From: ASHA Kisan Swaraj <firstname.lastname@example.org>
Date: Thu, Jun 25, 2020 at 1:37 PM
Subject: Withdrawal of letter to MoAFW with regard to proposed ban on 27 pesticides in India
Shri R K Chaturvedi,
Department of Chemicals & Petrochemicals,
Ministry of Chemicals and Fertilizers,
Shastri Bhavan, Dr Rajendra Prasad Road,
New Delhi 110 001
Dear Shri RK Chaturvedi,
Ref: Your letter to the Secretary, Department of Agriculture, Cooperation & Farmers Welfare, dated June 2, 2020 (C-I-25016/3/2016-CHEM.II-
This is with regard to your letter to the Secretary, Department of Agriculture, Cooperation and Farmers’ Welfare on the matter of MoAFW’s notification of a draft ban order with regard to 27 deadly pesticides in India.
It is shocking that the Ministry of Chemicals and Fertilisers is acting as a full partisan front for the industry, as though it has nothing to do with citizens and sustainable development even though this department is part of a democratic government.
It is even more shocking to see the Department of Chemicals and Petrochemicals parrot some talking points given by the industry and blindly use the same in its letter to the Ministry of Agriculture, without any rigour of its own.
What is also shocking is that what you have written to the MoAFW is in direct contradiction to the Prime Minister’s clarion call on India’s Independence Day in 2019, asking for a cutting down on the use of agro-chemicals and destruction of Mother Earth.
For one thing, decisions on bans cannot be based on market considerations. If that was the case, even deadly pesticides cannot be banned. Reviews and subsequent prohibition decisions are about safety, and short term profits for the industry cannot be the reason to take away the Right to Life of agricultural workers and farmers, or to do irreparable harm to the environment. The argument around these 27 pesticides having a 40% share of the Indian pesticide industry market is simply untenable. It is another matter that the claim around the market share of these pesticides is entirely industry-dependent, in the absence of any other robust data systems maintained by the government through departments like yours.
Secondly, we are sure you are already aware that this proposal of banning 27 pesticides, from the Ministry of Agriculture and Farmers’ Welfare, is not sudden or unexpected, even though your letter alludes to the “sudden banning”. Several of these pesticides have been featuring in reviews starting from the RB Singh Committee in 1999, and lack of data has been used to procrastinate sound decision-making in favour of sustainable development.
The Review Committee led by Dr Anupam Verma was constituted and began its work way back in 2013! From the time the review began – which itself was long-pending given that civil society reports and ground level poisoning reports were implicating many pesticides featured in this list of 27 pesticides – it was apparent that the possibility of these pesticides getting banned has become stronger and clearer.
What’s more, the pesticide industry insinuated itself into the review process and actually partook in that process. Being part of Central Insecticides Board & Registration Committee, your Ministry also partook in the processes of adoption of the Anupam Verma Committee report. Therefore, it is simply unsubstantiated to say that this banning is “sudden”.
Thirdly, you may be aware of a whole set of pesticides in India which are termed as “Deemed to be Registered Pesticides” or DRPs. It appears that at least 71 such pesticides were already in use when India brought in statutory regulation in the form of the Insecticides Act 1968 into force. No list is available in the public domain of such pesticides and we were able to compile a list of 51 DRPs from different official documents. These DRPs did not necessarily undergo biosafety assessment with regard to their safety and simply got incorporated into the new statutory regulatory regime at that time. The fact that comprehensive safety data with regard to these pesticides was not available is noted by even Parliamentary Committees apart from earlier review committees set up by the Agriculture Ministry. Further, even after registration, evolving science and scientific testing methodologies might trigger fresh assessments of the safety of a chemical and this is in fact a progressive regulatory framework. Regulation has to co-evolve with safety science. Data requirements of the regulators have to be met for sound decision-making in favour of citizens and their environment, and therefore, such data is sought. Ideally, regulators should charge the industry a certain fee and commission independent studies rather than depend on the industry-produced data which has an obvious conflict of interest. Those of us who have been looking at the regulators’ meeting minutes have noted that the required information is not always provided by the industry despite repeated requests and orders. It is therefore apt that the draft order refers to the same. It is indeed true that there is no data to prove the safety of these pesticides, and if there is, we demand that the same be put out in the public domain for independent scientific scrutiny.
Fourthly, the all-too-familiar argument of the industry about how “banning of a particular pesticide by a few countries based on some studies somewhere may not provide us enough ground to take similar action in India without having adequate scientific evidence in Indian context” is being repeated parrot-fashion by your Ministry. If banning based on some studies elsewhere is not acceptable, then registration based on some studies elsewhere should not be acceptable either. However, when it comes to registration, the industry works on “harmonisation” grounds and does not want to repeat toxicity studies. The “MAD” (Mutual Acceptance of Data) agreement with OECD that the Indian regulatory system has, is an example to illustrate. Following contradictory strands of arguments in an opportunistic fashion does not work, and data from elsewhere, that too based on scientifically-rigorous studies, should be used for feeding into our review processes and ban decisions.
Fifthly, about a risk-based approach to regulation – it is precisely this kind of a regulation which requires all the 27 pesticides listed in the draft order and around 75 more to be banned immediately since the probability of risk is higher in India for the same chemical and its hazard, compared to other locations. This is because of our peculiar and unique use conditions as well as exposure conditions. For instance, the level of manual labour activity in many crops in India is very high compared to other countries with highly mechanised operations and exposure routes are more direct to toxic pesticides.
Sixthly, about India deciding at a policy level to adopt double standards for its citizens and citizens of other countries thereby allowing exports of deadly pesticides manufactured here but prohibiting their use within India – this will be a shameful thing to adopt for a country that can in fact lead the world through agro-ecology. India’s growth in organic farming in the recent past has been impressive, and we need to take this forward.
Lastly, your letter alludes to need for economic growth for agro-chemical industry. It is sad that you would be supportive of economic growth to the exclusion of other serious concerns. It is precisely this short-sighted prioritisation of economic growth over environmental parameters which have caused a great damage to this country and its people.
About the more specific and detailed inputs that were provided as Comments of DCPC as an annexure to your letter:
- Mancozeb, as per UNEP is banned in Egypt and UAE too, apart from Saudi Arabia. The Anupam Verma Committee notes that it is restricted in Korea and Sweden. Importantly, Mancozeb and its metabolite ETU are classified as probable human carcinogens.
- About Malathion and Chlorpyrifos and their use in locust control – Malathion is banned not just in Syria and Palestine, but in Bangladesh and UAE too as per UNEP. Further, the Anupam Verma Committee notes that it is restricted in Sri Lanka, Canada and Korea. Importantly, it is a probable carcinogen. Chlorpyriphos is banned in Bangladesh, Saudi Arabia and UAE as per UNEP. Anupam Verma Committee notes a ban in Sri Lanka and restriction in 4 other countries. Further, India already has examples of having banned certain pesticides for all uses except for locust control. Importantly, India has not instituted any mechanisms to try out and validate non-chemical approaches which require a life cycle approach to be adopted to pest management for locust control.
- Cost-effective and affordable alternatives – it appears that the Department of Chemicals and Petro-chemicals has not yet caught up with post-modern science of pest management to understand what the true sustainable and safe alternatives to these bannable pesticides are. There are many practices and products which rely on Nature for pest management and agro-ecological approaches in farming can successfully tackle pest and disease infestations in our agriculture. Those are the real alternatives, and if the Ministry is really keen on cost-effectiveness and affordability from a farmers’ perspective, these agro-ecological practices are the practices that you would also be advocating.
Given all the above, it would be in the best interest of everyone concerned that your department withdraws its letter to the Ministry of Agriculture and Farmers Welfare.
Copy to: Shri Sadananda Gowda, Hon’ble Union Minister for Chemicals & Fertilizers, GoI.