The Centre's decision to ban 27 commonly-used pesticides in all three main categories, namely insecticides, fungicides and weedicides, is a move in the right direction
The decision of the Centre 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 are 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 scrutinising 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 pesticide 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 beings, animals and the environment. Based on examination by a committee of experts, it arrives at an 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 May 14, 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 over 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 The notification says: “Sixty-six insecticides, which are banned or restricted or withdrawn in other countries but continue to be registered for domestic use in India, were reviewed by an expert committee set up by the MoA&FW.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 recognised that use of 27 insecticides is likely to involve risk to human beings 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 toxicity for bees. For others, adequate data needed for regulatory purpose are 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 per cent. The export of pesticides will also take a hit of around 10 per cent on the existing Rs 20,000 crore.
The manufacturers argue that farmers have been using these chemicals for a long time and have found them to be economical even as the alternatives are expensive and will lead to increase in the cost of cultivation. They have also questioned the timing of the decision. They argue that farmers have to put up with frequent locust attacks, especially of late, that have gripped agriculture in several States like Rajasthan, Punjab, Haryana, Madhya Pradesh and Maharashtra. Growers urgently need relevant pesticides like malathion whose supplies could be affected by the ban.
The arguments advanced by the industry are untenable. First, it is not as if this has come as a 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 years.
This process also involved consultations with manufacturers of the 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 caused no harm to humans, animals or the environment, they could have presented requisite data to substantiate their contention. But that was never done.
Now, 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. It shows that from day one, firms who applied and got registration could not convincingly demonstrate their safety and efficacy to the regulator (courtesy, void in data). This has not been done till date which eventually drove the Centre to banning them.
Second, developments in various States (they are expected to ensure compliance with regulations on ground zero) signalled that the ban was in the making. In 2011, Kerala had banned monocrotophos, carbofuran and atrazine on grounds of public health concerns. In 2017, Maharashtra banned monocrotohos and acephate due to high incidence pesticides poisoning among cotton farmers. In 2018, Punjab said “no” to fresh licences for 2,4-D, benfuracarb, dicofol, methimyl and monocrotophos citing harm to humans and the 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 and 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. By the same logic, a new and safer product can’t be debunked — simply because it costs more.
Without compromising on safety, even if one were to consider the economics of use, we need to make comparison on like-for-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 on the list of pesticides proposed to be banned) — 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, whereas 300 gm of Acephate is required to control pests over an acre, in the case of Imidacloprid, the requirement is less than 100 ml per acre.
The effective cost per acre for the latter thus works out to be Rs 120 against Rs 165 for the former. Higher crop yield and better crop quality with Imidacloprid serve 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), the earliest the order can be enforced is July 1. That apart, normally the Government allows manufacturers to clear their supplies in the pipeline which are attuned to meet the demand.
To combat the locust attack, the very fact that the Agriculture Ministry itself is procuring malathion from none other than domestic manufacturers shows that the supply of even this pesticide (proposed to be banned) won’t be a constraint for now.
Alternative safer products are available in the market which will ensure that farmers don’t suffer. Finally, the 27 pesticides in the proposed ban list are less than 10 per cent of the current 289 pesticides registered for use in India. Hence, banning these 27 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 comprehensive assessment by the expert committee.
Looking at all critical factors viz. safety, efficacy, availability, cost-benefit and so on, the Government’s decision 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 and development and innovation to meet diverse needs of farmers, thereby helping them in boosting agricultural production and increasing their income.
(The writer is a New Delhi-based policy analyst)