INTER-COUNTRY WORKSHOP ON PUBLIC HEALTH PESTICIDES MANAGEMENT IN THE CONTEXT OF THE STOCKHOLM CONVENTION ON PERSISTENT ORGANIC POLLUTANTS (POPs)

AMMAN, JORDAN, 7 – 11 DECEMBER 2003

MANAGEMENT OFPUBLIC HEALTH PESTICIDES IN SUDAN

A Country Paper

By: Ahmed M. El Hindi *, Mustafa Y.H. Dukeen **& Ahlam H.A.***

1. Introduction:

A total of over 200 pesticides active ingredients are registered in Sudan either singly or in combination in over 600 different formulations. Almost 20% are used for mosquito control and other public health purposes . The remaining 80 % are used for control of cotton pests and other rotation crops, besides considerable amounts used for the control desert locust, birds and rodents..Very few are used for veterinary purposes.

Ever since the early use of pesticides in the nineteen thirties. Their hazards have well been recognized. Therefore, their use and handling was covered by the relevant regulations existing at that time namely Pharmacy and Poisons Ordinance 1939 which later became the Pharmacy and Poisons Act 1963. Due to intensive use of pesticides a separate Act has enacted in 1974 to control pesticides chemicals for all purposes. That was later amended to the 1994 Pesticides and Pests Control Product Acts.

*Consultant Chemical safety, Instiute ofTechnology, National Rearch Centre ( NRC),Min. of Science & Technology & Advisor ro the NRC , E-mail adress : ahmed El Hindi <>

** Consultant Vector Biologist, Nat. Adm. Of Malaria. Schistosomiasis & Leishmaniasis, FMOH E-mail adress :

***Crop Protection Specialist , National Pesticide Council ( NPC ),. E-mail adress : ahlam ahmed <>

2. Pesticides Regulations:

Pesticides for all purposes including public health are currently regulated in the Sudan by the same act namely the Pesticides and Pest Control Products Act 1994 (annex 1) which replaced the Pesticides Act of 1974. The act regulate all activities related to pesticides registration, importation, storage, transportation, use, formulation and any other related activities in the country through the National Pesticides Council (NPC). The NPC is a multidisciplinary interministerial council which have representatives from all stakeholders within the country including; Ministries of Agriculture, Health, Animal resources, , Research Institutions, Customs, Universities, …. etc. The council is chaired by the undersecretary, Ministry of Agriculture. The registrar of the council is the Director General, Plant Protection Directorate (PPD). The registrar is responsible for all administrative and executive functions of the council. The various specific issues which may require periodical revision were included in the relevant by-laws for ease of amendment. The last version of these by-laws was issued in 2002. Twenty six subsidiary state councils are established to cover the 26 states of the country. The main activities of the state council is to foresee the implementation of the NPC decisions and to carry out the necessary inspection & monitoring activities as well.

Pesticides were classified according to WHO regulations as acute, high, moderate and low toxicity based on the LD50 level. According to this criteria the NPC licensed the retailers to deal with the pesticides of low toxicity.

3. PRODUCT REGISTRATION:

1.Pesticides licensed importers should submit a filled form (form1) which provides information on the source, local agent, the product physico-chemical properties, , toxicology of the active ingredients and the formulated product, environmental impact ……etc (annex

2. The form should be examined by the Technical Committee (TC) of the NPC. Product satisfying the requirements of the TC, are granted provisional registration for testing at institutions recognized by the NPC ( Agricultural Research Corporatio ( ARC ), PPD Medical Entomology Department (MED) and Veterinary Research Corporation ( VRC ) .

3. Relevant scientists are assigned to conduct the necessary test for efficacy.

4. Applicants of products (agents) satisfying the NPC requirements granted permission for introduction of samples for the purpose of testing. The sample size is defended according to the testing purposes as prescribed by the scientist in charge.

5. Products applicants are then issued an import permit according to Form 111 to introduce the specific quantity ( Annex III ).

6. Final results of testing should be approved by the Pests and Diseases Committee (PDC) for agricultural pesticides , the Ministry of Health Scientific Committee (MHSC) for public health pesticides and. the Veterinary Research Corporation for. Veterinary pesticides .

7. Recommendations by the PDC or MHSC, Veterinary Committee ( VC ) have to be submitted to the NPC for endorsement and final approval for commercial registration .

PROCEDURES FOR TESTING & REGISTRATION OF PESTICIDES IN SUDAN:

Importation of License

Application for Provisional Registration of Pesticide ( form I )

Recommendation for Provisional Registration for Testing from the Technical Committee

Approval of Provisional Registration by

The National Pesticide Council

Provisional Registration

Sample Introduction ( form III & V )

Field Testing ( 3 month to 3 years)

National Pest & Disease Committee ,Health Committee or VC

Recommendation for Commercial Registration

Approval of Commercial Registration by

The National Pesticide Council

Commercial Registration ( form II & IV )

4. Procurement:

4.1.The main purchasers of pesticides are:

-Ministry of Health for malaria control and other disease vectors.

-PPD for control of national pests.

- Private sector mainly for vegetables, fruits and household.

- Irrigated Agricultural Schemes for cotton, sugar cane and other rotational cash crops.

- Rain-fed Agricultural Schemes.

Procurement of pesticides for irrigated schemes, PPD and Ministry of Health is done through National Public Tenders. Others purchases are done though direct quotations.

4.2.Donations mainly from WHO and NGOs.

N.B. illegal import is strictly prohibited.

5. Formulation and repacking:

There is no production, formulation and/or repacking of pesticides in Sudan at present. In 1963 Shell Chemicals established a formulation plant to produce organochlorines. The plant has stopped production since early 1995. Recently two companies applied for high technology formulations, their application is still under assessment and consideration.

6. Storage and Transportation:

According to the 1994 Act and its by-laws pesticides should not be stored together with any other item except the equipment used for spray operations, but the present pesticides stores due to their design and construction are by no means adequate.

In general, the storage and disposal of surplus pesticides is posing a real problem. National and International efforts are now coordinated to try to solve the problem.

Transportation of pesticides at present is also not adequate and the situation is deteriorating due to drop in capabilities of the national carrier (Sudan railways), in which special precautions were taken during the transportation of pesticides. These precautions include thorough cleaning of railway wagons after carrying pesticides and precautions were also taken not to transport food items together with pesticides. This drop in the capabilities of the national carrier lead to the use, in some cases of public transportation. The control of public transportation is extremely difficult.

7. Distribution:

According to the Act, only certified and licensed dealers are allowed to trade in pesticides.

The distribution process starts with the loading of pesticides at the port of entry. Purchasers are responsible for handling the products to their destiny and storage. Private sectors purchases are imported by local agent who in turn pass them to licensed retailer and hence the end users.

8. Application:

Public heath (mainly for malaria control), Government and semi-government enterprises are the main users of pesticides, mainly in cotton, sugar schemes . Therefore, all pesticides applications are carried out by skilled government employee or by private companies under governmental supervision.

In private agricultural schemes and for certain public heath operations, licensed applicators are allowed.

9. Disposal:

Generally, stockpiles of pesticides for public health use are no creating a problem. However, stockpiles of pesticides for agriculture that have lost their potency due to long storage or being received as consignments of substandard quality are causing real concern.

A preliminary inventory by PPD under the sponsorship of FAO has shown that in PPD stores and the agricultural schemes all over the country there are about 600 tons of pesticides out of which 90 tons are POPs. In addition there are 6000 m of contaminated soils. The storage in general is poor. The stockpiles are piled together. Hence contamination of the total quantity beside the soil is inevitable. Only few quantities of liquid waste have been incinerated using a mobile incinerator belonging to Shell Company with efficiency of about 80%. The remaining quantities are still waiting decision for disposal most probably outside the country hopefully with international assistance.

10. Monitoring and Surveillance:

Generally several survey studies on pesticide residues in water, soil and food materials were conducted during the period in early 1980s in which the organochlorine pesticides were extensively used in agriculture, DDT and related derivatives were the commonest residues encountered. Besides, residues of heptachlor, endosulfan, aldrin, dieldrin and HCH were significantly high ( greater than International Codex Alimantaris level) e.g. in the case of goats milk from the Gezira area.

Survey of water bore holes in the Gezira revealed the absence on organochlorine residues despite the long history of usage of these compounds, this could be attributed to the limited permeability of the Gezira soil. Surface waters were understandably found to be contaminated, being exposed to aerial spraying. However, the levels of most residues were well bellow the WHO limits. A comprehensive soil survey in the Gezira revealed low levels of DDT, despite the large quantities that were used. However regular monitoring is not common due to certain limitation.

11. Poisoning:

Human poisoning by pesticides is attracting little public or even medical attention. Poisoning sometimes goes under recognized, undiagnosed or unreported. Hence, documentation and registration of poisoning accidents is poor (annex IV). However 22 accidents were reported in the period 1968-1992. Some of these involved a large number of people and led to several mortalities. The major cause of poisoning was found to be due to the consumption of grossly contaminated food, sorghum, wheat, sugar, dried fish etc.. Consumption of treated seeds is the main reason of such accidents. In addition, food consignments are contaminated during transportation of food stuffs together with pesticides.

Several surveys and periodical medical attentions on Health workers exposed to organophosphrous pesticides indicated significant cholinesterase inhibition add symptoms of Poisoning. During early surveys in the 1989 it was noted that workers were completely ignorant or new little about the hazards of the toxic chemicals which they were handling, hence precautionary measures were rarely observed. Although the situation is now improving it is still far from being satisfactory.

Due to these facts, the professional and decision makers were simulated and a ministerial decease was issued in 1998 to establish a poison control center which is still under establishment.

12. Quality Control :

Public health pesticides are analysed for complience with WHO specifications for pesticides used in public health .The analysis is carried out The Reference National Chemical Laboratories, Minstry of Health .Particular emphasis is given to toxic impurities e.g. iso-malathion in malathion and physical properties e.g. emulsfiability and suspensibility . Agricultural Research Corporation Laboratories Minstry ofScience and Technology are responsible for the analysis of pesticide formulations in agriculture to determine complience with tender specifications .There is close collaboration between all these laboratories as regard analysis for cross-checking , verification and quality assurance of resuls .

13. CapacityBuilding :

13.1: Manpower Training :

Different categories of personnelleinvolved in the management of pesticides used in vector control receive regularly basic training related to specializations at respective institutes nationally and abroad with tangible support and assistance from WHO .These include entomolgists, analysts, physicians, public health inspectors, nurses, sanitory over-seers mosquito-men …etc.Refresher short courses are given regularly for the above categories .Special courses on safe and judiace use of pesticides are coducted periodically under WHO programme for Chemical Safety . During the period 1994 – 2003, more than seven courses were carried out , each involving 30 – 40 trainees of dfferent categories .

13.2: Infra-structure :

Different institutes involved in the management of public health and agricultural pesticides were established since the early last century ( Wellcome Laboratories, 1902, Medical Research Laboratories, Public Health School, 1920, Sennar Malaria Training Centre, Blue Nile Training and Research Institute …etc. ) .Most of these Institutes receive international donations and support beside the governmental component . Never-the-less, there is still great need for rehabilitaion and up-grading .

14. Public Education and Information Exchange:

Creation of community awareness; education, motivation and involvement in public health management including pesticides is usually done through mass media, public lectures, booklets, leaflets, posters…etc. It worth noting that in 1999, a comprehensive special manual ( an arabic version ) for safe and juduious use of pesticides has been issued by the Fedral Ministry of Health in collaboration with WHO .

15. : Monitoring vector resistance and susceptibilty to insecticides:

Among all preventive measures for malaria and other vector control programes, chemical insecticides play a major role . They are used for indoor house residual spraying (IHRS), larviciding, space spraying, and impregnation of insecticde treated nets ( ITNs ) . Thus it is necessary to regularly update information on susceptibilty and/or resistance of malaria and other disease vectors to inseticides currently under use in the country . Monitoring activities has been a routine since the introduction of chemical insecticides for vector control in Sudan in early 1940s.The WHO adult susceptibility test kit and methods are being used . Principly a shift from the use of one isecticide to an other is based on resistance bases provided that it is toxicologically safe and environmentaly sound .