reduced to the consequences of the institutional denial of the danger that these products pose for agricultural workers. As time has gone on, a genuine desire to understand the effects of pesticides on workers’ health has emerged within agricultural preventative institutions. But the reasons behind the lack of recognition of the illnesses provoked by various forms of exposure to less easily identifiable or quantifiable pesticides are actually inherent to this desire, and to its dependence on the cognitive means of treating occupational poisoning as a controllable and treatable risk. By using in vivo toxicity tests, preventative institutions have managed to inscribe occupational pesticide poisoning within a cognitive order structured around a way of observing the pathogenic effects of toxic substances on exposed workers. This “regime of perceptibility” [57] brings to light many pathogenic effects of pesticides for those who work with them, but at the same time unintentionally “structures the ignorance” [58] which surrounds the links between pesticides and the health of agricultural workers.

Between denial and disinterest

28Existing social science research on this topic clearly outlines two key hypotheses to explain the under-reporting of occupational pathologies whose connection with pesticides is nevertheless officially recognised by preventative institutions. The first hypothesis emphasises the specific cultural dispositions of the population exposed to pesticides. Sociological research has thus suggested that the attitudes of agricultural workers towards the dangers of pesticides oscillates between “defiance” and “denial”. [60] In an economic universe where the professional choices of farmers (whether career choices or circumstantial choices regarding agricultural practices) have long been – and still are – heavily restricted and where the use of pesticides constitutes an almost unavoidable technological constraint, these attitudes do not lend themselves to reporting pathologies for which the responsibility of pesticides is in fact relatively simple to ascertain. Along with the MSA’s occupational physicians, prevention consultants often encounter this difficulty when seeking to encourage workers who have suffered from pesticide poisoning to report their cases to the toxicity surveillance network and to modify their treatment practices to avoid further accidental exposure.

29

“This problem of denial, it’s important. One […] example […]: the leader of an association [of winegrowers in Hérault], but who is also from the town. In this association there was an assistant, and one day I get a call from her saying ‘our president has been poisoned… would you agree to do something with us?’ so I said ‘of course’… and I went off to meet them. First the assistant, with whom I got on very well, and then just after the president arrived […] and he said ‘you know what happened to me?’ He had his barrel behind the tractor and it was blocked, there was a clog in the barrel, so he had to get it out. He got into the barrel. It was round and made of plastic like that, and there was the bit for the wheels which made two edges on the side, so he was above the liquid like that. And with his hands, well, he had gloves on, I think, but he took out the clog of product that was blocking it. And of course, he fell in, well his legs, it didn’t get any further I suppose because the barrel wasn’t very big. And so the night afterwards he got pretty ferocious diarrhoea and so he was pretty bothered by that. That’s what he told me. When he finished I said ‘so what do you think?’ And he laughed and said ‘well anyway… my parents spread that stuff their whole life and they never got anything, so well, maybe it wasn’t that that made me sick’. So total denial of the incident, the accident, and so nothing else afterwards. I suggested he take the training course that we were setting up, but I never heard anything back. From the moment it reached his level… it didn’t go any further.” [61]

30A second explanation for the under-reporting of pesticide poisoning during crop treatment focuses on the limited awareness that the MSA’s prevention personnel have of this question and the lack of means at their disposal for identifying the effects of pesticides on workers’ bodies. [62] The role of physicians in the process leading victims of pesticide poisoning to report their exposure has recently been highlighted in mesothelioma cases brought on by asbestos. [63] As far as occupational pesticide poisoning is concerned, the MSA’s occupational physicians are at the heart of the toxicity surveillance framework and can encourage the agricultural workers that they see for regular check-ups to report any health problems likely to be caused by phytosanitary products. But the interest that these professionals have in occupational illnesses caused by pesticides varies significantly and depends on their training. The MSA’s decentralised structure also does not encourage advocacy of this issue among its medical staff. Spread throughout the country, the local branches of the MSA enjoy a large degree of autonomy, while the central branch (CCMSA) limits itself to a coordinating role in the domain of workplace health. Thus, the autonomy of occupational physicians provides them with freedom of choice regarding the themes or the issues on which they choose to concentrate. Without adequate training, occupational physicians often turn to other types of occupational health issues that are more immediately visible.

31

“It is true that we are not all on an equal footing. Some of my colleagues have priorities other than this one [pesticide poisoning]. This is amplified by the fact that the MSA doctors are autonomous. Some will say ‘ok you have a headache so I’ll give you some aspirin…’. But you know the difficulty comes from the fact that there is no hierarchy between doctors. They’re autonomous, they do what they like. We do have a coordinating doctor but he only has a certain amount of input, and what’s more you can’t evaluate an occupational physician, what would you evaluate them on? The primary doctor must provide assistance, he decides what to do.” [64]

Neglecting working conditions

32Although both of these explanations concerning the under-reporting of occupational illnesses due to pesticides were confirmed by our field study, the latter led us to formulate a third hypothesis, which emphasises the moral effects produced by the instrumentation of public policy in terms of the protection of agricultural workers during phytosanitary treatments. The fact that preventative institutions focus on the effects of high-dose exposure leads them to base the protection of workers on the alleged efficiency of the instructions for the application of phytosanitary treatments: preparing the spray liquid, applying it, cleaning the equipment, etc. The policies for the prevention of risks related to occupational chemicals are traditionally based on filters – or screens [65] – that limit workers’ exposure to dangerous doses. These include building ventilation systems, airborne particle exhaust systems and individual protection equipment. The homologation of phytosanitary products functions according to the same logic used to protect workers exposed to pesticides, except that the agricultural workplace is not conducive to collective protection measures. Thus, most of the time instructions concerning the need to wear protective equipment are brought to the attention of a product’s users via its labelling.

33This mode of prevention means that the responsibility for protection rests with the operators themselves. The MSA often uses the expression “accidents or incidents occurring during the use of phytosanitary products” [66] to describe the circumstances in which workers can end up poisoning themselves. These incidents may be linked to the phases of treatment (for example, accidental splashes during the preparation of the liquid) or to actions not in direct relation to the treatment itself (for example smoking or eating in a place of treatment which could lead to hand-mouth contact and facilitate the ingestion of the product). But they are almost always due to the non-respect of the instructions outlined in the approval process. If workers respect “best agricultural practice” as outlined on the label, and if they wear the necessary protection, they should not be exposed to unacceptable doses of pesticides.

34As both Gusfield and Stone have noted, the accident category refers to “a random event, that is neither understandable nor controllable”, [67] “occurring beyond human control”. [68] But the use of this notion in prevention policies is profoundly ambiguous. It supposes that accidents, which should be avoided, have identifiable causes and are consequently manageable. The “accidents” that public policy actors seek to prevent are thus not really accidents in their eyes; they are not the results of unfortunate and unpredictable circumstances, but instead the consequence of human actions that are modifiable by appropriate decisions. The causal theories used to explain them inevitably have moral implications, in the sense that they always indicate actors who are responsible or at fault, such as the “drunk driver” in the case of road safety prevention policy as studied by Gusfield. In primarily envisaging poisoning as a situation of sporadic high-dose exposure, the preventative institutions responsible for the health of agricultural workers legitimise an implicit theory situating the “source of the problem” in the behaviour of farm workers during their treatment practices. This is reiterated in most of the appraisals written by the toxicity surveillance network during the last twenty years:

35

“Insufficiencies in prevention and in the use of individual protection during the application of phytosanitary products are evident. In fact more than half of operators with problems use no protection at all. The simple fact of wearing glasses would enable them to avoid conjunctival penetration, for example, and the ocular issues that are the subject of many reports.” [69]

36This conception of poisoning makes the victim the one primarily responsible for his or her own suffering. It is based on the “reduction of the problem to an individual dimension” [70] and tends to overlook working conditions which may favour accidents during treatment, independent of the operator’s actions. This reduction is justified by two “fictions” [71] that are institutionalised in the framework for approval and toxicovigilance. The first is that recommendations regarding the wearing of individual protection equipment are compatible with agricultural work. The second is that this equipment in fact constitutes effective protection against pesticides. Yet for a number of years now, several ergonomic and epidemiological studies on the exposure of agricultural workers to pesticides have shown the fictional nature of these institutional beliefs. They describe the use of protection equipment for the prevention of pesticide-borne pathologies as a “transfer of poorly mastered technology” [72] from the industrial sector to agriculture.

37Firstly, these studies emphasise that agricultural working conditions are incompatible with a scrupulous adherence to the recommendations on the labels of phytosanitary products. Individual protection equipment limits an operator’s freedom of movement and is not very compatible with time constraints or tasks requiring particular dexterity. Given that phytosanitary treatments take place in the open air, they are subject to the vagaries of weather (rain, wind) which can force the operator to rush to finish the treatment to avoid having to return the next day. [73] Similarly, this work may be conducted on rough or uneven ground, increasing the likelihood of the treatment material breaking down, repairs often having to be made without gloves. Wearing the protective equipment recommended or not wearing it is thus more than a simple individual decision; it is the result of a complex decision-making process occurring in often difficult working conditions. The widespread practice of not wearing the required protective attire, as regularly noted in assessments made by the toxicity surveillance network, is indicative of this.

38Secondly, these studies have shown that protection equipment is not necessarily effective against the pathogenic effects of pesticides. In 2007, a team of ergonomists and epidemiologists demonstrated that many of the protective suits recommended by the homologation process were permeable to phytosanitary products. [74] The homologation process works pesticide by pesticide, both in terms of the measures for the toxicity of products and regarding the evaluation of workers’ exposure and the efficiency of protection equipment. The latter are not tested with combinations of several pesticides. Yet in real life, operators often use several products simultaneously when preparing their treatment solutions. For the most part, this situation remains unacknowledged by preventative institutions. An epidemiologist who conducted a number of studies on the effects of pesticides on workers’ health since the 1990s pointed this out in an interview:

39

“We could see that exposure was extremely complex. In other words, we selected people for their use of isoproturon or captan etc. and in fact, on a given day, they never used just one product. It was a mixture of products. For us this was a discovery. But it was a shame that it was also a discovery for the Ministry of Agriculture, who discovered it even later than 1996. It’s common practice to mix products, specifically to have a complementary range of action, and to not have to do several separate treatments.” [75]

Making it unmentionable – making it invisible

40By encouraging a focus on the individual behaviour of operators, the policy instruments used by preventative institutions attribute “moral connotations” [76] to the poisoning agricultural workers suffer during phytosanitary treatments. Even if the actors in the toxicity surveillance network are attempting to make this framework part of a functional perspective for improving recommendations which come out of the homologation process, the way they consider pesticide poisoning is contaminated by “the insidious return of moral attitudes through the back door” [77] with regard to exposed workers. Agricultural workers seeking to report an incident are liable to be sanctioned by their occupational physician, who will outline the mistakes they made and remind them of their obligation to remain vigilant, given the hazardousness of the products they handle. By considering pesticide poisoning from this moral perspective, the policy instruments used by preventative bodies to thwart occupational illnesses caused by pesticides ultimately render the latter invisible. It is in fact very difficult for workers who are victims of poisoning to report their cases. Some agricultural occupational physicians are aware of the need to move away from these moral attitudes to encourage reporting. In the interview extract below, one of these doctors puts forward the idea that the MSA’s prevention staff are moving towards a more global understanding of the material and organisational constraints that can lead to poisoning, independent of a worker’s intentions. However, this theory remains to be tested, and is hardly backed up the stagnation in the number of reports received by the toxicity surveillance network.

41

“In order to get those poisoned to speak out, in fact, you have to push them […] Because it’s always the same, the idea that ‘I made a mistake, I can’t manage it, I expect a moral sanction’, which sometimes we gave, back in the day, because there have been several eras at the MSA. Here, now, I think we have come a long way, we used to explain to them, `you just have to, it’s only a matter of, ‘you know. That attitude of ‘you just have to, it’s only a matter of’, it’s very bad for getting information from people. People expect to be criticised, or at least to be told nicely ‘but you really should have…’. And so then they clam up. In fact, we have to emphasise the fact that it’s normal, that it’s difficult, that these difficulties are enormous, that we understand them, that poisonings will necessarily happen, and that when they happen they should be talked about, precisely so that their working environment can be adapted […] It has to be presented as something unavoidable, ‘we understand your difficulties’, and so when I talk to them I try and not talk about ‘mistakes’ or ‘errors’, ‘anomalies’ and the negative things, but talk about ‘difficulties’, a ‘delicate organisation to put into operation’, you know. The more positive things. And which the farmer can relate to more. But that’s just basic psychology I’d say.” [78]

42In reality, occupational physicians in agriculture and the MSA’s prevention agents don’t collect many direct testimonies of pesticide poisoning. The knowledge that they have of the health problems linked to phytosanitary treatments most often comes from indirect sources: colleagues or friends of the poisoned farmers who choose to alert the prevention institutions when the victim refuses to do so. These poisoning incidents can only very rarely be confirmed and counted by the toxicity network, however, because of the lack of data concerning the exact nature of the problems encountered, the product used and the precise circumstances of the incident. For the most part, these indirect reports are ignored by preventative institutions.

43

“There were friends of the employee who said ‘yeah the other day he wasn’t feeling too good, well I’m not saying anything…’. So he wants to try and get the message across, because he… it’s not him. He didn’t make a mistake in the sense that he’s afraid that… because it’s the other guy. And so he wants to try and help him, so he talks about what happened. But we can’t take it any further […] When we know that someone had an accident, from a friend, etc. we’re not going to… Well everyone is free to say ‘I poisoned myself, too bad for me, I take responsibility for it’. So we’re not going to go up to the guy saying ‘so we know this happened, tell us about it’. That’s up to them. If they don’t want to come and talk to me about it, they’re free not to.” [79]

44During recent years, the MSA has clearly improved the toxicity surveillance network in order to make spontaneous reporting easier. To this end, the main innovation has been the introduction of a hotline in 2004, which allowed victims of pesticide poisoning to report their cases without having to go through an agricultural occupational physician. However, this hotline does not seek to neutralise the moral judgments which might present obstacles towards reporting, but rather to increase the number of reports coming from farm mangers who have less contact than their workers with occupational physicians. [80] This evolution is therefore not a radical break from the vision of poisoning as a result of individual error on the part of the operator. When this hotline was introduced, the toxicity surveillance network was re-baptised “Phyt’attitude”. Although this name change was part of a plan to make the framework more visible to the agricultural population, it also demonstrates a preventative strategy that based the protection of workers on “good” behaviour and appropriate “attitudes”. It did not lead to a significant increase in the number of reports made.

45

“In other words people don’t voice their concerns, and that’s what the hotline is there for, but ultimately it doesn’t work that well because, think about it, what would you call it? Altruism, a desire to help society, a guy is there and he’s had an issue, and he’ll tell someone else he mucked up and he got sick, and then he verbalises it, it’s horrible, you have to be worried, it’s a lot to ask. I still don’t understand how a guy who has had a problem can report it.” [81]