In July 2013, the government had set up a committee to review six neo-nicotinoids. A month later it expanded the ambit to 66 more chemical pesticides. The committee was headed by former ICAR National Professor Anupam Varma, a virologist. Among the 66 chemicals were some that pre-dated 1972 when the Insecticides Act became operational. These were Deemed Registered Pesticides and their use was continued, even though bio-efficacy and safety tests had not been done, so as not to disrupt agricultural activity. The Varma committee gave its report in December 2015. He said some chemicals should be immediately banned and a few others phased out. With regard to 27 chemicals, it recommended that their producers must do the required studies before the end of December 2017, failing which they should be banned. In a draft notification issued in May, the agriculture ministry declared its intention to ban them as, it said, the studies as recommended by the committee have not been done even as late as December 2019. But Crop Care Federation of India (CCFI), a group of mainly Indian pesticide companies, says by the time the Registration Committee (RC) reviewed the committee’s recommendations, advised new studies and obtained the government approval, 10 months had elapsed. It says the field studies cannot always be done in a time-bound manner. The RC had extended the deadline for submission of studies to the end of last December but in July 2019, this decision was reversed as the agriculture ministry had over-ruled it. Vivian Fernandes confronted CCFI with a list of non-compliances. Its Chief Scientific Adviser, Jagadish C Majumdar, gave a molecule-wise reply which is reproduced below.
(1)Acephate: AVC said resurgence studies on pests in rice and cotton caused by repeated use must be submitted by December 2017. Draft gazette notification says no data have been submitted.
CCFI: Data have been submitted in on 30 June, 2020. Delay is due to late approval of trial protocol by RC.
(2) Atrazine: AVC said groundwater contamination was a big concern so report on leaching and waiting period should be given by December 2017. Draft notification says incomplete bio-efficacy data submitted on leaching.
CCFI: Data on leaching have been submitted in December 2017 and April 2018. Bio-efficacy and residue data on maize and sugarcane were submitted in September 2019.
(3) Benfuracarb: AVC said the chemical breaks down into carbofuran which is an effective nematicide. Data needs to be generated and submitted by December 2017 on effectiveness against nematodes. Draft notification says nematicide data on brinjal crop was given by the registrant but Benfuracarb is not meant for use on brinjal.
CCFI: Label claim is approved for paddy and red gram. However, these crops do not get nematode attacks. Therefore, nematicidal effect of Benfuracarb was studied in Brinjal. The company (Coromandel International) is going to apply for label claim in brinjal.
(4) Butachlor: CCFI says it will go undefended.
CCFI: According to our information, it is not being defended by any company.
(5) Captan: AVC wanted data on waiting period, residue, toxicity, carcinogenicity and environmental contamination to be presented. Draft notification says no data have been submitted on residues, bio-efficacy and persistence.
CCFI: Data on residue, persistence and bio-efficacy have been submitted in tomato and grapes in September 2019. Reports on carcinogenicity and environmental contamination have been submitted in May 2016.
(6) Carbendazim: AVC said residue data to be generated where waiting period is not defined including for rice to address concerns of the export industry. Draft notification says registrants have not generated fresh bio-efficacy and residue data. Instead, they had requested CIBRC to consider 2009-2012 data. This request was not accepted.
CCFI: According to information received by us from reliable sources (CCFI is not defending this product), bio-efficacy, residue and persistence data have been submitted on paddy and cluster bean on 28 November 2018. Residue and persistence in tea and paddy, MRL (maximum residue level) and baseline toxicity data were submitted on 2o December, 2016 and 3 August, 2019.
(7) Carbofuran: AVC said residue data to be generated by December 2017 as waiting period on approved crops is not defined. Draft notification says no residue or persistence data given.
CCFI: As per information received by us from reliable sources (CCFI is not defending it), one season bio-efficacy data on rice, brinjal, maize and groundnut have been submitted on 31 December, 2019 and 4 March, 2020. Second season data are under generation. Residue data were to be submitted in July 2020. Bio-efficacy and residue data on sugarcane are to be submitted in December 2020.
(8) Chlorpyriphos: AVC said submit residue data by December 2017. Draft notification says studies on air concentration as recommended by Dr. Ranjit Roy Chaudhary Committee not undertaken. Incomplete data submitted for toxicity and bio-efficacy.
CCFI: Data have been submitted on 9 crops, viz., groundnut, paddy, brinjal, onion, french bean, gram, mustard, apple and sugarcane on 28 December, 2017 and 23 July, 2018.
As regards air concentration study, there was no such demand from AVC or RC. However, after discussion with Khurana sub-committee data have been generated and submitted on 24 July, 2020.
(9) 2,4-D: AVC said submit residue data by December 2017 because waiting period is not defined. Draft notification says incomplete data given for sugarcane, potato and maize.
CCFI: Complete data have been submitted in case of Sugarcane. Studies on potato and maize are in progress.
(10) Deltamethrin: AVC said resistance and resurgence studies should be submitted by December 2017. Draft notification says incomplete data on resurgence or resistance submitted. No data given on cotton (other than for whitefly), rice, tea, bhindi, groundnut, mango, chilli, brinjal and red gram for all pest infestations and impact on public health.
CCFI: As per information received by us from reliable sources (CCFI is not defending it), no study protocol was approved by RC. So the company (Bayer) generated data according to their own protocol and submitted data on 14 October, 2019.
(11) Dicofol: AVC said persistence on plant surfaces is a concern. It wanted data on residues by December 2017. It also wanted MRLs to be fixed for individual crops. Draft notification says no data have been given for bio-efficacy and persistence.
CCFI: According to our information, Dicofol is not being defended by any company.
(12) Dimethoate: AVC said submit residue data where waiting period is not defined. Don’t use on vegetables and fruits. Draft notification says no bio-efficacy and residue data as required by AVC and RC given.
CCFI: Residue and bio-efficacy data on cotton were submitted in November 2017 and September 2019 respectively. Studies are underway in maize, brinjal, and mustard.
(13) Dinocap: AVC said give residue data as waiting period is not defined. Draft notification says no bio-efficacy and residue data submitted.
CCFI: According to our information, Dinocap is not being defended by any company.
(14) Diuron: AVC said give residue data where waiting period is not defined. Draft notification says bio-efficacy, persistence and residue data not submitted for fixation of waiting period on rubber, sweet orange, banana and cotton crops. Incomplete data for grapes.
CCFI: Detailed bio-efficacy, residue and persistence data have been submitted in maize and grapes from multi-locational trials by Hikal.
ADAMA, a Crop Life India member, has also submitted a lot of data on Diuron but we do not have details.
(15) Malathion: AVC said submit residue data. Draft notification says no data given on bio-efficacy, residue and persistence for fixation of waiting period for paddy, sorghum, pea, soybean, castor, sunflower, bhindi, brinjal, cabbage, cauliflower, radish, turnip, tomato, apple, mango and grapes.
Bio-efficacy, residue and persistence data on paddy and bhindi have been submitted. Label claim on other crops may be deleted.
(16) Mancozeb: AVC said report of effect on iodine metabolism and how it affects the thyroid profile, and data on residue studies should be given by December 2017. Draft notification says incomplete data have been given on thyroid studies of industrial workers. (Data from one location were submitted instead of multi-locations). No bio-efficacy data submitted. No residue data given for wheat, maize, paddy, jowar, tapioca, groundnut, cauliflower, grapes, guava, banana, cumin, chillies and onion.
CCFI: The following bio-efficacy and residue data have been submitted along with compiled summaries to CIBRC in November and December 2019.
Bio-efficacy – chilli, apple, potato, tomato, paddy, maize and groundnut.
Residue – chilli, onion, groundnut, cauliflower, potato, grape, apple, paddy, wheat and sorghum
Fresh residue data have been submitted for four crops, viz., chilli, potato, onion and apple.
Fresh residue data are under generation in seven crops, viz., paddy, grape, groundnut, cumin, maize, cauliflower and banana.
Fresh efficacy data are under generation in 11 crops, viz., paddy, grape, groundnut, cumin, maize, cauliflower, banana, chilli, potato, onion and apple.
Iodine metabolism and thyroid function studies were being conducted by three companies, viz., Indofil, UPL and Dow. While Indofil study was completed and report was submitted before 31 December 2017, the remaining two studies were bogged down in procedural wrangles. Now the (medical) colleges have been changed and the data will be submitted very soon.
(17) Methomyl: AVC said generate and submit toxicity data for bees, fish and silkworm in Indian field conditions by December 2017. Draft notification says the above data have not been given.
CCFI: According to our information, nobody is defending Methomyl.
(18) Monocrotophos: AVC said do study on endocrine disruption by end of 2017. If not done as per protocol, use must be discontinued. Field study data on toxicity to honeybees, and residue studies must be submitted by December 2017. Draft notification says incomplete data submitted of studies on endocrine disruption. No studies submitted for toxicity to bees, bio-efficacy, residue and persistence (to fix waiting period for paddy, maize, black gram, green gram, pea, red gram, sugarcane, cotton, coconut, coffee and cardamom).
CCFI: Report on endocrine disruption study from CSIR-CFTRI, Mysore was submitted prior to December 2017. Some ED studies conducted in UPL factory were also submitted. However, the remaining studies scheduled to be conducted by CSIR-ITRC, Lucknow could not be done because the institute declined to undertake it due to lack of required facilities. Bo-efficacy, residue and persistence studies have been initiated. Regarding bee toxicity, customary cautionary statement is given on label and leaflet.
(19) Oxyfluorfen: AVC said generate residue data by December 2017. Draft notification says data on residue and persistence in rice (direct sown as pre-emergence), groundnut, onion and potato crops not submitted.
CCFI: As per information received by us from reliable sources (CCFI is not defending it), PHI and MRL in tea and mentha have been submitted. Residue and bio-efficacy data in rice and onion had been submitted on 9 December 2017. No data have been submitted in groundnut and potato.
(20) Pendimethalin: AVC said multi-location field studies for impact of spray on aquatic organisms, as recommended by CD Mayee committee, were conducted and given to CIBRC. It said CIBRC must expedite its comments on this report. Waiting period is not defined for approved crops. Residue data for these crops must be given by December 2017. Draft notification says incomplete toxicity data submitted. Also, industry has not submitted the clarification on studies submitted with respect to aquatic organisms. Data not submitted on residue and persistence in rice crop.
CCFI: As per the approved protocol, the report on “Multi-location field studies to assess the impact of Pendimethalin 30% EC spray on aquatic organism Common Carp (Cyprinus carpio)” was submitted to CIBRC on 18 November, 2013.
The manufacturers were never informed about any deficiency in toxicity data of Pendimethalin till date. Therefore, the statement that ‘incomplete toxicity data submitted’ is not correct.
Data on residue and persistence in wheat were submitted on 27 September, 2019 and in rice on 12 June, 2020.
(21) Quinalphos: AVC said impact study on aquatic organisms as recommended by 2006 Mayee committee not done despite approval of protocols. Regarding neurotoxicity, no study done as recommended by Mayee committee. A reference to a 1993 study on hens was submitted. Industry did not do fresh study. Industry must do study on neurotoxicity and give report by December 2017. It must also give report on bio-efficacy and build-up of resistance in polyphagous sucking pests like jassids, aphids, mites, thrips and their resurgence by December 2017. Residue data must also be given by that date. Draft notification says incomplete data on neurotoxicity and toxicity for aquatic organisms submitted. Data not submitted with regard to resistance or resurgence in target polyphagous sucking pests like aphids, jassids, mites and thrips. No data on residue or persistence for fixation of waiting period for jowar given. Data on resurgence or resistance for chilli have not been submitted. The selection of formulations of standard checks and their doses were not appropriate.
CCFI: Data on efficacy and residue and build-up of resistance/resurgence in aphids, jassids, thrips and mites in paddy, red gram and \chillies were submitted on 28 December 2017. Reports on bio-efficacy and residue studies in tea were submitted also on the same date as also neurotoxicity and eco-toxicity data. The data on aquatic organisms, viz. Zebrafish and Cyprinus carpio have been given.
(22) Sulfosulphuron: AVC said continuous use since 2000 showed resistance in target weed in Punjab, Haryana and Tarai region. Industry must conduct multi-location (at least three) field studies on resistance and give report by December 2017. Draft notification says multi-location studies to check the possible development of resistance in target weeds in Punjab, Haryana and Uttarakhand have been submitted. Further, as per report 32.5% resistance was observed against target weed Phalaris minor in Punjab and Haryana while no resistance was observed in Uttarakhand.
CCFI: As per information received by us from reliable sources (CCFI is not defending it), RC had not issued any approved protocol for studying resistance of target weed. So, the company (Sumitomo) generated data according to its protocol and submitted data on 23 August, 2019. Delay was caused due to non-approval of study protocol.
(23) Thiodicarb: AVC said do multi-location field studies on resurgence in mites. Draft notification says incomplete multi-location resurgence study submitted.
CCFI: As per information received by us from reliable sources (CCFI is not defending it), data on resurgence of mites were submitted on 14 October, 2019.
(24) Thiophanate methyl: AVC said study on thyroid impact and on earthworms to be submitted by December 2017. Draft notification says the studies are incomplete. Only one location data instead of multi-location data on thyroid function tests have been submitted and report field studies on earthworms are yet to be submitted.
CCFI: Thyroid study in other locations is underway and will be submitted soon. As regards earthworm study, RC failed to give any protocol despite repeated requests. So, the company (Biostadt) submitted international protocol which was approved in late 2019 by RC. The study is underway and data will be submitted at the earliest.
(25) Thiram: AVC said give data on study of persistence in soil and water by December 2017. Draft notification says the above data have not been given. Incomplete data given on bio-efficacy and residues.
CCFI: Data on efficacy and residues have been submitted in 2019 and 2020.
(26) Zineb: AVC said studies on residue, and iodine metabolism should be submitted. Draft notification says the above data have not been given. No toxicity or bio-efficacy data given either.
CCFI: The following bio-efficacy and residue data have been submitted in November 2019:
Bio-efficacy – chilli, maize, apple, tomato, cumin, and paddy
Residue – chilli, tomato, paddy, maize, apple, cumin , sorghum and wheat
Fresh efficacy and residue studies are underway in the following 11 crops: paddy, potato, chilli, grape, apple, maize, wheat, onion, tomato, cumin and citrus.
Iodine metabolism data were generated along with Mancozeb and have been submitted.
(27) Ziram: AVC wanted study of iodine metabolism and effect on thyroid as suggested by CD Mayee committee of 2006. Draft notification says no data on iodine metabolism given. Incomplete data on bio-efficacy and residue submitted. No data given on toxicity.
CCFI: Iodine metabolism data were not submitted due to some confusion. However, data are being generated now.
(Top photo of discarded pesticide canisters in a field in Sangli, Maharashtra, by Vivian Fernandes).