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 (âan 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, each pesticide is registered for a particular pest on a particular crop (it is worth noting that several pesticides are registered for the same pest in the same crop too). However, it has been documented that indiscriminate and illegal recommendation of pesticides is done by various players without any liability being fixed on them. This in turn has huge implications for farm livelihoods, food safety, environmental sustainability and so on. It is ironical that very often, despite our irrational regulatory approach and indiscriminate recommendation by proponents of pesticides, the farmers are blamed for indiscriminate and injudicious use of pesticides! This is a classic case of the victims being made the culprits.
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!
Pesticides in our farming and food: India’s regulatory regime
India’s regulation of toxins in the form of pesticides in our farming and elsewhere is neither rational nor scientific. We list out a few important issues with the unacceptable regulatory regime that governs poisons in our farming and food.
THE UNSCIENTIFICITY OF MRLs & ADIs IN INDIA
Apart from registration and other regulatory functions that flow out of the Insecticides Act in India, a concept called Maximum Residue Limits (MRL) is also part of the regulation, as quantitative limits set up by the Food Safety and Standards Authority of India (FSSAI) under the Ministry of Health & Family Welfare. It is worth noting that for the longest time, registrations at the Agriculture Ministry were happening independent of MRLs being set up by the Health Ministry. To this day, MRLs have not been set up for all uses for which particular pesticides have been registered.
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 had officially adopted IPM (Integrated Pest Management) as its main policy approach to plant/crop protection way back in 1985. The lack of political will is reflected in some pesticides not being banned, the pathetic outreach figures through FFS (Farmer Field Schools to promote IPM approach amongst cultivators), IPM not being made an integral part of Package of Practices for all crops for all extension work around the country, the pesticide consumption not decreasing in volume or value, the number of export consignments that get rejected etc. etc.
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.