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Introduction to GhanaIntroduction to Ghana’’s current pesticides s current pesticides registration framework and requirement for bio registration framework and requirement for bio

pesticides regulations in Ghanapesticides regulations in Ghana

Presented by Joseph C. Edmund, Chemicals Control and

Management Centre, Environmental Protection Agency (EPA)

Monday 27th June 2005Mensvic Hotel, Accra

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Presentation OutlinePresentation Outline

1. Introduction 2. Pesticides Control and Management Act,

1996 (Act 528)3. Pesticides registration4. List of approved pesticides; banned

pesticides5. Licensing of pesticides dealers6. Issues and challenges7. Biopesticides regulations in Ghana8. Conclusions

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Introduction to the pesticide Introduction to the pesticide registration process (1)registration process (1)

• Before a pesticide can be sold and used in Ghana, it must first be registered in accordance with the Pesticides Control and Management Act (Act 528, 1996). This is to enable the registration authority confirm that the product is safe and efficacious in normal or its intended use.

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Introduction to the pesticide Introduction to the pesticide registration process (2)registration process (2)

• The Pesticides Control and Management Act of 1996 (Act 528) makes the Environmental Protection Agency (EPA) of Ghana the lead Agency responsible for a comprehensive pesticide regulatory program. In that capacity, the EPA has the sole authority and responsibility to register all pesticides imported, exported, manufactured, distributed, advertised, sold or used within Ghana.

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PESTICIDES CONTROL AND MANAGEMENT PESTICIDES CONTROL AND MANAGEMENT

ACT 1996, ACT 528ACT 1996, ACT 528 (1)(1)• An Act to provide for the control,

management and regulation of pesticides in Ghana and to provide for related matters.

• The objective of regulating pesticides is to protect society from the adverse effects of pesticides without denying access to the benefits of their use.

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Act 528 (2)Act 528 (2)

The four main parts of Act 528 are as follows:

Part I: Registration of pesticidesPart II: Licensing of pesticides

dealersPart III: Enforcement and penaltiesPart IV: General provisions

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Definition of pesticide under Act Definition of pesticide under Act 528528

Any substance, mixtures of substances or other agents used to control, destroy, or prevent damage by or protect something from a pest. The definition also includes chemical substances that are used to attract and repel pests as well as those used to regulate plant growth or remove coat/leaves.

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Pesticides registration (1)Pesticides registration (1)

Section 1 of Act 528 states that:“No person shall import, export,

manufacture, distribute, advertise, sell or use any pesticide in Ghana unless the pesticide has been registered by the Environmental Protection Agency in accordance with this Act”

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Pesticides registration (2)Pesticides registration (2)

Registration is the process whereby the responsible national government authority approves the sale and use of a pesticide following the evaluation of comprehensive scientific data demonstrating that the product is effective for the intended purposes and does not pose unacceptable risks to human or animal health or to the environment.

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Pesticides registration (3)Pesticides registration (3)Registration enables authorities to

exercise control over quality, use levels, claims, labelling, packaging, advertising, and disposal of pesticides, thus ensuring that the interests of end-users are properly protected.

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Procedures for pesticides Procedures for pesticides registrationregistration

• In addition to submitting the completed application form, the applicant is required to submit scientific evidence or data in a dossier to support all claims for efficacy and safety of the product to be registered.

• The dossier must contain sufficient information to effectively address all pertinent issues regarding safety and efficacy.

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Structures for pesticides Structures for pesticides registrationregistration

1. Chemicals Control and Management Centre of the EPA receives all applications.

2. Three PTC sub-committees evaluate applications and submit reports to the Pesticides Technical Committee (PTC).

3. The thirteen member intersectoral PTC considers reports of sub-committees and makes recommendations to the EPA Board.

4. EPA Board takes final decision to register or deny registration of pesticides.

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ORG. STRUCTURE FOR PESTICIDES ORG. STRUCTURE FOR PESTICIDES REGISTRATION REGISTRATION

EPA BOARD

PESTICIDESTECHNICAL COMMITTEE

BIOEFFICACYSUB-COMMITTEE

TOX/ECOTOX SUB-COMMITTEE

LABELLING &ADVERTISING

SUB-COMMITTEE

CCMCTHE SECRETARIAT

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Approval categoriesApproval categories

A pesticides can be approved for use under the following categories:

1. Full registration (Valid for three years)• For General use• For Restricted use2. Provisional clearance (Max. 1 year)3. Suspended or Banned

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Provisional clearance (1)Provisional clearance (1)

• Most information required for registration of pesticide has been provided to the Agency, and the

• Pesticide does not present a toxicological risk to people, animals, crops or the environment,

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Provisional clearance (2)Provisional clearance (2)

• The agency may clear the pesticide for use without the registration, and this clearance shall be known as provisional clearance

• Shall be temporary pending the registration by the Agency of the pesticide (Section 9, Act 528).

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OperationalisationOperationalisation of Act 528of Act 528

• Even though Act 528 was promulgated in 1996, a number of problems prevented the full and effective implementation of its provisions.

• Between 2003 and 2004, full operationalisation of the Act was initiated.

• The Agency received over 300 applications for registration.

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List of approved pesticidesList of approved pesticides

A total of 114 pesticides comprising 62 fully Registered; 27 provisionally cleared and 25 banned as at January 2005. The breakdown of the fully registered and provisionally cleared pesticides is as follows:

• 38 insecticides• 10 fungicides• 33 herbicides• 3 larvicides• 1 nematicide• 1 desiccant • 1 growth regulator• 1 rodenticide• 1 biocide

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Banned pesticides (1)Banned pesticides (1)--POPs & POPs & PICPIC

• 2,4,5-T and its salts and esters

• Aldrin• Binapacryl• Captafol• Chlordane• Chlordimeform• Chlorobenzilate• Mirex• Endrin• DDT

• Dieldrin• Dinoseb and its salts

and esters• Dinitro-ortho-cresol

(DNOC) and its salts (such as ammonium salt, potassium salt and sodium salt)

• HCH (mixed isomers)• Heptachlor• Hexachlorobenzene

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Banned pesticides (2)Banned pesticides (2)• Parathion• Pentachlorophenol and its

salts and esters• Toxaphene• Methamidophos (Soluble

liquid formulations of the substance that exceed 600 g active ingredient/l)

• Methyl-parathion (emulsifiable concentrates (EC) with at or above 19.5% active ingredient and dusts at or above 1.5% active ingredient)

• Monocrotophos (Soluble liquid formulations of the substance that exceed 600 g active ingredient/l)

• Parathion (all formulations - aerosols, dustable powder (DP), emulsifiable concentrate (EC), granules (GR) and wettable powders (WP) -of this substance are included, except capsule suspensions (CS))

• Phosphamidon (Soluble liquid formulations of the substance that exceed 1000 g active ingredient/l)

• Dustable powder formulations containing a combination of Benomyl at or above 7%, Carbofuran at or above 10% and Thiram at or above 15%

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Pesticides licensingPesticides licensing

• Section 17 of Act 528 states that:

“No person shall import, export, manufacture, distribute, advertise or sell any pesticide except in accordance with a license issued under this Act”

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Categories of licenses Categories of licenses

• Pesticides activities which require to be licensed are Retailers; Importers; Distributors; Commercial Pest Controllers; Transporters; Manufacturers; Repackaging, Formulation, Warehouses and any other related pesticides activity.

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Licensing ProcedureLicensing Procedure• Applicant completes an application form

obtainable from the CCMC or any of the EPA Regional offices.

• The completed form is submitted together with two passport sized pictures and copies of all relevant documents.

• An inspection is conducted upon submission of completed form.

• A decision to issue a license or otherwise is based on the evaluation of inspection report and the assurance that applicant satisfies all conditions as required by the Act.

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Enforcement: Part III of Act 528Enforcement: Part III of Act 528

• A member of the relevant sub-committee of a District Assembly so authorised or an inspector appointed under section 15 of the Environmental Protection Agency Act, 1994 (Act 490) may-

• inspect any equipment used or to be used in applying pesticides;

• inspect any storage or disposal facilities or areas used for the storage or disposal of pesticides;

• inspect any land actually, or reported to be, exposed to pesticides;

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Enforcement (2)Enforcement (2)• investigate complaints or injury to human

beings and animals, or damage to land and pollution of water bodies resulting from the use of pesticides;

• take samples of pesticides applied or to be applied;

• monitor the sale and use of pesticides;• examine and take copies of a license or

other documents required by this Act or any regulations made under this Act.

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Issues and challenges (1)Issues and challenges (1)

• Since the operationalisation of the registration scheme in August 2004, the EPA has received support from its collaborators both locally and internationally to strengthen the scheme. However there is a lot to be done.

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Issues and challenges (2)Issues and challenges (2)The issues include:• Quality control aspect of the

registration.• Post registration monitoring and

surveillance by pesticides inspectors• Capacity building, staff and logistics • Enforcement (Prosecution of

offenders)• Education and awareness

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Requirements for Requirements for biopesticidesbiopesticidesregulations in Ghana (1)regulations in Ghana (1)

• Biopesticides have emerged as important pest management option with rapid development in research and commercialisation especially in the developed world.

• To guarantee their safety, measures are being developed to regulate the production and use of these products as with conventional pesticides.

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Requirements for Requirements for biopesticidesbiopesticidesregulations in Ghana (2)regulations in Ghana (2)

• In most developing countries, regulatory framework governing production, registration and use of biopesticides are not well developed.

• For instance there is no specific legal framework in Ghana to govern the registration of biopesticides even though some bio control agents have been introduced especially in our pest management system for sometime.

• The current regulatory framework for pesticides is not specifically relevant to biopesticides.

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Requirements for Requirements for biopesticidesbiopesticidesregulations in Ghana (3)regulations in Ghana (3)

• The existing requirements and procedures for conventional pesticides are extended to regulate the few biopesticides received. there is no doubt that there are specific needs this area.

• As they become increasingly important as pest management options, and in view of the potential risk and increased commercialisation in Ghana, it raises the need for stringent controls.

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Requirements for Requirements for biopesticidesbiopesticidesregulations in Ghana(4)regulations in Ghana(4)

• Regulations are required to control their registration, importation, distribution, use and manufacture, and to protect the environment from all potential risk associated with biopesticides.

• Need to develop specific data requirements• Need to develop expertise for evaluation• A separate review procedures from that for

conventional pesticides is required.

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Conclusion (1)Conclusion (1)

• The use of biopesticides in Ghana as compared to conventional pesticides is at the moment very low.

• With recent events regarding concerns raised about food safety especially in the horticulture industry, there is a huge potential for development of biopesticidesas an important pest management option.

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Conclusion Conclusion

• This calls for the establishment of structures and development of the requisite expertise and regulations to effectively handle biopesticides in all its forms to ensure their efficacy and safety to users and the entire environment.

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Thank you