While a draft ban order has been published, activists fear the government may constitute one more expert committee to evaluate the decision of two earlier committees., JULY 30, 2020 – 16:53Sridhar Radhakrishnan

“To B(an) or not to B(an)” sounds nearly like the Shakespearean soliloquy, but for the difference that this is a public debate on a decision by the Indian government to ban a few hazardous pesticides, many of which have been in use for more than half a century. In a seemingly bold step by the Ministry of Agriculture, Cooperation and Farmers Welfare, a draft order was published on May 14 this year, banning 27 pesticides used in India. Why “seemingly bold”? Because some of the pesticides in this list were banned based on environmental and health safety concerns in many countries in as early as 2001.

The order has been widely welcomed by civil society and farmer groups, including some agri-commodity trade groups. It’s indeed a rare order that lists these chemicals along with their hazardous characteristics, their status of ban in other nations and also the availability of alternatives. But the groups also complain that the ban is delayed and there are many more similar hazardous pesticides that have not found their place in the list. The pesticide industry associations, expectedly, has cried foul, alleging that adequate consultations have not been done, enough time was not given to submit critical data, and that banning so many widely used generic pesticides would affect food production and farmers’ income.

Their grumbles seem to have sympathisers in the government. The 45-day period allowed for submission of objections and suggestions was extended by another 45 days and they were also allowed to produce these pesticides for export purpose. The Department of Chemicals and Petrochemicals was also seen explicitly batting for them. The Secretary even wrote a letter to the Agriculture Ministry broadly stating the arguments that the industry raised and termed the ban untimely. It’s possible that the government may constitute one more expert committee. But this is a cliché, standard delaying tactics – a new expert committee to evaluate the ban decision of two earlier committees in a span of 7 years does not augur well at all, neither for science nor for society.

Let’s get to the bottom of the issue. The impending decision on the ban is expected to have far-reaching implications as to how we regulate these hazardous chemicals, how rigorous and effective our regulatory system is, is it timely in protecting human and animal health and safety, and is it on par with global developments in hazard management. This is critical in ensuring the safety of our farms and farm produce and the health of our farmers, consumers and the larger environment. In recent times, export of food produce like Basmati rice, grapes, mangoes, chillies, okra, curry leaves, etc. have also been affected due to pesticide residues, leading to export rejections and losses running into thousands of crores of rupees. It’s now a matter of protecting our food industry and trade as well.

Pesticides and regulation in India

India currently has a registered list of 295 pesticides and 746 approved formulations. These pesticides are registered by the Registration Committee (RC), and the Central Insecticides Board (CIB) acts as an advisory body. The two regulatory bodies are governed by the Insecticides Act, 1968 and the Insecticides Rules, 1971. The Act and Rules intend to “regulate the import, manufacture, sale, transport, distribution and use of insecticides with a view to prevent risk to human beings or animals…”. Since its inception, the CIBRC (as they are together called) registers pesticides upon receiving applications along with efficacy, toxicity and safety data from the company. The central government through its Ministry of Agriculture has the authority to cancel registrations and allow continued use or in some cases even ban the pesticides upon the recommendation of the RC.

The present ban order and debate also exposes the near total collapse of the regulation mechanism in the country. Let us look at an unrevealed secret – the ‘Deemed to be Registered Pesticides’ or DRPs. You will not see this list on official websites, but these are those pesticides that were in use before the Insecticides Act of 1968 and were allowed to be used on the assumption that the industries would apply for registration once the mandatory data on efficacy and toxicity is generated.

Studies done for ASHA-Kisan Swaraj, a farm sector advocacy group which the author is also associated with, show that there are at least 51 such DRPs. They all are considered registered, irrespective of the data submitted. No other nation is known to be following such an arbitrary, risky and unscientific regulatory practice. Many of the DRPs have been banned in various countries, even decades ago. Seventeen out of the 27 pesticides proposed to be banned now are also DRPs. Isn’t it a matter of grave concern that these pesticides that have now become qualified for a ban were used on our soil for 50 years or more?

A regulatory system fails

Flashback to 2001. That was when the slow poisoning incident of Endosulfan, an organochlorine pesticide which was later designated a Persistent Organic Pollutant (POP) and entered the same list as the toxic DDT, took hundreds of lives in Kerala’s Kasaragod. A large section of the population living in and around the cashew plantations in Kasaragod became morbid with multitude of ailments. The community went up in arms against the aerial spraying of the chemical.

Two expert committees set up by the CIBRC – in 1991 and 1999 – had recommended that Endosulfan should not be used near waterbodies owing to its acute aquatic toxicity. They even recommended that this be displayed in the labels of the pesticide. Only in 1999 was this recommendation approved by the RC, though it was never implemented, and this delay led to one of the worst pesticide disasters in the world.

In 2002, the High Court of Kerala banned Endosulfan in the state, on precautionary grounds. The CIBRC never found this reason enough to ban the chemical in the rest of India. Eventually, in 2011, the Stockholm Convention on POPs included Endosulfan in the list for a global phase-out. India conceded to this very reluctantly, after putting up a rather barefaced fight, but got away with a 5-year reprieve to use it. The Supreme Court, however, thought otherwise and in an order that same year banned Endosulfan in India. But researchers following this issue found that this order was not fully implemented and Endosulfan continued to be in the list of registered pesticides used in India till at least 2017.

This is the story of just one pesticide – used for five decades or more, caught in controversy in 2000, found to have been banned in many other countries, banned in Kerala in 2002, banned globally in 2011, but took another 6 years for us to effectively get it off our soil. In other words, if the Kasaragod disaster hadn’t happened, Endosulfan may also have escaped scrutiny. Now, looking at the toxicity information released by the government on the 27 pesticides, one wonders whether every pesticide has a ‘regulatory escapade’ story to recount.

How many pesticides allowed for use in India are banned in other countries? In 2001, in the context of the Endosulfan exposé, this question was asked in the Parliament. The then Minister in charge of Agriculture replied: “There are 33 pesticides that are banned in other countries and used in India”. Later in 2011, when the same question was asked in the Parliament, the reply was shocking – 67 pesticides. There isn’t better evidence to show that the pesticide regulatory system in India, with an intent to “prevent risk to human and animals”, had unquestionably failed to do so.

The Anupam Verma Committee

The present ban order of 27 pesticides has its origins in the Dr Anupam Verma Committee, set up to review the continued use of pesticides. This committee was constituted on July 8, 2013 to examine the continued use of or otherwise of neonicotinoid insecticides registered in India. A month after, on August 19, 2013, the mandate of the committee was further expanded to review 66 insecticides that are banned, restricted or withdrawn in other countries but continue to be registered for domestic use in India.

The Committee after detailed examination submitted its report to the government on December 9, 2015. It took almost another year for the RC to approve the recommendations on October 14, 2016. Then after nearly 2 years, we see the first list of 18 pesticides from this list being banned by an order on August 8, 2018. By this order, 12 pesticides were banned with effect from January 1, 2019 and 6 of them would stand banned with effect from the end of this year (December 31, 2020). Throughout the functioning of the committee, the industry was not only consulted but adequate time was provided to them for submitting data that the committee wanted. The draft ban order itself tells us how some of the pesticides are being banned simply because of lack of safety data. Even after getting time from 2013 when the review started to 2018 when the ban orders were given, the industry had enough and more time.

Though the committee report is not in the public domain, for reasons unknown, the proceedings of the RC approving the ban show the factors that were considered for the ban. The most important factor was the gap related to information on toxicity and on studies related to efficacy of the concerned pesticide. Other factors such as studies on development of resistance to the pesticide, reports of pest resurgence, and globally available information on health, safety and toxicity aspects seem to have been dealt with in some detail. The fact that some of the pesticides were DRPs was also considered.

Why the 27 pesticides need to be banned

This is not rhetoric. Let’s simply bullet-point the reasons, mostly from the draft ban order and the rest based on studies, reported incidents and information available.

– 24 of the 27 pesticides are banned in other countries (See Table 1).

– 4 are carcinogens, 16 are endocrine disrupting chemicals and 21 are known to have eco-toxicity, meaning they are toxic to honey bees/ earthworms/ aquatic organisms/ birds, etc. (Details in Table 2).

– In spite of the fact that these pesticides were used without adequate data for decades, the ban order lists 25 pesticides as having one or more incomplete data (even after adequate time was provided), including those pertaining to biosafety, residue, persistence, waiting period and toxicity. For two pesticides – Thiram and Ziram – no data seems to have been submitted.

– Even in a 2012 report of the Ministry of Health and Family Welfare, 11 of the 27 pesticides have cropped up as residues, and this includes Dicofol, Chlorpyriphos, Dimethoate, Malathion, Monocrotophos, Quinalphos, Deltamethrin, Carbofuran, Thiodicarb and Methomyl.

– In 2017, farmers deaths were reported and hundreds became ill in Yavatmal, Nagpur, Akola and Amravati districts of Maharashtra. Monocrotophos, a highly toxic pesticide, along with others were being used. Toxic pesticides are also linked to deaths due to accidental poisoning and suicides. In 2013, several schoolchildren in Bihar died because of accidental poisoning from monocrotophos. Other pesticides – acephate, quinalphos, chlorpyrifos, mancozeb, methomyl and carbendazim have also been implicated in acute poisoning cases.

– Malathion, chlorpyrifos, monocrotophos were implicated in documented evidences of wildlife poisonings.

Table 1

Number of countries where the proposed pesticides are banned (as per draft ban order)

Name of pesticideNumber of countries

Note: Of these, 16 pesticides are also not approved in the European Union and 4 of them are inactive (not in use) as per the US EPA.

Table 2

Toxicity characteristics of the pesticides proposed to be banned (as per the draft ban order)

CarcinogenicityEndocrine disruptionReproductive effects/
foetotoxic / teratogenic risk
2,4 – D2,4-DBenfurocarbAcephate
(causes Thyroid follicular
cell adenoma)
Captan Captan
 Carbofuran Carbofuran
 Chlorpyriphos Deltamethrin
 Deltamethrin Dicofol
 Dicofol Dinocap
 Dimethoate Diuron
 Diuron Malathion
 Malathion Mancozeb
 Oxyflourfen Methomyl
 Thiphanate methyl Monocrotophos
 Thiram Oxyfluorfen
 Zineb Pendimethalin
 Ziram Quinalphos
   Thiophanate methyl

Note: In addition, the ban order also lists 25 pesticides to have one or more incomplete data, including those pertaining to biosafety, residue, persistence, waiting period and toxicity. For two pesticides – Thiram and Ziram – no data seems to have been submitted.

How long can this poisoning be allowed to continue?

The Prime Minister of India in his Independence Day speech last year, for the first time perhaps, publicly stated a new direction for farming in India. His appeal was clear – we cannot continue to devastate mother Earth and our nation with chemical fertilisers and pesticides. He even said that if needed we will launch a campaign to free Earth and our nation from these chemicals. We wish to believe he means it.

This is a glimmer of hope. Every Indian and every life form has a right to a safe environment, safe food and water. Pesticides is one hazard which we can totally eradicate, without any impact on production and the economy. The safest alternative one can imagine, organic/natural farming and organic produce, is now one of the fastest growing sectors. Sikkim, Kerala, Andhra Pradesh, the North-East states are all moving ahead on this. The central government has also set apart substantial funds for the Paramparagat Krishi Vikas Yojana (PKVY). Industries have to take the cue and seize this opportunity as well. They need to eliminate their sunset products and shift to support this nation’s move to agroecological and natural farming. The phase-out of hazardous pesticides has been delayed at least 2 decades. This ordeal has to end. And it has to begin with this ban on 27 pesticides without any more delay.

Sridhar Radhakrishnan is a Steering Committee member of ASHA-Kisan Swaraj and Coordinator of the Save our Rice Campaign-India.