Technical committees — non-technical decisions

Agriculture is the backbone of Pakistan’s economy. About 68 percent of the population is engaged in farming directly or indirectly through production, processing, and distribution of major agricultural commodities.

Here in Pakistan, the pesticide business is regulated by the Agricultural Pesticide Technical Advisory Committee (APTAC) under the chairmanship of Federal Secretary of National Food Security & Research. The Sub-Committee of Agricultural Pesticide Technical Advisory Committee (Sub-APTAC) is chaired by the Adviser & Director General (A&DG), Department of Plant Protection (DPP). The federal Department of Plant Protection, Karachi, working under the Ministry of National Food Security & Research, provides the basic working to Sub-APTAC and APTAC for decision making on pesticides registration, deregistration, import and other matters like quarantine, etc.

The Sub-APTA Committee and APTA Committee members are the technical professionals from all the four provincial agricultural institutes, federal agricultural research institutes, universities and from the pesticide industry. This is the highest technical forum of Pakistan at federal level which regulates the pesticide business in Pakistan to have the better plant protection and good agricultural produce in the country. It is a point of concern that there is no regular Adviser and Director General of the Federal Department of Plant Protection for the last 13 years, which is not less than a big surprise.

Looking into all this, it will not be difficult for us to assess how the Sub-APTAC and APTAC have made the wrong technical decisions and some examples of these decisions are given below:

1. Requirement of the 100 percent breakup of technical grade material. When a technical grade material is described, the purity of the technical grade material is taken as minimum while the impurities are taken as maximum to have the complete assessment of the impurities and their toxic effect and in such situation, the total comes out as > 100 percent but the DPP asks for 100 percent and it has been covered under the APO (Asian Productivity Organization). The industry wants to provide the maximum information to the regulator, but the regulator is stuck at 100 percent only, which is quite surprising.

2. Analysis of recipe to confirm the product quality. This is the second wrong decision by the SUB-APTAC and APTAC. The recipe of a product is based on technical-grade material dissolved in a solvent, having emulsifier and stabilizer to make a stable formulation. The formulation chemist understands the solvent he is using and the emulsifier and stabilizers. To confirm the formulation quality, he evaluates the formulation reference to its physical parameters. A pesticide recipe is in fact a statement developed by a chemist. For quality determination of a formulation, only the analysis of the active ingredient and the physical parameters, not the 100 percent recipe of a product, are evaluated.

TGM + Solvent [OK + Emulsifier’s + stabilizers] [OK + storage stability + Emulsion stability, Active ingredient stable] [Recipe OK}

1. Storage stability of a formulation. Studying the storage stability of a product is the prime responsibility of the manufacturer, not the regulator’s. Storage stability varies from chemistry to chemistry, formulation to formulation and even based on the recipe. As per the FAO (Food and Agriculture Organization) of the United Nations, one formulation should have minimum 2 years storage stability, but the two years is not the final figure from FAO. The regulator should ask the manufacturer for storage stability study report to confirm the claim of the manufacturer on storage stability rather than fixing two years’ storage stability for each pesticide formulation, which is totally a wrong decision. If the industry follows two-year storage stability formula, then about 15 to 20% product will be the expired product every year. A huge quantity should go every year for incineration. It is, therefore, important to calculate the total loss to the industry in terms of expired product and incineration cost and a big loss to the environment. This will be unbelievable. Due to this very reason, industry does not show expired product to the regulator and the regulator does not provide any space to the industry on this issue.

2. Expiry of the technical grade material. Here in Pakistan, the regulator demands the two-year expiry of the technical grade material as well, which is wrong. The shipment/import documents for the formulated product and of the technical grade material are the same where the manufacturer must indicate the expiry of the material and he is bound to show the expiry of the technical grade material. Without the indication of the expiry of technical grade material, the regulator will not process the case of shipment for customs clearance, so he is bound to show the two-year expiry of the technical grade material. If he shows the expiry more than 2 years, then his case will not be processed. Just see the level of technical incompetence’s at the regulator’s level.

3. There is another issue of Pre-Shipment Inspection

   (PSI) for each batch produced (Technical/Formulated product) in the country of origin. This is a unique requirement in the world and being in practice for more than 12 years in Pakistan. The issue is now pending for almost 5 years now although it was unanimously agreed by all the members at the 52nd APTAC to abolish the PSI system in the country and establish local labs as it amounts to loss of valuable foreign exchange and more importantly, it challenges country’s integrity. While the PSI system is in place to ensure quality and source of the manufacturing, it is surprising that at the same time DPP undertakes further random sampling and rechecks product samples having no proper lab functional at the department. Due to the Covid-19 situation, companies are facing further delays in product imports, resulting in expected product shortage in the country for strategic crops like cotton, wheat, rice, corn and vegetables.

Every year, the pesticide industry pays millions of dollars in terms of laboratory analysis of every shipment to the foreign laboratories, but we could not establish a single laboratory in Pakistan to carry out the quality analyses of the pesticides on arrival of pesticide shipments. This issue has been discussed at length in many meetings but no decision has been finalized yet. If the industry pays half of the amount paid to foreign labs to a laboratory in Pakistan, more than one quality lab can be established in Pakistan within a period of 2 years. The question is why it has not been decided yet and still pesticide importers are paying thousands of dollars to foreign labs. This clearly reflects the interest of some key decision-makers and four to five PSI companies working for the government.

1. There is no regular Adviser & Director General (A&DG) of the DPP, Karachi, for the last 13 years. The A&DG is appointed for a period of just one to three months from among the four Directors Technical working with DPP with limited powers.

Technically, we have become weak because we take wrong decisions on technical matters. Some criteria should be decided for the participants—both from regulator’s and industry’s sides — who attend the SUB-APTAC and APTAC to make decisions. The regulator is required to build up the capacity of its working staff to effectively deal with technical matters. The regulator needs to be transparent.

(The views expressed in this article are not necessarily those of the newspaper)

Copyright Business Recorder, 2021