Current status of the development, regulation and use of bio-pesticides in Uganda

Samuel Kyamanywa, Makerere University

Regional Experts Workshop on Development, Regulation and Use of Bio-pesticides in East Africa, Nairobi, Kenya, 22–23 May 2014

Introduction • BIOINNOVATE is supporting development of bio-technologies to reduce

the impact of biotic and abiotic production constraints in crops, for the ultimate benefit of resource-poor farmers.

• Project 7 “Bio-pesticide Innovations for Bio-enhancement of Seeds and Seedlings” has developed a biopesticides based Microbial agents. This bio-pesticides is applied as seed treatment against common pests and diseases.

• Although this approach is common in USA and Europe, little use has been made of this technology in sub-Saharan Africa in spite of its great potential for vegetable and cereal crops

• Hence the need to analyse the factors limiting adoption of this technology.

• This report analyses the policy and regulative issues that may be hampering adoption of the technology in Uganda.

Objectives

• To review the policies, regulations and standards for bio-pesticides, and to identify key actors and incentives and/or disincentives affecting the adoption of bio-pesticides in the country.

Methodology

• Under took a desk review of the existing pesticide (including bio-pesticide) policies, regulations, standards and other reports and literature associated with pesticide development and use in the country

• conducted interviews with;- – (i) regulatory authorities in Ministry of Agriculture Animal

Industry and Fisheries, Ministry of Environment and Natural Resources,

– (ii) NGOs (iii) pesticide firms, (iv) Bio Pesticide firms (Kinyara sugar works), (vi) farmers, and

– (vi) scientists involved in the development and use of bio-pesticides.

Methodology• Identifying the type of bio-pesticides currently in use or being developed in

the country;

• Identifying the relevant regulatory agencies for bio-pesticides management

in the country...

• Identifying government policies governing the process of registration; and

the extent to which management of bio-pesticides are included in national

and sectoral strategies and plans in the country;

• Identifying any incentives that are currently available for adoption of bio-

pesticides in the country.

• Establishing what is the private sector and civil society organizations were

doing to promote use of bio-pesticides in the country (use specific

examples). Identifying the constraints experienced in the promotion of bio

pesticide use and adoption

Findings• Bio-pesticides as pesticides derived from natural materials such as

animals, plants, bacteria, and certain minerals. Biopesticides are categorizes into:-– Microbial pesticides: these consist of a microorganism (e.g., a bacterium,

fungus, virus or protozoan) as the active ingredient. – Plant-Incorporated-Protectants (PIPs): these are pesticidal substances

produced by plants from genetic material that has been added to the plant.. In this case the protein and its genetic material are regulated, but not the plant itself.

– Biochemical pesticides are naturally occurring substances that control pests by non-toxic mechanisms. include substances, such as insect sex pheromones, that interfere with mating, as well as various scented plant extracts that attract insect pests to traps

– The Control of Agricultural chemicals Act give a wider definition of Bio pesticides to include macrobial/invertebrates such as insects and nematodes and plants extract

Advantages Of Using Biopesticides • Biopesticides are less toxic than conventional pesticides. • Biopesticides are target specific, in contrast to broad

spectrum, conventional pesticides which affect a broad spectrum of organisms

• Biopesticides, when used as a component of Integrated Pest Management (IPM) programs, can greatly decrease the use of conventional pesticides, while crop yields remain high.

• Thus promoting Biopesticide may minimise the effects of indiscriminate use of pesticides human health and wildlife populations

Bio-pesticides currently in use /or being developed in the country

Bio-pesticides currently in use /or being developed in the country

• Few Biopesticide registered; of the 567 agricultural chemicals registered between 2007 and October 2013 only 11 were Biopesticide .

• In USA by 2014, EPA had more than 430 registered biopesticide active ingredients and 1320 active product registrations; Uganda has a long way to go in taking advantage of Biopesticides

• More biopesticides on the market than those know by the Department of Crop Protection.

• Some of these products may be faked or actual conventional pesticides being sold as biopesticides

Bio-pesticides currently in use /or being developed in the country

• Balton Uganda Ltd, is piloting marketing of Biopesticides in Uganda; so far they have four products which include Neemraz, Neemgold and Levo, and they were directly selling to the final consumer.

• Website of Bukoola Chemical industries, indicate that they are dealing in five bio products :- Nimbecidine, Bio-powder, Bio-catch, Priority, Bionematon, Bio-cure-B&F, Green Miracle, Bio-magic, Sting and Bacterimycine

• Kinyara sugar limited is registered to produce/manufacture various biopesticides. They have a well establish biopesticide production plant, which is supported, by an advanced microbiology

Bio-pesticides currently in use /or being developed in the country

• Other efforts to promote use of Biopesticides, are at the National Agricultural Research Laboratory (NARL) Kawanda where various biopesticides are being developed and tested.

• Dr. Caroline Nankinga, a scientist at NARL has developed Beauveria bassiana for control of Banana weevil. She has developed the product up level of commercialization.

• The problem has been lack of private investors to take up the commercialization process.

Regulatory Agencies For Bio-Pesticides Management InUganda.

• The National Environment Management Policy (1994): The policy document calls for promotion of farming systems, land-use practices and pest management systems that conserve and enhance land productivity in an environmentally sustainable manner. This therefore indirectly supports the use of Biopesticides.

• The National Land Use Policy (2007): The goal of the policy is ‘to achieve sustainable and equitable socio-economic development through optimal land management and utilization.’ This policy is very relevant to and supports indirectly the use of biopesticides. In NLU policy statement No.10, and No. 20, the policy pledges to encourage judicious use of agro-chemicals in a way that does not pollute the environment. ‘Encouragement of judicious use’ is a strong statement that would help the utilization of biopesticdes if it is spelt out in the Plant Protection act that Biopesticide are first priority in controlling pests and disease in Uganda.

Regulatory Agencies For Bio-Pesticides Management InUganda

• The National Bio-technology and Bio-safety Policy (2003)• Biotechnology is a field of science It refers to the application of scientific and

engineering principles to the processing of materials using biological agents to provide goods and services. On the other hand, Bio-safety refers to the safe development, transfer and application of biotechnology and its products. . It refer to the mechanisms put in place to regulate or control potential risks that biotechnology poses to human health, the environment as well as their socio-economic impacts.

• Therefore Biopestices in the category of Plant-Incorporated-Protectants would be regulated under this policy. Plant-incorporated protectants act like pesticides and are produced and used by a plant to protect it from pests, such as insects, viruses, and fungi..

• The biotechnology and biosafety policy however does not give clear rules that deal with plant-incorporated protectants (PIPs). It does not provide guidelines that would be followed in conducting scientific evaluation for purposes of registration.

Regulatory Agencies For Bio-Pesticides Management InUganda

• The Draft Uganda Organic Agriculture Policy (2009)– OA seeks to minimise the use of external biological inputs, avoiding the

use of synthetic drugs, fertilizers, and pesticides. And it aims at optimising the health and productivity of interdependent communities of soil life, plants, animals and people.

– This objective has a negative impact on promotion of Biopesticides.

• The National Seed Policy (2009)– The vision of the policy is: ‘competitive, profitable and sustainable,

market-led, regulated, and coordinated seed industry’. The mission is: ‘to ensure the availability of adequate high quality and safe seed on the market’.’. Consequently, Seeds treated with microorganism will be partly regulated by this policy and partly by the Control of Agricultural Chemicals act and the plant protection act.  

– Similarly seed for Plant-incorporated protectants shall be regulated by this policy.

Regulatory Agencies For Bio-Pesticides Management InUganda

The Agricultural Chemicals (Control) Act, 2006• The agricultural chemicals control Act of 2006 (Acts

supplement No.1) is an act to control and regulate the manufacture, storage, distribution and trade in, use, importation and exportation of agricultural chemicals and other related matters.

• The Act interprets agricultural chemicals to include: plant protection chemicals, fungicides, insecticides, nematicides, herbicides, miticides, bactericides, rodenticides, molluscides, avicides, fertiliser, growth regulators, wood preservatives, biorationals, bio-pesticides, bio-fertilisers or any other chemicals used for promoting and protecting the health of plants, plants products and by-products.

The Agricultural Chemicals (Control) Act, 2006

• The act provides for a Board consisting of 13 members. – Agricultural chemicals are duly registered in the country and are used

in a manner consistent with the rules made by the state.– It regulate agricultural chemicals imports and advises the government

on matters related to enforcement of provisions of the statute. – It appoints an Agricultural Chemicals. Technical Committee (ACTC)

to advise the board on the technicalities of agricultural chemicals. This committee is responsible for receiving applications for registration of pesticides, technical analysis, and verification of the efficacy of agricultural chemicals.

– The Agricultural Chemical Board and its technical committee fall under the Ministry of Agriculture, Animal Industry and Fisheries (MAAIF).

The Agricultural Chemicals (Control) Act, 2006

• The regulations, among others, clearly spell out that:• 1. No pesticide—whether imported or manufactured in Uganda— shall

be used, stored, distributed, or dealt in unless it is duly registered in accordance with rules and regulations of the Agricultural Chemicals Statute.

• 2. No person by way of business shall deal in pesticides unless the same is registered as a fumigator or commercial applicator with a certificate from the Agricultural Chemicals Board (ABC).

• 3. Any premise used in dealing in pesticides must be appropriate and registered by the Agricultural Chemicals Board as indicated in the statutory instrument of 1993.

• 4. Any person employed in the manufacturing, formulating, packaging and applying of pesticides shall have his/her health monitored, and be well protected with the appropriate equipment and safe practices.

Conditions For a pesticide to be registered

• It must undergo official screening and testing to prove that it is effective, safe, and not a danger to public health.

• It must be assessed by the Agricultural Chemical Control Technical Committee for active ingredient purity, and for toxicological, public health and environment acceptability.

• The ACB is responsible for appointing a researcher to test the candidate pesticide following specific standards and guidelines. The guidelines are currently under review to conform to international standards.

• A fee of Uganda Shillings two million (2,000,000/=) shall be paid by the registrant (pesticide manufacturer, reformulator, re-packager, re-seller, etc.) to cover the cost of testing and temporary registration

Conditions For a pesticide to be registered

• The new pesticide shall be tested for a minimum of three crop-growing seasons in different locations in Uganda, to cover the appropriate agroecological zones.

• Approval shall be granted or denied to a pesticide within six months from the end of the period required for testing. Pesticides are registered on the basis of their efficacy.

• The company submitting the pesticide shall provide all technical information necessary to guide the testing process—that is, toxicity to humans and the environment, the toxicity index (LD50), Maximum Residue Limits [MRLs] and tolerance levels, and any other relevant information.

• A pesticide is (duly) registered on payment of (an additional) fee

Conditions for registration as a fumigator and/or commercial applicator,

• Submit certified copies of relevant documents regarding the technical knowledge of the applicant.

• Pay a fee of Uganda Shillings 500,000/= only for a certificate of registration that remains valid until suspended or canceled.

• A tested pesticide shall be recommended for the control of specific pests on all host crops rather than for specific crops.

Conditions for registration of a premise as a pesticide seller or related business

• An application on Form F is submitted to the ACB by the applicant.

• The pesticide business, in relation to the premise, must be under immediate supervision of a registered fumigator or commercial applicator.

• A fee of Uganda Shillings 500,000/= is paid to the ACB for a certificate of registration.

• Registration is for a period of five years, after which a new application must be made.

• Registration may be canceled by the ACB if any of the provisions of the Agricultural Chemicals Statute are contravened.

Storage, Labeling, Packaging, and Transportation

• The agricultural chemicals regulation statutory instruments give clear details of how storage, labeling, packaging, and transportation of pesticides ought to be carried out safely. For example it stipulates, among other things, that:

• No pesticide shall be imported, distributed, sold, or used without a label; and that such a label should conform to FAO standards.

• There shall be no removal or alteration of the pesticide labels.• Packaging and re-packaging shall be carried out on premises

registered by the ACB.• Every manufacturer or distributor of a pesticide shall provide a

range of packaging sizes that can be used safely and appropriately by small-scale farmers and other users in Uganda

Storage, Labeling, Packaging, and Transportation

• .• Premises on which pesticides are stored shall be a separate

building strictly for purpose of storage of agricultural chemical and shall comply with specified requirement of the statute.

• Pesticide stores and shops shall not be used for sitting or sleeping.

• Food, feeds, and drinking water shall not be kept in pesticide premises, and premises shall not be used as sleeping places for human beings and livestock animals.

• There are shall be sufficient space for storing empty containers, damaged containers, spills of pesticide, and out-of-date stocks awaiting disposal.

Challenges in Bio-Pesticide Regulation and Use

Regulatory Framework • Registration of biopesticide follows the same registration framework

as conventional pesticides. This is a challenge because biopesticide, by their very nature, are not consistent and require slight modification system. Similarly biopesticides tend to pose fewer risks than conventional pesticides, and would therefore not require a lot of data for registration.

• Many other regulations and acts which impact on Biopesticide use and registration, it will therefore be necessary to harmonise how the demands of the various acts will be fulfilled.

• As observed by some members of the registering agency the long-term solution is a separate regulation and standards for handling Bio-pesticides within the Control of Agricultural chemicals Act.

Challenges in Bio-Pesticide Regulation and Use

• Inadequate inspection of manufacturing, storage and selling premises and advertising and promotional activities, inspection of farms. – The legal duties of pesticide inspectors in MAAIF

should include monitoring all premises where pesticides of any sort are handled or used. This includes scrutiny for misuse, and for poor quality, expired or fraudulent products. MAAIF however does have enough human resource and financial resources to handle these assignments adequately

Challenges in Bio-Pesticide Regulation and Use

• Capacity of the MAAIF to conduct Biopesticide evaluation trial– Scientists can demonstrate that a particular biopesticide controls the

t pests, but not able to ascertain the a.i. – Fear that some of the products on the market sold might be

conventional pesticides disguised as Biopesticides – Efforts should be on confirming whether the Biopesticide contains

the appropriate a. i. and it viability. – Establishing microbiology laboratories with good analytical

capacity. The laboratories should be certified.• Maintained reference culture material and technical grade, and• Conduct bio pesticide quality control analysis for purpose of registration

and for post-registration

Challenges in Bio-Pesticide Regulation and Use

• Limited number of Companies applying for registration of pesticides– there are very few companies submitting applications for registration of

biopesticides. If there is no owner to market the product then the product is doomed to fail.

– That is the fate of the Biopesticides developed at the NAL Kawanda and Makerere. There are very few companies interested in investing in Biopesticides in Uganda (Commissioner of Crop Protection and Dr Caroline Nankinga).

• Lack of infrastructure at farmers level to Handle Biopesticides

• Lack of Farmer and applicator training and extension programmes

• Post-registration controls – product stewardship

Encouraging and facilitating Biopesticide registration

• The biopesticide are given similar incentives as those given to any other agricultural chemical. “the only incentive given to pesticides, including Biopesticides is the tax exemption; otherwise the Department promotes all pesticides equally”

• Currently developing and promoting of Biopesticides is mainly by researchers from NARI, and IARI (IITA) and Makerere University.

• Dr. Nankiga at Kawanda developed Beauveria bassiana microbial biopesticide up to commercial production. The farmers had accepted the technology. Similarly IITA developed Beauveria as an endophyte for managing banana weevil; The technologies have not taken off because of lack of linkage with private sector.

Encouraging and facilitating Biopesticide registration

• The role played by private sector in promoting BIopesticide. Although there are few companies involved in biopesticide promotion, the coming on board of Kinyara Sugar Limited to produce and promote the use of Biological pesticides is a good sign for the future. The impact of Kinyara in creating awareness among farmers is likely to be faster because the company is applying the Biopesticide both on its own sugar cane plantation and on those of out growers.

• Companies currently using biopesticide are mainly flower growing companies including Rosebud.

• Balton is currently promoting 4 bioinsecticide. While Bukoola Chemical industry is also marketing over 5 biopesticide.

Recommendations• Creating awareness of the importance of

Biopesticides in our agricultural production system.• Improve on the regulatory processes for

biopesticides- including integration of the various acts and regulations that impact on biopesticides.

• Strengthening laboratories capacities.• Nurture the private sector to invest in biopesticides• Using Biopesticide based on locally available

microbial agents

Expert opinion

• Thank You