Dear Minister of Agro-industry and Food Security, Firstly, congratulations to you and your competent team for the enactment in our illustrious Parliament, of the new the Use of Pesticides Bill (No V1 of 2018), incorporated as we know, to supplement important aspects, not covered under the umbrella, of the Dangerous Chemicals Control Act (1970). I know this new piece of legislation has been incorporated into our system for the greater good of our society. The public is supremely grateful for this brave new development.

I want to declare, as I start, that I have no political affiliations. I do not support any political party locally. I made phone calls in favor of the Obama campaigners almost 10 years ago, but that is the closest I ever got into political activism (in the US). I have been away (sadly) from Mauritius for almost 25 years.

I write today to expressly ask for your involvement to carefully authenticate and audit the implementation of the new pesticide bill. I have grave doubts that it is being implemented in a smart, practical and decisive way. Although it covers a relatively short list of pesticides, it has been clear to many independent experts across the world that the list of pesticides in the first schedule of the bill is not exhaustive, and the legislation should have been more promiscuous in looking into, and catching other chemically sensitive and injurious bad actors. 

Like others have mentioned in locally published articles, “a provision should have been included in the Bill” to expand on, research new pesticides possibly not caught in the current net, actively and regularly update the Bill to widen its appeal, as well as relook at new limits for “existing” and “currently under the radar” pesticides. I do not really understand how we can possibly be functioning on a very puny little limited restrictive list of pesticides in the Bill, itself possibly, based on data collected by the government labs, that so far looks statistically and functionally poor. In a series of investigations by l’express in 2016-2017 (using private accredited laboratories to support their thesis), the newspaper seems to vehemently disagree with governmental lab records, and showed very high levels of pesticides in the samples.

About 20% of samples analyzed had residues above maximum residue limits (MRL). MRL, as you surely know, expressed in Parts per million, is a measurement of a set limit of the highest level of pesticides tolerated in or on food, when the pesticides are effectively applied. The data that they had provided was never contested, disproved or contested by any governmental institution. This created a sense of serious distrust by many in Mauritius. Is the accounting, collection and testing of samples across the country being done consistently, Honorable Mr Minister? 

If this is the case, and whilst we are still getting a good and strong grip on testing, sampling and monitoring, how are we possibly going to “train” planters on effective application of their products, or even train the “trainers”, and implement a vast rigorous new strategic policing plan of the new Bill. There is a grave doubt in the public domain, of our local ability to deliver on this. Do you agree? If not, what are we doing to curb the situation, and gain grounds?

What are you really doing to remediate this, Honorable Mr Minister? How are we making up for serious lost time, of never having actually really curtailed decades of bad pesticide practices in Mauritius. I doubt whether this is all getting fixed, as we speak. 

In the United States, for example, the Food and Drug Administration is always issuing updated guidance’s on Good Manufacturing Practices, to educate manufacturers of drugs. Even then, the battle to have safe and efficacious drugs on the market, is far from being won. In the pharmaceutical industry in the US and EU, there has been a serious re-look at the integrity of data, and hence all equipment qualification and validation are actively sought for and after, and companies regularly get audited (and shut down too) just on that specific aspect of their operations.

I personally and strongly question our analytical abilities to test and monitor the widespread use of pesticides in Mauritius (despite this Bill). Are our MS-MS, GC-MS, LCMS analytical equipment validated, and are we training ourselves to be the best in class to effectively run the locally collected data? Or are we outsourcing the testing because we are unable to tackle sheer complexity?

Far from saying we are incompetents (I truly and genuinely admire the local effort), I am just asking if our equipments are/will be validated independently, to cover the wide chemical array of pesticides, that flood our market legally and illegally. Is this why the Bill has a restrictive small list of pesticides, because we are, in fact, truly not equipped to throw a wider brave net to test and monitor? As you know testing also means having the right library of substances, as references and standards (from reliable sources), to certify and manage the testing. Are we equipped to qualify and quantify the said records?

The right Honorable Mr Minister, I have grave doubts, at least in this current state of affairs, and present time, about our ability to do just that, and I question, and wish to have your attention to look into effective nononsense implementation of proper analytical rigor and testing of pesticides levels in food stuffs, whether imported or cultivated locally. I wrote to you with great earnestness, and hope that you will ask your staff the right question/s, and shed light to the public about the right efforts being applied, without gimmicks. 

I write on behalf of all small planters, as well of course, all members of the general public. I especially and specifically avoided to discuss the connectivity between cancer rates and pesticides outspread in Mauritius, because I do not honestly have the complete data or picture. However, I decided not to wait anymore, and address the urgency to effectively apply the new Bill in the interest of all Mauritians. For their “bien-être”, I hope a more conscientious effort will be put into this from your team.