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Stringent Regulation Of Agrochemicals Needed

by Wangah Wanyama
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By Joshua Kato

At around 2pm in the afternoon, Nathaniel Abigaba started spraying his cattle. This was the third time he was doing so in a month however the ticks refused to go away. Meanwhile his herd of 30 milking cows plus several indigenous cattle was reducing production of milk each passing day.
Abigaba mixed several different chemicals including pesticides to create a concoction that he had been told was ‘tougher’ to the ticks.
“I was told that this was the toughest remedy against ticks,” he says. The next day, some of his cows started getting blind while others lost appetite. He seemed to have jumped from the flying pan into the fire! “I could not even properly explain the different chemicals that I used,” Abigaba says.
It is not surprising that the Government has been implored to urgently institute a robust regulatory system on the use of crop-based Agrochemicals and Veterinary Inputs (ACVIs) for the safety of Ugandans, the environment and investments in the sector.
According to findings by a special committee set up to investigate the effectiveness of Agrochemicals and Animal Health Products in Uganda, the current regulatory framework is characterized by strategic loopholes that are being exploited by some industry players to the detriment of human health, the environment and marketing efforts.
The committee was established by the Minister of Agriculture, Animal Industry and Fisheries, Frank Tumwebaze in September 2021, following widespread outcries by farmers on the low effectiveness of some of the available ACVIs in Uganda. Past efforts to mitigate the problems have not yielded the desired results. As such, the Minister formed a highly technical study team to assess the persistence of the problems, including the prevalent drivers, and propose viable interventions.
The eleven-member committee set up by Frank Tumwebaze, Minister, MAAIF was chaired by Prof. John David Kabasa established that there are outstanding gaps in the regulation of the importation, distribution, usage and knowledge on the effects of the ACVIs in the country, which has led to gross misuse and abuse of the chemicals. Several laws were also cited to be obsolete or wanting, and need to be reviewed. Members of the committee included: Dr. Stevens Kisaka,
who was the Secretary and Dr. Eve Kasirye Alemu, as the Deputy Chairperson. Members included: Dr. Julian Adyeri Omalla, Hudda Mahmood, Mrs. Beatrice Byarugaba, Dr. Ben Sekkamate, Dr. Patrick Vudriko, Mr. Emmanuel Tayebwa Rutamwebwa, Dr. John Nuwagaba, and Ms. Flora Kiconco who also served as the Legal counsel.
Farmers have over the years faced pressure to increase production and productivity due to the rapidly growing population and the need to increase their incomes. ACVIs have been adopted as an option to spurring production and productivity, although this has not created the intended results.

The pressure coupled with the inadequate knowledge on use has led to the improper use of some of the ACVIs and as such some Ugandan agricultural products have suffered rejection on the export market.
“Critical dangers are posed to the environment, food consumers, soil and water pollution, while potentially leading to the emergence of resistant strains of weeds and pests, ecological instability, and toxicity to humans and other organisms,” the report says. Such examples include the unintended killing of Crested Cranes in Lwengo after farms used dangerous chemicals in rice fields, blind cattle in many places around the cattle corridor due to abuse of chemicals and the growing resistance to acaricides by ticks. In fresh foods markets, it is common to see vegetables and fruits sprayed with farm chemicals while on sale!
Agrochemicals include specialty chemical products used in agriculture, for example, pesticides, soil conditioners, herbicides, fungicides, and nematicides, as well as synthetic fertilizers, hormones, and other chemical growth agents, and concentrated stores of raw animal manure.
Animal health products (veterinary inputs) refers to all pharmaceutical, biological, and medicinal products, including but not limited to, feed products, vaccines, parasiticides, and all other products intended to enhance the health or performance of all species of animals (also extending to aquatic animals and poultry but excluding humans).

“I cannot manage my coffee shamba without applying chemicals. On top of the wilt, there are bugs that affect the beans. It is making farming quite expensive,” says Sunday Mukasa, a coffee farmer in Nakaseke.
Pests and diseases remain a big threat to increasing agricultural production and productivity.
According to the committee, the loss of 35% to 40% of crops to pests and diseases severely limits the productivity of both cash crops and food crops. Unfortunately, the country is now host to pests and crop diseases that have no known cure and are fast wiping out major food and cash crops such as banana, sweet potato, cassava, Irish potato, maize, and robusta coffee, among others.
The banana bacterial wilt disease, for example, causes the loss of seven out of ten expected bunches, resulting in annual economic losses of approximately US$ 299.6 million. The sweet potato weevil and virus infestation causes a total loss of approximately US$6.7 million. The late blight disease that has become resistant to herbicides affects six out of every ten potatoes, yet the national demand for the crop in 2015 was up to 1,000,000 metric tonnes. The Cassava Brown Streak Disease and Cassava Mosaic are reducing cassava production and the country is producing a mere 6.7 million tonnes annually compared to a potential 30 million tonnes.
Similarly, due to drought and pests, Ugandan farmers’ average maize yield is 2.7 tonnes per hectare, compared to a potential 9 tonnes per hectare.
According to MAAIF statistics, livestock represents about 16% of the agricultural GDP and about 4% of the national GDP. However, the country continues to experience recurrent outbreaks of endemic, emerging, and re-emerging animal and/or human diseases. These include African Swine Fever (ASF), Peste des Petits Ruminants (PPR), Foot and Mouth Disease (FMD), Lumpy Skin Disease (LSD), sheep and goat pox virus, brucellosis, hemorrhagic fevers including Ebola and highly pathogenic avian influenza hemorrhagic fever (CCHF), ticks and tick-borne diseases, anthrax, and rabies. These, together with other diseases and vectors, cause losses of 35 percent to 40 percent, thus limiting animal productivity. Trypanosomosis causes an average annual loss of US$ 653 per household in terms of mortality and milk loss in cattle-keeping communities. In
total, Uganda suffers an aggregated annual loss (direct and indirect) of over US$ 1.1 billion due to ticks and tick-borne diseases and the situation is getting worse due to increasing acaricide resistance.
In its report that is yet to be released, the committee noted that the use of ACVIs has substantially increased in Uganda in recent years due to the above challenges. Farmers have largely blamed the failures on the presence of counterfeits on the market among other factors.
In its findings, the committee established that while the major sources of veterinary drug supply in Uganda include the government, private sector and nongovernmental organizations, there are the illegal drug sellers strewn across the country, and they obtain the drugs without a legal license from both inside and outside the country.
“It is not uncommon to find that these illegal drugs are also exported to neighboring countries where there is a growing need for the growth of animal sub-sectors.” the report noted.
There are four countries that are the major manufacturers of veterinary drugs imported into Uganda. These include China in Asia, Kenya in Africa, Jordan in Europe, Jordan in the Middle East, and India in Asia.
The report notes that sources of agrochemicals include manufacturers in China, followed by India. Uganda also imports agrochemicals manufactured by 10 companies in Kenya and two (02) in Tanzania. Importantly, there are nine (09) manufacturers in Uganda who supply the domestic market with agrochemicals.

The committee observed that there is need to create an autonomous Authority to regulate veterinary medicines other than the National Drug Authority (NDA) for prioritization purposes.
Currently, the Authority has the mandate to supervise the importation, exportation, and promotion of veterinary drugs in addition to human drugs. However it was observed to be understaffed and underprioritizing veterinary medicines and devices regulation.
The committee recommended the separation of veterinary medicines and devices from human medicines and devices to allow prioritization of the regulation of veterinary medicines under an autonomous Authority.
It was also noted that the National Drug Policy and Authority Act Cap 206 that established NDA is not explicit on the membership of veterinarians and veterinary drug suppliers on the Committee on Essential Drugs. The Committee was found to be in place, but with representation from the human health sector only.
Further still, the National Drug Authority Act under Section 8 (2) and (3) requires the NDA to make sure that the country has a National Formulary to regulate the importation or sale of any drug. However, no veterinary formulary was found to exist. This hinders the effective training of animal healthcare workers, and the effective and efficient prescription of drugs for various diseases. There is also no registered local herbal drug for veterinary use, yet farmers are using them.
The Ministry of Agriculture, Animal Industry and Fisheries was implored to reclaim the mandate for regulation of veterinary medicines and devices and create relevant structures that support efficient regulation.
“It was noted that several veterinarians and para-veterinarians are practicing without licenses, which calls for the Uganda Veterinary Board (UBV) strengthen enforcement and amend the law to decentralize veterinary services so that District Veterinary Officers can work with UVB to regulate veterinary practitioners in the field,” one of the committee members said.
The report also implored government to establish drug usage traceability systems as per international standards and enforce the restriction of prescription drugs to professionals only. A recommendation was made to the ministry of agriculture to fast-track the finalization and operationalization of the digital traceability system.
The committee noted that while agricultural chemical supplies are mostly traded at the “Container Village” in Kampala, many agrochemicals are also sold in public local markets, sometimes in unlabeled and recycled containers such as beverage bottles. Repackaging was observed to compromise the quality of agrochemicals. To stem the vice, it was recommended that manufacturers are engaged to package in sizes that are more tenable for smallholder farmers.
The ministry of agriculture was advised to appoint scientists to conduct efficacy trials and monitor of efficacy trails of agrochemicals.
“The other big challenge is faking genuine chemicals. As genuine producers we have faced a lot of backlash and of course loss of business from crooks who fake our products,” observed Christine Nakubulwa, a producer of several farm chemicals.
The committee therefore challenged manufacturers and agents were challenged to improve security features for their products to make it hard to fake. The committee recommended that all imported products should be subject to analysis before final clearance for distribution to farmers.
A number of laws relevant to ACVIs were also recommended for review and amendment to fit the new market trends.

Government was encouraged to consider promoting the local production of ACVIs given the central location of Uganda in the Great Lakes region of Africa. The annual import of veterinary inputs averages 378,000 litres of acaricides and 83,000 litres of associated drugs, which results into an annual forex outflow worth US$ 83.3 million.
“This has been our stand for years. Producing these chemicals locally will reduce incidences of scarcity but also help tame fakes,” said Stephen Birungi, director at Alfasan Uganda, who produce different farm chemicals at Namanve.
The combined ACVI forex outflow presents a significant drain on the national economy, which dents Uganda’s goal of import substitution and the creation of jobs among the youths. This trend calls for a repositioning of the sector toward the development of viable import substitution measures
The committee further noted that border controls are key points of ACVI quality and risk management as they are the first point of action for identifying unwanted or illegal imports. “It is therefore essential that better and internationally acclaimed border control mechanisms are
established with well-trained border control personnel, inspectors, and customs officers that are well facilitated and equipped.” the committee advised.
The committee said that the Uganda strategy for ACVI and agro-biosecurity should be comprehensive and focused on harnessing all threats and opportunities provided by the various pests, diseases, and associated ACVI industries. This will unleash the renaissance of comprehensive Afro-centric ACVI industrial value chain development, biosecurity, and
regulation so as to lead Uganda to where it should be as projected by Vision 2040 and Africa Agenda 2063.

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