Dear Editor,
The Pesticide and Toxic Chemicals Control Board takes this opportunity to respond to Mr LH Semple’s letter published on July 31 in the Stabroek News under the caption ‘Pesticides Board needs well equipped unit to tackle “backtrack” chemicals.’ This letter serves to clarify the misconceptions stated by Mr Semple about the Board’s mandate and functionality in addressing the issue of ‘backtrack’ chemicals in Guyana.
The Pesticides and Toxic Chemicals Control Board was established under the Pesticides and Toxic Chemicals Act 2004 (No. 13 of 2004) and its associated Regulations to protect the rights of the pesticides stakeholders, farmers and all end users of pesticides from unscrupulous operations. The drive by the Ministry of Agriculture to expand our agriculture production which makes provisions for the export of our local agricultural produce is foremost in our operations. Importing countries have established clear and concise requirements that our fresh produce must satisfy in order to access their markets, hence the need to protect the farmers from using unregistered products so as to ensure access to international markets.
Mr Semple stated that there is lack of a “well equipped unit” to adequately address the issue of backtrack chemicals. On the contrary, the Pesticides and Toxic Chemicals Control Board through its Registration, Licensing, Inspection and Enforcement Units is well equipped to adequately address all issues of pesticides importation and management. The board has recently conducted a number of enforcement exercises across the country which resulted in the seizures of large quantities of unregistered pesticides. The board is working with the Guyana Revenue Authority (GRA) and the Berbice Anti Smuggling Squad (BASS) to reduce the incidence of smuggled chemicals to farmers in Guyana. The board is committed to this process and will be intensifying these operations so as to deal with the illegal trans-boundary movement of pesticides. The board takes this opportunity as well to invite Mr Semple and other farmers, input suppliers and citizens to inform the board of persons supplying bogus pesticides and knowingly confusing farmers with these chemicals. Information provided to us of any such operations will be used to enhance and strengthen our service to the public.
Additionally, there have been a number of other activities executed by the board so as to manage pesticides and toxic chemicals in Guyana. The board in its public awareness activities which commenced in 2002 and intensified in February, 2010 has to date trained 1709 farmers in 2010, farm workers, students, customs officers, vendors and other stakeholders in the pesticides industry in various regions in Guyana. One of the key aspects of these training exercises is to educate farmers, farm workers and the general public on the proper use and management of registered pesticides and to recognize and abstain from the use of unregistered/illegal pesticides. What we would suggest to Mr Semple is that he invites the board to conduct one such training activity with the group that he purports to represent and be educated further in the current operations of the board.
Mr Semple also states that “backtrack chemicals account for 53% of the market share in Agro-chemicals sales.” The board is quite interested in seeing the results of the survey carried out by Mr Semple that provided this data. A comparison of import data for the current year in relation to previous years revealed that there has been a 29% increase in the importation of registered pesticide products. The question is if backtrack chemicals are flooding the market as Mr Semple states, where are they? We will be grateful for this information to act immediately.
Mr Semple identifies the Regulations and their requirements as “needless and harsh.” The Pesticides and Toxic Chemicals Regulations are the legal framework that allows for the proper management of pesticides throughout their life cycle in Guyana, with the main goal being to protect human health and the environment. We wish to reiterate that pesticides are poisons.
Many countries lacking the legal framework to manage pesticides experience severe difficulties in controlling import, sale, use and disposal of these hazardous products. The Regulations were developed after a national consultation with farmers, input suppliers, manufacturers, importers, pest control operators, farming groups, unions and the general public. The development has taken into consideration all the inputs from the aforementioned groups and no objection has ever been made, but lately, some companies who want to capitalize on our agriculture development without any concerns for our environment and farmers’ safety and our much needed agriculture trade are saying the same words as those of Mr Semple, “needless, harsh, bureaucratic, unnecessary.” In the interest of our agriculture development, we beg to differ.
Mr Semple states that the data requirements of the regulations are “unnecessary” since most of these products are “well established.” Does that mean that because a product is registered in another country it must be allowed to be imported in Guyana? For the purposes of Mr Semple, products are provided more cheaply by bottom house operations in other countries by changing the inert ingredient of some of these “well established” products, whereby the inert ingredients are now more dangerous than the active ingredients, which should never be the case. Our current requirements allow us to protect against these operations.
The board’s relationship with many countries in the Caribbean region have found that many are lacking the legal tools to register pesticides products; in some cases all that is required is a label and/or material safety data sheets (MSDS). In fact, at the recently concluded meeting of the Coordinating Group of Pesticides Control Boards for the Caribbean and Latin American Region held in Suriname it was agreed that countries lacking the legal framework for the importation and management of pesticides and toxic chemicals are currently moving to adopt Guyana’s legislative framework. Why?
There is a need for proper registration procedures which allow countries to make informed decisions on pesticide products for agricultural production.
We cannot over-emphasize that these products are poisons and very hazardous in nature, to human health and the environment and as such must be managed accordingly.
The board also works closely with the pesticide stakeholders in Guyana, all of whom have adequately met the regulations requirement for the importation of pesticides. These “legitimate” stakeholders have been abiding by the law as set out in the pesticides Act and Regulations. The board at present has received a 33% increase in registration submission by these very stakeholders for 2010, in comparison to 2009, 92% which have satisfied the registration requirements.
Mr Semple states that the Board is bureaucratic and unreasonable. Are we?
After reading the above points, you be the judge; we are simply upholding the laws that govern pesticides and toxic chemicals management in Guyana.
The Board wishes to emphatically state that its current structure is well equipped and knowledgeable to execute its mandate, and will continue to do so assiduously. We wish also to take this opportunity to invite Mr Semple to visit our office at NARI, Compound Mon Repos for any further clarifications he may require.
Yours faithfully,
Trecia David
Secretary
Pesticides and Toxic
Chemicals Control Board
