Reviewing the Alternatives of Endosulfan

Since EU lost its share of the Endosulfan pie when it went generic decades ago, their recent promotion of patented pesticides is only part of its attempt to re-enter global pesticide trade. Since their attempts to compete with Indian Endosulfan producers and regain their lost markets did not meet with success, some of them are understood to have resorted to unfair trade practices. By churning out unfavourable stories surrounding Endosulfan through patronage to certain NGOs, the EU appears to be out to recapture their markets by any means possible. Now, in order to counter the affordability, utility and beneficial softness of Endosulfan, EU is engaging in illegal attempts to introduce Endosulfan as a Persistent Organic Pollutant in the Rotterdam and Stockholm conventions. They hope that a total ban will initiate a shift in global pesticide demand patterns.

Endosulfan is a broad-spectrum pesticide active ingredient that is sprayed on a range of 29 crops to protect them from about 60 types of pests. The most prominent benefit of Endosulfan over other pesticides, including those touted as its replacements, is that it is safe for beneficials and pollinators, such as honeybees. Endosulfan is the last pesticide in use that is recommended as a first-spray during pollination by agriculture scientists and entomologists worldwide. The replacement of Endosulfan would not only result in incalculable and irreplaceable harm to biodiversity and the agriculture ecosystem, but also present an additional cost of pollination to farmers. Since India became a prominent Endosulfan producer, India’s farmers have trusted its use in a variety of crops, especially coffee, tea and cotton. The states of Maharashtra, West Bengal, Andhra Pradesh and Madhya Pradesh are the top consumers of Endosulfan in India. More than 12 million litres of Endosulfan is used here per annum. In order to be popularly accepted, any substitute for Endosulfan will have to possess similar attributes.

Imidachloprid (Rs 2,000/litre), Thiamethoxam (Rs 3,200/litre) and Coregen (Rs 700/litre) are the pesticides promoted as replacements for Endosulfan. Presently, the Indian farmer spends Rs 250/litre for Endosulfan. Therefore, the obvious repercussion of a shift from using Endosulfan is the manifold increase in the cost of pest-protection. The next cost to emerge with the replacement of Endosulfan is that of the potential purchase of bee boxes. Bee boxes cost as much as Rs 90,000 for pollinating a 1-hectare field of crops in the absence of honeybees. Wherever Endosulfan has been substituted by more expensive alternatives like Neonicotinoids, it has resulted in the elimination of pollinators. Imidachloprid, the most popular Neonicotinoid is blamed for killing bees and is banned in France, Germany and Slovenia, among other European nations.

Affordability as a factor will be an impossible offering for patented pesticides from the EU. If the European agenda to free up a brand new market by banning Endosulfan meets success, farmers in developing nations and India in particular, will be left in financial ruin. If they consider options touted by local governments, they will have to rely on methods like organic farming. This means risking their produce for a method that if successful, may not possess the effectiveness for a required scale. News reports suggest that the present situation has now compelled farmers in Kerala, where Endosulfan is banned, to resort to smuggling the pesticide into the state in cans and bottles. The clash of ‘patented versus generics’ threatens to leave many such innocents in a lurch.

Do we really have alternatives to Endosulfan?

In India, the use of Endosulfan is much more critical. It is the most widely used generic pesticide in India with significant use in crops such as cotton, pulses, tea, mango, vegetables and oilseeds. It is the only pesticide which is soft on pollinating insects such as honeybees and beneficial insects such as ladybird beetles and chrysoperla, among others. In fact, Endosulfan is widely recommended for use during pollination and in Integrated Pest Management (IPM) and Insect Resistance Management (IRM) programs globally. Farmers in Andhra Pradesh, Maharashtra, West Bengal and Madhya Pradesh are the largest users of Endosulfan in India, each using more than a million liters of the generic contact pesticide. They will stand to lose most of all in case of a move to ban the nation-wide use of Endosulfan. The alternatives available to them are expensive, and not nearly as effective on precious cash-crops.

Cost Comparison: Endosulfan and its Alternatives

Product	MRP per Lt or Kg		Cost per acre
		Cotton	Veg	Paddy
Endosulfan 35% EC	286	114	46	69
Flubendiamide 39.35 SC	13800	690		276
Chlorantraniliprole 18.5 SC	12280	737	246	737
Emamectin Benzoate 5% SG	8400	739	672
Flubendiamide 20% WG	7434	743		372
Thiamethoxam actera	4010	321	321	160
Indoxacarb 14.5 SC	3400	680	544

India’s premier agricultural university, Punjab Agricultural University, which in 2007 compared bio-efficacy of all contemporary insecticides, ranked Endosulfan as the best and most ideal for use in cotton crops.

Performance of various insecticides against insect pests and safety to natural enemies of cotton

Insecticides	Insect Pests						Natural enemies	Remarks
	J	W	PBW/SBW	ABW		TC
				Young	Grown up
Endosulfan	Good	Good	Good	Good	Poor	Very good	Safe	Safer to the natural enemies, low resistance to ABW early in the season
				Synthetic pyrethroids
	Poor	Poor	Very poor	Poor	Poor	Poor	Toxic	Excessive use can cause resurgence of whitefly and ABW, high level of resistance to ABW

J= Jassid; W= Whitefly; SBW= Spotted bollworm; PBW= Pink bollworm; ABW= American bollworm; TC= Tobacco caterpillar
Source: Punjab Agricultural University, India

For people who feel NIOH study is the final report on Endosulfan

In response to claims connecting Endosulfan with human disorders in Kerala and Dakshina Kannada, six committees and expert groups including representatives from health, environment and agriculture departments were set up by the Govt of Kerala, Govt of India and the Govt of Karnataka to investigate into the reported linkage of Endosulfan with the various incidences of adverse health effects. Each committee has concluded that none of the alleged victims were proven to be affected by Endosulfan. The findings of these committees have been methodically dismissed and barely presented in the media. 

Many NGOs have produced reports linking Endosulfan to adverse health problems including cancer, infertility, birth defects and neurotic disorder. These reports were based on the National Institute of Occupational Health (NIOH) report which is proved to have been flawed. Despite this, international conventions and regulatory authorities worldwide have referenced this report while reviewing Endosulfan in both, the Rotterdam and Stockholm conventions. Recently, the National Human Rights Commission has also demanded a nationwide ban on Endosulfan based on this faulty report. Media, polity and other vested interests are also pressuring the government into discontinuing the studies on Endosulfan as they are already aware of what the results would be.

NIOH Errors: The NIOH report of 2002 titled ‘Report of the investigations of unusual illnesses allegedly produced by Endosulfan exposure in Padre village, of Kasargode district (N. Kerala),’ had fundamental inconsistencies as was observed by scientists and experts. 

Chemical residue analyses are performed on a sophisticated analytical instrument known as Gas Chromatography (GC) fitted with an Electron Capture Detector (ECD). Each GC-ECD has a lower limit for the minimum amount of a chemical that it can detect. This is expressed as Instrument Detection Limit (IDL). For the study under question, the NIOH had used GC-ECD (HP Model 6890) with the minimum IDL of 1 part per billion (1 ppb) for Endosulfan. In other words, the instrument used by the NIOH could not detect Endosulfan residues lower than 1 ppb. Yet, the NIOH report carries residue findings as low as 0.4 ppb and 0.5 ppb. Simply put, the residue levels reported by the NIOH fall below the minimum detection limit of the instrument used. These findings are scientifically indemonstrable, and are false and incorrect claims. 

Since, the raw data recorded by the NIOH for generating Endosulfan residue data in water, soil and blood samples were fundamentally flawed, its subsequent analysis is even more peculiar. For instance, the table no. 4 in the report shows the total Endosulfan (ppb) in six samples as 0.030 ± 0.18. Annexure -8 shows β Endosulfan residues as 0.0005± 0.001. It may be observed here is that the standard deviation goes beyond the mean (average) by up to 500 per cent. 

Modern GC-ECDs are fitted with computers that process the data gathered from the detectors into chromatograms and finally produce an easy-to-view report. Normal practices of a residue-testing laboratory require that copies of chromatograms of analysed samples are retained and stored in the laboratory/computer for future reference in case of any dispute. Therefore, letters were sent to NIOH under Right to Information Act (RTI Act) seeking copies of chromatograms relevant to this study. NIOH did not respond to requests for parting with raw data until the intervention of the Chief Information Commissioner. The case was heard at the Information Commission and it took three hearings and two orders by the Chief Information Commissioner for NIOH’s appellate authority to finally handover the 1,700 pages of raw data. The varying and inconsistent excuses given by the NIOH while refusing required information under the RTI Act were revealing signs of a cover-up. On examining the data, experts learned that the analysis conducted by NIOH had sure laboratory failings. The conclusions drawn did not corroborate with the raw data and the complete analysis is now being believed to be forged.

Source: http://whybanendosulfan.org/facts-vs-myths.htm

NIOH failed to verify the final analysis of Endosulfan residues

PMFAI defends Indian government’s position on Endosulfan

At a media briefing held by the PMFAI, speakers questioned the flawed study conducted and published by National Institute of Occupational Health (NIOH), Ahmedabad. The study titled “The Final Report of the investigation of unusual illness allegedly produced by Endosulfan exposure in Padre Village of Kasargod district (N. Kerala)”, has been the root cause for the demand for a ban on the pesticide Endosulfan.  An expert panel examined the unscientific and implausible aspects of the NIOH’s study. The flaws have been exposed through the RTI query and the masked raw data evoked public outrage when ten thousand people drew a rally in Gujarat seeking withdrawal of the flawed report. Over thousand workers in Kochi held a rally recently to seek justice for the unfairly stigmatized staff at the government run HIL plant in Kerala.

As per the international norms prescribed by the Codex Committee on Pesticide Residues (CCPR), it is mandatory for residues to be reported as identified only after performing “confirmatory test” of each sample. “Different chemicals may appear in the same peak due to similar retention time leading to wrong reporting. However, in the NIOH study in Padre Village in Kerala no confirmatory data was generated, thus NIOH report on Endosulfan is incorrect and misleading. No decisions can be taken based on this report.” said Dr S K Handa. He further added “since there was no confirmation referring to presence of Endosulfan in the report made by scientists at NIOH, Endosulfan cannot be blamed for diseases in Kerala.”    Dr. S K Handa pointed out that Endosulfan is a safe molecule and as per World Health Organisation (WHO) and does not possess properties to cause cancer or diseases as reported in Kasargod, Kerala. Dr Handa is a Fellow of National Academy of Agricultural Sciences, has over 35 years of research experience in pesticide residues and was former WHO consultant, Ministry of Health, Government of India. He was All India Coordinator for pesticide residues, has authored several books on pesticide residue analysis and has published 120 research papers.

Mr. Pradip Dave, President, Pesticide Manufacturers and Formulators Association of India (PMFAI) indicated that several expert committees were set up by the Government of India and all of them concluded that there is no link established between Endosulfan and the alleged reports of health problems in Kasargod, Kerala. He added, “Even Government of Karnataka constituted an expert committee of very senior scientists. A detailed report was submitted in October 2004 stating that the use of Endosulfan was not responsible for the reported health problems. The report was table in the Karnataka Assembly on April 14, 2005 and accepted.”

Based on a proposal by the European Union, Endosulfan is being considered at the Stockholm Convention, to be listed as a Persistent Organic Pollutant (POP). India has rejected listing of Endosulfan as a POP due to lapse in proceedings, gaps in scientific data and lack of transparency which have been observed, reported and protested by India and other member countries. Endosulfan was invented in Europe and was manufactured and used across the entire region for over 55 years.

Clarifying the status of Endosulfan in USA, Mr. Charles Hanson – Executive Director, International Stewardship Centre clarified that “Endosulfan is not banned in the USA. It was a voluntary withdrawal by the manufacturer and sole registrants and a fall out of a congressional mandate to conduct cost prohibitive product testing for over 64 chemicals, one of which is Endosulfan. Citing small user market in USA, huge investment in research, mounting pressure and uncertainty at the international conventions, the manufacturer chose to avoid any further studies and opted for a voluntary withdrawal of Endosulfan.” There is concern amongst the farmers as USA has not found alternatives for all uses of Endosulfan. While various alternatives have been suggested as a possible replacement, many of these are known carcinogens, toxic to pollinators such as honey bees and are banned in countries like Germany and France.

EU’s move to ban Endosulfan to benefit European Crop Protection Industry

The Pesticide Manufacturers and Formulators Association of India (PMFAI) held a press conference today and invited speakers who pointed to European Union’s (EU) role in steering proceedings at international chemical conventions. The Stockholm Convention has been exploited by European Commission to further its trade interests as world market leader in crop protection chemicals. A push for elimination of the generic pesticide Endosulfan will directly promote the use of patented alternatives and benefit European multinationals.
The meeting was addressed by senior members from the International Stewardship Centre Inc. (ISC) – a non-profit organization registered in Washington D.C. that holds an observer status at these conventions. Along with ISC there was participation from Crop Care Federation of India (CCFI) which is focused on advancing the cause of Indian farmers through better crop protection. The speakers shared their experiences and highlighted the current status of Endosulfan and the proceedings that are likely to impact India and its agriculture in the months ahead.

Speaking to the press, Mr. Pradip Dave, President – Pesticide Manufacturers and Formulators Association of India (PMFAI) gave an overview of the international chemical trade. “Europe is a leader in the international chemicals trade which includes crop protection chemicals. The global crop protection market is valued at over US$ 40 billion. The top three companies which dominate this business are all European and account for over 50% of the global market. This market share has been built with a strong focus on patented and proprietary crop protection chemicals supported by strong regulations, driven by the European standards.” “This has been the motivation for European multinationals to replace “low priced generics” with their “expensive patented alternatives”, added Mr. Dave.

The European Union (EU) has been pushing for a global ban on Endosulfan by proposing its inclusion in the Stockholm Convention as a Persistent Organic Pollutant. As an observer at the Stockholm Convention, Mr. Charles Hanson - Executive Director of International Stewardship Centre Inc. shared that, “Aggressive campaigning by the EU and environmental NGO’s supported and funded by the EU, has resulted in a number of countries announcing a ban on Endosulfan.” Echoing the EU call, the Chemical Review Committee of the Stockholm Convention recommended the listing of Endosulfan as a Persistent Organic Pollutant despite significant data gaps and without a clear consensus on the decision.

Endosulfan is the third largest selling insecticide worldwide. Invented in Germany over 55 years ago, today it accounts for a global market in excess of 40 million liters valued at over US$ 300 million. Mr. R. Hariharan – Chairman, International Stewardship Centre Inc. (ISC) shared, “Indian companies account for over 70% of this market which has come at the cost of the European manufacturers. The replacement value of Endosulfan by patented alternative is estimated to be in excess of US$ 1 billion. As a result, Endosulfan is today in the eye of the storm in the battle of “patented” versus “generic” pesticides.”

 Source: Business Standard http://bit.ly/endosulfantruth