As the Thai chemicals regulation committee slaps a "hazardous substance type 1" label on 13 herbs used as organic pesticides, questions are mounting.

The 13 herbs and plants on the lsit are neem, lemongrass, turmeric, ginger, Chinese ginger, African marigold, Siam weed or bitter bush, tea seed cake, chilli, Chinese celery, ringworn bush, glory lily and stemona.

I did a quick check on whether there was any evidence that, say, ginger works as a pesticide and sure enough there is. In 2007, for example, researchers at Annamalai University in Tamil Nadu, India found that essential oils extracted by steam distillation from Zingiber officinalis (ginger) exhibited great effectiveness as a repellent against the filarial mosquito Culex quinquefasciatus.

The list announcement was made on 10 February by the Department of Agriculture, which sits on the Hazardous Substances Committee responsible for maintaining the list.

Being placed on the list means that growers, manufacturers, importers and exporters of pesticides made from these herbs will have to follow the same safety and quality control regulations applied to their inorganic competitors, else face six months in jail and/or a fine of 50,000 baht.

Rachada Singalavanija, Director-General of the Industrial Works Department under the Industry Ministry, insists that inclusion of these plants on the list was requested by the Department of Agriculture, which is said to have found many organic farmers concerned about fake or chemical-contaminated herbal pesticides.

Who could question such a desire to improve product safety?

Firstly, herb and plant-based pesticides are an effective, sustainable and appropriate technology for a developing country whose farmers can ill afford chemical pesticides in any event. Over-regulate their use with a regime designed for globally-marketed chemicals and their cost shoots up out of farmer's reach without corresponding benefit.

Try and overlay this kind of heavy-handed approach on the following description of how such plants are used in India, taken from The Hindu's Farmer's Notebook column by M.J. Prabu in April last year:

"For example [Ms. Rajareega, Raasi organic farms, Muthupatti] uses 5 different leaf extracts (eindhu ilai karaisal in Tamil) derived from Calotropis (called y erukku in Tamil), Jatropha curcas (kattu amanaku in Tamil), Neem (vembu in Tamil), Guduchhi/Amruth (seenthil kodi in Tamil), Chaste tree (nochi in Tamil), Malabar nut (adathoda in Tamil), Kalmegh (siriyanangai in Tamil), Clerodendron (peenarisanghu in Tamil) and Usil (arappu in Tamil). These plants are commonly found in all villages. About 1 kg of leaves from each plant is taken and powdered and then ground into a paste. It is then mixed with 5 litres of cow’s urine.

The concoction is then diluted in 5 litres of water and left undisturbed for 5 days. When required for using about 500 ml of this concoction is diluted in 10 litres of water and sprayed over the plants, she explains.

Ginger garlic extract: Another tried and proven mixture she uses is ginger garlic extract (called inji poondu karaisal in Tamil). About 1 gm of ginger and garlic each, 2gm of green chilli and 5 litres of cow’s urine and water are taken. The garlic, ginger and green chilli are ground into a paste and mixed with cow’s urine and water. After 10 days the mixture is filtered and used.

The prescribed quantity is about 500 ml of this solution diluted in 10 litres of water which can be sprayed over the plants."

And regarding the appropriateness of this "technology": "if using chemical pesticides and fertilizers for growing a crop in a hectare works out to about Rs.6,000-7,000 the cost of growing the same crop using organic inputs may come to only about Rs.500 - Rs. 1,000, according to Ms. Rajareega of Raasi organic farms at Muthupatti village in Sivaganga district, Tamil Nadu."

There are concerns, therefore, that this list change will impede much needed progress on sustainable agriculture in Thailand.

Sanitsuda Ekachai, Assistant Editor (Outlook), Bangkok Post, writes:

"Research shows that about 70 per cent of chemical pesticides used in Thailand are not allowed in the West. They are also categorised by the World Health Organisation as highly hazardous, if not extremely hazardous.

In just two decades, Thailand's use of chemical fertiliser has increased four-fold and chemical pesticides six-fold.

As a result, 81 per cent of all reservoir water is contaminated with DDT and other toxic substances, 17% of farmers have pesticides in their bloodstream, and nearly all fruit samples have residuals higher than safety standards, according to a study in 1994.

In the period 1988-93, pesticide-related illnesses also increased 17-fold.

Given these statistics, the past decade has seen the growth of farmers' and consumers' green movements to reduce the use of toxic farm chemicals and to promote organic farming.

For the farmers, apart from a desire to restore their soil and their health, they have also realised that the extremely expensive farm chemicals are the reason why they cannot make ends meet.

Hence their return to folk knowledge, to switch to herbal pesticides by using a variety of indigenous plants to get rid of dangerous pests while keeping the good insects safe.

From individual use of herbal pesticides, the growing market for organic produce has led to commercial production of herbal pesticides as a cottage industry in many locales."

A second problem with the list revision which is giving rise to questions is this: why does this hazardous substance label apply to derivatives of these herbs in pesticides, but not in herbal medicine?

Thirdly, these plants have been added to the list at the same time as 23 substances have been taken off it, substances including natural gas, copper sulphate, sulphur and cobalt-60, a radioactive isotope.

Particular attention is being paid to the Committee's removal of sulphur from the list as its removal is thought to be of benefit to 10 giant sulphur importers who are facing criminal charges over illegal imports last year.

A source at the Customs Department told the Bangkok Post that after this case was forwarded to the Department of Special Investigation (DSI) for investigation, the Industrial Works Department was "lobbied" to withdraw sulphur from the control list, which it duly did through its chairmanship of the hazardous substances committee.

Fourthly, groups are concerned about a lack of transparency and procedural regularity in the committee's work.

The Bangkok Post reports that Biothai, a non-government organisation working on organic farming, indicated that it would file an application for judicial review of the decision if it is not revoked within seven days.

Alternative Agriculture Network separately announced that it would submit a petition to the Upper House' committee on good government to investigate the members of the hazardous substances committee for conflicts of interest between some committee members and multinational agricultural companies that stood to benefit from the change.

A source on the committee is reported in the Bangkok Post as suspecting "a former Agriculture Department chief, a northeastern politician who is serving a ban from politics but whose party is in the coalition government, and a multinational chemical company [who] would benefit from the announcement."

Both advocacy groups point out that the list was revised without any public consultation or even transparency.

In a similar vein, the Bangkok Post also noted the undue haste in making the change: "A source on the committee on hazardous substances questioned the rush to approve the announcement. A representative from the Public Health Ministry opposed it at a Dec 24 meeting. A public hearing was planned for tomorrow but the announcement took effect on Feb 3."

UPDATE:

Agriculture Department chief Somchai Charnnarongkul has denied allegations that the listing was aimed at curbing the use of natural pesticides in favour of farm chemicals produced by multinational companies, the Bangkok Post reports:

""There is no such wicked idea in our heads. The department has spent more than 20 years researching and promoting herbs as alternatives to farm chemicals. We stand firm by our policy to cut the use of toxic farm chemicals," he said."

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