·
Registration
of pesticides is not based on need assessment nor on thoroughly assessing if
alternatives are available - including safer, affordable, farmer-controlled
alternatives rather than toxic, industry-controlled expensive technologies like
synthetic pesticides. The science of pesticides is also unsustainable and
self-defeating, though it provides constant markets for the industry. Even when
ecological alternatives for pest control and management are present, pesticides
are allowed to be produced, sold and used.
·
The
regulatory bodies-the Central Insecticides Board and the Registration
Committee-are located in the Ministry of Agriculture, which seeks to promote
the use of pesticides in agriculture! This represents an unacceptable conflict
of interest-independent, unbiased functioning of the regulators is a difficult
expectation here.
·
Rather
than perform the main mandate of the regulators described in the Insecticides
Act of 1968 (“an Act to regulate the import, manufacture, sale, transport,
distribution and use of insecticides with a view to prevent risk to human
beings or animals, or for matters connected therewithâ€), the regulators perform the
function of a Clearing House. Prevention of risk has not been apparent in all
these years. There is a great deal of emphasis on regulating the quality of
chemicals sold through an elaborate system of pesticide sample collection and
testing and prosecuting where needed in terms of regulating the pesticide
trade, without any sense of prevention of risk or even comprehensive risk or
impact assessment.
·
The
registration of pesticides is not based on any independent or long-term testing
but on data presented by the product developer/manufacturer. Many of the
prescribed tests are actually regular sources of revenue for public sector
agri-research bodies. Not even independent analysis of the safety tests is
taken up prior to registration. The regulatory processes are opaque and no data
is put out into the public domain. Worse, a provisional registration for 2
years is allowed without any health and safety considerations looked into!
·
There
is no in-built mechanism for monitoring, periodic reviews and revoking of
approvals. Reviews are few and far between and have very often recommended the
continued use of reviewed pesticides. In controversial cases of some
pesticides, review committees which were looking into health implications of a
given pesticides were headed by agriculture experts! Regulation from a health
point of view, especially with regard to chronic toxicity is nearly absent in India
·
A
quick scrutiny of the extent of inhalation poisoning cases, or accidents
involving pesticides, or residue analysis studies that show banned and
restricted pesticides ending up in the wrong places or a significant proportion
of our food being contaminated with toxins etc., puts a huge question mark on
the capabilities, independence, seriousness, scientificity and efficiency of
regulation. It has been found in independent analyses that public sector
agriculture universities as well as private sector pesticide companies actually
recommend and promote indiscriminate usage of pesticides. In India
·
Evidence
and reports exist of corruption that prevails in regulation and is exemplified
by the controversial American MNC Dow's Indian subsidiary DeNocil caught
bribing regulators to get four of its pesticides registered. It is worth noting
that even after admitting this, the government took an unacceptably long time
to withdraw permission!
THE UNSCIENTIFICITY OF MRLs
& ADIs IN INDIA
Apart from registration
and other regulatory functions that flow out of the Insecticides Act in India
It is also bewildering
to see that MRLs (an indicator for correct use of pesticides as argued by many)
set up by the Health Ministry rest a lot on Good Agriculture Practices being
followed by farmers, a constituency on which the Health Ministry has no control
or interface with!
However, what is
important interesting to note is that MRLs or compliance to the same may not
actually ensure safety. Why is this so? Two reasons: One, Indian MRLs have not
been fixed keeping the theoretical maximum daily intake of pesticides (TMDI, a
more cumulative measure than MRL for each product, which in turn requires
assessments like a Total Diet Study) within the Acceptable Daily Intake (ADI, a measure which is unfortunately
not part of the statutory regulatory framework); Two, even here, a cocktail
situation of multiple chemicals in our food and environment, in unimaginable
permutations and combinations and unforeseen synergy can never be covered by
such concepts as MRL or ADI!
INDIA FOR SAFE FOOD does not believe that there are any solutions
for food safety in the much-touted concept of MRLs and therefore does not
believe that our food safety has been ensured when the government's monitoring
reports show only a certain percentage of food contaminated with residues or
measures it by how many samples have failed MRLs.
The most bewildering aspect to
these glaring regulatory shortcomings comes from a lack of policy-level
political will-that of wanting to eliminate these toxins from our farms and
food.
The general belief that
the mainstream agriculture establishment holds (probably flowing from the
flawed agriculture education system itself) is that pesticides are
indispensable. This would be evident in the response to be seen from the
industry and the agricultural establishment (research, extension and other
fronts) on INDIA FOR SAFE FOOD MOVEMENT too. They will argue with Malthusian
convictions that there would be hunger and starvation without these poisons and
it is better to feed toxic food than to feed nothing at all! They would do so
despite the fact that India
While IPM seeks to
reduce pesticide usage by asking for the synthetic chemical to be used only as
a last resort when Economic Threshold Level (ETL) of a pesticide is reached,
several other technological approaches including NPM and organic farming have
successfully managed to eliminate the usage of pesticides in agriculture.
Taking these latter
approaches (NPM/Organic/Zero-Budget/Ecological/Natural) to farmers and
supporting them to shift their farming practices (including cropping patterns)
is the only real and lasting way of ensuring that our food and environment are
not contaminated by poisons called pesticides.
List of Pesticides which have been banned/severely restricted in
some countries but are used in India
|
S. No.
|
Name of the Pesticide
|
S. No.
|
Name of the Pesticide
|
|
1
|
35
|
||
|
2
|
36
|
||
|
3
|
37
|
||
|
4
|
38
|
||
|
5
|
39
|
||
|
6
|
40
|
||
|
7
|
41
|
||
|
8
|
42
|
||
|
9
|
43
|
||
|
10
|
44
|
||
|
11
|
45
|
||
|
12
|
46
|
||
|
13
|
47
|
||
|
14
|
48
|
||
|
15
|
49
|
||
|
16
|
50
|
||
|
17
|
51
|
||
|
18
|
52
|
||
|
19
|
53
|
||
|
20
|
54
|
||
|
21
|
55
|
||
|
22
|
56
|
||
|
23
|
57
|
||
|
24
|
58
|
||
|
25
|
59
|
||
|
26
|
60
|
||
|
27
|
61
|
||
|
28
|
62
|
||
|
29
|
63
|
||
|
30
|
64
|
||
|
31
|
65
|
||
|
32
|
66
|
||
|
33
|
67
|
||
|
34
|
|
|
