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It's not an outright ban; why are other highly hazardous pesticides left out?: PAN India

Counterview Desk 
Even as welcoming the recent Government of India (GoI) ban on four highly hazardous pesticides, the advocacy group Pesticide Action Network (PAN) India has regretted that the latest order has not banned outright, but qualified the ban with conditions. Government of India gives a window period of one year for farmers to move towards alternatives, PAN India said in a statement.
Pointing out that the ban notification only says that “sale, distribution or use of Monocrotophos 36% SL shall be allowed only for clearance of existing stock till its expiry period”, the advocacy group underlined, “There is ambiguity in this language which can be used to build stocks in this window period of 1 year, enabling the continued use of Monocrotophos beyond the 1 year period and until the stocks are cleared.”
Insisting that a specific line banning manufacture of Monocrotophos (all its formulations) is required, it said, field information on pesticide poisoning and exposures reinforce the demand for outright ban of other identified pesticides as well. The Agriculture Ministry has to explain why 16 pesticides, declared as highly hazardous, have still been left out.

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India has banned four insecticides -- Dicofol, Dinocap, Methomyl and Monocrotophos – through a Gazette Notification dated 29th September, 2023, but published on 6th October, 2023[1]. Pesticide Action Network (PAN) India welcomes the ban on these four pesticides, especially the addition of monocrotophos, as we represented for its inclusion in the ban list, subsequent to the draft order published in February, 2023.
Dr. Narasimha Reddy, public policy expert says that “this ban almost coincides with the recently concluded negotiations at the Fifth International Convention on Chemicals Management (ICCM5) in Bonn, and the emergence of Global Framework of Chemicals, and the target to eliminate Highly Hazardous Pesticides (HHPs) by 2035, among others”.
Monocrotophos has been named in several pesticide poisoning cases across India, including in the infamous Yavatmal pesticide poisoning episode, in 2017. Maharashtra Association of Pesticide Poisoned Persons (MAPPP) has been advocating for a ban on this and other pesticides involved in deaths and injuries to farmers and farm labour. In fact, Maharashtra government has written a letter to the Union Government of India to ban this and 4 other pesticides. There was no response from the government of India to that letter.
Even the latest order has not banned outright, but qualified the ban with conditions. Government of India gives a window period of one year, for farmers to move towards alternatives. It also says, “sale, distribution or use of Monocrotophos 36% SL shall be allowed only for clearance of existing stock till its expiry period.” There is ambiguity in this language which can be used to build stocks in this window period of 1 year, enabling the continued use of Monocrotophos beyond the 1 year period and until the stocks are cleared. A specific line banning manufacture of Monocrotophos (all its formulations) is required.
Additional Comments and observations from the ban notification:
1. Reference to Carbofuran in this notification is interesting, puzzling and is a cause of consternation. In fact, no change or restriction is brought in the case of Carbofuran even though it is mentioned on the top of the list. It clearly states that “All other formulations of Carbofuran, except Carbofuran three percent Encapsulated granule (CG) along with the crop labels, may be stopped from use.” This means Carbofuran three percent Encapsulated granule (CG) is not banned. Interestingly, Carbofuran 3% CG formulation is the only formulation registered in India. No other formulation is registered in India. We need Central Insecticides Board and Registration Committee (CIB&RC) to clarify on this.
2. The Ministry of Agriculture and Farmers Welfare should have re-issued the previous notification or approved the draft notification dated 18th May 2020, without modifications. Instead, it has reformulated and reduced the number of pesticides to be banned to three, qualified ban on one and allowed restricted usage of other seven pesticides. Earlier in July, The honorable Supreme Court made observations while hearing a PIL related to pesticide bans in India, that the Center has been constituting committees after committees to review the the proposal of banning 27 pesticides in 2020, so as to get a favorable response.
3. Banning three HHPs is right and welcome. But this is not enough. Expert Committee Report and the field information on pesticide poisoning and exposures reinforce the demand for outright ban of other identified pesticides as well.
4. The remaining 16 pesticides, out of the 27 pesticides in the previous draft notification, do not find any mention. The Agriculture Ministry has to explain why these 16 pesticides have been left out.
Process of watering down regulatory outcomes to satisfy profit motive of agrochemical industry continues
5. Malathion was restricted long back to be used only for public health purposes and banned from usage on food crops. However, this draft notification allows its usage on two vegetable crops, namely Paddy and Cabbage. The Agriculture Ministry has in fact extended its usage, from the previous restriction. Since it has been recommended for ban given its hazard potential, especially on food crops, Centre cannot justify continued usage of this highly hazardous pesticide. Malathion has been found in food residues across the country.
6. Surprisingly, seven pesticides were not proposed for an outright ban. These are currently being notified for restricted use on certain crops. This means they are banned for usage on specific crops, which were listed in the original registration. These seven HHPs are notified for amendment in the label claim. Pesticide companies that are manufacturing and marketing these pesticides have to change the labels, wherein the crops on which they can be used are mentioned.
“There is no rational for label change, and not outright ban as represented by us and recommended by the Expert Committee. Label change is merely a technical matter which does not have any implications in the field use, given that many pesticides in the country have been recommended beyond the approved use of pesticides in the country by Agriculture Universities and Commodity Boards, and actual field use is happening on many more crops as well as non approved pesticides have been detected among agriculture commodities in residues analysis”, says A. D. Dileep Kumar, CEO of Pesticide Action Network India.
While, PAN India appreciate the efforts of Government of India on banning some pesticides, it feels that the recent developments of appointing committees after committees, following the 2020 Draft ban notification  to review regulatory decisions is a process of watering down the regulatory outcomes to satisfy the profit motive of the agrochemical industry, undermining public health and environmental well being.
PAN India urges Government of India to urgently ban the remaining pesticides listed in the 2020 draft order that proposed banning of 27 pesticides since the Expert Committee and the Registration Committee found that their use is likely to involve risk to human being and animals.
---
[1] S.O. 4294(E) Notification, Ministry of Agriculture and Farmers Welfare (Department of Agriculture and Farmers Welfare), New Delhi, 29th September, 2023, published on 6th October, 2023, in exercise of the powers conferred by section 27 read with section 28 of the Insecticides Act, 1968 (46 of 1968). Click here for PAN India's information note on the ban

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