It is time for the government to awaken from its hitherto smug slumber
So What do we know
First, responsible governments ensure safety by fixing the Acceptable Daily Intake (ADI) of each pesticide -- in other words, toxicological science establishes the threshold at which a pesticide's residue is safe to consume, each day, over a lifetime. The ADI is the touchstone of safety. It cannot be breached. Regulation is about living within the ADI quota.
Second, living within the ADI quota requires a trade off between poison and nutrition. We have to ingest pesticides because we need nutrition, but we must not exceed our quota. So long as we cannot wish away pesticide use, it is imperative that this trade-off is a prudent one. What is 'safe' means calculating what we eat, how much we eat and how much pesticide can be allowed in all this. The food basket is also the pesticide basket.
Third, regulators have to ensure some 'elbow room' in the ADI. They must ensure our theoretical maximum daily intake -- what we eat, in the process ingesting legally allowed pesticides -- does not exceed the ADI. And that there is 'space' -- that only a proportion of the ADI is used and that more and more accurate dietary-pesticide intake models are estimated . This ensures that pesticides are not a health hazard because the exposure is much below ADI.
Fourth, with exposure much below ADI, governments can make adjustments for consumption of pesticides through other foods and media -- like water or even air. Then you can ingest some 'unaccounted for' pesticides through non-essential non-nutritive food, which is not part of the daily diet-pesticide calculation.
Fifth, regulation across the world is now moving towards tightening the acceptable toxicity of a pesticide so that the chemical itself is less harmful.
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.
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