ENDOSULFAN CONSPIRACY

It was a veiled threat that Padma S Vankar was least expecting. As advisor to CSE’s pollution monitoring laboratory, she had supervised the testing of samples collected from Padre. Vankar is also in charge of the Facility for Ecological and Analytical Testing at the Indian Institute of Technology (IIT), Kanpur. The threat came in the form of an unexpected visitor at IIT in September 2001. Meet M Raghavender. Raghavender is with EMFA (Endosulfan Manufacturers and Formulators Association). He had come to IIT with a clear agenda: to ask IIT to distance itself from CSE’s study and to make Vankar admit that her findings were flawed. In short to undermine the credibility of the study. “He ‘advised’ me to keep away from controversies as I was a woman,” says Vankar. He failed on both counts. But Raghavender was just a small pawn in a well-orchestrated campaign that had already been launched nationwide. The powerful pesticide industry was faced with its toughest challenge yet.

The might of an industry

The pesticide industry in India is the fourth largest in the world and second largest in the Asia-Pacific region, only after China. Estimates of its total market value vary between Rs 3,800 and Rs 4,100 crore. According to the Pesticides Manufacturers and Formulators Association of India (PMFAI),there are around 55 basic producers and 300 pesticide formulators. Besides, there are a number of small-scale players. Around 200-odd generic products are manufactured in India. Insecticides alone account for around 75 per cent of this market and the cotton crop consumes almost half the pesticides produced in the country. Pesticides exports stood at Rs 1,600 crore in 2000-2001 and the industry is confident that it will reach Rs 1,800 crore during this financial year. India is the largest producer of endosulfan in the world, according to EMFA. Three major companies produce endosulfan in India — Excel Industries, Hindustan Insecticides Limited (HIL) and EID Parry. Of these, Excel is the market leader as far as endosulfan is concerned (see box: Endosulfan peddlers). Therefore, it is not surprising that many of its officials have been visiting Kerala for the past one year trying to get the state government to lift the ban. “S Ganesan and other officials of Excel Industries have been spending a lot of time in Kerala meeting senior government officials and scientists,” says Sridhar R, an activist working with Thanal Conservation Action and Information Network, a Thiruvananthapuram-based NGO. The managing director of the Excel Industries, Ashwin C Shroff, refused to speak to Down To Earth saying that the magazine had a certain viewpoint. But he cannot deny that endosulfan dictates his company’s business interests. “We are acutely aware of our dependence on endosulfan. That is why in the last 6-7 years from a very high dependence of over 60-65 per cent, we have come to a level of less than 40 per cent. But it is like a flagship product,” he told Business Line (January 21, 2001). Profits had to be protected at all costs. And thus began the campaign.

The art of disinformation

In May 2001, an innocuous-looking advertisement appeared in a Bangalore-based daily. PMFAI had issued “a clarification on endosulfan” (see advertisement). The health problems in Kasaragod district were not due to endosulfan and that endosulfan was a ‘registered’ and safe pesticide, it said. This clarification was issued for the “benefit of users and general public and to clarify the incorrect impression created by the media reports”. The advertisement was a damage control exercise. Every newspaper and television channel worth its name had extensively covered the endosulfan tragedy in Padre. The plight of Padre villagers with cases of cerebral palsy, mental retardation, cancer and other diseases captured the public imagination. Endosulfan was becoming a bad word for everyone. “The advertisement was given in the newspapers to educate the people (sic). We were not concerned about the reports for the first three months. Later we realized that we had to intervene as this was wrong,” argues PMFAI president Pradeep P Dave. The association organised a number of press

conferences in Kerala claiming that endosulfan was being used in over 60 countries. Environmentalists in Kerala question the motive behind organising so many press conferences within a short period of time. “This was clearly to mislead the people,” says Jayakumar C, coordinator of Thanal. In June, articles taking up the cause of endosulfan appeared in magazines like Agriculture Today. One such article by E V V Bhaskara Rao, director, National Research Centre for Cashew in Puttur, Karnataka, said: “First convict the suspect then conduct the trial.” Obviously referring to the CSE study. This quote became the most preferred quote for the pesticide lobby. Ganesan became his biggest fan and wrote a letter showering praises: “It’s a masterpiece, a perfect blend of scientific information and literary skill.” (see p28-29) In another article, S K Handa, former head of the division of agricultural chemistry at ICMR, alleged that CSE’s study was “questionable” and “pseudoscientific”. It is another matter that these experts could not find any scientific inaccuracy in CSE’s study (see ‘Pesticide Plot’, Down To Earth, Vol 10, No 10). Dave lapped up whatever Handa had to say. Speaking to Business Standard, Dave said that “the endosulfan issue has been exaggerated.” One PMFAI member went on to blame the cause for the “strange diseases” on inbreeding — “many of those affected by these maladies are reported to be related to each other”. On background radiation, this association offered many explanations, “it could be microbial contamination of water in streams. Or heavy metal contamination. Or poor nutritional levels.” In other words, anything else under the sun. But not endosulfan.

The science of manufacturing data

The disinformation campaign brought only limited dividends for the pesticide lobby. They still needed a “scientific” study to counter the CSE study. And they didn’t have to wait long. In February 2001, a Kerala Agricultural University (KAU) team, headed by M Abdul Salam, associate dean, College of Agriculture, Kerala Agriculture University, conducted a study in Kasaragod. The results were astonishing. No significant residues of endosulfan were found in any of the samples. The industry couldn’t have asked for more. And they went to town with the findings. But there were only a few takers. The KAU study has become somewhat of a joke among learned circles. Differences within the KAU team have cast a shadow over its credibility. Thomas George, who did the residue analysis, has washed off his hands as far as the sampling process is concerned. “I never visited that place (Kasaragod), so I do not know how the samples were collected and from where they were collected. I simply did the residue analysis for the team,” says George. He is also quick to point out that he was only involved with the KAU team in the first round of analysis. “I was not involved the second time,” he says. But other scientists in the team swear that George was involved in both the analysis — the papers clearly mention his name in both the teams. Activists allege that Salam and Samuel Mathew, another member of the KAU team, were hobnobbing with industry representatives. “I met them only to get the scientific studies on endosulfan,” defends Mathew. Mathew’s situation is akin to a judge asking the accused for evidence to save him. Salam says that he was not influenced by anyone. Moreover, even the KAU team admitted the problems faced during their investigation in their report: “Non-availability of quick and reliable methods to assess the level of endosulfan contamination in the environmental, animal and human samples.” Activists and people’s groups in Kerala have rejected the KAU study. The endosulfan conspiracy took a new turn when the PCK commissioned the Fredrick Institute of Plant Protection and Toxicology (FIPPAT) in Kancheepuram, Tamil Nadu, to conduct a study at a cost of Rs 7 lakh, according to PCK. Controversy has trailed this study from the onset. Villagers of Padre and other areas refused to cooperate with this team to collect samples as they knew that it was an industry- sponsored study. “We did not even know when they collected the samples,” says Shree Padre, a journalist- farmer who along with Mohana Kumar Y S, a doctor in Padre, have been protesting against the spraying for many years. “Later we came to know that the samples were collected from young PCK workers, and not from the villagers,” says Sripathy Kajampady, a doctor in Kasaragod who has been fighting for the victims. FIPPAT director Balakrishnamurthy refutes these allegations: “We did a scientific collection with the help of proper authorities.” Members of the Achyuthan committee— constituted by the state government — are however, far from satisfied. They have criticised the report for improper sampling and also the lack of cross checking the findings at a different lab. The pesticide lobby was quick to question CSE’s study saying that it had used concentrated sulphuric acid and so it should be verified by an independent residue expert. It is another matter that while the CSE study did not use sulphuric acid on blood samples, the FIPPAT study, which the industry lapped up, did. It is unbelievable. CSE collected the samples a few days after the spraying and found high levels of endosulfan in all the samples. “The FIPPAT study, though started one month later than CSE, shows just the opposite results, that is, complete absence of endosulfan residues in blood, cow milk and water samples,” says the NIOH report. Moreover, NIOH, which did its study almost 10 months after the last spraying, found endosulfan residues in water samples collected from Kasaragod. NIOH also found residues in the blood samples of children of Vaninagar school. “The detection of endosulfan in the blood samples of children and water samples, 10 months after the last aerial spraying of endosulfan, signifies a continuous exposure to endosulfan,” says the report (see box: What the report says on p31). Although the FIPPAT study was commissioned by the PCK, it was released by PMFAI’s Dave at press conferences in Kozhikode and Thiruvananthapuram, where selective extracts were reproduced for the press. “This clearly points out the nexus between industry-PCK and FIPPAT,” says Jayakumar. Activists in Kerala and people of Kasaragod have branded the FIPPAT study as a “wellschemed industry effort”. An interesting incident that proves the nexus between the industry and private labs took place when the industry made a presentation before the Achyuthan committee. FIPPAT scientist A Ramesh accompanied the industry team that included Dave and S Ganesan of Excel Industries. “Ironically, the FIPPAT scientist did not accompany the PCK team, which had commissioned the study,” says Achyuthan. When Down To Earth asked FIPPAT director as to what business did their scientist have by accompanying the industry team to a government committee, he said: “He might have gone in the same car, but was not with them.” When told that Ramesh’s criticism of CSE analysis was recorded in the committee’s final report, he gave a contradictory reply: “It is not a big crime (accompanying the industry team). But we are not associated with any industry.”

The knack of intimidation

The industry’s next target was scientists and officials who were on committees that could decide the fate of endosulfan. Almost all of them confessed to Down To Earth that they had been approached by the industry representatives and fed with scientific literature about endosulfan. “Industry representatives approached me many times with a lot of documents, naturally to influence me. But I made it clear that I will just depend on scientific evidence. The representatives came with their so-called scientists and doctors to prove that endosulfan is harmless,” says Salam. Ditto for A Achyuthan, Samuel Mathew (scientist with KAU and member of Achyuthan committee), Thomas George (who did the residue analysis for the KAU team), C S Srinivasan (agriculture secretary) and L Sundaresan (former KAU director and member of Achyuthan committee). A look at the industry’s dossier is predictable: only selective information about endosulfan is enclosed. Says Achyuthan: “First they (industry representatives) came to my house. But I told them that I would hold discussions only in Kasaragod and not in my house.” Industry, however, refutes these allegations. “We never approached the scientists. We only approached the agriculture department,” was Dave’s candid reply. “It is amazing that the industry knew every move of the Achyuthan committee well in advance,” says Jayakumar. Just before the Achyuthan committee was to hold a public hearing in Kasaragod on September 5-6, 2001, PMFAI organised a press conference at Kochi on September 4. Three doctors from Mumbai spoke at the press conference and condemned the CSE study and Mohana Kumar. When grilled by newspersons, the doctors admitted that they had not visited Kasaragod or met the affected people. On August 30, 2001, PMFAI and Excel organised a dinner at the South Park hotel in Thiruvananthapuram, which was attended by senior government officials and KAU scientists. One regional newspaper Madhyamam Daily had an interesting comment to make on this gathering. “Pesticides manufacturers are trying to pull strings at the top to get the ban on endosulfan lifted. The PMFAI and the Excel company has been trying to influence the agricultural experts in the state to take a decision in their favour. For this, they had arranged a dinner in a prominent five-star hotel in Thiruvananthapuram where experts and government officials took part. It is learnt that people in the higher ups, including agricultural experts had taken part.Manufacturers lobby is making all intensive effort to get the ban lifted.” In another incident, a freelance filmmaker claims to have accidentally spotted Ganesan, Dave, and Thomas George (who did residue analysis for KAU) at Chaithram hotel, Thiruvananthapuram. George admits having gone to the hotel, but only “to collect some documents regarding endosulfan”. The pesticide lobby also tried to influence civil society groups. Ganesan paid a visit to Ravi Narayan of the Community Health Cell (CHC), Bangalore, who was trying to investigate the health problems in Kasaragod. Ganesan is the general manager with Excel Industries but was introduced to Narayan as a scientific advisor to PMFAI. “They wanted a leisurely meeting with me at some five-star hotel on a Sunday,” remembers Narayan. When he declined the offer, Ganesan went to meet Narayan at his office in January. Ganesan had an unbelievable incident to narrate. “CSE chairperson Anil Agarwal admitted that there was a mistake in CSE’s analysis of samples,” Ganesan is said to have told Narayan. “They can get away by saying anything because Anil is not there to call their bluff,” says Narayan. If civil society activists could not be won over, the industry tried to strangle their voices. Take the case of Madhumita Dutta. As central coordinator of Toxics Link, a New Delhibased non-governmental organisation, she had made a presentation at a conference organised by the Confederation of Indian Industry (CII) on Persistent Organic Pollutants (POPs) on March 6-7, 2002 in New Delhi. She spoke about the endosulfan problem in Kerala and how dangerous pesticides are to human health. This was enough for EMFA’s Raghavender to write a letter to CII wanting it to expunge her statements. He also wrote to Dutta insisting, “We strongly advice you to refrain from spreading further misinformation on the subject.” Such is the insecurity of the pesticide lobby. The Achyuthan committee submitted its final report in November 2001. “There is no evidence to implicate or exonerate endosulfan as a causative factor of the health problems,” it said. But some glaring errors in the report have come to light. The report quotes the remarks made by the Indian Agricultural Research Institute (IARI), New Delhi, to support the cause of endosulfan. IARI, in fact, made no such remarks. These notes were actually prepared by the PMFAI and submitted to the IARI (see p29). “We committed a mistake,” admits Achyuthan. This mistake was one of the basis on which the committee rejected the CSE report, while accepting the KAU and FIPPAT reports. On the basis of the Achyuthan committee’s findings, PMFAI filed a writ petition in the Kerala High Court to lift the ban on endosulfan in the state. They also tried to use Section 27 of the Insecticides Act of 1968. This act states that the state government can suspend the use of a chemical only for certain period of time and cannot ban it completely. This power rests with the registration committee of the Central Insecticides Board (CIB), Faridabad, Haryana. It seems that the endosulfan conspirators have won, at least for the time being. The Kerala government lifted the ban on endosulfan on March 22, 2002, based on the recommendations of the Achyuthan committee and the KAU study. It is surprising because lifting the ban was never the mandate of the Achyuthan committee. “We were not asked to comment on the issue of the ban,” says Achyuthan. However, the ban on aerial spraying of endosulfan remains. Perla division of PCK (covering Padre and Muliyar villages in Kasaragod district) have been given a pesticide holiday for five years. “When the ban was lifted, the entire state government employees were on strike. It is quite possible that the agriculture secretary who had issued the order might have had to type the order himself,” alleges Jayakumar. The agriculture secretary, C S Srinivasan, — who activists allege is an industry person — also held the additional post of director of agriculture department (February 28 to March 18) when the final decision was taken to lift the ban. When Down To Earth sought an appointment with Srinivasan, he refused. But when the same reporter approached him as a freelance journalist, he readily agreed for an interview. He said that he had just received the NIOH report (it reached him three months ago), but he didn’t have the time to go through it. Maybe Srinivasan just wanted to keep the report out of the media’s reach. The role of the state’s chief minister, A K Antony, has been quite bizzare. Some activists allege that he is a “dummy” — someone who has been unable to take a principled stand. His government has lifted the ban, even as it sits on the NIOH report, which clearly calls for stopping the use of endosulfan. According to Section 27 of the insecticides act, the state government could have either extended the ban or issued fresh orders to continue the ban. Antony could have also taken up the matter with the Union government on the use of endosulfan. But he did not do so. How can the chief minister be so apathetic to the sufferings of children. The order itself to lift the ban was a hushed up affair. Even today most people in Kerala are unaware that the ban has been lifted. And to add salt to injury, a fresh batch of endosulfan reached all Krishibhavans in Kerala this month. Kerala’s residents are terrified.

THE BUSINESS OF POISONING

Endosulfan constitutes only a small share of the pesticide market.
So why is the pesticide industry paranoid?

The protest against endosulfan in Kerala has become a symbol of struggle against pesticides in India. The pesticide industry is worried about endosulfan as much as it is of its other products. As Dave proudly puts it, “I do not defend just one molecule. I am the president for 200 molecules. We will not ban anything just on the basis that it is banned in other countries.” If endosulfan is banned in Kerala, it could have a cascading effect in the rest of the country. A successful campaign for banning a particular pesticide will fuel the fire for other movements as well in India. More pesticides would be under scrutiny. More communities would feel encouraged to protest. And more pesticides would be on the hit list. That is something the industry cannot afford to lose out on. There are already reports of a similar problem in Karnataka. The Karnataka Cashew Development Corporation had been spraying endosulfan on its plantations in Dakshina Kannada and Udipi districts since 1987. People in these areas are also suffering from strange diseases.

A larger game plan

The aim of the industry's campaign is, in fact, much larger. It is to strangle all the voices that are calling for a ban on pesticide products. Worldwide, awareness about harmful effects of pesticides on humans as well as the environment is increasing. Governments are buckling under the pressure from the civil society groups to ban harmful chemicals and pesticides. Last year, Columbia banned endosulfan. The Philippines reinstated the ban on endosulfan after a long-drawn battle with the industry (see box: Threats and a ban). Other countries are either restricting the use of this pesticide or banning it completely. The industry is feeling the heat for more than one reason. Recently, India signed the Stockholm Convention, a global treaty to protect human health and the environment from persistent organic pollutants (POPs). POPs are chemicals that remain in the environment over long periods. By implementing the Convention, governments will eliminate or reduce the release of POPs into the environment. In the first phase, 12 POPs have been identified for phase out. Endosulfan is not yet on this list, but has all the ingredients to make it in the next round. As consumer pressure is increasing, corporate bodies are voluntarily moving away from pesticides. “Industry representatives told me that endosulfan for cashewnut plantations is just a small market. They are more concerned about endosulfan being used in cotton and in other states. They said if it is banned in Kerala, it will have repercussions all over India,” says Salam. When Dave was asked whether they felt threatened by such campaigns (like the one on Kerala) he replied: “It's just that we have to protect our interests and present our side of the story.”

Threats and a ban
It’s not easy to take on the pesticide industry. The Philippines knows it better

The Philippines banned endosulfan in 1992. The industry led by Hoechst of Germany launched an offensive. It filed contempt proceedings against the Philippine Fertilizer and Pesticide Authority’s (FPA), which imposed the ban. It also harassed field workers who came forward with their personal experiences about exposure to endosulfan. The ban was successfully challenged by the industry. In 1993, a subsidiary of Hoechst, AG, of Germany, filed another lawsuit against a news agency, Philippine News and Features, that ran a story on the possible carcinogenic nature of the insecticide, Thiodan (Hoechst’s trade name for endosulfan formulation). Even a scientist quoted in the story, Romeo Quijano, was sued for over US $814,800, according to Pesticide Action Network (PAN), a global anti-pesticide body. Citizen and farmers groups got together to fight back. They were outraged that anyone coming out in the open about the effects of pesticides was slapped with a lawsuit. Activists were also disturbed by media offensive initiated by Hoechst’s regional subsidiary that portrayed pesticide products as safe. In March 1994, the Philippine government ordered Hoechst to withdraw its television advertisement on Thiodan calling it “false, misleading and deceptive”. On June 1, 1994, the government reinstated its restrictions on endosulfan sales and banned triphenyltin acetate, despite threats by Hoechst that it would pull out of the country if the decision were not reversed. The ban still holds on the use of endosulfan, except for use in pineapple farms.

RULES AND RENEGADES

Pesticide regulations in India are lax. The industry has exploited the loopholes to
corrupt the system. And the government has turned a blind eye to the problem

Pesticides are regulated under the Insecticides Act of 1968 and Insecticides Rules of 1971. In May 2000, the Insecticide (Amendment) Bill 2000, was passed under the shadow of suicide deaths of farmers because of spurious pesticides. This amendment made the punishment for adulterated pesticides more stringent. But it did little to clean up the regulations to register pesticides and to monitor this poison industry. The insecticide act regulates the import, manufacture, sale, transport, distribution and the use of insecticides to prevent any risk to people and animals. The registration committee, constituted under Section 5 of the act, registers an insecticide after verifying its efficacy and safety to human beings, animals and the environment. The Central Insecticides Board (CIB) based in Faridabad, Haryana, advises the Union and state governments on technical matters. In 2001, a total of 2,718 applications were received for registration, of which 1,439 were approved, according to the government. Basically, there are two types of registration under Section 9 of the Insecticides Act — primary and secondary. When a new molecule is registered in India it gets a primary registration. Subsequent applications for the same molecule get the secondary registration. Registering a new molecule requires the generation of studies — environment dependent data conducted under Indian agro-climatic conditions and environment independent data. Environment independent data can be straightaway lifted from existing data elsewhere in the world. But generating environment-dependent data usually takes around 4-5 years. Data sets on various subjects including toxicology and phytotoxicology need to be generated to register any new molecule. Once a primary registrant exists, others applying for fresh registration are given a secondary registration. Of course, these are just rules prescribed by the government. These are rarely followed.

Pest-infested system

The first step to register a new pesticide is the generation of data. This is also the first step where corruption can creep in. A company has the option of either going to a government lab or a government-approved private commercial labs. “Companies usually prefer government- approved commercial labs as they can generate the desired results. And quickly. Bureaucratic hurdles in government labs can cause long delays,” says N G Waghle, former vice-president, Pest Control India Limited. Private labs are primed to cater to the industry’s demands, he adds. Where everything comes at a price. “Indian registration procedures are hopeless. It is a big tamasha,” says P D Deshmukh, a senior pesticide industry insider. With an experience of 30 years with the industry, Deshmukh has amazing tales to narrate. “I know of one lab which promised to generate toxicological data for a product within a day. Generating this data usually takes one to one and a half years. The head of the lab told me that he would prepone the exchange of letters by one year — making it look as if the application was filed a year ago. Many multinational and Indian companies are a part of this racket,” alleges Deshmukh. “It is scary to imagine how many dangerous pesticides would have made it to the farms without proper testing,” fears Waghle. Recounting his 35 years of experience in the industry, Waghle, recounts shocking tales of how companies have corrupted even top officials in pesticide registration bodies. “Companies are wary of directly approaching CIB officials, so they use the services of a broker,” he says. Agents act as a liaison between the industry and CIB. Bribing of junior and senior officials at CIB takes place through these designated agents. The industry has developed the bribing of officials into an art form. And the agent is an integral part of this racket.

Ugly interface

The broker is usually a regular face at the CIB, says Waghle. So even officials feel comfortable interacting with him. Industry pays this agent for all the dirty work that they want to get done — registration of a new molecule or stealing data for already registered molecule or even bribing the registration committee members to influence decision-making at the top level. But the bribe is not always money. Many top CIB officials, including the registration committee members, regularly receive junket invitations, says Waghle. The company pays for all the expenses — air tickets, five-star hotel accommodation and even shopping expenses. Again there is no direct involvement of the industry. It is done through the agent. “The official simply has to inform the agent, who then gets in touch with the company. The company pays the agent for all the dirty work,” he adds. Waghle has given Down To Earth names of a few of the legendary agents and their clients. The laws itself are geared to protect the industry. The endosulfan establishment has used these loopholes to great advantage. For example, the PCK violated many regulations while conducting aerial spraying. The insecticides act makes it mandatory for a company to inform people about aerial spraying of pesticides. All waterbodies in the area must also be covered during spraying. But this was not done by the PCK. “The CIB has prescribed that the endosulfan spraying should be undertaken at a height of not more than 2-3 metres above the foliage. But even this was always violated in the PCK plantations,” says L Sundaresan, former director, department of agriculture, Kerala. “Aerial spraying of endosulfan was never allowed by the CIB after 1993. The CIB had given approval for aerial spraying of endosulfan to the PCK only till December 1992. But the department of agriculture in Kerala and the district collector have been issuing aerial spraying directives even till January 2001,” alleges Jayakumar. The Union government made some tired efforts to make pesticide use “safe”. It appointed committees. These committees allowed the use of endosulfan with a word of caution: pesticides must be used very carefully and specified areas where they must not be used. In 1991, the Union government appointed a committee headed by S N Banerjee, former plant protection advisor to the government, to review whether some pesticides, including endosulfan, should be used in India. The committee said that the registration committee of CIB should not allow the use of endosulfan near rivers, lakes, sea and ponds. The committee also recommended a warning must be displayed on all labels and leaflets of containers. As far as other warnings are concerned, companies display them in such small point size that it is unreadable (see Farmer education on this page). Another committee headed by R B Singh, made similar recommendations in 1999. It reinforced the fact that labelling should be made mandatory in bold letters to avoid use of endosulfan near water sources. The 195th meeting of registration committee of CIB, held in December 1999, agreed to implement the recommendations. But they were never actually implemented. The CIB has chosen to sit on these recommendations. Endosulfan is still used indiscriminately, as the Kasaragod tragedy shows. The pesticide industry does not like the regulations of the insecticide act saying that the cumbersome procedures for registration are strangling growth. But, seeing the way the industry has sidestepped, indeed, trampled over all procedures and norms of decency in the endosulfan case, it is clear that this “dirty” business needs more, not less, controls. But this time it needs monitors who will have public accountability. Otherwise, this industry of death will become even more deadly in the years to come.