“”Withdraw Pesticides Management Bill 2017, if the Objective is not right”
March 5, 2018
The Joint Secretary (Plant Protection),
(Room # 238),
Ministry of Agriculture & Farmers Welfare,
Department of Agriculture, Cooperation and
Krishi Bhawan, New Delhi 110 001.
Phone: 011-23382937 Ext. 4965
Sub: Comments/Suggestions on the Pesticides Management Bill 2017, as per F.No.13028/01/2017/PP-I, dated 19/02/2018 on Ministry of Agriculture & Farmers’ Welfare website – reg.
Greetings! The attached document provides a detailed feedback on the Pesticides Management Bill 2017, which constitute comments and suggestions from dozens of farmers’, environmental and consumer organisations from different states of India.
1. Consultations and public feedback collection incomplete: We believe that the time frame provided for receiving such comments/suggestions is too short, for a Bill of great importance to common citizens’ health and farmers’ livelihoods. We have also noted that the stakeholders meeting that you organised on 11/01/2018 was dominated by the pesticides industry, while you ignored other stakeholders, who have worked on alternatives to synthetic pesticides in farming, ones who have documented the ill effects of pesticides, and ones who have studied the regulatory regime’s shortcomings over the years. We write to you to also ask for another consultation to be organised (in fact, they should be organised at least regionally all over the country), before proceeding with the Bill.
2. Our main comments and suggestions:
(i) Reason for the Statute should be Right: Compared to the Insecticides Act 1968 which is in force right now, the PMB 2017 has not only diluted-down objectives, but objectives that need not be part of a regulatory statute. Needless to say, the entire edifice of a statute is created based on the reason for bringing in the statute, and if this is not correctly articulated, all other clauses are prone to faulty construction too. Biosafety, which is protection of human health and ecology/environment from the risks of synthetic pesticides, should be brought back as the core objective of this Bill. This is based on an enormous body of scientific evidence that shows that synthetic pesticides are unneeded in agriculture, and also evidence of the numerous adverse effects of these toxins. Further, definition of Pesticides should explicitly include Insecticides, Fungicides, Herbicides, Acaricides, Molluscicides, Rodenticides etc. in addition to this statute being applicable to pesticides in healthcare use and household use also.
(ii) Long-pending regulatory improvements have not been included: Once the correct objective is re-installed, several long-pending regulatory improvements can be brought in: (a) a precautionary approach that builds in a Needs and Alternatives Assessment into the regulatory regime; (b) an automatic review of every registered pesticide periodically; (c) that registration will take place only after transparent, independent, reviewed long term safety testing; (d) that safety testing will cover inert ingredients as well as metabolites; (e)that pesticides banned or restricted elsewhere will automatically come up for review in India; (f) that funds will be generated by charging the pesticides industry for independent safety data generation etc. (g) Further, the inadequacy of an MRLs-based health safety regime should also be addressed by looking at the fact that MRLs are based on Good Agricultural Practices whereas Theoretical Maximum Daily Intake (TMDI) should be the basis for fixing tolerance limits (not even average daily intake which is not based on complete dietary exposure). (h) No provisional or deemed registration should be allowed.
(iii) State Governments should be empowered: Agriculture is a State subject as per the Constitution of India. The Bill should empower the state governments not just in terms of licensing of trade, but to give them a role in registration process, to prohibit or place restrictions on the sale of a pesticide, to regulate marketing and advertising and to lay down conditions that sale should be against prescription by specified authorities.
(iv) There should be No Penalisation of Farmers as Users – Deterrent Penalties for all Others: The distinction being made between different categories of offences is not water-tight enough, with additional terms like ‘ineffective’ pesticide etc. laid down. No punishment has been spelt out for environmental and human toxicity and penalties cannot be limited to only efficacy aspects of regulation. They should cover safety aspects too.
(v) Explicit Compensation, Redressal and Remediation Clauses should be included: Farmers’ and affected persons interests are not being protected by this Bill, which lays down that they should take resort to the Consumer Protection Act when affected persons may not even be ‘consumers’ as defined in the said Act. The PMB 2017 itself should include time-bound, simple and accessible mechanisms as clauses for compensation, redressal and remediation.
(vi) Protection of farmers and farm workers as users of pesticides: There are no provisions that have been built to ensure safety of use of pesticides, which should be addressed by inclusion of appropriate clauses in the Bill.
In our attached feedback, we had given several other suggestions which merit serious attention and addressal, including about transparent functioning, building of data systems that will govern better regulation etc.. We believe that regulation is not just about quality and efficacy based on which pesticide industry’s business is facilitated by framing a statute (PMB 2017 is mainly centred around this) but more importantly, regulation should be around safety from the deployment of a toxic technology, in a context when science of pest management has evolved to show that such a technology is certainly dispensable.
In either case, the current Bill falls significantly short in protecting the interests of common citizens, including farmers, farm workers and consumers and their environment. When regulation does not co-evolve with scientific developments and evidence as well as societal demand, then it obviously falls short of what is required.
Without taking care of the several lacunae in the existing regime as well as in the proposed Bill, the Government of India would have done disservice to citizens, especially after the recent unconscionable episodes of deaths and hospitalisations of dozens of citizens due to pesticide poisonings. In the coming days, we will be providing clause-by-clause amendments needed in the Bill. We hope that the PMB 2017 will be re-cast in significant ways, based on our collective feedback. Thank you.
WITHDRAW THE PESTICIDES MANAGEMENT BILL 2017 IF THE OBJECTIVE CANNOT BE RIGHT!
The Pesticides Management Bill 2017 is little more than a slightly modified version of the 50-year old Insecticides Act 1968. Rather than seeking to regulate hazardous and toxic materials (i.e. pesticides) in the interest of farmers, consumers and wildlife, the proposed bill seeks to dilute the very need and required objective for a statute of this kind. This collective response has been drafted by farmers’ organisations, public health groups, environmental organisations and consumer groups, and is being sent by ASHA (Alliance for Sustainable and Holistic Agriculture) on behalf of all these groups.
1. NEED FOR A NEW LAW?
The current law regulating pesticides in India, called the Insecticides Act 1968, has safety as its central objective. It begins by saying that the Act is to “regulate the import, manufacture, sale, transport, distribution and use of insecticides with a view to prevent risk to human beings or animals, and for matters connected therewith”. Yet the current Bill (Pesticides Management Bill 2017) is a great departure from this starting point. It is a Bill “to regulate the import, manufacture, export, sale, transport, distribution, quality and use of pesticides with a view to (i) control pests; (ii) ensure availability of quality pesticides; (iii) allow its use only after assessing its efficacy and safety; (iv) minimize the contamination of agricultural commodities by pesticide residues; (v) create awareness among users regarding safe and judicious use of pesticides, and to take necessary measures to continue, restrict or prohibit the use of pesticides on re-assessment with a view to prevent its risk on human beings, animals or environment, and for matters connected therewith or incidental thereto”.
It is bordering on the ridiculous that a regulatory law seeks to control pests, which is the business of agricultural departments and farmers! Similar is the case with “creating awareness among users regarding safe and judicious use of pesticides”, as an objective for a regulatory law – it is all the more ironical that not a single section of the bill actually deals with this objective.
It is indeed important to get the Objective and need of the Bill straight, because without the intent being correct, all other clauses will not follow or fall into place.
About the objective for the Bill: it is not clear why the Government wants to bring in a completely new legislation, to begin with. There are really no great differences between the Insecticides Act 1968, nor the UPA-time Pesticides Management Bill 2008/2010 and the current NDA Bill, Pesticides Management Bill 2017.
The only differences between the Insecticides Act 1968 and the Pesticides Management Bill 2017 are:
- Nomenclature changing from insecticides to pesticides, though the current Act does regulate all pesticides (incl. bio-pesticides) even though it is called Insecticides Act, and even though the proposed Bill explicitly does not name all kinds of pesticides;
- Laying down conditions that every pesticide should have its expected performance disclosed, and usage instructions included in its application for registration in addition to laying down a condition that no registration can take place without tolerance limits specified under another statute on food safety;
- Increasing the penalties for offences, after first categorising the offences into “misbranded”, “sub-standard” and “spurious” and laying down different penalties for different offences, which does not exist in the extant law;
- Including a so-called Compensation clause for farmers or affected persons (safety aspect), but then actually asking them to take resort to the Consumer Protection Act 1986;
- Increasing the possibility of prohibition of sale, distribution of use of a pesticide for reasons of public safety, from 2 months in the extant statute, to 6 months in the proposed 2017 Bill;
- Including a clause on Segregation and Disposal of pesticides;
- Reflecting the growth and evolution of government departments, increasing the number of representatives into the Central Board’s constitution, e.g. to include the Department of Biotechnology
- Including two farmer members into the Central Board’s constitution.
The above differences are hardly any reason to bring in a new legislation, when they can be addressed by simple amendments to Insecticides Act 1968.
Therefore, the first thing that the Government of India should do, is to clarify why there is a need to bring in a fresh legislation on regulation of pesticides, especially since no real improvements on the existing statute are seen. This proposed Bill is not supportive of, and in fact contradicts the wider emerging demand for a shift to agro-ecological practices in farming. It is not out of place to remind that the Union Minister for Agriculture had stated that “organic farming should be promoted with the same spirit as Green Revolution”. (http://pib.nic.in/newsite/PrintRelease.aspx?relid=176577)
2. BIO-SAFETY & REDUCTION OF SYNTHETIC PESTICIDE USAGE SHOULD BE THE OBJECTIVE:
The Pesticides Management Bill 2017 should have biosafety (safety for human beings and the ecology) as its Central Objective. There is no reason why the core reason for regulation, which was laid down in Insecticides Act 1968 has to change, especially after 2017 witnessed hundreds of pesticide poisoning cases –including deaths- due to occupational exposure in multiple states, and threw up the grim reality of use conditions and failure of regulation on the ground. The recent episodes of poisoning were only a sequel to other such instances in the past. Questions around the manufacture and use of deadly pesticides, the need for continuous independent generation of safety data on pesticides, lack of authority in the state government’s hands, weak penal clauses etc., in the extant statute received attention in the ensuing public debate. It appears that the Pesticides Management Bill 2017 has not taken cognisance of any of this.
Meanwhile, it should be remembered that both the science of pest management based on greater understanding of agro-ecology, and the body of evidence on toxicity of pesticides has developed strongly in the past decade or so. On another front, it is also clear that India’s citizens, as with those around the world, are more aware of the toxic effects of pesticides than before, and are demanding safe food and environment.
Any sound regulatory regime should co-evolve with both such scientific evidence as well as with societal demand. Therefore, it is surprising that the Objective of the Pesticides Management Bill 2017 is not bio-safety and reduction in the usage of chemical pesticides. The Government of India should immediately make the required changes in the very objective of the Bill before proceeding further.
Towards this objective, the following related clauses should definitely be inserted:
- That any new pesticide will be registered only after a Needs and Alternatives Assessment, deploying NPM (non pesticidal management) approaches;
- That any pesticide will be registered only after transparent, independent, peer-reviewed, long term safety testing is cleared, if the condition above is met;
- Given that there is a new body of scientific evidence on the toxicity of so-called “inert” or innocuous materials used in pesticide formulations, other than the active ingredient, biosafety testing should necessarily include these ingredients too, which means that formulation registration is also required;
- Biosafety testing should cover toxicology of secondary and tertiary half life metabolites and the data should be put in the public domain;
- That there should be rigorous biosafety testing for “combination” products, before they are registered and allowed to be manufactured, sold or used;
- That there will be a periodic and automatic review of all pesticides, every five years from the time of registration – each registration should be valid for only five years;
- That any pesticide registered in India, which has been banned or severely restricted in at least two other countries will be reviewed and put up for comprehensive safety testing, based on which a ban or restriction decision will be taken here too;
- That the Government of India will generate and set aside funds, by collecting the same from the pesticides industry as a percentage of their turnover, to commission independent studies to generate safety data including long term data, that will feed into the periodic review. Review processes should be transparent, scientific, participatory and devoid of any conflict of interest. It is often seen that the irregular, occasional reviews that the Government of India conducts, depend on the industry to produce safety data, ignoring the inherent conflict of interest.
3. NO BIOSAFETY TESTING REGIME WORTH THE NAME SPELT OUT IN THE BILL:
The primary basis for registering a pesticide should be an established need, the fact that there are no alternatives, and importantly, clearance of a rigorous biosafety testing regime.
The proposed Bill does not spell out any mechanisms to ensure that independent, comprehensive and long term testing for biosafety takes place, for registration and other regulatory decisions to be taken on a given pesticide.
4. STATE GOVERNMENTS SHOULD BE EMPOWERED:
The Pesticides Management Bill, despite the experience of implementation of Insecticides Act 1968, does not empower state governments the way it should. Agriculture is after all, a State Subject as per the Indian Constitution.
Other than the powers of licensing vested with the state government, and other than some representation in the Central Pesticides Board (five state government department of agriculture officials representing 5 agro-climatic zones), state governments have been provided with very little role in the registration process, or prohibition process. State governments, for instance, are not shown the biosafety data based on which, given the regional specificities of environment, communities and crops grown, they could have a say in the registration process itself.
In the case of prohibition of pesticides too, state governments should be empowered to take action. This could be on the basis of data that they generate locally, reviewed by a competent body.
State Governments should also be empowered to regulate marketing and advertising of pesticides, in addition to placing restrictions on sale and usage as required.
State Governments should be able to lay down conditions for sale against prescription for specific pesticides.
5. DEFINITION OF PESTS & PESTICIDES SHOULD BE COMPREHENSIVE:
The definition spelt out in the proposed Bill for a Pesticide should be comprehensive and should explicitly include all household pesticides, pesticides used for vector control in healthcare systems, herbicides and weedicides, fungicides, rodenticides etc. Similar is the case of definition of Pests, which could mean wildlife too. The definition should be clearly spelt out.
6. PENALTIES TO BE DETERRENT ENOUGH – THERE SHOULD BE NO PENALISATION OF FARMERS:
The penalties have been laid down for user too, and not just “causes to use a pesticide”. Farmers are often victims of an aggressive toxic industry, when it comes to pesticides. There should be absolutely no penalties on users. While there should be deterrent penalties for those “who cause to use a pesticide in contravention” of any provision of the Act.
Further, punishment for misbranded pesticide and sub-standard pesticide have been kept at the same level, which does not make sense, given that there is a new categorisation of offences in this proposed Bill, as compared to extant law. Further, a category of “ineffective pesticide” is introduced under Section 39, with a higher punishment, though it is not clear how it is different from Sub Standard pesticide, which is expected to manifest itself as an ineffective pesticide. Spurious pesticides are punishable with the highest quantum of punishment in the proposed Bill.
However, no punishment has been spelt out for environmental and human toxicity that is proven to be caused by a particular pesticide, as in the case of acute poisonings for instance. While this could be part of the provision that specifies about “failing to perform as per the claims of safety”, the penalty laid down is the lowest, which is objectionable!
7. PUT IN COMPENSATION, REDRESSAL AND REMEDIATION CLAUSES:
The Pesticides Management Bill 2017 only asks for farmers and other affected persons to resort to a Consumer Protection Forum for compensation and redressal. It is not clear how affected persons (i.e. an agricultural worker who is poisoned due to occupational exposure, and is not the one who purchased the pesticide, or communities who are affected by large scale use of a cocktail of pesticides in states like Punjab, or consumers of highly contaminated food items), who may not be buyers/consumers of a pesticide are supposed to take resort in a law that is meant for Consumers.
What is needed in the proposed Bill is a clause that makes the pesticides industry as a whole, and particular manufacturers/marketers/retailers as liable for losses incurred by farmers, or effects experienced by any other affected persons. The procedure laid down should be simple, time-bound and accessible to all affected persons.
Block level committees, consisting of Agriculture and Health department officials, along with farmer/community representatives can be created for the purpose of scrutinising demands for compensation, redressal as well as remediation of pesticide toxicity, or failure to perform as promised.
8. SEPARATE OUT BIO-PESTICIDES IN THE REGULATORY REGIME:
The proposed Bill, in its definition of Pesticides includes pesticides with a biological origin, along with chemical origin. Bio-pesticides may need regulation, but cannot be on par with hazardous chemicals. The regulatory regime for bio-pesticides has to be separated out, and only relevant clauses included here.
9. BRING IN TRANSPARENCY AND INDEPENDENT FUNCTIONING INTO REGULATION:
The pesticides regulatory regime, at all levels, starting from biosafety testing to periodic reviews after registration, should be rid of any conflict of interest, and should also be based on transparent functioning. This applies to all regulatory bodies created in this law, including licensing officers, inspectors, analysts and others. It is noteworthy that unlike the 1968 Act, the proposed bill (clause 25) deletes mention that Pesticide Inspectors should not have financial interest in pesticide industry. Data being generated, prosecution initiated, results of lab analyses and other such information should be mandated to be put in the public domain by respective authorities.
10. BUILD DATA SYSTEMS AND PUT OUT INFORMATION INTO PUBLIC DOMAIN, INCLUDING POISONING INSTANCES:
There is a need for data systems to be built within the pesticides regulatory regime, and such data being available in the public domain.
The following are some of the systems that should be put into place in a mandatory and not optional fashion:
- Information on acute poisoning cases, through hospital-based surveillance initially, followed by village-level systems (the Pesticides Management Bill clause 32 spells out that state government may require any person to report all occurrences of poisoning, rather than laying down that every state shall);
- Pesticide residue levels in drinking water in identified areas;
- Traceability in a supply chain from production till end consumption of a given pesticide;
- Pesticide residue levels in various foods in different wholesale and retail points including those of street vendors (i.e. not only supermarkets).
Further, half-life data and toxicology reports of all registered pesticides and formulations must be put in public domain by the regulator. Surveillance should include information on developments in other countries including fresh bans and restrictions, which should trigger reviews within India.
11. PESTICIDES MANAGEMENT BILL AN OPPORTUNITY TO MAKE LONG-PENDING CORRECTIONS IN OUR REGULATORY REGIME:
The proposed Bill needs to re-look at concepts liked “deemed” registration and provisional registration. This is an opportunity to generate and align all data required for all pesticides, so that bio-safety can be upheld. Provisional registration is unacceptable and this clause should be deleted completely.
MRLs as a concept, based on “Good Agricultural Practices” would not be adequate to ensure safety from a pesticide – these are being faultily equated with “tolerance limits for residues on crops and commodities”. Theoretical Maximum Daily Dietary Intake should become the basis for fixing MRLs by the Health Ministry agencies, without which no pesticide should be registered. Fixing of tolerance limits should be comprehensive, for all uses of a given pesticide.
12. REGULATE ADVERTISING/AGGRESSIVE MARKETING OF PESTICIDES:
There should be powers vested with state government to curb any aggressive marketing of pesticides, and to prohibit advertising. The abuse of pesticides that one witnesses is because today, the pesticides industry is built on aggressive marketing where retailers and farmers are incentivised around greater use of pesticides, rather than reduction in the use of pesticides.
13. PROTECT FARMERS AND FARM WORKERS:
Only at the very end of the proposed Bill is protective clothing to workers mentioned (Clause 48(2)(zi)). ‘Worker’ is vaguely defined in Chapter I, and it is unclear if farm workers employed informally by farmers fall in the category ‘worker’. Nowhere in the Bill is there mention of promotion of the use of, and ensured availability of, protective clothing for farmers and farm workers. Penalties for failure to provide protective equipment for farm workers who use pesticides should be specified.
It should be mandatory for those who sell pesticides to keep a stock of protective clothing, and to recommend or give out protective clothing to purchasers of pesticides.
Currently millions of farmers have no idea about the dangers of exposure to pesticides other than that direct consumption is deadly. The Bill should make it mandatory for states, at the block level, and through news media etc., to create awareness about the toxic effects of pesticides. For this, funds should be collected from the industry – a clause to this effect should be put into the proposed Bill.
14. SPECIFY AND INCREASE SCOPE OF PESTICIDE INSPECTORS’ DUTIES:
The proposed bill notably positions the discussion on Pesticide Inspectors in a chapter called ‘Analysis of Pesticides’. The job description of Pesticide Inspectors needs to be specified and it should not be limited to taking and testing samples of pesticides. The Inspectors’ duties should include, for example, ensuring input dealers stock protective equipment, and ensuring dealers provide farmers with the leaflets that accompany pesticides (this is specified in the proposed bill under clause 23(1)(f) “…usage instructions as suggested by the manufacturer… to farmers…” and clause 28(2)(a) where it states that Pesticide Inspector shall use all reasoning to determine whether the pesticide sale or use contravenes any of the provisions in clause 23). Another duty of Inspectors can be to identify those pesticide sellers without licenses. It should be mandatory for states to appoint a sufficient number of full-time Inspectors, able to deal with the burgeoning number of formal and informal dealers.
- Clause 17(8) says that the State government will send report for period of six months to central government containing details of information in 17(7), which includes “information… on performance of registered pesticide in improving agricultural production”. This does not appear to be tenable and there is no reason to include this in the Bill.
- While there is regulation around imports for food, limits to import of feed is completely missing.
- The proposed Bill and all its clauses should apply completely to pesticides used in healthcare and household pest control.
- LC/MS/MS and GC approaches should be included in testing.
- The manufacturer should be made responsible for the end disposal of pesticide containers.
- Include representatives of consumer organisations, environmental NGOs and independent toxicologists and epidemiologists into the Central Pesticides Board.
- Include independent researchers and scientists into the Registration Committee.
Kavitha Kuruganti, ASHA (Alliance for Sustainable & Holistic Agriculture), Bangalore
1. Afsar Jafri, Focus on the Global South, New Delhi
2. Amrita Mangat, Ludhiana Safe Food Alliance, Punjab
3. Anand Mazgaonkar, Gujarat Sarvodaya Mandal, Ahmedabad
4. Ananthoo, Safe Food Alliance, Tamil Nadu
5. Anil Singh, SANSAD, New Delhi and Uttar Pradesh
6. Annakili, Kalanjium Unorganised Workers’ Union, Tamil Nadu
7. Anshuman Das, BhoomiKa Network, New Delhi
8. Arun Tyagi, Dalit Adivasi Mahapanchayat, Madhya Pradesh
9. Aruna Rodrigues, Sunray Harvesters, Mhow, Madhya Pradesh
10. Arup Rakshit, MGSSS, West Bengal
11. Ashish Gupta, Muskaan Jaivik SHG, Himachal Pradesh
12. Ashish Kothari, Kalpavriksh, Pune, Maharashtra
13. Avik Saha, Jai Kisan Andolan, New Delhi
14. Badribhai Joshi, Shantigram Nirman Mandal, Gujarat
15. Bhanuja, Rural and Environment Development Society, Andhra Pradesh
16. Chellamuthu, Farmers and Tillers Party, Tamil Nadu
17. Chinmoy Das, FIAM, Dinajpur, West Bengal
18. Claude Alvares, Organic Farming Association of India, Goa
19. Debasis Panda, Kanthi, West Bengal
20. Debjeet Sarangi, Living Farms, Odisha
21. Devesh Patel, Madhya Gujarat Sajiv Kheti Mandal, Boriyayi
22. Dineshan, Jaiva Samskruthi, Kerala
23. Dr A R Vasavi, Punarchith, Chamarajanagar, Karnataka
24. Dr Amar Singh Azad, Environmental Health Action Group, Patiala
25. Dr Debal Deb, Basudha, West Bengal and Odisha
26. Dr G S Kaushal, former Director-Agriculture, Madhya Pradesh
27. Dr G V Ramanjaneyulu, Centre for Sustainable Agriculture, Hyderabad
28. Dr Jeevanantham, Tamil Nadu Green Movement, Tamil Nadu
29. Dr Mallareddy, Accion Fraterna, Andhra Pradesh
30. Dr S Seshadri, Indigenous and Frontier Technology Research Centre (IFTR), Chennai
31. Dr Sijin, Nalla Bhashana Prasthanam, Kerala
32. Dr Tarak Kate, Dharamitra, Wardha, Maharashtra
33. Dr V Rukmini Rao, Gramya Resource Centre for Women, Nalgonda, Telangana
34. Dr V S Vijayan, Salim Ali Foundation, Kerala
35. Dr Virendra Vidrohi, Indian Social Action Forum (INSAF), New Delhi
36. Engals Raja, Nammalvar Ecological Foundation for Global Food Security and Farm Research, Tamil Nadu
37. George Mulakara, Kerala Jaiva Karshaka Samithi
38. Haribabu, Thiruvallur Mavatta Iyarkai Vivasaya Kootamaippu, Tamil Nadu
39. Ishwar Chandra Tripathi, Bhartiya Kisan Union, Madhya Pradesh
40. Jayant Verma, Hamara Beej Abhiyan, Madhya Pradesh
41. Jayanta Das, Santiniketan, West Bengal
42. Jaykrishnan TV, Paithragam, Kerala
43. Jitendra Prasad, South Indian Organic Producers and Retailers Association
44. K P Illiyas, Ore Bhoomi Ore Jeevan, Kerala
45. K V Biju, All India Organising Secretary, Swadeshi Andolan
46. Kalai Selvam, Nammalvar Thagaval Maiyam, Chennai
47. Kapil Shah, Jatan Trust, Gujarat
48. Kavita Kowshik, Mai Mati Foundation, Pune, Maharashtra
49. Kiran Vissa, Rythu Swarajya Vedika, Telangana
50. Kongu Kolandaisamy, Erode District Horticulture Farmers Assocation
51. Krishna Prasad, Sahaja Samrudha, Karnataka
52. Kumar, Vanagam, Tamil Nadu
53. Laxman Singh Munia, Lok Jagriti Manch, Madhya Pradesh
54. Lipika Kochar, Jalandhar Safe Food Alliance, Jalandhar
55. Mohan, Cauvery Right Bank Farmers Association, Nerunchipettai
56. Nallasamy, Keel Bhavani Vivasayegal Sangam, Arachalur
57. Nilesh Desai, Beej Swaraj Abhiyan, Madhya Pradesh
58. Parthasarathy V M, Pandeswaram Farmers Society
59. Ponarasu, GD Naidu Uzhavar Mandran, Tamil Nadu
60. Ponnaiyaian, Tharsarbu Vivasayegal Sangam, Chennimalai
61. Ponnthai, Kalanjium Women Farmers Association, Tamil Nadu
62. R Selvam, Tamil Nadu Organic Farmers’ Federation, Tamil Nadu
63. Raja Sankar, Madhu Farms/Sriram Foods/Purva Naturals, Tamil Nadu
64. Rajesh Krishnan, Coalition for a GM-Free India, Wayanad, Kerala
65. Rajnibhai Patel, Sabarkantha Sajiv Kheti Samaj, Modasa, Gujarat
66. Ramesh bhai, Satvik, Bhuj, Gujarat
67. Rathinasamy, Thamilaga Vivasayegal Sangam, Erode, Tamil Nadu
68. Ravi Kanneganti, Telangana Rythu Joint Action Committee
69. Ravisankar, Nalla Unavu Trust
70. Rohit Parakh, India For Safe Food, Mumbai
71. Rohit Prajapati, Paryavaran Suraksha Samiti, Vadodara
72. Rupam Chatterjee, Ganaudyog, West Bengal
73. Sachin Jain, Bhojan Ka Adhikaar Abhiyaan, Madhya Pradesh
74. Sahaja Aharam Producer Company, Hyderabad
75. Seema Kulkarni, MAKAAM, Pune
76. Sheelu Francis, Women’s Collective, Tamil Nadu
77. Shivani Shah, Greenpeace India, Bangalore
78. Sivakumar, Advocate, Networking and Development Centre for Service Organisations, Tamil Nadu
79. Soumik Banerjee, Swala, Godda, Jharkhand
80. Sreedevi, Anantha, Coimbatore, Tamil Nadu
81. Sunderarajan, Lawyers for Environmental Justice and Human Rights, Chennai
82. Sundari Perumal, Tamil Nadu Resource Team
83. Thamilnesan, Uzhavu, Chennai
84. Umendra Dutt, Kheti Virasat Mission, Punjab
85. Usha S, Thanal, Kerala
86. V T Padmanabhan, Society for study of Science, Environment and Ethics (So-SEE), Tellicherry, Kerala
87. Vadivelu, Lower Bhavani Irrigation Farmers Federation, Erode
88. Vasu Gunjur, SOIL, Karnataka
89. Velayutham, Kalingarayan Pasana Vivasayigal Sangam, Tamil Nadu
90. Vetriselvan, Poovulagu Nanbargal, Chennai
91. Vettavalam Manikandan, Thamilaga Vivasayegal Sangam, Tamil Nadu
92. Vinod K P, Nalla Bhoomi, Kerala
93. Vishala Padmanabhan, Buffalo Back Collective, Karnataka
94. Yatri Bakshi, Paryavaran Santri, Ahmedabad
Endorsements received after joint feedback was sent to the MoA&FW:
1. Datta Patil, YUVA Rural Association, Maharashtra
2. KIRDTI, Odisha
3. Keonjhar Chassi Sanghatan, Odisha
4. Khandadhar Anchalik Mahasanghtan, Odisha
5. Bharat Mansata, Vanvadi Agro-ecological Regeneration Association (VARA), Maharashtra
6. Vinita Mansata, Earthcare Books, Kolkata