Sunday, July 8, 2007

KVM representation to Director PGIMER on Pesticides and Health

August 31, 2005
Dr.K.K.TalwarDirector – PGIMER
Chairman,Expert Group on Health impacts of Pesticides,Chandigarh

Subject: Environmental Health Crisis in Punjab – SlowPoisoning of Punjab through Pesticides – Immediate and Long-termEnvironmental and Health remediation needed – Restoration of Eco-Agriculture only way out

Respected Sir,

Through this submission we (scientists, doctors and members of thecivil society groups working in the field of public health,environmental health, sustainable agriculture and ecology) wish tosubmit our views on the serious environmental health crisis that isbeing reported from the villages of Punjab, in particular regardingthe high incidences of cancer cases and deaths and the traces ofpesticides detected in blood samples in Malwa region.

Reports of high incidence of cancer and other illnesses that couldbe linked to pesticides are emerging from the cotton belt of Malwaon a regular basis in recent times. The experience of such adversehealth impacts by members of the farming community cannot be denied –this is evident both from hospital records in the region as well asfrom informal discussions with people in the villages here. Civilsociety groups and media have been regularly reporting these figuresand experiences to the larger public. Just one private hospital inMuktsar has records to show that 1400 cases of cancers haveconsulted the hospital in just the last year!It is also well-established that cancers and pesticides are linkedand that certain types of cancer are related to pesticides more thanother factors. The higher incidence of pesticides-related cancers[within various types of cancers] in the Malwa belt cannot be deniedeither.Pesticides, many of which are endocrine disruptors, teratogens,mutagens, cholinesterase inhibitors and so on, are known to cause avariety of other human health impacts too. A study by GreenpeaceIndia and Kheti Virasat Mission in 2003 showed that thedevelopmental abilities of children in high-pesticide consumingareas like Bathinda are significantly lower than children in lowpesticide-consuming areas, pointing out that the next generation ofthe farming community in the state is also being put at risk withpesticides.

The use of pesticides, many of them in high volume, of very toxicclasses of pesticides and banned long ago in other countries, hasover the years come to stop killing the pests (due to development ofresistance in pests) and has started killing human beings and otherbeneficial fauna instead. In such a situation, farmers are beingbranded as negligent, erratic and ignorant. Farmers have startedmisusing and overusing many pesticides as resistant pests need morepesticides to kill, for which they are not to be blamed. The packageof practices which the PAU recommends have not only become archaicbut completely violated - the scientists and the extension wings ofthe PAU and the department of agriculture stand helpless as more andmore pesticides keep appearing in our vegetables, fruits, soil,water and human blood and tissues.Punjab has always been a state that showed the way forward for thecountry in the field of agriculture. Our people are supposed to bethe healthiest in the nation. But today Punjab is a mauled figure.Its people are getting less and less healthy. Its farmers aregetting more and more depressed, indebted and disillusioned withagriculture. Our farming – natural and organic as it used to behalf a century back - is now fully chemical and pesticide (poison)driven. More than 50% of our cost of cultivation in most crops goesfor chemical fertilisers and pesticides. Today Punjab, just onesmall state in terms of its agricultural area 1.5 % of totalgeographical area and near 2.5% of total agriculture land of India,consumes more than 18 % of the total pesticides used in thecountry. We believe this is a shame and speaks very badly of ouragriculture research and extension work as well as our farmingcommunity – that so much of poisons should be used to produce ourfood and crops. It's a shame especially in a new brave world wheremore and more countries, farmers and consumers are moving theorganic way and becoming conscious of the safety of the food theyeat and the water they drink. Punjab still continues to consume somuch of poisons in the name of an old and now derelict method ofcrop protection – by using pesticides. We hope the Expert Committeethat the government has set up recognizes this concern.We must end this vicious cycle of agro-chemicals with sustainable,sensible, safer methods of crop production. Organic Farming, No-Pesticide management (NPM), IPM etc, especially in Cotton, haveproven to be feasible and viable as farmers in other states aredemonstrating.

Studies done by the PPCB-PGIMER have concluded that pesticides usedand detected in the Malwa region could be one of the main reasonsfor the high incidence of cancer in the region. We are glad thatthis study initiated on the personal interest of the Chief MinisterCapt. Amarinder Singh, about two years back, has been able toidentify the main causes of this environmental health crisis amongthe people of Punjab.But with pain we wish to bring to your attention theirresponsibility on the part of some of the officers of the healthdepartment who are undoing the results of the PPCB-PGIMER study,without any scientific basis or understanding of toxicology and theeffects of pesticides on ecology and human health.It has come to public notice that the state health department alongwith some of the scientists of the PAU is negating this scientificand first ever large environmental epidemiological study done inPunjab by PGIMER with the support of the PPCB.Sir, what has been happening in the last few weeks can only betermed as Environmental Offence. It is already a shock thatPesticides have been detected in human blood and that the prevalenceand incidence of cancer in rural Punjab is increasing alarmingly.While public concern on this issue is wide and deep, we are equallyshocked to see that there is a concerted effort from many officersin the above-said departments to spread misinformation and dilutethe issue, thereby not only killing the seriousness of the matter,but abetting further continuance of the mistake of using more andmore pesticides in the fields. This official apathy to recognise thetruth in this matter is an act against the interests of Punjab andits people. The PPCB-PGIMER study was a scientifically planned andexecuted cancer-prevalence epidemiological study in selected highpesticide-exposure geographic areas of Punjab and this study is aclear indicator of the grave situation Punjab has fallen into.

The study released by the Department of Health and Family Welfare[DH&FW] can in no way be called a study and is only a collation ofdata, irresponsibly collected with no specific objective. This wasdone on the basis of unscientific sample size, sample selection,methodology, data validation and statistical analysis. This raisesdoubts about the vested interests that our health department seemsto want to serve.Trying to extrapolate the results of such an ill planned study tothe whole state of Punjab and that too to compare it with anexhaustive epidemiological geographically localized study is, to saythe least, a perverse attempt to discredit one of the nation'spremier medical research institutions – the PGIMER, Chandigarh.It seems that the Department of Health Services is deliberatelytrying to create confusion about PPCB-PGIMER study by saying thatits sample size is not adequate (Population of 1,83,243 wassurveyed).Ironically, the same health department was part of whole processduring PGIMER study. Since PPCB-PGIMER study was reviewedperiodically by a expert group which include DHS also besides othereminent scientists. This study was accepted by this group beforebeing made public. Even a representative of DHS had singed thereport on the behalf of DHS .Hence it is a consensus documentbinding on all including state health department. But, suddenlyhealth department had taken a complete U – turn.. Now the healthdepartment saying that sample size of PPCB-PGIMER study by is notadequate (incidentally, nearly one lakh people were surveyed). Theyhave even gone to the extent of questioning the findings ofIndustrial Toxicology Research Centre, Lucknow (a CSIR institute,which is the nodal centre for the UNEP sponsored Regionally-BasedAssessment of Persistent Toxic Substances and also the nodal centrefor the National Implementation Plan for the Stockholm Convention onPersistent Organic Pollutants) and the Quality Control Laboratoryfor Processed Food, Department of Post Harvest Technology, PAUwhich had done laboratory tests on behalf of PGIMER.The Centre for Science and Environment [CSE, New Delhi] foundpesticides in the blood of our fellow Punjabis. The CSE has done aservice to the general public of Punjab by drawing attention to thisvery important and urgent issue. Studies carried out in variousparts of the world by reputed research organisations have founddangerous levels of pesticides in the human body that can manifestas diseases at some later stage. But it is for the first time that aresearch organisation has come out with such startling data on thePunjabis. It was the duty of state health department to take noticeof issues like this whereas in Punjab the entire debate onenvironmental health crisis was initiated and regularly pursued bythe civil society groups. Unfortunately, instead of responding tothe crisis with initiation of mitigation measures, as is the mandateof the health department, and instead of encouraging and involvingthese civil groups in the process, the department seems to be keenon discounting all the evidences emerging and the efforts by civilsociety by discrediting them and branding their initiativesas 'false hue and cry' and 'unwanted panic'.Interestingly, many questions remain about the health department'srecent study on pesticides. The department did not find anypesticides in 235 blood samples taken from 12 districts and testedin the State Forensic Laboratory. One wonders whether the StateForensic Laboratory actually looked for pesticides; if so, whatmethodology was used, what equipments, what validation methods andwhat were the results and the graphs. Moreover, using such a studyto invalidate the PPCB-PGIMER study is itself ridiculous, as theobjectives and methods of the two studies were quite different.Another serious matter of concern is the statement made by the In-Charge of Patiala Laboratory about pesticide residues in human body.Dr. D. C. Sharma believes that pesticides get metabolised in thebody and are passed out in urine or excreta. He is of the view thateither pesticides get metabolised or a person will die of exposure.This is a very simplistic, ill-informed understanding ofpesticides. Each class of pesticides and each pesticide has a verydifferent toxicological profile and impacts on various media aredifferent. Hence, such a simplistic understanding of toxicology,especially from a responsible officer in charge of a public healthlab is dangerous for the good of the state.Several experts including senior toxicologist Dr. Prahlad K. Seth,Former Director, ITRC, Lucknow clearly says that it is just notpossible that chlorine (contained in many of the Organochlorinepesticides) doesn't leave behind any traces.Dr Sharma of the Patiala Lab has naively asked how the residue foundby PGIMER had pesticides which were banned in India two decadesback. This shows his ignorance about the Persistent OrganicPollutants or POPs.The `pesticides in blood' issue came into light with the CSEDirector Ms. Sunita Narayan releasing their study to the media on7th June, 2005 at Chandigarh. The Punjab Government swung intoaction only after that, ordered an enquiry and constituted a HighPowered Committee to look into this issue. With appreciablepromptness, on 25th July 2005, in a meeting of the expert group heldat PGIMER Chandigarh, the health department declared – "NO PESTICIDEFOUND IN BLOOD"! In just 40 days, they got 235 blood samples testedfor at least four groups of pesticides. This is simply impossible –both the process of testing and the results are not believable.Tests of breast milk even in an urban setting like New Delhi haverevealed pesticides in it and here our health department has notfound anything in as much as 235 samples in a study in as short atime !!It is important to know that within five days of the CSE report theofficials of the Patiala Laboratory had gone to the pressclaiming "No Pesticides in human blood, urine and vegetables". CSEstudy was released on 7 th June 2005 and on 12th June, the ChiefChemical Examiner had made a claim based on his findings in 2500cases of viscera examination. According to media reports, a clinicalstudy was conducted at State Chemical Laboratory, Patiala on thepossibility of insecticides used over crops and no poison has beendetected in the substance of any eatable or vegetable tested. Theyalso add that samples of blood and urine of human beings obtainedfrom different sources such as blood banks, clinical laboratoriesand volunteers have also been tested for traces of insecticides andpesticides. None of these samples have tested positive for anypoison. This statement was also reported in The Tribune dated June13, 2005.Incidentally Chairman of Agro-Chemical Promotion Group Mr SalilSinghal had also addressed the press conference refuting CSEfindings and on June12 and on the very same day the pressstatement was released by State Chemical Examiner from Chandigarh.What a interesting co-incidence !!It was demeaning to see how they contradicted the CSE study withoutany basis, and that too within five days. All they wanted to say isthat "The situation is not alarming". Interestingly two thingsmatter much here:a) The conclusions of Patiala laboratory and the logic of Agro-Chemical Promotion Group are so very similar.b) The haste with which they wanted to hush up the matter waslike silencing a crime.Many questions raised below remain unanswered:a) The Patiala Laboratory study was done very secretively. Whyhave they not revealed the study methodology and results even in theexpert group meeting held at PGI Chandigarh on 25th July? Why do notsuch studies have a proper report or a document? Who are theinvestigators and who are the experts who reviewed this study?b) Why are the conclusions given by Director-Family Welfare(DFW) very much similar with the arguments given by the Chairman ofAgro-Chemical Promotion Group? (Both are of the viewthat `pesticide residues' is not an issue in Punjab). The DFW hadgone to the extent of claiming that state level average of Cancerincidences of Punjab is very much lower than the national average –however, he has not made the source of his data clear. They saidthat prevalence of cancer is 120/lakh population in Punjab and this,they claim, is comparable to national prevalence. As the issue ofhigh cancer prevalence in Punjab is related to rural areas ofBathinda and Giddarbaha, we have to compare it with rural areasmentioned in National Cancer Registry Program of ICMR. The datastates that the incidence rate for male and female populations is46/lakh and 57/lakh population respectively in rural areas for India!c) The Department, according to their statements, had coveredfour districts – Mansa, Bathinda, Faridkot and Muktsar comprising ofnearly 1000 habitats and villages beside towns in just three days!!It is not clear what methodology was adopted for this survey. If thehealth department compiled this information from its paramedicalstaff then they should have visited each and every house. If door-to-door survey was conducted then the health staff would have visitednearly three lakh households and would have filled up as many surveyforms. Is this possible in three days? Or did they adopt any othermethodology to do such an exhaustive exercise? Every epidemiologicalstudy has a requisite protocol to be followed and a scientificmethodology to be adopted. What systems were followed in the study?What was the study design? What was the implementation mechanism?What was the time frame? Who was the Principal Investigator?d) Does the Patiala Laboratory have more expertise than ITRC?From where did they collect their samples? Did they take samplesfrom farmers, their families and farm workers or others who had longterm occupational exposure? What tests were carried out and whatwas the protocol followed? What instruments and equipments wereused? Do they have Gas Chromatograph (GC) or GLC with electroncapture detector for organochlorine, nitrogen, phosphorous detectorfor Organ phosphorous? Do they have an accredited lab for pesticideresidual analysis? Our information tells us that the ChemicalExaminer does not have a GC and they are working with a lesssensitive technique of THIN LAYER CHROMATOGRAPHY. To detectpesticides in blood a scientific residual analysis is required andfor that we have to detect pesticide traces to the extent of PPM orPPB. It is very doubtful whether the Patiala laboratory is capableof undertaking this exercise.Interestingly, these questions were asked in many a platform and theDirector Health & Family Welfare did not have any answer to thesequestions because of a simple reason – there were no proper surveysundertaken. The Health & Family Welfare department may swear by theauthenticity of the survey and data produced but the circumstantialevidence clearly indicates that a scientific fraud has beencommitted.According to news that appeared in Times of India Chandigarh editionon July 20 with dateline from Bathinda and Faridkot, the healthworkers had gone to the villages and announcements from loudspeakersin village gurudwaras were made to get the name of cancer patientsregistered at the health center in the village. In a large number ofvillages there was no announcement and hence no collection of data.The situation seemed to be more fudged up in urban areas - a largenumber of cancer patients in towns still have no knowledge about anysurvey.In Faridkot, most of the medical officers were asked on July 5thevening to submit the report of cancer patients in their respectiveareas by 12 noon on July 6. So, in some villages the auxiliary andparamedical staff members made the effort to reach gurudwaras forthe said announcements and in many other villages, the survey reportwas filled as per the whims and fancies of staff members.We request, for the sake of protection of public health, that athorough investigation be done to unveil the truth behind thisresponse from the Health Department, including an investigation intothe fraudulent way in which they went about manufacturing the studyreport. If it is true that the health department had indeed donesuch a thing, they should be made liable for committing a scientificfraud with intent to cause public harm and criminal prosecutionmeasures be taken against the officers responsible.We would also like to remind you that about three years ago, it wasthe same department which set aside the cancer prevalence findingsat that time. It was the same system through which the departmentfound nothing alarming even after high number of cancer cases werereported in villages like Jajjhal and Guiana even after it wasinstructed to take up a survey by the Hon'ble Chief Ministerhimself. The same arguments were given then but due to the vigilantrole of media and environmental groups and persistent follow-up ofthe Chief Minister, a study was sponsored by the Punjab PollutionControl Board.

PERSISTENT ORGANIC POLLUTANTS OR POPs:Though banned about two decades in many countries and banned andrestricted in India too later, many of the POPs are found in bloodsamples even today, all over the world. According to PGIMER study,the blood samples that they studied contain the residues of POPslike Heptachlor, DDT, Aldrin and other extremely toxic pesticideslike Chlorpyriphos, Ethion and Endosulfan. The Centre for Science &Environment (CSE) also found six to thirteen pesticides in virtuallyall blood samples. Some of them were POPs as: HCH, Aldrin and DDT.They also found Monocrotophos, Endosulfan, Phosphamidon,Chlorpyrifos and Malathion, all of which are used in high volumes inPunjab.POPs are banned in a majority of countries in the world. They are tobe eliminated from use all over the world through the StockholmConvention (2002), of which India is also a signatory. POPs areknown Endocrine disrupters and the main reason behind neurotoxicity,immunotoxicity, reproductive disorders, testicular cancer, andcongenital malformations. Even motherhood is challenged by POPsthrough foetotoxicity. Many of the POPs are also classified ascarcinogens, mutagens and even teratogens.POPs don't degrade for decades and cause toxicity for a very a longtime. Most of these POPs have a half-life period of 10 years andmore. The scientists and officials of the department of health andfamily welfare and the Patiala laboratory are either unaware orneglecting the knowledge available on these chemicals from acrossthe world. The message we are trying to make is that the HealthDepartment of Punjab in this case does not seem to have thecompetency to undertake or to review any epidemiological study.What the mind does not know the eyes do not see and the ears do nothear.We feel that the situation is grave and needs urgent interventions.The Expert Committee should take a serious view not just of theissue of cancer and pesticides but the lack of informed people inthe public health arena in our State. We also feel that the worthyChief Minister should himself intervene and should involveinstitutions of international repute like the Poison Control Centreof the National Institute of Occupational Health, Ahmedabad; Centrefor Occupational & Environmental Health, New Delhi and ITRC, Lucknowin this matter along with civil society groups from Punjab andelsewhere.PESTICIDES AND CANCER:Each cell of a body has the inherent property residing in itsgenetic code to divide. Simultaneously, the genetic code of a cellhas the property to stop cell division once the purpose of divisionis achieved. If a cell starts dividing and the latter controllingmechanism fails, the uncontrolled multiplication of cells resultsinto what is commonly called cancer in lay language. As there arethousands of types of cells so there are thousands of types ofcancers. Further, what triggers the division of a particular celland what inhibits the controlling genetic code being variable theresultant types of cancers also vary in their nature, rapidity ofgrowth, mode and possibility of spread, malignant potential andabove all to response to the various modes of treatment (surgery,radiotherapy, chemotherapy). There is no single (universal) cause ofcancer and there is no single (universal) treatment of cancer.Substances or factors that enhance the occurrence of a particulartype or types of cancer are called CARCINOGENS (cancer causingagent). No carcinogen alone causes cancer – it only enhances therisk of a cancer. Such cancers are called carcinogen related cancer.Thus there are tobacco related cancers (cancers of mouth, pharynx,larynx and lungs); Radiation-related cancers (blood and lymphoidtissue cancers especially child hood blood cancers) and Pesticiderelated cancers (thyroid, breast, uterus, lymphoma – leukemia).Greater the exposure (amount and duration) more are the chances ofcancer. Even as the probability of cancer in the exposed group isenhanced with carcinogenic chemicals in the environment, there isnever any certainty in a particular individual exposed.Pesticide exposure has been recognized as an important environmentalrisk factor associated with cancer. Many of the pesticides used inIndia and in Punjab are known carcinogens and mutagens (a list ofpesticides classified under different classes of carcinogens isbeing annexed to this letter). Epidemiological association ofmalignancy in human beings with pesticide exposure has beenrecognized long back. A scientific study was initiated in 1993 byNational Cancer Institute, a premier and well known institution ofUSA on this matter. This very large study known as agriculturalhealth study (AHS) conclusively proved that pesticide exposure leadsto retinal degeneration, respiratory symptoms, dizziness, skinirritation, nervousness, depression and above all, a 15% increasedrisk of prostate cancer among pesticide users. Phase III of thisstudy has been started in 2004 and will give us more information onill effects of pesticide use.Agriculture and industrial workers are well-recognized as a high-risk group for these effects, but farming community at large,including families of pesticide users, population consumingpesticide contaminated products and population staying near fieldswhere pesticides are used liberally, is also at risk.Many pesticides are known or suspected to cause cancer in laboratoryanimals. The US EPA classifies pesticides into groups of known,probable and possible causes of human cancer. There is now a largebody of evidence that pesticide exposure is a risk factor for cancerin humans, especially children. Studies done in the United States,several European countries, Brazil and China show that childrenwhose parents are occupationally exposed to pesticides or whoseparents use pesticides in and around the home are more likely to getleukaemia, brain cancer, non-Hodgkin lymphoma, soft tissue sarcomaand Wilm's tumour. There are many studies done throughout the worldon farmers, pesticide sprayers and factory workers exposed topesticides that link cancer in adults to pesticide exposures. Thekinds of cancer that have been found include non-Hodgkin Lymphoma,brain cancer, leukaemia, soft tissue sarcoma, pancreatic, testicularand prostate cancer among others .A systematic review of pesticide human health effects was taken upin Canada in 2004 from studies all over the world . Chapter 3 of thereview focuses on lung cancer, breast cancer, pancreatic cancer,brain cancer, prostate cancer, stomach cancer, ovarian cancer andkidney cancer. The review found many scientific studies which showedpositive associations between solid tumours and pesticide exposure.In particular, the large well-designed cohort studies that thereport reviewed consistently showed statistically significantpositive associations.Most of the time when these issues are raised by public healthexperts and concerned social activists, the Pesticide Industry (orthe chemical manufacturers' organisations) has always brought someoutdated papers to show that there is no such evidence to prove thelinkages. These arguments are exactly along the same lines used bythe tobacco industry for a long time to contradict the associationbetween tobacco exposure and cancer. They used to submit so-called 'scientifically valid' research studies to illustrate theirpoint that there was no correlation between tobacco exposure andcancer. This matter was debated in America's highest courtsextensively. Ultimately it was accepted world over that studiescorrelating tobacco with cancer were more reliable. The Americantobacco companies were made to pay billions of dollars ascompensation to cancer patients. Now, world over tobacco relatedcancers are accepted to be a reality - including in India.Similarly, pesticide related cancers are now a well known realitybased on scientific studies. There are several experimental,epidemiological and clinical studies published showing relationshipbetween certain types of cancers and certain pesticides. Pesticidesas a risk factor in specific types of cancers are cited in number ofrecent reports from USA and other parts of world. And most of thesereports are recent studies conducted since the 1990's.
The well planned and executed PGI Chandigarh study brings outunequivocal evidence that the indiscriminate, indiscreet, excessiveand unsafe use of pesticides in the study area, spurred mainly byaggressive marketing from the pesticide industry, is resulting insignificantly higher number of pesticide related cancers and cancerdeaths. Cancer figures from Rajasthan lend support to thecarcinogenic and teratogenic effect of pesticides used in the state.In Rajasthan, increased load of pesticides, especially in mustardand cotton cultivation, is believed to be responsible for high andincreasing incidences of blood, breast and thyroid cancers. Studiesconducted in the regional Cancer centre in Thiruvananthapuram, apremier Cancer Institute also clearly suggest the link of breastcancer to pesticides.Most common cancers linked with pesticide use are prostate cancer,breast cancer, lymphoma-leukaemia (blood cancers), and cancer ofstomach, gall bladder and various sarcomas. Much of these types ofcancers are found to be leading in the cotton growing study area ofthe PPCB-PGIMER study as well.

PESTICIDES AND NUMEROUS OTHER ADVERSE HEALTH IMPACTS:Many pesticides are also known to produce Teratogenic and mutagenicdefects. Like carcinogens, there are a wide variety of substancesand factors that may influence a growing foetus and cause birthdefects. Pesticides, by nature being life-threatening substances,have the potential, of varying grades, to adversely affect a growingfoetus. The delicate, developing foetus is highly vulnerable to suchtoxic substances. It is also well established that earlier the stageof pregnancy, greater the vulnerability. The vulnerability is alsosex linked i.e. a foetus of one sex is more likely to be adverselyaffected by a particular environmental insult (pesticide exposureetc). Strong evidence has been adduced to relate high incidence ofbrainless female children (neural tube defects) and high femalefetal loss (less number of females born or low female sex ratio atbirth especially in villages) in Rajasthan, Haryana and Punjab topesticide use. In Kerala, the increased incidence of congenitaldisorders an, male reproductive system problems in children havebeen linked to the use of a chemical Endosulfan in the cashewplantations. Apart from the ill effects of pesticides on embryo andfetus in the womb, pesticides have been demonstrated to severelyaffect the developmental abilities, both mental and motor, ofchildren. In Punjab, a study by Greenpeace India and Kheti VirasatMission had demonstrated this . Special attention should be paid toasses the ill effects of pesticide exposure on children. They arethe most vulnerable and silently suffering segment of the population.Besides being cancer causing (carcinogen) and birth defect causing(teratogen) agents, pesticides by their basic nature arebiologically toxic chemicals. They are known to and are meant tocause disruption of some vital biological functions of livingorganisms. In others, including human beings, they may causefunctional disruption resulting in bodily disorders in susceptiblepersons or on reaching a toxic level in the body systems.Other major health problems due to pesticide exposure are alsoincreasing at an alarming pace in the Malwa region of Punjab. Theseinclude neurological disturbance, female foetal loss, poorreproductive health, foetal growth retardation, low birth weightbabies, congenital birth defects and several endocrine-disruptingdiseases.

IMMEDIATE COURSE OF ACTION TO BE TAKEN UPIn this grave situation that one is witnessing in the Malwa regionof Punjab, what any responsible government would do is to approachthe matter with precaution. The Precautionary Principle saysthat "conclusive scientific evidence is not necessary in matters ofenvironment to take action to stop or prevent the problem". Hence,it is important that we need to stop the source of such a problemand then start mitigation measures, studies etc. In such situations,it is always recommended that we err on the side of precaution andnot wait for conclusive scientific evidence.Malwa Cotton Belt is an important cotton-producing region of ourcountry. Incidence of cancer is increasing day by day as is apparentfrom the number of cancer cases approaching major cancer treatmentcenters of this region. In just one private hospital in Muktsartown, 1400 cancer cases were recorded in the past one year. What ismore worrisome is that the majority of these cancer cases are thosewhich have a known association with pesticide exposure. In thiscontext, it should also be mentioned that around 54% of pesticidesused in this country are used on cotton alone, which occupies only5% of the agricultural land of the country. This intense use of amixture of pesticides on cotton makes Malwa especially vulnerable topesticide related cancers and other ailments.Given this context, we demand that pesticide use in the regionshould be phased out and alternative systems of farming likeIntegrated Pest Management-IPM, No Pesticide Management, OrganicFarming be implemented on a war footing so that we can make Punjab asafe place for us and our children to live and grow.
We also demand that:
• ECOLOGICAL and HEALTH EMERGENCY be declared immediatelyfor the entire cotton belt in the state. The plans and fundsallocated for the region should be diverted for remediation,rehabilitation and relief work of the affected on urgent basis. Thestate government should re-prioritise, re-structure and re-categorize its plans and projects with emphasis on crisismanagement.
• The Punjab Government should establish a highpowered "Environmental Health Crisis Management Task Force" withmajority participation from NGOs , Labour Organizations and farmergroups. A senior Epidemiologist or Environmentalist should head thistask force with powers on par with secretary rank to theGovernment.•
Punjab government must evolve a state policy on sustainableagriculture with a special focus on the cotton belt. It is alsourged that State Water Policy must reflect concerns aboutincreasing pesticide contamination in water resources andparticularly in ground water. Punjab is one of the highest consumersof agrochemicals and therefore, the state needs a policy onapplication of agrochemicals, with emphasis to eliminate their usein a phased manner.We also request you to permit us to present the peoples' view,including the view of experts from civil society, on this wholeissue giving us adequate time to prepare our facts and to arrangefor the travel of our experts.We have attached herewith:a) The Community Action Plan on Environmental Health andSustainable Agriculture evolved through a series of participatorydialogue and consultationsb)
A Compilation of studies on "Pesticides and Health" for yourperusalc) A list of carcinogenic pesticides and other chemicalsd) USEPA document on chemical evaluated for CarcinogenicPotentialAwaiting your positive response,

With regardsYours truly,
Umendra Dutt
Executive Director
Kheti Virasat Mission
The following organisations / scientists/doctors have signed on andendorsed this submission:
1. Kheti Virasat Mission, Jaitu, Faridkot 2. Greenpeace India, Bangalore
3. Thanal Environmental Group, Thiruvananthapuram 4. Centre for Sustainable Agriculture, Hyderabad 5. Peoples' Science Institute, Dehradoon 6. The Ecological Foundation, New Delhi
7. Toxics Link, New Delhi 8. Centre for Education & Communication, New Delhi
9. Community Action for Pesticide Elimination,Thiruvananthapuram
10. Dr. S.G. Kabra, Indian Institute of Health Management &Research, Jaipur
11. Dr. T.K. Joshi, Director , Centre for Occupational &Environmental Health, LNJP Hospital, New Delhi
12. Dr. Davinder Sharma, Agriculture Expert and SeniorJournalist,New Delhi
13. Dr. B.D.Gupta, Retd. Head, Department of Oncology, PGIMER,Chandigarh
14. Dr. Kalinga K. Nayak, Adesh Cancer Hospital, Muktsar
15. Ms. Madhumitta Datta, Independent Environment Activist, NewDelhi

Copy to:1. Dr Manmohan Singh, Hon'ble Prime Minister, Government ofIndia, New Delhi
2. Capt. Amarinder Singh, Hon'ble Chief Minister – Punjab,Punjab Civil Secretariat, CHANDIGARH3. Justice D.K.Jain ,Chief Justice, Punjab & Haryana HighCourt, Chandigarh.
4. Dr Anbumani Ramdoss, Hon'ble Minister for Health, Governmentof India , New Delhi
5. Dr. S.S.Johl, Deputy Chairman, Punjab State Planning Board,Chandigarh
6. Dr.G.S.Kalkat, Chairman, State Farmers Commission- Punjab,Mohali.
7. Jai Singh Gill, Chief Secretary- Punjab, Civil Secretariat,Chandigarh

For further Communications please contact:
Umendra DuttExecutive DirectorKHETI VIRASAT MISSIONStreet-5, Hardayal Nagar,JAITU-151202District: Faridkot, PunjabPhones:98726 82161 ;01635 – 503415E-mail:

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