Pesticide Management Bodies and Instruments

In the CILSS (Permanent Interstate Committee for Drought Control in the Sahel) zone, there has been for more than 40 years, an interstate institution called INSAH (Institut du Sahel), which coordinates and animates research and development toward food security and drought and desertification control. This institution also works for better ecological balance in the Sahel region. Among several committees within INSAH, there is the Sahélien Pesticides Committee (CSP[1]) which was tasked to make decisions on the circulation and judicious use of pesticide within the CILSS member states.

Regulation of pesticides in the CILSS zone

The State members Common Regulation on pesticides registration was adopted for the first time in 1992 by the Resolution No. 7/27/CM/92 of the 27th ordinary session of the CILSS Ministerial committee. This resolution became operational in 1994 through the INSAH by the establishment and the operationalization of CSP. Following multiple attempts of ratification by the National Assemblies of individual State members, this regulation was revised with the support of FAO on December 16, 1999 by the Resolution 8/34/CM/99 of the 34th session of the CILSS Ministerial committee. This resolution takes into account member states multiple experiences in pesticide legislation and registration procedures acquired by the CSP since its inception.

This common pesticide registration system is based on the following reasons:

The agronomic, climatic and ecological conditions are almost similar in the Sahelian countries, which facilitates the harmonization of pesticide trials and mutual acceptance of the data;
The technical and scientific expertise required for certification in each country may be used for the benefit of all countries;
The pesticide market is greater at the level of all countries, which increases the regulatory power, and in particular to impose administrative fees, and common registration procedures;
A single office is created for the reception of applications for pesticide registration and a mere approval by CSP is valid in all CILSS Member States, which facilitates registration procedures for the pesticide industry;
This single approval facilitates free movement of pesticides in the CILSS member states by reducing the number of borders where the importation of pesticides must be controlled;
A joint decision making on regional level reduces the risk of confrontation with national conflicts of interest.

Sahelian Pesticides Committee (CSP)

The CSP is the committee responsible for the registration of pesticides on behalf of CILSS member states. It holds the registry of approved and authorized pesticides for the protection of crops in nine countries member of CILSS. These countries include Burkina Faso, Cape Verde, Gambia, Guinea Bissau, Mali, Mauritania, Niger, Senegal and Chad. Most recently in 2011, four countries including Côte d’Ivoire, Benin, Guinea (Conakry) and Togo joined the CILSS organization, which makes the number of states to 13. However, these new member states have not yet ratify the Common Regulation on Pesticide of CILSS member states on the registration of pesticides on the pretext of they signed Regulation C/Reg.3/05/2008 on the harmonization of Rules governing the registration of pesticides in ECOWAS and, when it comes into force, supersedes the national regulations.

Objectives of CSP

The mission of the CSP includes:

To promote and coordinate activities and research on agricultural inputs (seeds, pesticides, fertilizers), biosafety and crop protection;
To promote the synergism of legislative and regulatory guidelines on agricultural inputs and biosafety in the region;
The monitoring and implementation of regional and international regulations and conventions related to agricultural inputs;
To ensure the implementation of decisions made by regional committees for the regulation and harmonization of agricultural inputs at sub-regional and national levels;
To promote the integrated management pests.

Assignment of CSP

The main tasks assigned to CSP are:

Defining methods for monitoring the composition, quality and evaluation of products with regard to humans, animals and the environment;
Defining technical guidelines concerning the data to be supplied by the applicant for approval of pesticide and the tests to be carried out;
Keeping the registry of approvals and authorizations of pesticides;
Making an inventory of the pesticides used or sold in CILSS countries;
Establish the list of prohibited or severely regulated pesticides in CILSS countries;
Maintaining links between the National Pesticide Management Committees (CNGPs) in CILSS member states.

CSP will be replaced in the coming months by a new institution that will cover all the countries of West Africa.

Scope of the Regulation

The scope of the Common Regulation is the authorization, release on the market, use and control of active ingredients as well as formulated products of pesticides in member states. This regulation also applies to the classification, labeling, and packaging of pesticide formulations.

The management of pesticides, as stipulated in the Common Regulation, is based on a division of responsibilities between the regional and national levels.

The activities of pre-registration (experimentation) and post-registration (marketing, import/ export, use, monitoring, information and destruction of obsolete products) are carried out by national research and extension structures.

The role of the regional level is to assess the registration applications for approval. Each year CSP publishes at least one list of registered pesticides that should be used in the CILSS member countries.

This publication includes:

The global list of pesticides including all categories of crop protection products;
The list of insecticides to control insect;
The list of acaricides to combat mites;
The list of herbicides to destroy weeds;
The list of fungicides to control fungi causing diseases for crops;
The list of the nematicides against nematodes;
The list of the bactericide to control bacteria;
The list of rodenticides to control rodent.

These lists also contain biopesticides such Bt based products containing suspensions of Bacillus thuringiensis against caterpillars or products based on suspensions of Aspergillus against aflatoxins. However, the analysis of pesticides list released each year indicates the presence of few biological products. This is very insufficient for the promotion of sustainable agriculture, with less risk to human health and the environment in the Community.

Strengths and weaknesses of CSP

The Common Regulation which is a very close interstate cooperation for the registration and management of pesticides within the CILSS countries is now cited as a reference in the world. However, this regulation presents strengths and weaknesses that need to be capitalized for better promotion of sustainable agriculture and food and nutritional security of populations.

Strengths:

The system has been operational since 1994 without its relevance being questioned;
The legal basis of this committee is strong (ratification by all member states);
Relative financial autonomy;
The staff of the Permanent Secretariat have a very good knowledge of the work to be carried out and have the necessary expertise;
The synergism of expertise in a sub-regional system for a sound assessment of pesticide registration applications;
Existence of a functional and regularly updated database on pesticides: authorized pesticides (under Provisional Authorization for Sale or approval), and prohibited pesticides;
Existence of technical documents for the evaluation of pesticide applications (pesticide registration documents for agricultural use, public health pesticide registration documents, biopesticides registration document, procedural manual, framework protocols and specific protocols for the testing of pesticides);
Compliance with basic procedures, availability of good reading grids and decisions on files;
Respect for confidentiality.

Weaknesses

Virtually no control of pesticides (conformity, residues, transport, storage, conditions of use, etc.) circulating in the member countries;
Low promotion of organic products;
Almost total absence of enforcement;
Non-functionality of CNGPs in certain countries;
Low risk assessment of pesticides for human health and the environment;
A multitude of working languages (French, English, Arabic, Portuguese);
Insufficient technical expertise in certain areas.

Selected References

CILSS, 1999. Règlementation commune aux Etats membres du CILSS sur l’homologation des pesticides Version révisée Décembre 1999.

Diarra, A., 2015. Revue des politiques sur les pesticides et les produits vétérinaires dans l’espace CEDEAO. USAID/WA, N° West Africa-JSR-2015-2.

REDISSE, 2016. Plan de gestion intégrée des vecteurs et des pesticides du projet. Rapport provisoire. Dakar, Sénégal.

Ruelle P., Van der Valk, H & Sylla, C.H., 2012. Evaluation du système d’homologation commune des pesticides dans les Etats membres du CILSS et du Comité Sahélien des Pesticides Rapport de la mission d’évaluation indépendante FAO 2012.

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Read French version of phytosanitary regulations in CILSS zone

[1] The French acronym for the Sahelian Pesticide Committee, CSP, is maintained throughout the text.