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

Endosulfan is Safe!

Since Endosulfan is a contact insecticide as opposed to a systemic one, it is not absorbed into crops or the food chain. It cannot bio-accumulate in the human body as it is continually degraded by metabolism to a lesser state of hazard.

• The Endosulfan evaluations conducted in 1998 by World Health Organisation (WHO), Food and Agriculture Organization (FAO) and Joint FAO/WHO Meeting on Pesticide Residues have recorded that no genotoxic activity was observed in an adequate battery of tests for mutagenecity and clastogenecity. This study categorically mentioned that no evidence was found to prove estrogenic activity involving Endosulfan.
• Endosulfan has been certified by WHO and FAO to not cause cancer, birth defects or any hormonal imbalance on contact.
• It is the opinion of the UN Environment Programme, International Labour Organisation, International Agency for Research on Cancer, the US Environmental Protection Agency (US-EPA) and California Department of Pesticide Registration, that Endosulfan has no carcinogenic potential.
• In 2007, US-EPA established that Endosulfan is not an anti-androgen, i.e. it does not affect sperm production, sperm count, motility, and the like.
• A peer review by Silva and Gammon (2009) declared that Endosulfan is not a developmental or reproductive toxicant or an endocrine disruptor.
• The WHO has classified Endosulfan as a Class II–moderately hazardous insecticide.

http://www.whybanendosulfan.org/what-is-endosulfan.htm

Effects of Endosulfan on Pollinators and Beneficials

Pollination determines the life of flowers, fruits and crops. It is estimated that every third morsel we consume is a result of pollination. The honey bee is among the most effective pollinators. 90 per cent of pollination in cross-pollinated crops like oil-seeds, vegetables, fruits and cereals is aided by honey bees alone. According to the National Bee Board, Government of India, honey bees help increase yields of fruits like pear, litchi and apple, to the extent of 240–6,014%, 4,538–10,246% and 180–6,950% respectively. So, honey bee pollination is paramount in the cultivation of food crops. Similarly, certain insects such as ladybird beetle, chrysoperla and trichograma are beneficial to crops. Being naturally available, these insects are vital farming inputs available to farmers at no cost. However, they face a real threat of eradication by most insecticides used in fields today.

Farmers in warm and tropical countries generally experience pest attack and honey bee pollination at around the same time. However, the use of pesticides such as neonecotinoids aimed at the former, works by eliminating both. If used at the flowering stage, this results in drastically reduced yields. An ideal pesticide is characterised by effectiveness against target pests, but softness towards pollinators and beneficials. One of the few pesticides with this virtue is Endosulfan. Endosulfan is comparable only to neem in terms of its softness on honey bees.

Endosulfan in IPM systems: Endosulfan is an excellent tool for precision farming. While being soft on beneficial insects, it eliminates 60 kinds of pests that attack 29 crops including cereals, legumes, oilseeds, fruit, nuts, vegetables, cotton and ornamental plants...http://www.whybanendosulfan.org/pollinators-and-beneficials.htm

Endosulfan

Maslow's theory of hierarchy of needs is very relevant in understanding psychology of activists.

According to Maslow, human needs can be presented in form of a five-level pyramid with the most basic needs at the bottom of the pyramid and highest level needs at the top.

5. self-actualization (morality, creativity, achievement etc.)

4. esteem

3. belongingness

2. safety

1. physiological needs (food, clothing, shelter)

As per Maslow's theory, people will first try to satisfy their physiological i.e., lowest level needs such as food, clothing, shelter etc. Once the lowest order need is satisfied, they will try to satisfy higher level needs such as safety and belongingness. Once that is satisfied, they will think of esteem. And finally, when all lower order needs are satisfied, they will think of self-actualization.

This theory is applicable to activists. More particularly in developing countries like India; there is a problem of unemployment. To start with something, activists accept funds for campaigning. Sacrificing morality, they come out with tailor-made unscientific reports. Once they get addicted, they want to make a quick-buck through funded campaigns.

There is also a rush to claim "compensation" for which people try to prove that they are "endosulfan victims". Some politicians distribute funds to such victims despite the fact that the expert committee appointed by the government has concluded that there is no link between alleged health effects and Endosulfan.

Q&A: Pradip Dave, President, PMFAI

Even as it raises the banner of revolt against the European Union over the ban on the use of Endosulfan, the Pesticides Manufacturers and Formulators’ Association of India (PMFAI) is gearing up to lock horns with the Central Insecticides Board and the Union Ministry of Agriculture over a threat to the pesticide industry — issuance of registrations to import readymade pesticide formulations, without registering the technicals. In an interview to K Rajani Kanth, PMFAI President Pradip Dave, also the vice-president of Endosulfan Manufacturers and Formulations’ Association charts the association’s plans, including going to the Gujarat High Court. Edited excerpts:
Besides Endosulfan, what are the other issues facing the Indian pesticides industry?
Lately, the Central Insecticides Board (CIB), a Government of India body, has been issuing registrations for import of readymade pesticide formulations without registering the technicals. This presents a great danger for the country as even the government would not be in a position to know where the raw material comes from and whether it is toxic, sub-standard or expired. And, if this registration process continues (without registering the technicals), there will not be any pesticide manufacturing activity in the country and we (manufacturers) will end up becoming re-packers.

So far, how many such registered products have entered India?
Almost 18 products have been registered in the last seven-to-eight years, valued at more than Rs 4,000 crore, courtesy the vested interests of multinationals, especially from the European Union.

Are you making any representations to the Central government to cease such registrations?
As per existing regulations, the pesticide industry needs to obtain clearance from the Central and State regulatory authorities before commencing production. All products need to be scrutinised and registered by CIB, and companies are required to submit various data and dossiers to the authorities, which is not the case at present. Pesticides Manufacturers and Formulators’ Association of India (PMFAI), comprising 210 members – including ….http://www.business-standard.com/india/news/ltbgtqampaltbgt-pradip-dave-president-pmfai/425109/

Withdraw erroneous report on endosulfan, Centre urged

The Pesticides Manufacturers and Formulators' Association of India (PMFAI), on the radar of some environmentalists and business lobbies, on Friday demanded the Central government to withdraw the “erroneous” report of the Ahmedabad-based National Institute of Occupational Health (NIOH) declaring endosulfan as a health hazard.

Describing the opponents of the insecticide as the agents of some European chemical manufacturers, the PMFAI claimed that imported substitutes to endosulfan would cost the Indian farmers dearly.

Pointing out at a media conference that the NIOH report had become an alibi for some non-governmental organisations working for an environmental cause and business lobbies to raise the anti-endosulfan propaganda, the PMFAI claimed that there was nothing to suggest that endosulfan was harmful to human health in any way.

‘Genetic disorder'

The six committees set up by the Centre earlier had also concluded that endosulfan was not the reason for the alleged ill-health of the people at Padre village in Kasaragod district of Kerala, where the farmers had been using the insecticide for many years.

The diseases were found to be caused by some inherited genetic disorders that obtained even before endosulfan came to be used, PMFAI president Pradip Dave said. He alleged that the basic issue involved was “to protect the business interests of European chemicals manufacturers at the cost of the Indian farmers under the garb of environmental and health issues for which the NIOH report has come in handy.”

S. Ganesan, Chairman, International Treaties Experts' Committee, said that these European chemical giants had decided to phase out endosulfan in 2001 as it was no longer profitable to them. Chemicals including pesticides and insecticides were the second largest traded commodity in the world, after fuel, in which the manufacturers of the European Union countries enjoyed a 60 per cent share in 2009. A ban on endosulfan to be substituted by other imported pesticides would immensely benefit these manufacturers, he alleged.

‘Largest manufacturer'

According to R. Hariharan, a representative of the International Stewardship Centre, India is the world's largest manufacturer of endosulfan and has a 70 per cent market share of endosulfan business globally with exports worth Rs.180 crore annually. Gujarat alone produced about 55 per cent of the world's requirements - of 40 million litres worth Rs.1,350 crore, while its imported substitute would cost the Indian farmers over Rs.4,500 crores, he claimed.

A farmer from Amreli district in Gujarat, Nayan Visavalya, claimed that he had been using endosulfan for many years and it had not caused health problem to his family or anyone in the village.

Source: http://www.thehindu.com/news/national/article1447725.ece

Endosulfan cannot be blamed for diseases in Kerala: Dr. S. K. Handa

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 which has been under scanner for the last one year. The flaws have been exposed through the RTI and the masked raw data has evoked public outrage when ten thousand people drew a rally in Gujarat to seek withdrawal of the flawed report. Similar agitation was led by thousand workers in Kochi to demand justice for the unfairly stigmatized workers at the government run HIL plant.
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 his report.” said Dr S K Handa, Fellow of National Academy of Agricultural Sciences. 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) does not possess properties to cause cancer or diseases as reported in Kasargod, Kerala.
Source: http://www.business-standard.com/india/news/endosulfan-cannot-be-blamed-for-diseases-in-kerala-dr-s-k-handa/424070/

‘Move to ban Endosulfan will hit Indian farmers’

The Pesticide Manufacturers and Formulators Association of India (PMFAI) expressed concern over European Union’s proposal to categorize Endosulfan as a persistent organic pollutant (POP).

According to PMFAI, EU’s proposed move to launch new, patented, expensive products in the Indian market will be against the interests of the farming community.

Currently, farmers use generic pesticides which are available at affordable prices. Interestingly, Anil Kakkar, director, Crop Care Federation of India, said in countries such as India where small acre farming and sustainable farming was widely prevalent, a ban on Endosulfan would deprive the Indian farmer access to an affordable and effective crop protection solution and alternatives are likely to be harmful to the farm ecosystem and destroy pollinators and beneficials.

“The European Union’s proposal to list Endosulfan as POP is against the interests of Indian farmers as they will be forced to buy patented pesticides at high prices,” said R Hariharan, chairman, International Stewardship Centre Inc (ISC). For instance, Imidachloride, a product touted as a replacement to Endosulfan costs `2,000 per litre, while other alternative pesticides such as Thiamethoxam costs `3,200 per litre and Coregen `700 a litre while Endosulfan is only `200 per litre.

According to estimates, the global crop protection industry is worth $40 billion and the top three companies alone account for over 50 per cent. “There is a strong motivation for the European multinationals to replace widely used, generic and low-priced pesticides with their high-priced patented alternatives,” said Pradip Dave, president, PMFAI.

Endosulfan is the third largest selling generic insecticide worldwide with global market in excess of 40 million liters valued at over $300 million with replacement cost of alternative estimated to be in excess of $1 billion. India’s share in global Endosulfan market is over 70 percent. Similarly, exports of Endosulfan from India are valued at $40 million.

Source: http://expressbuzz.com/cities/hyderabad/%E2%80%98move-to-ban-endosulfan-will-hit-indian-farmers%E2%80%99/246486.html

Proxy battle over endosulfan

Strange is the interplay of money power, business interests and NGO politics. In most cases, farmers turn out to be victims. A recent notification of the Kerala government is a good instance. The State Government recently issued guidelines which render sale of pesticides illegal , unless supported by a prescription from an appropriate agricultural officer.

Behind this apparently innocuous notification lies a complex interplay of various interests. The ostensible object of the notification is to ensure a proactive remedy against health hazards caused by certain pesticides. The real purpose is to effectively proscribe a particular pesticide, viz. endosulfan blamed for certain incidents of congenital abnormalities, cancer and other diseases.

DEBATE OVER ENDOSULFAN

Endosulfan has been the subject of intense debate and controversy. Sixty nations have banned it — 27 belong to the European Union; the 21 African countries that have banned it have substantial trade with Europe known for its reservations against GM foods and pesticides in agricultural produce.

India accounts for about 70 per cent of the world production of this pesticide — about 12 million litres annually, valued at Rs 4,500 crore. The controversy is very similar to that concerning GM foods. European Union countries do not favour GM food items as they harm European pesticide interests. They also oppose pesticides that have ceased to interest them.

On the other hand, endosulfan is used on a very large scale by Indian farmers, particularly in horticulture and pulses. It is considered to be soft on pollinators such as honeybees and other beneficial insects such as ladybird beetles, though effective as a pest killer, acting through the digestive system. It is used for aerial sprays in the cashew plantations in Kasargode district of Kerala.

In the incidents reported from certain villages in Kasargode district , no conclusive evidence has been produced to show that the diseases were linked causally to endosulfan and nothing else. An independent study demonstrates that the symptoms in reported cases correspond to those of handi godu, attributed to chronic inbreeding in the region. Kasargode district represents a peculiar topography that is not ideal for aerial sprays. Endosulfan by itself applied locally might have produced no adverse effects of the alleged type.

The timing of the Kerala notification is ominous. A group of 172 nations is scheduled to meet in April 2011, under the auspices of the Stockholm Convention, to take a final decision on declaring endosulfan as a persistent organic pollutant (POP). India is opposed to such listing…http://bit.ly/proxybattle

Ban on Endosulfan is meaningless

The ban on Endosulfan is meaningless. There is either very little or no agricultural activity in counties where Endosulfan is banned, or the use of Endosulfan in those countries was negligible. For example, in Europe only 201 tonnes of Endosulfan was used when it was banned.http://epp.eurostat.ec.europa.eu/cache/ITY_OFFPUB/KS-76-06-669/EN/KS-76-06-669-EN.PDF In all other countries where it is banned, the land used for agriculture is very insignificant. In some of the counties like Singapore, there is practically no agricultural activity. In countries like Bahrain, Belize, St. Lucia etc., where Endosulfan is banned, the irrigated land is hardly 30-40 sq. km. In six other countries it is 130-750 sq km. In four countries it is 1k to 9k sq km and in one country it is 16k sq km.
Therefore there was nothing to lose in banning Endosulfan in those countries when the activists published wrongful information on Endosulfan. The authorities did not find it necessary to verify the statements made by activists as it was not going to make any difference in those countries!
US EPA has classified Endosulfan under the class of non-carcinogenic substances i.e., class-E. The activists created stories stating Endosulfan as "cancer causing substance" to draw attention of public.
In fact Endosulfan is very important substance as there are no viable alternatives for many of its uses.

http://www.whybanendosulfan.org

Kerala’s pesticide puzzle

Twice every year, between 1981 and 2000, a helicopter would whirr around the hills of the Western Ghats in Kasargod, a district in north Kerala bordering Karnataka, spraying endosulfan over the cashew plantations on the upper reaches. Children would rush out to take a look at the helicopter and the white spray would settle like mist on their heads and on leaves and shimmer in the sunlight. But that’s also when people associated the mist with something deadly—the unusually high number of people with infertility and congenital problems in 11 panchayats in the district.

In 2000, after a sustained anti-endosulfan campaign, the state government banned the pesticide. But the issue stayed alive and images of the ‘pesticide victims’ from Kasargod villages filled the public debate in the state. Recently, Union Minister of State for Agriculture and the Congress’s MP from Kochi, K V Thomas, reignited that debate when he said there was no proof to hold the pesticide guilty for the health hazards in Kasargod. Thomas’s comment came soon after India opposed a global ban on endosulfan at the sixth meeting of the Persistent Organic Pollutants Review Committee to the Stockholm Convention. But the issue is an emotive one in Kerala and Thomas quickly changed his stand to go with the prevailing mood.

Last week, the Indian Council for Medical Research commissioned a study to look into the extent of the damage the aerial spraying of endosulfan over 4,696 hectares of cashew plantation, owned by the state-run Plantation Corporation Kerala Limited, had done to the surrounding villages.

... contd… http://bit.ly/keralatragedy

Fabricated False Evidence against Endosulfan

Activists have created stories and have fabricated false evidence against Endosulfan. Obviously they were funded for carrying out campaigns against Endosulfan. 

Many useful products like Endosulfan have become off-patent today, in due course of time. As anyone can manufacture these products, there is competition in the market. Consequently, these products have become available at an affordable price, and poor consumers are benefited. But some companies launch a campaign against such off-patent products through activists, with a view to prejudice people and impose a ban on such products. The result will be that, the off-patent products will be off-market. On one hand, the consumers will suffer as they will have to pay high price for patented products, and on the other hand, the small industry will also suffer, as the off-patent products which they manufacture will be banned with the help of activists.

Symptoms of iodine deficiency wrongfully linked with Endosulfan

Symptoms of iodine deficiency include thyroid enlargement, goiter, nodules within goiter, and pregnancy related problems such as miscarriages, stillbirth, preterm delivery and congenital abnormalities in babies. Children of mothers with severe iodine deficiency during pregnancy can have mental retardation, problems with growth, hearing and speech, cretinism and low intelligence. 
These effects are NOT caused by Endosulfan, but it is due to iodine deficiency. 

Read more on the website of American Thyroid Association. http://www.thyroid.org/patients/patient_brochures/iodine_deficiency.html#symptoms

Down To Earth [DTE] Publishes Unscientific Articles

Down To Earth publishes unscientific articles on Endosulfan. This magazine has also published in past a lab report on analysis of Endosulfan carried out by Centre For Science and Environment [CSE] lab. In said report, CSE has reported amount of Endosulfan 27 times higher than its scientifically established solubility in filtered water. Study conducted by CSE was funded by European Union. Activists

If such horror story entertains you, there is another one at: http://www.downtoearth.org.in/node/32919
Another Kasaragod
Author(s): Savvy Soumya Misra
Issue: Jan 31, 2011

The article starts with "Like Kerala’s Kasaragod, neighbouring Dakshina Kannada is bearing the brunt of spraying of endosulfan. While Kasaragod grabbed media spotlight and Kerala banned the pesticide, victims in Karnataka are still struggling for recognition"

The expert committee constituted by Government categorically concluded that there is no link between Endosulfan and alleaged health effects in Kasargod.

Now desparate attempts are made through DTE magazine to deceive public. The article states:

"If one cannot prove endosulfan as a causative factor, one cannot disprove it either."

Media has selectively picked up only such horror sensationalizing stories which are not based on science.