190519 FAW outbreak
In a shocking incident the Seeds Division, Ministry of Agriculture, Government of India has issued a directive signed by Mr. Dilip Kr. Srivatsava, Asst. Comm (QC), making compulsory seed treatment with cyantraniliprole and thiomethoxam , we are shocked to see that such a direction is given in spite the formulation not registered in India and also not been evaluated in AICRP program and purely based on the feed back from seed growers feed back that the seed treatment giving protection for 2-3 weeks after germination. This is violation of Insecticide Act
we are amazed that the chemical seed treatment of an un-evaluated and un-registered formulation has been given more prominence in your advisory than all the collective wisdom and established field experience of farmers, organizations and state governments on Non Pesticidal Management, Natural Farming and Organic Farming. monitoring and scouting measures to be taken up other than cultural, mechanical and bio-control measures being recommended. Furthermore, it has been made compulsory and we are keen on understanding the scientific basis for the same. Biosafety issues with the chemicals recommended
Even if we assume that the emergency situation, it is illegal to make it compulsory to use chemicals which are not tested and registered in India. As per the Central Insecticides Act, 1968 the Central Insecticide Board andRegistration Committee (CIBRC) under the Directorate of Plant Protection, Quarantine & Storage, Department of Agriculture & Cooperation is supposed to register each pesticide in the country after scrutinizing their formulae and claims made by the applicant as regards its efficacy and safety to human beings and animals. The Registration Committee is also expected to specify the precautions to be taken against poisoning through the use or handling of insecticides. The recommendations made has not taken into account the international published information which show the following serious concerns with cyantraniliprole and Thiamethoxam. Cyantraniliprole
Cyantraniliprole is a systemic insecticide belonging to the diamide class of pesticides. Cyantraniliprole works by binding with insect ryanodine receptors, which leads to unregulated activation of ryanodine receptor. Insects exposed to cyantraniliprole “first exhibit lethargy, followed by muscle paralysis, and then death.” says the CYANTRANILIPROLE RISK ASSESSMENT by US Environmental Protection Agency. It further states that
As a systemic insecticide, translocation of cyantraniliprole through the xylem and phloem results in expression of the chemical throughout exposed plants, resulting in multiple routes of exposure for various non-target organisms, including mammals, fish, invertebrates and plants.
Cyantraniliprole biodegradation proceeds more slowly in aerobic conditions than anaerobic conditions, suggesting that it could be fairly persistent in the agricultural environment and adjacent ecosystems.
Degradation times in soils and sediments reached 89 and 25 days, respectively, showing an extended period of activity after application. When the total toxic residues were calculated (including degradates), a range from 88 to 1327 days was identified. Cyantraniliprole is also characterized as moderately mobile, meaning that it can move off-site and affect nearby terrestrial and aquatic ecosystems. Some of the degradates of cyantraniliprole are more persistent and mobile than the parent compound, a concern for ecological effects as some may be more toxic than the parent and may accumulate over time. Thiamethoxam
Thiamethoxam is a second-generation neonicotinoid compound that belongs to the chemical subclass thianicotinyls and acts on target pests by interfering with the nicotinic acetylcholine receptor. It is known to impair honeybee flight ability. There are also evidences and published data which shows that TMX. as it is called, may also pose reproductive risks on mammalian reproductive health. The American Bird Conservancy (ABC) report, The Impact of the Nation’s Most Widely Used Insecticides on Birds, concluded that it would take only six corn seeds coated with thiamethoxam to achieve a 50 percent chance of lethality (LD50) given sensitivity at the 5% tail of bird distribution, assuming an avian body weight of 50 g – somewhere between a large sparrow and a blue jay. Like-wise only 0.3 (roughly a third) of a treated seed would be enough to impair reproduction. Adverse Impacts of Cyantraniliprole Products Co-Formulated with Thiamethoxam
While independently both the chemicals have their own biosafety problems, the co-formulated products may have much more severe impacts. EPA conducted a specific risk assessment of this mixture and concluded that “the typical end-use products with thiamethoxam are also modeled because they presented more sensitive toxicity values than their technical-grade counterparts.” In other words, this mixture of these two pesticides is more dangerous than the pure, technical grade active ingredient in isolation. EPA’s own initial analysis determined that “cyantraniliprole-thiamethoxam mixture would require buffer in excess of 1000 ft for all uses.”
As the Fall Army Worm is a polyphagous pest, the order amounts to making the seed treatment with cyantraniliprole-thiamethoxam mixture for almost every crop mandatory, which can be an ecological disaster. Hence, we request the Plant Protection Division, Directorate of Plant Protection Quarantine & Storage to retract this decision by the seeds division as it a violation of law a potentially dangerous chemicals are introduced without any basic research and registration. This will set a serious bad precedence to violate the law.
Moving towards Agroecological Approaches
It is clear that the incidence of and losses due to FAW are largely due to increasing monoculture of maize and excessive use of chemical pesticides which is leading to disturbance of the ecological balance.
The major pest outbreaks in the last three years, if we consider, are Pink Boll Worm in Cotton across the country, Brown Plant Hopper in Odisha, parts of Andhra Pradesh, Fall Army Worm across the country. All these outbreaks are in the areas of high monoculture of these crops and high use of chemical pesticides. Whereas, the areas under agroecological approaches like Non Pestidical Management (NPM), Organic and Natural Farming, Zero Budget Natural Farming (ZBNF) have not shown any high incidence of the pest. Therefore, the solution lies in moving towards agroecological approaches which can restore back the ecological balance rather than doing more of the same with monocultures. The experiences across the world proved the same.
The Non Pesticidal Management experience in Andhra Pradesh (united) between 2004 to 2010 showed that if farmers can be trained well on understanding their agroecosystem and trained on effective use of local resources, pests can be managed with a combination of scouting, preventative care, use of locally available botanicals and animal waste and without out using chemical pesticides. While number of studies on these experience shows that the chemical pesticide use is reduced, neither major pest out breaks nor yield reductions were recorded. In villages where Centre for Sustainable Agriculture (http://www.csa-india.org) Maize is grown and could be managed with minimalistic damage. The emphasis on deep summer ploughing, pheromone traps, prophylactic sprays of 5% NSKE, inter-cropping and using of trap crops, erection of bird perches, effective weed control, release of Trichogramma for bio-control, spraying of Bt powder formulations, application of dry sand into affected whorls etc. are all to be taken up with equal emphasis, that too on community-based, and area-wide approach for proper management.
The Zero Budget Natural Farming model in Andhra Pradesh where large no of farmers also cultivates maize, the crop could be managed with the ZBNF + practices. FAO was also involved in training farmers on agroecological approaches through Farmer Field Schools.
Similarly, the organic farmers across the country who grow maize as intercrop/mixed crop with organic farming practices have not reported any serious damage with Fall Army Worm as it happened in the monoculture maize crop under high input intensive cultivation.
Several studies from Africa observed that FAW damage was found to be lower for maize crops established through zero-tillage compared to maize crops established through conventional tillage, The lower FAW damage was also found when manure or compost were applied. Similarly, the push-pull system, a stimulo-deterrent cropping strategy consisting of intercropping cereals with herbaceous legumes and surrounded by fodder grasses, is presented as a promising crop diversification strategy contribute to maize stemborer suppression, while improving soil fertility and providing feed for livestock.
Similarly, National Institute for Plant Health Management (NIPHM) has come out with what they call as ecological engineering based on the Integrated Pest Management (IPM) model.
All these experiences show that a scientific approach to manage any pest including the Fall Army Worm is shifting towards agroecological approaches and not blindly recommend couple of toxic chemicals which may provide protection only for the initial 2-3 weeks of the crop. The experience with a similar chemical Imidacloprid is still in front us, the bee collapse it has caused due to indiscriminate use.
It is this lack of balanced emphasis on cultural, mechanical and biological control measures with an over-emphasis on chemical approaches that has led to the current crisis, which then becomes the basis for further unscientific and unsafe technologies to be ushered in, like transgenics.
It is clear that timely, coordinated management practices will certainly help in checking the spread of FAW, and that the current urgency should not be used for promoting any untested, unproven and potentially hazardous solutions.
We urge the Ministry of Agriculture & Farmers Welfare to kindly refrain from promoting any unreasoned and unscientific recommendations – Thiamethoxam, for instance, has been banned on field crops in the European Union, given its adverse impacts on bees. The chemical is being considered for phasing out in Canada, where it is used as a seed treatment chemical (including on corn) after a review of impacts on aquatic insect species.
(G V Ramanjaneyulu)
Executive Director http://krishi.bih.nic.in/Acts-Rules/Insecticides_Act_1968.pdf https://www.regulations.gov/document?D=EPA-HQ-OPP-2011-0668-0008 CYANTRANILIPROLE RISK ASSESSMENT http://publications.gc.ca/collections/collection_2013/sc-hc/H113-9-2013-9-eng.pdfhttps://www.biologicaldiversity.org/campaigns/pesticides_reduction/pdfs/Notice_of_Intent_re_Cyantraniliprole_3.21.2014.pdf https://www.biologicaldiversity.org/campaigns/pesticides_reduction/pdfs/CTP_Complaint.pdf https://www.centerforfoodsafety.org/files/cfs_abc–joint-cyantraniliprole-registration-comments–final_16053.pdf https://www.regulations.gov/docket?D=EPA-HQ-OPP-2011-0581 https://www.nature.com/articles/s41598-017-01361-8.pdf https://www.ejmanager.com/mnstemps/31/31-1486156117.pdf?t=1558237961 http://abcbirds.org/wp-content/uploads/2015/05/Neonic_FINAL.pdf  CYANTRANILIPROLE RISK ASSESSMENT http://csa-india.org/what-we-do/npm/ http://www.apzbnf.in https://www.sciencedirect.com/science/article/pii/S0261219419300304 https://www.sciencedirect.com/science/article/pii/S0261219417303216 https://www.sciencedirect.com/science/article/pii/S0167880918303931 https://niphm.gov.in/IPMPackages/Maize.pdf
You all may be aware about the recent discussion about unapproved and untested pesticides being recommended by the Government for Fall Army Worm and making them mandatory. In CIBRC 401st meeting which happened on 15th May. 3 insecticides including Spinetoram 12%SC, Chlorantraniliprole 18.5%SC and Thiamethoxam + Lambda cyahalothrin have been approved and given recommendation for FAW management in India.
Current EU regulations forbid human exposure to pesticides that are classified as mutagenic, carcinogenic, reprotoxic (toxic for reproduction), persistent or capable of disrupting endocrine systems. By virtue of these and other protective measures EU regulations are considered the gold standard in public protection.
However, experts who are closely linked to industry (or are part of anti-regulation pressure groups) have taken control of the EU’s new Science Advice Mechanism (SAM). These experts have contributed to a report commissioned to reevaluate the EU’s authorisation of pesticides. The report, called “EU authorisation processes of Plant Protection Products”, and published in late 2018, recommends dramatically weakening the EU regulatory system. Especially notable is the adoption of many ideas previously proposed by the chemical industry. For example, the EU currently deems the acceptable level of public exposure to mutagenic pesticides (those that damage DNA) to be zero. The new report recommends scrapping this standard of protection.
The history of the new SAM report is that it was requested by EU Health Commissioner Vytenis Andriukaitis. Its purpose was to determine how to act in cases of so-called ‘diverging views’; that is, when media and public interest groups get involved. The request follows a series of major controversies over EU regulatory decision-making. One such controversy was over the herbicide Glyphosate. A “European Citizens Initiative” delivered more than a million signatures to the EU Commission asking for a ban on Glyphosate. Several cities banned Glyphosate. Even a dairy company banned the use of Glyphosate by their farmers.
With this pressure from all over Europe, the EU Commission had difficulty reaching a decision since many EU member states (Bulgaria, Denmark, Czech Republic, Estonia, Ireland, Spain, Cyprus, Latvia, Lithuania, Hungary, the Netherlands, Poland, Romania, Slovakia, Finland and the U.K) opposed a ban. Ultimately, a very unusual 5-years extension for glyphosate was agreed but soon the discussion will start again.
Issues with neonicotinoids have also pushed the EU Commission into a corner. Neonicotinoid insecticides are linked by much research to ‘bee colony collapse’ and, according to the International Union for the Conservation of Nature “represent a worldwide threat to biodiversity, ecosystems and ecosystem services” (Goulson, 2013; IUCN 2017). This again placed the EU Commission in the crossfire since many EU member states and their ministries of agriculture wished to keep neonicotionids on the market. Waves of scientific publications and media attention about dying bees and empty beehives forced the EU Commission to finally ban them. Nevertheless, Poland, Romania, Hungary, and Lithuania still resist the ban by using derogations.
A third big controversy has been endocrine disruption. Public concern about hormone-mimicking chemicals forced politicians in 2009 to address endocrine disruption concerns in the regulations and ban endocrine disrupting pesticides. An enormous lobbying effort from industry, the US chamber of commerce, EU Directorate General (DG) Enterprise, and EU DG Growth, tried to stop the implementation of the new rules, especially during the TTIP trade negotiations with the US. EU DG Environment was isolated and in the end DG SANTE (health) was found willing to do the dirty work of undermining the rules. Again, waves of bad publicity from the public and scientists harmed the credibility of the EU Commission. This debate too is far from over.
Conflicted science advice
The SAM report is important since it will soon be used by the EU Commission as an input for its ‘REFIT’ programme to evaluate pesticide regulation. This is a programme that the chemical industry sees as a major opportunity for a regulatory roll-back.
Some of the experts invited to help SAM and listed on the SAM website, however, are not independent. Instead, they have strong links to the International Life Sciences Institute (ILSI). ILSI is a worldwide network, a federation of non-profits funded by many industries, including the pesticide industry, and which provides expertise in regulatory issues.
ILSI global includes over 400 company members and ILSI Europe includes 88. Among them are every pesticide multinational.
Sourcewatch writes of ILSI that: “The interests of food, pharmaceutical, tobacco, energy, and other industries have become even more entwined. They have learned to cooperate (rather than blaming each other for the cancer epidemic) and they now form coalitions to fight health and environmental regulations.
“It is notable that [ILSI members] generally employ the same lawyers, lobbyists and PR companies, and use essentially the same tactics”.
ILSI has a negligible public profile, and claims not to be a lobby group, but is very active behind the scenes in obtaining seats for ILSI-associated scientists on regulatory panels such as that of the EU Food Safety Authority (EFSA) and international organisations like WHO, the World Health Organisation, the Food and Agriculture Organisation (FAO) of the UN, and the International Programme on Chemical Safety (IPCS) of the WHO. Experts generally do not disclose their links to ILSI and pretend to be independent academic scientists.
A recent example of ILSI members successfully getting seats on an EFSA-panel concerned the risk assessment idea of a Threshold of Toxicological Concern (TTC). This idea assumes chemicals are safe at low doses without (expensive) testing. It has been an important goal of the chemical industry to establish TTCs in European and other jurisdictions.
PAN Europe has analysed the process of developing guideline for the TTC at the European Food safety Authority EFSA. We discovered that the chair of the EFSA working group was Sue Barlow, who worked for ILSI and the cigarette industry. She had volunteered to be chair of the EFSA working group. From this position she installed an ILSI network. This EFSA working group then more-or-less copy-pasted the ILSI proposal, making it into an EFSA opinion.
ILSI has been imposing its ideas on many other current EU risk assessment methods too, intending to weaken protections and ease access of pesticides to the market. Thus a PAN Europe survey showed that out of 12 EU pesticide risk assessment methods analysed, 8 were designed and promoted by ILSI. Industry is being allowed, under the radar, to “write its own rules”.
The conflicted scientists
In the case of the SAM, a prime example of these conflicts is UK professor Alan Boobis who is listed on the SAM website as a contributor to the SAM report. Alan Boobis has been active in ILSI for decades. Until January 2018 he was the chair of its Board of Trustees. Due to his conflicts of interest Boobis was disbarred from a new expert panel convened by EFSA in 2012.
French professor Dominique Parent-Massin is mentioned alongside Boobis as working on the SAM report. Prof. Parent-Massin has previously worked with ILSI member, Ajinomoto – the world’s biggest Aspartame producer.
Also listed on the SAM website is Joergen Schlundt, former Director of the Danish National Food Institute. Schlundt is also a former ILSI board member .
All three are listed on the SAM-website as contributors to the report, or as providers of evidence through another report written by a new network called Science Advice for Policy by European Academies (SAPEA), or as being part of a ‘sounding board’ and fact-checking process. Despite these counter-indications the SAM website states that “The Commission found that none of the interests declared constituted a conflict of interest.”
Another expert used by the SAM is German professor Daniel Dietrich, editor-in-chief of the journal Chemico-Biological Interactions. With a group of editors of journals of pharmacology and toxicology he has been very vocal in trying to stop the regulation and banning of endocrine disrupting pesticides (in EU Regulation 1107/2009). Dietrich published editorials in several scientific journals that triggered highly critical responses from other scientists, such as members of the ‘Endocrine Society’. Ties between the Dietrich group of authors and industry were exposed by Le Monde journalist Stéphane Horel who found 17 out of the 18 experts of Mr. Dietrich’s group have past or current ties to industry. The Dietrich group has been prolific, publishing articles like ‘Endocrine disruption: Fact or urban legend?’ that disputes the health risks of endocrine disruption (Nohynek et al., 2013). Even after former EU science advisor Anne Glover achieved a consensus between opposing groups that toxicological thresholds below which chemicals are safe (see TTC above) were unproven, Dietrich and his group (along with Alan Boobis) still claimed their opponents used “pseudoscience” (Dietrich et al., 2016). Dietrich also opposed the EU ban of bee-harming neonicotinoids, and both Dietrich and Boobis criticized the IARC-report asserting the genotoxicityof Glyphosate.
Conflicts in EU science advice
The EU has mechanisms to prevent conflicts of interest from derailing its scientific decisions. The SAM website currently presents ‘Declarations of Interest’ (DoI) for its members including for Boobis, Parent-Massin, Dietrich, and Schlundt. But one might wonder if procedures to report conflicts of interest are functioning. DoI’s were not available online when the SAM-report was published (in June 2018). One was even not signed until considerably after publication, in August 2018.
The efforts of ILSI have so far been effective. Several of its campaigning targets are included in an important “SAPEA evidence review report“. SAPEA (Science Advice for Policy by European Academies) is a new body set up by European science academies. This evidence review is intended to feed into the SAM report and featured many of the conflicted scientists above. SAPEA’s report promotes many industry objectives, such as the use of ‘historical control data’. The great importance of this is that, since many potential historical controls exist, their use makes it much easier to ascribe toxic effects observed in animal testing as being simply noise and therefore irrelevant.
Another industry goal is to promote inexpensive (in vitro) ‘mode-of-action assessment’ in preference to expensive adverse outcome testing. A third is to drop the obligation for chronic mouse testing.
The aims of PAN Europe and the Endocrine Society, on the other hand, are: 1) to recognise the reality of ‘low dose effects’ which are currently not tested at all for pesticides; 2) the recognition that chemicals may cause non-linear toxicity responses over a wide range of doses. These are called ‘non-monotonic dose-effect responses’ (whereas regulators presently acknowledge only linear dose-response curves of toxicity and even dismiss effects entirely if they are not linear); 3) mandatory testing for endocrine disruption; 4) to dispute the current regulatory assumption that chemicals have safe thresholds. All are missing from the SAPEA report.
In a further blow to precaution, the SAM report proposes to change EU rules by exchanging the acceptable level of citizen protection from “do not have any harmful effects on humans” for an undefined level, that of “acceptable risk”. This is the change of regulation that would make human harm legal, since it would stop the EU’s much-detested-by-industry ‘hazard approach’ that aims to avoid any exposure of humans to classified (mutagenic, carcinogenic, reprotoxic (toxic for reproduction), persistent and endocrine disrupting) pesticides.
SAM proposes that the EU should re-examine this ‘hazard approach’, which has been under attack by industry for many years; and so it seems that SAM might prove to be the instrument by which industry finally achieves successes for which they have campaigned so long.
The EU has shown itself sensitive to public pressure. What is now needed is for that pressure to be redoubled.