We do not even begin to ensure safety by fixing the ADI. In fact, we disregard safety and public health completely in our regulations. We register pesticides, we use these toxins but we do not know what our exposure is and how this can be contained. At best and at times, for some pesticides in some food, we fix the MRL. But we don't enforce the legal limits so that is also reduced to a meaningless farce. The system is managed, till it is so compromised that it is deadly for our health.
Estimations show that we exceed the ADI by upto 7,000 per cent in some pesticides. Children -- most vulnerable -- are worst affected. Their daily quota is exceeded manifold. How can this be acceptable? How can this have just happened under the noses of our informed regulators?
We will have to incorporate ADI into our regulatory systems. Pesticides can be registered for use only when the estimations of the intake and exposure have been completed, and established to be safe. For this, MRLs will have to be fixed at the time of registration. The government will have to do calculations based on diets, and only then register. Then, only if consumption is below safe levels. Only then.
Currently we exceed the ADI because we have set very high MRLs -- legal limits for residues in our food. This will need to change. There is a ridiculous policy initiative to "harmonise" Indian MRLs with MRLs set under Codex Alimentarius -- the global food standard agency. We need to harmonise our pesticide standards with our diets, not with Codex.
Because we exceed the ADI, we have no space for non-essential foods. Remember, pesticide regulation is about a nutrition-poison trade off. If our daily diet of pesticides is being exceeded just via essential food, we cannot allow pesticides in non-essential and non-nutritive foods. This is why we cannot allow pesticides in coke or pepsi (see box: And...coke and pepsi?).
But also, we will need to enforce the legal limits through an effective programme of surveillance and enforcement. We cannot argue that we cannot control pesticide contamination on our raw agricultural commodities and so cannot enforce standards for food safety. This is unacceptable. No, this is completely wrong.
Finally, we have to remember that regulation will cost. Every time we register a pesticide for use we will have to incorporate this cost -- of regulation and enforcement. Otherwise, we are discounting the real costs -- of ill health, perhaps death. This deliberate style of negligent governance -- criminally negligent -- must stop.