Strategies for improving risk assessment in developing countries 

Pesticide risks are high in many developing countries, because farmers and farmworkers using the products are working in unsafe conditions. Pesticide regulators have limited resources to assess risks and promote the least hazardous pest control strategies. Barbara Dinham discusses proposed regulatory changes in Europe, and how developing countries could benefit from better sharing of information and responsibilities. 

One of the very few pineapple farmers in Benin to use any form of protection against inhalation when using pesticides. Photo: OBEPAB

Many European stakeholders, including environment and consumer organisations, supermarkets and food companies, want to see changes that would contribute to reducing the risks of pesticide exposure. They are proposing changes in the way pesticides are regulated in order that, where a broad choice is available, regulators channel the least hazardous products onto the market. 
    A PAN UK conference in London in November 2002, brought together a wide range of stakeholders to discuss changing pesticide regulation in order to phase out the most hazardous pesticides and phase in safer alternatives where these are effective and available (see PN58 and 59). The proposed regulatory tool would introduce a process of ‘comparative risk assessment’ (CRA). Already in use in Norway, Denmark and Sweden, the European Commission has now accepted the principle of CRA, and is discussing the criteria and timetable for its introduction. 

Possibilities and constraints
The objective of CRA is to identify, within a group of products, the least hazardous for health and the environment taking into account national conditions of use and crop protection needs. CRA encourages precautionary approaches to pest management in agriculture. Comparative risk assessment can be defined as the regulatory process that considers and ranks the risks of different active ingredients or products within a group of similar products. 
    There are differing views about whether CRA should lead to registration of only the least hazardous products and that these would then be substituted for more hazardous products. Alternatively, CRA could be an advisory tool for farmers and growers. Ideally, a CRA system would identify products that present significantly less risk to health or the environment and that would be equally effective in controlling the target pest or organism. This more radical approach is based on the ‘substitution principle’ which can be defined as the use of comparative assessment to phase out of the market the most hazardous substances and products, and favour registration of the least hazardous product.
    In adopting CRA with the substitution principle, governments would need to develop a process that would continue to encourage registration of less hazardous products and to review all registrations on a regular, preferably five-year, basis. A separate registration track for alternatives such as biological controls could be included. At present, pest control product registration systems in the EU and Member States put serious obstacles in the path of approving biological products (see PN59 pp10-11).
Figure 1 shows how the Swedish regulatory body, KEMI, approaches CRA and substitution in their regulatory system. They have found that the system is uncomplicated, and allows swift decision-making without a loss of quality or predictability. 

Figure 1. Using a Comparative Risk Assessment (CRA) approach to move to registration of least hazardous pest control products

A and B – Withdrawals or phase outs based on establishing unacceptable hazard criteria: persistence in soil and surface water, bioaccumulative, extremely toxic, carcinogenic, endocrine disrupting, reproductive or other chronic effects C – Maintain acceptable products, particularly where no viable alternatives are available D – Policies encourage registration of least hazardous products, including non-chemical controls Source: Adapted from presentation to the Pesticide Challenge conference, London, November 2002 (Peter Bergkvist, KEMI, Sweden).

Issues for developing countries
In many developing countries agriculture is the basis of the economy and a high percentage of the population is dependent on it for their livelihoods. Pesticides are applied by small-scale farmers with limited resources, or by agricultural workers with little protection. The health and environmental problems that result are a concern for governments. Regulators are expected to evaluate and control the large range of pesticides and products on the market, to ensure product efficacy and to ensure recommended use will not result in residues that jeopardise future export markets. Regulators must also consider the risks to agricultural workers, farmers, and consumers in developing countries where very limited resources (human and infrastructural) are available. 
    The agricultural export sector plays a vital role in bringing foreign exchange into many developing countries. Traditional agricultural exports included field and estate crops, such as tea, coffee, cocoa, sugar, cotton or soya beans. But increasingly, as a result of economic and trade liberalisation, exports of fresh fruit, vegetables and flowers are promoted to supply rich markets with exotic produce, luxuries, or year-round supplies of favoured foods. The production of export crops has almost entirely focused on high external inputs of inorganic fertiliser and chemical pest control and the same approach is increasingly common in production for national markets.
    New European pesticide regulations require a Maximum Residue Level (MRL) of effectively zero on imported fruit and vegetables for active ingredients that are not registered for use in the EU. The 56 African, Caribbean and Pacific (ACP) countries exported fresh horticultural products worth over Euro 1 billion to the European Union in 1999. In July 2003, an additional 320 pesticides will be ‘deregistered’ in the European Union, but developing countries may still be using many of these products, and their export industries may suffer as a result. Small-scale farmers are likely to be the hardest hit, as agribusiness food producers operating in developing countries will institute their own controls, and in doing so may displace the small growers. 
    Structural adjustment and trade liberalisation policies have been encouraging small-scale farmers to take advantage of fresh produce ‘export opportunities’. But the farmers may now be deprived of markets unless they can rapidly meet the new standards. Recognising this, the European Commission has financed a Pesticide Initiative Programme (PIP) for ACP countries, which is operated by the Europe-Africa-Caribbean-Pacific Liaison Committee (COLEACP), an association of exporters, importers and other stakeholders in the EU-ACP horticultural trade. PIP is raising awareness of the changes, and to some extent helping ACP fruit and vegetable producers and exporters adapt to the new import requirements. However its activities will include defending the registrations of threatened pesticides, rather than focus on safer alternatives. 

CRA, substitution and developing countries
Developing countries could benefit greatly by introducing CRA and substitution. Regulators are faced with requests for registration of products without reference to other products already available in their country or elsewhere for the same purpose. Moreover registered active ingredients and formulations are often not subject to a regular review and reassessment process that would ensure the least hazardous products were on the market. Resource-constrained developing countries could more easily introduce CRA if governments developed regional collaborative mechanisms such as the common registration systems adopted in West Africa by the nine CILSS countries (Comité Inter-Etats de Lutte contra la Sécheresse au Sahel includes Burkina Faso, Cap Verde, Chad, Gambia, Guinea Bissau, Mali, Mauritania, Niger, Senegal). Regional coordination brings together a wider pool of expertise. 
    Another strategy would be to use regulatory decisions made in countries with greater regulatory capacity or to draw on standardised data assessed against national conditions. 

Progress in reducing pesticide dependence
Developing countries have made considerably more progress than industrialised countries in reducing pesticide dependence on certain crops through Integrated Pest Management (IPM). This is particularly apparent where Farmer Field Schools (FFS) have trained farmers, increased available knowledge on pests and predators, improved the farmers’ ability to assess levels of economic damage from pest attack, and improved confidence to select from a range of appropriate pest management options. In Zimbabwe, for example, the adoption of IPPM (Integrated Production and Pest Management) in cotton and vegetables is proving cost-effective among trained farmers as well as environmentally friendly and sustainable. Much closer liaison between FFS/IPM developments and pesticide registration could assist in identifying pest management priorities. 

Risks and alternatives in vegetable production
For the London conference, four countries (Tanzania, Zimbabwe, Senegal and Vietnam) considered how their registration systems recommended and controlled vegetable pesticides. Zimbabwe and Senegal have large export horticulture sectors; Tanzania is just entering the export market. In Vietnam vegetable production is largely for the national market. 
    In Senegal, the horticultural sector has been expanding rapidly since the early 1990s with 15,000 tonnes exported in 2001 compared with 5,000 tonnes in 1997. The main exports are green beans to EU markets. Small and large producers are involved but the big producers have the major share of export market. In Tanzania exports of horticulture crops, spices and flowers are increasing. While most vegetable production is for local consumption, some estates export to the UK and the Netherlands. Chemical pesticides and fertilizers are widely used in both sectors. In Zimbabwe vegetable production is categorized into two distinct sectors, large-scale commercial and small-scale: the former dominates both export and local urban markets. The latter mainly caters for local markets, though some producers have begun to export. 
    In Vietnam, vegetable production is increasing significantly mainly for the national market, with only 1.3% going for export. The average farm size is small. Farmers are untrained in pesticide use, and spray a mixture of different products many of which are acutely toxic. Governments are well aware of the problems of untrained, ill-equipped farmers using acutely toxic products, although the chronic health and environmental risks are more difficult to assess. 

Phasing out the most acutely toxic pesticides
Regulators in Tanzania, Zimbabwe and Vietnam indicated that it would be technically possible to phase out registrations of the most hazardous products, those in World Health Organisation Classes I and II (Extremely, Highly and Moderately Hazardous). Tanzania has deregistered or banned a number of pesticides considered dangerous for health or the environment, including aldicarb, methyl parathion and ethyl parathion. Government policy is to reduce the use of hazardous pesticides and adopt pest control alternatives. The Registrar of Pesticides in Tanzania encourages registration of less hazardous pesticides and withholds permits to import products if less toxic alternatives are registered. Zimbabwe has phased out some highly toxic products, and identified others for phase out (parathion, captafol and methyl bromide). Its policy is to reduce high-risk products through registration systems that favour the less hazardous products. The Vietnam government has deregistered or banned a number of the more hazardous pesticides, including parathion methyl, monocrotophos and methamidophos, and regards prohibition of Class I for vegetable production as feasible. The policy is to prevent registration of pesticide formulations in class Ia or Ib. Acutely toxic pesticides are often favoured by farmers as they kill pests, are cheap, and are generally less persistent. 

Availability of non-chemical pest control products
The Ministry of Agriculture and Food Security in Tanzania supports an IPM programme, and advocates the use of botanicals and cultural control methods. Some non-chemical alternatives have been registered (pyrethrum plant extract, parasitoids). Trials are taking place on biopesticides for vegetable pests. Informally, farmers use neem, pepper, onion, tobacco and other plant extracts to control pests. 
    In Zimbabwe the only registered biopesticide for use on vegetables is Bacillus thuringiensis (Bt). Small-scale farmers make use of their knowledge of local plants to control pests, but research is needed to establish the effective rates of application. The government introduced IPPM, and has mainstreamed the FFS methodology to some extent by locating the programme inside the body responsible for pesticide registration. FFS-trained farmers have demonstrated their ability to select from the range of pest management options. Ideally IPPM should inform 
registration. 
    Development and use of biopesticides, particularly Bt, has been encouraged in Vietnam. The government has a significant IPM training programme on vegetables, with 22,000 farmers trained between 1997-2000 in 802 FFS. The training has reduced pesticide use by 40-50%, and increased the profit to farmers. The country has designated ‘safe vegetable production areas’ in a number of the larger cities, and residue levels in these areas are regulated.

Recommendations and conclusions 
Participants from the countries discussed above met at a recent workshop on CRA in developing countries in London and recommended that pilot projects be carried out in three or four countries in order to promote CRA and substitution. The projects would:

• review the list of vegetable pesticides and follow the CRA methodology in order to remove the most hazardous products from the market
• use the CRA methodology to establish the feasibility of withdrawing all WHO Class I products
• investigate barriers to registering biological controls and other suitable less hazardous alternatives
• establish a rigorous information exchange with one or more OECD countries on chemical control agents in order to offer a wider range of alternatives

Comparative risk assessment and substitution of least hazardous pest control strategies offers a positive model for developing countries. The FAO periodically revises guidance documents on pesticide registration and could include advice on implementing comparative risk assessment and substitution of more hazardous formulations with less toxic pest control, including non-chemical alternatives. The resource limitations on developing countries could be mitigated to some extent by common pesticide registration systems within regions and use of internationally available data. OECD countries, particularly those promoting and adopting CRA strategies, urgently need to consider ways of improving access for developing countries to their information and data, and improved assistance in implementing safer pest management strategies.

[This article first appeared in Pesticides News No. 60, June 2003, pages 20-22]