Exporting risk - US hazardous trade 1995-1996

Trade in hazardous pesticides is being targeted through international legally binding instruments-the newly agreed PIC Convention and the forthcoming POPs negotiations. But there is little publicly available information on trade. Carl Smith of  FASE has analysed one of the few sources which shows pesticides too hazardous for use in the US are routinely shipped to developing countries.

Despite a quarter century on the verge of export reform, American policy makers have not acted to stop the export of pesticides forbidden in the US. Pesticides that the US Environmental Protection Agency (EPA) has judged too dangerous for domestic use, as well as pesticides never evaluated by EPA, are routinely shipped from US ports. Many are bound for destinations in the developing world, where it has long been established that prevailing conditions-a lack of protective equipment, unsafe application and storage practices, inadequate training of pesticide applicators-increase their hazards.
    The US government does not maintain complete records of pesticide shipments. Two separate General Accounting Office (GAO) reviews have found that the EPA does not monitor pesticide exports adequately(1). Moreover, EPA recently revealed that it does not even have permission from the Department of Commerce to access the information in shipper's export declarations.
    In 1991, the Foundation for Advancements in Science and Education (FASE) began a project to document the extent of the trade in banned and hazardous pesticides, through the analysis of US Customs shipping records(2,3).

1995-1996 findings
According to Customs documents, a total of 630,040,438 pounds (lbs)* of pesticide products were exported in 1995. The 1996 total was 687,601,508 lbs, an average rate of 936 tons (t) per day(4). The 1996 figure represents a more than 40% increase over the 1992 figure of 490,113,733.
    Between 1992 and 1996, more than 2 billion lbs of pesticides left US ports with their specific chemical names omitted from publicly accessible shipping records-a rate well over 500t per day. In many cases the description is simply 'pesticide', or 'weed killing compound'; in others, trade names or abbreviations are used which cannot be found in publicly-accessible pesticide dictionaries, reference books or on-line databases.

US-prohibited pesticides
In 1995 and 1996, at least 21,026,794 lbs of pesticides which are forbidden to be used in the United States were exported from US ports. This total, which includes banned as well as never-registered products, represents an average rate of more than 14t shipped per day. It is almost 2% of all pesticides shipped during this period.
    Banned products include silvex (18t), chlordane (1,302t), ethylene dibromide (EDB) (30t), mevinphos (21.6 t), monocrotophos (504t), sodium penta (306t) and copper arsenate (1,895t)  (see table 1).

Never-registered
Pesticides produced for export only are not subject to registration, and so are not evaluated by EPA for health or environmental risk. Moreover, FAO has confirmed a general lack of testing of pesticide products in the developing world6. Nearly 9.4 million lbs of 'never-registered' pesticides were exported in the years 1995 and 1996-an average rate of more than 6t per day. This rate is a  40% increase over the 4.6t per day noted in the three-year period from 1992 through 1994.
    The 9.4 million lbs figure is almost certainly a gross underestimate. As discussed in previous FASE reports, Congressional testimony by the National Agricultural Chemicals Association indicates that the real total is likely to be at least 10 times greater(7).

Severely restricted
Severely restricted pesticides are products "for which virtually all registered uses have been prohibited by final government regulatory action, but for which certain specific registered use or uses remain authorised."(8) From 1995 to 1996, 11.7 million lbs of such pesticides left US ports, an average rate of 8t per day(9).

Extremely toxic
Under the World Health Organization a classification system 'extremely hazardous' pesticides(10) are designated 'Class Ia.' These pesticides pose great risk to agricultural workers.
    Class Ia pesticides exported 1995-1996 totalled more than 48 million lbs-an average rate of 1.4t per hour. The rate of export of these products climbed steadily between 1992 and 1996. The 1996 total of 28,579,982 lbs is a more than 500% increase over the 1992 total of 5,366,172 lbs (see table 2).

Endocrine disruption
Exports of pesticides linked with endocrine disruption have been rising over the last five years, even accounting for the addition of new chemicals to this list. The 1996 total was 72,667,924 lbs, an average rate of 100t per day, and a 28% increase over the rate of 78t per day during the previous four years(11). The primary destinations were Belgium, Brazil, Argentina, India, the Philippines and Japan (see table 3).

Recommendations
There must be no double standard of safety. The fact that most developing countries do not have the necessary infrastructure to fully evaluate the risks of imported pesticides must be reflected in US export policy. The following steps must be taken:

• The export of banned pesticides must be prohibited. As evident from many examples in EPA's history, the process of banning a pesticide involves extensive review, including verifying that alternative products exist. There is no substantial reason for allowing their export.

• Mandatory filing of data on pesticide shipments via the US Customs Service: the Automated Export System (AES) must be implemented. This can be accomplished relatively easily via an existing system already established by AES(13). AES allows for electronic filing of details regarding exported products.

• A central, easily navigable on-line resource must be established which provides complete information on product exports and imports, as well as relevant information on product toxicity. A wide variety of data is available on-line, including product data sheets, regulatory decisions, and other information. However, finding this information can involve extensive and confusing searches. Detailed data on international trade is not available.

• In 1969, the US Congress committed America's government to the establishment of policies, regulations and laws which "prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man." Current pesticide export policy is alarmingly divergent from this goal. Nothing would be a more appropriate way to celebrate the 30-year anniversary of the National Environmental Protection Act than to bring US pesticide export policies into alignment with this very prescient policy statement.

References
1.  Export of unregistered pesticides is not adequately monitored by EPA, Washington, DC: GAO/RCED-89-128, 1989.
2. Exporting banned and hazardous pesticides: a preliminary review, FASE Reports 9(1), 1991.
3. The raw data used is not available from the Department of Commerce. FASE obtains export records from the Port Import Export Reporting Service (PIERS) of the Journal of Commerce, which makes daily transcriptions of the shipping manifests submitted at US ports.
4. The percentage of pesticides that could be identified increased from 24% in 1995 to 36% in 1996. All statistics in this report are based on the products that could be identified.
5. The registration status of some of the products considered in this survey has changed since 1992. The fact that in 1992 EPA had not yet recognized the risks associated with certain products does not mean that the risks did not exist. As the main objective of this report is to evaluate the trade in hazardous pesticides, products are categorized according to their current registration status.
6. An analysis of the responses to the second international questionnaire on the international code of conduct on the distribution and use of pesticides, Food and Agriculture Organisation, UN, Rome, 1996.
7. Hearing on the circle of poison: impact on American consumers, Committee on Agriculture, Nutrition and Forestry, 20 September  1991.
8. Reinventing EPA's pesticide export notification program, US EPA, 20 September 1995.
9. Banned and severely restricted pesticides, US EPA, Washington, DC, 1997.
10. International Program on Chemical Safety (IPCS): The WHO recommended classification of pesticides by hazard and guidelines to classification 1996-1997. (The final classification of the toxicity of a pesticide depends upon its formulation.)
11. The annual totals for the years 1991-1994 have changed from earlier estimates, as new pesticides have been added to the list of suspect chemicals.
12. Ibid.
13. GAO, op cit.
*  1 pound = 0.45 kg; 1 ton = 1,016 kg (1.016 tonne)

Carl Smith is Project Director of FASE, Park Mile Plaza, Suite 215, Wilshire Bld, Los Angeles, 90010, US, Fax +1 213 937 7440, cesmth@aol.com     

[This article first appeared in Pesticides News No. 40, June 1998, pages 4-5]