The decision of the union government to ban 27 commonly-used pesticides in all three main categories viz. insecticides, fungicides and weedicides in India has led to consternation among various stakeholders particularly a certain section of the industry. To understand the issue and its implications, let us put a few facts in order.
The manufacturing, import, sale, distribution and use of pesticides is regulated under the Insecticides Act [1968] with a view to prevent risk to human beings or animals, and for matters connected therewith. The Registration Committee [RC] – set up under the Act – registers every pesticide after scrutinizing the formula, verifying claims of efficacy and safety to human beings and animals and specifying the precautions against poisoning and any other functions. The RC is empowered to refuse registration of any pesticides if issues pertaining to safety have not been satisfactorily adhered to.
From time to time, the Ministry of Agriculture and Farmers’ Welfare [MoA&FW] – the nodal ministry for regulation of pesticides – orders review of the registered pesticides with particular reference to the risk these pose to human being, animals and the environment and based on examination by a committee of experts arrive at appropriate decision on ‘whether to allow their continued usage [with additional precautions, if any] or prohibit their use completely’.
In 2013, an expert committee was set up to study the continued use or otherwise, of a total of 66 pesticides which are banned in two or more other countries but continue to be registered for use in India. Based on its recommendations [the committee submitted its report on December 9, 2015], the government banned 18 pesticides in 2018. However, it allowed continued usage of the 27 pesticides, to be reviewed after completion of recommended studies.
In a gazette notification issued on 14thof May 2020, the MoA&FW issued a draft order intended to ban the manufacture, usage and storage of these 27 pesticides and sought comments or suggestions from stakeholders for the next 45 days. The notification says:-
‘Sixty-six insecticides which are banned or restricted or withdrawn in other countries but continue to be registered for domestic use in India’ were reviewed by an Expert Committee set up by the MoA&FW. The ministry considered recommendations of this committee and recognized that use of the ‘twenty seven insecticides are likely to involve risk to human being and animals as to render it expedient or necessary to take immediate action’. The pesticides to be banned include:
2,4-D, acephate, atrazine, benfuracarb, butachlor, captan, carbendazin, carbofuran, chlorpyriphos, deltamethrin, dicofol, dimethoate, dinocap, diuron, malathion, mancozeb, methimyl, monocrotophos, oxyfluorfen, pendimethalin, quninalphos, sulfosulfuron, thiodicarb, thiophante methyl, thiram, zineb and ziram.
The committee has found some of the above pesticides to be highly hazardous with potential to cause severe health effects viz. hormonal changes, neuro-toxic effects, reproductive and developmental health effects, carcinogenic effects as well as environmental impacts such as toxic to bees. For others, adequate data needed for regulatory purpose is not available. While, arriving at the decision, the government has also been guided by the fact that ‘newer’ and ‘safer’ alternatives are available for all the pesticides it intends to ban.
The generic industry [a euphemism to describe manufacturers other than firms who are innovators] has taken umbrage to the ban citing that this will chop off domestic sales – currently about Rs 20,000 crore – by about 20%. The export of pesticides will also take a hit of around 10% on the existing Rs 20,000 crore.
The farmers too have not taken it kindly saying they have been using these chemicals for a long time and have found them to be economical even as the alternatives are high priced and will increase the cost of cultivation. They have also questioned the timing of the decision. Apart from being hamstrung by Covid – 19 crisis, they also have to put up with an unprecedented locus attack that has gripped agriculture [horticulture crops are most vulnerable] in several states viz. Rajasthan, Punjab, Haryana, Maharashtra, Madhya Pradesh etc.
To combat locus attack, even as farmers need pesticide such as malathion, the government has decided to ban which will affect its availability.
The arguments given by these stakeholders are untenable. First, it is not as if that this has come as bolt from the blue. The government has taken the decision only after a thorough examination and evaluation of their safety in the light of available evidence – a process that continued for seven long years.
This process also involved consultations with manufacturers of the concerned pesticides. They got full opportunity to present their case before the expert committee including submission of studies to demonstrate their continued safety and efficacy. If, they believe that these pesticides have been in use for long causing no harm to humans or environment, they could have presented requisite data to substantiate their contention. But, that has not been done.
15 of the 27 pesticides that are proposed to be banned are considered ‘deemed to be registered pesticides’ in the country owing to data lacunae since several years’. This is anomalous. It shows that from the day one, firms who applied for their registration could not convincingly demonstrate their safety and efficacy to the regulator. This has not been done till date which eventually drove the union government towards its decision on their banning.
Second, developments in various states [they are expected to ensure compliance with regulations on ground zero] signaled that ban was in the making. In 2011, Kerala had banned monocrotophos, carbofuran, atrazine, etc on grounds of public health concerns. In 2017, Maharashtra banned monocrotohos and acephate due to high incidence pesticides poisonings among cotton farmers. In 2018, Punjab said ‘no’ to fresh licenses for 2,4-D. benfuracarb, dicofol, methomyl and monocrotophos citing harm to humans and environment.
Third, when it comes to a decision on pesticides which are hazardous, the only criteria the regulator relies on is ‘safety’ and ‘efficacy’. It also sees whether newer safer alternatives are available. The decision can’t be guided by any other consideration such as cost. Merely because an existing product costs less can’t justify its continued use even if it is found to be unsafe. On the same logic, a new safer product can’t be debunked – simply because it costs more.
Without compromising on this basics, even if one were to consider the economics of use, then we need to make comparison on a like to like basis. Here, one should not be looking only at the price but also the dose; in addition, the impact on crop yield and crop quality has also to be considered. Let us illustrate with an example.
One kilo of Acephate [this is in the banned list] – used for controlling cotton pests – costs around Rs 550 per kg against an alternative say, Imidacloprid a newer and safer molecule which is priced at Rs 1,200 per litre. As regards dose, 300 gm of Acephate is required to control pest over an acre, in case of Imidacloprid, the requirement is <100 ml per acre. The effective cost per acre for the latter is Rs 120/- against Rs 165/- for former. Higher crop yield and better crop quality in case of Imidacloprid serves as icing on the cake.
Fourth, an argument that banning will result in non-availability and affect farming operations is fallacious. The phase out of any product takes prospective effect. In the instant case, taking 45 days for comments from stakeholders [from the date of notification i.e. May 14, 2020], earliest the order can be enforced is July 1, 2020. That apart, normally the government allows manufacturers time to clear their existing stocks. Moreover, alternative safer products are available in the market place which will ensure that farmers don’t suffer.
Finally, 27 pesticides in the proposed ban list are less than 10 percent of the current 289 pesticides registered for use in India. Hence, banning these 27 pesticides is unlikely to have any adverse impact on agriculture production and India’s food security all the more when newer and safer alternatives are available for all of them – as brought out in a careful and comprehensive assessment by the expert committee.
On taking a holistic look at all factors viz. safety, efficacy, availability, cost-benefit etc it turns out that the decision of the government to ban 27 pesticides is apt. It will help in promoting use of ‘newer’, ‘safer’ and environment-friendly crop protection solutions. It will drive companies to focus more on research & development and innovation to meet diverse need of farmers thereby helping the latter in boosting agricultural production and increasing their income.