African regulators starved of resources

It is often not recognised that pesticide regulation in developed countries has a massive impact on export countries in the South. Jonathan Ak’habuhaya gives this vivid example from Tanzania.

Registration process
Pesticides Registration in most African countries has been developed in line with the Food and Agriculture Organization of the United Nations (FAO) recommended Guidelines. FAO played a direct role in the development of pesticides legislation in many African countries. Although the FAO Guidelines mention five registration schemes, the most commonly advocated and adopted is the so called ‘Preventive Scheme’. Under this scheme, it is forbidden to manufacture, formulate, import, sell, use, dispose, or deal with any pesticide business unless explicitly allowed. The scheme elaborates requirements for pesticides registration, importation, labelling, packaging and transportation. 
    Being so elaborate, the preventive registration scheme is prohibitively expensive for most developing countries. It requires heavy investments in terms of infrastructure, equipment, personnel and operational costs. Efficient communication and collaboration between the regulatory authorities and other institutions such as the Tanzanian central bank, customs and postal services, are also required.

Data assessment
On applying to register a pesticide, the registrant brings dossiers to the Registrar of Pesticides which contain comprehensive and complex scientific data on the product, its properties, its environmental and toxicological properties. Assessment and interpretation of this data requires special expertise of well trained toxicologists, chemists and environmentalists. These are usually not readily available in Tanzania.

Sample and residue analysis
Samples of active ingredients for registration, and pesticide consignments for use in the country, have to be analysed. This is usually not done satisfactorily because of the shortage of trained analysts and modern equipment. So, at most, it is the active ingredient which is determined, leaving out the so called ‘inerts’. These inerts may, in some cases, be of significant toxicological importance. Analysis for crop residues and metabolites is hardly done satisfactorily because of the same reasons.

Registration and selection 
Before registration pesticides are tested for efficacy under the Tanzanian local conditions. If found suitable and approved by various technical Committees, they are then registered. De-registration follows the same process. Their choice would be guided by price, and, to some extent, product performance. Health and environmental considerations are hardly addressed.

Changes in EU residue limits 
If and when the EU Regulation on Residues is passed, there will be no pesticides left on the market in Tanzania approved for use on vegetables for export. The country has neither developed nor registered plausible biopesticides or natural pesticides which do not leave residues on the crop. Consequently, the vegetable export industry will be crippled. Secondly, in a frantic effort to put the situation under control, the government may have to allow importation and use of locally untested/unapproved biopesticides and natural products. The result of this is that Tanzania would be forced to adopt the so called ‘Vertical Registration’, which allows farmers and investors to dictate which products will be used on their crop so as to meet the EU Regulations. The function of the local Regulatory Authorities would be reduced to allowing importation of products approved in the developed countries.

Comparative risk assessment 
The Comparative Risk Assessment approach would supplement and possibly accelerate the current efforts by the Tanzanian Pesticides Regulatory Authority of phasing out the ‘higher risk’ products by ‘lower risk’ ones. The phasing out by replacement is also likely to stimulate the registration of ‘lower risk’ products, particularly biopesticides and natural products. The system, however, must be well studied, and the regulatory authority and decision makers in the technical committees receive thorough training on how it works. Lastly, the system must be formally introduced into the current Tanzania pesticides legislation and regulatory system.

Edited presentation to the Pesticide Challenge conference, November 2003, J. Ak’habuhaya, Registrar of Pesticides, Tropical Pesticides Research Institute, Arusha, Tanzania, akhabuhaya@yahoo.co.uk, www.habari.co.tz/node/arusha.htm

[This article first appeared in Pesticides News No. 58, December 2002, page 15]