Is it banned? 
Guidance for implementing Prior Informed Consent

News Release: 04/04/2001

The question most asked about pesticides is 'has it been banned?' The number of pesticides actually banned is surprisingly few. But a new international Convention agreed in September 1998 will help to answer the questions of what is banned or severely restricted, by which governments, and for what reasons.  A group of experts met in Rome from 19-23 March to help implement the Convention.

Governments signed the Rotterdam Convention on Prior Informed Consent (PIC) to alert other governments, particularly those in developing countries, of actions to ban or severely restrict a pesticide. Once a pesticide is agreed for inclusion in PIC, governments have the right to bar the imports of the active ingredients and any products, and exporting countries undertake to ensure their exporters comply.  The Convention will enter into force when it has been ratified by 50 parties (the present tally is 14), but it is already operating on a voluntary basis.

While PIC was already operating under the International Code of Conduct on the Distribution and Use of Pesticides of the UN Food and Agriculture Organisation (FAO), the negotiations for a Convention were triggered by the 1992 Earth Summit.  The FAO and the UN Environment Programme, which act as Joint Secretariats of the Convention, are urging governments to ratify before World Summit on Sustainable Environment and Development (Earth Summit III), in Johannesburg, June 2002.

The task of identifying whether a pesticide qualifies for PIC (i.e. whether a  government's regulation is actually a ban or severe restriction) falls to the Interim Chemical Review Committee (ICRC). Membership of the ICRC consists of 29 government-designated experts balanced from different regions of the world. When the Convention has been ratified, the ICRC will become the Chemical Review Committee of the Conference of the Parties (CoP) of the Convention.

The Convention already includes 21 pesticide active ingredients (and 5 formulations of pesticides considered too hazardous for use in developing countries) identified when the procedure was voluntary.  The March meeting was the second of the ICRC, and the experts still spent time to developing procedures for implementation, but they made their first recommendation on a pesticide that was not waiting in the wings under the voluntary procedure.

New warning on monocrotophos 

The governments of Australia and Hungary have both banned monocrotophos, meeting the criteria of a ban in two different regions of the world.  Experts from both countries made presentations, and the ICRC, "taking into account each of the specific requirement set out in . the Rotterdam Convention, concluded that the requirements . had been met." This makes monocrotophos the first 'new' pesticide to go forward for PIC entry (though formulations over 600g/l are already included under 'conditions of use').  The ICRC is a technical advisory committee, and preparations now need to be made to draw up a Decision Guidance Document, and put the pesticide before a full meeting of governments at an International Negotiating Committee for a decision.

Maleic hydrazide - formulations cleared

The ICRC also discussed how to treat maleic hydrazide, as a result of a European Union ban on formulations with more than 1ppm hydrazine. Investigations and industry evidence clarified that contamination above this level occurs in the diethanoleamine (DEA) salt formulations of maleic hydrazide only, and that the product in trade is the potassium salt.  The main industry producer (Uniroyal) was present and indicated that their company, and other producers, changed their processing systems many years ago to ensure that all their products on the market conformed to this standard. The other two main US producers (Drexel and Fair Products) also changed their processing systems. These companies have 100% of the US market; Uniroyal and Drexel have 80% of the market in Europe and Asia. Other manufacturers are Otsuka Chemical (Japan), and a manufacturer in China (name unknown). Uniroyal has been sampling products on the market regularly for over 10 years and it confirmed that:

1,500 metric tonnes of maleic hydrazide acid (technical grade) and approx. 2,000 metric tonnes of maleic hydrazide potassium salt are manufactured world wide. No hydrazine is produced in the formulation of maleic hydrazide into the potassium salt, nor in the storage of the potassium salt;  DEA salt formulations were withdrawn several years ago; the last samples on the market were found over 10 years ago.

On this basis, the ICRC concluded there was no trade in maleic hydrazide potassium salt with the level of impurity subject to the EU ban.  Uniroyal and other manufacturers were requested to apply to the FAO for a specification for the technical product, and the company is already preparing this application. The expert from the US undertook to write to the other two US companies producing maleic hydrazide to ask them to also apply for an FAO specification.

PIC is a tool to reflect government actions: but it is an important tool which increases information flow about bans and severe restrictions, and can help developing countries to stop unwanted imports. While the process moves slowly, if it begins to pick up pesticides such as monocrotophos - a very hazardous organophosphorus pesticide responsible for deaths and ill-health worldwide - the process is worthwhile.

Barbara Dinham , PAN UK