Playing with poison

Food Safety and Standards Regulations came into force in August 2011. It was expected to overhaul the food safety scenario in India. After a year, we wanted to see how much it has delivered. Going through the maximum residue limits (MRLs) of pesticides in the ‘Toxins, Contaminants and Residues’ part of the regulations we found that it was very similar to the earlier version in Prevention of Food Adulteration Act. It prompted us to look for the overall scenario of pesticide regulations from a food safety perspective. What we found was far from satisfactory.

Centre for Science and Environment (CSE), a Delhi based non profit had conducted a series of experiments on bottled water and soft drink brands in 2003. It found unbelievably high amounts of pesticides in both bottled water and soft drinks. The companies were quick to react. They declared their products safe. So did the government. After much debate, a Joint Parliamentary Committee (JPC) was formed in 2004 to verify if the results found by CSE were correct. After enquiry, JPC found not only the results to be correct, but also the complete system of pesticide regulations in disarray. It recommended an overhaul in regulations. The recommendations included discontinuing the practice of registering pesticides without setting their MRLs, reviewing MRLs for their compliance with acceptable daily intakes (ADIs), recommending waiting periods for all pesticides and setting up a proper monitoring system for pesticide residues.

Maximum Residue Limit (MRL) - The maximum amount of residue of a pesticide (or other toxins) that can be expected in an agricultural product for which it has been used following Good Agricultural Practices (GAP)

Good Agricultural Practices (GAP)
– Practices (set by competitive authority) that address environmental, economic and social sustainability for on-farm processes, and result in safe and quality food and non-food agricultural products.

Acceptable Daily Intake (ADI) – The maximum amount of a pesticide (or other toxin) that can be consumed by a person from all sources in a day.

Theoretical Maximum Daily Intake (TMDI)
– Estimated amount of pesticide intake per day for a person following a particular diet from all dietary sources considering the MRLs to be equal to residues in different products.

Waiting period – The time period prescribed between application of a pesticide and harvesting of crop so that the residues may be minimized.

Our analysis shows nothing much has changed. There are still pesticides registered without MRLs. Existing MRLs have not been reviewed, waiting periods have not been set and monitoring system remains inefficient. We analyzed MRLs of 20 most used and recommended pesticides for their compliance with the ADIs set by Joint Meeting of Pesticide Residues (JMPR) of United Nation’s Food and Agriculture Organization (FAO) and World Health Organization (WHO). We also analyzed the recommendations of state agricultural universities and other important bodies like national horticultural board (NHB) and Spices Board of India (SBI) to see if they match the list of pesticides that have been registered by Central Insecticides Board and Registration Committee (CIBRC) for the same crops. We analyzed the recommended waiting periods for 10 important pesticides. Finally, we asked famers, activists and dealers in different states about pesticide uses.

TMDIs calculated with the MRLs in the FSS Act and a dietary plan based on the dietary guidelines of National Institute of Nutrition (NIN) still cross the ADIs. Waiting periods are still incomplete and monitoring system looks flawed. Agricultural universities do not essentially recommend the same pesticides that CIBRC has registered for the crops. Worse is the fact that farmers do not follow the recommendations at all. They follow what the dealers suggest them.

Why should they do so? The answer came from a marketing executive of one of the leading pesticide companies. “State Agricultural Universities are slow in their process. They do not change their recommendations as per the availability of new pesticide formulations in market. So we have to do it ourselves” He says.

Key findings
  • There are 234 pesticides registered by CIBRC. Fifty nine of these pesticides do not have MRLs set
  • MRLs set do not cover all the crops a pesticide is registered for and they have not been reviewed for their compliance with ADI
  • The recommendations of State Agricultural Universities and other boards for different crops do not match with the pesticides that have been registered for the same crops by CIBRC
  • Farmers do not follow the recommendations in most of the cases. They follow what dealers suggest them.
  • Waiting periods recommended by CIBRC for many pesticides are incomplete.

Experts do not endorse the practice but agree with the condition of universities. “The recommendation process for pesticides in India is in complete disarray. State Agricultural Universities are not very thorough with their research and they are also very late in updating their recommendations. There is an urgent need to overhaul the process” notes G V Ramanjaneyulu, agricultural scientist and activist with Hyderabad based non profit Centre for Sustainable Agriculture.

What needs to be done? “MRLs can only be corrected by following good agricultural practices. We need to focus on what, when and how much (of pesticides) to use” says A K Dikshit, Scientist with Agricultural Division of Indian Agricultural Research Institute, New Delhi.

There should be a harmonization between the pesticides that have been registered by CIBRC for a crop and the recommendations of universities and boards. Without this monitoring of pesticides seems impossible. “If this (harmonization) does not happen we will not be able to know what pesticides are being used for which crops and hence will not be able to monitor pesticides” adds Ramanjaneyulu.

Hopes betrayed

We selected 20 pesticides which are very commonly recommended and used to see the status of their MRLs. Eleven important crops were chosen and recommendations for them in different states were studied. Similarly, we chose 10 pesticides to study the waiting periods recommended for them. What we found is as follows

MRL status of common pesticides

MRLs should be set for all the crops a pesticide has been registered for. Just two of the 20 pesticides considered, phorate and fenvalerate, were found to have MRLs set for all the crops they were registered for. Methyl parathion had MRLs set for just two crops for which it was not registered. It did not have MRLs set for any of the crops it was registered for. Quinalphos did not have MRLs set for 28 crops it was registered for (see table).

MRL Status of Common Pesticides

Pesticides Crops Registered MRLs set MRLs not set
Phorate 23 23 0
Mancozeb 23 14 9
Methyl Parathion 7 0 7
Cypermethrin 8 6 2
Carbendazim 18 14 4
Monocrotophos 14 11 3
Malathion 16 11 5
Quinalphos 32 4 28
Acephate 3 2 1
Triazophos 4 3 1
Fenvalerate 4 4 0
2, 4 – D 8 7 1
Captan 14 11 3
Zineb 18 13 5
Paraquat dichloride 10 7 3
Dichlorvos 10 3 7
Dimethoate 24 14 10
Chlorpyrifos 13 10 3
Phosalone 13 5 8
Carbofuran 27 22 5

Safety limits

MRLs are not the safety limits. They have to be compliant with ADIs. It means TMDI should be less than ADI for the prescribed set of MRLs for all age groups and both the sexes. If that does not happen, agricultural practices should be reviewed to bring the MRLs down, failing which, a pesticide should not be recommended for the concerned crops. The TMDIs for seven out of 20 pesticides considered in the study were found to be higher than corresponding ADIs for adults. For children, TMDIs of nine pesticides exceeded ADIs (see table).

TMDIs’ comparison with JMPR ADIs


Pesticide ADI (mg/kg BW) ADI (adult) ADI (Child) TMDI (adult) TMDI (child) TMDI as % ADI (adult) TMDI as % ADI (child)
Phorate 0.0007 0.042 0.00903 0.0564 0.0196 134.3 217.1
Methyl Parathion 0.003 0.18 0.0387 0.52 0.17 288.9 439.3
Monocrotophos 0.0006 0.036 0.00774 0.17 0.122 472.2 1576.2
2,4 – D 0.01 0.6 0.129 0.243 0.232 40.5 179.8
Captan 0.1 6 1.29 9 3.75 150.0 290.7
Dichlorvos 0.004 0.24 0.0516 0.535 0.1225 222.9 237.4
Dimethoate 0.002 0.12 0.0258 1.2 0.5 1000.0 1938
Phosalone 0.02 1.2 0.258 0.864 0.59 72.0 228.7
Carbofuran 0.001 0.06 0.0129 0.122 0.03 203.3 232.5


The case of methyl parathion

TMDI for methyl parathion was found to be about three times its ADI for adults. The calculation was based on FSS Act MRLs and a diet plan according to dietary recommendations of National Institute of Nutrition, Hyderabad. Vegetables are the major contributor of this pesticide in our diet (see table).

TMDI calculation for methyl parathion

Food Commodity Quantity (g/day) MRL (mg/kg) Intake (mg)
Cereals and millets 375   0
Rice 173   0
Wheat 139   0
Others 63   0
Pulses 75   0
Milk and milk products 309   0
Roots and tubers 200 1 0.2
Potato 116   0
Onion 62   0
Others 22   0
Green leafy vegetables 100 1 0.1
Cabbage 36   0
Palak and others 64   0
Other vegetables 200 1 0.2
Tomato 44   0
Cauliflower 24   0
Brinjal 34   0
Okra/Lady finger 16   0
Others 82   0
Fruits 100 0.2 0.02
Mango 14   0
Banana 56   0
Apple 11   0
Citrus 8   0
Others 11   0
Sugar 20   0
Fat 25   0
TMDI     0.52
ADI 0.003   0.18
TMDI as %  ADI     288.89



Revisiting recommendations

Recommendations made by state agricultural universities and other important bodies like commodity boards and research institutes should be in line with what the pesticides have been registered for. The universities and boards have not met this criterion in most of the cases.

The case of wheat

Agricultural Universities in Punjab, Haryana, Uttar Pradesh and Madhya Pradesh recommended pesticides which were not registered for wheat (see table). The cases for paddy, mango, apple, cauliflower, potato, cardamom, black pepper, tea, sugarcane and cotton were also analyzed and found to be similar.

Pesticides recommended and registered for wheat

  Registerd Recommended Registered but not recommended Recommended but not registered for
Punjab 38 40 9 11
Haryana 38 31 12 5
Uttar Pradesh 38 23 17 2
Madhya Pradesh 38 29 18 9


Waiting periods

Waiting periods should be recommended for all the pesticides for all the crop pest combinations they have been registered for. For instance, phorate, an insecticide, is registered for a combination of 49 crops and their corresponding insects, there should be prescribed waiting periods for all these crops. Analysis of ten pesticides showed that it happened only for two of these pesticides: acephate and triazophos. No waiting periods have been recommended for phorate, monocrotophos and malathion (see graph).