2. COUNTRY REPORTS^[1]

Bangladesh

by M.A. Aziz

Introduction

Bangladesh is predominantly an agricultural country with an area of 147 570 sq. km. Agriculture plays an important role in the lives of Bangladeshi people.

The major crops grown in the country are rice, wheat, jute, potato, sugarcane, vegetables and tea. The warm and humid climatic conditions of the country, increased use of modern high yielding varieties of crops and more use of chemical fertilizers are highly favorable for development and multiplication of pests and diseases. The estimated loss in yields due to attacks from pests and diseases annually ranges from 15 to 25 percent. The severity varies depending on the variety, season and climate. The main pests of economic importance in different crops are:

Pest control in Bangladesh is dependent on the use of pesticides, the bulk of which are in granular formulations. However, the total usage is approximately 20 000 metric tons of formulated products which is not high compared to usage in other countries in the Asia-Pacific region. In practice, farmers use pesticides only when infestation is evident; even then, only minimal doses are applied.

Use of pesticides

The use of pesticides in Bangladesh is based on minimum curative applications with 70 percent in rice and the remaining 30 percent on tea, sugarcane, potato, mango, banana & vegetables. Key pesticides being used are carbofuran 5 percent GR, Diazinon 10 percent GR, Sulphur 80 percent WDG, Mancozeb 80 percent WP, Chlorpyriphos 20 percent EC, Cypermethrin 10 percent EC, Cartap 50 percent SP, Quinalphos 25 percent WC, Pretilachlor 50 percent EC, Propiconazole 25 percent EC and Phenthoate 50 percent EC, Butachlor etc. Consumptions of pesticides during last three years are:

Pesticide industry profile

The Pesticide industry in Bangladesh is comprised of private companies and foreign companies. It is represented by an organization, Bangladesh Crop Protection Association. Total members of the association are around 50. Pesticides are distributed through distributors.

Local production of pesticides

Because the Government is committed to a policy of self sufficiency, the Government provides with duty waiver on import of technical material and other related adjuvant for local formulation of pesticides. There are 10 companies operating in different areas of the country producing some granular and emulsifiable concentrate formulation. Key pesticides being formulated in the country are Carbofuran 5 percent GR, Diazinon 10 percent GR, Butachlor 5 percent GR, Malathion 57 percent EC, Fenitrothion 50 percent EC and Diazinon 60 percent EC. Criterion required for obtaining a formulation license is mostly in consonance with the 'Integrated International Safety Guidelines for Pesticide Formulation in Developing Countries'. Besides, clearance is to be obtained from the Department of Environment after establishment of the facilities for local formulation. Department of Environment after assessing and examining the product emitted during formulation of certain pesticide consider recommendation for a formulation license. Quarterly medical check up for the workers of the formulation plant is mandatory.

Pesticide regulatory policies

Agricultural pesticides have been primarily in use since early sixties. However, Pesticide Ordinance was promulgated in 1971 to regulate import, manufacture, formulation & distribution and use of pesticides. The ordinance was amended in 1980 mainly to accommodate the provision for licensing and the trade was handed over to the private sector. Pesticide rules were framed in 1985 for carrying out the provision of the ordinance.

The Ordinance extends to all pesticides, whether used for agriculture, public health or any other purpose. The Ministry of Agriculture through the Plant Protection Wing of the Department of Agricultural Extension (DAE) administers it. The Ordinance and the rules provide the basic framework for the regulation and control conforming to the proposed guidelines of the UN Food and Agricultural Organization (FAO).

The Ordinance provides for a Pesticide Technical Advisory committee, a laboratory, Government appointed analysts and inspectors required licensing of all handlers of pesticides, controlling imports, manufacture and formulation of pesticides, packaging, labeling, storage guidelines and safety precautions for handlers of pesticides.

However, implementing the legislation depends on a large extent on available expertise, laboratory facilities and field research stations. The pesticide laboratories operated by chemists, management staff including a Director, Additional Director, Deputy Director and Regulation Officer of Plant Protection.

Registration scheme

The registration scheme incorporates most of the concepts and guidelines recommended by Food and Agricultural Organization and certain features from countries such as Pakistan, India, Philippines and the United States.

Importing, formulating, repackaging, selling, holding in stock for sale and advertising of any pesticide is prohibited unless the product has been registered:

1. An application form, according the provision Pesticide Rules along with literature and a sample of the product are submitted to the Plant Protection Wing of the Department of Agricultural Extension. All submitted documents are reviewed and the sample is verified in the pesticide laboratory of Plant Protection for verification of the specification. The data requirements for registration are essentially in accordance with FAO guidelines that include: physical and chemical properties; toxicological data; efficacy data; residues and environmental effects. Foreign data are acceptable, except for efficacy and fish toxicity studies. These must be conducted in Bangladesh in accordance with prescribed guidelines.
   
   
2. Upon receipt of the results of the chemical analysis the sample is sent to concerned Government research institutes for bioefficacy tests under field conditions. The results of the efficacy trials are evaluated by a sub-evaluation committee composed of experts representing various research institutes, Department of Environment, Health and Fisheries.

The Pesticide Technical Advisory Committee, chaired by the Secretary, Ministry of Agriculture, finally grants registration to a brand of pesticide after thorough examination of all reports when it is recommended by sub-evaluation committee. A registration certificate which is valid for three years and renewable for the same period is issued by the Director of Plant Protection if the products prove effective for the intended purpose. Under the present scheme, registration may be obtained between six months to three years from the date of application, depending on the number of seasons of trials required.

List of registered pesticides

A total of 628 brands of agricultural pesticides and 170 brand of public health pesticides are registered which are as follows:

Agricultural pesticides:

Public health pesticides:

Following acceptance for registration, the applicant must submit a copy of the proposed label to the Director, Plant Protection before marketing. All labels must be printed in Bengali, must include the expiration date and must be marked "POISON" and display the skull and crossbones symbol. Color coding differs slightly from FAO code.

Labeling of pesticides

All pesticides regardless of classification carry the word 'POISON'. Only class I formulation displays skull and cross bone. Class II and class III formulation carries the word 'DANGEROUS' and 'CAUTION' respectively. Three panel labels are used which incorporates most of the features of the FAO guidelines on labels. The following information is provided on the label of the pesticide containers:

Enforcement mechanism

The label is printed in national language i.e. in Bengali.

Enforcement mechanism

Ensuring the quality of the pesticides in the market and regulating the formulation and packaging of products after registration is an important aspect of pesticide legislation. Therefore inspectors are appointed to ensure enforcement through regularly visiting pesticide dealers and collecting samples for checks on specifications. In cases of adulteration, penalties are imposed. To strengthen the registration process and to ensure enforcement of the provisions of the legislation, additional controls have been implemented. These include controlling imports, controlling the availability and use of pesticides, and licensing handlers. For example, pesticides cannot be imported unless previously registered, packed and labeled as prescribed. In addition, the importer must have an import license and proper storage facilities.

Banned or restricted pesticides

Pesticides which do not conform to the regulatory standards are not permitted for registration. The following pesticides are banned in Bangladesh for use in agriculture:

Licensing requirements of pesticide handlers

Under the provision of the Pesticide Ordinance, all pesticide handlers must obtain a license before they can engage in any business dealing with pesticides. All types of licenses are valid for a period of two years unless earlier revoked or cancelled. A renewal for a same period may be obtained by submitting the appropriate fee.

Training in the safe and efficient use of pesticides

The Plant Protection Wing, Department of Agricultural Extension, emphasizes training programs designed to meet the needs of specific target clientel. After handing over the pesticide trade to the private sector in 1981 a training program for the pesticide dealers was conducted by the Plant Protection Wing, in collaboration with ESCAP/ARSAP. Meanwhile, the industry has accepted the responsibility of training their personnel. In this context, progress has been made and pesticide dealers are being trained on safe and efficient use of pesticides by the industry.

Regulatory deficiencies and other problems

In theory, the regulatory scheme is systematic. But in practice, however, there are gaps between the policies and implementation. For example, while the intent of the Ordinance and Rules to monitor formulations and residues is commendable, the lack of facilities and trained analysts does not allow proper monitoring. Thus, specification of pesticides on the market may differ from those registered.

Lack of residue monitoring

Although the Government is concerned about pesticide residues in the food and the environment, staff and facilities to conduct the necessary monitoring programs are not available. In addition the country has not yet established legal limits for residues and depends upon Codex allowable limit which are not always proposed for all crops and major pesticides used within the country.

Conclusion

In brief, I tried to give you an overall idea of the pesticide registration, requirements, implementation process and their monitoring for maintaining the quality of the pesticide. Efforts are underway to implement FAO guidelines at all levels. In this regard a joint collaborative program among the member countries in this region with the assistance of FAO is a must.

QUESTIONNAIRE SUMMARY

Bangladesh

Selected Country Statistics:

GDP = Gross Domestic Product; GNI = Gross National Income; Hunger = Population below minimum energy requirement; FAOSTAT = latest data entry between 1998 and 2002

Institutional Profile

Industry Associations: Bangladesh Crop Protection Association

Non-Governmental Associations: Bangladesh Paribesh Undolon

Questionnaire responses: Yes = Yes; - = No;? = don't know; (blank) = no answer