A RATIONAL PEST MANAGEMENT POLICY FOR INDIA

Background India does not have a pesticide policy leave alone a rational pest management policy. The only articulations which could be interpreted as policy formulations are ones incorporated into the Agenda 21 declarations of this country, where Integrated Pest Management (IPM) was given a great thrust1. Other articulations are included in the report submitted by the Working Group on Organic And Biodynamic Farming formed under the Tenth Plan, in the Planning Commission (report from September 2001) and the report of the National Taskforce on Organic Agriculture. The latest in the series of recommendations that reinforces the need to wean away farmers from synthetic pesticide use is the Joint Parliamentary Committee report, headed by Mr Sharad Pawar, who is the present Minister of Agriculture. Further, correlating to other commitments / indication of commitment that the Government of India had made, either as part of the FAO code of conduct, or the Rotterdam Convention, or the Stockholm Treaty at the international level, there is an imperative to change the national laws and regulations so that they conform to the overall framework. Also taking into account other policy documents like the National Agriculture Policy (here Sustainable Agriculture has been given an important thrust) and the National Health Policy of 2002, it becomes important to re-visit the current scenario with regard to pesticides their production, distribution, storage, marketing, transportation, use and disposal in the country and find ways of consistent reduction. The problems with regard to pesticides in general, and those that get used in crops like cotton in India are too well known to be repeated here. The context also has to take into account the fact that sustainable and safer alternatives are present in most cases, and even noted scientists from premiere institutions like IRRI are now revealing startling findings about pesticides: that they were never needed in the first instance.

To alleviate the ill effects of pesticides, India has officially adopted IPM as its policy and is a prominent feature in recent Five Year Plans. On a broader scale, IPM is defined and explained in terms that encompass the farm families & their environment, and regional food security. The essential element for IPM includes one or more management activities that are carried out by farmers that result in the density of potential pest populations being maintained below levels at which they become pests, without endangering the productivity and profitability of the farming system as a whole, the health of the farm family and its livestock, and the quality of the adjacent and downstream environments.
Agenda 21 articulations of Government of India, repeated in Natural Resource Aspects of Sustainable Development in India, Indias official report submitted to the 5th Session of the UN Commission on Sustainable Development. The present paper

Even if one accepts that IPM is a rational policy, the lack of serious political will of the Indian governments (state and central) in pushing IPM is evident from the continuing intense use of pesticides in certain areas as well as the financial outlays and physical progress of work in terms of the Farmer Field Schools created and trainings organized. The actual progress is dismally low compared to the need evident from the pesticide crisis at both the farming and urban consumption end.

The present paper creates a desirable rational pesticides policy for India, where the manufacturing, distribution, transportation, storage, marketing, use and disposal of pesticides is driven by objectives centered around ecological and sustainable agriculture (and not just a part of chemical management). This is also to be seen in the context of several countries elsewhere coming up with similar policies and being in a position to not only improve the situation of the environment in their countries but also being able to capture niche markets of organic produce. Such a policy also paves the way for more trade opportunities conforming to acceptable standards (like Codex, for example).

THE BASIC PRINCIPLES ON WHICH THIS POLICY RESTS:

That any perspective on pesticides should be driven by concerns of sustainable agriculture development That precautionary approach is required in the case of pesticides That pesticides should be products of last resort if no safer alternative exists (pesticide substitution principle) That the Polluter Pays Principle should be an important guiding and binding principle; liability systems should be based on cradle to grave accountability, for all processes and products that the pesticide industry comes up with.

Overriding goals

Ecological agriculture without use of pesticides throughout India should be the overriding goal. This goal should manifest itself on several fronts, the important ones being: 2. No hazards to or negative impacts on human health, non-target organisms, groundwater or the environment through production, use, release or disposal of pesticides No pesticide residues in groundwater, surface waters, rainwater, drinking water, foodstuffs or the human body No erosion of livelihoods2 due to pesticides in agriculture, either directly or indirectly A quantified yearly reduction of pesticide use as per set targets Immediate steps in the manufacture, marketing, use, importing and exporting of pesticides

There is an urgent need to review all the registered chemicals in India, towards two objectives: Ban with immediate effect all those pesticides that have been banned in two other developed/developing countries (refer to the Syrian policy provided as an annexure for more on this).

The term Livelihoods is used in a broad sense here, to include human and environmental health, economic conditions etc.

A ban on those pesticides whose active agents and/or other active components or decomposition products have the following characteristics: - are carcinogenic, mutagenic or reproduction-toxic (CMR) - have endocrinal disruption effects - highly acutely toxic (WHO class Ia, Ib, II) - are neurotoxic - are persistent - are pesticides which may contaminate groundwater - are bioaccumulative - whose ecotoxicity is a cause for concern, e.g. toxic to bees or fish - are hazardous to water class 2 (hazardous to water) and 3 (highly hazardous to water) - listed by the Ospar Convention as "hazardous to the marine environment"

Any violations in the above bans are to be met with strict sanctions in civil and criminal law. For all remaining pesticides, there should be a liability system that works on cradle to grave accountability principle.

3. Core elements of Registration, Review and Monitoring

Registration should have strict tests and criteria adhered to, where tests should take into account long term effects beyond five years too and take into account the cocktail situation of use in real life (human and environment health, in addition to efficacy of the chemical in pest control); Registration should be based on the Precautionary Principle, which means that any existing data on the chemical, even if insufficient in a fullest sense and even from other places, should be considered and possible future hazards avoided There should be a time bound de-registration and re-registration clause for every pesticide registered3 as well as fixed periodic reviews Registration and review processes should be transparent and with participation from external, independent agencies also. Pro-active dissemination of information on all the pesticides under review necessary so that more information flows inwards Every registration should be accompanied by a liability cause centered around Polluter Pays Principle, where accountability terms and mechanisms are spelt out for non-performance/non-effectiveness and for human and environmental degradation caused

Institutional mechanisms in this regard: Transparent assessment and authorization of pesticides: there must be public access to, and participation by environmental and consumer protection organisations in assessment and licensing procedures for pesticides and the information used thereof. There should be more public participation at all levels of environmental decision-making (including making all meetings of regulatory authorities open to the public). This means

In countries like the US and Sweden, this clause exists for every registration

inclusion of public, qualified representatives on the decision-making bodies. should be a reconstitution of the regulatory authorities to this effect urgently.

There

There is also a need to set up an inter-ministerial committee with environment and health ministries playing a pivotal role in the processes of registration and review. There should also be more institutions set up and resources allocated for monitoring of health impacts from pesticides. 4. REGULATION OF THE PESTICIDE INDUSTRY4: Marketing: There should be serious restrictions on marketing (mostly advertising but also on retail sales) of pesticides since these are inherently poisonous chemicals. Any marketing done with incentives should have penal clauses. Marketing of pesticides should also strictly adhere to the FAO code of conduct, including the Labeling Norms. Labels on pesticide containers should clearly mention in the local language, with more symbols and color coding evolved for the purpose the possible health hazards short term and long term from the use of the pesticide, in addition to poisoning symptoms and anti-dotes. Extended Product Responsibility: The principle of EPR should be applied to specific manufacturers as well as the industry in general, for the complete life cycle of the products that are created, including the containers in which pesticides are sold, as well as for expired/obsolete pesticides and pesticide dumps. Pesticide Substitution and Reduction Policy: The manufacturer has the onus of proving safer alternatives do not exist; also, the obligation to provide all information including bans and restrictions elsewhere and the grounds for the same. The industry has to cooperate with the yearly targets set for reduction in use, which encompasses reduction in manufacture and marketing5. Taxation policy: The industry has to be subjected to increased taxation through which reduction in use is hoped to be achieved. The additional revenues are expected to support research in organic farming as well as for monitoring health impacts6. Pesticide Manufacture: Strict siting guidelines should be evolved and implemented. There should also be strict occupational health guidelines. Stricter monitoring of worker safety in pesticide manufacturing facilities to be entrusted to bodies consisting of independent observers also. No synthetic pesticide manufacturing or formulation is to be allowed in the SSI sector.

5. REGULATION OF USE OF PESTICIDES:

This means all those organizations and individuals engaged in manufacturing, formulating or marketing pesticides and pesticide products. 5 Sweden had a well-thought out pesticide reduction programme, including the phasing out of particular chemicals 6 Denmark, for instance, enacted such a policy way back in 1996 itself

Monitoring of pesticide use should be left to decentralized systems, with greater public participation and transparency. For this, more regulations with regard to record-keeping of pesticide use are also necessary (which crops, in what combinations, by which farmers, with what intensity, by what methods of spraying etc.: this should be left to the agriculture departments along with Panchayats and at the pesticide dealer end, during sale of pesticides). It is also important to amend various existing regulations to make them consistent with 73rd and 74th amendments where local elected bodies have a right to decide on matters pertaining to their jurisdiction, including safeguarding the local environment and human health. Where such effective monitoring of pesticide use, including Safe Use, is not possible, the marketing of pesticides should not be allowed. It becomes the responsibility of these monitoring agencies to put into place mechanisms that ensure rational use, right from the stock received by distributors and dealers, to the use of empty pesticide containers. As part of this regulation, some sensitive ecological zones be declared as Pesticide Free Zones, and not pesticide marketing or use allowed here. IN addition to this, some Pesticide Holidays be declared so that intense use of pesticides over long periods of time does not build up in an area. As part of regulating and reducing use of pesticides, more support to organic agriculture, including research, training, extension and credit support to be provided by the government. This includes moving any indirect subsidies that still exist to support pesticides to organic and sustainable alternatives. There should be restrictions on pesticide use in terms of location of use (in a specified perimeter around schools, habitations, hospitals, ecologically fragile zones etc.). 6. INFORMATION, DOCUMENTATION, DISSEMINATION AND EDUCATION ABOUT PESTICIDE HAZARDS: There should be extensive government-run awareness and publicity campaigns against pesticides, highlighting the hazards that they pose. For this purpose, all mainstream media channels as well as alternative communication channels have to be fully utilized. The technical and documentation facilities in all hospitals and pesticide residue laboratories are to be enhanced. In the hospitals, poisoning data should be desegregated into intentional poisoning (suicides) and occupational/exposure poisoning. More studies to be encouraged to document the impacts of pesticides, by medical and agricultural colleges and resources allocated for the purpose. Results of such studies to be put out in the public domain and actively disseminated. Consumer awareness and protection to be made part of the plans.

7. IMMEDIATE DISASTER MANAGEMENT PLANS IN CERTAIN AREAS:

There is a need to identify those areas in the country where pesticide usage patterns have reached the scale of a disaster this is reflective in the cropping patterns (cotton, paddy, plantations, vegetable cultivation etc.), in the patterns of intensity of use (sales figures in particular districts of the country are indicators), in pest resistance and resurgence seen, in poisoning cases reported in addition to other health effects, in groundwater contamination and so on. These areas should be declared as Pesticide Disaster Areas and special plans drawn up for remediation and conversion of these areas into Sustainable Agriculture areas. Adequate resources have to be allotted for the purpose. Health and medical services in these areas are to be specially geared up to meet the impacts of pesticide abuse. Livelihood and medical rehabilitation in these areas (Kasargod, for example) should be borne by the pesticide industry. There should also be special Preparedness Plans drawn up for emergencies like food production crises, for outbreak of particular diseases etc., and the use of pesticides in such a case. 8. PROTECTION PESTICIDES: OF CONSUMERS FROM ADVERSE IMPACTS OF

The government should take full responsibility to provide Safe Food, devoid of any pesticide residues, to all citizens. This includes, in the short run, no marketing of critically contaminated foodstuffs. For this, there is a need to upgrade technical facilities with regard to monitoring of residues as well as better standards for residues allowed (BIS standards to be upgraded to the best standards available in the world). There should be an acknowledgement that residue management tools like MRLs and ADIs are only protective to some extent and do not take care of the whole problem (the synergistic effects of multiple chemicals is not yet estimable or known to human kind). The same should be communicated to consumers even when contamination is below legal limits. There should be pro-active dissemination of the possible health effects of pesticide contamination and the advantages of switching over to organic foods. Crops and grains that dont require chemical farming in their very cultivation should be provided more support and awareness created about the same (millets, for example). 9. EXPORTS: The government should not allow any exporting of pesticides which might not be allowed for use within the country on account of their hazardous nature. The data on exports be placed in the public domain with full details. 10. OBSOLETE PESTICIDES: Producers and suppliers in countries of origin must take on full logistical, technical and financial responsibility for their expired products.

Also, inventories of all expired pesticides throughout the country must be made in a special programme. All these must be made safe by being re-packed, brought back and in accordance with the requirements of the Stockholm POPs Convention disposed off in an environmentally sound way. The manufacturers in specific and the industry in general is to be made responsible for providing resources for the same. 11. BILATERAL, MULTILATERAL AND PROGRAMMES IN AGRICULTURE: PRIVATE DONORS THEIR

Sustainable and Organic agriculture without the use of pesticides should be the policy priority for all donors. Their support should be extended only to such projects. 12. INTERNATIONAL COMPLIANCE: INSTRUMENTS, OBLIGATIONS THEREIN AND

For all those international instruments that the country had signed up, proper implementation mechanisms should be put into place, if not already done so. This includes the FAO Code, the Rotterdam Convention and ILO conventions. In addition, India should immediately ratify the Stockholm Convention.