Endosulfan - A Victim of Dirty Politics

Politicians are back in action, thanks to the forthcoming Assembly elections in Kerala and this time the agenda for Kerala State Assembly election is, ‘Ban Endosulfan’. But as always, ‘All talk no work’ is the strategy to execute this political agenda as well. Every political party has suddenly become concerned about the ill-effects of Endosulfan on human health and joined the race to show the people of Kasargod District their invaluable support. A scientific subject has now transformed into a political issue. Politicians of the state are leaving no stone unturned to encash this opportunity.

Please note that Endosulfan is being used across the globe for more than 50 years and before the Kasargod conundrum came into light, there has been no talk of health hazards due to this pesticide in India or anywhere else. It is interesting to note how the debate on Endosulfan has intensified in the last few months. For the first time, something other than the Plachimada issue has caught the fancy of politicians in Kerala. Obviously, politicians have a stand on issues that are hot-favourites among the media and create public frenzy. And all they have to do to achieve their objectives is to build on the havoc created by the NGOs in Kerala over the past few years. The fascinating thing here is while the scientific community is ridiculing the studies published by National Institute of Occupational Health (NIOH), these politician and NGOs are using the same as tools to persuade people to support a nationwide ban on Endosulfan.

Some of them went ahead and compared the Kasargod situation to the Bhopal Gas Tragedy. What they did not consider is that if Kasargod was an ‘industrial disaster’ like Bhopal, then workers in Endosulfan manufacturing facilities would have reported health problems. On the contrary, these workers are condemning politicians and NGOs for exploiting the Kasargod situation for their vested interests and demanding an end to anti-Endosulfan campaigns immediately. They are also demanding a withdrawal of the misleading NIOH studies on Endosulfan.

On the other hand, politicians and NGOs are completely ignoring experts’ opinions regarding the fraudulent NIOH studies. They are deliberately ignoring facts that point towards serious scientific flaws in these studies. They have even criticised the Minister of Agriculture, Consumer Affairs, Food and Public Distribution, Shri Sharad Pawar for setting up a panel to study the Endosulfan issue. Insensitive towards farmer’s needs and its various socio-economic repercussions, these politicians and activists are blindly struggling for a total ban of Endosulfan in the country.

So far, politicians have declared relief packages, but made negligible efforts to find the actual cause of these health problems to keep a check on it or try to eradicate it. It is apparent from the poor conditions of these victims that only a portion of these relief packages have actually been handed to them. The state government is now demanding that the Central government provide a Rs 100-crore rehabilitation package to the alleged Endosulfan victims of Kasargod district. An approval to this effect will only give room to more publicity for these politicians. Vote bank politics in Kerala never had it so good.

The Fraud NIOH report

In 2002, National Institute of Occupational Health (NIOH), Ahmedabad published a study titled, “Report of the investigations of unusual illnesses allegedly produced by Endosulfan exposure in Padre Village of Kasargode district (N. Kerala)”. It was followed by another study made by the NIOH titled, “Effect of Endosulfan on Male Reproductive Development.” Both of these studies have become available on internet for public access. During thorough readings of these reports, scientists and experts have noted that the studies have several serious scientific errors relating to the residue analysis of Endosulfan.

Analytical Errors in the NIOH report

The NIOH report named ‘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 ß 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.

The Most Clinching Evidence: 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.

Many erroneous reports emerged after the NIOH study that was proved to be fundamentally flawed. Among these was another noted NIOH report, ‘Effect of Endosulfan on Male Reproductive Development.’ Kasargod-based NGO Thanal, Centre for Science and Environment (CSE) and National Institute of Occupational Health, Ahmadabad (NIOH) have all produced reports linking Endosulfan to adverse health problems including cancer, infertility, birth defects and neurotic disorder. There were numerous scientific flaws in these reports too. For instance, CSE found Endosulfan residues of 9.91 ppm (parts per million) in filtered water samples taken from Padre village. The dissolved chemical concentration in water cannot exceed the solubility of the chemical. Endosulfan’s water solubility is 0.32 ppm. The analytical methodology used by CSE for estimation of Endosulfan residue was scientifically incorrect and inconsistent. CSE’s claim of 9.19 ppm is scientifically implausible. It violates the basic laws of chemistry.

Supported internationally by PAN, EJF (Environment Justice Foundation) and I-PEN (International POP’s Elimination Network) NGOs with vested interests have effectively used media to generate a negative public perception of Endosulfan. Despite the inconsistencies, international conventions and regulatory authorities worldwide have referenced the NIOH report while reviewing Endosulfan, including the Rotterdam and Stockholm Conventions. Recently, the National Human Rights Commission has pressed the Central Government for a nation-wide ban on Endosulfan based on the same report.

Source: http://whybanendosulfan.org/endosulfan-in-india.htm#niohreport

Unknown facts about Endosulfan

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

European Union Exploits Stockholm Convention

Driven by trade interest, EU is pushing Endosulfan for POP listing

Elimination of Endosulfan is expected to severely impact pollination and India’s farming

India is today the second largest producer of horticulture crops (fruits at vegetables) and annually produces over 215 million mt (2008-09 figures source Ministry of Agriculture). This is almost as much as India’s total food grain production of 235 million mt (2008-09 figures source Ministry. of Agriculture). India’s export of fresh fruits and vegetables was Rs 3659 crores during 2008-09 (source APEDA). India ranks fifth in the world in cropped area under cultivation and production of potatoes. India produces 40% of world’s mangoes, 26 %bananas, 18 % cashew nuts, 28 % green peas and 12% onion.

Endosulfan is a plant protection chemical used by farmers for more than 55 years to control pests during the early phase of cultivation and particularly during pollination. It is widely used by farmers in India as a broad spectrum insecticide soft on pollinators and beneficial insects. Besides cross pollinating our food crops, Honey bees are vital links that forge the bio diversity of the environment. Endosulfan is used extensively in cultivation of fruits and vegetables. Today India is the largest producer of Endosulfan and accounts for over 70% of the global trade of this product.

The European Union is pushing the Stockholm Convention to bring about a global ban on Endosulfan by spearheading a campaign to list Endosulfan as a Persistent Organic Pollutant. All decisions taken against Endosulfan at the Stockholm Convention have been without consensus and in spite of lack of full scientific certainty and significant data gaps.

While considering the EU proposal to list Endosulfan there were serious procedural lapses:

• The text of the convention, their articles and rules were not followed
• The process was not transparent
• There was conflict of interest as European Union the notifying party for Endosulfan also prepared the risk profile
• The proposals to recommend Endosulfan lacked scientific merit and decisions were taken despite significant data gaps.

• India’s protest and dissent notes were ignored and all the decisions relating to Endosulfan were taken by voting in spite of serious objections from India, China, Argentina and other countries.

 

The European Union (EU) is pushing India and the global community to stop use of Endosulfan as it has proposed listing of Endosulfan as a persistent organic pollutant, in spite of lacking full scientific certainty. If Endosulfan is banned farmers will need to find replacements and will be forced to use expensive patented and proprietary molecules produced by European multinationals. Farmers in India will be forced to use alternatives like neonicotinoids in spite of it being banned in parts of Europe.

To create a climate for ban on Endosulfan in India, the EU funded lobby of environmental NGO’s has generated various studies and surveys to link Endosulfan to incidences of  human health effects and have stigmatized Endosulfan by unleashing a false propaganda against Endosulfan in the  media.

World Health Organisation (WHO) and Food and Agriculture Organisation (FAO) and the International Agency for Research on Cancer (IARC) have all classified that Endosulfan does not cause cancer, is not genotoxic or mutagenic.

  

Pesticides Manufacturers and Formulators Association of India (PMFAI) held a Press Conference in an effort to support India’s position on Endosulfan at The Stockholm Convention and invited Mr R Hariharan, Chairman International Stewardship Centre (ISC), an observer at The Stockholm Convention and Mr Anil Kakkar, Director Crop Care Federation of India (CCFI) to share their experiences.

Shri Pradip Dave, President of Pesticides Manufacturers and Formulators Association of India (PMFAI), expresses fear that “India’s Food Security would be at stake if the use of Endosulfan is banned.” An industry issue, it is gaining more ground as a political issue, where facts or fundamentals have no considerations. Under any circumstances, if the Government bans the use of Endosulfan in the country, the farming community and the country’s food security will be adversely affected, he added.

With the growing population of India and to meet the basic needs of the masses, it is becoming essentially vital and important that agricultural production keep pace with the increase in population. This is the only way to feed more than billions people without being dependent on imports.

A very few plant protection products actually qualify for Integrated Crop Management system,  Endosulfan is one such product which is not only effective in controlling pests but also helps in improving the productivity of crops/plants without being harsh on the environment.

Shri Hariharan, Chairman of International Stewardship Centre (ISC) said that “Currently, the worldwide usage of Endosulfan is estimated at 40 million litres, which makes it one of world’s top five generic agricultural insecticides. The trade in Endosulfan today is in excess of US$ 300 million (Rs 1350 crores) and its replacement value is estimated to be in excess of US$ 1000 million (Rs 4500 crores). Endosulfan’s popularity as a broad spectrum generic insecticide soft on pollinators and beneficial insects has resulted in its safe use for over 55 years. Today India is the largest producer of Endosulfan and accounts for over 70% of the global trade in Endosulfan. As a result it’s caught in a cross fire in a battle between “generic” insecticides produced by Indian companies vs. “patented” insecticides produced by European multinationals”.

Shri Anil Kakkar, Director of Crop Care Federation of India (CCFI), further added that “Endosulfan is one of the most widely used pesticides in India. Indian farmers have been relying on Endosulfan to protect their crops since several years. The climatic conditions and the pest complex in India are very different that Europe and the use of products like Endosulfan are well suited for tropical countries like India. Banning the use of Endosulfan can impose serious threat to pollination and on its resultant effect on our food security. Replacing Endosulfan with other patented costly plant protection products will increase the cost of pest management for Indian farming community, which may increase food prices and aggravate inflationary pressure”.

About Pesticides Manufacturers and Formulators Association of India (PMFAI):

It came into existence in the year 1967 as Pesticides Formulators of India with a view to provide a platform for small scale Pesticides Formulators. It was subsequently changed in 1997 as Pesticides Manufactures & Formulators Association of India. The members of PMFAI include multinationals, large-medium and small scale basic manufacturers & manufacturers of intermediates required for Pesticides. PMFAI also organises various training programmes and seminars for the Indian Pesticide Industry and also circulate to members the recent developments as regards to regulatory affairs which are time to time changed by State and Central Governments.

International Stewardship Centre, Inc.:

 The International Stewardship Centre (ISC) is a non-profit corporation, with roots in the early 1990s it was created for the purpose of educating, promoting and encouraging safety in the manufacture, transport, distribution, storage, use and disposal of chemical substances. ISC works through its member companies with both end users and governments in sharing product stewardship information. Its membership consists of manufacturers of industrial chemicals and insecticides. By the nature of its charter, member companies of ISC are committed to the safe use of chemicals. ISC supports the stated principles of the Stockholm Convention in which it has been granted observer status and has followed closely the deliberations and developments at its various meetings. 

Crop Care Federation of India (CCFI):

 It is one of the oldest and foremost associations. CCFI is a non-profit, non-commercial organization, endeavoring to build a responsible image for the agrochemical industry Most of the leading pesticides manufacturers and formulators are its members. As a committed and progressive body representing the Indian agrochemical industry, CCFI has pursued its focal goal of advancing the cause of Indian farmers through better crop-protection. 

Source: http://www.business-standard.com/india/news/european-union-exploits-stockholm-convention/422653/

Endosulfan is safe to bees and beneficial for insects

Endosulfan exhibits low toxicity to bees and beneficial insects http://www.atsdr.cdc.gov/toxprofiles/tp41-c4.pdf ). 
Endosulfan has relatively low toxicity to many species of beneficial insects, mites and spiders. These insects are beneficial in the sense that they prey upon pests which damage crops. Hence it is important that the insecticide used to kill pests is not unsafe to these beneficial insects. Other chemicals, necessarily substituted for endosulfan, would kill beneficial insects leading to population explosions of damaging pests which in turn would require more frequent sprays of harsher chemicals than if endosulfan had been used in the first place.

Vested interests in demanding ban on endosulfan: PMFAI

Domestic pesticide makers today said that the demand for banning endosulfan pesticide in India is being driven by vested interests of Multinational firms.

"The demand for banning endosulfan in India, is motivated by the vested interest of Eurpean pesticide makers, who are interested in promoting their patented products in the country,"Pesticides Manufacturers and Formulators Association of India (PMFAI) President Pradeep Dave told media here.

European companies, which have vested business interests are lobbying for imposing an international ban on endosulfan as the ban would create a market for their products in the third world countries, he said.

Dave added that endosulfan is being used in the country for the last 50 years and there has been no such scientific records available, which indicate that the use of this chemical has resulted into serious health hazards of any kind.

International Stewardship Centre, an NGO working for chemical industry, said that replacing endosulfan with any other chemical would be at least 10 times costlier for the Indian farmers.

"A litre of endosulfan costs Rs 250 to Indian farmers whereas any chemical manufactured by multinational would cost more than Rs 2,500 per litre thus making the use of pesticides 10 times costlier,"International Stewardship Centre Chairman R Hariharan said.

Source: Press Trust of India (PTI)

H/T India Reports [India Reports | Vested interests in demanding ban on endosulfan: PMFAI ]