History 

After years of intermittent discourses, and regular alarm bells raised by many in and outside the agricultural sector, a new pesticides Bill finally sees the light of day in Mauritius. As first glance, a great initiative seems to have been planned and activated, as the government has been very well-aware that since the last few decades, pesticide levels have been cropping up above residual maximum limits, without in fact a well-defined national strategy for rigorous testing, management and policing the abnormalities and outliers. 

Validity of Government Data 

Data that drove this Bill is based out of monthly samples collected from laboratories for the Ministry of Agro-industry (its Food Tech Labs) which had in itself shown latent weaknesses, in the sense that, no one really explained why in 2018 the levels of pesticides ‘actually tested’ suddenly shot to 182, when in the past it was seven time less, whilst the rate of pesticides above limits remained at a fixed ~ 6 % mark. In the past (we know it by the same trending of the data set) the level above max. limits, per the said sampling size, had at times risen to as high as 40%. Did all planters suddenly all modify their spreading habits? I do not think so! 

There seems to be a real gaping hole when it comes to the statistical validity/rigor/trending analysis/analytical testing of the government data, especially when we know that the range of pesticides being targeted is still just a nimble 60 substances per the first schedule(FS) of this Bill. 

Independent data and EU guidelines show a range of pesticides results monitored to be actually above 12,000! As reference, here is what we read in the article, TrAC Trends in Analytical Chemistry, volume 29, issue 1, January 2010, Pages 70-83, which discussed European Commission proficiency tests for pesticide residues in fruits and vegetables. The article states:  ‘….between 1996 and 2008, these EUPTs (European Proficiency Test in Fruits and Vegetables) generated an important database of more than 12,000 pesticide-residue results using multi-residue methods, which have led to very valuable achievements in aspects of analysis (e.g., sample preparation, data dissemination and statistical evaluation). They also made possible an overview of the effectiveness of the EUPT as an important tool in developing quality-control results in pesticide-residue laboratories..’ 

Gaping Questions: 

Some questions need to be urgently asked, which I hope the honorable Minister will read and respond: 

• Why are we then stuck with a restrictive list of 60 pesticides in the first schedule of this new pesticides Bill for Mauritius? 
• Are we more proficient and rigorous than the EU database? 
• Do we know something, that they do not? 
• Are we using a multi-throng analytical approach to test and collect baseline data? 
• If not, how can we be sure that we have a hit list of the optimized list of pesticidal bad actors used in our fields? 
• The EU seems to be collecting a vast volume of data on active substances and pesticides? Did we consult their database and did we harmonize with ours? 
• Why do we trust food products (rice, lentils etc) that are imported into our territory? 
• Can we trust the often conveniently written ‘certificate of analysis’ of imported foodstuffs? 

Recent Debate in Parliament 

I found it very heart wrenching that in the recent debate on this Bill on 29th June at the parliament, I read, ‘si la PNQ a fait sourire plus d’un, il n’y avait pas un gros intérêt lors des débats sur le Use of Pesticide Bill’. This should not have been a casual debate. There was (based on witness reports) no cross-party impetus to really tease apart the weaknesses inherent in this Bill, for the obvious general interest of the health of the public. This is a plainly mediocre response by our esteemed members of the assembly, to say the least, and a serious failure, to address the weaknesses latent in the Bill. 

Simplifying the Issue for All and Root Problem: 

I wanted to distill my thoughts to as simple as possible to all my compatriots, so they understand what is really at stake here: 

Assume that folks in Mauritius use a range of brands of washing liquids for their dishwashers at home. Assume it is from a variety of only 10 different brands only. There will then possibly be residual levels of detergents in our diet, if we are overloading the washer with detergent liquid, not washing our plates multiple times after dish washing cycles, cutting short the wash times, or possibly there could even be a mechanical defect in the equipment. Assuming, hypothetically, that we decide to take severe control measures to protect our health, and decide to test residual detergents via a private lab, it would be unthinkable for us to ask the local laboratory to ‘just’ simply test for 2 of those detergents when in fact the other 8 might be as dangerous as the other two. 

This is the real root problem and issue at stake here with this new pesticides Bill. 

We have restricted ourselves to a shortened list when in fact the potential of seeing active substances and pesticides in food and vegetables is much more widespread. It suffices to read European Commission guidances to understand how the ‘war’ on pesticides overuse is truly a vast enterprise, and often involves multi-residue detection methodologies to understand what enters/does not enter ones territory. Is the Food tech laboratory of the Ministry truly in total control of the widespread nature of pesticides usage in the regional fields of Mauritius, and even outside of Mauritius. If it was, the top parade list in the catchment zone of the first schedule (FS) of this Bill would have been much more extensive, and much open to what we do not in fact know, and with specific clauses allowing for their facile regular updates. 

Rigor and Integrity of the Pesticide Database: 

The Bill clearly does not take into account the worldwide knowledge base of pesticides proven to be major risks for public health. It bases itself on an arbitrary restrictive list of ’60 pesticides’ in the FS captured by a statistically flawed data set, with no rigorous correct trend analysis linked to real time data on the fields. This is a serious lacuna and should have been brought up during the recent debate in parliament. Does EU collect a data base of > 12,000 pesticide residue results for mere pleasure? The EU collects a massive list of pesticides, and active substances in fruits, vegetables, frozen products per these lists: a) Active Substances, Regulation (EC) No 1107/2009, and b) Pesticides EU-MRLs Regulation (EC) No 396/2005. 

The EU is aware that new substances (many from synthesis) are regularly being commercialized and used worldwide (often without adequate controls), such as, many countries have a serious lack of control/s on what they inject into their fields. So as a fortress to this unwanted ‘invasion’, compiled lists are assiduously updated, and supported with acceptable limits and concurring toxicity tests. The most recent noted few weeks ago (see below), where additional pesticides were added to the open database of the EU lists. 

‘…Extension of the approval periods of the active substances chlorpyrifos, chlorpyrifos-methyl, clothianidin, copper compounds, dimoxystrobin, mancozeb, mecoprop-p, metiram, oxamyl, pethoxamid, propiconazole, propineb, propyzamide, pyraclostrobin and zoxamide..’ 

Conclusions: 

In brief, why is the pesticide Bill restricting itself on a pudgy little list of 60 substances. I see a lack of scientific rigor, a lack of knowledge of the presence of pesticides in the agricultural systems in Mauritius prior to promulgation of this Bill, and a rush, to show the public, that the government are in control, when it fact the story is inherently incomplete. Without a real and fundamental baseline, we dared to came out with a fast-tracked Bill without constructively arguing and discussing additional works and additions that would make it an effective government legal instrument to curb a major health hazard for the population. I agree that it is a start, but is it a false start? 

Worst of all, why is the Bill silent about imported food stuffs, and frozen foods. Is there really a check at port of entries for pesticide content in rice, lentils and other ‘grains’ imported, or does the government just accept the certificate of analysis for these imports, and totally and fully trust the systems from exporting countries such as, Pakistan, India and Bangladesh. On the other side of the argument, why does the EU in fact not trust these same imports, and regularly blockades certain imports, and forces regulatory bodies to check/report everything that comes into their borders? 

There are some major works ahead for the pesticides regulatory body to be instituted per the Bill. I think a thorough mapping should have been done regionally in Mauritius, supported by both private and government laboratories, to collect baseline markings of pesticide usage and relevant trends. The Bill should hence have had detailed guidelines on ‘best agricultural’ practices and required implementation programs. Just setting out ‘fines and penalties’ is not good enough as a deterrent, when we are still in our infancy, with regards to pesticides control in Mauritius. Lastly, I see no information addressing the use of active substances in fields heavily relied upon by the sugar industry. Why is the elephant in the room not even being addressed in this new Bill? Are we so sure that our soil mass does not already have left over reservoirs the side products of pesticides, herbicides etc used without respite for decades? 

The road is to effective pesticide over use and controls is arduous and long. It is a small step forward, and sustainable agricultural practices in Mauritius in its infancy. Much remains to be clarified by the Ministry of Agro-Industry. 

Rattan Gujadhur, PhD, MBA 
Saratoga, California, USA 
July 1st 2018