August 15th 2020
Joint Secretary (Plant Protection),
Ministry of Agriculture and Farmers Welfare,
New Delhi-110 001.
Subject: Feedback on S.O. 1512(E) Draft Order – Banning of Insecticides Order, 2020
Greetings! I am writing on behalf of Rythu Swarajya Vedika (RSV), a state-wide network of farmers, scientists, environmental and consumer organizations and concerned citizens working in both the Telugu states of Telangana and Andhra Pradesh.
This letter is a collective submission, not only from Rythu Swarajya Vedika, but a large number of organizations and individuals in Telangana and Andhra Pradesh. This includes many farmers’ organizations, cooperatives and FPOs, as well as prominent persons such as Shri Vadde Sobhanadreeswara Rao (former M.P. and Agriculture Minister of AP), Prof. M.Kodandaram (leader of Telangana movement and President of Telanagana Jana Samiti), Dr.G.V.Ramanjaneyulu and Dr.N.Venugopal Rao (agricultural scientists), Dr.V.Rukmini Rao (women’s rights activist).
We submit this as a collective feedback on S.O. 1512(E) Draft Order Notification called “Banning of Insecticides Order, 2020” which was published on 18th May 2020 by the Ministry of Agriculture and Farmers’ Welfare, Government of India, soliciting inputs from citizens and organizations.
1. We welcome the draft order that proposes the banning of 27 insecticides included in the notification, which is actually a long-overdue measure from the government. As the notification itself notes, the Expert Committee headed by Dr Anupam Verma was set up in 2013. Their report was first considered by the Registration Committee in the Central Insecticides Board & Registration Committee (CIBRC) way back in December 2015.
2. We hope that no delay tactics deployed by the industry will come in the way of prompt ban on these 27 deadly pesticides. Given that the Government of India took quite long to actually effect a ban on 12 pesticides in the past from the time the draft order was notified, we urge that the Centre actively facilitate the suspension of licensing for sales of these pesticides in all those states where the state governments are keen on putting into place an end to the usage of these deadly pesticides.
3. While this draft Order refers to only 27 bannable insecticides, we call upon the Ministry of Agriculture to look at another 70+ pesticides which need to be banned in India. A complete list of pesticides banned in one or more countries elsewhere including many not necessarily considered by Anupam Verma Committee is attached to this letter as Annexure 1. Within such a list of bannable pesticides are pesticides such as Paraquat.
Some issues that we would like to raise with regard to speedy implementation of decisions related to review and prohibition/ban of bannable pesticides in India and about the 27 pesticides for which a ban is now proposed are given below.
Pesticide Poisoning Deaths & Hospitalisations
Rythu Swarajya Vedika documented cases of pesticide poisoning at district hospitals and found that every month there are between 50 and 100 deaths and hospitalisations related to pesticide exposure in each district hospital. Our fact-finding efforts (along with Alliance for Sustainable and Holistic Agriculture – ASHA) over the years show very clearly that certain pesticides like Monocrotophos, Acephate, Carbendazim, Mancozeb, Quinalphos, Chlorpyriphos, Methomyl etc. are repeatedly implicated in such incidents of occupational poisoning. A ban on the pesticides will certainly help reduce such pesticide poisoning deaths and hospitalisations. The right to life of farm workers and farmers struggling to make a day’s living by spraying pesticides will be thereby protected.
Chronic Health Impacts
Out of the 27 pesticides in the proposed list, 6 are probable/likely carcinogens as per US EPA, 3 are endocrine disrupting, 3 are reproductive toxicants, and 1 is a probable human carcinogen in WHO classification. Within chronic health impacts are issues like neurotoxicity of pesticides making exposed persons depressed and suicidal and resorting to killing themselves using those very pesticides, and of immunity system getting affected which will have its own implications in pandemics like the current covid-19 pandemic.
Impact on non-target organisms
Malathion, chlorpyrifos, monocrotophos etc., are implicated in various wildlife poisonings across the country as per various media reports and experts. Further, the eco-toxicity of several of these pesticides in terms of their harmful impacts on bees, earthworms, fish etc., has already been noted. In 2013, it was found that poachers were using carbofuran to kill tigers and leopards in Uttarakhand.
Impact on Exports and India’s Trade Security
The ban being proposed will help India in tackling rejections in our crop export consignments due to residues and improve our trade security. Presence of pesticide residues has led to rejection of hundreds of our exports in countries around the world in Asia, North America and Europe affecting businesses and farmers. For instance rejection of such exports was the main reason why the basmati rice export price reduced from Rs 3700 per quintal in 2018 to Rs 2700 per quintal in 2019. Earlier this year, Indian government has recently said that due to EU’s practice of low MRL limits, major barriers are created for exports of rice, peanuts, chillies, spices, tea, fruits, vegetables and sea food.
Some of the pesticides implicated in such export consignment rejections by other countries include acephate, carbofuran, thiophanate-methyl, chlorpyrifos, carbendazim, dicofol, dimethoate, malathion, methomyl, monocrotophos, quinalphos, methomyl, thiodicarb etc. which feature in the list of 27 pesticides to be banned. We therefore welcome the notification for this reason too.
State Governments Desirous of Ban as well
State governments like Kerala, Andhra Pradesh, Punjab, Maharashtra, Sikkim etc., have already taken pro-active interventions in trying to prohibit the use of several of these pesticides. In 2011, Kerala stopped sales of Atrazine, Carbofuran and Monocrotophos amongst 11 others. AP had recommended to the Centre a ban on pesticides like Benfuracarb, Deltamethrin, Dinocap, Thiodicarb and Thiophanate-Methyl amongst several others. Maharashtra had recommended a ban on Monocrotophos and Acephate amongst others. Punjab, in January 2018, tried to stop sales of pesticides like Benfuracarb, Dicofol, Methomyl, Monocrotophos and Thiophanate Methyl in an order that sought to ban 20 pesticides. Monocrotophos was briefly banned by Adilabad district collector in 2019 as well. In 2014 under Sikkim Agricultural, Horticultural Input and Livestock Regulatory Feed Act Sikkim banned all inorganic agricultural inputs including highly hazardous pesticides and pesticides were withdrawn in Sikkim in 2016.
However, a serious statutory shortcoming in our current regulatory regime restricts state governments (and district administration) from banning pesticides, and they can only resort to stopping of licensing of sales. The proposed ban will therefore uphold a federal cooperation spirit.
Chemical residues in our food
While the central sector scheme of the Ministry of Agriculture and Farmers’ Welfare called MPRNL (Monitoring of Pesticide Residues at National Level) routinely reports a certain level of contamination of India’s food samples tested in the project, there are numerous independent studies that indicate a much higher level of contamination of our foods with pesticide residues. Such studies emerge not just from civil society groups but several public sector research bodies and even from judicial institutions’ suo motu action at times. Some of the pesticides listed in the notification feature in these reports too – for example, chlorpyrifos, deltamethrin, malathion, acephate, malathion, pendimethalin, quinalphos, dicofol, monocrotophos etc. This is one more reason why we welcome this ban order.
Pursuing Sustainable Development Goals and Compliance with international commitments
Goal 3 (Good Health and Well-being), Goal 12 (Responsible Consumption and Production), Goal 14 (Life Below Water), and Goal 15 (Life on Land) all require governments and businesses to get more responsible about toxic chemicals in our food, farming and environment. The proposed ban on 27 pesticides takes India closer to its commitments to SDGs, and therefore, is welcomed by us.
Pesticide Biosafety Data
Data from the industry must not be used for the pesticides review as this would present an obvious conflict of interest. For future, we propose that funds collected from pesticide industry on their turnover must be used by the government to conduct independent, transparent and long-term research studies on a continuous basis on the pesticides for which additional data is sought. Data from the studies must be put out in public domain on a government website in a searchable format. All the insecticides must be banned until such studies are completed – as the focus must be on biosafety. Further, industry-linked individuals must not be allowed to be involved in these studies and reviews, while public participation must be sought in general.
Scare-mongering in the name of impacts on Yields
It is often argued that production and productivity will get affected without the use of pesticides like the ones listed in the latest notification. This was argued for the August 2018 ban order too. However, there is no evidence whatsoever that these pesticides are needed for our productivity to be improved or sustained. No declines are seen in India specifically related to the earlier set of pesticides that were banned or in states that have taken policy decisions on certain deadly chemicals or an overall non-chemical approach. In fact, for most crops, evidence is to the contrary – production and yields are increasing.
These insecticides are banned in several countries including China and those in European Union. Despite the bans, these countries have higher yields than India’s for crops for which these pesticides are registered and used which illustrates that farming can indeed be done without these pesticides.
Alternative pest management science is not just safer but also far more affordable
The industry is arguing that alternatives to the about-to-be-banned chemicals are expensive for farmers. They say so because they are only looking at chemical molecules that the industry can manufacture and sell as alternatives. The real alternatives based in agro-ecological pest management do not cost much and farmers will find it very affordable and even free of cost in many cases if they use Nature’s processes and products for pest management.
In the mainstream pest management science, Integrated Pest Management (IPM) was shown as the most progressive approach so far. Here, NIPHM has evolved IPM packages for numerous crops and this includes grapes (here, chemical alternatives to the proposed-to-be-banned pesticides can be seen). This is available at https://niphm.gov.i/IPMPackages.html.
Non-Pesticidal Management (NPM) alternatives and approaches to pest management in various crops are available on www.pestoscope.com which is tried and tested in lakhs of acres of CMSA (Community Managed Sustainable Agriculture) in Andhra Pradesh.
Another ICAR institute, Indian Institute for Farming Systems Research (IIFSR) in Modipuram had brought out its own set of organic farming packages for different crops and states based on a multi-year research, available at: http://www.iifsr.res.in/npof/index.php?id=package_of_practices . Therefore, farmers have the choice of choosing from IPM, NPM and organic PoPs.
Arguments by Ministry of Chemicals and Fertilizers
An argument has been made by Ministry of Chemicals and Fertilizers (by Secretary R.K. Chaturvedi on 2nd June 2020 – Ref C-I-25016/3/2016-CHEM.II – Part (2)) in its letter to Ministry of Agriculture that even where India wishes to ban insecticides, it must continue exporting these pesticides. This would show India in poor light where India exports such insecticides which are being banned in the country too and show India avoiding its responsibility towards other nations. India must in fact insist with other countries to not export directly or through transit routes pesticides with strong restrictions or bans on their usage in their home countries.
It has been argued by industry entities that the pesticides have been registered after all requisite data has been submitted on bio-efficacy, toxicity, residue etc., whereas in reality there are several pesticides that have been “deemed to be registered” even in the absence of such data. Even for the review that led to this proposed ban, industry did not comply with data required by the regulators and minutes of the RC meetings show that such data was repeatedly asked for. It is clear from the notification of the draft ban order in May 2020 that such studies have not been done and data submitted. Meanwhile, there is adequate data that justifies the ban.
Further, it is unacceptable to say that “sudden banning” will lead to wasted investments, when it is at industry’s pace that Ministry of Agriculture has actually been moving. There is nothing ‘abrupt’ about this draft ban order, coming as it does 7 years after a review committee was constituted in 2013. There is also nothing unilateral about the review process and subsequent decisions since industry was part of the review process. Pesticides industry associations as well as individual MNC and Indian companies’ representatives participated in the Varma Committee processes.
Another argument being referred to in this letter from DCPC is that these pesticides need to be considered for dealing with desert locusts is already covered in the Ministry’s drafts where exception on using specific insecticides for desert locusts is already mentioned. In fact, the Ministry of Agriculture must prioritize non-pesticide management techniques of dealing with desert locusts which have been highlighted in much detail.
The comments mentioning that pesticide usage in India is much less compared to other developed countries is fallacious. This argument is highly misleading because exposure routes are what matter, not (intensity of) usage of pesticide. Compared to other countries with high levels of mechanization, farmers and farm workers are exposed in more direct ways to deadly pesticides in India and this is a more important aspect of risk assessment.
Arguments that this ban will lead to MNCs taking over our market is not a valid argument in this context since poisons are poisons, irrespective of which company makes them and have to be stopped. Further, Indian and foreign companies are working together in the case of numerous molecules. It is clear that many Chinese companies will find their markets being cut off with this ban, since the share of imports from China is the largest when it comes to these 27 pesticides. The industry is throwing unreliable data about potential losses from the proposed ban. However, human lives/livelihoods and environmental regeneration matter more than profiteering by the industry.
A detailed response to the DCPC from ASHA is available here: http://www.kisanswaraj.in/2020/06/25/ashas-letter-to-secretary-dept-of-chemicals-petrochemicals-on-his-letter-to-the-ministry-of-agriculture-about-proposed-ban-on-27-pesticides/
We end this letter by once again welcoming this draft ban order, by demanding that the final ban order on all 27 pesticides be published soonest and also urging the Ministry to immediately take up review of other bannable pesticides which are around at least 75 in number. We would like the government to know that such bans affirm that our regulatory regime is not stagnant and is actually co-evolving with bio-safety science and post-modern pest management science. This is an opportunity that India has to take a leadership role in showing the world how agro-ecology can be scaled up and how a paradigmatic shift is possible by bold decisions to phase out agro-chemicals.
KiranKumar Vissa (Rythu Swarajya Vedika)
Signed by the following:
1) Vadde Sobhanadreeswara Rao, Former Agriculture Minister, A.P., Former M.P. (LS)
2) Dr. G.V. Ramanjaneyulu, Executive Director, Centre for Sustainable Agriculture
3) Prof. Kodandaram, President, Telangana Jana Samiti (TJS)
4) Kanneganti Ravi – Convenor, Telangana Rythu Joint Action Committee
5) Dr. V. Rukmini Rao – Gramya Resource Centre for Women, Telangana
6) Prof. Nagumothu Venugopal Rao (Retd. Prof., Acharya NG Ranga Agricultural University)
7) Asha Latha – Mahila Kisan Adhikaar Manch (MAKAAM), Telangana
8) Cheruvu Bhanuja – Rural and Environmental Development Society, Andhra Pradesh
9) P.S.Ajay Kumar – National Secretary, All India Agricultural and Rural Workers Association
10) Kondapalli Achyuta Ramarao – State Secy, All India Kisan Mazdoor Sabha (AIKMS)
11) P. Shankar – Dalit Bahujan Front (DBF), Telangana
12) Ambati Nagaiah – President, Telangana Vidyavantula Vedika, Telangana
13) Gorrepati Madhava Rao – President, Human Rights Forum, Telangana
14) Usha Seethalakshmi – Mahila Kisan Adhikaar Manch (MAKAAM), Telangana
15) M. Janardhan – PILUPU, Telangana
16) Naveen Ramisetty – Rythu Swarajya Vedika, Telangana and A.P.
17) Dr. Uma Shankari – Rashtriya Rythu Seva Samiti, A.P.
18) Sayanna – Telangana Raithanga Samiti
19) Raghava Chary – President, Palamuru Adyayana Vedika, Telangana
20) Thomas – Premananda Adyatmika Samstha, Telangana
21) Kotamraju Ranadhir – All India Kisan Mazdoor Sabha (AIKMS)
22) Dr. Kolla Rajamohan – Nallamada Rythu Sangam
23) Patapanchala Jamalaiah – State Secretary, AP Tenant Farmers Union
24) Silpa Bobba – Connect2Farmers, Andhra Pradesh
25) Juvvala Babuji Rao – State Secretary, Andhrapradesh Vyavasaya Vrutthidaarula Union
26) Mattagalla Venkatayya – General Secretary, Telangana Vyavasaya Vrutthidarula Union
27) K Kamakshi – State Secretary, Karnataka Vyavasaya Vrutthidarula Union
28) A Parvathi – State Secretary (Women Wing), Raashtriya Vyavasaya Vrutthidarula Union
29) T Srishailam – Suraksha FPCLtd, Siddipeta District, Telangana
30) T Sathyapal – Safe Food FPCLtd, Siddipeta District, Telangana
31) M Suraiah – Cherial FPCLtd Siddipeta District, Telangana
32) B Giribabu – Adarsha Enabavi FPCLtd, Janagaon District, Telangana
33) N Surender Reddy – Nelathalli FPCLtd, Yadadri Bhongir District, Telangana
34) Sangameshwar – Tummalapally FPCLtd, Vikarabad District, Telangana
35) Y Rajender Reddy – Talamadugu FPCLtd, Adilabad District, Telangana
36) Shankar – Bellampally FPCLtd, Manhirial District, Telangana
37) T. Praneetha – CEO, Vemula FPO, Andhra Pradesh
38) Gangha Bhavani – CEO, Vempalli FPO, Andhra Pradesh
39) P. Pavan Kumar – CEO, Proddatur FPO, Andhra Pradesh
40) B. V. Ramana – CEO, Talupula FPO, Andhra Pradesh
41) Upendra – CEO, Thungabhadra FPO, Andhra Pradesh
42) P. Venkat Rao – CEO, Haritha FPO, Andhra Pradesh
43) S. Venkat Rao – CEO, Brahmalingeshwara FPO, Andhra Pradesh
44) P.V. Swamy – CEO, Vepada Tribal FPO, Andhra Pradesh
45) P. Balamani, President, Nelamma Mahila Rythula Parspara Sahakara Sangam
46) Nageswramma – Mallaiahgaripalli Mahila Raithu Uthpathidarula MACS
47) Chinnamma – Mallaiahgaripalli Mahila Raithu Uthpathidarula MACS
48) Narashimha Reddy – Mallaiahgaripalli Mahila Raithu Uthpathidarula MACS
49) Rajesh Kumar Reddy – Nallamada Swasakthi Sendriya Atavi Uthpathidarula MACS
50) Lakshmi Narayana – Nallamada Swasakthi Sendriya Atavi Uthpathidarula MACS
51) Sobharani – ODC Mandala Mahila Raithu Uthpathidarula MACS
52) Lakshminarayana Reddy – ODC Mandala Mahila Raithu Uthpathidarula MACS
53) P. Surendra – Amamdagur Mandala Raithu Uthpathidarula MACS
54) Lakshminarayana – Amamdagur Mandala Raithu Uthpathidarula MACS
55) Arunamma – Pulakunta village, Farmer, Andhra Pradesh
56) Ratnamma – Talupur village, Farmer, Andhra Pradesh
57) Sushilamma – Kamarupalli village, Farmer, Andhra Pradesh
58) Potulayya – Kurugunta village, Farmer, Andhra Pradesh
59) Vijaykumar – Kurugunta village, Farmer, Andhra Pradesh
60) Nagendramma – Talupur village, Farmer, Andhra Pradesh
61) Subbarayudu – Talupur village, Farmer, Andhra Pradesh
62) Ramudu – Penakacherla village, Farmer, Andhra Pradesh
63) Subbareddy – Talupur village, Farmer, Andhra Pradesh
64) Munireddi – Taticerla village, Farmer, Andhra Pradesh