Toxicitea tangle

In 1995, Indian exporters got a rude shock when a consignment of Darjeeling tea was rejected by Germany. The reason for this drastic measure: the tea leaves contained excessive pesticide residue levels. The unsavoury incident left a bitter aftertaste in India, but the fact remains that the tea did contain banned toxic substances. It is also true that since then, neither have any domestic standards been set for maximum pesticide residues in tea nor an effort made to curb unscrupulous exporters (some of them are known to give one sample for clearance and another for actual export). This unhealthy blend of inaction and non-implementation has left the country just as susceptible as it was seven years ago to non-tariff trade barriers and unfair practices of developed nations.

Germany had rejected the Darjeeling Gold brand of tea from market leader Teekanne because it contained 0.24 milligrammes (mg) of tetradifon -- a pesticide used against mites in horticultural crops, cotton, hops, tea and rice -- per kilogramme (kg) of tea. This was 24 times the maximum residue level (mrl) fixed by Germany. mrls indicate the maximum amount of pesticide levels in foodstuffs allowed by any country.

Indian exporters argued that the tetradifon levels found in Darjeeling tea were within the standards set by the us Environmental Protection Agency (epa), which then allowed a maximum limit of 8 mg/kg. However, their contention that tea liquor and not tea leaves should be tested for pesticide residue levels did not cut much ice with the Germans. The tea was also found to contain ethion, which is used to control leaf-eating insects and mites, above the stipulated German levels.

Interestingly, the main producer of tetradifon in India was a German manufacturer which sold it under the brand name Tidion. The product was banned in India in 1992. When the controversy erupted, it was believed that the use of leftover stocks had led to the lapse.
Flavoured with politics Over one and a half billion cups of tea are consumed daily all over the world. In fact, tea is said to be the second most consumed beverage after water. With so much at stake, it is not surprising that a North-South divide has emerged where industry lobbies in both the regions exert their influence over key policy matters. Concern has been expressed over the domestic environmental policies of developed nations adversely affecting market access of products from developing countries. These laws are often so stringent that developing countries lack the technical and financial ability to comply with them.

In this context, it is widely believed that the 1995 German ban was protectionist. Veena Jha of unctad (United Nations Conference on Trade and Development) puts the issue into perspective: "Doubts have arisen about the justifiability of the objections about pesticide residue in the European market. The German mrls were arbitrarily imposed because of lack of data from India on its pesticide safety limits."

Ironically, this was done right under the nose of an international standard-setting body -- the Codex Alimentarius Commission (see box: Codex strives for some bite ). This global watchdog has been established under the aegis of fao (Food and Agriculture Organisation) and who (World Health Organisation) and is recognised by the wto (World Trade Organisation) for fixing technical specifications as well as benchmarks for all agricultural commodities including tea. While it cannot impose its standards, countries that adhere to Codex guidelines automatically conform to international trade rules. Significantly, Codex has not set a standard for tetradifon.

T C Choudhary, director of research, Tea Board, Kolkata, optimistically claims that "the problems have been sorted out due to our successful campaign amongst tea growers". His confidence may, however, be misplaced considering the fact that reports of pesticide residues in tea continue to pour in. "That tetradifon was banned in India before it was detected in tea indicates a poor enforcement regime," points out Mohammed Saqib, consultant at the Rajiv Gandhi Institute for Contemporary Studies, Rajiv Gandhi Foundation, New Delhi. The tea producers take the stand that at us $ 200 per sample, the cost of testing for maximum residue levels is prohibitive in Germany and amounts to non-trade barriers.

Biswajit Dhar, senior fellow, Research and Information System For the Non-Aligned and Other Developing Countries, a New Delhi-based ngo (non-governmental organisation), echoes their views: "These regulations have the potential to create barriers to trade, particularly for products exported by developing countries, despite several agreements to safeguard their business interests."

The correct dosage
mrl science -- meant to protect the health by determining the amount of pesticide residues that can be tolerated by humans -- is the key to this business. But it is complicated and takes time, as it involves collection of sufficient data from different agro-ecosystems and quantification of what is known.

The residue data obtained from analysed samples is evaluated by experts, who then recommend an mrl consistent with national good agricultural practices (gaps). Each country's authorised safe uses of pesticides under actual conditions necessary for effective pest control are included in their gaps.

The acceptable daily intake (adi) is a quantitative expression of acceptable daily amounts of residue that can be ingested on a long-term basis and which is established on the basis of toxicological data from animal studies.

But the lack of sufficient data on pesticide residue and toxicological studies on adi leads to the setting of mrls through temporary acceptable daily intake (tadi). A tadi estimated by the joint fao/who meeting on pesticide residues normally involves the application of a safety factor larger than that used in estimating an adi.

In such cases, Germany applies a default value based on the limit of determination for the pesticide. This translates into the lowest level at which residues of the pesticide can be detected, quantified and confirmed in the product. Such a limit is also referred to as 'zero' tolerance. Jha points out that "these levels are impossible to maintain even if a minuscule amount of the pesticide is being used".

Toxic infusions
The seasonal appearance of pests during tea cultivation necessitates timely management of the crop through pesticides. However, care has to be taken not to overdose on pesticides because this can lead to a high residue level of toxic substances in tea leaves in excess of the mrl set by importing countries. Consequently, emphasis is laid on striking a balance between pest toxicity and mammalian toxicity.

Pests that commonly attack tea crop include mites, thrips, jassids, helopeltis, mosquitoes, bugs, leaf-eating beetles and defoliating caterpillars. Tetradifon is the most effective pesticide to counter a potent pest -- the red spider ( Oligonychus coffeae ). For other mites , dicofol and ethion are used.

Endosulfan helps tackle pests such as thrips, jassids, aphids, helopeltis and other sap-feeders. Unlike mites, sap-feeders disperse rapidly and can be dealt with by applying pesticides over a large area. Organophosphate insecticides such as quinalphos and phosphamidon are also used to control sap-feeders and leaf-eaters. When conventional chlorinated hydrocarbons like endosulfan fail to control leaf-eating beetles and defoliating caterpillars, synthetic pyrethroides like deltamethrin are applied. On account of the complex pest situation in tea cultivation a total avoidance of pesticides does not appear feasible, say industry observers. It is in this context that mrl assumes importance.

Row spiced up
The mrls for tea are based either on the toxicity level of active ingredients of the pesticide or on the field data generated in different tea producing countries.

Codex Alimentarius has fixed the maximum limits for pesticide residues in tea but the list is not comprehensive and often countries set their own standards that are far more stringent (see table: Dregs with a difference ). In 1994, Germany established an mrl for ethion in tea at 2mg/kg in accordance with a European Council (ec) directive. The order stated that only a temporary mrl could be fixed due to insufficient data.

As compared to this, epa was applying an mrl of 10mg/kg in tea whereas Codex stipulated a 5mg/ kg level for ethion -- but only in citrus fruits. Though Germany adopted a lower limit than other countries, it was approximately of the same order of magnitude. Incidentally, who categorises ethion as a pesticide that is highly to moderately toxic to humans by the oral route.

Such differences in mrls have been grist to the reaction mill. According to Jha, "The maximum residue levels in Germany have been set without any scientific basis. It is now taking advantage of the situation through value addition. It buys Darjeeling tea in bulk at low prices justified by the alleged pesticide contamination, then processes it and sells it at high prices."

A K Kala, special officer, Tea Board (northwest India), concurs: "The standards set by Germany are too stringent. Further, if the country allows other food products with a higher mrl value, it should follow the same regulations for tea too. " Atul Kaushik, ex-deputy secretary in the Union ministry of commerce and currently in the cabinet secretariat , says in his experience "even other European countries like the Netherlands feel that the German standards are not based on scientific evidence".

India stirs
Concerns such as these were addressed at a meeting of the inter-governmental group on tea, held under the aegis of fao in New Delhi in October 2001. The wide variations in mrls applied by different importing countries were seen as a potential deterrent to trade. Worse still, mrl standards in some countries were found based on 'minimum detection limits' rather than on scientific field residue data. The outcome of the meeting was that the government decided to constitute a committee to look into the discrepancy in standards. The proposed panel will fix unified global mrls and submit them to Codex. It remains to be seen whether this move succeeds in reconciling North-South differences on the issue.

In India, the groundwork has been done to provide a broad base for fixing mrls for the entire range of pesticides being used domestically. But these have yet to be given the official nod. Extensive field trials covering all tea-growing regions have been conducted at Tea Research Association, Kolkata; United Planters Association of Southern India, Coimbatore; and Institute of Himalayan Bioresource Technology, a csir (Council of Scientific and Industrial Research) lab in Palampur, Himachal Pradesh. In order to harmonise the mrls formulated within the country with those prevalent at the global level, an expert group of scientists has developed a national protocol. It has proposed mrls for 14 pesticides including ethion, dicofol and endosulfan. Experiments are on to include another 12 compounds. These standards will be tougher than those of Codex.

On its part the Tea Board, formed by the Union government to promote trade in the beverage, ducks queries on how the industry is currently dealing with pesticide residues by citing the implementation of Prevention of Food Adulteration (pfa) standards. "The Indian tea production process, which adheres to the pfa regulations, is considerably good," avers Kala. Standards laid down under the pfa Act are similar to iso 3720 stipulations that take into account water, ash and crude fibre content in tea but not pesticide residues. In effect, India has no legs to stand on because no mrls have been set as yet.

Tee-off time
Global trade is rarely free. Efforts to make major inroads into European markets by developing countries are often stymied due to trade restrictions. At such a time, the exporting nation can be further hamstrung by its own lack of preparedness. The case of Darjeeling tea illustrates how a high-value product is affected by the absence of domestic standards, the prevalence of poor agricultural practices and even poorer enforcement.

India's own mrls have been a long time coming but better late than never. What is also important is that the country's farmers should be helped in improving their pest management strategy, failing which the whole process may be an exercise in futility. "Once we set our standards, if the importing countries restrict the entry of food items on the basis of their own regulations the burden of proof will be on them," opines Jha. "We can then raise the objection that their standards are not in conformity with the international guidelines," she adds.

Foreseeing functional problems, Saqib says: "Enforcement will not be easy." Dhar points out that "only after setting our standards can we get countries with similar interests, like Sri Lanka and Kenya, to join us in our fight".

The fact is that problems persist regarding testing and conformity assessment. There are only a few laboratories which can test commercial samples of tea in India. The cost of testing is high and unaffordable for the bulk tea exporters who get low realisation. "Though the Tea Board has now authorised some labs in India, at Rs 3500 per sample testing turns out to be too expensive," laments New Delhi-based tea exporter Sanjay Kapoor.

Shakti Singh, branch manager in another tea company located in Delhi, says they have found a solution: "We have removed all hurdles to export by going organic and biodynamic." Organic tea production usually does not involve the use of pesticides or chemical fertilisers. Instead, it relies on livestock manure, composted crop residues and intercropping for plant nutrients, and natural pesticides (such as neem and rotenone) or predators for pest control.

Currently, India accounts for almost 90 per cent of the 2.4 million kg of organic tea produced worldwide annually. But only about half of India's organic tea estates make profits.

Kaushik, meanwhile, puts some pertinent posers:

• how does India propose to implement its own mrls?

• who will foot the bill incurred as a result of adherence to these standards?

• once the market is lost during the transition period, how will it be regained?

The answers to these questions may provide a workable solution to the vexed tea tangle. Till then, India can seek solace in playwright Arthur Wing Pinero's famous quote: "Where there's tea there's hope."