Untested and Unapproved pesticides mandatory for seed treatment

190519 FAW outbreak
In a shocking incident the Seeds Division, Ministry of Agriculture, Government of India has issued a directive signed by Mr. Dilip Kr. Srivatsava, Asst. Comm (QC), making compulsory seed treatment with cyantraniliprole and thiomethoxam , we are shocked to see that such a direction is given in spite the formulation not registered in India and also not been evaluated in AICRP program and purely based on the feed back from seed growers feed back that the seed treatment giving protection for 2-3 weeks after germination. This is violation of Insecticide Act

we are amazed that the chemical seed treatment of an un-evaluated and un-registered formulation has been given more prominence in your advisory than all the collective wisdom and established field experience of farmers, organizations and state governments on Non Pesticidal Management, Natural Farming and Organic Farming.  monitoring and scouting measures to be taken up other than cultural, mechanical and bio-control measures being recommended. Furthermore, it has been made compulsory and we are keen on understanding the scientific basis for the same.
Biosafety issues with the chemicals recommended
Even if we assume that the emergency situation, it is illegal to make it compulsory to use chemicals which are not tested and registered in India.  As per the Central Insecticides Act, 1968[1] the Central Insecticide Board and Registration Committee (CIBRC) under the Directorate of Plant Protection, Quarantine & Storage, Department of Agriculture & Cooperation is supposed to register each pesticide in the country after scrutinizing their formulae and claims made by the applicant as regards its efficacy and safety to human beings and animals. The Registration Committee is also expected to specify the precautions to be taken against poisoning through the use or handling of insecticides.  The recommendations made has not taken into account the international published information which show the following serious concerns with cyantraniliprole and Thiamethoxam.
Cyantraniliprole
Cyantraniliprole is a systemic insecticide belonging to the diamide class of pesticides. Cyantraniliprole works by binding with insect ryanodine receptors, which leads to unregulated activation of ryanodine receptor. Insects exposed to cyantraniliprole “first exhibit lethargy, followed by muscle paralysis, and then death.” says the CYANTRANILIPROLE RISK ASSESSMENT by US Environmental Protection Agency[2]. It further states that
As a systemic insecticide, translocation of cyantraniliprole through the xylem and phloem results in expression of the chemical throughout exposed plants, resulting in multiple routes of exposure for various non-target organisms, including mammals, fish, invertebrates and plants.
Cyantraniliprole biodegradation proceeds more slowly in aerobic conditions than anaerobic conditions, suggesting that it could be fairly persistent in the agricultural environment and adjacent ecosystems.
Degradation times in soils and sediments reached 89 and 25 days, respectively, showing an extended period of activity after application. When the total toxic residues were calculated (including degradates), a range from 88 to 1327 days was identified. Cyantraniliprole is also characterized as moderately mobile, meaning that it can move off-site and affect nearby terrestrial and aquatic ecosystems. Some of the degradates of cyantraniliprole are more persistent and mobile than the parent compound, a concern for ecological effects as some may be more toxic than the parent and may accumulate over time.
Thiamethoxam
Thiamethoxam is a second-generation neonicotinoid compound that belongs to the chemical subclass thianicotinyls and acts on target pests by interfering with the nicotinic acetylcholine receptor[3].  It is known to impair honeybee flight ability[4]. There are also evidences and published data which shows that TMX. as it is called, may also pose reproductive risks on mammalian reproductive health[5]. The American Bird Conservancy (ABC) report, The Impact of the Nation’s Most Widely Used Insecticides on Birds[6], concluded that it would take only six corn seeds coated with thiamethoxam to achieve a 50 percent chance of lethality (LD50) given sensitivity at the 5% tail of bird distribution, assuming an avian body weight of 50 g – somewhere between a large sparrow and a blue jay. Like-wise only 0.3 (roughly a third) of a treated seed would be enough to impair reproduction.
Adverse Impacts of Cyantraniliprole Products Co-Formulated with Thiamethoxam
While independently both the chemicals have their own biosafety problems, the co-formulated products may have much more severe impacts.  EPA conducted a specific risk assessment of this mixture and concluded that “the typical end-use products with thiamethoxam are also modeled because they presented more sensitive toxicity values than their technical-grade counterparts.”  In other words, this mixture of these two pesticides is more dangerous than the pure, technical grade active ingredient in isolation. EPA’s own initial analysis determined that “cyantraniliprole-thiamethoxam mixture would require buffer in excess of 1000 ft for all uses.”[7]
As the Fall Army Worm is a polyphagous pest, the order amounts to making the seed treatment with cyantraniliprole-thiamethoxam mixture for almost every crop mandatory, which can be an ecological disaster.
Hence, we request the Plant Protection Division, Directorate of Plant Protection Quarantine & Storage to retract this decision by the seeds division as it a violation of law a potentially dangerous chemicals are introduced without any basic research and registration.  This will set a serious bad precedence to violate the law.

Moving towards Agroecological Approaches
It is clear that the incidence of and losses due to FAW are largely due to increasing monoculture of maize and excessive use of chemical pesticides which is leading to disturbance of the ecological balance.
The major pest outbreaks in the last three years, if we consider, are Pink Boll Worm in Cotton across the country, Brown Plant Hopper in Odisha, parts of Andhra Pradesh, Fall Army Worm across the country.  All these outbreaks are in the areas of high monoculture of these crops and high use of chemical pesticides.  Whereas, the areas under agroecological approaches like Non Pestidical Management (NPM), Organic and Natural Farming, Zero Budget Natural Farming (ZBNF) have not shown any high incidence of the pest. Therefore, the solution lies in moving towards agroecological approaches which can restore back the ecological balance rather than doing more of the same with monocultures.  The experiences across the world proved the same.
The Non Pesticidal Management experience in Andhra Pradesh (united) between 2004 to 2010[8] showed that if farmers can be trained well on understanding their agroecosystem and trained on effective use of local resources, pests can be managed with a combination of scouting, preventative care, use of locally available botanicals and animal waste and without out using chemical pesticides.  While number of studies on these experience shows that the chemical pesticide use is reduced, neither major pest out breaks nor yield reductions were recorded.  In villages where Centre for Sustainable Agriculture (http://www.csa-india.org) Maize is grown and could be managed with minimalistic damage. The emphasis on deep summer ploughing, pheromone traps, prophylactic sprays of 5% NSKE, inter-cropping and using of trap crops, erection of bird perches, effective weed control, release of Trichogramma for bio-control, spraying of Bt powder formulations, application of dry sand into affected whorls etc. are all to be taken up with equal emphasis, that too on community-based, and area-wide approach for proper management.
The Zero Budget Natural Farming[9] model in Andhra Pradesh where large no of farmers also cultivates maize, the crop could be managed with the ZBNF + practices.  FAO was also involved in training farmers on agroecological approaches through Farmer Field Schools.
Similarly, the organic farmers across the country who grow maize as intercrop/mixed crop with organic farming practices have not reported any serious damage with Fall Army Worm as it happened in the monoculture maize crop under high input intensive cultivation.
Several studies from Africa observed that FAW damage was found to be lower for maize crops established through zero-tillage compared to maize crops established through conventional tillage[10], The lower FAW damage was also found when manure or compost were applied.  Similarly, the push-pull system, a stimulo-deterrent cropping strategy consisting of intercropping cereals with herbaceous legumes and surrounded by fodder grasses, is presented as a promising crop diversification strategy contribute to maize stemborer suppression, while improving soil fertility and providing feed for livestock[11].
Similarly, National Institute for Plant Health Management (NIPHM) has come out with what they call as ecological engineering[12] based on the Integrated Pest Management (IPM) model.
All these experiences show that a scientific approach to manage any pest including the Fall Army Worm is shifting towards agroecological approaches and not blindly recommend couple of toxic chemicals which may provide protection only for the initial 2-3 weeks of the crop.  The experience with a similar chemical Imidacloprid is still in front us, the bee collapse it has caused due to indiscriminate use.
It is this lack of balanced emphasis on cultural, mechanical and biological control measures with an over-emphasis on chemical approaches that has led to the current crisis, which then becomes the basis for further unscientific and unsafe technologies to be ushered in, like transgenics.
It is clear that timely, coordinated management practices will certainly help in checking the spread of FAW, and that the current urgency should not be used for promoting any untested, unproven and potentially hazardous solutions.
We urge the Ministry of Agriculture & Farmers Welfare to kindly refrain from promoting any unreasoned and unscientific recommendations – Thiamethoxam, for instance, has been banned on field crops in the European Union, given its adverse impacts on bees. The chemical is being considered for phasing out in Canada, where it is used as a seed treatment chemical (including on corn) after a review of impacts on aquatic insect species.
Thank you
(G V Ramanjaneyulu)
Executive Director
[1] http://krishi.bih.nic.in/Acts-Rules/Insecticides_Act_1968.pdf
[2] https://www.regulations.gov/document?D=EPA-HQ-OPP-2011-0668-0008 CYANTRANILIPROLE RISK ASSESSMENT
http://publications.gc.ca/collections/collection_2013/sc-hc/H113-9-2013-9-eng.pdf https://www.biologicaldiversity.org/campaigns/pesticides_reduction/pdfs/Notice_of_Intent_re_Cyantraniliprole_3.21.2014.pdf
https://www.biologicaldiversity.org/campaigns/pesticides_reduction/pdfs/CTP_Complaint.pdf
https://www.centerforfoodsafety.org/files/cfs_abc–joint-cyantraniliprole-registration-comments–final_16053.pdf
[3] https://www.regulations.gov/docket?D=EPA-HQ-OPP-2011-0581
[4] https://www.nature.com/articles/s41598-017-01361-8.pdf
[5] https://www.ejmanager.com/mnstemps/31/31-1486156117.pdf?t=1558237961
[6] http://abcbirds.org/wp-content/uploads/2015/05/Neonic_FINAL.pdf
[7] CYANTRANILIPROLE RISK ASSESSMENT
[8] http://csa-india.org/what-we-do/npm/
[9] http://www.apzbnf.in
[10] https://www.sciencedirect.com/science/article/pii/S0261219419300304
[11] https://www.sciencedirect.com/science/article/pii/S0261219417303216
https://www.sciencedirect.com/science/article/pii/S0167880918303931
[12] https://niphm.gov.in/IPMPackages/Maize.pdf