ASHA’s submission: Comments on the Report of the Committee on Labeling of Pesticides as per Toxicity

COMMENTS ON THE REPORT OF THE COMMITTEE ON LABELLING OF PESTICIDES AS PER TOXICITY

To:

The Secretary,

Central Insecticides Board,

Directorate of Plant Protection, Quarantine & Storage,

Ministry of Agriculture, Cooperation & Farmers’ Welfare,

Government of India.

Email: cibsecy@nic.in (vivek.narayan14@nic.in, viveknarayan77@gmail.com)

Dear Sir,

This is in response to the Public Notice put out on 9^th August 2019, seeking comments on the Report of the Expert Committee on manner of labelling of pesticides as per toxicity. Our feedback is three-fold, the further details of which have been provided in this document.

·       One, even with the current system of classification, the acute poisoning instances of farmers and farm workers are unacceptably high in the country with the hospitalisations and deaths from even occupational exposure to pesticides (not intentional ingestion alone) being a reflection of this phenomenon. When the classification is revised substantially with most LD50 values through both oral and dermal route being classified as Moderately Toxic, Slightly Toxic and Unlikely to be Harmful, this will make the entire farming community and regulatory regime more complacent and will increase the prospects of acute poisoning, since the same chemical’s ability to cause poisoning has already been proven (for example) even though its classification for labelling purposes might be changed!

·       Two, labelling of pesticides is meant for informed choices to be made by the end user, who is the farmer. This, therefore, cannot be limited to acute toxicity alone, but toxicity of various kinds including chronic human health impacts as well as environmental toxicity. Otherwise, this labelling is incomplete and not useful enough.

·       Three, labelling alone is not enough to educate the farmer and help him/her take an informed decision. The rules should therefore encompass the leaflets too.

The following are more specific comments from us:

1.       We believe that the current classification system should not be changed, in terms of median LD50 values through oral or dermal route. This is all the more so given that acute inhalation toxicities have not been specified in the proposed labelling regime related to toxicity.

2.       The GHS (Global Harmonised System) also contains gas and vapour acute toxicity estimates too. While the Committee has recommended that the proposed classification should take care of acute inhalation too, it does not specify any values in the draft. This should be addressed.

3.       This proposed classification is based only on acute poisoning as is the case right now. However, there is a need to classify as per chronic health impacts like mutagenicity, carcinogenicity, reproductive toxicity, specific target organic toxicity, developmental toxicity, teratogenicity etc. Additional classifications based on skin and eye irritation criteria that can and should be adopted.

4.       There is a need for presenting data on the labels related to eco-toxicity, including aquatic toxicity. Bio-accumulation properties should be listed too.

5.       Label should be in legible font size in all local languages where the pesticide is being sold.

6.       The leaflet should also be legible, in appropriate font size and in all local languages.

7.       Very often, the leaflet that is supposed to accompany the pesticide container is not given to the farmer, the end consumer. No sales should be allowed without the full label as well as leaflet.

8.       Leaflets should mandatorily contain information with regard to first aid support in case of poisoning in addition to clear and full instructions on safe use.

9.       The label as well as the leaflet should contain not just the manufacturer’s details but also the distributor and supplier.