The modern world is built on chemicals, be it medicines we apply, or cleaning fluids, crop protection products, or the raw materials for everything from laptops and mobile phones to clothes and furniture. Across all, we have created an entire modern society with chemicals, and, as a result, constantly stretched the size of the world population we can feed, clothe and shelter.

Yet, balancing all the gains from the modern chemistry around us against any negative environmental and human impact has been a rising concern, making for ever greater focus on testing and on risk assessment.

However, not all positions are about weighing the costs and benefits, or striking a balance. Sometimes issues become clouded by emotions, or populism, maybe they become a rallying call for campaigners drumming up membership drives or funding, or they can just become what some people call ‘politically correct’, where opinions shift with or without reason, and it just becomes rebellious to hold any other view or make any other case.

This has seen divergence in the way we have treated approvals in our chemical world, and particularly in relation to the crop protection products  we use in Kenya to cull locusts or manage the Fall Army Worm.

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As it is, for all chemicals, the regulatory starting point has long been what is called risk assessment.

This risk-based approach assesses the possibility of a substance causing harm to human health and the environment when it is used for the purpose proposed.

In fact, it can be better to take examples we are all familiar with in order to understand the nature of the differing regulatory regimes: an obvious one is household bleach. Bleach can kill you nastily if you drink it. If you put your hand into it or splash it onto your skin or into your eyes, it will burn. Pour it into soils and it kills all the vital soil bacteria. Yet we use it constantly.

That’s because it comes with warnings, and when used with water and protection for our skin, it protects us from literally millions of germs and pathogens that would have ended many of our lives already.

So, risk assessment would look at whether bleach will hurt or kill us when it’s used as it should be, with gloves on and diluted. And if it doesn’t harm us then it can be approved for home use, but with clear markings on it that it is a ‘hazard’ and packaging that young children cannot open.

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In fact, until 2009, every regulatory regime in the world used risk assessments to decide which pesticides to approve, which household cleaning products to approve, and which foods to approve (for example, cassava is lethal when undercooked, but is still approved as a human food).

To carry out the risk assessments on crop protection products require comprehensive studies that can take six to nine years of testing, looking at what happens if the product gets in your eyes, is breathed in as fumes, or touches your skin, and examining with animal testing its impact on the nervous system, in creating cancerous cells, in affecting the reproductive or any other biological system or function. The tests span every conceivable environmental impact too.

These tests typically cost around Sh23bn to complete for any one chemical, and the product will only be approved if it is safe for the use proposed, without damaging either humans or the environment. Pesticide approvals, thus, do not come from nowhere, they take years to secure and require proof that one chemical company once summarized as the equivalent of 50-man years of work and five lorry loads of test results, if printed out.

However, in 2009, the European Union decided to take a different approach – not to food, or any other chemicals, but just with pesticides - and moved to what is called hazard assessment.

This regime simply determines whether a chemical has any capacity to cause human or environmental harm in any way. Back to bleach – it’s a hazard. So, if it was a pesticide for the EU, no testing would happen, it cannot under any circumstances get approval for any use (and nor could cassava under a hazard assessment, nor salt, nor sugar).

Now Europe’s move has been deeply controversial, but every nation and region has its politics.

However, the nasty part, in Kenya, is that because the EU changed its rules, some petitioners and NGOs have told the Kenyan parliament and public that Europe banned our approved pesticides because they caused cancer or other harm, when used as pesticides.

That’s just not true. Yet people have even worried about culling locusts that will otherwise move our peoples into starvation because air-spraying must be dangerous, despite the Food and Agricultural Organisation (FAO) recommending it.

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Whereas, in fact, all of these pesticides remain in use in the US, Australia and all those regimes that measure them for their safety in use. They have not been ‘banned’ because they harm human health as pesticides. They have been removed, by Europe alone, from all testing to even assess their safety as pesticides, because they can cause harm in other ways.

Which is a very dubious reason for letting the locust multiply. For, of course, Europe doesn’t have locusts, or Fall Army Worm, or food insecurity, so no one is starving to death there over its change of regime. But in Kenya, people will die. So we can ban pesticides with nine years of testing proof they are safe for use. But let’s be aware they are still safe for use, just as they always were, and thousands of people will die as our crops disappear.

Photo:Erick Kimunguyi CEO, Agrochemicals Association of Kenya.

Agricultural and industry organisations have today called on the government of Kenya to intervene to secure due process in the country's pesticide regulation, amid warnings that a current initiative by four NGOs could wipe out the country's food production within months.

A move to secure a ban by parliament of 262 pesticides approved for use in Kenya would slash the country's maize production by 70 per cent, create a ballooning locust problem and lead to the collapse of the agriculture sector, warned the growers and scientists.

The calls come in response to a petition to parliament seeking the banning of the products that are currently being used to prevent the infestation of Kenyan maize by Fall Army Worm and to curb the locust invasion in northern Kenya.

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The petitioners want the pesticides banned following a change in the European pesticide regulation, which has seen the EU abandon risk assessment as a basis for approving pest control products. Instead of considering the safety of products when they are used in pest control, as elsewhere in the world, the EU now approves products only where they are non-hazardous in all circumstances, meaning, for instance, that consumers could safely drink them.

"The consequences of changing our pesticide approval criteria, by default, without changing our current laws, without scientific assessments, and as an appeal to elected members of parliament who have no background on pesticide approvals, will be literally catastrophic," said Fresh Produce Consortium CEO, Ojepat Okisegere.

"We lost 70 per cent of our maize production in 2017 to Fall Army Worm, which is now restored due to pest control. If we now ban the pesticide, we shall move back to crop devastation, in an environment where pest infestation is skyrocketing across our agricultural production," he said.

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The pest infestation rate for cabbages would move to around 98 per cent, tomatoes to 24 per cent, produce such as flowers, French beans and soybeans, to around 66 per cent, and 40 to 80 per cent on wheat and other crops, he said.

"Pest such as Tuta absoluta, which is notorious in attacking tomatoes can wipe out 100 per cent of the yields within days, and attacks whenever the host is available.  Female pests can produce up to 260 eggs in 21 days, while stem borer, FAW and cutworms have been the famous pests attacking our maize crops cutting our yields by almost half," said Ojepat.

The ban would leave farmers grappling with pests like Aphids, Whiteflies, Thrips, Moths, and Spider mites, weeds and fungi's that farmers, as well as locusts, which have now spread in Wajir, Marsabit, Samburu, Garissa, Isiolo counties and are already depleting northern Kenya's food supply. Locusts can cause 80 to 100 per cent crop losses, leaving behind barren land.

"The organic farming methods being pushed with the pesticide ban petition cannot beat a locust invasion such as this one: we need pesticides to fight them and salvage the little food that still exists," said Ojepat.

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Currently, through the Ministry of Agriculture's consultation with FAO, the government is fighting the locusts with pesticides such as Fenitrothion, which is in the petitioners proposed list of pesticides to be banned.

"If we ban the use of insect pesticides such as Fenitrothion used to eradicate desert locust, close to Sh22bn worth of food produce such as wheat, maize will be lost this year alone," said Dr Evelyne Samita, a member of the Entomology Society of Kenya.

Overall, the ban would affect crops and livelihoods in five agriculture producing regions, with Rift Valley and Central set to be the hardest hit, followed by Western, Eastern and the Coast.

"Just 10 of the pest control products in the list are used in over 20 crops spanning maize, French beans, flowers, beans, cabbage, wheat, potatoes, tomatoes, soy beans, onions, rice, bananas, and fruits among others. Banning these pesticides means production of these crops would be slashed," said Joel Mutai Regulatory & Liaison Manager, Agrochemicals Association of Kenya.

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On his side, Eric Kimunguyi, CEO of the Agrochemicals Association of Kenya said that PCPB is staffed by many excellent scientists and that the legislation and regulatory structure existing only allows pesticides to be approved for use in Kenya where they have been subjected to the most thorough international testing and approved for use by leading testing regimes, such as the US and Australia.

“It follows therefore that we do not venture into accepting pesticides for use that are deemed or classed as a risk to health or the environment elsewhere despite the fact that we face many pests that are not found in the northern hemisphere, or which Europe may never have to grapple with, such as locusts, for instance. There are no locusts in Europe,” said Kimungunyi.

He says, battling the country’s biggest locust invasion in 25 years, the strongest line of attack in curbing the scale of the locust swarms and slowing their breeding are limited approved insecticides such Fenitrothion, which the government is now air spraying in an effort to save billions of shillings worth of crops and to prevent a serious famine in our lands.

Fenitrothion is just one of 262 active ingredients that several proponents wish to see banned in the country. The products have been banned nowhere else in Africa. They are approved for use and in use in the US, in Australia, and very widely across the globe.

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According to Kimungunyi, there are two things that have prompted the groups to seek the exclusion for Kenya alone in Africa from using pesticides such as the ones we are using to curb the locusts, and such as the pesticide we are using to control Fall Army Worm on our maize.

“As a result, for us, alone, they would rather that Fall Army Worm went untreated, as it did in 2017, when we lost 70% of our maize harvest as a result.”

“Their first reason for wanting this is that they are committed to organic farming and against all pesticide use as a matter of principle. We respect the commitment of all organisations to organic agriculture and have no issue whatsoever with the development and application of organic methods and products, indeed, we laud such efforts.

But to take that commitment to the level that we must settle down for a barren year of harvests destroyed by locusts, or accept the loss of our maize and staple crops to the Fall Army Worm, even where that generates famine and many thousands of deaths from starvation: this we cannot support.”