UNITED NATIONS SC

UNEP/POPS/POPRC.6/INF/24

Distr.: General 1 October 2010 Stockholm Convention on Persistent Organic English only Pollutants

Persistent Organic Pollutants Review Committee Sixth meeting Geneva, 11–15 October 2010 Item 5 of the provisional agenda* Consideration of the draft risk management evaluation on endosulfan

Compilation of information submitted pursuant to Annex F that is relevant to endosulfan

Note by the Secretariat

The annex to the present note contains a compilation of information pursuant to Annex F to the Stockholm Convention that is relevant to endosulfan and has been submitted by parties and observers in response to the invitation issued by the Committee in accordance with Article 8, paragraph 7 (a), of the Convention. The annex is presented as prepared by the working group and has not been formally edited by the Secretariat.

* UNEP/POPS/POPRC.6/1/Rev.1.

K1062292 061010

For reasons of economy, this document is printed in a limited number. Delegates are kindly requested to bring their copies to

meetings and not to request additional copies.

UNEP/POPS/POPRC.6/INF/24

Annex

Compilation of information submitted pursuant to Annex F that is relevant to endosulfan

Draft prepared by the ad hoc working group on endosulfan under the POPs Review Committee of the Stockholm Convention

July 2010

Contents

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INTRODUCTION ...... 4

ADDITIONAL ANNEX E INFORMATION...... 5 (i) Production data, including quantity and location...... 5 (ii) Uses...... 7 (iii) Releases, such as discharges, losses and emissions ...... 16

ANNEX F INFORMATION...... 18

(A) EFFICACY AND EFFICIENCY OF POSSIBLE CONTROL MEASURES IN MEETING RISK REDUCTION GOALS...... 18 (i) Description of possible control measures...... 18 (ii) Technical feasibility...... 26 (iii) Costs, including environmental and health costs ...... 28

(B) INFORMATION ON ALTERNATIVES (PRODUCTS AND PROCESSES)...... 33 (i) Description of alternatives ...... 33 (ii) Technical feasibility...... 51 (iii) Costs, including environmental and health costs ...... 51 (iv) Efficacy ...... 53 (v) Risk ...... 54 (vi) Availability...... 55 (vii) Accessibility...... 56

(C) SUMMARY ON INFORMATION ON IMPACTS ON SOCIETY OF IMPLEMENTING POSSIBLE CONTROL MEASURES...... 56 (i) Health, including public, environmental and occupational health ...... 56 (ii) Agriculture, including aquaculture and forestry...... 59 (iii) Biota (biodiversity) ...... 67 (iv) Economic aspects...... 68 (v) Movement towards sustainable development...... 70 (vi) Social costs...... 71

(D) WASTE AND DISPOSAL IMPLICATIONS (IN PARTICULAR, OBSOLETE STOCKS OF PESTICIDES AND CLEAN‑UP OF CONTAMINATED SITES) ...... 71 (i) Technical feasibility...... 71 (ii) Costs...... 73

(E) ACCESS TO INFORMATION AND PUBLIC...... 73

(F) STATUS OF CONTROL AND MONITORING ...... 76

(G) ANY NATIONAL OR REGIONAL CONTROL ACTIONS ALREADY TAKEN, INCLUDING INFORMATION ON ALTERNATIVES, AND OTHER RELEVANT RISK MANAGEMENT INFORMATION ...... 79

(H) OTHER RELEVANT INFORMATION FOR THE RISK MANAGEMENT EVALUATION ...... 83

(I) OTHER INFORMATION REQUESTED BY THE POPRC...... 101 ANNEX-I ...... 106 ANNEX-II...... 115

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Introduction Endosulfan, a synthetic organochlorine compound, is widely used as an agricultural insecticide. It was introduced into the market already back in the mid 1950s but plant protection products containing endosulfan are still used in a number of countries worldwide. The European Community and its Member States that are Parties to the Convention submitted a proposal to list endosulfan in Annexes A, B or C of the Convention in 2007 (UNEP/POPS/POPRC.3/5). At its fourth meeting held from 13 to 17 October 2008 in Geneva the POPRC decided to invite Parties and observers to submit the Annex E information on Endosulfan proposed by European Community and its Member States that are Parties to the Convention for listing in Annexes A, B, and/or C of the Convention in order to prepare a draft risk profile. A large number of parties and observers have responded to this invitation. The ad hoc working group prepared the draft risk profile (UNEP/POPS/POPRC.5/3). A supporting document for the draft risk profile can be found in document UNEP/POPS/POPRC.5/INF/9. At its 5th meeting in Geneva from 12 to 16 October 2009 the POPRC reviewed and adopted a revised draft risk profile on endosulfan by which it agrees that the POP characteristics of the chemical warrant global action. The Committee decided to develop for endosulfan a risk management evaluation document that includes an analysis of possible control measures for consideration at its next meeting and final recommendation to the COP for its listing in the Annexes of the Convention.i Parties and observers have been invited to submit to the Secretariat information specified in Annex F by 8 January 2010ii. Several EU and non EU Member States and a few organisations followed the invitation and provided the relevant information. Among them Australia, Brazil, Bulgaria, Burundi, Canada, China, Colombia, Costa Rica, Croatia, Germany, India, Japan, Lithuania, Madagascar, Malaysia, Mexico, Monaco, Norway, Poland, Romania, Sri Lanka, Switzerland, Togo, Ukraine, the United States of America and institutions like CropLife, IPEN, ISC and MAI. They provided useful information according to Annex F of the Stockholm Convention. In addition to the information relevant for the risk management evaluation, two parties (Australia and Norway) provided additional information relevant for the risk profile with respect to adverse human health effects. The corresponding information provided by Australia can be found in chapter “(I) Other information requested by the POPRC”. The corresponding information provided by Norway can be found in chapter “(h) Other relevant information for the risk management evaluation”.

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Additional Annex E information (i) Production data, including quantity and location Australia Production data: Endosulfan is not produced or manufactured in Australia but technical active ingredient is imported (from e.g. Israel or Germany) and formulated into four registered Australian products. Therefore, these data represent national sales of endosulfan (not production). Quantity: Tonnes of active ingredient sold in the Australian market per year: 2004: 125.2 tonnes 2005: 119.4 tonnes 2006: 116.4 tonnes 2007: 74.1 tonnes 2008 (to mid-December): 89.9 tonnes Location: Brisbane, Queensland; Other: A small amount of endosulfan is formulated in Australia and exported to New Zealand Brazil Data provided by companies owning registries of formulations based on endosulfan indicate that the amounts (tons of active ingredients) commercialised/used in Brazil, in the time span of 2000 – 2006 are: 2000: 5346.6 tons 2001: 4058.0 tons 2002: 2454.8 tons 2003: 4179.1 tons 2004: 7294.1 tons 2005: 6664.9 tons 2006: 6010.1 tons Authorized Uses: Leaf application in the crops of cotton, cocoa, coffee, sugar cane and soybean. Application in the soil, in sugar cane crops. Non-agricultural uses: Application to control ant pests. Use as a wood protector: Exclusive use to protect wood and timber to manufacture railway sleepers, posts, crosses, fence posts for farm property, and roof beams. Below are listed all the crops and biological targets approved. Soybean: Euschistus heros, Piezodorus guildinii ,Pseudoplusia includes, Nezara viridula, Anticarsia gemmatalis, Diabrotica speciosa, Mocis latipes, Spodoptera frugiperda, Etiella zinckenella, Epinotia aporema Cotton: Alabama argillacea, gossypiella, Heliothis virescens, Anthonomus grandis, Polyphagotarsonemus latus, Aphis gossypii, Frankliniella schultzei, Costalimaita ferruginea vulgata, Aphis gossypii, Bemisia tabaci, Helicoverpa zea, Horcias nobilellus, Dysdercus spp., Eutinobothrus brasiliensis Coffee: Hypothenemus hampei, Sugar cane - Heterotermes tenuis, Migdolus fryanus, Cornitermes cumulans, Cocoa: Steirastoma breve, Selenothrips rubrocinctus, Peosina mexicana, Maecolaspis ornata, Sylepta prorogata, Toxoptera aurantii, Taimbezinhia theobromae, Ant control - Atta opaciceps

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Bulgaria None. Endosulfan has never been produced in Bulgaria, but had been formulated by Agria AD as Thiogrin 35 EC, 350 g endosulfan /L formulation in 1996, banned for use as of Jan 2000. Table 1: List of Producers/Importers of Endosulfan ID Company Town Country 0001 DIACHEM SPA 24061 ALBANO SA. ITALY 0002 HELM AG 20097 HAMBURG GERMANY 0003 HOECHST SCHERING AGREVO GMBH 65926 FRANKFURT/MAIN GERMANY 0004 PAC S.R.L. 24124 BERGAMO ITALY 0005 SCAM 41010 MODENA ITALY Source: ESIS (European Chemical Substanses Information System): http://ecb.jrc.ec.europa.eu/esis/ Synonyms (IUCLID Chemical Data Sheet): BENZOEPIN (JMAF); Source: DIACHEM SPA, Albano SA.; THIODAN, Source: PAC S.R.L., Bergamo; THIODAN, BENZOEPIN, Source: SCAM , Modena Quantity produced: 10 000 – 50 000 tonnes; Canada Not produced in Canada. China In China, the output of endosulfan is 4602 tons for 2006, 5003 tons for 2007, and 5177 tons for 2008, while Anpon Electrochemical Co. LTD, located in the suburban area of Huai’an City, Jiangsu Province, produced 4706 tons of endosulfan in 2008. Costa Rica Costa Rica non produce el endosulfan. Croatia Endosulfan and products based on endosulfan have not been in use since 1 July 2007, accordance with the Decision of 28 May 2007 concerning the withdrawal of authorizations for plant protection products containing certain active substances. Existing stocks were allowed to be used for agricultural purposes until the end of 2008. Mostly used in orchards and vineyards as insecticide (apple, grapevine) and on sugar beet. According to the registers submitted by companies to the Croatian Institute for Technology, and based on their statements, there is no recorded production or sale of endosulfan-based products after that date. Also, companies importing and manufacturing endosulfan-based plant protection products have confirmed that in their warehouses there are no longer any of the said raw materials (technical endosulfan) nor any endosulfan-based products. Germany 10 000 – 50 000 t/a in Europe. Production of endosulfan in Germany is going to be shut down. Besides the German manufacture, manufacturing of endosulfan has been reported for Israel, India and South Korea [Australian National Registration Authority for Agricultural and Veterinary Chemials Review of Endosulfan 1998]. India 10,500 Mt in Gujarat, Kerala and Maharashtra states. Until 2006, the EU was the largest producer of Endosulfan. Its production in the EU ceased towards end of 2006. Now production of Endosulfan (technical grade) is in India, China, Israel and Korea. Endosulfan is one of the largest used insecticides in India. Out of estimated annual production of 9500 t (technical grade), 4500 to 5000 tonnes are consumed domestically and the balance is exported in technical grade and/or in the form of formulations. India, accounts for 50% to 60% of the global production of Endosulfan estimated to be 18000 to 20000 tonnes. (Annexure-I). Lithuania Remark: By the e-mail message of 5 January 2009 from the Lithuanian Ministry of Environment it was reported that according to the information provided by the Competent Authorities responsible for different areas of chemicals management

6 UNEP/POPS/POPRC.6/INF/24 there are no data on endosulfan production, uses or placing on the market in Lithuania. There are no registered plant protection products in which endosulfan is a constituent part. Madagascar No local production of substance (active substance and in commercial products); total import from 2000 to 2009: 62.935 L (yearly maximum: 23.900L in 2001); location: Toilara, Mahajanga (cotton) and Hauts Plateaux (vegetables). Malaysia Endosulfan has been banned since 2005 where the importation, exportation, manufacturing, possession, sale and use become prohibited. Monaco This chemical is not produced nor used in Monaco Norway No production. Endosulfan has never been produced in Norway. Poland No production. Prohibition or restriction of production, use, import and export by legislative measures including trained personel and risk communication system. Sri Lanka Sri Lanka has already prohibited the import and distribution with effect from 31.12.1997 in order to reduse occupational and suicidal death rate. Togo None. Ukraine Never produced in Ukraine. Is not included into the List of hazardous chemicals, production and trade of which should be licensed (Law of Ukraine “On licensing of certain types of activities (2000), Decree of the Cabinet of Ministers #1698 of 14.11.2000, Decree of the Cabinet of Ministers #1287 of 17.08.1998). United States of America No endosulfan production reported for the last two years (2007 and 2008). ISC See next chapter (ii): uses. (ii) Uses Australia There are four registered endosulfan products in Australia for use on: canola, linseed, safflower, sunflower, cereals, cotton, chickpeas, cowpeas, pigeon peas, adzuki beans, faba beans, field peas, navy beans, mung beans, lupins, soybeans, cabbages, cauliflower, broccoli, beetroot, capsicums, okra, cape gooseberry, carrots, celery, cucurbits, egg plant, potatoes, sweet potato, taro, tomatoes, avocados, cashews, custard apple, citrus, guavas, persimmons, kiwi fruit, longans, loquats, lychees, macadamia nuts, mammey apples, mangoes, passion fruit, pawpaw, pecan nuts, pistachios, pome fruit, pomegranates, rambutans, sapodillas, tamarillos, native trees, shrubs, nursery crops, ornamentals, wildflowers, proteas and tobacco. Brazil Authorised Uses: Leaf application in the crops of cotton, cocoa, coffee, sugar cane and soybean. Application in the soil, in sugar cane crops. Non-agricultural uses: Application to control ant pests. Use as a wood protector: Exclusive use to protect wood and timber to manufacture railway sleepers, posts, crosses, fence posts for farm property, and roof beams. Below are listed all the crops and biological targets approved.

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Soybean: Euschistus heros, Piezodorus guildinii, Pseudoplusia includes, Nezara viridula, Anticarsia gemmatalis, Diabrotica speciosa, Mocis latipes, Spodoptera frugiperda, Etiella zinckenella, Epinotia aporema Cotton: Alabama argillacea, Pectinophora gossypiella, Heliothis virescens, Anthonomus grandis, Polyphagotarsonemus latus, Aphis gossypii, Frankliniella schultzei, Costalimaita ferruginea vulgata, Aphis gossypii, Bemisia tabaci, Helicoverpa zea, Horcias nobilellus, Dysdercus spp., Eutinobothrus brasiliensis Coffee: Hypothenemus hampei Sugar cane: Heterotermes tenuis, Migdolus fryanus, Cornitermes cumulans Cocoa: Steirastoma breve, Selenothrips rubrocinctus, Peosina mexicana, Maecolaspis ornata, Sylepta prorogata, Toxoptera aurantii, Taimbezinhia theobromae, Ant control: Atta opaciceps Bulgaria Endosulfan is not placed on the market and is not permited for use from the beginning of 2000 in Bulgaria. In the past it was used in agriculture as insecticide. In 1996, several plant protection products, containing Endosulfan were placed on the market like: - Thionex 50 WP, 500 g endosulfan /L, Makhteshim Agan, Israel; - Thionex 35 EC, 350 g endosulfan /L, Makhteshim Agan, Israel; - Thiotox 35 EC, 350 g endosulfan /L, Diana ET, Bulgaria; - Thiogrin 35 EC, 350 g endosulfan /L, Agria AD, Bulgaria; - Thiodan 35 EC, 350 g endosulfan /L, AGREVO GMBH, Germany; (now BAYER CROPSCIENCE) - Cleothan 30 EC, 233 g endosulfan/L+ 133 g dimethoat /L , Climatex EAD, Bulgaria. In 1999 the products were withdrawn from the market and the production and use were ceased at the end of 1999, the authorisation for placing on the market expired at the end of 1999. No authorisations are given onwards. Canada Currently registered pest control uses include greenhouse and terrestrial food and ornamental crops, and for outdoor bait stations of food processing plants. China Due to the fact that endosulfan is not easily cross-resistant with other pesticides, it is a good choice for rotation angriculture and defering pests’ resitance to pesticides. Endosulfan has been registered for use in wheat, cotton, fruit, tea tree, and tabacoo. More importantly, it has been applied for pest prevention and control in cotton planting and further study is being carried out on its application in tea planting area. As endosulfan is effective in pest prevention and control in cotton planting and rationl use of it poses no safety risk to humans, its application risk is acceptable. Costa Rica Nombre del producto: Endosulfan casagri 35 EC; tipo de uso: uso agricola; año: 1993; referencias: MAG; comentarios: Venta restringida bajo la receta profesional. Se prohibe el uso del arroz, solo se autoriza el uso agricola de endosulfan en formulaciones liquidas o micro encapsuladas que contengan concentraciones menores o iguales a 35% de ingredient activo. Nombre del product: Endosulfan 93-96 TEC; tipo de uso: uso agricola; año: 1992; referencias: MAG; comentarios: Venta restringida bajo la receta profesional. Se prohibe el uso del arroz, solo se autoriza el uso agricola de endosulfan en formulaciones liquidas o micro encapsuladas que contengan concentraciones menores o iguales a 35% de ingredient activo. Se comercializa en estaños de hierro de 208, 200 litros pichinga de hierro de 20, 10 y 18 litros y en envases plásticos de 1 litro y 500 mL. Envases metálicos de 100 y 250 mL. Nombre del producto: Endosulfan 36 EC; tipo de uso: uso agricola; año: 1995; referencias: MAG;

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India Used as agricultural insecticide for pest management in cereals, pulses, oilseeds, fibre crops, tea, vegetables and fruits. It is registered and used in such agriculturally important countries as India, China, United States of America, Brazil, Argentina, Australia, Canada, Mexico, Israel, Japan, Nigeria etc, Pakistan etc. It must be noted that these countries account for more than 60% of world’s area under crop production. (Annexure-I) Lithuania Remark: By the e-mail message of 5 January 2009 from the Lithuanian Ministry of Environment it was reported that according to the information provided by the Competent Authorities responsible for different ares of chemicals management there are no data on endosulfan production, uses or placing on the market in Lithuania. There are no registered plant protection products in which endosulfan is a constituent part. Madagascar Agriculture, mainly cotton and less vegetable. Malaysia Banned. Norway No uses. Use banned since 1/1/1999. It is prohibited to stock, sell and use endosulfan as a pesticide. Poland Endosulfan is not included in the register of active substances, which are allowed for use in biocides Romania Currently banned. In 2009 a derogation for use as rodenticide for the rape, orchards, stalky cereals crops (harmful organisms – Microtus arvalis) was granted by the Ministry of Agriculture - National Phytosanitary Agency, for a quantity of 16620.8 kg endosulfan (included into 47488kg/44800 litres THIONEX 35EC), in accordance with the provisions of Article 8 (4) of Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant products on the market. Switzerland Endosulfan is not registered anymore in Switzerland as a plant protection product. In 2009 product registrations were revoked and companies are only allowed to sell existing stocks. Togo Use in cotton production: As of 11 December 2000, Endosulfan stock and its consumption was 10.889 liters. For the 2010-2011 cotton production campaign there is no stock and use will be discontinued. Use of alternatives has already started during the 2009-2010 production campaign (Source: Director General, Nouvelle société cotonnière du Togo: NSCT, 11 December 2009). Ukraine Probably used in the former USSR. Registered in Ukraine within the period 1992-1996 for import from Germany. At present there are no available data on the imported quantity. Since 1996 was not registered and not included into the List of pesticides and agrochemicals allowed for usage in Ukraine (Law of Ukraine “On pesticides and Agrochemicals” (1996), Decree of the Cabinet of Ministers #295 of 04.03.1996). Not revealed among the identified obsolete pesticides in the OP inventory of 2003 (Order of Three Ministers (2001) and the Decree of the Cabinet of Ministers of Ukraine “On developing the infrastructure for elimination of the banned and obsolete pesticides” (2002)). United States of America Insecticide used for crop (including ornamental crop) and livestock protection. ISC General Endosulfan is a safe and cost effective insecticide and acaricide for protecting crops used for food, clothing, shelter and energy from attack by and is registered for use in most of the major crop producing countries of the world. Although

9 UNEP/POPS/POPRC.6/INF/24 first introduced over 50 years ago, endosulfan continues to be recognized as the product of choice in the protection of a wide range of crops including vegetables, fruits, nuts, cereal grains, soybean, sugar cane, coffee, sunflower and cotton, as well as ornamental shrubs, trees, vines, and ornamentals for use in commercial agricultural settings. It carries this distinction because of its efficacy in the battle against insects including, among other pests, the boll weevil, , worms, whiteflies, leaf miner, aphids, mites, thrips and stinkbug while being protective of beneficial insects like the honey bee and beetles. Total average annual use of endosulfan is estimated at approximately 15,000 metric tons of active ingredient. It is the third largest off patent, generic agricultural insecticide and is used in all continents except Antarctica. Endosulfan is registered for use in the countries with more than 70% of the food producing farm land in the world. The major markets for endosulfan are Brazil, India, China, Argentina, the United States, Pakistan, Australia and Mexico. The use in Latin America and Asia has been growing consistently, driven by the demand for food and alternative energy requirements. Argentina Endosulfan is important to Argentina: • because of its role in the cost effective and environmentally sound production of crops for food and other uses, making lower prices for the consumer, more profit for the farmer and a more competitive position for Argentina in the world market place; • because of its usefulness in Integrated Pest Management (IPM), resulting from its characteristic of being able to be used for years without insects building a resistance to it; and • because beneficial insects continue to thrive in the crops where it is used making available an abundant population of pollinating insects and honey. In Argentina, endosulfan is registered as an insecticide for use by SENASA (Nacional de Sanidad y Calidad Agroalimentaria) in 45 different crops (Official newspaper Nº 31.546) with its main use being to combat the insects that afflict soybean, sunflower and cotton crops. Soybean is a major export crop for Argentina with over 50 million metric tons produced, which aids not only Argentina from an economic perspective but makes food and energy more affordable to the nation. Without endosulfan, some of the pests encountered today cannot be controlled by the existing replacement insecticides. In Argentina the sunflower crop involves US$ 1.402 billion per year. Argentina is the main exporter of sunflower oil in the world with 2,400,000 ha devoted to this crop. The yield is 4 million ton of seeds and 1.6 million oil tons. Sunflower production is dependant on the IPM containing endosulfan. Cotton is an important crop for the economy of Argentina. It represents one of the largest export products of Argentina including cotton fiber and cotton seed oil. Argentina is the world’s leading producer of sunflower oil followed by Russia and Ukraine. Sunflower oil is the fourth most important production worldwide after soy, palm and colza oils. It represents a major export product for Argentina. Argentina is reliant on endosulfan as part of an IPM for protection of the crop from pests. Volume 1,500 metric tons Registered uses in Argentina (Volume 1,500 metric tones): Crop Pest Rate Alfalfa Chinche de la alfalfa PC 35%: 1,2 - 1,5 l/ha (Piezodorus guildinii) PC 50/: 0,8 - 1 kg/ha Isoca de la Alfalfa PC 35%: 0,7 l/ha (Colias lesbia) PC 50%: 0,5 kg/ha Isoca medidora PC 35%: 1,2 - 1,5 l/ha (Rachiplusia nu) PC 50%: 0,8 - 1 kg/ha Cotton Chinche rayada PC 35%: 1,5 -3 l/ha (Horcias nobilellus) PC 50%: 1 - 1,4 kg/ha Chinche sanguinolenta, Chinche del Poroto (Athaumastus haematicus) Chinche verde

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(Nezara viridula) Oruga de la hoja PC 35%: 1 - 1,5 l/ha (Alabama argillacea) PC 50%: 0,7 - 1 kg/ha Oruga del capullo del algodonero PC 35%: 2 - 2,5 l/ha (Helicoverpa gelotopoeon) PC 50%: 1,4 - 1,7 kg/ha Picudo del algodonero PC 35%: 1,5 - 2 l/ha (Anthomonomus grandis) Pulgón del algodonero PC 35%: 100 - 150 cm3/hl (Aphis gossypii) PC 50%: 70 - 100 g/hl Trips PC 35%: 1 - 1,4 l/ha (Thrips spp.) PC 50%: 0,7 - 1 kg/ha Cereals Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Oruga militar verdadera PC 35%: 2 - 2,5 l/ha (Pseudaletia adultera) PC 50%: 1,4 - 1,75 kg/ha Flowers Alquiche chico PC 35%: 1.5 - 3 l/ha Vegetables (Edessa meditabunda) PC 50%: 1 - 1,4 kg/ha Bicho moro de la papa PC 35%: 300 cm3/hl ( adpersa) PC 50%: 200 g/hl Brucho de la arveja PC 35%: 1,5 l/ha (Bruchus pisorum) PC 50%: 1,1 kg/ha Chinche verde PC 35%: 1,5 - 3 l/ha PC 50%: 1 - 1,4 kg/ha, PC 35%: 1,5 (Nezara viridula) - 3 l/ha Cotorrita PC 35%: 1,5 - 3 l/ha (Empoasca fabae) PC 50%: 1 - 1,4 kg/ha Gusanos cortadores PC 35%: 1,7 l/ha (Agrotis spp.) PC 50%: 1,4 kg/ha Marandova de las solanáceas PC 35%: 1,5 - 2 l/ha (Protoparce sexta paphus) PC 50%: 1 - 1,4 kg/ha Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Oruga militar verdadera PC 35%: 2 - 2,5 l/ha (Pseudaletia adultera) PC 50%: 1,4 kg/ha Polilla de la papa PC 35%: 1,5 - 3 l/ha (Gnorimoschema operculella) PC 50%: 1 - 1,4 kg/ha Pulgón de la papa PC 35%: 100 - 150 cm3/hl (Macrosiphum euphorbiae) PC 50%: 70 - 100 g/hl Pulgón del crisantemo (Macrosiphoniella sanborni) Pulgón del repollo (Brevicoryne brassicae) Pulgón del rosal (Macrosiphum rosae) Pulgón verde del duraznero, Pulgón rojo (Myzus persicae) Pulguilla PC 35%: 0,9 - 1,5 l/ha (Epitrix argentinensis) PC 50%: 1 - 1,4 kg/ha Trips PC 35%: 1,5 -3 l/ha (Thrips spp.) PC 50%: 1 - 1,4 kg/ha Vaquita PC 35%: 1,5 - 3 l/ha (Diabrotica vittegera) PC 50%: 1 - 1,4 kg/ha Pome fruit Agalla de la Hoja del Peral PC 35%: 150 cm3/hl (Eriophyes piri) PC 50%: 100 g/hl Bicho canasto

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(Oiketicus platensis) Enrulador de la hoja (Eulia loxonephes) Herrumbre del Peral (Epitrimerus piri) Psílido del peral (Cacopsyla pyricola) Pulgón lanígero PC 35%: 100 - 150 cm3/hl (Eriosoma lanigerum) PC 50%: 70 - 100 g/hl Sunflower Gusano cortador o Gusano variado PC 35%: 1,7 l/ha (Peridroma saucia) PC 50%: 1,2 kg/ha Gusanos cortadores (Agrotis spp.) Isoca medidora PC 35%: 1,5 l/ha (Rachiplusia nu) PC 50%: 1 kg/ha Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Polilla del girasol PC 35%: 1,5 -3 l/ha (Homoeosoma heinrichi) PC 50%: 1 kg/ha Flax Oruga del capullo del algodonero PC 35%: 2 - 2,5 l/ha (Helicoverpa gelotopoeon) PC 50%: 1,4 - 1,75 kg/ha Corn Gusano cogollero PC 35%: 1,5 l/ha (Heliothis virescens) PC 50%: 1 kg/ha Gusanos cortadores PC 35%: 1,7 l/ha (Agrotis spp.) PC 50%: 1,2 kg/ha Isoca de la espiga PC 35%: 2 - 2,5 l/ha (Heliothis zeae) PC 50%: 1,4 - 1,75 kg/ha Peanut Gusano cortador o Gusano variado PC 35%: 1.7 l/ha (Peridroma saucia) PC 50%: 1,2 kg/ha Gusanos cortadores PC 35%: 1,7 l/ha (Agrotis spp.) PC 50%: 1,2 kg/ha Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Soybean Chinche de la alfalfa PC 35%: 1,2 - 1,5 l/ha (Piezodorus guildinii) PC 50%: 0,8 - 1 kg/ha Chinche verde PC 35%: 1,2 - 1,5 l/ha (Nezara viridula) PC 50%: 0,8 - 1 kg/ha Isoca bolillera PC 35%: 1,5 l/ha (Heliothis sp.) Isoca de la Alfalfa PC 35%: 0,7 l/ha (Colias lesbia) PC 50%: 0,5 kg/ha Isoca medidora PC 35%: 1,2 - 1,5 l/ha (Rachiplusia nu) PC 50%: 0,8 - 1 kg/ha Oruga de las leguminosas PC 35%: 0,6 l/ha (Anticarsia gemmatalis) PC 50%: 0,5 kg/ha Oruga del capullo del algodonero PC 35%: 1,5 l/ha (Helicoverpa gelotopoeon) PC 50%: 1 kg/ha Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Vaquita de San Antonio PC 35%: 1,5 - 3 l/ha (Diabrotica speciosa) PC 50%: 1 - 1,75 kg/ha Sorghum Mosquita del sorgo Mosquita del sorgo (Contarinia sorghicola) (Contarinia sorghicola) Siete de Oro PC 35%:1,5 l/ha (Astylus atromaculatus) PC 50%: 1 kg/ha

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Tobbaco Cotorrita PC 35%: 1,5 - 3 l/ha (Empoasca fabae) PC 50%: 1 - 1,4 kg/ha Gusano cogollero PC 35%: 1,5 l/ha (Heliothis virescens) PC 50%: 1 kg/ha Gusanos cortadores PC 35%: 1,7 l/ha (Agrotis spp.) PC 50%: 1,2 kg/ha Marandova de las solanáceas PC 35%: 1,5 - 2 l/ha (Protoparce sexta paphus) PC 50%: 1 - 1,4 kg/ha Oruga militar tardía PC 35%: 1,5 - 2 l/ha (Spodoptera frugiperda) PC 50%: 1 - 1,4 kg/ha Pulgón de la papa PC 35%: 100 - 150 cm3/hl (Macrosiphum euphorbiae) PC 50%: 0,7 - 1 kg/ha Pulgón del repollo (Brevicoryne brassicae) Pulgón verde del duraznero, Pulgón rojo (Myzus persicae) Pulguilla PC 35%: 0.9 - 1,5 /ha (Epitrix argentinensis) PC 50%: 0,6 - 1 kg/ha Trips PC 35%: 1,5 - 3 l/ha (Thrips spp.) PC 50%: 0,7 - 1 kg/ha Vaquita PC 35%: 1,5 - 3 l/ha (Diabrotica vittegera) PC 50%: 1 - 1,4 kg/ha

Brazil Seventy percent of the product used in Brazil is formulated domestically, which creates thousands of direct and indirect jobs. Endosulfan provides the economy with an influx of more than one hundred million dollars per annum. The major crops which are dependant on endosulfan for protection against pest in Brazil are cotton, soybean, cane sugar and coffee. Brazil has an annual production of cotton of approximately five million bales. It is a major crop for them for national use and export. Cotton is dependant on endosulfan as part of an IPM for combating its target pests. Sugar from cane drives Brazil’s successful alternative fuel business which distinguishes it as the biofuel industry leader in the world. The Migdolus can destroy a crop requiring replanting. Due to the resistance of Migdolus to other products, endosulfan as part of an IPM, is the chosen insecticide. Brazil is the second largest producer of soybeans in the world with a production of 57 million metric tons. Soybean accounts for 94.5% of oilseed crops, constituting the main export crop. The growing demand for export of soybean oil is having to compete with the use of soybean oil for the production of biodiesel. Without endosulfan, some of the pests encountered today cannot be controlled by the existing replacement insecticides. Endosulfan used as part of an IPM is the pesticide of choice because of the pests’ increased resistance to other products. Coffee is the number one cash crop of Brazil. Its importance is based on national consumption as well as export. From the discussion above coffee production is dependant on the availability of endosulfan. Volume use 4,400 metric tons. Registered uses in Brazil (4,400 metric tons): Crop Pest Cotton Boll weevil (Anthonomus grandis), leaf worm (Alabama argillacea), apples caterpillar (Heliothis virescens, Helicoverpa zea), mite (Polyphagotarsonemus latus) and aphid (Aphis gossypii) Cane Migdolus fryanus Sugar Soybean Caterpillar (Anticarsia gemmatalis), the Brown Stink Bug (Euschistusheros), Southern Green Stink Bug (Nezara viridula) and the Small Green Stink Bug (Piezodorus guildinni) Coffee Coffee berry borer (Hypothenemus hampei)

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Registered uses in India (5,000 metric tons): Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 500 Whiteflies, Leaf roller, Bollworm Paddy White jassid, Stem borer, Gall 500 midge, Rice hispa Gram Aphid, Caterpillar 500 Groundnut Jassid, Hairy caterpilar, Semi 1200 looper Okra/bhindi Aphid 400 Chilli Aphid 400 Tea Flush worm, Thrips, 1000 Helicoverpa Mango Hoppers, Fruit flies 1500 Jute Bihar hairy caterpillar, Yellow 500 mite Red gram Pod borer 1400 Brinjal Fruit & Shoot borer 1400 Onion Jassid, Aphid 500 Potato Jassid, Aphid 500

Registered uses in China (4,100 metric tons): Crop Pest Dose (ml or g/ha) Cotton Bollworms, Aphids, Thrips 1 l Tea Aphids, Thrips 1 l Apple Aphids 1 l Citrus Fruit borer, Fruit fly 1 l Tobacco Aphid , Tobacco Warm 1 l

Registered uses in United States of America (400 metric tons): Squash, eggplant, cantaloupe, sweet potato, broccoli, pears, pumpkins, cotton, tomatoes, potatoes. Registered uses in Pakistan: Crop Pest Dose (ml or g/ha) Cotton Heliothis, Aphid, 1 litre jassid

Registered uses in Mozambique: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 2000 Whiteflies, Leaf roller, African Bollworm Cowpea & Bean Jassids, Aphids, 1500 Spodoptera, leafminer Maize Stem borer 2000 Horticulture crops Leaf Miner, Aphids, 1000 Thrips, Spodoptera

Registered uses in Zambia: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 1500 Whiteflies, Leaf roller, African Bollworm

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Cowpea & Bean Jassids, Aphids, 1500 Spodoptera, leafminer Maize Stem borer 2000

Registered uses in Ethiopia: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 2000 Whiteflies, Leaf roller, African Bollworm Cowpea & Bean Jassids, Aphids, 2000 Spodoptera, leafminer Maize & Cereals Stem borer 1000 Vegetables, Oilseeds & Leaf Miner, Aphids, 1000 Pulses Thrips, Spodoptera, Diamond Back Sweet potato Sweet Potato 2000 Butterfly

Registered uses in Uganda: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 1500 Whiteflies, Leaf roller, African Bollworm Cowpea & Bean Jassids, Aphids, 1500 Spodoptera, leafminer Maize Stem borer 2000 Tomato/ vegetable Leaf Miner, Aphids, 1500 Thrips, Spodoptera

Registered uses in Sudan: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 1800 Whiteflies, Leaf roller, Bollworms, Spodoptera

Registered uses in Nigeria: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 2000 Whiteflies, Leaf roller, African Bollworm Cowpea & Bean Jassids, Aphids, 2000 Spodoptera, leafminer Maize Stem borer 2500 2500 Tomato/ vegetable Leaf Miner, Aphids, 1500 Thrips, Spodoptera

Registered uses in Guinee: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 2000 Whiteflies, Leaf roller,

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African Bollworm Cowpea & Bean Jassids, Aphids, 2000 Spodoptera, leafminer Maize Stem borer 2500 Tomato/ vegetable Leaf Miner, Aphids, 1500 Thrips, Spodoptera

Registered uses in Ghana: Crop Pest Dose (ml or g/ha) Cotton Jassid, Aphid, Thrips, 1000 Whiteflies, Leaf roller, Bollworm

(iii) Releases, such as discharges, losses and emissions Australia Discharges: The maximum label application rate ranges from 150 to 2800 g a.i./ha. Australia previously reported the maximum label application rate to be 840 g a.i./ha. The new figure of 2800 g a.i/ha is based on horticultural use (e.g. spraying on avocadoes, macadamias etc). Bulgaria None in 2008 and 2007. Costa Rica Alajuela. Reportando en agua de cañeria para consumo humano y de drenaje de aguas servidas en San José de la Montaña. (de la Cruz et al. 2004); Cartago, Central. Evaluación de agua de escorrentía. De 13 muestras de agua, encontraron 12 positivas con endosulfan (92%). 470 ug/l. (Rodríguez – Brenes OM. 1998.) San José de la Montaña, Heredia. En aguas superficiales de zona productora de helechos, se encontró endosulfan a (9,3 ug/l) y endosulfan b (8,9 ug/l). (de la Cruz et al. 2004) San José, Heredia y Cartago Central. Evaluación de agua de naciente para consumo humano, 96 muestras. Encontrado endosulfan a (2,0 ug/l), endosulfan b (<1,4) Readman et al. 1992); sulfato de endosulfan (<1,4 ug/l). (Von Duszeln J. 1988); estos mismos autores reportan en aguas superficiales y residuals del Pacifico la presencia de los metabolites endosulfan a y b. Bagatzí, proyecto Tamarindo, Guanacaste. Determinado en muestras de agua de riego y parcelas de arroz junto al Parque Nacional Palo Verde. (de la Cruz et al. 2004). Fraijanes, Alajuela. En muestras de agua superficial se encontró endosulfan a (0,1 ug/l) y endosulfan b (1,0 ug/l); en sedimentos endosulfan a (9 ug/l) y endosulfan b (46 ug/l); y en suelo de invernadero endosulfan a (1 ug/l) y endosulfan b (2,6 ug/l); luego de una intoxicación de personas (IRET-UNA. 2002). Bagatzí, Guanacaste. En muestras de agua de canales de riego para cultivos de arroz, caña y pastos se encontró a endosulfan (0,02 ug/l) y b endosulfan (0,04 ug/l). (IRET-UNA. 2009). 30 San José de la Montaña, Heredia. En muestra de agua de un estanque para la produción de truchas, se encontró endosulfan a (2 ug/l) y endosulfan b (0,8 ug/l) por un muestra efectuado debido a un evento de alta mortalidad de peces (IRETUNA. 2009). India Terms unclear. Lithuania Remark: By the e-mail message of 5 January 2009 from the Lithuanian Ministry of Environment it was reported that according to the information provided by the Competent Authorities responsible for different ares of chemicals management

16 UNEP/POPS/POPRC.6/INF/24 there are no data on endosulfan production, uses or placing on the market in Lithuania. There are no registered plant protection products in which endosulfan is a constituent part. Malaysia No specific study has been carried out but acknowledge some illegal used. We believed it is being smuggled. Since its ban in 2005 a total of 3.857 tons has been confiscate. Norway No releases. Togo No local data available. United States of America Currently (2006-2008), less than 400,000 lb per year are used for insecticidal purposes.

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Annex F information (a) Efficacy and efficiency of possible control measures in meeting risk reduction goals (i) Description of possible control measures Australia The regulatory authority (the Australian Pesticides and Veterinary Medicines Authority (APVMA)), has both legislative and administrative regulatory options for control measures. The legislative option is to include endosulfan under the Agricultural and Veterinary Chemicals (Administrative) Regulations 1992 to include conditions that will enable Australia to comply with the Stockholm Convention (e.g. prohibit the production, use, import and export of endosulfan). The regulatory option is to (i) cancel approvals/registrations or impose conditions on the approval of endosulfan and the registration of the associated chemical product under section 40 of the Agvet Codes following a reconsideration (i.e. review); or (ii) cancel approvals/registrations (or vary conditions consistent with the listing of endosulfan as a POP chemical) under section 41 of the Agvet Codes for non-compliance with the critiera for the approval or registration set out in section 14. Section 34 of the AgVet codeiii allows the APVMA to review and reconsider existing registered chemicals/products at any point in time. Any outcome from a review can initiate changes to the Agricultural and Veterinary Chemicals (Administration) Act 1992 (69CA - Complying with International Agreements), and initiate relevant changes to associated regulations for the registration, supply and use of endosulfan in Australia. In 2005, a review under section 34 of the AgVet code declared endosulfan a ‘Restricted Chemical Product’ in Australia. Details of the restricted supply and use of endosulfan including limits on frequency of spraying, introduction of mandatory buffer zones during spraying to reduce spray draft, and revised labels can be found on the Australian Pesticides and Veterinary Medicines Authority (APVMA) websiteiv. The full review can be found on the APVMA websitev. Control measures for end-users of endosulfan products are described in an APVMA brochure entitled ‘Endosulfan users’ Notice (published in 2005)vi. In Australia, the requirements for purchase and use of endosulfan may differ in each state or territory. Users must ensure that state and territory Control Of Use legislation is adhered to as summarised in the APVMA brochure entitled ‘Endosulfan users’ Notice (published in 2005, APVMA)vii. Further details of specific state requirements, user training and certification which have been found acceptable to the APVMA for the purposes of supply and use of endosulfan can be found on the APVMA websiteviii. Brazil - Conama Resolution 357, 2005 - the maximum allowable levels of endosulfan contamination may vary according to the use of the water body, and are so established: Parameter - Endosulfan ( α + β + sulfate) *Fresh Waters - 0,056 μg/L (for protection of aquatic life from chronic effects) to 0,22 μg/L (for protection of aquatic life from acute effects). *Saline and brackish waters - 0,01 μg/L for protection of the aquatic comunity. - Conama Resolution 396, 2008 - Parameter - Endosulfan ( α + β + sulfate) * Predominant Water Usages: Human Consumption – LQP (practical quantification limit, abreviation in portuguese – is the lowest concentration of a substance that can accurately be quantitatively determined by the method used): 0,6 μg/L * Watering of : not established * irrigation and recreation: 1 μg/L *LQP (as above) - 0,02 for each predominant use of water * Health´s regulation SVS/MS nº 518, 2004 * Maximum allowed value for presence of endosulfan in drinkable water – 20 μg/L

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- Standard joint law ANVISA/MAPA/IBAMA nº 2, june, 20, 2008 * For an active ingredient to be registered, it is necessary a 5-batches study with mandatory data about the impurities endosulfan ether, endosulfan-alcohol and endosulfan-sulfate, which can not exceed the limits of 10, 20 and 2 g/Kg respectively. - Based on the analysis of the severe adverse effects of Endosulfan to human health, ANVISA (Brazilian Sanitary Surveillance Agency) is re-evaluating this pesticide in Brazil and proposing its banishment in Public Consultation. The deadline of this consultation is next February, 4th. Before making a re-evaluation final decision on endosulfan, ANVISA will consider all comments received from the public in response to this consultation document. After that, there will be a meeting with designed members from Ministry of Agriculture and Environment in order to consider the information on the availability and viability of alternative chemical and non-chemical pest management practices for the site and pest combinations registered for it. Bulgaria Bulgaria is a Member State of the European Union from 01 Janury 2007 and as such applies the EU legislation related to Enduslfan as well as the international treatys to which the country is a Party. Prohibition or restriction of production, use, import and export; Production – banned (none) in Bulgaria; Use – prohibited (none) in Bulgaria; No authorization for placing and use of Endusfan formulations in Bulgaria are given from the beginning of 2000. With Commission Decision 2005/864/EC of 2 December 2005 concerning the non-inclusion of Endosulfan in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing this active substance, Endosulfan is prohibited for placing on the market and use from 3 December 2005 in EU. In Bulgaria Endosulfan is included in the List for of active substances for which European Commision has taken a decision for non- inclusion endosulfan in Annex I to Council Directive 91/414/EEC, which is prohibited for the production for placing on the maket and use, under article 15 (2), p.2 of Plant Protection Act, promulgated in State Gazette 91/10.10.1997, amended SG 43/29.04.2008, last amended SG 82/16.10.2009. Import and export - banned in Bulgaria Endosulfan is listed in Annex I, Part 1 (List of chemicals subject to export notification procedure, referred to in Article 7) and Annex I, Part 2 (List of chemicals qualifying for PIC notification, referred to in Article 10) of Regulation (EC) No 689/2008 of the European Parliament and of the Council of 17 June 2008, concerning the export and import of dangerous chemicals. Endosulfan is a pesticide in the group of plant protection products [p(1)]. The Regulation (EC) No 689/2008 on export and import of dangerous chemicals implements the provisions Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, in which Bulgaria is a Party. Classification and Labelling – covered Classification and Labelling is covered by Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures of 16 December 2008 and corresponding amendments Endosulfan (ISO), CAS No.: 115-29-7; EC No.: 204-079-4; Index 602-052-00-5; Classification (T+; R26/28, Xn; R21, N; R50-53); Labelling (T+; N; R: 21-26/28-50/53; S: (1/2-)28-36/37-45-60-61-63). Control of discharges or emissions – covered Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC.

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Endosulfan is included in Annex II “Pollutants” of Regulation 166/2006/EC. No CAS Pollutant (1) Threshold for releases (column 1) number to air (column 1a) kg/year to water (column 1b) kg/year to land (column 1c) kg/year 38 115-29- Endosulfan — 1 1 7 (1) Unless otherwise specified any pollutant specified in Annex II shall be reported as the total mass of that pollutant or, where the pollutant is a group of substances, as the total mass of the group. (2) A hyphen (—) indicates that the parameter and medium in question do not trigger a reporting requirement. The European Pollutant Release and Transfer Register provides information from the industrial facilities of 27 European Member States on industrial and non-industrial releases into air, water, land and off-site transfers of waste water and waste including information from point and diffuse sources, e.g. traffic and agriculture and is intended to fully implement the obligations of the UN-ECE PRTR Protocol, which was signed by Bulgaria and the European Community. Bulgaria as a EU Member state has reported from 2007 data for endosulfan releases in the European Pollutant Release and Transfer Register of industrial and non-industrial releases into air, water, land and off-site transfers of waste water and waste including information from point and diffuse sources. None of the operators had reported industrial and non- industrial releases of Endosulfan into water, land for 2007 and 2008 Replacement of the chemical by alternatives– covered; Endosulfan formulations are prohibited for use in Bulgaria from 2000 and were replaced with more safe alternative plant protection productsq which are placed on the market Termination of processes which could lead to unintentional release of the chemical; Endosulfa has never been produced in Bulgaria. Complex permits are issued in Bulgaria (by MOEWix & EEAx) for the operators dealing with waste treatment or temporary storage of prohibited and obsolete pesticides. Clean-up of contaminated sites; Because the inventory of storage sites for prohibited and obsolete pesticides, conducted annually from 2000 did not show availability of obsolete pesticides, containing Endosulfan, or presence of contaminated sites, there is no need for clean-up measures. Environmentally sound management of obsolete stockpiles; An Environmentally sound management of prohibited, obsolete and unusable pesticides stockpiles is in place in Bulgaria from 1998. The storage facilities for prohibited, obsolete and unusable pesticides are one of the sources for local environmental pollution.To solve the problem of safe storage of prohibited, obsolete and unusable pesticides in Bulgaria, with Order RD-159/12.05.1998 of the Ministry of Environment and Water and Order RD-09-991/11.05.1998 of the Ministry of Agriculture and Forests it was created an Inter-Agency Expert Committee for the management of „Prohibited, obsolete and unusable pesticides stockpiles“. The responsible institutions for obsolete pesticides management are the Ministry of Agriculture and Forestry (MOAF), now Ministry of Agriculture and Food (MAF), the Ministry of Environment and Water (MOEW), and their regional structures (RIEWxi). By initiative of MOEW, in 2000 the RIEW jointly with the Municipal administrations and Regional plant protection services (RPPS) had inspected the number and staus of warehouses and obsolete pesticides stored in them.Using information cards, the RIEWs collect every year and submit to the EEA information about the warehouses status and the obsolete pesticides stockpiles. The obsolete and useless pesticides are stored in centralized and municipal storage facilities and BB-cubes (reinforced steel containers 195x195x195 cm in size, hermetically sealed, with an effective storage capacity of 5 m3). From 2007 started the export of obsolete pesticides for final disposal by incineration in Germany. From 2009 on the Executive Environmental Agency web page http://nfp-bg.eionet.eu.int, a public access is available for the prohibited and obsolete pesticide database for 2007 and 2008.

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The annual inventories on the warehouses status and the obsolete pesticides stockpiles conducted in Bulgaria from 2000 onwards did not show the presence of obsolete Endosulfan stockpiles, due to the fact that Endosulfan formulations were on the market only for 3 years (1996-1999) and perhaps all quantities of Endosulfan formulations placed on the market were apllied out before 2000. Prohibition of reuse and recycling of wastes or stockpiles; Wastes or obsolete pesticides stockpiles are considered as hazardous wastes, and are not permited for reuse or recycling in Bulgaria. Commission Decision 2005/864/EC of 2 December 2005, concerning the non-inclusion of Endosulfan in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing this active substance. The main regulatory framework applied in Bulgaria are the Waste Management Act , promulgated in SGxii 86/24.09.2003, last amended SG 95/01.12.2009), Regulation 7/24.08.2004 on the Requirements for the Sites for Waste Treatment Facilities, promulgated SG 81/17.09.2004 and Regulation 8/24.08.2004 on the Conditions and Requirements for Construction and Operation of Waste Landfills, promulgated SG 83/24.09.2004, amended SG 87/30.10.2007 and the National Waste Management Programme 2009-2013. Establishment of exposure limits in the workplace; No exposure limits in the workplace for Endosulfan are established in Bulgaria. Establishment of maximum residue limits in water, soil, sediment or food. Maximum admissible concentrations (MAC) or Maximum residue limits (MRL) in water, and food are established in Bulgaria. For soils: Endosulfan is not included in the National system for soil monitoring, established and maintained by EEA at MOEW. In soil no maximum admissible concentrations (MAC) for Endosulfan are in place in Bulgaria. For surface water: 1. Regulation 12 on the quality requirements for surface water meant for drinking water supply, promulgated SG 63/28.06.2002, effective as of 01.01.2007 for pesticide MRL. Annex 1: “Quality requirements for surface water meant for drinking water supply” The mandatory maximum residue levels (MRL) of total pesticides in surface water, meant for drinking water supply in Bulgaria are respectively 0,001 mg/L (A1 category – first quality); 0,0025 mg/L(A2 category – second quality); and 0,005 mg/L (A3 category – third quality) . 2. Regulation 9/16.03.2001 for water quality, meant for drinking and domestic purposes, promulgated in SG 30/28.03.2001, amended SG 87/30.10.2007, effective as of 01.01.2007 for pesticide MAC. Annex 1, Table B “Chemical indices for water meant drinking and domestic purposes” Maximum admissible concentrations (MAC) in water, meant for drinking and domestic purposes for individual pesticide is 0,10 mg/L and for pesticides total sum is 0,50 μg/l. 3. In Bulgaria Endosulfan is included in the List of priority substances and identified as priority hazardous substances in waters with an Order RD 321/07.05.2007 of Minister of Environment and Water related in accordance with the provisions of Water Act, promulgated in SG 67/27.07.1999г., amended SG 22/13.03.2007г., SG 59/20.07.2007г., SG 36/4.04.2008г., last amended SG 47/ 23.07.2009 and Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. 4. Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental quality standards in the field of water policy, amending and subsequently repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the European Parliament and of the Council – not effective for Bulgaria yet. Annex I: Environmental quality standards for priority substances and certain other pollutants, Part A: Environmental quality standards (EQS)

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AA: annual average; MAC: maximum allowable concentration. No Name of CAS AA- AA- MAC- MAC- substance number EQS (2) EQS EQS EQS (4) (1) (2) (4) Inland Other surface Other Inland surface surface surface waters waters (3) μg/l waters waters μg/l (3) μg/l μg/l (14) Endosulfan 115- 0,005 0,005 0,01 0,004 29-7 (1) CAS: Chemical Abstracts Service. (2) This parameter is the EQS expressed as an annual average value (AA-EQS). Unless otherwise specified, it applies to the total concentration of all isomers. (3) Inland surface waters encompass rivers and lakes and related artificial or heavily modified water bodies. (4) This parameter is the EQS expressed as a maximum allowable concentration (MAC-EQS). Where the MAC-EQS are marked as ‘not applicable’, the AA-EQS values are considered protective against short-term pollution peaks in continuous discharges since they are significantly lower than the values derived on the basis of acute toxicity. Annex II Annex X to Directive 2000/60/EC is replaced by the following: Annex X: List of priority substances in the field of water policy No CAS EU Name of Identified as number number priority priority (1) (2) substance hazardous (3)

substance (14) 115-29-7 204-079- Endosulfan X 4 (1) CAS: Chemical Abstracts Service. (2) EU number: European Inventory of Existing Commercial Substances (Einecs) or European List of Notified Chemical Substances (Elincs). (3) Where groups of substances have been selected, typical individual representatives are listed as indicative parameters (in brackets and without number). For these groups of substances, the indicative parameter must be defined through the analytical method. 5. Regulation 7 for the indices and standards for determination of movinf surface water quality, promulgated in SG 96/12.12.1986. For ground water: 1. Regulation 1/10.10.2007 for investigation, use and protection of groundwater, promulgated in SG 87/30.10.2007. Annex 1 “Standards for groundwater quality“, Specific organic pollutants Pesticides – 0,1 μg/L for each active substance, metabolite or reaction produc , Pesticides (total) – 0,5 μg/L for sum of all individual pesticides found within the monitoring. For foods: Regulation 31 on the maximum admissible quantities of pesticide residue levels in foods, promulgated in SG 14/20.02.2004, amended SG 8/25.01.2007, SG 69/24.08.2007, last amended SG 29/18.03. 2008.

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Annex I, Part 1 “List of pesticides and their residues in or on foods” Endosulfan (Sum of alpha and beta isomers and endosulfan sulfate, expressed as endosulfan). Annex II, Part 2 “MRL of pesticides in or on foods”, effective from 1.01.2007. Table: MRL of Endosulfan (Sum of alpha and beta isomers and endosulfan sulfate, expressed as endosulfan) in or on foods effective from 1.01.2007: Foods Groups of foods, including MRL endosulfan in foods, mg/kg Fruits, fresh, dried, or non-boiled, Citrus fruits 0.05 conservated by freezing without added sugar Kernel fruits with or without shell Nuts 0.1 Seed fruits Apricot, Cherry, Peach, Plum, others 0.05 Stone or stoneless pulpy fruits Vine and desert grapes 0.5 Strawberry, Blackberry, Raspberry, 0.05 Blueberry,Red, white or black currants & others; wild pulpy fruits Other fruits Avocado, Banana, Date, Fig, Kiwi, Kumkuati, 0.05 Mango, Olive, Papaya, Marakuya, Pine- apple, Pomegranate & others Vegetables, fresh or non-boiled, frozen or Root crops and tuberiferous vegetables: Beet, 0.05 dried: Carrot, Manioc, Horse-raddish, Celery, Jerusalem artichoke, Roots of Parsley, Radish,

Goat tassel, Seet potatoes, Turnip, Dioscorea and others Table cont: MRL of Endosulfan (Sum of alpha and beta isomers and endosulfan sulfate, expressed as endosulfan) in or on foods effective from 1.01.2007: Foods Groups of foods, including MRL endosulfan in foods, mg/kg Vegetable-Fruits Tomato 0.5 Pepper 1.0 Eggplant, Okra 0.05 Others 0.05 Vegetables with bulb Garlic, Onion, Seed onion, Green onion & 0.05 others Pumpkin vegetable with eatable peel Cucumber, Vegetable marrow, & others 0.05 Pumpkin vegetable with non-eatable peel Melon, Pumpkin, Watermelon & others 0.3 Seet corn 0.05 BRASSICA vegetables Cabbage,Broccoli, Cauliflower, Brussels 0.05 sprout, Chinese cabbage, Kohlrabi, Leafy vegetables Lettuce, Rucula, Spinach, Water cress, 0.05 Succory,

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Fresh spices Wild celery, Siberian onion, Stonewort, 0.05 Celery leaves & others Leguminous plants Beans, Split peas, 0.05 Stem vegetables, fresh Asparagus,Cardoni, 0.05 Celery stem, Fennel, Artichoke, Leek, & others Mashrooms Cultivated and wild mashrooms 0.05 Leguminous plants Beans, Lentils, Peas, & others 0.05 Oleagenous seeds Flax seeds, Peanuts, Poppy-seeds, Sesame 0.1 seeds, Sunflower seeds, Rape seeds, Soya- beans, Mustard seeds, Cotton seeds, Hemp seeds, Pumpkin seeds & others Table cont: MRL of Endosulfan (Sum of alpha and beta isomers and endosulfan sulfate, expressed as endosulfan) in or on foods effective from 1.01.2007: Foods Groups of foods, including MRL endosulfan in foods, mg/kg Potatoes Early potatoes, potatoes for conservation 0.05 Tea Dried leaves and stems of Cammelia sinesis 30 Hops, dried Incl. Hops in the form of granules and powder 0.1 Cereals Wheat, Rye, Barley, Sorghum, Oats, 0.05 Triticale, Maize, Durum wheat, Millet, & other Cereals Foods from origin Meat, animal fats, meet products 0.1 Milk and dairy products 0.004

Eggs 0.1 The following factors may influence the efficacy and efficiency of possible control measures: (a) Legal, administrative, and enforcement measures are in place in Bulgaria including adequately trained personnel; (b) Monitoring measures are in place in Bulgaria including of suitable laboratory and monitoring capability – 15 accredited Regional laboratories within MOEW for monitoring of land and surface and ground water. (c) Risk communication system and public participation: through EEA web-page http://nfp-bg.eionet.eu.int and MOEW Web-page http://www.chemicals.moew.government.bg (d) Accessibility of alternative chemicals or processes: Endosulfan was never produced in Bulgaria. The use of Endosulfan in Bulgaria is prohibited and other safer alternative plant protection products are available on the market. (e) Accessibility of safe installations and technology to eliminate stockpiles – adequate facility for final disposal or destruction of obsolete pesticide stockpiles is not available in Bulgaria. During annually conducted Inventories of warehouse status and obsolete pesticidesq stored there, Endosulfan, containing pesticides were not identified. Canada As per Re-evaluation of Endosulfan: Interim Measures, Appendix II (REV2009-09): a) The following uses will no longer be allowed: homeowner/residential use; agricultural use on alfalfa, clover, sunflower, spinach, succulent beans, succulent peas; and, for wettable powder products, use on field tomatoes, sweet corn, dry beans and dry peas.

24 UNEP/POPS/POPRC.6/INF/24 b) Restrictions are required on application to remaining uses (see (1-4) below) to reduce human and environmental exposure. China

1）Improve the production sites of endosulfan; specify the maximum residue value of endosulfan in the ambient air of production plants; meanwhile, effectively treat the gas emissions, wastewater, and waste residue caused by endosulran production in order to reduce its adverse impact to the surrounding environment and workers’ health.

2）Use endosulfan scientifically; restrict its application scope, prevention targets, amount and times, to effectively reduce the environmental risk

3）When conditions are met, IPM, including physical and biological measures should be promoted to further reduce the use of chemical pesticides and lower environmental risks. Costa Rica Prohibición del uso del endosulfan. India Replacment of Endosulfan by other chemicals becomes expensive considering unique pest control properties of Endosulfan. Japan We will prohibit production, import , distribution and use. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were developed. Endosulfan was proposed by the European Community and its Member States that are Parties to the Convention in 2007 for addition to Annexes A, B and/or C of the Convention. It was proposed to amend relevant Annexes of the Convention by adding endosulfan taking into account existing Community legislation with regard to uses and derogations regulated therein. As far as Lithuania is the Member State of the European Community, Lithuania keeps the position of the European Community regarding inclusion of endosulfan into the Annexes of the Stockholm Convention. Placing on the market and use of all plant protection products containing endosulfan is prohibited in the European Community, including Lithuania. Madagascar Duly control aiming on interdiction of import and usage of products based on that substance, or at least limitations of specific usage (cotton) by qualified manpower. Evaluation of water contamination and contamination in areas of primary use. Evaluation of content/concentration of residues in vegetable products. Malaysia After being banned in this country, possibility of its discharge to the environment is only through illegal use. Enhancing enforcement activities and at the same time if possible cutting off the supply globally will stop the discharge to the environment. Norway In Norway, endosulfan has been banned from use since 1/1/1999. Moreover, it is prohibited to stock, sell and use endosulfan as a pesticide. Endosulfan has never been produced in Norway. Poland Prohibition or restriction of production, use, import and export by legislative measures including trained personel and risk communication system. There are no standards for BAT and BEP.

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Romania Prohibition of use; in order with the provisions of Commission Decision 2005/864/EC concerning the non-inclusion of endosulfan in Annex I to Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant products on the market and withdrawal of authorisations for plant protection products containing this active substance. Togo Total ban on import and use in the CILSS countries that have conditions very similar to the ones in TOGO. Alternatives are being used that should be suitable for use in Togo. Indeed the country is already in the process of banning the use of Endosulfan. Ukraine Already included into the List B – Pollutants which are controlled and prohibited for discharges (Decree of the Cabinet of Ministers #1100 of 11.09.1996). At present there are no available data on any releases. Since 1996 not registered, any permissions not issued for production, storage, transportation, usage, disposal and destruction (Decree of the Cabinet of Ministers #440 of 20.06.1995); BUT is not included into the List of pesticides banned for usage in agriculture, registration and re-registration (Ministry of Health, 05.08.1997). United States of America 1. Cancel (i.e., ban) any or all uses. 2. Restrict application rates in any or all uses. IPEN The most cost effective and practicable control measures are the prohibition of all production, use, import and export of endosulfan; and the replacement of all uses by non-chemical pest control practices and safer alternative chemicals. Endosulfan has already been widely subjected to such measures in more than 60 countries.xiii Endosulfan should be listed in Annex A, Part 1, of the Stockholm Convention, with no specific exemptions. This should be supported by the clean up of contaminated sites, such as at or near manufacturing facilities, and environmentally sound management of obsolete stockpiles and wastes. ISC Safe residue levels for endosulfan have been established by the Joint FAO/WHO Meeting on Pesticide Residues (JMPR) and these are routinely met. JMPR is an international expert scientific group that is administered jointly by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO). JMPR has been working since 1963 estimating the maximum residue levels that might occur as a result of the use of a pesticides according to good agricultural practices and estimating, where possible, acceptable daily intakes for humans of the pesticides under consideration. The JMPR has established safe residue levels for endosulfan in foods for human consumption. Other national authorities including the United States, Australia, India, Brazil, China, Canada and the EU have established safe residue levels. (ii) Technical feasibility Australia The technical feasibility of applying possible control measures to comply with risk reduction goals for endosulfan would be determined during a subsequent review of endosulfan. It is feasible to amend the legislation and cancel approvals and registrations. If a pesticide is de-registered by the APVMA, the APVMA is not obliged under its legislation to provide suitable replacements, but will evaluate and register suitable alternatives that are determined by affected industries Bulgaria What measures would be needed to effectively prohibit or restrict production and use: Production and use is prohibited in Bulgaria. Chemical or non-chemical alternatives which are already in use or which could be phased-in: Endosulfan containing plant protection products were replaced with other alternative pesticides permited for placing on the market and use in Bulgaria.

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National standards for best available techniques and best environmental practices (BAT/BEP) and inventory of installations meeting the BAT/BEP standards: Adequate facility for final disposal or destruction of obsolete pesticide stockpiles is not available in Bulgaria. Projects in progress involving elimination of stockpiles and clean-up of contaminated sites: Finacing of project proposals at 100% by allocating state budget funds to municipalities for improvement of storage facilities status and safe and environmentally sound storage of obsolete pesticides and recently for export obsolete pesticides abroad for final elimination. Endosulfan, containing pesticides were not identified during annually conducted inventories in Bulgaria. Canada A pre-decision consultation with stakeholders determined the interim control measures described by REV2009-09 were feasible. Further consultation on the feasibility of additional control measures for remaining uses is required. Costa Rica Si hay alternativas. Japan The control measures are technically feasible. The POPs chemicals for agricultural uses are already prohibited to distribute and use based on the ordinance of Ministry of Agriculture, Forestry and Fisheries of Japan ( MAFF). Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Madagascar An abolishment of the substance would not cause relevant problems since there exist homologue substitution products. Supplementary investment for replacement of residual substances by nouvelles materials. Malaysia Banning and enforcement of the ban shall be an effective way of reducing or eliminating its discharge into the environment. Poland Implementation of national BAT/ BEP standards. Togo Technical feasibility using of Calfos has already been demonstrated through field experiments during the 2009-2010 cotton production campaign. Ukraine Not estimated. United States of America Yes. IPEN As stated in the POPRC guidance on alternatives, “Commercial or current availability of an alternative is an important indicator of technical feasibility.”xiv The wide commercial and current availability of alternatives for endosulfan indicates technical feasibility and the practicability of prohibition (see Section B below). For all known uses of endosulfan there are safer alternative chemicals and practices already in use in developing, transition, and developed countries, such that endosulfan is no longer needed. For example alternatives to endosulfan for pest control on cotton, vegetables, rice, pulses, and tobacco are being used in Indiaxv and West Africaxvi on vegetables, rice and tea in Sri Lankaxvii and on coffee, soy, flowers, and other crops in Latin America.xviii In China, where endosulfan is used on cotton, wheat, tea, tobacco and apples, it is used on only 25% of the acreage grown of each crop, indicating that alternatives are used on the remaining 75% of crop.xix At least 62 countries have prohibited endosulfan use and have already broadly implemented technically feasible alternatives.xx Many more countries currently employ an array of endosulfan alternatives even before prohibiting production and use.

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Some countries may not have the capacity to enforce a selective ban of endosulfan on some crops while allowing its continued use on others. For example, reports indicate continued use of DDT in agriculture in South Asia, despite the use of DDT being restricted to malaria vector under Stockholm Convention. For this reason, and because ample, affordable alternatives exist for all known uses, endosulfan should be listed in Annex A with no exemptions. (iii) Costs, including environmental and health costs Australia Australia has not estimated the potential costs (to Australia) that might be associated with reviewing and de-registering a product such as endosulfan. Costs could include costs to government to conduct the work, as well as costs to industry, and potential social and economic impacts. Environmental and health costs are unknown at this stage. Bulgaria Appr. 300 000 - 500 000 $ per year from state budget are allocated for securing and/or final elimination of obsolete pesticide stockpiles. Endosulfan, containing pesticides were not identified during annually conducted inventories in Bulgaria. The total amount of funds, allocated from state budget [Ministry of Environment and Water (MOEW), respectively the Enterprise for the management of the environment protection activities (EMEPA) and Ministry of Agriculture and Food (MOAF), respectively National Plant Protection Service (NPPS)] to secure storage of obsolete and out-of-use obsolete pesticides in Bulgaria for the Years 1998 – 2008 amounted to ca. 5 800 000 Euros ≈ 4 500 000 US $. Endosulfan, containing pesticides were not identified during annually conducted inventories in Bulgaria. Costa Rica No hay información disponible. Japan Impossible to estimate. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were developed. Madagascar Eventually elevation of production costs. Analysis costs need renewal of laboratory, since the laboratories are focused on analysis of residues. Malaysia The recommended alternatives do have disadvantage in term of cost effectiveness. The comparison of products prices is attached in Appendix 1: Appendix 1: List of Endosulfan and Alternatives and Their Cost Comparison Crops Pests Alternatives Rate Cost Cost Per Ha. Per Per (Liter/ Liter Ha. Kg) (RM) (RM)

1. Tobacco • Bud 1. B.T. aizawai 0.25 28.00 7.00 caterpillar 2. Endosulfan 33% 0.60 20.00 12.00

3. Cypermethrin 5.6% 0.55 28.00 15.00

4. Quinalphos 25% 0.45 35.00 16.00

5. Deltamethrin 1.4% 0.48 39.00 19.00

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Crops Pests Alternatives Rate Cost Cost Per Ha. Per Per (Liter/ Liter Ha. Kg) (RM) (RM)

6. Deltamethrin 2.8% 0.40 49.00 19.60 7. Chlorpyrifos 45% 0.45 45.00 20.00 8. Deltamethrin 2.8% 0.48 49.00 24.00 9. Chlorpyrifos 45 %+ Cypermehtrin 4.5% 1.00 48.00 48.00 10. Permethrin 11.1% 2.00 30.00 60.00 11. Fenvalerate 20% 0.13 - - 12. Lufenuron 5.1% 0.70 160.00 112.00

• Army worm 1. B.T. aizawai 0.25 28.00 7.00 2. Lambda-cyhalothrin

2.8% 0.22 59.00 13.00 3. Endosulfan 33% 0.70 20.00 14.00 4. Cypermehtrin 5.6% 0.55 28.00 15.00 5. Qinalphos 25% 0.45 35.00 16.00 6. Deltamethrin 1.4% 0.48 39.00 19.00 7. Chlorpyrifos 45.9+

Cypermehtrin 4.59 0.56 48.00 24.00 8. Deltamethrin 2.8% 0.56 49.00 25.00 9. Methidathion 20.6 1.00 37.00 37.00 10. Esfevalerate 2.8% - - -

• Mealy bug 0.67 20.00 13.00 1. Endosulfan 33% 0.45 35.00 16.00 2. Quinalphos 25%

• Leaf Roll caterpillar 0.72 20.00 14.00 1. Endosulfan 33%

2. Tea • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 2. Quinalphos 25% 0.90 35.00 32.00

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Crops Pests Alternatives Rate Cost Cost Per Ha. Per Per (Liter/ Liter Ha. Kg) (RM) (RM)

• Bug Kepin- ding 1. Endosulfan 33% 0.90 20.00 18.00

2. Deltamethrin 2.8% 0.50 49.00 25.00

3. Brinjal • Aphids 1. Dimethoate 38.4 % 0.45 14.50 6.50 2. Endosulfan 33% 1.00 20.00 20.00 3. Cypermethrin 5.6% 0.80 28.00 22.40 4. Permethrin 11.1% 1.20 30.00 36.00 5. Acetamiprid 3% 1.50 92.00 138.00 6. Fevalerate 10% - - -

• Fruit/ shoot 1. Cypermethrin 5.6% 0.50 28.00 14.00 borer 2. Permethrin 11.1% 0.50 30.00 15.00 3. Endosulfan 33% 0.88 20.00 17.60 4. Deltamethrin 2.8% 0.36 49.00 18.00 5. Deltamethrin 1.4% 1.20 39.00 47.00 6. L-cyhalothrin 2.8% 1.00 59.00 59.00 7. Tebufenozide 21% 0.50 150.00 74.00 8. Indoxacarb 0.18 - - 9. Lufenuron 5.1% 0.50 160.00 80.00

4. Corn • Stem Borer 1. Profenofos 45% 1.50 54.00 81.00 2. Methidathion 20.6% 2.50 37.00 92.50 3. Lufenuron 18.3% 0.80 160.00 128.00 4. Trichlorfon 95% - - - 5. Endosulfan 3% 35.00 kg - -

5. Orange • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 2. Deltamethrin 2.8% 0.36 49.00 17.60 3. Dimethoate 38.4% 1.80 14.50 26.10 4. Triazophos 40% 0.56 58.00 32.70

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Crops Pests Alternatives Rate Cost Cost Per Ha. Per Per (Liter/ Liter Ha. Kg) (RM) (RM)

6. Black Pepper • Pepper 1. Deltamethrin 2.8% 0.10 49.00 4.90 Beetle 2. Deltamethrin 1.4% 0..20 39.00 7.80

3. Endosulfan 33% 0.80 20.00 16.00

1. Deltamethrin 2.8% 0.10 49.00 4.90 • Kepin-ding 2. Deltamethrin 1.4% 0.20 39.00 7.80 3. Endosulfan 33% 0.80 20.00 16.00 4. L-cyhalothrin 2.8% 1.00 59.00 59.00

6. Cocoa • Cocoa Pod 1. Chlorpyrifos 45.9 + 0.16 48.00 7.70 borer Cypermehtrin 4.59

2. Deltamethrin 2.8% 0.16 49.00 7.80 3. L-cyhalothrin 2.8% 0.14 59.00 8.30 4. Cypermehtrin 5.6% 0.30 28.00 8.40 5. Chlorpyrifos 45.9% 0.20 45.00 9.00 6. Endosulfan 33% 0.45 20.00 9.00 7. Deltamethrin 1.4% 0.36 39.00 12.50 8. Chlorpyrifos 21.2% 0.48 45.00 21.60 9. Fevalerate 3% 0.45 - - 10. Esfenvelerate 2.8% 0.40 - -

• Kepin-ding 1. Qinalphos 25% 0.20 35.00 7.00 2. Endosulfan 33% 0.45 20.00 9.00 3. Deltamethrin 2.8% 0.20 49.00 9.80 4. Deltamethrin 1.4% 0.36 39.00 14.00 5. Cypermethrin 5.6% 0.30 49.00 14.70 6. Chlorpyrifos 45.9 +

Cypermehtrin 4.59 0.50 48.00 24.00 7. Dimethoate 38.4% 1.80 14.50 26.00

31 UNEP/POPS/POPRC.6/INF/24

Crops Pests Alternatives Rate Cost Cost Per Ha. Per Per (Liter/ Liter Ha. Kg) (RM) (RM)

8. Methidathion 20.6% 1.00 37.00 37.00

8. Lady fingers • Fruit borer 1. Permethrin 11.1% 0.23 30.00 6.90 2. Endosulfan 33% 0.50 20.00 10.00 3. Deltamethrin 2.8% 0.35 49.00 18.70 4. Deltamethrin 1.4% 0.48 39.00 18.70 5. Cypermethrin 5.6% 0.80 28.00 22.40 6. Chlorpyrifos 45.9 + Cypermehtrin 4.59 0.90 48.00 43.20 7. L-cyhalothrin 2.8% 1.00 59.00 59.00 8. Tebufenozide 21% 0.62 150.00 93.00

9. Manggo • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 (#) (#) 2. Endosulfan 33% 1.20 20.00 24.00

10. Banana (#) • Aphids 1. Endosulfan 33% 1.20 20.00 24.00 (#) 11. Cabbage • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 2. Dimethoate 38.4% 0.70 14.50 10.15

12. Cauliflower • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 2. Dimethoate 38.4% 0.70 14.50 10.15 13. Bok • Aphids 1. Endosulfan 33% 0.50 20.00 10.00 choy/Mustard green (#) (#) Note: (#) Indicates the crops (mango, banana and Bok Choy/Choy Sam and their corresponding pest that do not have registered alternatives. Togo Banning Endosulfan will certainly cost the price difference between the cost of the alternative pesticides and that of Endosulfan. This information is not yet available. There is of course no invironmental cost linked to the ban of Endosulfan in Togo. Ukraine Not estimated.

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United States of America Type and magnitude of costs depend on the control measure(s) taken. Types of costs could include: ƒ Direct costs to agricultural producers in terms of more costly alternatives and/or decrease in quantity or quality of output. ƒ Indirect costs to consumers of agricultural products in terms of reduced availability and high prices. ƒ Possible environmental and human health, but highly unlikely. IPEN The POPRC has concluded “endosulfan is likely, as a result of its long-range environmental transport, to lead to significant adverse human health and environmental effects such that global action is warranted”. This indicates that the elimination of endosulfan production, uses, export and import as the result of a listing in Annex A of the Stockholm Convention will benefit human health and the environment. This view is supported by the current existence of widespread global environmental and human food chain and body tissue contamination by endosulfanxxi which is likely to reduce and eventually to disappear some time after cessation of endosulfan production and use. The considerable phase-out of endosulfan that has already occurred in at least 62 countries (most of them developing countries) indicates that alternatives to endosulfan are economically feasible. In West African cotton production the substitution of endosulfan by other pesticides is projected to reduce costs to farmers;xxii and in India replacement of endosulfan use in cotton, and other crops with nonpesticide management methods has significantly reduced costs and increased incomes for farmers.xxiii,xxiv In Sri Lanka, no reduction in yields of 13 vegetable crops or rice were observed in the years following the prohibition of endosulfan (together with monocrotophos and methamidophos), nor were there any sudden changes in costs of rice production coinciding with bans.xxv Any costs incurred in substituting other pesticides or practices for endosulfan should be measured against the costs to human health and the environment of ongoing use of endosulfan. Although there is no meaningful way of measuring these costs, some conclusions on costs to human health can be drawn from the remediation efforts being undertaken by the State Government of Kerala (India) for victims of endosulfan poisoning resulting from aerial spraying of cashew nut plantations, as reported in Section C (iv). For countries with current use and/or endosulfan stockpiles, prohibition of endosulfan production and use would lead to costs for waste handling and management. They may also be costs related to regulation, enforcement, and compliance activities. (b) Information on alternatives (products and processes) (i) Description of alternatives Australia In avocado, alternatives to endosulfan are beta-cyfluthrin, methidathion and trichlorfon. In custard apple, alternative is methidathion. In lychee, alternative is azinphos-methyl. In macadamia nuts, alternatives are acephate, azinphos-methyl, beta-cyfluthrin, methidation and trichlorfon. In pawpaw (papaya), alternatives are beta-cyfluthrin, trichlorfon and beta- cyfluthrin (on permit). On passion fruit, alternative is trichlorfon. On pecan nuts, alternative is beta-cyfluthrin (on permit). On persimmons, alternative is methidathion (on permit). There are no alternatives to endosulfan to control the fruit spotting bug (Amblypelta lutescens) on cashew nuts, cucurbits, guava, kiwi fruit, longans, loquats, mango, rambutans and tamarillo. Preserving beneficial insects is an important element of developing an integrated pest management (IPM) system for fruit spotting bugs. This involves limiting the impact on a number of egg parasitoidsxxvi and adult predators for which endosulfan is the least disruptive of currently available insecticide options. Currently, there is ongoing research into the possible use of semiochemicals (pheromones).xxvii,xxviii,xxix There is reasonable confidence that all the major components of the male sex pheromone of the fruit spotting bug have been identified.xxx Combinations of pheromone components will be evaluated for testing in potential lures and traps. However, this research is at a very early stage and commercial availability is unlikely within the next five years. Replacement of conventional cotton crops by genetically modified cotton crops (which reduce the need for endosulfan) may also continue to occur.

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Brazil Preliminary studies indicate the possibility of the following active ingredients as replacements. However, this finding did not study efficiency assessment. For cotton crop and its respective biological targets, the active ingredients methyl-parathion and bifenthrin. For sugar cane crops, fipronil is a possibility. For coffee, Chlorpyrifos. For soybean, the following: Imidacloprid + Beta-cyfluthrin e Thiametoxam + Lambda-cyhalothrin and methamidophos. Canada Alternatives pesticides that were registered for similar purposes as endosulfan as of 2006 are listed in Appendix VI of REV2007-13. Some of those alternatives have since been withdrawn, e.g. use of diazinon for several vegetable and ornamental crops, or may be withdrawn within a few years, as a result of ongoing re-evaluation work. Growers are concerned that, in some situations, available alternatives are either lacking in Canada, less effective, inadequate for resistance management or are under consideration for restriction. China Other alternatives such as pyrethroids, organophosphorus, carbamates etc. Costa Rica Las principales alternativas de uso se han dirigido a cultivos como el café, ahí se utiliza el hongo entomopatógeno Beauveria bassiana para el control de broca, también una avispa parasitoide Phymastichus coffea, daba un buen resultado controlando larvas de broca, pero el programa de producción y liberación no se continuó. Otros parasitoides enemigos de la broca son Prorops nasuta, Cephalomia stephanoderis, Heterospilus coffeicola; también los depredaores Crematogaster curvispinosus y Diadomus rubiginosus (Lopez 1994). Practicas culturales utilizadas: recolección del fruto brocade, tanto del suelo como de la planta después de la cosecha. En lotes con alta incidencia se recoje el fruto brocade verde antes de la cosecha. También practicas culturales preventivas que eviten la diseminación de frutos de una zona a otra. En otros cultivos como repollo, tomate, chile y pepino se ha dado la utilización de Bacillus thruingiensis para el control de larvas de lepidopteros como Diaphania nitidalis, Heliothis sp y Pieris sp (CATIE y GTZ 2006); el insecticida spinosad se usa en broccoli, repollo y piña, es un insecticida de origen natural producido por la fermentación de una bacertia actinomiceto llamada saccharopolyspora spinosa. También las sales potásicas de ácidos grasos (Impide) se han utilizado como un isecticida biologic para el manejo de muchas plagas agricolas en muchos cultivos. Para control de áfidos (Aphis sp) y trips se puede utilizar extractos de ajo, chile y mostaza, y para mosca blanca (Bemiscia tabaci) y mosca minadora (Liriomyza sp), el aceite de Neem ha dado Buenos resultados. India Available alternatives are not as cost effective except few crops. India has elaborated the following text regarding unique uses of endosulfan (Annexure-I): “Endosulfan Safety to Natural Enemies Endosulfan is relatively safe to natural enemies like Predators and parasitoids. The early season use of Endosulfan conserves the population of natural enemies of pests (predators and parasites) and causes suppressive effect on early season sucking pests such as aphids, jassids, and white fly. Due to this property Endosulfan is recommended to use during initial stage of crops when population of beneficial insects is at its peak. Many alternative products are much harder on such beneficial insects. Early season use of Endosulfan could reduce total insecticides uses considerably. Endosulfan found compatible with NPV, growth regulator diflubenzuron, Novaluron. Endosulfan is considered to be selective pesticide that causes minimal harm to the natural enemies that play an important role in the biological control of insect pests such as aphids, mites, thrips and whitefly, borers etc. Integrated Pest Management (IPM): Endosulfan is a broad spectrum insecticide, less toxic to several useful insect parasites, predators and pollinators, inevitable candidate under IPM systems. Endosulfan is an ideal mixing partner with Biopesticides & Nonchemical pesticides like NPV, Neem, Pheromones, IGR, etc. The importance of endosulfan as part of an IPM is the lack of resistance on the part of pests to it

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Pollinator Management: It is recommended for use in cross pollinated crops in bloom by Bureau of Indian Standards vide IS: 6695 – 1972 (Code for conservation and maintenance of Honey Bees) which classifies Endosulfan as relatively less toxic to bees. India is the second largest producers of fruits and vegetables in the world. A vast majority of horticultural crops are dependent on honeybees for pollination. Insecticides Resistance Management (IRM) Endosulfan has a unique mode of action different to organophosphates, carbamates, synthetic pyrethroids, neonicotinoids, oxadiazine carboxylate, spinosad and all other classes of insecticides currently available or in development on the market. One of the most important aspects of endosulfan in the agriculture of India is that it serves as an alternative to other pesticides which suffer from the development of resistance by the target insects. Furthermore there is no cross resistance in between endosulfan and synthetic pyrethroids, organophosphate, neonicotinoids or otherchemical group used in crop protection. For these reasons Endosulfan is an important tool in Insecticide ResistanceManagement (IRM) programs preventing or overcoming resistance against other chemical classes of insecticides. Substitute of Endosulfan in India Endosulfan is a broad spectrum insecticide& acaricide, IPM tool, multi crop product , excellent crop tolerance ( Non phytotoxic), harmless to natural enemy of crop pests, Resistant management tools (IRM) due to its unique mode of action & cost effective (US$-3.8/ha/spray) plant protection chemical .Considering these properties of Endosulfan, there is no cost effective alternatives of Endosulfan in India. Other alternatives of Endosulfan are narrow spectrum. Cost per hectare per spray of those alternatives are as followes:- Imidacloprid (US$-4.0), Neem base pesticide ( US$-6.0), Spinosad (US$-40) ), Acetamiprid (US$-6.0), Buprofezin (US$-15.0), Novaluron (US$-35) Indoxacarb (US$-25.0), Flubendiamide (US$-30.0), Thiomethoxam( US$-10.0), Emamectinbenzoate( US$-20.0) Chlorantraniloprole (US$ 40). Concluding Remarks If Endosulfan is not available for use in India, the need to use other insecticides will result in greater plant protection costs, excessive bees’ mortality and frequent use of narrow spectrum insecticides. Alternatives are not cost effective in all situations.” Japan There are many alternatives for agriculture uses. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Malaysia Endosulfan was used to control various pest in various plants before its ban. Alternatives recommended by authorised agency including synthetic pyrethroids, organophosphorous, Bacillus thuringiensis and other type of pesticides. List of alternatives is attached in Appendix 1. See section a (iii). Monaco Not applicable in Monaco (the alternative chemicals used in France or in UE are used in Monaco, if so) Sri Lanka Dimethoate, Carbaryl, Carbofuran, Diazinon. Switzerland Other insecticides/acaricides such as neonicotinoids (e.g. thiacloprid, acetamiprid), abamectin, clofentezine or spinosad can be used alternatively. Togo In cotton production, alternative pesticide under testing is Calfos (active ingredient: profenophos 720g.l-1 Thian, another alternative pesticide will be probably under field testing in the near future.

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Ukraine At present there are about 900 names of pesticides registered in Ukraine, mainly imported, any special alternatives are not required United States of America Effective alternatives vary by use and sometimes by geographical region. Insecticides that control pests treated with endosulfan include organophosphates, carbamates, synthetic pyrethroids, neonicotinoids, and various “organic” insecticides. IPEN There is a very wide range of available alternatives to endosulfan, including substitute chemical and biological insecticides; biological controls; and Integrated Pest Management (IPM), organic and agroecological practices. These depend at least in part on the pest/crop complex and only a few examples can be given here. Please note that although the endosulfan industry states endosulfan is compatible with IPM, PAN and IPEN do not agree with this view because of the known adverse effects of endosulfan on beneficial insects (refer section Cii) and the IPM referred to here specifically does not include endosulfan. Endosulfan is used mainly on cotton, tea, coffee, vegetables, rice, pulses and fruit. Cotton Cotton companies in West Africa have proposed spinosad, indoxacarb, malathion, flubendiamide, spirotetramat, triazophos and thiodicarb as replacements for endosulfan to control Helicoverpa armigera on cotton in the 9 Sahelian countries (Burkina Faso, Cape Verde, Chad, Gambia, Guinea Bissau, Mali, Mauritania, Niger and Senegal) that have banned endosulfan. Other alternatives being tested in Senegal include emamectin benzoate.xxxi In the 2001-2004 period, PAN Africa conducted an Integrated Pest and Production Management (IPPM) training programme on cotton in the Vélingara county (Senegal). The programme trained 583 producers from 72 villages belonging to 4 rural communities. The programme was highly successful, with producers obtaining large yields without using chemical pesticides. Instead they used a variety of methods and products including solutions of neem, African dry zone mahogany, and pepper. Improved yields were obtained, with yields under IPPM ranging from 1,120 kg/ha to 2,660 kg/ha, compared to the average 1,200 kg/ha in the previous year.xxxii Global organic cotton production is booming. In Benin there was a 360% increase in the area under organic cotton cultivation between 2005 and 2008, the area having grown to 1,800 hectares.xxxiii India is the world’s largest organic cotton producer. Organic cotton output increased 292% during 2007-08 to 73,702 tonnes compared with the previous year. This resulted in a global organic cotton increase by 152%, to 146,000 tonnes. India contributes half of the world’s organic cotton output. The state of Madhya Pradesh grows the largest quantity in India, followed by Maharashtra and Orissa.xxxiv Gujarat and Andra Pradesh are also important organic cotton producers. Table: Global Organic Cotton growth (tonnes)xxxv Country 2006-07 2007-08 India 18,790 73,702 Syria 2,5023 28,000

Turkey 1,520 24,440

China 4,079 7,354

Tanzania 1,662 2,852

USA 1,918 2,726

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In India Organic cotton growers, in place of endosulfan and other synthetic chemical pesticides, manage pests by varietal selection, crop rotation, intercropping with maize and pigeon peas as trap crops, use of flowering plants like marigold and sunflower to attract beneficial insects, use of the parasitic wasp Trichogramma, and use of botanical pesticides.xxxvi,xxxvii In Benin (where endosulfan is prohibited), non-chemical strategies used by organic cotton growers to manage pests include planting early maturing and pest resistant varieties, use of plant extracts, rotation, and trap crops. A research project is underway to develop food attractive for beneficial insects that combat Helicoverpa armigera. The project is identifying the appropriate food and the vegetable cycle stages at which to use this food as sprays.xxxviii There is a large a number of biological, physical and chemical controls for cotton pests described in two documents by PAN Germany.xxxix,xl For example Helicoverpa armigera may be controlled by using castor as a border crop; using sunflower, black gram and/or cowpea as trap crops; use of light traps and bird perches, and spraying with extracts of Gliricidia sepium leaves.xli As of December 2009, endosulfan is still registered for use on cotton in the US. Historically, in the US, more endosulfan is used on cotton than any other crop;xlii however only about 1% of cotton acres are treated with it each year.xliii Use is mostly on Pima cotton, which is grown in Arizona and California,xliv and its use on California cotton has plummeted in recent years, from more than 100,000 lbs/year in the early 1990s to just under 2,000 lbs/year (1 tonne) in 2007.xlv The US Environmental Protection Agency (EPA) concluded in 2009 that “there will be minimal impacts on cotton producers that are not likely to exceed 1% of net operating revenue if endosulfan is not available,” and that growers would likely switch to alternatives if endosulfan was not available. US EPA noted that there are more than 33 alternative insecticides, representing 9 different chemical classes, which are labelled for use on cotton and recommended for controlling the same pests targeted by endosulfan. Furthermore, US EPA concluded that “endosulfan's current role in resistance management is minimal and that the loss of endosulfan will not result in adverse resistance management outcomes.”xlvi Tea The following list of natural and synthetic pesticides are recommended, by the Chinese tea industry, Zhejiang University Tea Research Institute, and the Tea Research Institute of the Chinese Academy of Agricultural Sciences, as alternatives to endosulfan for pest management in tea plantations.xlvii,xlviii,xlix,l,li Some of these pesticides are used in various combinations. Table: Examples of alternatives to endosulfan for cultivation of tea in China Pest Product Loopworm Ectropis obliqua hypulina (i) Bacillus thuringiensis (Bt) (ii) Buzura suppressaria nuclear polyhedrosis virus (BsNPV) (iii) Ectropis obliqua nuclear polyhedrosis virus (EONPV) (iv) osthole (extract from the plant Cnidium monnieri) (v) matrine (extract from Sophora japonica roots) (v) bifenthrin (vi) deltamethrin (vii) permethrin (viii) cypermethrin (ix) beta-cypermethrin (x) lambda cyhalothrin

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(xi) flucythrinate (xii) diflubenzuron (xii) malathion (xiii) dichlorvos (xiv) phoxim (xiv) chlorpyrifos Tussock moth Euproctis pseudoconspersa (i) Bacillus thuringiensis (ii) beta-cypermethrin (iii) lambda-cyhalothrin Smaller greenleaf hopper Empoasca sp. (i) bifenthrin (ii) cypermethrin (iii) brofluthrinate (iv) dichlorvos (v) chlorpyrifos (vi) difenthiuron (vii) imidaclothiz (viii) imidacloprid (ix) acetamiprid (x) beta-cypermethrin (xi) stemonine (extract from Stemona tuberosa) (xi) toosendanin (extract from Melia sp) (xii) nicotine (xiii) fenobucarb (xiv) isoprocarb (xv) malathion (xvi) phoxim White fly bifenthrin Weevil bifenthrin Caterpillars (i) deltamethrin (ii) cypermethrin Gall mites (i) flucythrinate (ii) propargite Gracillariidae (leaf miners, stem borers) diflubenzuron Red spider mite Oligonychus coffeae lime sulphur Tea pink mite petroleum oil

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Coffee A wide range of biological control organisms have been used to replace endosulfan in coffee cultivation. These include the parasitic wasp Cephalonomis stephanotheris and the entomopathogenic fungus Beauvaria bassiana for coffee berry borer (Hypothenemus hampei) in Bolivia.lii Field studies have shown that B. bassiana can eliminate up to 80% of adult coffee berry borers. In Costa Rica B. bassiana and the parasitoid wasp Phymastichus coffea effectively control H. hampei. B. bassiana is also used in Cuba.liii In 2005, Mexico had 123,000 producers of organic coffee, representing about 19% of the total land area grown in coffee, with this increasing to 25% in 2008. They do not use endosulfan. Coffee berry borer is the main pest. Main alternatives to endosulfan are the fungus Beauvaria bassiana; parasitic wasps Cephalonomia sephanoderis, Prorops nasuta and Phymastichus coffea; and neem.liv Cultural practices to lessen pest problems include collecting infested coffee beans before and after harvest (Costa Rica), and using attractant traps for coffee berry borer (Mexico).lv In 2007 Costa Rica grew 1,713 hectares of organic coffee, without endosulfan.lvi Vegetables Bacillus thuringiensis is widely used in place of endosulfan in Costa Rica and Cuba, to control lepidopteran pests on a range of vegetable crops.lvii In Cuba, the parasitic wasp Trichogramma is used on approximately 777,000 hectares against lepidopteran pests of tomato, peppers, curcubits and tobacco as a substitute for endosulfan. Other parasitoids Telenomus spp, Euplectrus plathyhypenae, Tetrastichus howardii Ollif and Tetrastichus spp are used variously for corn, garlic, onion, peppers, tomatoes, potato, and curcubits as substitutes for endosulfan.lviii As of December 2009, endosulfan is still registered for use on some vegetables in the US. The US EPA noted, in 2009, that alternative chemicals exist for all endosulfan uses, and estimated that should endosulfan become unavailable, the financial impacts on farmers would be minimal. Specifically US EPA concluded that: • switching to alternatives would result in “little impact” on production costs for potatoes;lix • switching to alternatives would result in “generally minor” impacts on cucumber growers, and noted that “[equally] efficacious and affordable alternative exist” for the niche use in Florida against whiteflies;lx • for watermelons and cantaloupe producers “[t]here are alternatives to endosulfan, which according to published efficacy data, can control the pest spectrum as well as endosulfan”;lxi • for pumpkin growers “[t]here are at least two alternatives which control the same pest spectrum as endosulfan but have slightly higher cost per acre”;lxii • “the overall benefits of endosulfan on squash are generally minor” and “available data indicates that efficacious and affordable alternatives exist” for the niche use on squash in Florida against whiteflies;lxiii • according to the EPA “[e]ffective chemical alternatives are available, although some are more expensive” for fresh tomato producers”.lxiv US EPA also notes that there are non-chemical alternatives to many of endosulfan’s current uses. For cucumbers—the crop for which implementing alternative chemicals would be most costly, with impacts on net revenues for those few growers still using endosulfan of 5.5% to 12.3%—US EPA noted that a spring planting should reduce Pickleworm populations and trap crops can also help. For whiteflies, US EPA noted natural predators such as ladybird beetles (Nephasis oculatus), green lacewing larvae (Delphestus spp.), Beauvaria bassiana, and parasitic wasps (Encarsia pergandiella, Eretmocerus spp.) can be employed.lxv

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Aphids, cucumber beetles, and squash bugs are key pests on pumpkins that are targeted by endosulfan (which is only used by a minority of growers). US EPA noted that the use of silver mulch is an important tool for aphid control. US EPA also noted a variety of cultural practices that, as part of an IPM program, can control these pests, including: crop rotation, cover crops, sticky traps, and using certified pest-free plants.lxvi Tomatoes are the one crop in the US on which endosulfan use appears to be increasing significantly. California and Florida are the largest producers of fresh tomatoes, each accounting for about one third US production, while California dominates the production of tomatoes for processing, contributing 93% of US production.lxvii Negligible quantities of endosulfan are used on California’s tomato crop: in 2007 only a single application of endosulfan to fresh tomatoes was reported, and only 26 applications were reported to tomatoes for processing,lxviii amounting to less than 1% of planted acres of tomatoes. In contrast, 86% of fresh tomato acres in Florida were treated with endosulfan in 2006, an increase from 43% and 44% treated in 2002 and 2004 respectively. Thus, the increase in use of endosulfan is confined to fresh tomatoes grown in Florida.lxix The main pests that endosulfan is used against in Florida are whiteflies, aphids, and stink and leaffooted bugs. US EPA’s analysis notes that 14, 21, and 9 alternative insecticides are recommended for use against these pests in Florida, respectively. The Agency estimated the costs of transitioning from endosulfan to each of three alternative chemicals: esfenvalerate, befenthrin, and cyfluthrin. Production costs were estimated to change by 0 to $8 per acre, amounting to 0–1% changes in net revenue. US EPA thus anticipated “little to no economic impact” if farmers were forced to switch to these chemicals.lxx An earlier analysis by US EPA had yielded similar results: losses of 0.02 to 0.7% of the total value of production.lxxi US EPA also identified a number of non-chemical controls for these pests, though they did not estimate the costs associated with implementing them in lieu of spraying endosulfan. With regard to whitefly control, US EPA notes:lxxii

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With regard to aphids:lxxiii

And with regard to bugs:lxxiv

In summary, there is no shortage of documented alternatives—both chemical and culture—to endosulfan use in tomato production. Alternatives are affordable and available now. In addition, the example of California shows that tomatoes can be produced affordably without resorting to endosulfan.

Other crops Bacillus thuringiensis is widely used to control lepidopteran pests in Costa Rica and Cuba, on tobacco and in forestry.lxxv In the US, 10.3% of apple acreage was treated with endosulfan in 2005–07, amounting 52,900 lbs/year. The key pests targeted by endosulfan are the aphids and stink bugs. There are from 12 to more than 40 alternative insecticides available for the control of these pests on apples. For apple growers in the Pacific Northwest, US EPA concluded that “use of alternative [chemical]s should not increase costs although there may be regulatory issues that make the alternative less desirable.” For other apple growers, US EPA acknowledged that “[e]ffective chemical alternatives are available” but noted that those alternatives “are somewhat more costly and managerially complex.”lxxvi US EPA also noted that several non-chemical approaches are available for controlling these pests. Woolly apple aphids can be controlled with natural enemies such as green lacewing larvae, adult and larval lady beetles, syrphid fly larvae, and parasitic wasps. Growing flowering plants in or around orchards can help attract these natural enemies. Other apple aphids can be controlled by these same predators as well as midge larvae, pirate bug, damsel bugs, and the predator Campylomma. Pruning and fertilization practices can also help manage apple aphids. For stink bugs, US EPA notes that the elimination of weed hosts such as mustard, milkweed, morning glory, and others from in and near orchards can “minimize” problems with this pest.lxxvii

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Crops in India Because India is the world’s largest producer of endosulfan it is worth examining whether there are alternatives to endosulfan that are economically feasible, available, in use, and/or recommended by the Government of India or by other credible sources in India.lxxviii The table below shows combinations of crops and pests along with the chemical and biological treatments recommended by the Expert Committee, Government of India, 2008-2009 for use in the State of Orissa.lxxix Note that for many crop/pesticide combinations several pesticides are suitable. Key economic crops for the state are rice, pulses, oil seeds, jute, mesta, sugarcane, coconut and turmeric. Where endosulfan is recommended for any of these crops, alternatives are also recommended. The items underlined are the only pests for which the Expert Committee does not provide an alternative to endosulfan. This amounts to eight pests out of 55 listed in the table, demonstrating that 85% of the listed pests can be treated with alternatives to endosulfan according to Indian government recommendations. In addition, below this table can be found information from other credible sources in India on alternatives to endosulfan for the eight remaining pests.

Table 3: Government of India recommended use of insecticides for certain crop/pest combinations Crop Pest Chemicals Biologicals Paddy Leaf folder endosulfan Trichogramma cypermethrin chilonis lambda-cyhalothrin Hispa/case worm/cut endosulfan Trichogramma worm quinalphos chilonis monocrotophos chlorpyrifos Swarming caterpillar/ carbaryl surti caterpillar quinalphos monocrotophos endosulfan triazophos chlorpyrifos Arhar Pod borer acephate Helicoverpa [pigeon pea] endosulfan armigera nuclear triazophos polyhedrosis virus (NPV) Bacillus thuringiensis Pod bug endosulfan chlorpyrifos methyl oxydemeton imidacloprid Pod fly endosulfan Defoliators endosulfan acephate

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Bengal gram Pod borer azardiractin Helicoverpa endosulfan armigera NPV Bacillus thuringiensis Green gram, black Pod borer monocrotophos Helicoverpa gram triazophos armigera NPV endosulfan Bacillus thuringiensis Groundnut Leafminer monocrotophos endosulfan

Defoliator (Spodoptera endosulfan Spodoptera litura litura) NPV Pheromone traps Helicoverpa/Spodoptera/ triazophos Helicoverpa other leafeating endosulfan armigera NPV caterpillar azadirachtin Spodoptera litura chlorpyriphos NPV

Mustard Leaf and pod caterpillar endosulfan

sawfly endosulfan

Leaf webber ethofenprox Bacillus thuringiensis endosulfan

Sesamum Antigastra sp/ Pod endosulfan capsule borer

Spingid caterpillar endosulfan Sunflower Helicoverpa (head borer) endosulfan Helicoverpa armigera NPV Pheromone traps

Defoliators endosulfan azadirachtin Cutworm dichlorvos endosulfan Castor semilooper endosulfan

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Niger Lucern caterpillar endosulfan defoliator monocrotophos

Linseed Lucern caterpillar chlorpyrifos endosulfan

Defoliator endosulfan carbaryl

Safflower Bihar hairy caterpillar endosulfan methyl oxydemeton dimethoate

Soyabean Leaf roller triazophos Leaf miner phosalone endosulfan Maize Stalk borer endosulfan carbofuran

Corn earworm/defoliator endosulfan carbaryl Ragi Pink borer endosulfan

Millets shoot fly endosulfan Sorghum Defoliators quinalphos fenvalerate endosulfan chlorpyrifos

Gram pod borer endosulfan Helicoverpa armigera NPV Bacillus thuringiensis Cotton Spotted bollworm; pink endosulfan Pheromone traps bollworm; Helicoverpa; triazophos Trichogramma chilonis Red cotton bug; Dusky spinosad Bacillus thuringiensis cotton bug indoxacarb Helicoverpa armigera NPV

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Leaf roller endosulfan chlorpyrifos Jute Semilooper endosulfan quinalphos phosalone

Bihar hairy caterpillar; endosulfan Indigo caterpillar monocrotophos

Mites dicofol endosulfan propargite Mesta Jassid phosalone endosulfan dimethoate Sugarcane Top shoot borer; endosulfan Trichogramma Internode borer carbaryl japonicum

quinalphos Trichogramma carbofuran chilonis

Bhindi Leaf roller endosulfan carbaryl

Curcubits Red pumpkin carbaryl endosulfan

Chilli Fruit borer endosulfan triazophos dicofol Tomato Fruit borer (Helicoverpa endosulfan Helicoverpa armigera) triazophos armigera NPV Trichogramma chilonis Bacillus thuringiensis Pheromone traps

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Cabbage/Cauliflower Cabbage borer endosulfan Bacillus thuringiensis carbaryl malathion

Tobacco caterpillar endosulfan carbaryl

Leaf webber acephate Bacillus thuringiensis (Crocidoloma binotalis) endosulfan malathion

Cabbage butterfly endosulfan Bacillus thuringiensis carbaryl malathion

Potato Cutworm chlorpyriphos endosulfan Pea Pod borer endosulfan Helicoverpa triazophos armigera NPV carbaryl Bacillus thuringiensis

Mango Mango hopper endosulfan carbaryl

Mealy bug endosulfan monocrotophos chlorpyrifos malathion Citrus Lemon butterfly NSKE endosulfan (carbaryl/malathion in fruiting stage) Guava Bark eating caterpillar monocrotophos endosulfan

Cater capsule borer carbaryl endosulfan

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The above table provides alternatives to endosulfan (both chemical pesticides and biological controls) for all crop/pest complexes, except the following:

1. Arhar (pigeon pea) - Pod fly (Melanagromyza obtusa (Malloch)) 2. Mustard - Leaf and pod caterpillar; sawfly 3. Sesamum - Antigastra sp/ Pod capsule borer; Sphingid caterpillar 4. Sunflower - Castor semilooper 5. Ragi - Pink borer; Millets shoot fly An Indian IPM site, hosted by the Jawaharlal Nehru Krishi Vishwavidyalaya Agricultural University, Jabalpu, Madhya Pradesh, gives the following recommendations for both chemical and non-chemical management of four of these eight specific pest/crop complexes: 1. Arhar (pigeon pea) a) Pod fly (Melanagromyza obtusa (Malloch)) Cultural Control • sow resistant varieties • intercropping with jowar, maize or groundnut etc • crop rotation

Biological Control • conserve Ormyrus sp (parasite of pod fly) Chemical Control • monocrotophos • endosulfan • neem seed kernel extract 2. Mustard a) sawfly (Athalia lugens proxima) Cultural controls • summer ploughing to destroy the pupa • early sowing should be done • maintain clean cultivation • apply irrigation in seedling stage is very crucial for sawfly management because most of the larvae die due to drowning effect • severe cold reduce pest growth Mechanical Control • collection and destruction of grubs of saw fly in morning and evening Biological Control • conserve Perilissus cingulator (parasites the grubs), and the bacterium Serratia marcescens Bizio infect the larvae of sawfly • use of bitter gourd seed oil emulsion as on anti-feedent Chemical Control • malathion

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• endosulfan • quinalphos • methyl parathion • carbaryl 3. Sesamum a) Antigastra sp/ Pod capsule borer [Leaf webber, roller and capsule borer (Antigastra catalaunalis)] Cultural Control • early sown (first week of July) Kharif crop is less infested than late sown crop • use resistant tolerant varieties • intercrop with mungbean, pearl millet, urdbean, moth bean and groundnut Mechanical Control • removal of larvae from the leaf webs during the initial stages of plant growth Biological Control • release Bracon hebator, B. Brevicornis and Phanerotoma handecasisella for shoot • webber • release predators like Cantheconidia furcellata, Cicindella spp • release parasitoids like Trathala flavoorbitallis, Campoplex sp., Erioborus sp.,Temelucha biguttula, Apanteles spp. and Cremastus flavoorbitalis Chemical control • endosulfan • quinalphos • phosalone • malathion • deltamethrin • cypermethrin b) Sphingid caterpillar The IPM site lists controls for Hawk moth (Sphinx caterpillar), Acherontia styx, which is a Sphingid caterpillar. Cultural Control • deep ploughing exposes the pupae for predation to insectivorous birds Mechanical Control • hand picking, collection, and destruction of caterpillars Biological Control • use egg parasite Anastatus acherontiae • use larval parasite like Sarcophaga sp., Zygobothria ciliate walp, Apanteles • acherontiae Chemical Control • phosalone • malathion • endosulfan • DAS Alternatives to endosulfan for the remaining four pest/crop complexes (leaf and pod caterpillar on mustard; castor semilooper on sunflower; and pink borer and millets shoot fly on Ragi) are provided by other sources:

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1. Mustard (a) leaf and pod caterpillar This pest is difficult to identify without a scientific name, and it is not included on the IPM site referred to above so it is probably a minor pest of mustard. Until such time as it is properly identified it is difficult to locate alternatives, other than Bacillus thuringiensis which is active against all , and azadirachtin. 2. Sunflower (a) Castor semilooper [Achaea janata] This is another lepidopteran pest that can be controlled by Bacillus thuringiensis and azadirachtin. Recommended measures include:lxxx • deep summer ploughing and destruction of pupae; • encouraging natural control agents like Trichogramma, Apanteles, Bracon, Chrysopa, and ladybird beetles; • spraying 5% Neem seed kernel suspension as repellent for adults from egg lying; • spraying chilli-garlic suspension to kill young larvae; • use of light traps to trap and kill adult insects; • putting bird perches at 10 per acre to attract birds for controlling larval stages. 3. Ragi (Eleusine coracana), also known as finger millet and African millet (a) Pink borer • “Crop rotation with short duration non-graminaceous (legume) crop to reduce the borer population. This practice helps in breaking the life cycle of the borer. • Application of optimal rates of nitrogenous fertilizers in split application minimises the crop susceptibility to the borer. • Removal and destruction of dead hearts at the initial stages of infestation. • Harvesting the crop close to the ground level will greatly help in eliminating the larval and pupal stages of the pest. • Ploughing the fields immediately after harvesting kills larvae and pupae over wintering on the stubbles, which serves as chief source of infestation in the succeeding seasons. • The eggs of the borer are naturally parasitised by Telenomus dingus and Trichogramma sp. • The larvae are naturally infected by the fungus Beauvaria bassiana during winter. • Spiders and birds also prey efficiently on adult during brood emergence in the fields. • In case of wide spread infestation, spray any one of the insecticides such as phospamidon 85 WSC 1.0 ml/litre or chlorpyriphos 20 EC 2.0 ml/litre or endosulfan 35 EC 1.5 ml/litre on need basis 15 days after sowing.”lxxxi (b) Millet shoot fly • For infestation of shoot fly and stem borer after sowing spray quinalphos 0.05% or triazaphos 0.04% @ 600 l/ha at 15 days after sowing. If necessary a second spray of same pesticides after 15 days should be done; • use high seed rate i.e. 5 kg/ha and remove plants with ‘dead heart' at the time of thinning; spray with methyl parathion 2% or malathion 5% dust @ 25 kg/ha at 15 days after sowing; • use plant bio-pesticides Nimark @ 30ml/10lit. at 10, 20 and 30 days after sowing; • two sprays of neem oil 0.05% and 4g soap in 1 l water at 10 and 20 days after sowing.lxxxii ISC Endosulfan is a broad spectrum pesticide Endosulfan is used in the control of a broad spectrum of insects in numerous important crops throughout the world in the battle against a variety of chewing and sucking type insects. This characteristic brings the benefit of a reduction in the number of pesticides and applications necessary to combat target pests resulting in an overall lessening of the amount of pesticides released into the environment. Endosulfan is a critical tool in resistance management Although in use for over 50 years, the efficacy of endosulfan has remained constant and the target insects have not built a tolerance for it, consequently it is valued as an important tool for use in resistance management. One of the most important aspects of endosulfan in agriculture is that it serves as an alternative to other pesticides which suffer from the development

49 UNEP/POPS/POPRC.6/INF/24 of resistance by the target insects. Newer products such as neonicitinoids and pyrethroids need to be sprayed more frequently and are becoming less effective and showing more insect resistance. It is common knowledge that products in the same chemical group can not be used in isolation against a particular pest for an extended period because insects will develop resistance to the products. Continued application of these pesticides requires increased doses due to the gradual reduction in efficacy each season, until it is completely ineffective. Insects do not build a resistance to endosulfan. In order to avoid the development of resistance and maintain the effectiveness of the pesticides, the farmer must vary the type pesticide used. This is an integral part of a system known as Integrated Pest Management (IPM). This provides a more efficient control of agricultural pests, which results in improved economy for the producer and consumer and protection of the environment. It is essential that the products constituting the IPM for a given application prevent the development of resistance, have high efficiency and low cost in order to maintain profitability for the grower and reasonable prices for the consumer. The importance of endosulfan as part of an IPM is the lack of resistance on the part of pests to it. From 1914 until 2008 there have been more than eight thousand cases of resistance to insecticides in the world, none of which includes endosulfan. Endosulfan is an indispensable product of the IPM for soybean, sugar cane, cotton and coffee and sunflower. In the 2002 RED the USEPA states “Resistance, which has been observed in other crops, hinders control with another pyrethroid application, the usual method of treatment, and would require use of potentially harsher alternatives.” Should endosulfan not be available for use, the need to use increased volumes as insects’ resistance builds to the replacement products will result in exposing the environment to a greater chemical burden. These products will cost more per area of farmland, which will increase the prices of food and other agricultural products.

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(ii) Technical feasibility Technical feasibility can be understood to consider whether an alternative (chemical, semio-chemical, biological control, IPM control or cultural control) exists or is expected to be developed in the foreseeable future (see UNEP/POPS/POPRC.5/6). Australia Endosulfan is currently used in an IPM system to control fruit spotting bug which involves crop monitoring, identifying infestation hot spots and treating only the affected arealxxxiii. Although the alternatives listed above are already registered in products for those uses or, for those allowed on permit, are being trialled, beta-cyfluthrin and the organophosphates are disruptive to IPM systems. Of the organophosphates, azinphos-methyl, acephate and methidathion are currently subject to regulatory reviews and trichlorfon is earmarked as a review candidate. Therefore, the number of alternatives may be reduced leaving only beta-cyfluthrin. In the longer term, pheromone based traps may assist in fruit spotting bug management. However, even if these are commercially viable, various industries will still require IPM compatible control options. Costa Rica Hay viabilidad tecnica. Japan Those alternatives have already been registered by MAFF. Malaysia The alternatives product is being used without major complaint from the users. Monaco Not estimated in Monaco (same for iii-vii). Switzerland Highly feasible. Togo Under evaluation. United States of America Alternatives to endosulfan are currently available in the United States of America; but some may not be as effective as endosulfan. IPEN As stated in the POPRC guidance on alternatives, “Commercial or current availability of an alternative is an important indicator of technical feasibility”.lxxxiv All the alternatives described above are believed to be already in use and therefore technically feasible. (iii) Costs, including environmental and health costs Australia For use in cotton, endosulfan costs about AUD $14/ha to control Helicoverpa spp., Green Vegetable Bug and Cotton Aphid, whereas alternatives are more expensive at $20-45/ha. Environmental and health costs are unknown at this stage. Brazil Regarding environmental hazard, most formulations based on endosulfan are considered class 1 – highly dangerous. The possible alternatives range between classes 2 (very dangerous) and 3 (dangerous), whereas the combination (Thiametoxam +Lambda cyalotrina) was also considered class 1, highly dangerous.

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Canada Modern re-assessments of the human health and environmental risks of several possible alternative chemicals are underway or scheduled. An analysis of benefit costs of restricting endosulfan use on strawberries can be found in the Annex. China The cost of above-mentioned products (b, i), especially their environmental and health cost is to be evaluated. Costa Rica No hay información. India Not applicable. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Malaysia The chemical has been banned and its alternatives have been used in the areas of its usage although there are some cost implication. Togo As mentioned in previous chapter. United States of America Type and magnitude of costs depend on pests, production systems, and availability of alternatives. Types of costs could include: ƒ Direct costs to agricultural producers in terms of more costly alternatives and/or decrease in quantity or quality of output. ƒ Indirect costs to consumers of agricultural products in terms of reduced availability and high prices. Possible environmental or health costs. In some situations, multiple alternative insecticides may be needed to replace endosulfan. IPEN Implementing substitutes for endosulfan has been found to result in either very small increases in costs (e.g. 0–1% changes in net revenue in US tomato production),lxxxv no additional costs, projected reductions in costs, or increases in income for farmers. For example, in West African cotton production the substitution of endosulfan by other pesticides is projected to reduce costs to farmers;lxxxvi and in India replacement of endosulfan use in cotton with non-pesticide management methods has significantly reduced costs and increased incomes for farmers.lxxxvii In Sri Lanka there were no sudden changes in costs of rice production coinciding with the bans of endosulfan, methamidophos and monocrotophos.lxxxviii Detailed research in 2003 and 2004 in India demonstrated that organic cotton farming can be far more profitable than conventional cotton farming using endosulfan, with gross margins about 30-52% higher than the conventional production. Revenues from organic cotton sales were about 30% higher than conventional cotton.lxxxix In the state of Andra Pradesh, one of India’s major producers of cotton, rice, groundnut and lentils and where endosulfan is widely used on a number of crops, more than 300,000 farmers have adopted ‘Community Managed Sustainable Agriculture’ (CMSA) on 1.36 million acres of farmland. This represents 5.1% of the cropped area in the state and this has been achieved in just over four years. Crops grown include chilli, groundnut, red gram, cotton, rice, maize, onion, beans, okra, and eggplant. Endosulfan and other synthetic chemical pesticides and fertilisers have been replaced with a combination of physical and biological measures including IPM practices, neem, pheromone traps, soil inoculation with Azospirillum and Azotobacter, vermiculture, green manure crops, and intercropping.xc

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Results reported by the World Bank show “a significant net increase in farmers’ incomes in addition to significant health and ecological benefits”, without “significantly reducing the productivity and yields”.xci The yields are the same for chilli and groundnut, slightly higher for red gram and slightly lower for cotton and rice, as compared with conventional farming:

Table: Yield comparisons – CSMA and Conventional production in Andra Pradesh

A survey of 141 of the CMSA farmers found the costs of cultivation to be only 33 % of the costs under conventional production. A state-wide survey found these farmers are making the following average savings on the cost of cultivation, per acre, per year: rice = US $20 chilli = US $300 cotton = US $100 groundnut = US $16 red gram = US $24 others (fruit, vegetables, cereals) = US $20 Based on the savings made by individual farmers, the state-wide estimate of cumulative savings made by farmers practising CMSA is US $38.6 million for the year 2008-09.xcii The authors of this World Bank report stated that “there is a potential for scaling up this approach to the whole of India as CMSA is showing trends of being economically viable and ecologically friendly. The newly set up National Mission on Sustainable Agriculture in India is considering adopting CMSA as one of the key strategies at the national level”.xciii (iv) Efficacy Australia The APVMA assessed each registered alternative as being efficacious for the intended use. China The above-mentioned pesticides have been applied for year. Pests are already resistant to them. Thus they can not be used as alternatives to endosulfan. Costa Rica En Costa Rica al año 2008 existian alrededor de 8.000 hectáreas de cultivos agricolas certificados de agricultura orgánica, que non hacen uso de ningún plaguicida o fertilizante químico, dentro de éstas existen 1.713 has de café, 1.123 has de piña, 85 has de hortalizas y 55 has de arroz (Ecológica. 2009). El número de hectáreas organicás disminuyó del 2006 al 2008, debido a que los altos precios del café hicieron que muchos productores reiniciaran el uso intensivo de fertilizantes químicos y algunos plaguicidas, y a que el programa de liberaciones de parasitoides para broca no se continuó. India Endosulfan is an effective broad spectrum insecticide, no reports of resistance development and it is safer to honey bees and to other beneficial insects of agroecosystems. The alternatives may not have all such good qualities. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped.

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Malaysia Although the alternatives recommended not really as good as endosulfan in term of efficacy and cost, generally they are accepted by users. Togo Under evaluation United States of America Varies by pest and agro-environmental conditions. IPEN As stated in the POPRC guidance on alternatives, “Efficacy is how well the alternative performs in a particular functionality including any potential limitations.”xciv Efficacy of the alternatives to endosulfan is demonstrated by the maintenance of, or increase in, yields, and also by the widespread use of alternatives even when endosulfan is available. For example in Sri Lanka, no reduction in yields of 13 vegetable crops or rice were observed in the years following the prohibition of endosulfan (together with monocrotophos and methamidophos).xcv In Andra Pradesh, the CMSA techniques are efficacious as yields are largely maintained. In Senegal, PAN Africa’s IPPM cotton programme (which replaced endosulfan use with other products and practices) improved yields, with yields under IPPM ranging from 1,120 kg/ha to 2,660 kg/ha, compared to the average 1,200 kg/ha in the previous year.xcvi In 2008, 25% of the coffee produced in Mexico was organic.xcvii In 2007 Costa Rica grew 1,713 hectares of organic coffee.xcviii In both countries organic production systems have proven efficacious replacements for endosulfan. The US EPA acknowledged that “[e]ffective chemical alternatives are available” for apple growers”.xcix Bacillus thuringiensis is widely used in place of endosulfan in Costa Rica and Cuba, to control lepidopteran pests on a range of vegetable crops, tobacco and in forestry.c The Community Managed Sustainable Agriculture practiced in 5.1% of the cropped area of Andra Pradesh, India, is achieving “a significant net increase in farmers’ incomes in addition to significant health and ecological benefits”, without “significantly reducing the productivity and yields”. The yields are the same for chilli and groundnut, slightly higher for red gram and slightly lower for cotton and rice, as compared with conventional farming. Here, it is not only endosulfan that has been replaced by alternatives but also all other synthetic chemical pesticides.ci ISC See chapter (B) (i). (v) Risk Australia For those registered alternatives, the APVMA conducted assessments on environmental and human health risks and were satisfied that the use of the chemicals would not have adverse effects. China Environmental and health risk is to be evaluated. Costa Rica No hay información. India Risks of pesticides get duly evaluated before registration. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped.

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Malaysia Generally the alternatives are less toxic to human and less persistent in the environment. Switzerland Risk evaluated during plant protection product registration and thus known within the country of use. Togo Not yet assessed. United States of America All alternatives evaluated currently meet EPA’s registration standard. (vi) Availability Australia Registered alternatives are available on the market. Those under permit are available according to the conditions of the permit. Brazil All these active ingredients have registered products in the Brazilian market and are being commercialized. Bulgaria Alternative plant protection products, not containing Endosulfan are placed on the market from 2000. Costa Rica No hay información. Japan Many alternatives are already sold. India Available alternatives are expensive. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Malaysia The alternatives are widely available in the country. Switzerland Available. Togo Commercially available. United States of America Alternatives generally available, some variability by pest and use site. IPEN The alternatives described above, and many others, are on the market and ready for immediate use in many countries, including developing and transition countries.

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(vii) Accessibility Australia The accessibility of both registered and permitted alternatives is governed by the conditions of use specified on the label of each product. This information is not connected to the specific needs and circumstances of developing countries. China Since 2007, China has banned the use of five highly toxic organophosphorus pesticides: methamidophos, methyl parathion, parathion, monocrotophos, and phosphamidon. As a result, there aren’t many choices available for Chinese peasants. Costa Rica No hay información. India High costs limit the accessibility. Japan Many alternatives are sold nationwide. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Malaysia The alternatives are accessible in the country. Switzerland Accessible. Togo Easily accessible. United States of America Registered alternatives should be widely accessible to users. IPEN The alternatives described above are widely accessible, and especially in developing countries such as African countries (Burkina Faso, Cape Verde, Chad, Gambia, Guinea Bissau, Mali, Mauritania, Niger and Senegal), Argentina, Bolivia, Brazil, Chile, China, Costa Rica, Cuba, India, Mexico, Paraguay, Sri Lanka, and Uruguay, as appropriate. (c) Summary on information on impacts on society of implementing possible control measures (i) Health, including public, environmental and occupational health Australia The Department of the Environment, Water, Heritage and the Arts is finalising a review for the APVMA of the environmental risks posed by the continuing use of endosulfan in Australia. The results of this review are not yet available. Brazil Endosulfan is an organochlorine pesticide and since it presents high toxicity to human health, in many countries it has been banished or suffered severe restrictions. The studies submitted by the companies to ANVISA demonstrate that endosulfan presents unacceptable acute and chronic risks for the whole population. This pesticide exhibits high oral, dermal and inhalatory toxicity, and also causes extreme ocular irritation, as well as corneal opacity in experimental animals. Accordingly to Brazilian legislation, endosulfan is classified as Class I: Extremely Toxic.

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The oral, inhalatory, ocular and dermal exposure of endosulfan can cause adverse effects in humans, for example, hepatic and respiratory damages, or even death. There are many laboratory assays to evaluate chronic toxicity and carcinogenicity and genotoxicity. They demonstrate that endosulfan is genotoxic, causing DNA damage and clastogenicity, as well as non-genotoxic effects are shown, for example apoptosis inhibition. Both effects are extremely important to evaluate the carcinogenic potential of a pesticide. And considering that the genotoxicity effects are not dose dependent, there was not established safety limits for humans exposed to this kind of pesticide. The genotoxic effects, that can also cause the lost of the cellular proliferation control, can be minimized and not necessarily induce the appearance of neoplasias, when compensatory mechanisms – as apoptosis and immune surveillance – are preserved. However, as endosulfan inhibits apoptosis, this physiological mechanism of killing the mutated cells is not efficient. The immune surveillance is also affected when the organism is exposed to an immunossupressor agent. The in vitro studies with human and animal cell culture also demonstrate that endosulfan is an immunossupressor substance, affecting the cellular and humoral immune response. The immune system is also intrinsically associated to the endocrine and nervous systems. In this context, endosulfan causes acute neurotoxicity and the human health effects are described in detail in studies, as epilepsy, hyperactivity, convulsions and muscle paralysis. The endocrine function is also affected when the exposure to endosulfan occurs, as demonstrated by various epidemiological and laboratorial studies. Endosulfan is considered an endocrine disruptor agent, as it is able to induce histopathological effects in reproductive tissues, reduction and delay of fertility and hormonal alterations. Some endocrine adverse effects can be reversible, whereas when the exposure occurs in critical moments as, for instance, during the embryo fetal development, these effects are sustained. The adverse effects associated to endosulfan human exposure are basically the genotoxicity, the reproductive and embryo fetal development toxicity, neurotoxicity, immunotoxicity and also the endocrine disruption. Therefore, it can be concluded that endosulfan acts on the neuro-immune-endocrine triad. Bulgaria Not assessed in Bulgaria. Costa Rica Con la prohibición del endosulfan se estaría deteniendo la contaminación persistente de Fuentes de agua utilizadas para el consume humano, la salud ambiental de ecosistemas de bosques nubosus donde no se aplica endosulfan pero por mecanismos metereológicos este Ilega hasta estasa alturas. La salud ocupacional de los productores y trabajadores de fincas de melon, hortalizas, café y otros, se vería mejorada por la no presencia de este contaminante. (Ramírez F. RAPAL Costa Rica). India Registered pesticides do no cause any health hazards. Japan No impact. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Madagascar Risk reduction of workers health and health of sourrounding population (reduction of presence of residues in water and other vegetable products). Malaysia Exposure to applicators have been removed completely since the effective date of its ban, thus, its release to the environment has been avoided except for illegal use. Monaco Not estimated in Monaco (also for ii-vi).

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Switzerland Not known as not studied for endosulfan. Togo Banning Endosulfan will undoubtedly prevent from using it for pest control on food crops like beans and market gardening production as it has been pointed out during the inventory of Annex A pesticides in the NIP development process in Togo. Ukraine At present n/a, will be represented additionally when available (related to whole part (c)) United States of America Likely positive environmental and health impacts; however, control measures could require use of multiple alternative insecticides in some cases. IPEN Elimination of endosulfan production, use, export and import through a listing in Annex A of the Stockholm Convention would have a positive impact on human health and the environment by decreasing emissions of a substance that warrants global action. As outlined in the Risk Profile, endosulfan is toxic, persistent and bioaccumulative. There is evidence of widespread contamination of the environment, wildlife, the human food chain and human body tissues.cii If endosulfan production and use is not eliminated, then levels in the environment and humans will continue to rise, even in locations distant from production and use. Considerable adverse human effects have been caused by exposure to endosulfan. Numerous intentional and unintentional deaths have occurred from ingestion of endosulfan, and poisonings have been reported in Benin, Colombia, Costa Rica, Cuba, Guatemala, India, Indonesia, Malaysia, Philippines, New Zealand, South Africa, Sri Lanka, Sudan, Turkey and United States of America. It is regarded as one of the main causes of poisoning in many countriesciii including in Asian countries,civ Latin America,cv and West Africa.cvi Endosulfan is one of the most frequently reported causes of poisoning globally.cvii Many of the deaths from endosulfan have resulted from occupational exposure, especially in cotton farmers in Africa.cviii In the Kasargod district in Kerala, India, sustained exposure to endosulfan resulted in congenital, reproductive, longterm neurological damage, and other symptoms. There were observations of similar effects in animals: cows giving birth to deformed calves, cows and chickens dying inexplicably, domestic animals with miscarriages, bleeding, infertility, stunting of growth and deformities, as well as fish kills and dwindling populations of honeybees frogs, and birds (Yadav & Jeevan undated; NIOH 2003).cixcx A committee set up by the Kerala State Health Department to study the health hazards of endosulfan recently observed that the major impacts of exposure in the villages included increased congenital abnormalities including limb and cardiac abnormalities, severe mental retardation including cerebral palsy and hydrocephalous, cancers, and skin diseases. Most of these conditions led to death or permanent disabilities.cxi Whilst 500 deaths have been officially acknowledged, unofficial estimates place the figure at around 4,000. More than 9,000 people are reported to have health problems resulting from the exposure to endosulfan.cxii Recent reports indicate another 137 victims of endosulfan in the neighbouring state of Karnataka.cxiii Elimination of endosulfan production and use would positively impact human health by reducing and eliminating the contribution of endosulfan to these types of health impacts. ISC Overall statement of the socio-economic benefits created by endosulfan Importance of food supply for a growing population with limited crop land The world, with a current population of approximately 6,700,000,000 people and expected to grow to 9,200,000,000 by 2050, is dependant on an adequate food supply to avoid hunger, starvation and the health problems associated with malnutrition, which are among the basic elements for the preservation of peace and tranquility. With limited land available for the production of food crops, it is necessary to optimize the efficiency of food production on this available land. Endosulfan aids in fulfilling this need The wide use of endosulfan based pesticides is strongly associated with its characteristic of being a broad spectrum insecticide, its excellent efficacy and selectivity to natural enemies, the lack of resistance of insects to it and its lack of adverse impact on pollinating insects including the honey bee. In addition to these characteristics it is a product of choice because of its lower cost of treatment than products being sold for the same purposes. All of these factors work together to

58 UNEP/POPS/POPRC.6/INF/24 provide: an economic food supply to the population and economic benefit to the grower and the countries in which it is used. Minimal risk associated with the manufacture and use of endosulfan Endosulfan has been used for more that 50 years as a pesticide with minimal impact on the health of workers, the public or the environment. Many studies have been conducted such that the hazard characteristics of endosulfan are well documented. Many of these studies may be found on the POPs website. The risk of using endosulfan has been well studied and acceptable tolerances (Minimum Residue Levels) have been established by national regulatory authorities as well as the World Health Organization. On the other hand the consequences of using the newer products have not been fully determined. The risk of the use of endosulfan has been evaluated by the governments with registration processes and its application specific registration prescribes risk mitigation steps which make the use of endosulfan in these countries acceptable from a human health and environmental standpoint. (ii) Agriculture, including aquaculture and forestry Australia Implementing control measures on endosulfan would have a negative impact on cashew nuts, cucurbits, guava, kiwi fruit, longans, loquats, mango, rambutans and tamarillo, as endosulfan is the only chemical registered on these crops to control the fruit spotting bug. Loss of endosulfan could mean loss of control and economic loss for growers. Although alternatives may be available, it takes some time for new products to be registered/approved, especially for new chemistry products and for use on minor crops. The Australian cotton industry has indicated endosulfan plays an important role in integrated pest management (IPM) because of its particular pest spectrum and mode of action, which allow it to provide effective control of a range of important chewing and sucking pests whilst having a low risk of generating secondary pest outbreaks. It is valued by the cotton industry as a strategic early season plant bug control option that limits later season secondary pest build up which often results in the need for more expensive insecticide treatments. The cotton industry has had a voluntary insecticide resistance management strategy (IRMS) for 25 years that has limited resistance development by rotation of all major insecticide groups registered for use on cotton. Despite this, many chemicals have developed some resistance in one or more pest species. Over this time, endosulfan has proved highly resilient to the development of resistance in the key cotton pests. Loss of endosulfan would reduce the number of different chemical modes of action available and could result in quicker resistance build up in pests. Implementing control measures could further reduce the risk of endosulfan residues in beef when cattle consume stock feed or pastures. However, the results of random monitoring by the National Residue Survey (NRS) indicate the level of risk involved is already low. In the period from July 2004 to June 2009, NRS monitoring programs tested 5,557 beef samples for endosulfan residuescxiv. Only one sample was detected above the NRS limit of reporting (LOR)cxv for endosulfan of 0.02 mg/kg. Brazil The wide use of endosulfan based pesticides is inextricably linked to its characteristic of being a broad spectrum insecticide, its excellent efficacy and selectivity to natural enemies, the lack of resistance of insects to it and its lack of adverse impact on pollinating insects like the honey bee. In addition to these characteristics it is a product of choice because of its lower cost of treatment than products being sold for the same purposes. All of these factors work together to provide a competitive position for Brazilian agricultural production in the world. One of the most important aspects of endosulfan in Brazilian agriculture is that it can serve as an alternative to other pesticides which suffer from the development of resistance by the target insects. It is common knowledge that products in the same chemical group can not be used in isolation against a particular pest for an extended period because insects will develop resistance to the products. Continued application of these pesticides requires increased doses due to the gradual reduction in efficacy each season, until it is completely ineffective. Insects do not build a resistance to endosulfan. In order to avoid the development of resistance and maintaining the effectiveness of the pesticides, the farmer must vary the type pesticide used. This is an integral part of a system known as Integrated Pest Management (IPM) (FAO definition: Integrated Pest Management means the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations and keep pesticides and other

59 UNEP/POPS/POPRC.6/INF/24 interventions to levels that are economically justified and reduce or minimize risks to human health and the environment. IPM emphasizes the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms). This provides a more efficient control of agricultural pests, which results in improved economy for the producer and consumer and protection of the environment. It is essential that the products constituting the IPM for a given application prevent the development of resistance, have high efficiency and low cost in order to maintain profitability for the grower and reasonable prices for the consumer. The importance of endosulfan as part of an IPM is the lack of resistance on the part of pests to it. From 1914 until 2008 there have been more than eight thousand cases of resistance to insecticides in the world, none of which includes endosulfan (Source: www.pesticideresistane.org). Endosulfan is an indispensable product of the IPM for soybean, sugar cane, cotton and coffee. As for coffee, the only substitute does not have suitable efficacy, therefore the value of this crop will be lost without the availability of endosulfan. If endosulfan will not be available for use, will be need to use other products and is possible that these products will cost more per area of farmland, and is possible which will increase the prices of food and other agricultural products, too. The coffee berry borer (Hypothenemus hampei) is considered a key pest of the coffee crop in the main areas where coffee is grown in the world, attacking fruit at any stage of maturation, from green to dry. The males are smaller than females, have rudimentary hind wings (membranous), consequently they do not fly and never leave fruit from which they came. They attack young fruits resulting in losses in yield. (Source: Rural Magazine, Ed No. 119, Jan. 2008). The only insecticides that satisfactorily control the coffee borer are those which are based on endosulfan, the products with the active ingredient chlorpyrifos fail to provide the necessary control, and increase the production costs by 64%. This dependence of coffee production on endosulfan is well illustrated by the statement of Regional Cooperative of Coffee Growers of São Sebastião do Paraíso - Cooparaiso. This cooperative is one of the largest coffee producer cooperatives in Brazil, working directly in 72 municipalities. The producers are mostly small and mini growers and their properties have an average area of 11.92 hectares. Coffee, its main product, is responsible for 58% of their revenue. This region has a coffee area of 340 thousand hectares, which produces an average annual 5.2 million 60-kg bags of coffee. Composed of 5,500 associates, the cooperative makes the following statement: "Among the major pests in coffee is the fruit borer (Hypothenemus hampei). It causes large losses in the quality of green coffee, which results in loss of quality of the final product. Of the pesticides registered for use in the coffee crop, the only one that has efficacy in controlling this pest is the active ingredient endosulfan. Not having any other insecticide that might replace it, if its registration is cancelled, it will cause significant losses to the Brazilian coffee industry". If the coffee berry borer can not be controlled by the farmer, the low productivity as the result of agricultural pest makes coffee growing economically unviable. It is no coincidence that more than 3,000 coffee farmers signed a petition, which was strongly against a ban on endosulfan. It should be remembered that Brazil is the world’s largest producer and exporter of coffee and ranks second in the consumer market. In addition, Brazil has also started to capture the world’s market of high quality roasted coffee beans and ground coffee. The cultivation of cotton is certainly more expensive than other major crops, since it requires a heavy investment in exclusive machines, logistics and in pest control. This is the case because of cotton’s increased susceptibility to disease and pest, especially in the early stage of its growth. The boll weevil (Anthonomus grandis) can cause, at any time of cultivation, losses of up to 70% of production of cotton. Of the products used in its control, endosulfan is the most important, considering that the crop protection products based on malathion and methyl parathion have lower selectivity and low efficiency. The use of pyrethroid based insecticides, which has low selectivity to natural enemies, is not recommended in cotton before the crop is 80 days old, which can result in an unacceptable mite population. While endosulfan is being used specifically against the boll weevil, due to it being a broad spectrum insecticide, it is also effective in controlling other important pests as the leaf worm (Alabama argillacea), apples caterpillar (Heliothis virescens, Helicoverpa zea), mite (Polyphagotarsonemus latus) and aphid (Aphis gossypii). As the result of this, endosulfan is vital to control the boll weevil and other secondary insects, especially in the first 80 days of the crop’s growth. Consequently, if endosulfan is not available for use as part of the IPM for cotton, production will be severely impaired, as the boll weevil becomes resistant to existing products. The state government of Parana, EMBRAPA and the Foundation for Support of Agricultural Research of Mato Grosso and House of Cotton Sector project such effects. The main pest that plagues the sugar cane crop is the beetle Migdolus (Migdolus fryanus). The losses caused by this pest may restrict production to a few tons of cane per hectare. In most cases in which the control is inadequate, the loss is of the entire crop, which requires replanting the crop.

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The difficulty of fighting Migdolus lies in the fact that it is not possible to be aware of where it is in its life cycle or to accurately predicts its appearance in a given area. This is coupled with the fact that adults spend part of their life at great depths in the soil (2 to 5 meters), which provides this insect substantial protection to traditional measures of treatment (Source: www.agrobyte.com.br/migdolus.htm). Experience indicates that the use of insecticides based on endosulfan is the best way to control the Migdolus, providing increased production of 19 metric tons per hectare. If endosulfan is removed from the market, the only replacement products will be based on fipronil, to which insects build resistance. This concern is highlighted by Cosan: "Endosulfan has a mode of action that differentiates it from other products such as organophosphates, carbamates, and pyrethroids. Fipronil is protected by patent, and is supplied by a single supplier and would represent an increase of 268% in cost per hectare treated. For these reasons endosulfan is an important tool in management programs resistance to insecticides, since it helps in preventing emergence of resistance to other classes of insecticides. These data lead to the unwavering conclusion that the maintenance of the IPM of cane sugar depends on the availability of endosulfan on the market, with its unavailability will, on the other hand, result in a significant increase in the cost of production. In Brazil, soybean accounts for 94.5% of oilseed crops, constituting the main export crop. Without endosulfan, some of the pests encountered today cannot be controlled by the existing replacement insecticides. The soybean crop is subject throughout its cycle by the attack of different species of insects and IPM is needed to maintain its population within acceptable levels. Among the main pest affecting soybeans are the caterpillar (Anticarsia gemmatalis), the Brown Stink Bug (Euschistusheros), Southern Green Stink Bug (Nezara viridula) and the Small Green Stink Bug (Piezodorus guildinni). They cause quantitative and qualitative losses because they suck the grain, reducing them or changing the amount of oil and protein according to Embrapa (Dourados-MS), a unit of Empresa Brasileira de Pesquisa Agropecuaria-Embrapa, under the Ministry of Agriculture, Livestock and Supply. Stink bug control on soybean is mostly accomplished by organophosphate based products (including pyrethroids and neonicotinoids) and endosulfan. It has been reported, however, that the exclusive use of organophosphates in some regions of Brazil led to the unsuccessful control of the bugs. The most likely explanation of this is the development of resistant populations, due to lack of rotation with endosulfan, which possess distinct mechanism of action and high selectivity to natural enemies and, as is common knowledge, does not generate resistance. The need for endosulfan as part of the IPM for soybean has been highlighted by the Association of Soy Producers of Mato Grosso - APROSOJA: "Especially with its unique mode of action, selectivity to natural enemies, endosulfan has been a key tool for Integrated Pest Management (IPM) and programs Handling Resistance. Endosulfan is the ideal product for species difficult to control such as Helicoperva armigera and whitefly cotton culture in which there is already resistance to insects to other groups of insecticides in Europe. In this context, endosulfan is of fundamental importance to maintain the IPM used in the plantation, so as to avoid the development of resistance of the pests to available organophosphates. Also it is important to provide resources to farmers to maintain the economic viability of their production. Bulgaria Not assessed in Bulgaria China China is an angricultural country with a large territory and a variety of pests. Endosulfan, as an effective pest control chemical, once banned, angricultural production will surely be affected by the shortage of pesticides available or hight cost for alternatives. Costa Rica Con la prohibición del endosulfan para uso Agricola, se tendria aguas proveniente de uso Agricola menos contaminadas, que Ilegarian a los lugares vecinos de producción de camarones y peces sin causar mortalidades ni enfermedades crónicas acumulativas en los organismos acuáticos. (Ramírez F. RAPAL Costa Rica) Japan The possibility of the reduction in damage of fish.

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Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Malaysia Apart from its illegal use in applications that were not recommended there is no complaint from the users although the alternatives have disadvantage on price. Switzerland Not known as not studied for endosulfan. Togo No data collected. United States of America Maybe negative impacts on agriculture (crops and livestock). Magnitude of impacts depends on the control measure(s) taken. IPEN Eliminating endosulfan from agriculture and substituting safer alternatives, especially agroecological practices, would have a positive impact on agricultural production. Bees Endosulfan is toxic to bees and other beneficial insects. Therefore, removing it from the market would have a positive impact on these species, provided that it is not substituted with chemicals that are even more toxic to these species. The acute honeybee oral LD50 is 2 "g/bee, and the acute contact LD50 has been determined to be 0.82 to 4.5 "g/bee, making endosulfan moderately to highly toxic to this species (Apis mellifera).cxvicxvii Sublethal effects of endosulfan on bees include reduced olfactory learning.cxviii It reduces their ability to provide pollination services in agriculture. Canada has mandated that labels of endosulfan products sold in that country bear the statement: “TOXIC to bees exposed to direct treatment, drift, or residues on flowering crops or weeds. DO NOT apply this product to flowering crops or weeds if bees are visiting the treatment area. Minimize spray drift to reduce harmful effects on bees in habitats close to the application site.”cxix The US state of Washington has required that “Pollinator Protection Statements” appear on the labels of certain endosulfan products, limiting their use in such a way as to protect bees. For example, the state requires that products sold for use on alfalfa bear the statement: “This product is highly toxic to bees exposed to direct treatment or residues on blooming crops or broadleaf weeds. Do not apply the 1.33 quarts per acre (1 lb ai/A) rate of this product to blooming seed alfalfa: apply at that rate as a pre-bloom or post-bloom spray only. Application of the 1.33 pints per acre (0.5 lb ai/A) rate of this product to blooming seed alfalfa must be timed to coincide with periods of minimum bee activity, between late evening and midnight.”cxx All Makhteshim Agan endosulfan products sold in the US bear the following statement on their label: “This pesticide is toxic to bees exposed to direct application. Applications should be timed to coincide with periods of minimum bee activity, usually between late evening and early morning.”cxxi Beneficial insects Endosulfan is ranked as highly toxic to the following beneficial insects: beneficial mites, big-eyed bugs, damsel bugs, ground beetles, lacewings, ladybird beetles, minute pirate bugs, predatory midges and thrips, spiders, and syrphid fly larvae, and ranked as moderate toxicity to parasitic wasps.cxxii Hence endosulfan is incompatible with IPM, and its continued use inhibits proper adoption of IPM systems. It significantly reduced the emergence and the parasitism of the parasitic wasp Trichogramma pretiosum,cxxiii which kills the eggs of various moth pests such as Heliothis, corn borer, cabbage moth, loopers, and yellow peach moth. It is toxic to Orius insidiosus (minute pirate bug / insidious flower bug), which predates thrips, mites, aphids and small caterpillars; and to the parasitic wasp Aphidius colemani, which parasitizes aphidscxxiv —both important in glasshouse IPM programmes. Orius insidiosus also predates Helicoverpa zea (cotton bollworm), as does Geocoris punctipes. Endosulfan is toxic to both of

62 UNEP/POPS/POPRC.6/INF/24 these predators, but more so to females of the latter species, and it reduces fecundity and consumption of bollworm eggs by both predators.cxxv Endosulfan is toxic to the predacious mite Phytoseiulus persimilis, which predates spider mites and is very important in IPM programmes. It reduces the number of females laying eggs and the number of eggs that hatch.cxxvi Endosulfan is highly toxic to the eggs and larvae of Chrysoperla externa, a lacewing that predates mites and so is a valuable biological control species.cxxvii It also reduces prey consumption and web building of the spider Araneus pratensis, an important predator of agricultural pests such as midges, and an indicator of ecosystem disturbance.cxxviii Endosulfan significantly reduced the development of the ‘entomopathogenic’ fungus, Verticillium lecanii (Zimm.)—a fungus used in some IPM programmes to kill insect pests such as aphids, thrips and whitefly.cxxix Canada has mandated that labels of endosulfan products sold in that country bear the statement: “TOXIC to certain beneficial insects. Minimize spray drift to reduce harmful effects on beneficial insects in habitats next to the application site such as hedgerows and woodland.”cxxx Soil health Endosulfan reduces the ability of soil microorganisms to recycle nutrients and to fix nitrogen and maintain soil fertility and structure, and therefore it has an adverse effect on soil health and productivity. It is highly toxic to earthworms, and ‘normal use’ of endosulfan could significantly reduce populations of earthworms in agricultural soils.cxxxi Endosulfan treatment of cotton fields in India resulted in a 60.5% decrease in the population of actinomycetes 10 days after treatment.cxxxii Actinomycetes are beneficial bacteria that play a vital role in replenishing the supply of nutrients in the soil: they help with the decomposition of organic matter and the formation of humus, particularly by breaking down cellulose and chitin. They also help non-leguminous plants fix nitrogen. Endosulfan is also toxic to major groups of beneficial small soil invertebrates, mites and springtails, causing a persistent decline in populations. These invertebrates are key to maintaining soil fertility and mixing the organic and mineral components of soil.cxxxiii Resistance management The US EPA concluded that “endosulfan's current role in resistance management is minimal and that the loss of endosulfan will not result in adverse resistance management outcomes.”cxxxiv A significant number of pests are now resistant to endosulfan, reducing the benefits from its ability to kill insects. Resistance to endosulfan has developed in at least 28 species affecting at least 22 crops. The insects that have developed resistance include aphids, whitefly, mosquito, cotton bollworm, tobacco budworm, coffee berry borer, Colorado potato beetle, leafhoppers, midges, diamond-back moth, cutworms, and thrips. The crops include cotton, tobacco, coffee, cocoa, grape, grains, fruit such as pears, berry fruit, hazelnuts, sugarcane, and many vegetables.cxxxv

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Table: Reported Resistance to Endosulfancxxxvi

ISC Endosulfan is not harmful to the indispensible beneficial insects including the honeybee Farmers depend on honeybees for pollination of their corps. Honeybees pollinate more than 90 food, fiber and seed crops in the United States alone, valued at US $14.6 billion annually. Beneficial insects including honeybees feed on the flowering plants of many of the crops that rely on treatment with pesticides to combat the insects that compete with man for the fruits of the crops. There is a growing concern that the reduction in bee population in the world is due in part to the use of insecticides which are toxic to honeybees. As one current example of this concern, it was reported in Agro December 4, 2009 that the New Zealand Environmental RiskManagement Authority has issued draft data requirements to assess the risks of new pesticides to bees and other non- target invertebrates. Endosulfan is friendly to beneficial insects such as honey bees, bumble bees and beetles. The United States Environmental Protection Agency (EPA) states in its Re-registration Eligibility Decision (RED) document of 2002 that “Endosulfan is an important resistance management tool and is an important element of integrated pest management programs in some areas especially considering its relatively low impacts on bees.” This is in contrast to many of the other pesticides used to combat the same target pests including: neonicotinoides, pyrethroids, and organic phosphates, which are toxic to honeybees. This is an indispensable property of endosulfan in times when the Colony Collapse Disorder (CCD) is spreading over the world. Honeybees are important not only in agriculture for pollination but also in the production of honey, beeswax and many other products for consumer use, which is very important to the economies of many countries. Among the major honey producing countries are the United States, China, Argentina, Hungry, Bulgaria, Romania, Greece, Turkey, Brazil, India,Vietnam, and the UK. Farmers support the use of endosulfan Farmers communicate periodically with the governments of the world in support of endosulfan. Such a communication took place in 2009 with over 3000 farmers signing a petition to the government of Brazil in support of endosulfan.

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New registered uses of endosulfan Endosulfan, with its proven and long record of safe and reliable use, is still positioned as a good candidate for new applications. In 2006, a new use for endosulfan was registered in the United States in ear tags. This new product is viewed as the most significant insecticide ear tag introduced in the last 20 years. Sold under the “Avenger,” brand name, this Endosulfan based ear tag will protect cattle and dairy cows from flies and other pests all season. This endosulfan containing ear tag is registered for both cattle and dairy cows and is significantly bolstering the growth of the ear tag market. Importance of endosulfan in some major applications The importance of endosulfan in cotton production The cultivation of cotton is certainly more expensive than other major crops, since it requires a heavy investment in exclusive machines, logistics and in pest control. This is the case because of cotton’s increased susceptibility to disease and pest, especially in the early stage of its growth. The boll weevil (Anthonomus grandis) can cause, at any time of cultivation, losses of up to 70% of production of cotton. Of the products used in its control, endosulfan is the most important, considering that the crop protection products based on malathion and methyl parathion have lower selectivity and low efficiency. The use of pyrethroid based insecticides, which has low selectivity to natural enemies, is not recommended in cotton before the crop is 80 days old, which can result in an unacceptable mite population. While endosulfan is being used specifically against the boll weevil, due to it being a broad spectrum insecticide, it is also effective in controlling other important pests as the leaf worm (Alabama argillacea), apples caterpillar (Heliothis virescens, Helicoverpa zea), mite (Polyphagotarsonemus latus) and aphid (Aphis gossypii). As the result of this, endosulfan is vital to control the boll weevil and other secondary insects, especially in the first 80 days of the crop’s growth. Consequently, if endosulfan is not available for use as part of the IPM for cotton, production will be severely impaired, as the boll weevil becomes resistant to existing products. The state government of Parana, EMBRAPA and the Foundation for Support of Agricultural Research of Mato Grosso and House of Cotton Sector project such catastrophic effects. The importance of endosulfan for cane sugar. The main pest that plagues the sugar cane crop is the beetle Migdolus (Migdolus fryanus). The losses caused by this pest may restrict production to a few tons of cane per hectare. In most cases in which the control is inadequate, the loss is of the entire crop, which requires replanting the crop. The difficulty of fighting Migdolus lies in the fact that it is not possible to be aware of where it is in its life cycle or to accurately predict its appearance in a given area. This is coupled with the fact that adults spend part of their life at great depths in the soil (2 to 5 meters), which provides this insect substantial protection to traditional measures of treatment 4. Experience indicates that the use of insecticides based on endosulfan is the best way to control the Migdolus, providing increased production of 19 metric tons per hectare. If endosulfan is removed from the market, the only replacement products will be based on fipronil, to which insects build resistance. This concern is highlighted by Cosan: "Endosulfan has a mode of action that differentiates it from other products such as organophosphates, carbamates, and pyrethroids. Fipronil is protected by patent, and is supplied by a single supplier and would represent an increase of 268% in cost per hectare treated. For these reasons endosulfan is an important tool in management programs resistance to insecticides, since it helps in preventing emergence of resistance to other classes of insecticides. These data lead to the unwavering conclusion that the maintenance of the IPM of cane sugar depends on the availability of endosulfan on the market, with its unavailability will, on the other hand, result in a significant increase in the cost of production. The importance of endosulfan for soybeans. The soybean crop is subject throughout its cycle by the attack of different species of insects and IPM is needed to maintain its population within acceptable levels. Among the main pest affecting soybeans are the caterpillar (Anticarsia gemmatalis), the Brown Stink Bug (Euschistusheros), Southern Green Stink Bug (Nezara viridula) and the Small Green Stink Bug (Piezodorus guildinni). They cause quantitative and qualitative losses because they suck the grain, reducing them or changing the amount of oil and protein according to Crébio Jose Avila, entomologist and researcher at Embrapa (Dourados- MS), a unit of Empresa Brasileira de Pesquisa Agropecuaria-Embrapa, under the Ministry of Agriculture, Livestock and Supply. Stink bug control on soybean is mostly accomplished by organophosphate based products (including pyrethroids

65 UNEP/POPS/POPRC.6/INF/24 and neonicotinoids) and endosulfan. It has been reported, however, that the exclusive use of organophosphates in some regions of Brazil led to the unsuccessful control of the bugs. The most likely explanation of this is the development of resistant populations, due to lack of rotation with endosulfan, which possess distinct mechanism of action and high selectivity to natural enemies and, as is common knowledge, does not generate resistance. The need for endosulfan as part of the IPM for soybean has been highlighted by the Association of Soy Producers of Mato Grosso -- APROSOJA: "Especially with its unique mode of action, selectivity to natural enemies, endosulfan has been a key tool for Integrated Pest Management (IPM) and programs Handling Resistance. Endosulfan is the ideal product for species difficult to control such as Helicoperva armigera and whitefly cotton culture in which there is already resistance to insects to other groups of insecticides in Europe. In this context, endosulfan is of fundamental importance to maintain the IPM used in the plantation, so as to avoid the development of resistance of the pests to available organophosphates. Also it is important to provide resources to farmers to maintain the economic viability of their production. At present, soybean uses at least 50% of the commercialized endosulfan in Argentina. It is widely used in this crop against Himenópteros, Pentatómidos (bugs) and Lepidópteros (caterpillars) attacks. It is used alone or, in some cases, mixed with other products to reach a broader spectrum. It is the product of choice because target insects do not build resistance to it, its lower cost, and its lack of adverse effects on beneficial insects. The possible alternatives are mainly pyrethroids and organophosphate used individually which suffer from a narrower spectrum of action, the insects build resistance to it, higher prices and a significant effect on beneficial insects. The importance of endosulfan for Sunflower The Sunflower crop is subject throughout its growing season to attack by Rachiplusia nu, which is the most harmful pest in Sunflower due to the high insect pressure in all the sunflower areas. The effective control of this Lepidoptera pest for the protection from high foliar damage that happens in only a few days is through use of an IPM containing endosulfan. The importance of endosulfan for coffee The coffee berry borer (Hypothenemus hampei) is considered a key pest of the coffee crop in the main areas where coffee is grown in the world, attacking fruit at any stage of maturation, from green to dry. The males are smaller than females, have rudimentary hind wings (membranous), consequently they do not fly and never leave fruit from which they came. They attack young fruits resulting in losses in yield. (RuralMagazine, Ed No. 119, Jan. 2008). The only insecticides that satisfactorily control the coffee borer are those which are based on endosulfan, the products with the active ingredient chlorpyrifos fail to provide the necessary control, and increase the production costs by 64%. This dependence of coffee production on endosulfan is well illustrated by the statement of Regional Cooperative of Coffee Growers of São Sebastião do Paraíso - Cooparaiso. This cooperative is one of the largest coffee producer cooperatives in Brazil, working directly in 72 municipalities. The producers are mostly small and mini growers and their properties have an average area of 11.92 hectares. Coffee, its main product, is responsible for 58% of their revenue. This region has a coffee area of 340 thousand hectares, which produces an average annual 5.2 million 60-kg bags of coffee. Composed of 5,500 associates, the cooperative makes the following statement: "Among the major pests in coffee is the fruit borer (Hypothenemus hampei). It causes large losses in the quality of green coffee, which results in loss of quality of the final product. Of the pesticides registered for use in the coffee crop, the only one that has efficacy in controlling this pest is the active ingredient endosulfan. Not having any other insecticide that might replace it, if its registration is cancelled, it will cause significant losses to the Brazilian coffee industry.". If the coffee berry borer can not be controlled by the farmer, the low productivity as the result of agricultural pest makes coffee growing economically unviable. It is no coincidence that more than 3,000 coffee farmers signed a petition, which was strongly against a ban on endosulfan. It should be remembered that Brazil is the world’s largest producer and exporter of coffee and ranks second in the consumer market. In addition, Brazil has also started to capture the world’s market of high quality roasted coffee beans and ground coffee. Even if it were economically feasible to treat the coffee berry borer with the alternatives to endosulfan, such as those with the active ingredient chlorpyrifos, the low efficiency of these products would require much larger applications of pesticides. This could lead to an increase in the exposure of the population and the environment. The simple withdrawal of a product may not result in improved toxicological efficiency. On the contrary, it could lead to the use of another product agriculturally less efficient, with greater impacts on human health and the environment. Hazel nuts Endosulfan is a product of necessity for the protection of certain crops. In Italy, where the use of endosulfan ceased in 2005, a problem developed in the hazelnut that threatened the crop as the result of mite infestation. Italy is the second largest

66 UNEP/POPS/POPRC.6/INF/24 producer of hazelnuts in the world with approximately 100,000 tons of production annually. Although Italian hazelnuts are exported around the world, the main use outside Italy is Germany, France and Switzerland. In order to protect the hazelnut crop from certain types of mites, Italian growers successfully argued for and obtained a special exemption for endosulfan use in the EU. The hazelnut producers received the special exemption because endosulfan is the only insecticide that is both effective in controlling the mites that attack hazelnuts and is also safe for the crop. (iii) Biota (biodiversity) Australia As mentioned at (i) the Department of the Environment, Water, Heritage and the Arts is finalising a review for the APVMA of the environmental risks posed by the continuing use of endosulfan in Australia. The results of this review are not yet available. Bulgaria Not assessed in Bulgaria Costa Rica La biota en general se vería menos expuesta a compuestos orgánicos persistentes; podrían haber recuperaciones de poblaciones naturales, aumentando la biodiversidad. (Ramírez F. RAPAL Costa Rica) Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Switzerland Not known as not studied for endosulfan. Togo No data collected. United States of America Likely positive; however, the magnitude of impact will depend on the specific control measures taken. Also, multiple alternative insecticides may be required in certain cases which may have some associated negative impacts. IPEN Endosulfan is a broad spectrum insecticide with toxic effects on all classes of biota. Its toxicity to insects is likely to lead to reduced biodiversity in areas where it is used. The elimination of endosulfan, and its replacement with less toxic products and management methods, will have a positive effect on biota and biodiversity. Canada has mandated that labels of endosulfan products sold in that country bear the statement:

“TOXIC to aquatic organisms, birds, and small wild mammals.”cxxxvii ISC Endosulfan is not harmful to the indispensible beneficial insects including the honeybee Farmers depend on honeybees for pollination of their corps. Honeybees pollinate more than 90 food, fiber and seed crops in the United States alone, valued at US $14.6 billion annually. Beneficial insects including honeybees feed on the flowering plants of many of the crops that rely on treatment with pesticides to combat the insects that compete with man for the fruits of the crops. There is a growing concern that the reduction in bee population in the world is due in part to the use of insecticides which are toxic to honeybees. As one current example of this concern, it was reported in Agro December 4, 2009 that the New Zealand Environmental RiskManagement Authority has issued draft data requirements to assess the risks of new pesticides to bees and other non- target invertebrates. Endosulfan is friendly to beneficial insects such as honey bees, bumble bees and beetles.

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The United States Environmental Protection Agency (EPA) states in its Re-registration Eligibility Decision (RED) document of 2002 that “Endosulfan is an important resistance management tool and is an important element of integrated pest management programs in some areas especially considering its relatively low impacts on bees.” This is in contrast to many of the other pesticides used to combat the same target pests including: neonicotinoides, pyrethroids, and organic phosphates, which are toxic to honeybees. This is an indispensable property of endosulfan in times when the Colony Collapse Disorder (CCD) is spreading over the world. Honeybees are important not only in agriculture for pollination but also in the production of honey, beeswax and many other products for consumer use, which is very important to the economies of many countries. Among the major honey producing countries are the United States, China, Argentina, Hungry, Bulgaria, Romania, Greece, Turkey, Brazil, India,Vietnam, and the UK. (iv) Economic aspects Australia Loss of control of fruit spotting bug on crops for which no alternatives exist would cause economic loss. Brazil Endosulfan has been used for more that 50 years as a pesticide. Approximately 40% of the world production of endosulfan active ingredient is used in Brazil. Endosulfan provides the economy with an influx of more than one hundred million dollars per annum (Source: Sindicato Nacional da Indústria de Produtos para Defesa Agrícola – SINDAG). Brazil does not stand alone in its dependence on the availability of endosulfan. Endosulfan is among the five best selling insecticides in the world. Countries with more than 70% of the food producing farm land in the world uses endosulfan. Among these are India, Brazil, Argentina, China, Australia, the United States, and some African countries. Bulgaria Not assessed in Bulgaria China Since a mature production chain of endosulfan technical, its intermediates and preparation has been formed, once the production and use of endosulfan is banned, this industry chain will be impacted with idle production facilities, thus causing adverse impacts on the whole industry. Costa Rica La prohibición del endosulfan no afectaría economicamente las producciónes, ya que existen alternativas econimicamente viable para cada uso. (Ramírez F. RAPAL Costa Rica) India Endosulfan being cheaper, use of other alternatives may affect cost of production. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Madagascar Eventually increase of production costs. Switzerland Not known as not studied for endosulfan. Togo Not yet analysed. United States of America Potential negative impacts on consumers. See Sec. B(iii) of this form. Will be crop-specific and depend on control measures taken.

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IPEN Cost competitive alternatives that do not exhibit POPs characteristics have already been implemented in many countries, covering all known uses of endosulfan. The economic aspects of substituting alternatives for endosulfan include the savings made on health and environmental costs resulting from exposure to endosulfan, and improved incomes for those no longer using endosulfan. Health costs of endosulfan As referred to earlier in this document, in Section A(iii), although there is no meaningful way of measuring costs to human health and the environment from ongoing endosulfan use, some idea of the costs of medical care for exposed people can be drawn from the remediation efforts being undertaken by the State Government of Kerala, India, for victims of endosulfan poisoning resulting from aerial spraying of cashew nut plantations. The initial amount allocated by the State Government was Rs 50 lakh (US $10,806) for costs such as health surveys and medical camps, wheel chairs, spectacles, hearing aids, surgical care treatment of cleft lips and palates and bone deformities, medicines for seizure and psychiatric conditions, and solatium for 300 families of deceased victims.cxxxviii,cxxxix However about 2,000 more patients were reported to require advanced medical care and rehabilitation, and voluntary aid by the organisation Solidarity has provided a further Rs 45 lakh (US $9,725), with their second phase projected to cost another Rs 50 lakh (US $10,806).cxl This total of US $31,337 cannot be expected to represent the total cost of medical care resulting from this incident and it does not include any environmental costs or take into account the cost of human suffering. Whilst 500 deaths have been officially acknowledged, unofficial estimates place the figure at around 4,000. More than 9,000 people arereported to have health problems resulting from the exposure to endosulfan in Kerala.cxli The costs not covered by the figures above include the solatium for many families of deceased victims, modification of homes so that wheelchairs can be used, special education and home care for those with birth defects, medical care and rehabilitation for about another 2,000 people, greater likelihood of developing chronic diseases, loss of ability to earn income for victims and their caregivers, loss of enjoyment of life and loss of dignity, environmental remediation (soil and water), loss of biodiversity, loss of livestock, loss of agricultural productivity. In mid December 2009, the State Government of Kerala agreed to further relief and remediation measures for 1,966 endosulfan victims identified by the Health Department (103 are severe cases), although at this point the cost has not been specified (the State Cabinet approved Rs. 125 lakh—US $27,015— just for modernisation of hospitals and improved medical facilitiescxlii). The further measures include: - a special ward at the Kasargod General Hospital - mobile vans for medical assistance - pension of Rs. 250 per month for those who are disabled - a payment of Rs. 250 per month for caregivers of those with severe handicap.cxliii The government also agreed to the continuation of the Rs. 50,000 solatium for each of the families of deceased victims.cxliv Surgery for the 1996 victims is projected to cost between Rs. 10,000 and 40,000. The Social Security Mission is also planning to provide free surgeries for children below 18 years of age suffering from heart disease, cerebral palsy, renal disease and neurological problems.cxlv There is no real way to add up all these costs, especially those such as loss of enjoyment of life, and death. However, the data indicate substantial economic costs and human suffering even in this relatively small area within a single state and country. Extrapolating to a global context, the total costs to human health and the environment from the use of endosulfan are inestimable but can be judged to be very, very high. Even within India, another state (Karnataka) is now proposing to compensate at least 137 endosulfan victims.cxlvi Many deaths and acute poisonings have been known to occur in other Asian, African and Latin American countries, but the real number of victims of endosulfan has not been fully recorded. Improved incomes for those no longer using endosulfan Studies have shown that the rural poor in developing countries can increase their income through the substitution of endosulfan by alternatives products and practices. For example, Community Managed Sustainable Agriculture (CMSA) practised on 5.1 % of cropland in Andra Pradesh, India, achieved “a significant net increase in farmers’ incomes in addition to significant health and ecological benefits”, without “significantly reducing the productivity and yields”. These farmers replaced endosulfan and all other chemical pesticides with a variety of non-pesticide methods of pest management. A survey of 141 of the CMSA farmers found the costs of cultivation to be only 33 % of the costs under conventional production. A state-wide survey found these farmers are making the following average savings on the cost of cultivation, per acre, per year:

69 UNEP/POPS/POPRC.6/INF/24 rice = US $20 chilli = US $300 cotton = US $100 groundnut = US $16 red gram = US $24 others (fruit, vegetables, cereals) = US $20 Based on the savings made by individual farmers, the state-wide estimate of cumulative savings made by farmers practising CMSA is US $38.6 million for the year 2008-09.cxlvii ISC Importance of food supply for a growing population with limited crop land The world, with a current population of approximately 6,700,000,000 people and expected to grow to 9,200,000,000 by 2050, is dependant on an adequate food supply to avoid hunger, starvation and the health problems associated with malnutrition, which are among the basic elements for the preservation of peace and tranquility. With limited land available for the production of food crops, it is necessary to optimize the efficiency of food production on this available land. Endosulfan aids in fulfilling this need The wide use of endosulfan based pesticides is strongly associated with its characteristic of being a broad spectrum insecticide, its excellent efficacy and selectivity to natural enemies, the lack of resistance of insects to it and its lack of adverse impact on pollinating insects including the honey bee. In addition to these characteristics it is a product of choice because of its lower cost of treatment than products being sold for the same purposes. All of these factors work together to provide: an economic food supply to the population and economic benefit to the grower and the countries in which it is used. (v) Movement towards sustainable development Bulgaria Not assessed in Bulgaria. Costa Rica La prohibición del endosulfan sería un paso más en la búsqueda de una producción sostenible a future. Es necesario dejar de ursarlo para disminuir las consecuencias ambientales a largo plazo. (Ramírez F. RAPAL Costa Rica) Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Switzerland Not known as not studied for endosulfan. Togo Using a chemical to remplace another chemical is not an innovative approach that would promote sutainalbe agriculture. IPEN Elimination of endosulfan is consistent with sustainable development plans that seek to reduce emissions of toxic chemicals. A relevant global plan is the Strategic Approach to International Chemicals Management (SAICM) that emerged from the World Summit on Sustainable Development.cxlviii Over 100 health and environment ministers agreed to the SAICM, which was adopted at a high-level meeting in Dubai in February 2006.cxlix SAICM makes the essential link between chemical safety, sustainable development, and poverty reduction.cl The Global Plan of Action of SAICM contains specific measures to support risk reduction that include prioritizing safe and effective alternatives for persistent, bioaccumulative, and toxic substances.

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The Overarching Policy Strategy of SAICM includes POPs as a class of chemicals to be prioritized for halting production and use and substitution with safer substitutes. Additionally, the FAO has agreed to facilitate the phase out of Highly Hazardous Pesticides,cli the definition of which includes those pesticides, such as endosulfan, that are deemed to be POPs.clii (vi) Social costs Bulgaria Not assessed in Bulgaria. China May cause social issues such as job loss for workers. Costa Rica Se gastaría menos en salud por efecto de enfermedades crónicas, menos intoxicados, mejor esperanza de vida, etc. (Ramírez F. RAPAL Costa Rica) India See Annexure-I. Lithuania Remark to a, b, c tables/questions: As far as there were no national risk evaluations conducted in Lithuania no recommendations for the risk management and introduction of alternatives were dveloped. Switzerland Not known as not studied for endosulfan. Togo Not yet analysed. IPEN There should be few social costs associated with the elimination of endosulfan because there is wide spread availability of safer products and practices. Costs may be incurred in training farmers used to using endosulfan in the adoption of agroecological methods. Societal benefits will include reduced human health effects and environmental contamination resulting from exposure to and emissions of endosulfan. In Andra Pradesh, India, the estimated prevalence of indebtness among conventional farmer households in the state was 82%, with income being insufficient to meet associated expenditure. However, for those who practiced Community Managed Sustainable Agriculture, in which endosulfan and other synthetic chemicals pesticides were replaced with non-chemical methods, household incomes and food security have improved; debt and mortgage loads have reduced and land ownership been retrieved; pesticide related health problems eliminated; soil ecology has improved, and water contamination diminished; and beneficial insects and birds have returned.cliii

(d) Waste and disposal implications (in particular, obsolete stocks of pesticides and clean‑up of contaminated sites) (i) Technical feasibility Australia Waste or disposal implications are unknown at this stage. Brazil Incineration at 900ºC, with a flux of 300 kg/hour. Bulgaria Adequate facility for final disposal or destruction of available obsolete pesticide stockpiles is not available in Bulgaria. Endosulfan, containing pesticides were not identified during annually conducted inventories in Bulgaria.

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Costa Rica No hay viabilidad técnica para limpiar sitios asperjados con endosulfan. India Disposal of obsolete/date expired pesticides is a problem for all pesticides. Lithuania Lithuania has developed an Action Plan as part of National Implementation Programme called for in Article 7 of the Stockholm Convention, Article 8 of the Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants (hereinafter – Action Plan of NIP). The measures provided in the Action Plan aimed at minimising sources of pollutants, reducing the emission to the environment of unintentional POP. One of the measures is dedicated to manage obsolete pesticides including POPs pesticide, to collect, store, decontaminate and/or dispose of PCB containing oil and equipment. In Lithuania (like in the all European Community) it is prohibited to place on the market and use plant protection products containing POPs listed in the Stockholm Convention and endosulfan as well. Therefore it is unlikely to expect accumulation of new stockpiles of pesticides containing POPs (including endosulfan). One of the most sensitive problems in Lithuania was management of old pesticide stockpiles. There is no data on pesticides containing endosulfan stockpiles. We can provide only general information on management of pesticide waste. The Governmental Pesticide Waste Management Programme for 2002-2005 has been implemented. In total during the period of 2002-2005 year 3280 tons of old pesticides have been disposed. The rest part of stockpiles of pesticide waste which have not been included in the Government pesticide waste management programme will be managed using funds allocated according to the Strategy of Cohesion Fund, approved by Decree No. 1K-054/D1-79/3-99 of February 2004 of the Finance Minister, the Minister of Environment and the Minister of Transport. The European Commission by Decision of 29 June 2006 allocated 3800 thousand EUR for management/disposal of pesticide waste according to the Project „Dangerous Waste Management in Lithuania“ (among them 1026 thousand EUR from the Budget of the Republic of Lithuania and Litas 2774 thousand EUR from EU Cohesion Fund). Unused pesticides were stored for many years, thus problem of their safe storage and pollution of the territories around the storage depots emerged. The storage depots were found throughout Lithuania on former sites of collective farms next to lakes and rivers, in vulnerable places from the environmental pollution point of view. According to the Action Plan of NIP the Programme for the Management of the Pesticide Waste Landfills and Contaminated Sites for 2007-2013 has been developed (adopted by Governmental Decision of 350 on 4 April 2007). The European Commission by Decision of 29 June 2006 allocated 5500 thousand EUR for management of contaminated sites according to the Project „Dangerous Waste Management in Lithuania“ (among them 1485 thousand EUR from the Budget of the Republic of Lithuania and 4015 thousand EUR from EU Cohesion Fund). During period from 17-07-2008 till 03-06-2009 in total it was transported 2 220 764 kg (bruto weight) pesticide waste to SAVA GmbH&Co.KG incineration plant in Germany. During period from 18-08-2008 till 04-06-2009 in total it was transported 5630 m3 contaminated soil with the pesticide waste to KNAPSAX disposal facility in Germany or BAO recovery facility in Latvia. The 29 warehouses of old pesticides have been cleaned. Note: There is no data on pesticides containing endosulfan stockpiles. We have provided only general information on management of pesticide waste (see Table (d) above). Madagascar No information available on eventual stockpiles. To mention, there does not exist any local infrastructure for realisation of destruction of eventual stockpiles. Malaysia Confiscated products are disposed through licensed toxic waste disposal operator. The disposal is in accordance to legal requirements. Sri Lanka No obsolete stocks at present.

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Togo Endosulfan was not included in POP pesticides inventory during the initial enabling activities. Information on eventual stockpile is to be collected using the well known FAO inventory methodology. Ukraine Not available in the national inventory of obsolete pesticides (Ministry of Environmental Protection, Ministry of Agrarian Policy, Ministry of Health Protection) United States of America Discarded endosulfan is regulated by USEPA as hazardous waste. IPEN Endosulfan use has been declining in most countries in recent years, so stocks of obsolete product, whilst they will exist, should not be large in comparison with stockpiles of some other obsolete POPs (such as HCH). However the countries that still manufacture endosulfan may have considerable stockpiles to manage. (ii) Costs Australia Unknown at this stage. Bulgaria The required funds for the construction of National Centre for threatment, disposal or destruction of hazardous wastes for the period 2010 – 2013 are amounting approximately to 60 000 000 US $, planned to be invested, according National Waste Management Programme 2009-2013. India Very high costs. State of art facilities need to be developed. Lithuania See (i). Malaysia The cost of disposal borne by the government is about USD 1085/ton. Switzerland Unknown. Togo Financial support is a constant need. United States of America Minimal incremental costs associated with the disposal of endosulfan. (e) Access to information and public Australia Product labels as well as information materials provided by State departments, e.g.: Information examples: http://www2.dpi.qld.gov.au/horticulture/5522.html http://www2.dpi.qld.gov.au/horticulture/5107.html http://www2.dpi.qld.gov.au/horticulture/5348.html http://www2.dpi.qld.gov.au/horticulture/5427.html

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Label examples: http://www2.dpi.qld.gov.au/extra/asp/infopest/nra/labels.asp?prodcode=32799 http://www2.dpi.qld.gov.au/extra/asp/infopest/nra/labels.asp?prodcode=45838 http://www2.dpi.qld.gov.au/extra/asp/infopest/nra/labels.asp?prodcode=50004 http://www2.dpi.qld.gov.au/extra/asp/infopest/nra/labels.asp?prodcode=52163 Brazil Label recommendations present information relative to use precautions and orientations about care to protect environment and human health; procedures for cleaning, storage, return, transport and fate of used pesticide containers and waste material of products unsuitable for use or obsolete. Bulgaria Information system for prohibited and obsolete pesticides, including annually updated data for quantities, and storage sites are in place for Bulgaria. The information is collected annually by Regional Inspectorates for Environment and Water (RIEW) using information cards, and is submitted to the Executive Environmental Agency (EEA) of MOEW for summarizing and analysis through special software programme. From 2009 on the Executive Environmental Agency web page http://nfp-bg.eionet.eu.int , a public access is available for the the prohibited and obsolete pesticide data base for the years 2007 and 2008. Canada Published documents available at http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_decisions/index-eng.php#revnote include: REV2007-13 Preliminary Risk and Value Assessment of Endosulfan REV2009-03 Re-evaluation of Endosulfan Interim Mitigation Measures REV2009-09 Endosulfan Costa Rica Existe conocimiento sobre las restriciones del endosulfan, pero no siempre son acatadas, tanto por mantener reservas de años anteriores como por falta de fiscalización del cumplimiento de esas medidas. India Farmers are being trained and educated through integrated pest management programme. Lithuania The previously mentioned NIP’s Action Plan (as part of National Implementation Programme on persistent organic pollutants management) includes inter alia: Public awareness and education on the adverse effect of POPs on health and environment and on the opportunities of reduction of their release. Aim of the action plan: 1) to provide information on POPs, their negative impact on health and environment, their formation and accumulation in the environment, possible impact to the Lithuanian society and to interested groups and organizations; 2) to ensure the active participation of the public in the process of developing of environment policy; 3) to inform general public about POPs with the help of all efficient ways of information dissemination and education, and in close cooperation between state, municipality institutions and non-governmental organizations. The publications for different interested groups have been prepared and published. These publications provide information in a friendly and understandable manner to all concerned groups and associated with POPs features, impact on human health, detection in the environment surrounding us, possible methods to identify equipment polluted with PCB, preventive and other POPs management measures, control of dioxin and furan emissions into the environment, solution of related problems in Lithuania, the European Union and internationally. Information material on the environmental and human health impact of POPs has been prepared and disseminated. This info was aimed -

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- at the prevention of POPs formation; - to inform the public and other stakeholders regarding POPs generation potential, features, harm to human health and the environment, distribution in the natural environment, identified quantities in foodstuffs. The education of the general public took place not only by providing information about POPs and its environmental and health impact, but also on the ways and means of contributing to POPs pollution reduction with particular attention given to prevention of incineration of domestic waste. The seminars on POPs to the public and other stakeholders, special seminars on PCBs – to the enterprises were organised in 8 regions of the country. It should be noted that that the awareness raising activities (publications, seminars, etc.) were focussed on POPs currently listed in the Stockholm Convention. Link to the information on POPs at the website of the Lithuanian Misnistry of Environment: http://www.am.lt/VI/index.php#a/5494 Remark: awareness raising activities (publications, seminars, etc.) were focussed on POPs currently listed in the Stockholm Convention. Madagascar Information access and public training insufficient because of minimal data availability; notably in socially disadvantaged population (cottonfield workers). Insufficient equality in further knowledge about usage of products. Malaysia Information regarding the control measures and alternatives could be obtained at Department of Agriculture Office through out the country. Monaco The control measures and alternatives have not been hitherto the subject of information and public education. Poland Access to information is provided by the information point located in the Institute of Environmental Protection and it’s website http://ks.ios.edu.pl/, which is being updated recently. Switzerland A public database on all plant protection products registered in Switzerland is available in German (http://www.blw.admin.ch/psm/produkte/index.html?lang=de), French (http://www.blw.admin.ch/psm/produkte/index.html?lang=fr) and Italian (http://www.blw.admin.ch/psm/produkte/index.html?lang=it)

An information and consultation system also exists for farmers, run by state agencies and / or plant protection product companies. Togo The current impoters and users of Endosulfan and alternatives are all well informed of the process under way to phase out Endosulfan. Ukraine Free access to information available on the web-site of the Ministry of Environmental Protection www.menr.gov.ua United States of America Various government and public and private institutions provide information on current alternatives to endosulfan. US EPA registered products have labels with information regarding required control measures.

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IPEN Listing endosulfan in Annex A will involve control measures that are straight forward to communicate and therefore should be effective and suitable, even in countries that have limited chemical regulatory infrastructure. Information on alternatives is readily available, and can be easily disseminated as needed. (f) Status of control and monitoring Australia National - Agricultural and Veterinary Chemicals Code Act 1994cliv, Agricultural and Veterinary Chemicals Code Regulations 1995clv Details for compliance with requirements for supply of endosulfan products by Australian retailers can be found on the APVMA websiteclvi. Queensland - Chemical Usage (Agricultural and Veterinary) Control Act 1988, Chemical Usage (Agricultural and Veterinary) Control Regulation 1999, Agricultural Chemicals Distribution Control Act 1966, Agricultural Chemicals Distribution Control Regulation 1998. Part 4 of the Chemical Usage (Agricultural and Veterinary ) Control Regulations provides for specific controls over the use of Restricted Chemical Products (RCP). For RCPs containing endosulfan, the user must be authorised to use the product or hold a commercial operators licence or hold a pilot chemical rating licence or accreditations from ChemCert/Farmcare/QACAC. (Authorised means authorised to use the product under an approved label or a permit for the product.) Northern Territory – Agricultural and Veterinary Chemicals (Control of Use) Act 2004clvii, Agricultural and Veterinary Chemicals (Control of Use) Regulations 2007clviii Control is at the point of sale where supply is restricted to persons specifically identified by the label or permit. Where the APVMA does not specifically identify the person, the Chemicals Coordinator will authorise the person. If the RCP is scheduled as an S7 chemical, then additional authorisation is required in addition to that stipulated on the label. New South Wales - Pesticides Act 1999 – Pesticide control order (under section 38): pesticide control (endosulfan) order (no. 2) 2000clix. Tasmania – Restrictions applying under the various provisions of the Agricultural and Veterinary Chemicals (Control of Use) Act 1995, Agvet Code Act 1994 and Poisons Act 1971. Restrictions and control of use are summarised on the Tasmanian Department of Primary Industries, parks and wildlife webpageclx. Brazil The registrant companies carried out two environmental monitoring studies demanded by the Brazilian environmental authority. One of them was performed in cotton and soybean crops in Aguaí (São Paulo state) and Cornélio Procópio (Paraná state), respectively. The other one was carried out in a 43,56 hectares (equals 107,64 acres) area in the Campinas City region (São Paulo state) with 89% cotton crop and the remaining area with a water body and surrounding vegetation. Both studies showed the need for a separation buffer of 40m (first study) and 100m (second study), corresponding to the minimal distance to protect the available water bodies. It is worth noting that the Brazilian recommendations in these product labels establishes the minimum distance of 250m from water sources. Bulgaria Monitoring is in place in Bulgaria, including suitable laboratory and monitoring capability – 15 accredited Regional laboratories within MOEW for monitoring of land and surface and ground water. - National System for monitoring of Surface Water Endosulfan is monitored in surface waters at 19 points spread allover the country with monthly sampling frequency from 2008 omwards.Analysis is done by MOEW Regional laboratories. In most cases the values found were under the minimum limit of determination (MDL) and in occasional cases the values were found to be under the threshold of contamination. Thus it can be concluded that in Bulgaria there are no surface water contaminated with Endosulfan.

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- National Network for Monitoring of ground water The National Network for monitoring of groundwater established with Order N0 RD-867/29.11.2007 consists of 290 points for control and 82 points for operative monitoring of groundwater, split within the four Basin Directorates of MOEW. The specific pollutants in groundwater measured are the following organic substances – trichlorethylene, tetrachlorethylene, aldrin, atrazine, DDT/DDD/DDE, dieldrine, drini, endosulfan, emdrin, metoxychlor, HCH – compounds, propazine, simazine, heptachlor, chlordane, 2,4 D, acetochlor, pendimetalin, flutriafluor, triadimenol, mancozeb, tebuconazole, chlorpyrophos, trifluoraline, alachor, cypermetrhrin. For 2009, all monitoring data were below the minimal limit of determination (MDL) and pesticide’s concentration values are far below the groundwater quality standard of 0.1 μg/L. Thus it can be concluded that in Bulgaria there are no groundwater, contaminated with Endosulfan. - Reporting to the European Pollutant Release and Transfer Register of industrial and non-industrial releases into air, water, land and off-site transfers of waste water and waste including information from point and diffuse sources. Bulgaria as a EU Member state has also reported data for endosulfan releases in the European Pollutant Release and Transfer Register. None of the operators had reported industrial and non-industrial releases of Endosulfan into water, land for 2007 and 2008. Burundi Emergency Decree No 1/158 of 12/11/1971, Ministry of Finances (decret-loi n°1/158 du 12/11/1971, ministere des finances); Decree No 1/010 of 30/6/2000, Ministry of Environment (loi n°1/010 du 30/6/2000, ministere en charge de l´environnement) Canada Use of pesticides is regulated under the Pest Control Products Act in Canada. China Some universities and research institutes in China are capable of monitoring endosulfan. Costa Rica Muy poca vigilancia de las medidas de control recientes (restricción en cultivos y en forma de aplicación). (Ramírez F. RAPAL Costa Rica) India India has adequate infrastructure for promotion and implementation of plant protection programmes both at national and regional levels. Lithuania Legislation: Placing on the market and use of all plant protection products containing endosulfan is prohibited in the European Community (and in Lithuania). The chemical was excluded from Annex I to Council Directive 91/414/EEC concerning the placing of plant protection products on the market and authorisations for plant protection products thus had to be withdrawn by 2 June 2006 (Commission Decision 2005/864/EC of 2 December 2005 (OJ L 317, 3.12.2005, p. 25) concerning the non-inclusion of endosulfan in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing this active substance). Monitoring: State Environmental Monitoring Programme for 2005-2010 has been established and adopted (Decision of the Governmentof the Republic of Lithuania of 7 February 2005, No. 130). The Implementation plans for 2006, 2007, 2008 and 2009 (adopted by the Orders of the Minister of Environment) of the State environmental monitoring programme include monitoring of endosulfan in surface water (water, bottom sediments, biota). The monitoring is to be conducted by taking samples from Baltic Sea, interim water and certain rivers. It should be noted that depending on the measure of the monitoring plan the endosulfan, α-endosulfan or β-endosulfan will be monitored

77 UNEP/POPS/POPRC.6/INF/24 correspondingly. The monitoring of endosulfan and α-endosulfan in rivers’water started in 2005. The responsible authority is Center of Marine Research. Madagascar At the moment focused on registration and control of imports. Sporadic controls of the use of the products because of lack of technically educated manpower. No activities on surveillance and control of environmental contamination from residues of agricultural products because of defect analysis material and too high costs. Management plan established neither for the above mentioned nor for control of residues and danger resulting therefrom. Malaysia Endosulfan is controlled by Pesticides Act 1974. The Act is implemented and enforced by Pesticide Control Division, Department of Agriculture Malaysia. Its import, export, manufacture, sale, storage and use is under the purview of the Act. Environmental monitoring is carried out in order to monitor the presence of residue of pesticides (including endosulfan) in the environment and food crops. Based on the monitoring carried the presence of endosulfan in residue is reducing. Monaco The prohibition of this chemical is not subject to a legal instrument in Monaco. It is not subject to environmental and biological monitoring, too. Poland The use of endosulfan in biocides and pesticides is not permitted in Poland (it is not included on the list of active substances permited for use in pesticides and biocides products) – legislative act. The production, import and sale is controlled by competent staff (government authorities). Sri Lanka The alternatives are given in pesticides recommendation booklet year 1997, published by Department of Agriculture, Sri Lanka. Switzerland No specific framework for endosulfan exists. See information provided for Annex E (Submission by Switzerland, 9.1.2009). Togo The GMP has clearly indicated that almost all African LDCs including Togo do not have any significant technical infrastructure to undertake the monitoring of POPs in core matrices (human milk, human blood, ambient air). Some limited data contamination of other media (water, food, soil and sediments, etc.) were collected mainly from individual scientific papers. A harmonized regional monitoring programme on POPs and other persistent toxic substances is a major need for the Africa region. The UNEP/GEF capacity building for monitoring is a atrting step towards this objective. Ukraine The State Sanitary Rules and Norms 8.8.1.2.3.4-000-2001 (Ministry of Health Protection) set the following maximum residue limits for endosulfan: 0.1 mg/m3 – in the workplace (air); 0.02 mg/m3 – in the ambient air; 0.1 mg/kg – in soil; 0.1 mg/kg – in cotton seed; 0.05 mg/kg – in cotton oil; prohibited in cucumbers, currants, strawberries, tomatos. The State Sanitary and Epidemiological Service of Ukraine (SES) is in charge for the net of laboratories which provide the corresponding control measures under the above norms for foodstuff, plants, water and soils.

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Endosulfan is not included into the list of chemicals for regular monitoring within the state environmental monitoring system. The state enterprise “Ukrmetrteststandard” under the State Standartization Committee is certified for analytical measurements of α- and β-endosulfan in drinking, surface and sewage water – detection interval 1-10 ng/l (state certificate No. В 008-2009 of 23.02.2009). The Institute of Ecohygiene and Toxicology named by L.Medved (Ministry of Health Protection) is experienced in endosulfan analysis in food (inter-calibration study, Prodanchuk N.G. et al., 2004 – in Russian lang.) and water (Prodanchuk N.G. et al., 2007 - in Ukrainian lang). United States of America In the U.S., endosulfan is regulated under Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food Drug and Cosmetic Act (FFDCA), as amended by the Food Quality Protection Act (FQPA). Once discarded, endosulfan is regulated as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). Regarding monitoring capacity, the U.S. supports a number of monitoring programs for various chemicals, including endosulfan. In aquatic ecosytems, for example, these include (but are not limited to): the U.S. Geological Survey’s National Water Quality Assessment (NAWQA) program, EPA’s Environmental Monitoring and Assessment Program (EMAP), EPA’s National Sediment Inventory (NSI), in addition to numerous regional and State-level monitoring programs. US Food and Drug Administration (FDA), the US Department of Agriculture (USDA), and some States monitor endosulfan residues on domestic and imported commodities to ensure compliance with maximum residue limits. IPEN Listing endosulfan in Annex A would be the most cost effective option. With regard to environmental monitoring and bio- monitoring, endosulfan can be added to existing programmes for monitoring other POPS pesticides. Countries that lack the needed infrastructure to adequately monitor production and uses of endosulfan may require additional resources and infrastructure. (g) Any national or regional control actions already taken, including information on alternatives, and other relevant risk management information Australia The APVMA began a review of endosulfan in 1995 in response to public concerns over environmental impacts and possible trade risks from endosulfan residues in livestock as a result of spray drift from cotton and some other broad acre crops. In the course of the review, new data emerged and a number of measures and restrictions were implemented when the review was finalised in 2005clxi. There were changes to withholding periods and livestock feeding restraints; mandatory buffer zones for spraying were introduced; uses on beans, sweet corn and peas were removed; new label instructions were included to ensure worker safety and manage environmental risks; and mandatory neighbour notification and record keeping requirements were established. Most importantly, endosulfan was declared a Restricted Chemical Product only available to, and to be used by, persons with appropriate training. More details can be found on the APVMA websiteclxii. Brazil Label recommendations present the following information about harmful effects on the environment: - This product is highly persistent in the environment. - This product is highly bioaccumulative in fishes - This product is highly toxic for aquatic organisms - This product is highly toxic for bees, being able to harm other beneficial insects. Do not apply the product during intense bee activity time. - Avoid environmental contamination – Preserve Nature. - Do not use punctured equipment. - Do not apply this product in the presence of strong winds or during the hottest hours (obs – absent when the product is designed for seed treatment) - Apply only the recommended doses - Do not wash used containers or applying equipment in lakes, sources, rivers or other water bodies. Avoid water contamination.

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- The wrong destination of used containers or product waste causes soil, water and air contamination, harming fauna, flora and human health. - Do not perform aircraft application of the product in areas closer than 500 (five hundred) meters from any human settlement or water source used for public consumption, or closer than 250 meters (two hundred and fifty) from isolated water sources, single human habitations, clusters of susceptible animals or vegetation. - Observe the legal procedures contained in the state and county law regarding aircraft agricultural activities. Bulgaria Bulgaria is a Member State of the European Union from 01 Janury 2007 and as such applies the EU legislation related to Endosulfan. EU Legislation Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. During the evaluation of this active substance, a number of areas of concern have been identified. This was in particular the case concerning its environmental fate and behaviour as the route of degradation of the active substance is not completely clear and unknown metabolites were found in soil degradation, water/sediment degradation and mesocosm studies. In ecotoxicology many concerns remain since the long term risk, in particular, due to the presence of the abovementioned metabolites, cannot be sufficiently addressed with the available information. In addition exposure of operators under indoor conditions has not been considered to be sufficiently addressed with the available information. Moreover endosulfan is volatile, its main metabolite is persistent and it has been found in monitoring results of regions where the substance was not used. Consequently, as these concerns remain unsolved, assessments made on the basis of the information submitted have not demonstrated that it may be expected that, under the proposed conditions of use, plant protection products containing endosulfan satisfy in general the requirements laid down in Article 5(1)(a) and (b) of Directive 91/414/EEC. Commission Decision 2005/864/EC of 2 December 2005, concerning the non-inclusion of endosulfan in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing this active substance Endosulfan, SANCO/4327/2000 - rev. 2, 15.2.2005, Review report for the active substance endosulfan, finalised in the Standing Committee on the Food Chain and Animal Health at its meeting on 15 February 2005 in support of a decision concerning the non-inclusion of endosulfan in Annex I of Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing this active substance. This review report SANCO/4327/2000 - rev. 2, 15.2.2005, including the background documents has been developed and finalised in support of Decision 2005/864/EC (OJ No L 317, 03.12.2005) concerning the non-inclusion of endosulfan in Annex I to Directive 91/414/EEC. The overall conclusion of this evaluation, based on the information available and the proposed conditions of use, is that concerns were identified with regard to the fate and behaviour of the substance in the environment, in particular its degradation, persistence, potential of long range transport and potential of bioaccumulation ; its possible impact on non-target organisms; its possible impact on operators under indoor conditions. In conclusion from the assessments made on the basis of the submitted information, no plant protection products containing the active substance concerned is expected to satisfy in general the requirements laid down in Article 5 (1) (a) and (b) of Council Directive 91/414/EEC. Endosulfan should therefore not be included in Annex I to Directive 91/414/EEC. Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances EU classification (extract from Annex I Directive 67/548/EEC): T; R24/25 Xi; R36 N; R50-53. Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the approximation of the laws, regulations and administrative provisions of the Member States relating to the classification, packaging and labelling of dangerous preparations Source: EU pesticide data base Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006

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EU classification and Labelling (extract from table 3.1 and table 3.2 of Regulation (EC) No 1272/2008): Table 3.1:List of harmonised classification and labelling of hazardous substances from Regulation (EC) No 1272/2008 International Chemical Classification Labelling Identification Hazard Class Hazard Pictogram, Hazard Index No/EC No./ and Category statement Signal statement Code(s) CAS No. Code(s) Word Code(s) Code(s) Endosulfan, Acute Tox. 3 * H311 GHS06 H311 Index No.: 602-052-00- Acute Tox. 3 * H301 GHS09 H301 5; Eye Irrit. 2 H319 Dgr H319 EC No.: 204-079-4; Aquatic Acute 1 H400 CAS No.: 115-29-7; Aquatic Chronic H410 H410 1

Table 3.2. The list of harmonised classification and labelling of hazardous substances from Annex I to Directive 67/548/EEC International Chemical Classification Labelling Identification,

Index No/EC No./ CAS No. Endosulfan, T; R24/25 T; N Index No.: 602-052-00- Xi; R36 R: 24/25-36 5; N; R50-53 R: 50/53 EC No.: 204-079-4; S: (1/2-)28-36/37-45 CAS No.: 115-29-7; S 60-61 Council Regulation No (EC) 689/2008) of the European Parliament and of the Council of 17 June 2008 concerning the export and import of dangerous chemicals Endosulfan is pesticide in the group of plant protection products, banned for useq according Annex I, Part 1 (List of chemicals subject to export notification procedure) of Council Regulation No (EC) 689/2008). Endosulfan is listed in Part 2 (List of chemicals qualifiying for PIC notification) of Annex I to Regulation (EC) 689/2008. This implies that explicit consent must be obtained for the export to proceed. Council Decision of 19 December 2002, concerning the approval, on behalf of the European Community, of the Rotterdam Convention on the Prior Informed Consent Procedure (PIC) for certain hazardous chemicals and pesticides in international trade (2003/106/EC). Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC. Source: ESIS (European chemical Substances Information System) In Bulgaria Endosulfan is included in the List of priority substances and identified as priority hazardous substances in waters with an Order RD 321/07.05.2007 of Minister of Environment and Water related in accordance with the provisions of Water Act, promulgated in SG 67/27.07.1999г., amended SG 22/13.03.2007г., SG 59/20.07.2007г., SG 36/4.04.2008г.,

81 UNEP/POPS/POPRC.6/INF/24 last amended SG 47/ 23.07.2009г. and Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. Burundi Penalty-Regulation of Storage/Deposition – Regulation of Import (penalites-regulation de l´entreposage – reglementation de l´importation). Canada National actions described in REV2009-13 indicate label changes which will affect the allowed use, to be implemented by the 2012 growing season. China China will carry out activities for environmental risk assessment of endosulfan in some regions. Costa Rica A partir del 9 de abril de 2009, entran a regir las siguientes restricciones al endosulfan, dadas por el Decreto Ejecutivo 34782-S-MAG-MTSS:MINAET. N°195 del 9 de octubre 2008. • La venta de plaguicidas que contengan endosulfan solo se autoriza bajo receta profesional expedida en los formularios oficialmente aprobados, por un profesional incorporado al Colegio de Ingenieros Agrónomos. • Solo se autoriza el uso agricola de endosulfan en formulaciones liquidas o microencapsuladas que contengan concentraciones menores o iguales a 35% de ingrediente activo. • Se prohibe el uso de los productos que contengan endosulfan en el cultivo del arroz. • Durante las aplicaciones se deberan respetar las zonas de proteccion de los rios , arroyos y otros cuerpos de agua estipulados en la Ley Forestal. • Las personas que realicen labores de manejo y uso de productos que contengan endosulfan deben cumplir con las disposiciones que sobre examenes medicospreeexposicion y periodicos de conformidad con lo que dispongan los Ministerios de Salud y el Ministerio de Trabajo y Seguridad Social. Además, deben utilizar el equipo de protección personal recomendado en la etiqueta del product y cumplir con las medidas establecidas en el Reglamento de Salud Ocupacional en el manejo y Uso de Agroquimicos. India No. Japan Endosulfan is designated as an Agriculural Chemical causing water pollution under Order for Enforcement of the Agricaltural Chemicals Regulation Law of Japan. Local governments can restrict use of the aguricultural chemicals causing water pollution. Lithuania The HELCOM* Baltic Sea Action Plan (adopted on 15 November 2007 in Krakow, Poland by the HELCOM Extraordinary Ministerial Meeting). The HELCOM Baltic Sea Action Plan is an ambitious programme to restore the good ecological status of the Baltic marine environment by 2021. The Baltic Sea Action Plan addresses all the major environmental problems affecting the Baltic marine environment. The environmental situation in the Baltic Sea has drastically changed over recent decades. Human activities both on the sea and throughout its catchment area are placing rapidly increasing pressure on marine ecosystems. Of the many environmental challenges, the most serious and difficult to tackle with conventional approaches is the continuing eutrophication of the Baltic Sea. Inputs of hazardous substances also affect the biodiversity of the Baltic Sea and the potential for its sustainable use. Clear indicators of this situation include problems with algal blooms, dead sea- beds, and depletion of fish stocks. Such problems call for immediate wide-scale action to put an end to the further destruction of the Baltic Sea environment and to avoid an irreversible disaster. The agreed goal of HELCOM on hazardous substances is a Baltic Sea undisturbed by hazardous substances**. Seeking to achieve the overall goal of HELCOM hazardous substances segment the contracting parties have agreed on a number of activities. E.g. the contracting parties have agreed that by 2010 in the whole Baltic Sea catchment area of the Contracting

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States to ban the use, production and marketing of endosulfan, pentabromodiphenylether (pentaBDE) and octabromodiphenylether (octaBDE). *The Helsinki Commission, or HELCOM, works to protect the marine environment of the Baltic Sea from all sources of pollution through intergovernmental co-operation between Denmark, Estonia, the European Community, Finland, Germany, Latvia, Lithuania, Poland, Russia and Sweden. HELCOM is the governing body of the "Convention on the Protection of the Marine Environment of the Baltic Sea Area" - more usually known as the Helsinki Convention. ** Within HELCOM substances are defined as hazardous if they are toxic, persistent and bioaccumulative (PBT- substances), or very persistent and very bio-accumulative (vPvB). Moreover, substances having an equivalent level of concern such as substances with effects on hormone and immune systems are also hazardous substances. Malaysia At national level endosulfan is already banned since 2005. The reason of its banning was to prevent it being miss used in control of rodent and golden snail in rice planting area. Endosulfan is toxic to aquatic organism. We have no information on control actions at regional level. Mexico Adicionalmente, la Misión Permanente tiene el honor de informar que el Instituto Nacional de Ecología ha programado como parte de sus actividades de 2010, la elaboración de un diagnóstico del Endosulfan en Mexico, a fin de contar con mayor información especifica sobre esta sustancia.. Monaco This chemical is not used in Monaco, no action in this direction has been undertaken on the territory of the Principality. Poland A publication and website information are being prepared. Togo The CILSS countries members the Economic Community of West African States (ECOWAS) have already phased out Endosulfan. A process of harmonizing the pesticides regulation within the ECOWAS area is under way and other countries will easily benefit from the experience of the CILSS countries on the various control actions regarding Endosulfan. United States of America EPA’s Reregistration Eligibility Decision (RED) in 2002; Post-reregistration evaluation of risks and risk management options is on-going. More information can be found at: http://www.epa.gov/opp00001/reregistration/endosulfan/ IPEN At least 62 countries have already banned endosulfanclxiii and substituted a wide variety of effective alternatives products and practices, depending on the specific crop/pest complex. This includes two regional control actions – the EU-wide ban, and the ban by the 9 Sahelian countries of West Africaclxiv imposed by the Sahelian Pesticides Committee in 2007.clxv (h) Other relevant information for the risk management evaluation Australia Details for compliance with requirements for supply of endosulfan products by Australian retailers can be found on the APVMA website.clxvi Canada The re-evaluation of the health and environmental risks of existing older chemicals which could be possible alternatives to endosulfan is targeted for completion in 2010. India NIL.

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Norway As requested by the POPRC Committee we provide additional documentation relating to adverse human health effects of endosulfan: Human exposure (sources, levels and uptake) 1. Carreño J, Rivas A, Granada A, Jose Lopez-Espinosa M, Mariscal M, Olea N, Olea-Serrano F. Exposure of young men to organochlorine pesticides in Southern Spain. Environ Res. 2007 Jan;103(1):55-61. Epub 2006 Aug 4. PubMed PMID:16889768. It has been hypothesized that endocrine disruptors and especially synthetic estrogenic environmental contaminants (xenoestrogens) are etiologic factors in the global decrease of sperm counts and other problems of the male reproductive tract, including cryptorchidism, hypospadias, and testicular cancer. This possibility has prompted research into the current and historical incidence of these diseases. The largest area of intensive greenhouse agriculture in Europe is near the Mediterranean coast of Southern Spain, where this activity has greatly expanded since the 1960s. We determined and compared levels of 14 organochlorine pesticides in the blood of 220 young males in Southern Spain. Aldrin, dieldrin, endrin, lindane, methoxychlor, endosulfans, and DDT and its metabolites were identified. Detectable concentrations of p,p'-DDE were found in 96% of serum samples. Among the remaining DDTs, o,p'-DDD was the most prevalent, detected in 65% of serum samples. Detectable concentrations of endosulfan I or II or their metabolites endosulfan-diol, or -sulfate were found in all samples; endosulfan-diol was the most frequently detected metabolite (92%) followed by sulfate. Results indicate that men of reproductive age in Southern Spain have been and are exposed to organochlorine pesticides. Because many of these chemicals have estrogenic and anti- androgenic activity, further research is warranted to interpret the male reproductive health consequences of this exposure. 2. Pathak R, Suke SG, Ahmed RS, Tripathi AK, Guleria K, Sharma CS, Makhijani SD, Mishra M, Banerjee BD. Endosulfan and other organochlorine pesticide residues in maternal and cord blood in North Indian population. Bull Environ Contam Toxicol. 2008 Aug;81(2):216-9. Epub 2008 May 17. PubMed PMID: 18488129. Humans are exposed to various environmental chemicals such as organochlorine pesticide residues, heavy metals, polychlorinatedbiphenyls (PCBs) etc. There is paucity of data regarding the present blood levels of organochlorine residues in North Indian population with reference to reproductive health. The present study was designed to analyze the levels of organochlorine pesticide residues in maternal and cord blood samples of normal healthy women with full term pregnancy to gain insight into the current status of pesticide burden in newborns. Hexachlorocyclohexane (HCH) contributed maximum towards the total organochlorine residues present in maternal and cord blood followed by endosulfan, pp' DDE and pp' DDT being the least. This is also the first report indicating endosulfan levels in this population. Our data indicates a transfer rate of 60-70% of these pesticides from mothers to newborns and this high rate of transfer of pesticides is of great concern as it may adversely affect the growth and development of newborn. 3. Singh PB, Singh V, Nayak PK. Pesticide residues and reproductive dysfunction in different vertebrates from north India. Food Chem Toxicol. 2008 Jul;46(7):2533-9. Epub 2008 Apr 15. PubMed PMID: 18499323. Organochlorines (isomers of hexachlorocyclohexane--HCHs and metabolites of dichlorodiphenyltrichloro-ethane-- DDTs, aldrin and endosulfan) and organophosphate (chlorpyrifos) insecticide residues were investigated by gas liquid chromatography in the blood of fish, chick, goat and man. The plasma levels of testosterone (T) and estradiol-17beta (E2) was measured by radioimmunoassay in the catfish Rita rita captured from unpolluted reference site and polluted river Gomti during prespawning phase. Results indicated that in R. rita the SigmaDDT, SigmaHCH, endosulfan, aldrin, chlorpyrifos in blood levels were in preferential order (SigmaDDT>SigmaHCH>endosulfan>aldrin>chlorpyrifos) of their bioaccumulation. The blood levels of SigmaHCH and SigmaDDT also showed high levels in chick, goat and man, and preferential order of bioaccumulation was goat>chick>man>fish. The SigmaDDT also showed preferential order (man>chick>goat>fish) of bioaccumulation. Among the different tissues of fish (blood, liver, brain and ovary) the SigmaDDT was very high as compared to SigmaHCH as well as the rest of tissues which was very selective bioconcentration in different tissues of fish during prespawning phase. The gonado-somatic index, T and E2 declined in the catfish captured from polluted river when compared with the catfish captured from reference site affecting reproductive physiology. Our results indicated that increase of insecticides in blood level in vertebrates causes reproductive dysfunction and suggested that for human beings food like fish, chick and goat containing beyond permissible limit of insecticides must be avoided. 4. Shen H, Main KM, Andersson AM, Damgaard IN, Virtanen HE, Skakkebaek NE, Toppari J, Schramm KW. Concentrations of persistent organochlorine compounds in human milk and placenta are higher in Denmark than in Finland. Hum Reprod. 2008 Jan;23(1):201-10. Epub 2007 Nov 19. PubMed PMID: 18025027.

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BACKGROUND: A significantly reduced male reproductive health status, including a higher prevalence of cryptorchidism and hypospadias, has been documented in Danish men compared with Finnish men. Exposure to environmental pollutants with endocrine disrupting activities has been suggested as a possible contributing factor. In this study, we investigated whether there was a difference in milk and placental concentrations of persistent organohalogen compounds, between the two countries. METHODS: Organohalogens were analysed by high-resolution gas chromatography-high-resolution mass spectrometry in human milk samples from Finland (n = 65) and Denmark (n = 65) and in placentas from Finland (n = 112) and Denmark (n = 168). RESULTS: 1,1-dichloro-2,2-bis(4- chlorophenyl)ethane (p,p'-DDE) was the dominant pollutant. beta-Hexa-chloro-cyclohexane (beta-HCH), hexachlorobenzene (HCB), endosulfan-I, dieldrin, oxychlordane (OXC), cis-heptachloroepoxide (c-HE) and 1,1,1- trichloro-2,2-bis(4-chlorophenyl)ethane (p,p'-DDT) were the other main organochlorines detected. Danish samples had significantly higher concentrations of p,p'-DDE, p,p'-DDT, beta-HCH, HCB, dieldrin, c-HE and OXC than did the Finnish samples. Levels of organobrominated compounds were very low and most were undetectable in the majority of samples. BB-153 and BB-155 were the most abundant polybromobiphenyl congeners. BB-153 was more abundant in Danish milk samples compared with Finnish samples, whereas BB-155 was more abundant in the Finnish milk. CONCLUSIONS: The organochlorine levels were higher in Danish, than in Finnish, samples, suggesting a higher exposure for Danish infants. 5. Salem NM, Ahmad R, Estaitieh H. Organochlorine pesticide residues in dairy products in Jordan. Chemosphere. 2009 Oct;77(5):673-8. Epub 2009 Aug 19. PubMed PMID: 19695668. The use of aldrin, dieldrin, endrin, heptachlor and hexachlorobenzene (HCB) has been banned in Jordan officially in 1981, and of dichlorodiphenyltrichloroethane (DDT) in 1995. However, residues of such compounds can still be found in the environment and in foodstuffs. Dairy products are an important exposure route for organochlorine pesticides (OCPs) to humans. For this reason, the presence of OCP residues in 233 dairy product samples; comprising milk, butter, cheese, labaneh and yoghurt collected from Jordan was determined. All samples were analyzed for their residual contents of aldrin, DDT and metabolites (DDTs), dieldrin, endosulfan isomers, endrin, hexachlorocyclohexane isomers (HCHs), heptachlor and HCB. Levels of these compounds were determined by gas chromatography with electron capture detector (GC-ECD). The results indicated that 9% (21/233), 8.5% (20/233), 6% (14/233) and 2.1% (5/233) of the examined samples were contaminated with beta-HCH, pp'-DDE, alpha-HCH and gamma-HCH, respectively. Heptachlor and alpha-endosulfan were only present in less than 2% of the analyzed samples. None of the samples revealed the presence of aldrin, op'-DDD, pp'-DDD, op'-DDE, op'-DDT, pp'-DDT, dieldrin, beta-endosulfan, endrin and HCB at their detection limits. The order for the contamination in the analyzed dairy products was labaneh>cheese>yoghurt>butter>milk. This study has provided the preliminary information on the concentration of OCPs in dairy products for the first time in Jordan. The results will help in a scientific assessment of the implications of pesticide residues with regards to human risks in Jordan. 6. Kalyoncu L, Agca I, Aktumsek A. Some organochlorine pesticide residues in fish species in Konya, Turkey. Chemosphere. 2009 Feb;74(7):885-9. Epub 2008 Dec 21.PubMed PMID: 19103455. The levels of organochlorine pesticides were measured in 18 fish species from Konya markets, Turkey. These species were selected on the basis of their importance to local human fish consumption. The extracted residues were analyzed on a micro capillary gas chromatograph equipped with an electron capture detector. Total 14 different organochlorine pesticides were determined. These residues were detected in all fish species, except in trout, horse mackerel and bonito. DDT and its metabolites and HCH were the predominant contaminants in fish muscles. The mean concentrations of summation operator DDT were in the range between 0.0008 and 0.0828 microg g(-1). DDT was the predominant residue in Sparus aurata. Detectable levels of HCH, aldrin, and heptachlor were found in most samples. However, dieldrin, endrin, beta endosulfan, p-p' DDT, and p-p' DDD were not found in Salmo trutta. The mean of endrin ranged from 0.0040 microg g(-1) (Triglia lineate) to 0.0326 microg g(-1) (Trachurus trachurus). These results give no indication of important health risks associated with the consumption of these fishes in Konya markets. 7. Liu X, Zhang G, Li J, Yu LL, Xu Y, Li XD, Kobara Y, Jones KC. Seasonal patterns and current sources of DDTs, chlordanes, hexachlorobenzene, and endosulfan in the atmosphere of 37 Chinese cities. Environ Sci Technol. 2009 Mar 1;43(5):1316-21. PubMed PMID: 19350897. China has a history of large scale production and application of organochlorine pesticides (OCPs) although, data on their nationwide distribution and seasonal variations in the atmosphere is still sparse. Passive air samplers (PAS) were therefore utilized to obtain seasonal data from 37 Chinese cities and three background sites in 2005. Concentrations and spatial and seasonal distribution of dichlorodiphenyltrichloroethanes (DDTs), chlordanes (CHLs), hexachlorobenzene (HCB), and endosulfans (Endo) are presented in this paper, and their potential sources are

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discussed based on the dataset. It is estimated that ca. 95% of DDTs present in the atmosphere of Chinese cities was still from technical DDT, while only ca. approximately 5% was "dicofol-type of DDT". DDT application for public health control and DDT activated antifouling paint for fishing ships may be the two most important current sources of technical DDT. The DDT concentrations in several Chinese cities seem to match well with the reported DDT concentrations in human breast milk. A low TC/CC ratio was observed across China in the winter to spring, which may provide a fingerprint of Chinese chlordane emission. It was suggested that "weathered" chlordane emitted from urban construction foundations in winter may give the distinctively low TC/CC ratio. The data showed that China is an important global source for HCB. Higher HCB concentrations were observed in winter and spring, and in colder cities, highlighting an important contribution from combustion sources. Samples with higher endosulfan concentrations occurred in the cotton production areas, indicating its major use in killing cotton pests. 8. Muralidharan S, Dhananjayan V, Jayanthi P. Organochlorine pesticides in commercial marine fishes of Coimbatore, India and their suitability for human consumption. Environ Res. 2009 Jan;109(1):15-21. Epub 2008 Oct 11. PubMed PMID:18849026. Organochlorine pesticide residues were determined in 10 species of fishes caught at Cochin and Rameshwaram coast, and sold in Coimbatore, Tamil Nadu, India. Species were selected on the basis of their regular availability throughout the year and commercial value. A total of 389 fishes were analyzed for organochlorine residues and their suitability for human consumption was evaluated. Results show varying levels of residues of hexachlorocyclohexane (HCH), DDT, heptachlor epoxide, endosulfan and dieldrin. Among the 10 species, high concentration of pesticide residues were recorded in Sardinella longiceps, Carangoides malabaricus, Chlorophthalmus agassizi, Saurida tumbil and Rastrelliger kanagurta. The variation in total organochlorine residues among species and between places was not significant (P>0.05). Only five species of fishes showed monthly variation in residue levels and there was no significant correlation between the body size and residue levels in the tissue. About 22% of the fishes exceeded the maximum residue limits (MRL) of total HCH prescribed by FAO/WHO for fish products. The calculated dietary intake of total HCH through consumption of C. malabaricus, C. agassizi and S. longiceps exceeded the maximum acceptable dietary intake (ADI) limits prescribed for human consumption. The present study recommends continuous monitoring of environmental contaminants in marine fishes to assess the possible impact on human health. 9. Sibali, LL, Okwonkwo, JO, McCrindle, RI. Determination of selected organochlorine pesticide (OCP) compounds from the Jukskei River catchment area in Gauteng, South Africa WATER SA, 2008 34 (5): 611-621 Organochlorine pesticides (OCPs.) are continually detected in the environment due to their increasing applications in agriculture and industry. The presence of OCPs in the environment is not desirable since they are well known to have negative impact ill humans, animals and birds. Thus, there has been a continual demand to monitor the presence of OCPs within the environment. Liquid-liquid extraction (LLE) and Sexhlet extraction (SE) methods (using dichloromethane as the extracting solvent,) were optimised and evaluated for the determination of these compounds in surface water (unfiltered and filtered) and sediment samples. The crude extracts obtained were subjected to column chromatography for clean-tip. Thereafter, 1 mu l of the cleaned extracts were injected into the GC equipped with ECD. Percentage recoveries obtained for OCPs ranged from 98.90 +/- 7.32 (2,4'-DDE) - 124.1 +/- 8.23 endosulfan II (ENDO II) % and from 98.99 +/- 5.30 (2,4'-DDE) - 121.1 +/- 0.38 (4,4'-DDE) % in spiked triply distilled water and sediment samples respectively. The levels of OCPs obtained in unfiltered environmental water samples ranged from 0.631 +/- 0.03 (gamma-HCH) - 1 540 +/- 0.19 mg.ml(-1) (4,4'-DDT) while levels in filtered water samples ranged from 0.895 +/-.0.01 (gamma-HCH) - 9 089 +/- 0.08 ng.ml(-1) (HEPTA). Levels of analyzed OCPs obtained in sediments ranged from 0.266 +/- 0.01 (delta-HCH) - 22 914 +/- 2.85 ng-gdw(-1) (2,4'-DDE). Analytes adsorbed on the sample bottles used for water samples collection gave levels which ranged front 0.01 +/- 0.01 - 1.06 +/- 0.02 mg.ml(-1) for OCPs. The levels obtained from the catchment were significantly higher than the water criteria values recommended by USEPA and DWAF, for the protection of the aquatic environment. Levels obtained were also higher than those of other studies conducted so far in South African aquatic environments. There is, therefore, a definite pollution of the Jukskei River catchment by the OCPs studied. 10. Gouin, T, Shoeib, M, Harner, T . Atmospheric concentrations of current-use pesticides across south-central Ontario using monthly-resolved passive air samplers. ATMOSPHERIC ENVIRONMENT, 2008, 42 (34): 8096-8104 In this study passive air samplers (PAS) were deployed on a monthly basis at a number of sites along a south-north transect, extending 700 km north from Toronto, Ontario, characterizing an urban-agricultural-forested gradient, to investigate the spatial and temporal trends of current-use pesticides (CUPs), between spring 2003 and spring 2004. The most frequently detected CUPs were chlorpyrifos, dacthal, trifluralin, and alpha-endosulfan. Highest

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air concentrations of chlorpyrifos were observed in May, whereas a-endosulfan and dacthal peaked in July and August, reflecting differences in usage patterns. At the agricultural site, representing the source region of CUPs, chlorpyrifos air concentrations (pg m(-3)) varied from 2700 to 3.2 and alpha-endulsulfan from 1600 to 19. The most frequently detected legacy pesticides were the hexachlorocylcohexanes (alpha-HCH and gamma-HCH). For the forested sites, located on the Precambrian Shield, a region with limited agricultural activity, seasonal differences were less pronounced and air concentrations were observed to be much lower. For instance, air concentrations (pg m (-3)) of chlorpyrifos and a-endosulfan ranged from 7.6 to 0.3 and 50 to 2.0, respectively. By combining PAS data with trajectory air shed maps it is demonstrated that potential source-receptor relationships can be assessed. Air shed maps produced in this study indicate a potential of increased deposition of CUPs to Lake Erie and Lake Ontario. 11. Essumang, DK, Dodoo, DK, Adokoh, CK, Fumador, EA. Analysis of some pesticide residues in tomatoes in Ghana. HUMAN AND ECOLOGICAL RISK ASSESSMENT, 2008, 14 (4): 796-806 Pesticide residues, both natural and synthetic, can be found in most of the things we eat, for example, fruits, vegetables, bread, meat, poultry, fish, and the processed foods made from them. Some of this pesticide contamination is legal, but does this mean it is safe? Much of it is illegal, with residues found in excess of regulatory safe levels. Identifying and determining the level of trace contaminants in our food and environment is critical in protecting and improving human health and the environment. This study evaluates the residue levels of select pesticides used on tomato crops in Ghana that are likely to have accumulated in the tomatoes during application. The results obtained confirm that pesticide residues were indeed present in the tomatoes and further analysis quantified the amount present. Analysis of some organochlorine and organophosphorus residue levels in the fruits indicated that chlorpyrifos, which is an active ingredient of pesticides registered in Ghana under the trade name dursban 4E or terminus 480 EC for use on vegetables, has the greatest residue level of 10.76 mg/kg. The lowest residue level observed was that of pirimiphos- methyl with 0.03 mg/kg. Human health risk assessment was performed on the results obtained from the analysis using Human Health Evaluation computerized software-RISC 4.02. The risk assessment showed cancer risk for adults and children due to the presence of endosulfan and chlopyrifos. Endosulfan is not registered in Ghana as a pesticide for use on vegetables, therefore the detection of endosulfan in several samples indicates misuse of agrochemicals among Ghanaian farmers. 12. El Bakouri H, Ouassini A, Morillo Aguado J, Usero García J. Endosulfan sulfate mobility in soil columns and pesticide pollution of groundwater in Northwest Morocco. Water Environ Res. 2007 Dec;79(13):2578-84. PubMed PMID: 18198703 Groundwater pollution from agricultural practices is a serious environmental and health problem. In this work, stir bar sorptive extraction (SBSE) and gas chromatography (GC) with mass spectrometry (MS) detection were used to determine phytosanitary products in groundwater samples from the Loukkos perimeter in Northwest Morocco. Some pesticides--in particular, endosulfan and its metabolites--were found in water destined for human consumption. Analyses of soil samples were also carried out, and the results showed endosulfan sulfate and endosulfan ether in abundance. Endosulfan sulfate leaching was also performed in undisturbed soil columns to obtain more information on the vertical migration of pesticides used in the perimeter. The kinetic study showed a high recovery rate (73%) after 10 days of experimental work. 13. Darko G, Acquaah SO. Levels of organochlorine pesticides residues in meat. INTERNATIONAL JOURNAL OF ENVIRONMENTAL SCIENCE AND TECHNOLOGY, 2007,4 (4): 521-524 FAL 2007 Concentrations of organochlorine pesticides (Lindane, Aldrin, Dieldrin, Endosulfan, DDT and DDE) residues in beef samples from the Kumasi and Buoho abattoirs in Ghana were determined using gas chromatography. Organochlorine residues were found in all the samples. The average concentration of lindane in beef fat samples from Kumasi was 4.03 mu g/kg and 1.79 mu g/kg in beef fat from Buoho. The average levels of lindane were 2.07 mu g/kg for lean meat samples from Kumasi abattoir and 0.60 mu g/kg in lean meat samples from Buoho. Endosulfan concentration in meat samples from Buoho was 2.28 mu g/kg in the fat and 0.59 mu g/kg in the lean beef. 1,1-dichloro-2,2-bis(p- dichlorodiphenyl)ethylene (DDE) recorded mean concentrations of 118.45 mu g/kg in beef fat and 42.93 mu g/kg in lean beef samples from Kumasi abattoir. Beef samples from Buoho had DDE concentration of 31.89 mu g/kg in the fat and 5.86 mu g/ kg in the lean beef. 1, 1, 1-tricliloro-2, 2-bis-(4'-clilorophenyl) ethane (DDT) recorded an average concentration of 545.22 mu g/kg in beef fat and 18.85 mu g/kg in lean beef samples from Kumasi abattoir. The average concentration of DDT in beef fat from Buoho was 403.82 mu g/kg but lean meat samples from the same sampling site recorded mean concentration of 10.82 mu g/kg for DDT. Although, most of the organochlorine residues detected were below the maximum limits set by the FAO/WHO, bioaccumulation of these residues is likely to pose health problems in higher organisms like human beings.

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14. Darko G, Acquaah SO. Levels of organochlorine pesticides residues in dairy products in Kumasi, Ghana. Chemosphere. 2008 Mar;71(2):294-8. Epub 2007 Oct 17.PubMed PMID: 17942137. Determination of six organochlorine pesticides, lindane, aldrin, dieldrin, endosulfan, dichlorodiphenyltrichloroethane (DDT), and dichlorodiphenyldichloroethylene (DDE), residues were carried out on three dairy products sampled from six communities in the Kumasi metropolis in Ghana. Cheese samples were collected from three communities, (Tafo, Asawasi, and Aboabo), yoghurt samples from K-Poly and Ayeduasi while yoghurt and milk samples were collected from KNUST. Concentrations of DDT and DDE were, respectively, 42.17+/-6.00 microg kg(-1) and 31.50+/-3.44 microg kg(-1) in cheese sampled from Asawasi. Cheese samples from Tafo had an average DDT concentration of 298.57+/-28.02 microg kg(-1) while DDE concentration was 140.15+/-56.77 microg kg(-1). The highest average concentration of DDT in all the samples was 149.07 microg kg(-1) detected in cheese samples from Aboabo. Levels of DDT and its metabolite, DDE, in cheese from all the three sampling sites (Aboabo, Asawasi and Tafo) were well below the levels recommended by World Health Organisation (WHO). Mean concentration of DDT in fresh milk samples from KNUST was 12.53+/-1.61 microg kg(-1). As bioaccumulation of these residues is likely to pose problems in higher organisms, like human beings, there is the need for effective monitoring of these residues in the environment. This work, thus, seeks to provide information on levels of pesticide residues in dairy products that will assist in a scientific assessment of the impact of pesticides on public health, agriculture and the environment in Ghana. 15. Lopez-Espinosa MJ, Lopez-Navarrete E, Rivas A, Fernandez MF, Nogueras M, Campoy C, Olea-Serrano F, Lardelli P, Olea N. Organochlorine pesticide exposure in children living in southern Spain. Environ Res. 2008 Jan;106(1):1-6. Epub 2007Oct 29. PubMed PMID: 17915209 Despite the prohibition of most persistent organochlorine (OC) pesticides in Spain, their presence has been widely documented in adult human tissues. However, scarce information is available on the exposure of children. The aim of the present study was to investigate the presence of 16 OC pesticide residues in 52 fat samples collected from boys with a mean age of 7yr (0-15yr) living in Southern Spain and to assess the association between OC pesticide levels and child characteristics. No pesticide was found in more than 50% of samples, except for p,p'-DDE (79% of samples; median, 710ng/g lipid). After this compound, the most frequent pesticides were o,p'-DDT (17%; median, 330ng/g lipid) and o,p'-DDD (15%; median, 1510ng/g lipid). No statistically significant association was found between p,p'-DDE or SigmaDDTs and the birth year, birth weight, gestational age, infant feeding history or the age, weight, height or Quetelet Index at the time of sampling. The lack of correlation between the presence of the main metabolite p,p'-DDE and that of the parent compounds, o,p'-DDT and p,p'-DDT, suggests that children were exposed mainly to the metabolite rather than to the commercial pesticide, which was banned 30yr ago. In contrast, among currently used OCs, endosulfan was positively correlated with the presence of its metabolites, suggesting exposure to the commercial products. Further research is warranted to investigate the health consequence in children resulting from exposure to chemicals suspected of endocrine-disrupting effects. 16. Sharma HR, Kaushik A, Kaushik CP. Pesticide residues in bovine milk from a predominantly agricultural state of Haryana, India. Environ Monit Assess. 2007 Jun;129(1-3):349-57. Epub 2006 Dec 16. PubMed PMID: 17180431. One hundred forty seven samples of bovine milk were collected from 14 districts of Haryana, India during December 1998-February 1999 and analysed for the presence of organochlorine pesticide (OCPs) residues. summation operator HCH, summation operator DDT, summation operator endosulfan and aldrin were detected in 100%, 97%, 43% and 12% samples and with mean values of 0.0292, 0.0367, 0.0022 and 0.0036 microg/ml, respectively. Eight percent samples exceeded the maximum residue limit (MRL) of 0.10 mg/kg as recommended by WHO for summation operator HCH, 4% samples of 0.05 mg/kg for alpha-HCH, 5% samples of 0.01 mg/kg for gamma-HCH, 26% samples of 0.02 mg/kg for beta-HCH as recommended by PFAA and 24% samples of 0.05 mg/kg as recommended by FAO for summation operator DDT. Concentrations of beta-HCH and p,p'-DDE were more as compared to other isomers and metabolites of HCH and DDT. 17. Guo JY, Zeng EY, Wu FC, Meng XZ, Mai BX, Luo XJ. Organochlorine pesticides in seafood products from southern China and health risk assessment. Environ Toxicol Chem. 2007 Jun;26(6):1109-15. Erratum in: Environ Toxicol Chem. 2007Sep;26(9):2024. PubMed PMID: 17571674. Seafood consumption is an important route of human exposure to organic contaminants. Residual levels of organochlorine pesticides (OCPs), including DDTs, hexachlorocyclohexanes (HCHs), heptachlor, aldrin, alpha- endosulfan, beta-endosulfan, dieldrin, endrin, endrin aldehyde, endrin ketone, methoxychlor, endosulfan sulfate, and heptachlor epoxide, were determined in a wide variety of seafood products collected from 11 coastal cities in southern China in June and October 2005. The results indicated that OCPs were predominated by DDTs and HCHs. The concentrations of other OCP components generally were low and were detectable in a small number of seafood

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samples only, probably reflective of the generally low levels of these OCPs in the study region and low bioaccumulation potentials in the species under investigation. Risk assessment against various standards clearly showed that seafood products were highly contaminated by DDTs and may pose health threat to local residents and the consumers all over the world. Furthermore, other OCP components, such as dieldrin and heptachlor, also impose lifetime cancer risk, especially to residents of coastal regions who often consume more seafood than those living inland. Therefore, continual monitoring of OCPs in various environment compartments, including biota and abiota, urgently is needed to mitigate effectively the impact of OCPs, particularly DDTs, on human health and the ecological environment. 18. Jimenez Torres M, Campoy Folgoso C, Cañabate Reche F, Rivas Velasco A, Cerrillo Garcia I, Mariscal Arcas M, Olea-Serrano F. Organochlorine pesticides in serum and adipose tissue of pregnant women in Southern Spain giving birth by cesarean section. Sci Total Environ. 2006 Dec 15;372(1):32-8. Epub 2006 Aug 14.PubMed PMID: 16904732. Since the appearance of DDT, increasingly potent insecticides have been developed to overcome the resistance developed by insects to successive products. Pesticides are also used in public health programs to control disease vectors. Despite legislation to control the use of certain products, they repeatedly appear in the adipose tissue, milk and serum of human populations. The present study determined the presence of organochlorine molecules in the adipose tissue, serum, and umblical cord of women giving birth by cesarean section in order to establish a possible correlation in organochlorine molecule content between these biological compartments and to examine fetal exposure to molecules with hormonal effects. Presence of nine organochlorines was detected by GC/ECD and confirmed by GC/MS. Highly significant differences (p<0.000) were observed between adipose tissue and maternal serum in concentrations of lindane, HCB, DDE, DDD, and endosulfan but not (p>0.5) in concentrations of endosulfan II or endosulfan sulfate. Only DDE concentrations differed (p<0.001) between maternal serum and umbilical cord serum. An association between pp'DDE and op'DDT was observed in maternal serum (p<0.094). An association in pp'DDE and pp'DDD content was found between adipose tissue and umbilical cord serum, and in pp'DDT content between adipose tissue and maternal serum. Results obtained indicate that exposure can be measured solely in serum when relatively high concentrations of pesticides are present. Toxicity and human health risk 19. Silva MH, Beauvais SL. Human health risk assessment of endosulfan. I: Toxicology and hazard identification. Regul Toxicol Pharmacol. 2009 Sep 3. [Epub ahead of print] PubMed PMID: 19733203. Endosulfan is persistent in the environment and toxic to wildlife. Legal mandates necessitate that a risk assessments be performed for endosulfan by the California Department of Pesticide Regulation (CDPR) and the United States Environmental Protection Agency (USEPA). This hazard identification (hazard ID) compared critical no-observed effect levels (NOEL) for acute, subchronic and chronic exposure intervals between the agencies. NOELs were discussed in light of their application to numerous exposure scenarios (occupational, general population and dietary). Only the acute oral NOELs differed between CDPR (0.7mg/kg/day) and USEPA (1.5mg/kg/day). Pregnant rabbits were considered by CDPR to be more responsive to low gavage doses of endosulfan than non-pregnant female or male rats in the acute study selected by USEPA. NOELs for other exposure routes and durations were similar between agencies. CDPR and USEPA concurred that a Food Quality Protection Act (FQPA, 1996) Safety Factor is not needed after evaluating all studies including a Developmental Neurotoxicity study. The SF was reduced to 1x. NOELs generated from this hazard ID will be used to calculate the Margins of Exposure for all scenarios and subsequently the risk characterization for endosulfan. 20. Silva MH, Carr WC Jr. Human health risk assessment of endosulfan: II. Dietary exposure assessment. Regul Toxicol Pharmacol. 2009 Sep 3. [Epub ahead of print] PubMed PMID: 19733202. The California Department of Pesticide Regulation (CDPR) and the United States Environmental Protection Agency (USEPA) performed dietary exposure assessments for endosulfan in 1998 and 2002, respectively. Results of the USEPA assessment showed an increased risk for the population sub-group "Children 1-6years" (>100% of the Population Adjusted Dose [PAD]). USEPA then required registrants to satisfy database uncertainties by performing subchronic neurotoxicity and developmental neurotoxicity studies and, based on the results, USEPA decreased the Food Quality Protection Act (FQPA, 1996) Safety Factor from 10x to 1x. Additionally, several tolerances on commodities consumed in quantity by children were cancelled in 2006. CDPR re-evaluated the dietary risk initially performed in 1998 after review of these same studies. Based on a review of the revised USEPA tolerances, decreased usage, decreased consumption, cancellations, and prior health protective margins of exposure (MOEs>100), CDPR determined that it was not necessary to redo the 1998 exposure assessment. In 2007, USEPA conducted a new human health risk assessment for endosulfan combining food+drinking water residues that characterized dietary risk as

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%PAD=([Exposure/PAD]x100). For all relevant USEPA population sub-groups, the %PADs were<100% (health protective benchmark). 21. Beauvais SL, Silva MH, Powell S. Human health risk assessment of endosulfan. Part IV: Occupational reentry and public non-dietary exposure and risk. Regul Toxicol Pharmacol. 2009 Sep 3. [Epub ahead of print] PubMed PMID: 19733201. The California Department of Pesticide Regulation (CDPR) and the United States Environmental Protection Agency (USEPA) released revised draft risk assessments for the pesticidal active ingredient, endosulfan, just 2months apart, in November 2007 and January 2008. The exposure estimates, critical to risk assessment, were calculated by each agency using dissimilar approaches in certain aspects. The scenarios for which exposures and risks were estimated also varied somewhat between the two agencies, although there were substantial overlaps that allowed specific comparisons of exposure and risk estimates. Reasons underlying major differences in estimates of exposure for field workers working in treated crops (reentry exposure) are discussed in this paper. Differences in dislodgeable foliar residue levels calculated by CDPR and USEPA, reflecting endosulfan residues encountered by field workers entering treated orchards and fields, contributed the most to discrepancies in reentry exposure estimates between the two agencies. Additionally, because of differences in legal mandates CDPR estimated exposures for members of the public exposed to endosulfan in ambient air and when swimming, whereas USEPA did not. Exposures calculated for bystanders adjacent to a pesticide application suggest a potential health concern, but estimated swimmer exposures did not. 22. Das PP, Shaik AP, Jamil K. Genotoxicity induced by pesticide mixtures: in-vitro studies on human peripheral blood lymphocytes. Toxicol Ind Health. 2007 Sep;23(8):449-58. PubMed PMID: 18669166. To assess the damage caused by pesticides and their mixtures on humans, we designed in-vitro experiments to evaluate their cytotoxicity and genotoxicity. Three equimolar pesticide mixtures were investigated for their capability to affect cultured human peripheral blood lymphocytes. The LC50 values for cytotoxicity, using standard trypan blue dye exclusion and calculated by probit analysis, were 4.18, 5.76, and 7.5 microM for endosulfan, carbofuran, and monocrotophos, respectively. When combined in equimolar concentrations, the LC50 values for cytotoxicity were 0.7, 0.9, and 1.0 microM for monocrotophos + carbofuran, endosulfan + monocrotophos, and endosulfan + carbofuran, respectively, using the method. DNA damage was estimated using chromosomal aberrations (chromatid breaks, fragments, gaps, aneuploidy, and satellite association) and comet assays using 1/10 of the LC50 concentrations. Using a standard alkaline comet assay procedure, high concentrations of individual pesticides (0.5-4.0 microM) caused significant DNA damage as indicated by visible tail lengths. Lower concentrations (0.05-0.5 microM) of their binary mixtures could cause the same effect. The results suggest that analysis of genotoxicity may serve as an important biomarker for occupational and household exposure to pesticides, especially mixtures of pesticides, with different modes of action. 23. Singh ND, Sharma AK, Dwivedi P, Patil RD, Kumar M. Citrinin and endosulfan induced maternal toxicity in pregnant Wistar rats: pathomorphological study. J Appl Toxicol. 2007 Nov-Dec;27(6):589-601. PubMed PMID: 17429798. Dietary exposures to environmental food pollutants such as mycotoxin(s) or pesticide(s) have gained immense significance due to their adverse effects on production and reproduction in animal and human populations. The present investigation was conducted to evaluate the maternal toxicity of citrinin (CIT) and endosulfan administered per os either alone or in combination in pregnant rats during gestational days 6-20. CIT (group I, 10 mg kg(-1) feed, through diet) and endosulfan (group II, 1 mg kg(-1) body weight, by oral intubation) when administered either alone or in combination (group III) in Wistar rats caused clinical signs of toxicity and pathomorphological changes in all the toxin treated groups, the severity being more pronounced in the combination treatment compared with that observed in the control (group IV). The rate of fetal resorptions was highest (22.22%) in the combination treatment followed by endosulfan (16.48%) and CIT (12.50%) treatment groups compared with the control group (3.86%). The histopathological changes such as engorged vasculature, vacuolar degeneration and karyomegaly in liver; congestion, tubular degeneration and cast formation in kidneys; vascular changes and hemosiderosis in uterus and lymphocytic depletion and apoptosis in the lymphoid organs were recorded in the animals of the toxin treated groups. The lesions were consistent and more severe in the combination treatment group compared with the individual treatment groups, suggesting an additive interaction of CIT and endosulfan in inducing maternal toxicity in Wistar rats. 24. Sharma S, Nagpure NS, Kumar R, Pandey S, Srivastava SK, Singh PJ, Mathur PK. Studies on the genotoxicity of endosulfan in different tissues of fresh water fish Mystus vittatus using the comet assay. Arch Environ Contam Toxicol. 2007 Nov;53(4):617-23. Epub 2007 Aug 20. PubMed PMID: 17713809.

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Endosulfan, a widely used organochlorine pesticide, is readily bio-accumulative in fishes and can be indirectly harmful to human populations. Limited efforts have been made to study long-term genotoxic effects of endosulfan in different tissues of fish using gentoxicity biomarkers. Therefore, the current investigation was undertaken to detect single-cell DNA strand breaks induced by endosulfan in the fresh water teleost fish Mystus vittatus using the comet assay. The LC(50) value of technical grade endosulfan was first determined for the fish species in a semistatic system, and on the basis of the LC(50) value, the sublethal and nonlethal concentrations were determined. The DNA damage was measured in gill, kidney, and erythrocytes as the percentage of DNA in comet tails of fish specimens exposed to the sublethal and nonlethal concentrations of endosulfan. In general, significant effects (p < 0.01) from both concentration and time of exposure were observed in exposed fishes. It was found that all the tissues at all concentrations exhibited the highest DNA damage on day 1, after which there was a nonlinear decline in the percentage of tail DNA. The comparison of DNA damage among the tissues at different concentrations could not show the sensitivity of particular tissue to endosulfan. The current study explored the utility of the comet assay for in vivo laboratory studies using fish species to screen the genotoxic potential of chemical agents. 25. Antherieu S, Ledirac N, Luzy AP, Lenormand P, Caron JC, Rahmani R. Endosulfan decreases cell growth and apoptosis in human HaCaT keratinocytes: partial ROS-dependent ERK1/2 mechanism. J Cell Physiol. 2007 Oct;213(1):177-86. PubMed PMID: 17503468. Endosulfan is an organochlorine insecticide described as a potential carcinogen in humans. This insecticide was recently reported to alter the mitogen-activated protein (MAP) kinase signaling pathways and is suspected to affect cell growth and differentiation in human keratinocytes. This study was designed to assess the mitogenic, apoptogenic, and genotoxic effects of endosulfan on the HaCaT cell line. We first found that 25 microM endosulfan led to persistent extracellular signal-regulated kinase (ERK)1/2 phosphorylation with an accumulation of the phosphorylated form in the nucleus, probably caused by MAP kinase phosphatase (MKP) inhibition. As previously described under sustained ERK1/2 activation, cell growth was decreased: delayed confluency and 35% decrease of BrdU incorporation was demonstrated in endosulfan-treated keratinocytes. In addition, endosulfan has been shown to generate transient reactive oxygen species (ROS), and blocking this oxidative stress by N-acetyl cysteine (NAC) strongly prevented both persistent nuclear ERK1/2 phosphorylation and cell growth decrease. Additional experiments demonstrated that unchanged endosulfan rather than its metabolites has mutagenic effects (Ames positive without S9) and increased DNA strand breaks (Comet assay) in HaCaT cells, via a ROS-dependent mechanism. Therefore, to assess the putative pro- apoptotic response of damaged cells, caspases 3/7 activity and poly(ADP-ribose)-polymerase (PARP) cleavage were measured. The results clearly indicated that endosulfan inhibited both spontaneous and staurosporine-induced apoptosis. Taken together, these findings strongly support that endosulfan induces ROS generation leading to sustained ERK1/2 phosphorylation and decrease in cell growth. Moreover, endosulfan was found to inhibit apoptosis and this could contribute to mutant cell survival and therefore have possible carcinogenic effects. 26. Hodgson E, Rose RL. Human metabolic interactions of environmental chemicals. J Biochem Mol Toxicol. 2007;21(4):182-6. Review. PubMed PMID: 17936932. Investigations utilizing recombinant human xenobiotic-metabolizing enzymes as well as human hepatocytes have revealed a number of interactions not only between different environmental chemicals (ECs) but also between ECs and endogenous metabolites. Organophosphorus insecticides (OPs) are potent inhibitors of the human metabolism of carbaryl, carbofuran, DEET and fipronil, as well as the jet fuel components, nonane and naphthalene. OPs are potent irreversible inhibitors of testosterone metabolism by cytochrome P450 (CYP) 3A4 and of estradiol metabolism by CYP3A4 and CYP1A2. All of these CYP inhibitions are believed to be due to the release of reactive sulfur during CYP- catalyzed oxidative desulfuration. It has also been shown that the esterase(s) responsible for the initial step in permethrin metabolism in human liver is inhibited by both chlorpyrifos oxon and carbaryl. A number of pesticides, including chlorpyrifos, fipronil and permethrin, and the repellent, DEET, have been shown to be inducers of CYP isoforms in human hepatocytes, with fipronil being the most potent. Several agrochemicals, including fipronil and the pyrethroids, permethrin and deltamethrin, show toxicity toward human hepatocytes with fipronil being the most potent in this regard. Endosulfan-alpha, which has shown promise as a model substrate for phenotyping CYP3A4 and CYP2B6 in human liver microsomes, is also an inducer of CYP2B6, acting through the PXR receptor. 27. Kucuker H, Sahin O, Yavuz Y, Yürümez Y. Fatal acute endosulfan toxicity: a case report. Basic Clin Pharmacol Toxicol. 2009 Jan;104(1):49-51. PubMed PMID:19152551. Endosulfan is an organochlorine pesticide. It is banned in the United States of America and Europe, but use is unrestricted for insect control. Endosulfan causes many intentional and unintentional toxicities in developing countries and in Turkey. Acute exposure to endosulfan has rarely been reported in deaths due to ingestion. Here, a fatality of 61-

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year-old woman of a family who was poisoned due to ingestion of endosulfan has been reported. Based on autopsy findings, patient history and toxicological results, the cause of death was determined to be acute intoxication of endosulfan and the manner, unintentional toxicities. Endosulfan has histopathological toxic effects on many organs and this toxic effect occurs within a short period after ingestion. To prevent endosulfan poisoning, the usage of it must be restricted and even prohibited. To prevent death and to accelerate improvement, the organs that have more apparent histopathological injury should be considered and early and intensive supportive treatment be initiated. 28. Yavuz Y, Yurumez Y, Kücüker H, Ela Y, Yüksel S. Two cases of acute endosulfan toxicity. Clin Toxicol (Phila). 2007 Jun-Aug;45(5):530-2. PubMed PMID: 17503261. BACKGROUND: Endosulfan is widely used in insect control and is absorbed by both humans and animals through the intestinal tract, the lungs, and the skin. Organochlorine insecticides are highly toxic compounds that are responsible for a number of severe intoxications worldwide, with several deaths. A 9-year analysis by one of Turkey's poison control centers reported that pesticide intoxications accounted for 8.8% of 25,572 poisoning calls, with 80.3% of them relating to insecticides and 19.7% concerning rodenticides. CASE REPORTS: We present two cases of unintentional exposure to endosulfan, one of which presented with neurological manifestations, liver toxicity, and required mechanical ventilation and emergent hemodialysis; the other had only neurological manifestations and liver toxicity. CONCLUSION: In cases of endosulfan poisoning, physicians must be aware of neurological manifestations, seizures, and severe metabolic acidosis. If severe metabolic acidosis is present, we suggest that hemodialysis may be an important intervention and should be performed early. 29. Satar S, Sebe A, Alpay NR, Gumusay U, Guneysel O. Unintentional endosulfan poisoning. Bratisl Lek Listy. 2009;110(5):301-3. PubMed PMID: 19507667. Endosulfan is an organochloride insecticide, widely used in insect control. It is responsible for many severe intoxication and several deaths. We present a case series of endosulfan poisoning, admitted to our emergency department with different clinical courses. Two patients presented with status epilepticus and were successfully treated with thiopental sodium to control seizures. One patient required also hemodialysis. All patients were discharged following a complete recovery of their health. Endosulfan is a highly toxic insecticide that produces tonic-clonic convulsions, headache, dizziness and ataxia. It can cause also life threatening metabolic disturbances. Treatment is symptomatic and supportive (Tab. 2, Ref. 11). 30. Ramaswamy S, Puri GD, Rajeev S. Endosulfan poisoning with intravascular hemolysis. J Emerg Med. 2008 Apr;34(3):295-7. Epub 2007 Jul 19. PubMed PMID:17976761. We describe a 26-year-old female patient, who had attempted suicide with Endosulfan, and who presented to the Emergency Department with status epilepticus. She subsequently developed hypotension refractory to inotropes, intravascular hemolysis, disseminated intravascular coagulation (DIC), metabolic acidosis and, finally, cardiac arrest and death. Endosulfan is a chlorinated insecticide that causes central nervous system hyperstimulation. It is absorbed from the gastrointestinal tract, skin, and respiratory tract, and leads to nausea, vomiting, paraesthesia, giddiness, convulsion, coma, respiratory failure, and congestive cardiac failure. Hepatic, renal and myocardial toxicity, agranulocytosis, aplastic anemia, cerebral edema, DIC, thrombocytopenia, and skin reaction also have been reported. Management includes decontamination of skin and gastrointestinal tract, supportive care including treatment of status epilepticus, dysrhythmias, and mechanical ventilation. Mortality and morbidity rates are very high and there is no specific antidote. Atropine and catecholamines should be avoided. 31. Moon JM, Chun BJ. Acute endosulfan poisoning: a retrospective study. Hum Exp Toxicol. 2009 May;28(5):309-16. PubMed PMID: 19755461. Endosulfan is a widely used insecticide that is associated with a high fatality rate in humans when ingested accidentally or with the aim of suicide. However, the literature concerning human endosulfan exposure is limited to case reports. Thus, we sought to 1) describe the clinical features of patients with acute endosulfan poisoning and 2) identify independent factors to predict patients' outcome. Fifty-two patients who presented with acute endosulfan poisoning between January 2001 and January 2007 were enrolled in this retrospective study. Sixteen (30.7%) of the 52 patients died, and 48 patients experienced seizures. Endosulfan poisoning caused the hypotension and the abnormalities on electrocardiogram at presentation. Over half of the patients developed complications, such as rhabdomyolysis, hepatic toxicity, and hypotension. These complications resolved without sequelae in the survival group. Refractory status epilepticus was the most common cause of death in this series (75.0%). Amount ingested being greater than 35 g of endosulfan was the most found to be an independent variable that predicted patient mortality. Patients with this risk factor must be treated aggressively during the early stage of endosulfan poisoning.

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32. Durukan P, Ozdemir C, Coskun R, Ikizceli I, Esmaoglu A, Kurtoglu S, Guven M. Experiences with endosulfan mass poisoning in rural areas. Eur J Emerg Med. 2009 Feb;16(1):53-6. PubMed PMID: 18931618. This paper describes very rare chemical poisoning and characteristics of patients with acute endosulfan mass poisoning in a rural area of Turkey and our experiences of these patients. We included 41 patients who were treated in our hospital with the diagnosis of endosulfan poisoning. After the first vital intervention they were examined in terms of age, sex, symptoms and physical examination findings, laboratory results, treatment and outcome. Forty-one patients were admitted to the emergency department (ED) after triage. Nineteen (46.3%) of the patients were female, 22 (53.7%) were male. The mean age was 27.9+/-16.0 years (1-67 years). The mean time to the ED was 4.1+/-0.9 h (3-6.5 h). The most common symptoms were anxiety (97.6%), nausea (56.1%) and vomiting (48.8%). Tests of the blood samples obtained at the ED revealed leucocytosis (11 070.6+/-4302.5/microl), increased blood glucose, LDH, CK and CK-MB levels. Toxicological analysis of blood and urine samples revealed endosulfan as the causative agent. Especially in the rural areas, cases with acute repetitive seizures should suggest endosulfan intoxication when the aetiology is uncertain even in the absence of any signs of intoxication. Health care professionals should understand the hazards associated with the pesticide use as well as diagnosis and treatment of these types of poisonings. 33. Ahmed T, Tripathi AK, Ahmed RS, Das S, Suke SG, Pathak R, Chakraboti A, Banerjee BD. Endosulfan-induced apoptosis and glutathione depletion in human peripheral blood mononuclear cells: Attenuation by N-acetylcysteine. J Biochem Mol Toxicol. 2008 Sep;22(5):299-304. PubMed PMID: 18972393. Present study investigated whether endosulfan, an organochlorine pesticide is able to deplete glutathione (GSH) and induce apoptosis in human peripheral blood mononuclear cells (PBMC) in vitro. The role of oxidative stress in the induction of apoptosis was also evaluated by the measurement of the GSH level in cell lysate. The protective role of N- acetylcysteine (NAC) on endosulfan-induced apoptosis was also studied. Isolated human PBMC were exposed to increasing concentrations (0-100 microM) of endosulfan (alpha/beta at 70:30 mixture) alone and in combination with NAC (20 microM) up to 24 h. Apoptotic cell death was determined by Annexin-V Cy3.18 binding and DNA fragmentation assays. Cellular GSH level was measured using dithionitrobenzene. Endosulfan at low concentrations, i.e., 5 and 10 microM, did not cause significant death during 6 h/12 h incubation, whereas a concentration-dependent cell death was observed at 24 h. DNA fragmentation analysis revealed no appreciable difference between control cells and 5 microM/10 microM endosulfan treated cells, where only high molecular weight DNA band was observed. Significant ladder formation was observed at higher concentration, which is indicative of apoptotic cell death. Intracellular GSH levels decreased significantly in endosulfan-treated cells in a dose-dependent manner, showing a close correlation between oxidative stress and degree of apoptosis of PBMC. Cotreatment with NAC attenuated GSH depletion as well as apoptosis. Our results provide experimental evidence of involvement of oxidative stress in endosulfan-mediated apoptosis in human PBMC in vitro. 34. Zhu Z, Edwards RJ, Boobis AR. Increased expression of histone proteins during estrogen-mediated cell proliferation. Environ Health Perspect. 2009 Jun;117(6):928-34. Epub 2009 Feb 7. PubMed PMID: 19590685; PubMed Central PMCID: PMC2702408.

BACKGROUND: There is concern about the potential risk posed by compounds with estrogen-like activity present in the environment. As previous studies have shown that combined exposure to such compounds results in dose additivity, it should be possible to assess estrogen exposure with suitable biomarkers of effect. OBJECTIVES: Our goal was to identify candidate protein biomarkers of effect for estrogenic compounds. METHODS: In the search for biomarkers, we assessed the effect of several estrogenic compounds on the expression profile of proteins in breast-derived cell lines varying in their estrogen receptor (ER) phenotype using surface-enhanced laser desorption/ionization time-of-flight mass spectrometry. We identified responsive proteins, after separating them by SDS-polyacrylamide gel electrophoresis, and analyzing the trypsin-digested proteins by tandem mass spectrometry. RESULTS: The estrogenic compounds 17beta-estradiol, genistein, bisphenol A, and endosulfan produced similar protein profile changes in MCF- 7 cells (phenotype: ERalpha(+)/ERbeta(+)), but had no effect on MDA-MB-231 (ERalpha(-)/ERbeta(+)), MCF-10F (ERalpha(-)/ERbeta(+)), or MCF-10A (ERalpha(-)/ERbeta(-)) cells. The most responsive proteins in MCF-7 cells were identified as histones H2A, H2B, H3, and H4. Histone levels were not increased in cell lines that showed no proliferative response to estrogens despite their rapid intrinsic growth rate in culture. CONCLUSION: Our results indicate that ER-mediated cell proliferation results in up-regulation of core histone proteins. 35. Ansari MI, Malik A. Genotoxicity of agricultural soils in the vicinity of industrial area. Mutat Res. 2009 Mar 17;673(2):124-32. Epub 2009 Jan 9. PubMed PMID: 19167512.

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Soil samples from agricultural fields (cultivated) in the vicinity of industrial area of Ghaziabad City (India) were collected. In this city, wastewater coming from both industrial and domestic sources and without any treatment is used to irrigate the food crops. This practice has been polluting the soil and pollutants might reach the food chain. Gas chromatographic analysis show the presence of certain organochlorine (DDE, DDT, dieldrin, aldrin and endosulfan) and organophosphorus (dimethoate, malathion, methylparathion and chlorpyrifos) pesticides in soil samples. Samples were extracted using different solvents, i.e. methanol, chloroform, acetonitrile, hexane and acetone (all were HPLC- grade, SRL, India), and the extracts were assayed for genotoxic potential using Ames Salmonella/microsome test, DNA repair defective mutants and bacteriophage lambda systems. TA98 and TA100 were found to be the most sensitive strains to all the soil extracts tested. Methanol extracts exhibited a maximum mutagenicity with TA98 strain {540 (-S9) and 638 (+S9) revertants/g of soil} and 938 (-S9) and 1008 (+S9) revertants/g of soil with TA100 strain. The damage in the DNA repair defective mutants was found maximum with methanolic extract followed by acetonitrile, chloroform, hexane and acetone at the dose level of 40 microl/ml culture after 6h of treatment. The survival was 25, 30, 32, 33 and 35% in polA strain after 6h of treatment when tested with wastewater irrigated soil extracts of methanol, acetonitrile, chloroform, hexane and acetone, respectively. A significant decrease in the plaque forming units of bacteriophage lambda was also observed when treated with 40 microl of test samples. Present results showed that methanolic extracts of soil were more toxic than other soil extracts. The soil is accumulating a large number of pollutants due to wastewater irrigation and this practice of accumulation has an impact on soil health. 36. Koç ND, Kayhan FE, Sesal C, Muşlu MN. Dose-dependent effects of endosulfan and malathion on adult Wistar albino rat ovaries. Pak J Biol Sci. 2009 Mar 15;12(6):498-503. PubMed PMID: 19579998. In this study, histological effects and malondialdehyde (MDA) levels were investigated by endosulfan and malathion in adult female rat ovaries. An increase of MDA level in rat ovarium tissues due to endosulfan and malathion may be an indicator of the free radicals occurred during the metabolism and their lipid peroxidative inducing damage. In this study in accordance with the biochemical findings, the study demonstrated that there are pronounced structural defects in histological examinations of ovarian tissues in rats which were administered endosulfan and malathion. It has been observed that the size of ovarian tissues of rats which were administered endosulfan and malathion in different doses was decreased in various levels. There was a significant decrease healthy follicles and a significant increase atretic follicles in low dose of endosulfan and malathion (11 mg kg(-1)) treated rats. The histologic observations of the ovary revealed the presence of less number of healthy follicles and more number of atretic follicles and corpus luteums in high dose of endosulfan and malathion (33 mg kg(-1)) treated rats. Finally, a peroxidative damage occurs inavitably due to endosulfan and malathion for ovarium tissues. The biochemical results (MDA levels) also showed such a damage, similar with the histological results. 37. Silva MH, Gammon D. An assessment of the developmental, reproductive, and neurotoxicity of endosulfan. Birth Defects Res B Dev Reprod Toxicol. 2009 Feb;86(1):1-28. Review. PubMed PMID: 19243027. BACKGROUND: Endosulfan has been used for over 50 years. Although most analogs have been discontinued, endosulfan has less environmental persistence. Nevertheless, pressure groups are lobbying for a worldwide ban. The reasons are: possible rodent male reproductive toxicity, other endocrine effects and cancer; human epidemiology, and exposure studies; residues appearing in remote areas of the world, e.g., the Arctic. METHODS: The endosulfan toxicology database is described and risks of its use assessed. RESULTS: Endosulfan is an antagonist at the GABA(A) receptor Cl(-) ionophore in mammalian CNS. Rat acute toxicity is moderate, LD(50)=48 (M) or 10 mg/kg/d (F), oral gavage; 130 (M), 70 mg/kg/d (F) dermal; LC(50)=34.5 microg/L (M), 12.6 microg/L (F), inhalation. Critical NOELs for risk assessment: acute oral (gavage)=0.7 mg/kg/d (rabbit developmental); Subchronic oral (diet)=1.2 mg/kg/d (rat reproduction); Chronic oral (diet)=0.6 mg/kg/d. There were no acceptable dermal toxicity studies. The critical acute and subchronic inhalation NOELs=0.001 mg/L, chronic inhalation=0.0001 mg/L (estimated). Toxicity to rat sperm occurred at doses causing neurotoxicity. Endocrine effects, resulting from P450 oxygenase(s) induction, were reversible. Increased cancer, genotoxicity, or histopathology in rodents was not observed in any organ. Possible effects on brain biogenic amine levels were probably secondary. CONCLUSIONS: Epidemiology and rodent studies suggesting autism and male reproductive toxicity are open to other interpretations. Developmental/ reproductive toxicity or endocrine disruption occurs only at doses causing neurotoxicity. Toxicity to the fetus or young animals is not more severe than that shown by adults. 38. Brunelli E, Bernabò I, Berg C, Lundstedt-Enkel K, Bonacci A, Tripepi S. Environmentally relevant concentrations of endosulfan impair development, metamorphosis and behaviour in Bufo bufo tadpoles. Aquat Toxicol. 2009 Jan 31;91(2):135-42. Epub 2008 Sep 18. PubMed PMID: 18950876.

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Endosulfan is a widely used organochlorine pesticide with well-documented neurotoxic effects in both humans and laboratory animals (mammals and fish). Neurotoxicity has been implied also in amphibians after short-term exposure to endosulfan. Little is known about effects of chronic exposure of endosulfan in amphibians. Previously, we examined the short-term toxicity of endosulfan in common toad (Bufo bufo) tadpoles and determined the LC50 value to 0.43 mg/L. In the present study, we investigated the effects of endosulfan on B. bufo tadpoles after chronic exposure to ecologically relevant concentrations. Tadpoles were exposed in a static renewal test, from shortly after hatching (Gosner stage 25) to completed metamorphosis, to 0.01, 0.05 and 0.1mg endosulfan/L (nominal). The exposure period lasted 43-52 days. Mortality, larval growth (mass), development (reached Gosner stage at various times and deformities presence), metamorphosis and behaviour (swimming activity) were monitored regularly over the entire course of larval development. Our results show that 0.05 and 0.1mg endosulfan/L caused impaired behaviour, prolonged time to metamorphosis, increased incidences of mouth and skeletal malformations as well as mortality, and reduced body weight (observed also at 0.01 mg/L) in B. bufo tadpoles. Behavioural effects occurred at exposure day 4, before any other effects occurred, indicating a neurotoxic effect. Endosulfan levels found in groundwater and surface water range from 0.1 to 100 microg/L and after extraordinary runoff events, concentrations exceed 0.5 mg/L in surface water. Our results indicate that endosulfan may negatively affect wild frog populations in agricultural areas. 39. Stoker C, Beldoménico PM, Bosquiazzo VL, Zayas MA, Rey F, Rodríguez H, Muñoz-de-Toro M, Luque EH. Developmental exposure to endocrine disruptor chemicals alters follicular dynamics and steroid levels in Caiman latirostris. Gen Comp Endocrinol. 2008 May 1;156(3):603-12. Epub 2008 Feb 29. PubMed PMID:18384790. Human and wildlife are exposed at critical periods of development to endocrine disruptor chemicals (EDC) that may be responsible for reproductive disorders. To test the hypothesis that in ovum exposure to EDC at a critical period for gonadal organogenesis alters post-hatching folliculogenesis and steroidogenesis in Caiman latirostris, we studied the impact of in ovum exposure to 17 beta-estradiol (E2), bisphenol A (BPA), endosulfan (END) and atrazine (ATZ) on gonadal differentiation, follicular dynamics and circulating levels of steroid hormones in neonatal and juvenile caiman. Since C. latirostris is a species with temperature dependent sex determination, eggs were incubated at male (33 degrees C) or female (30 degrees C) producing temperatures and the effect of EDC was evaluated. Neonatal ovaries exhibited germ cells mainly located in clusters evidencing proliferative activity and type I to III follicles. Juvenile ovaries exhibited germ cells and advanced stages of pre-vitellogenic follicles. Prenatal exposure to the highest doses of E2 (1.4 ppm) or BPA (140 ppm) overrode male temperature effect on sex determination. Neonatal females produced by sex reversion lacked type III follicles, while females prenatally exposed to the lowest doses of E2 (0.014 ppm) and BPA (1.4 ppm) or ATZ (0.2 ppm) showed an increase in type III follicles. Juvenile caiman prenatally exposed to E2 or BPA showed an augmented incidence of multioocyte follicles. Neonatal female caiman exposed in ovum to E2 or BPA had higher estrogen serum levels whereas exposure to E2, BPA, ATZ and END decreased T levels. Present data demonstrates that exposure to EDC during gonadal organogenesis alters follicular dynamics and steroid levels later in life. These effects might have an impact on caiman fertility. 40. Wu F, Khan S, Wu Q, Barhoumi R, Burghardt R, Safe S. Ligand structure-dependent activation of estrogen receptor alpha/Sp by estrogens and xenoestrogens. J Steroid Biochem Mol Biol. 2008 May;110(1-2):104-15. Epub 2008 Feb 23. PubMed PMID: 18400491; PubMed Central PMCID: PMC2519242. This study investigated the effects of E2, diethylstilbestrol (DES), antiestrogens, the phytoestrogen resveratrol, and the xenoestrogens octylphenol (OP), nonylphenol (NP), endosulfan, kepone, 2,3,4,5-tetrachlorobiphenyl-4-ol (HO-PCB- Cl(4)), bisphenol-A (BPA), and 2,2-bis-(p-hydroxyphenyl)-1,1,1-trichloroethane (HPTE) on induction of luciferase activity in breast cancer cells transfected with a construct (pSp1(3)) containing three tandem GC-rich Sp binding sites linked to luciferase and wild-type or variant ERalpha. The results showed that induction of luciferase activity was highly structure-dependent in both MCF-7 and MDA-MB-231 cells. Moreover, RNA interference assays using small inhibitory RNAs for Sp1, Sp3 and Sp4 also demonstrated structure-dependent differences in activation of ERalpha/Sp1, ERalpha/Sp3 and ERalpha/Sp4. These results demonstrate for the first time that various structural classes of ER ligands differentially activate wild-type and variant ERalpha/Sp-dependent transactivation, selectively use different Sp proteins, and exhibit selective ER modulator (SERM)-like activity. 41. Chatterjee S, Kumar V, Majumder CB, Roy P. Screening of some anti-progestin endocrine disruptors using a recombinant yeast based in vitro bioassay. Toxicol In Vitro. 2008 Apr;22(3):788-98. Epub 2007 Dec 25. PubMed PMID: 18262749. The present study was aimed to develop a sensitive, fast and user friendly progesterone receptor transactivation assay using recombinant yeast cells, Saccharomyces cerevisiae, modified to express human progesterone receptor (PR) and progesterone response element (PRE) driving the expression of green fluorescent protein. Stimulation of cells with

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increasing concentrations of progesterone resulted in significant elevation in fluorescence activity, with the minimum effective dose of progesterone being 0.1 nM. RU486, significantly inhibited progesterone induced transactivation and non-progesterogenic steroids failed to transactivate PR till 10 microM concentrations. About 7 different chemicals (mostly pesticides or their metabolites) like DDT and its metabolites, nonylphenol, endosulfan were screened in this assay system for their role in transactivation and they were all found to be anti-progestative and IC50 values within the range of 3-20 microM. Further, the assay was used to analyze the endocrine disrupting activity of extracted water samples from leather industries known for their high content of various chemicals and it was found to be rich in anti- progestative compounds. It resulted in about 30% reduction in transactivation. In conclusion, we demonstrated that this yeast based bioassay provides a rapid and robust assay for high throughput screening of (anti)progestative compounds from various sources. 42. Schoeters G, Den Hond E, Dhooge W, van Larebeke N, Leijs M. Endocrine disruptors and abnormalities of pubertal development. Basic Clin Pharmacol Toxicol. 2008 Feb;102(2):168-75. Review. PubMed PMID: 18226071. Onset and development of puberty is regulated by the neuroendocrine system. Population-based studies worldwide have observed secular trends towards earlier puberty development. These changes are apparently caused by environmental factors such as improved socio-economic status, improved health care and nutrition. However, they may also partly result from endocrine-disrupting chemicals in the environment. Epidemiological studies have investigated the relationship between pubertal development and exposure to endocrine-disrupting chemicals (polychlorinated biphenyls, polybrominated biphenyls, 1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane, phthalate esters, furans and the pesticide endosulfan). Associations with both perinatal and postnatal exposure have been reported. Studies in experimental animals support some of these findings and point to differential endocrine regulatory mechanisms linked to pubertal development acting in the perinatal and the pre-pubertal period. Pubertal development is naturally associated with growth and body composition. There is increasing evidence for a link between prenatal development and pubertal onset. In girls born small for gestational age (SGA), pubertal onset and age at menarche often are advanced, especially if there has been an extensive catch-up growth during the first months of life. In utero growth retardation may have multiple causes including exposure to xenobiotic substances as was suggested for some endocrine-disrupting chemicals. An abnormal perinatal environment of children born SGA may alter the endocrine status and the sensitivity of the receptors for endocrine and metabolic signalling that may have effects on maturation of brain and gonads. However, the causal pathways and the molecular mechanisms that may link the pubertal growth pattern of children born SGA, pubertal development and endocrine-disrupting chemicals need further study. 43. Roy JR, Chakraborty S, Chakraborty TR. Estrogen-like endocrine disrupting chemicals affecting puberty in humans--a review. Med Sci Monit. 2009 Jun;15(6):RA137-45. Review. PubMed PMID: 19478717. Estrogen-like endocrine disrupting chemicals (EEDC) are exogenous, man-made chemicals that alter the functions of the endocrine system and cause various health defects by interfering with the synthesis, metabolism, binding or cellular responses of natural estrogens. EEDCs have been found in various plastic products, flame retardants, pesticides and many other products that are needed for daily use. Some of the greatest effects of EEDCs are on puberty, a period of rapid physiological changes like growth spurt, maturation of the gonads and the brain. Estrogen, one of the key hormones required in puberty is crucial for the sexual differentiation. The structural similarity of estrogen disruptors with estrogen allow them to bind and activate estrogen receptors and show a similar response even in the absence of estrogen that can lead to precocious puberty (PP). Major EEDCs found abundantly in our environment include; dichlorodiphenyltrichloroethane (DDT), dioxin, polychlorinated biphenyls (PCBs), bisphenol A (BPA), polybrominated biphenyls (PBB), phthalate esters, endosulfan, atrazine and zeranol. In girls, DDT has been linked to earlier menarche. Dioxin causes abnormal breast development in pre-pubertal girls. BPA has shown to cause PP in pubertal girls. PBB causes earlier menarche, thelarche and earlier pubic hair stage in pubertal girls. PCB's showed a significant delay in puberty in pubertal boys. De-feminization, thelarche, or early secondary breast development are shown in pubertal girls when exposed to phthalate esters. Endosulfan affects pubertal boys by slowing down the timing of reproductive maturation. This article provides a possible structure-function relation of the above mentioned EEDCs which interfere with sexual development during puberty. 44. Fernandez MF, Olmos B, Granada A, López-Espinosa MJ, Molina-Molina JM, Fernandez JM, Cruz M, Olea-Serrano F, Olea N. Human exposure to endocrine-disrupting chemicals and prenatal risk factors for cryptorchidism and hypospadias: a nested case-control study. Environ Health Perspect. 2007 Dec;115 Suppl 1:8-14. PubMed PMID: 18174944; PubMed Central PMCID: PMC2174399. BACKGROUND: Exposure to xenoestrogens during pregnancy may disturb the development and function of male sexual organs. OBJECTIVE: In this study we aimed to determine whether the combined effect of environmental

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estrogens measured as total effective xenoestrogen burden (TEXB) is a risk factor for male urogenital malformations. METHODS: In a case-control study, nested in a mother-child cohort (n = 702) established at Granada University Hospital, we compared 50 newborns with diagnosis of cryptorchidism and/or hypospadias with 114 boys without malformations matched by gestational age, date of birth, and parity. Controls did not differ from the total cohort in confounding variables. TEXB and levels of 16 organochlorine pesticides were measured in placenta tissues. Characteristics of parents, pregnancy, and birth were gathered by questionnaire. We used conditional and unconditional regression models to estimate odds ratios (ORs) and 95% confidence intervals (CIs). RESULTS: TEXB from organohalogenated compounds was detectable in 72% and 54% of case and control placentas, respectively. Compared with controls, cases had an OR for detectable versus non-detectable TEXB of 2.82 (95% CI, 1.10-7.24). More pesticides were detected in cases than in controls (9.34 +/- 3.19 vs. 6.97 +/- 3.93). ORs for cases with detectable levels of pesticides, after adjusting for potential confounders in the conditional regression analysis, were o,p'-DDT (OR = 2.25; 95% CI, 1.03-4.89), p,p'-DDT (OR = 2.63; 95% CI, 1.21-5.72), lindane (OR = 3.38; 95% CI, 1.36-8.38), mirex (OR = 2.85; 95% CI, 1.22-6.66), and endosulfan alpha (OR = 2.19; 95% CI, 0.99-4.82). Engagement of mothers in agriculture (OR = 3.47; 95% CI, 1.33-9.03), fathers' occupational exposure to xenoestrogens (OR = 2.98; 95% CI, 1.11-8.01), and history of previous stillbirths (OR = 4.20; 95% CI, 1.11-16.66) were also associated with risk of malformations. CONCLUSIONS: We found an increased risk for male urogenital malformations related to the combined effect of environmental estrogens in placenta. 45. Lee HK, Moon JK, Chang CH, Choi H, Park HW, Park BS, Lee HS, Hwang EC, Lee YD, Liu KH, Kim JH. Stereoselective metabolism of endosulfan by human liver microsomes and human cytochrome P450 isoforms. Drug Metab Dispos. 2006 Jul;34(7):1090-5. Epub 2006 Mar 31. Erratum in: Drug Metab Dispos. 2007May;35(5):829-30. PubMed PMID: 16581944. Endosulfan (6,7,8,9,10,10-hexachloro-1,5,5a,6,9,9a-hexahydro-6,9-methano-2,3,4-benzo(e)dioxathiepin-3-oxide) is a broad-spectrum chlorinated cyclodiene insecticide. This study was performed to elucidate the stereoselective metabolism of endosulfan in human liver microsomes and to characterize the cytochrome P450 (P450) enzymes that are involved in the metabolism of endosulfan. Human liver microsomal incubation of endosulfan in the presence of NADPH resulted in the formation of the toxic metabolite, endosulfan sulfate. The intrinsic clearances (CL(int)) of endosulfan sulfate from beta-endosulfan were 3.5-fold higher than those from alpha-endosulfan, suggesting that beta- endosulfan would be cleared more rapidly than alpha-endosulfan. Correlation analysis between the known P450 enzyme activities and the rate of the formation of endosulfan sulfate in the 14 human liver microsomes showed that alpha-endosulfan metabolism is significantly correlated with CYP2B6-mediated bupropion hydroxylation and CYP3A- mediated midazolam hydroxylation, and that beta-endosulfan metabolism is correlated with CYP3A activity. The P450 isoform-selective inhibition study in human liver microsomes and the incubation study of cDNA-expressed enzymes also demonstrated that the stereoselective sulfonation of alpha-endosulfan is mediated by CYP2B6, CYP3A4, and CYP3A5, and that that of beta-endosulfan is transformed by CYP3A4 and CYP3A5. The total CL(int) values of endosulfan sulfate formation catalyzed by CYP3A4 and CYP3A5 were consistently higher for beta-endosulfan than for the alpha-form (CL(int) of 0.67 versus 10.46 microl/min/pmol P450, respectively). CYP2B6 enantioselectively metabolizes alpha-endosulfan, but not beta-endosulfan. These findings suggest that the CYP2B6 and CYP3A enzymes are major enzymes contributing to the stereoselective disposition of endosulfan. 46. Abadin HG, Chou CH, Llados FT. Health effects classification and its role in the derivation of minimal risk levels: immunological effects. Regul Toxicol Pharmacol. 2007 Apr;47(3):249-56. Epub 2006 Dec 27. PubMed PMID: 17194513. The Agency for Toxic Substances and Disease Registry (ATSDR) derives health-based guidance values known as minimal risk levels (MRLs). By definition, an MRL is a substance-specific estimate of the daily human exposure to a substance that is likely to be without an appreciable risk of adverse, noncancer effects over a specified duration of exposure. MRLs are preferentially derived from human studies, if available, or from the most sensitive animal species and the endpoint that is most relevant for humans. To date, the agency has derived 346 MRLs. Fifteen MRLs were derived for 11 different chemicals where the database has identified the immune system as the most sensitive target of toxicity. The chemicals include benzene, chlorfenvinphos, endosulfan, heptachlor, gamma-hexachlorocyclohexane, dibutyl tin, tributyl tin, PCBs, 2,3,4,7,8-pentachlorodibenzofuran, 2,3,7,8-tetrachlorodibenzo-p-dioxin, and 2,4- dichlorophenol. The agency's rationale for classification of immunological endpoints is discussed and a brief description given of the critical studies selected for MRL development using immune system endpoints. 47. Lee HK, Moon JK, Chang CH, Choi H, Park HW, Park BS, Lee HS, Hwang EC, Lee YD, Liu KH, Kim JH. Stereoselective metabolism of endosulfan by human liver microsomes and human cytochrome P450 isoforms. Drug

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Metab Dispos. 2006 Jul;34(7):1090-5. Epub 2006 Mar 31. Erratum in: Drug Metab Dispos. 2007May;35(5):829-30. PubMed PMID: 16581944. Endosulfan (6,7,8,9,10,10-hexachloro-1,5,5a,6,9,9a-hexahydro-6,9-methano-2,3,4-benzo(e)dioxathiepin-3-oxide) is a broad-spectrum chlorinated cyclodiene insecticide. This study was performed to elucidate the stereoselective metabolism of endosulfan in human liver microsomes and to characterize the cytochrome P450 (P450) enzymes that are involved in the metabolism of endosulfan. Human liver microsomal incubation of endosulfan in the presence of NADPH resulted in the formation of the toxic metabolite, endosulfan sulfate. The intrinsic clearances (CL(int)) of endosulfan sulfate from beta-endosulfan were 3.5-fold higher than those from alpha-endosulfan, suggesting that beta- endosulfan would be cleared more rapidly than alpha-endosulfan. Correlation analysis between the known P450 enzyme activities and the rate of the formation of endosulfan sulfate in the 14 human liver microsomes showed that alpha-endosulfan metabolism is significantly correlated with CYP2B6-mediated bupropion hydroxylation and CYP3A- mediated midazolam hydroxylation, and that beta-endosulfan metabolism is correlated with CYP3A activity. The P450 isoform-selective inhibition study in human liver microsomes and the incubation study of cDNA-expressed enzymes also demonstrated that the stereoselective sulfonation of alpha-endosulfan is mediated by CYP2B6, CYP3A4, and CYP3A5, and that that of beta-endosulfan is transformed by CYP3A4 and CYP3A5. The total CL(int) values of endosulfan sulfate formation catalyzed by CYP3A4 and CYP3A5 were consistently higher for beta-endosulfan than for the alpha-form (CL(int) of 0.67 versus 10.46 microl/min/pmol P450, respectively). CYP2B6 enantioselectively metabolizes alpha-endosulfan, but not beta-endosulfan. These findings suggest that the CYP2B6 and CYP3A enzymes are major enzymes contributing to the stereoselective disposition of endosulfan. 48. Watson CS, Bulayeva NN, Wozniak AL, Alyea RA. Xenoestrogens are potent activators of nongenomic estrogenic responses. Steroids. 2007 Feb;72(2):124-34.Epub 2006 Dec 18. PubMed PMID: 17174995; PubMed Central PMCID: PMC1862644. Studies of the nuclear transcriptional regulatory activities of non-physiological estrogens have not explained their actions in mediating endocrine disruption in animals and humans at the low concentrations widespread in the environment. However, xenoestrogens have rarely been tested for their ability to participate in the plethora of nongenomic steroid signaling pathways elucidated over the last several years. Here we review what is known about such responses in comparison to our recent evidence that xenoestrogens can rapidly and potently elicit signaling through nongenomic pathways culminating in functional endpoints. Both estradiol (E(2)) and compounds representing various classes of xenoestrogens (diethylstilbestrol, coumestrol, bisphenol A, DDE, nonylphenol, endosulfan, and dieldrin) act via a membrane version of the estrogen receptor-alpha on pituitary cells, and can provoke Ca(2+) influx via L-type channels, leading to prolactin (PRL) secretion. These hormones and mimetics can also cause the oscillating activation of extracellular regulated kinases (ERKs). However, individual estrogen mimetics differ in their potency and temporal phasing of these activations compared to each other and to E(2). It is perhaps in these ways that they disrupt some endocrine functions when acting in combination with physiological estrogens. Our quantitative assays allow comparison of these outcomes for each mimetic, and let us build a detailed picture of alternative signaling pathway usage. Such an understanding should allow us to determine the estrogenic or antiestrogenic potential of different types of xenoestrogens, and help us to develop strategies for preventing xenoestrogenic disruption of estrogen action in many tissues. 49. Jia Z, Misra HP. Reactive oxygen species in in vitro pesticide-induced neuronal cell (SH-SY5Y) cytotoxicity: role of NFkappaB and caspase-3. Free Radic Biol Med. 2007 Jan 15;42(2):288-98. Epub 2006 Oct 28. PubMed PMID: 17189834. Oxidative stress has been implicated in pesticide-induced neurotoxicity, based on its role in the cascade of biochemical changes that lead to dopaminergic neuronal cell death. We have, therefore, examined the role of oxidative stress caused by the pesticides endosulfan and zineb in human neuroblastoma cells (SH-SY5Y) in culture. Upon treatment with 50-200 microM concentrations of either of these pesticides, SH-SY5Y cells generated both superoxide anion and hydrogen peroxide in a dose-and time-dependent manner. Mixtures of the pesticides significantly enhanced the production of these reactive oxygen species compared to individual pesticide exposures. Pesticide treatment decreased superoxide dismutase, glutathione peroxidase, and catalase activities in SH-SY5Y cells. Additionally, these pesticides induced lipid peroxide (thiobarbituric acid reactive products) formation in these cells. While both pesticides individually (at 100 microM) increased caspase-3 activity, cells exposed to a mixture of the pesticides exhibited significantly low levels of this enzyme, probably due to excessive necrotic cell death. Furthermore, exposure to these pesticides increased nuclear NFkappaB activity. Taken together, these findings suggest that the cytotoxicity of endosulfan and zineb, both individually and in mixtures may, at least in part, be associated with the generation of reactive oxygen species with concomitant increased expression of NFkappaB.

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50. Bajpayee M, Pandey AK, Zaidi S, Musarrat J, Parmar D, Mathur N, Seth PK, Dhawan A. DNA damage and mutagenicity induced by endosulfan and its metabolites. Environ Mol Mutagen. 2006 Dec;47(9):682-92. PubMed PMID: 16933317. Endosulfan is a widely used broad-spectrum organochlorine pesticide, which acts as a contact and stomach poison. Nontarget species, such as cattle, fish, birds, and even humans, are also affected. Studies on the genotoxicity and mutagenicity of endosulfan have been inconsistent and nothing is known about the genotoxicity of its metabolites. In the present study, endosulfan (as a commercial isomeric mixture and as the alpha- and beta-isomers), and metabolites of endosulfan (the sulfate, lactone, ether, hydroxyether, and diol derivatives) were assayed for their ability to induce DNA damage in Chinese hamster ovary (CHO) cells and human lymphocytes using the Comet assay and were assayed for their mutagenicity using the Salmonella reversion assay (Ames test with TA98, TA97a, TA102, TA104, and TA100, with and without S9 activation). The compounds produced statistically significant (P < 0.01), concentration-dependent (0.25-10 microM) increases in DNA damage in both CHO cells and human lymphocytes. Endosulfan lactone caused the most DNA damage in CHO cells, while the isomeric mixture of endosulfan produced the greatest response in lymphocytes. The test compounds also were mutagenic in Salmonella strains at concentrations of 1-20 mug/plate (P < 0.05), with TA98 being the most sensitive strain and the diol and hydroxyether metabolites producing the highest responses. The results indicate that exposure to sublethal doses of endosulfan and its metabolites induces DNA damage and mutation. The contribution of the metabolites to the genotoxicity of the parent compound in Salmonella and mammalian cells, however, is unclear, and the pathways leading to bacterial mutation and mammalian cell DNA damage appear to differ. 51. Lee HK, Moon JK, Chang CH, Choi H, Park HW, Park BS, Lee HS, Hwang EC, Lee YD, Liu KH, Kim JH. Stereoselective metabolism of endosulfan by human liver microsomes and human cytochrome P450 isoforms. Drug Metab Dispos. 2006 Jul;34(7):1090-5. Epub 2006 Mar 31. Erratum in: Drug Metab Dispos. 2007May;35(5):829-30. PubMed PMID: 16581944. Endosulfan (6,7,8,9,10,10-hexachloro-1,5,5a,6,9,9a-hexahydro-6,9-methano-2,3,4-benzo(e)dioxathiepin-3-oxide) is a broad-spectrum chlorinated cyclodiene insecticide. This study was performed to elucidate the stereoselective metabolism of endosulfan in human liver microsomes and to characterize the cytochrome P450 (P450) enzymes that are involved in the metabolism of endosulfan. Human liver microsomal incubation of endosulfan in the presence of NADPH resulted in the formation of the toxic metabolite, endosulfan sulfate. The intrinsic clearances (CL(int)) of endosulfan sulfate from beta-endosulfan were 3.5-fold higher than those from alpha-endosulfan, suggesting that beta- endosulfan would be cleared more rapidly than alpha-endosulfan. Correlation analysis between the known P450 enzyme activities and the rate of the formation of endosulfan sulfate in the 14 human liver microsomes showed that alpha-endosulfan metabolism is significantly correlated with CYP2B6-mediated bupropion hydroxylation and CYP3A- mediated midazolam hydroxylation, and that beta-endosulfan metabolism is correlated with CYP3A activity. The P450 isoform-selective inhibition study in human liver microsomes and the incubation study of cDNA-expressed enzymes also demonstrated that the stereoselective sulfonation of alpha-endosulfan is mediated by CYP2B6, CYP3A4, and CYP3A5, and that that of beta-endosulfan is transformed by CYP3A4 and CYP3A5. The total CL(int) values of endosulfan sulfate formation catalyzed by CYP3A4 and CYP3A5 were consistently higher for beta-endosulfan than for the alpha-form (CL(int) of 0.67 versus 10.46 microl/min/pmol P450, respectively). CYP2B6 enantioselectively metabolizes alpha-endosulfan, but not beta-endosulfan. These findings suggest that the CYP2B6 and CYP3A enzymes are major enzymes contributing to the stereoselective disposition of endosulfan. Mixed exposure effects and additivity 52. Aggarwal M, Naraharisetti SB, Sarkar SN, Rao GS, Degen GH, Malik JK. Effects of subchronic coexposure to arsenic and endosulfan on the erythrocytes of broiler chickens: a biochemical study. Arch Environ Contam Toxicol. 2009 Jan;56(1):139-48. Epub 2008 Apr 29. PubMed PMID: 18443843. Arsenic is a known global groundwater contaminant. The organochlorine insecticide endosulfan has gained significance as an environmental pollutant due to its widespread use in the control of many food- and non-food-crop- damaging insects. The adverse effects produced by arsenic or endosulfan alone in humans and animals are well documented, but very little is known about the consequences of their coexposure. We evaluated whether their simultaneous exposure can induce oxidative stress and affect antioxidative systems and certain membrane-bound enzymes in erythrocytes of broiler chickens. Day-old chicks were exposed to 3.7 ppm of arsenic via drinking water or 30 ppm of endosulfan-mixed feed or similarly coexposed to these in the same dose levels for 60 days. At term, the impact of their coexposure was assessed by evaluating lipid peroxidation (LPO), activities of superoxide dismutase (SOD), catalase, glutathione peroxidase (GPx), glutathione-S-transferase (GST), different ATPases and

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acetylcholinesterase (AChE) in erythrocytes, serum glucose, and levels of glutathione (GSH) and glycosylated hemoglobin (GHb) in blood. LPO was increased with all of the treatments. Catalase was decreased with endosulfan and the coexposure, but not with arsenic, whereas GSH was decreased with arsenic and endosulfan, but not with the coexposure. All of the treatments increased SOD and GPx activities. GST activity was increased only in the coexposed birds. None of the treatments affected the activities of total ATPase and Mg2+-ATPase. Na+-K+-ATPase activity was decreased in the endosulfan-treated and the coexposed birds. All three exposures increased erythrocyte AChE activity. Endosulfan increased the serum glucose level and arsenic and endosulfan increased GHb levels, but these were not altered in the coexposed birds. Erythrocyte protein content was insignificantly decreased with these treatments. Overall, the effects of coexposure were not appreciably different from either of the agents, except on AChE, GSH, and glucose. The results do not reflect any specific type of interaction between these agents in chicken erythrocytes, but they do indicate that the coexposure induces a low level of oxidative stress, which is comparable to that induced by arsenic or endosulfan. 53. Aggarwal M, Naraharisetti SB, Dandapat S, Degen GH, Malik JK. Perturbations in immune responses induced by concurrent subchronic exposure to arsenic and endosulfan. Toxicology. 2008 Sep 29;251(1-3):51-60. Epub 2008 Jul 23. PubMed PMID: 18694802. The metalloid arsenic and the chlorinated insecticide endosulfan are common environmental contaminants. Humans, animals, and birds are exposed to these chemicals through water and food. Although health effects due to either arsenic or endosulfan exposure are documented, the toxicological impact of co-exposure to these environmental pollutants is unpredictable and unknown. The present study was undertaken to assess whether concurrent exposure to arsenic and endosulfan induces significant alterations in immunological functions. Day-old chicks were exposed to 3.7 ppm of arsenic via drinking water and to 30 ppm of endosulfan-mixed feed either individually or concurrently for up to 60 days. All the chicks were vaccinated with Ranikhet disease virus (F-strain; RD-F) on days 1 and 30. During the course of study and at term, parameters of cellular and humoral immunity were determined. None of the treatments altered the absolute body weight or body weight gain, except arsenic significantly reduced weight gain on day 60. Absolute, but not the relative, weights of spleen, thymus and bursa of Fabricius were significantly reduced in all the treatment groups. The metalloid and insecticide combination significantly depressed the ability of peripheral blood and splenic lymphocytes to proliferate in response to antigen RD-F and mitogen Con A. The delayed type hypersensitivity response to 2,4-dinitro-1-chlorobenzene or to PHA-P was also significantly decreased. Nitric oxide production by RD- F or lipopolysaccharide-stimulated peripheral blood and splenic mononuclear cells was significantly suppressed following concurrent exposure to arsenic and endosulfan. Furthermore, the combined exposure also decreased the antibody response to RD-F. The suppression of cellular and humoral immune responses was also evident following administration of individual compounds, and it was not exacerbated following concurrent exposure. To our knowledge, this is the first report describing the suppression of immune responses following exposure to arsenic alone or in combination with endosulfan at environmentally realistic concentrations in avian species. Therefore, immunotoxicological effects induced by concurrent exposure to arsenic and chlorinated pesticides should be considered when assessing the risk to human and animal health. 54. Zhu Z, Edwards RJ, Boobis AR. Proteomic analysis of human breast cell lines using SELDI-TOF MS shows that mixtures of estrogenic compounds exhibit simple similar action (concentration additivity). Toxicol Lett. 2008 Sep 26;181(2):93-103. Epub 2008 Jul 15. PubMed PMID: 18675332. Endocrine modulating chemicals in the environment are possible causative agents of a number of human diseases. Many of these compounds act on the same molecular target, and hence risk assessment requires consideration of their possible combined effects. Here, we studied the combined effects of 17beta-estradiol, genistein, bisphenol A and endosulfan on MCF-7 cells. Full concentration-effect curves for cell proliferation were obtained for each compound and used to identify appropriate concentrations for investigating the effects of binary mixtures of the compounds. Protein profiling by surface-enhanced laser desorption/ionization time of flight mass spectrometry was performed to identify responsive proteins. Treatment with each of the compounds produced similar protein profile changes. Prominent and consistent changes were seen in 12 protein ions. Cell proliferation and protein levels responded monotonically to the estrogens, with identifiable no observable effect concentrations in all cases. Binary mixtures of the compounds produced effects on cell proliferation and on each of the responsive protein ions that were fully consistent with concentration additivity. Thus, no reason to deviate from the application of the principles of dose- response and dose additivity in the risk assessment of combinations of estrogenic compounds was found in this study. 55. Jia Z, Misra HP. Exposure to mixtures of endosulfan and zineb induces apoptotic and necrotic cell death in SH-SY5Y neuroblastoma cells, in vitro. J Appl Toxicol. 2007 Sep-Oct;27(5):434-46. PubMed PMID: 17309119.

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A number of epidemiological studies have demonstrated a strong association between the incidence of Parkinson's disease and pesticide exposure. Earlier it was demonstrated that exposure to the pesticides endosulfan and zineb, alone and in combination, caused neurodegeneration in vivo. It was hypothesized that these pesticides cause neurotoxicity, in part, by enhancing apoptotic cell death. SH-SY5Y human neuroblastoma cells, which retain a catecholaminergic phenotype, were exposed to endosulfan, zineb or a combination of these chemicals, in vitro. For mixture studies, concentrations of pesticides (100 microM each) were chosen based on LC(25) (lethal concentration) that would result in minimum cell death. Exposure to a mixture of pesticides exhibited significantly (P < or = 0.05) higher toxicity than each one alone. Both pesticides were found to cause apoptotic cell death that was concentration (50-400 microM) dependent. A flow cytometric (7-aminoactinomycin D) assay was used to distinguish live, early apoptotic and late apoptotic/necrotic populations. Exposure to mixtures of the pesticides enhanced both early apoptosis and late apoptosis/necrosis compared with either chemical alone. Visual evaluation using a DNA ladder assay and a fluorescence Annexin V/PI assay confirmed the contribution of both apoptotic and necrotic processes. These findings suggest that the cytotoxicity of endosulfan and zineb, both individually and in mixtures, is associated with the occurrence of early and late apoptotic/necrotic processes in SH-SY5Y human neuroblastoma cells and support the contention that pesticide-induced neuronal cell death leading to neurodegenerative disease may, at least in part, be associated with early and late apoptosis of dopaminergic neurons. 56. Singh ND, Sharma AK, Dwivedi P, Patil RD, Kumar M. Citrinin and endosulfan induced teratogenic effects in Wistar rats. J Appl Toxicol. 2007Mar-Apr;27(2):143-51. PubMed PMID: 17186572. Dietary exposures to food pollutants such as mycotoxin(s) or pesticide(s) are most significant due to their adverse effects on the production and reproduction in animals and the human population. The present investigation was conducted to evaluate the teratogenic potential of citrinin (CIT) and endosulfan either alone or in combination in pregnant rats during gestational days 6-20. Endosulfan (1 mg kg(-1) body weight, by oral intubation) and CIT (10 mg kg(-1) feed, through diet) when administered either alone or in combination in pregnant rats caused significant teratogenic effects in the developing fetuses. There was no maternal mortality, however, reduced maternal weight gain and number of live fetuses and increased fetal resorptions were recorded in all the treated groups. The fetal body weights and crown to rump lengths were significantly decreased and the per cent gross, visceral and skeletal anomalies were significantly increased in the fetuses of dams of all the treated groups. The internal hydrocephalus, cerebellar hypoplasia, microphthalmia, contracted and notched kidneys, multilobulated liver, dilated renal pelvis, incomplete ossification of skull bones, rib anomalies and sacral and caudal vertebrae agenesis were the important fetal malformations. The occurrence of fetal gross, skeletal and visceral malformations was more severe in the combination group, suggesting an additive interaction of CIT and endosulfan in inducing developmental toxicity in Wistar rats. Switzerland No additional information on human health effects available. United States of America See section (g) (I) Other information requested by the POPRC Australia Adverse effects on human health (provided by the Australian Department of Health and Ageing, Office of Chemical Safety and Environmental Health) Exposure through certain conditions of use (e.g. lack of protective equipment), and ‘bystander’ exposure have been linked to congenital physical disorders, mental retardations and deaths in farm workers and villagers in developing countries in Africa, Asia and Latin America. A survey conducted by PAN Africa in Mali in 2001 of villages in 21 areas of Kita, Fana and Koutiala found a total 73 cases of pesticide poisoning and endosulfan was the main pesticide identified. Endosulfan was found among the most frequently reported intoxication incidents, adding unintentionally further evidence to its high toxicity for humans.

Endosulfan is highly acutely toxic via oral, dermal and inhalation routes of exposure. In laboratory animals, the LD50 of endosulfan varies widely depending on the route of administration, species, vehicle, and sex of the animal. The lowest oral -1 LD50 value is 9.6 mg kg bw in female Sprague-Dawley rats (Ratus norvegicus), and the lowest inhalation LC50 is 0.0126 mg L-1 (2.13 mg kg-1 bw) in female Wistar rats (R. norvegicus). Female rats are clearly more sensitive to endosulfan than male rats, and, on the basis of a single study, this sex difference appears to apply to mice also. Acute exposure to high doses of endosulfan results in hyperactivity, muscle tremors, ataxia, and convulsions.

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The primary effect of endosulfan, via oral and dermal routes of exposure, is on the central nervous system (CNS). Effects in laboratory animals as a result of acute, subchronic, developmental toxicity and chronic toxicity studies indicate that endosulfan causes neurotoxic effects, particularly convulsions, which may result from over stimulation of the CNS. Possible mechanisms of neurotoxicity include (a) alteration of neurotransmitter levels in brain areas by affecting synthesis, degradation, and/or rates of release and reuptake, and/or (b) interference with the binding of neurotransmitters to their receptors. Additional effects were noted in the liver, kidney, blood vessels and haematological parameters following repeated exposure to endosulfan. Long-term dietary studies in rodents indicated that endosulfan was not carcinogenic, it lacked genotoxicity in a range of tests, and it had no adverse effects on reproductive parameters. While evidence of delayed development was seen in rat foetuses, this was associated with maternotoxicity, and no treatment related teratogenicity was observed in any studies. In rats, the kidney appeared to be the main target in a number of studies. Renal effects seen included; increases in kidney weights and granular pigment formation after short-term administration, and progressive chronic glomerulonephrosis or toxic nephropathy after long-term exposure to endosulfan. The toxicology review noted that these renal findings are common in ageing laboratory rats and also occurred at a high incidence in non-exposed control animals. It is likely that endosulfan enhanced the aging effects. The lowest relevant NOAEL for endosulfan in laboratory animals is 0.6 mg kg-1 bw day-1. Several other published studies of interest include an oral study in rats with a NOEL of 0.3 mg/kg bw/day (LOEL 3 mg/kg bw/day) based on decreased body weight gain, testis weight, sperm count, sperm motility, and sperm abnormalities (Rao et al 2005), and a series of neurobehavioural studies in rats (Paul et al 1993, 1994, 1995) with a NOEL of 0.2 mg/kg bw/day (LOEL 2 mg/kg bw/day) based on reduced body weight, reduced food consumption, increased mortality, increased tremor intensity and increased liver enzyme activity. However, it was concluded from a subchronic neurotoxicity study (Sheets et al 2004, cited in Cal DPR 2008) and a developmental neurotoxicity study (Gilmore et al 2006) that there was no evidence that endosulfan induced developmental neurotoxicity in rats. In addition, there were no adverse effects in sperm parameters, testes weights or histopathology of the testes, ovary weights or other reproductive organs (Sheets et al 2004; Gilmore et al 2006). It was also concluded that increases in pituitary and uterine weights seen in a 2-generation reproductive study in rats were not of concern as these effects only occurred at the highest dose tested, 6.2 mg/kg bw/day (US EPA 2007). Degradation studies indicate that endosulfan is degraded into a large number of other metabolites, all of them retaining the endosulfan structure, and some of them showing significant toxicity while others do not. Regarding the metabolites, a particularly relevant study is the 90d toxicity study in rat dietary exposure on endosulfan-lactone, conducted by Langrand- Lerche (2003) and included in the EU dossier. The NOEC reported in this study is 0.6 mg kg-1 bw day-1, although mild effects in liver and kidney were observed at this dose. Evidence regarding genotoxicity is inconclusive. The assessments conducted by the EU, Canada or the United States of America concluded that endosulfan is not carcinogenic. However, Bajpayee et al., (2006) found that exposure to sublethal doses of endosulfan and its metabolites induce DNA damage and mutation. Although the contribution of the metabolites to the genotoxicity of the parent compound in bacteria (Salmonella spp.) and mammalian cells was unclear, and the pathways leading to bacterial mutation and mammalian cell DNA damage appeared to differ. It should be noticed that the toxicological reviews have been mostly conducted in the framework of the pesticides registrations in various countries. As a consequence, some specific issues, of particular relevance in the long-term exposure assessment of POP related characteristics received little attention. For example, in the rat chronic study, females from the high dose group had a reduced survival rate after 26 weeks (93% in controls, 74% in high dose) and 104 weeks (88% in controls, 46% in high dose). The deaths were predominantly associated with respiratory infections. This effect could be associated to the potential immunotoxicity of endosulfan that has been hypothesized in some studies. As the study was not designed for the specific assessment of these endpoint, relevant effects at low doses could remain unobserved and only dramatic effects (over 50% mortality was observed in this case) were evidenced. In some chronic toxicity studies, the concentrations of endosulfan and its metabolites were measured at the end of the study, but the limit of detection levels were too high and only endosulfan sulfate and occasionally endosulfan lactone, were above the quantification level. These limitations increase the uncertainty in the comparison of measured values in biota with the reported toxicological information. Contradictory opinions on the potential for endocrine disruption have been presented. Recent information indicates that endosulfan mimics non-uterotrophic E(2) actions, strengthening the hypothesis that endosulfan is a widespread xenoestrogen (Varayoud et al., 2008), acts via a membrane version of the estrogen receptor-α on pituitary cells and can

102 UNEP/POPS/POPRC.6/INF/24 provoke Ca++ influx via L-type channels, leading to prolactin (PRL) secretion (Watson et al., 2007), and is also anti- progestative (Chatterjee et al., 2008). More importantly, there is epidemiological data suggesting endocrine effects of endosulfan in humans. An epidemiological study by Saiyed et al (2003) assessed the potential effect of aerial spraying of endosulfan on sexual maturation in 117 male children. Endosulfan was sprayed 2-3 times per year for over 20 years on cashew nut plantations in India. Results showed that 78% of male children sampled had significant levels of endosulfan in their serum, as well as decreased testosterone levels and delayed sexual development. The authors of this study noted that to understand the implications of these results a larger sample size needs to be tested and a follow-up on all children involved should be performed. In an epidemiological study by Damgaard et al (2006), the association between exposure to organochlorine pesticides via human breast milk and cryptorchidism in male children was examined. This longitudinal birth cohort study, conducted in Finland and Denmark between 1997 and 2001 examined the regional prevalence rates and risk factors for cryptorchidism using questionnaires and biological samples including blood samples from both mother and child, as well as breast milk and placenta samples. The presence of organochlorine pesticides was determined in 62 breast milk samples from mothers of cryptorchidism boys and 68 from mothers of healthy boys. The study showed that 8 different organochlorine pesticides (including endosulfan) were quantifiable in all breast milk samples (control and case samples). It was shown that 17 pesticides were measured in slightly higher media concentrations in milk from mothers giving birth to cryptorhid boys than in mother giving birth to healthy boys, however these results did not reach statistical significance (except for trans- chlordane). Combined statistical analysis (a Monte Carlo permutation test) of the 8 most prevalent pesticides demonstrated that pesticide levels in breast milk were significantly higher in boys with cryptorchidism. From these results it can be concluded that although there is no association between exposure to individual organochlorine pesticides alone and cryptorchidism, there may be an association between exposure to more than one pesticide and cryptorchidism. Exposure to xenoestrogens during pregnancy and the development of male sexual organs was further examined in a case- control, nested mother-child cohort (n = 702) study by Fernandez et al (2007). In this study, the concentration of 16 organochlorine pesticides was measured in the placenta of 50 newborn boys with cryptorchidism and 114 newborn boys without malformations. Results showed that mothers working in agricultural settings, occupational exposure of fathers to xenoestrogens and a history of previous stillbirths were associated with an increased risk of urogenital malformations in boys. All placentas studied were positive for at least one pesticide. However a higher number of pesticides were detected in cases than in controls. Endosulfan was found in 52.4% of placentas examined, however there was no statistically significant difference in the mean concentration of endosulfan in control and case placentas. The authors of this study concluded that the combined effect of environmental estrogens is a risk factor for male urogenital malformations. The health standards including an acceptable Daily intake (ADI) and an acute reference dose (ARfD) have been established. An Acceptable Daily Intake (ADI, or Chronic Reference Dose in the US) of 0.006 mg/kg bw/day was established based on the NOAEL (or NOEL) of 0.6 mg/kg bw/day derived from a combined chronic toxicity / carcinogenicity study in rats and a safety factor of 100. It is based on reduced body weight gain, enlarged kidneys, increased incidences of marked progressive glomerulonephrosis; and blood vessel aneurysms in male rats seen at the LOAEL of 2.9 mg/kg bw/day. The acute reference dose (ARfD) for endosulfan of 0.02 mg/kg bw (0.015 mg/kg bw for the US) was established in 2000 and is derived from a NOEL of 2 mg/kg bw from a developmental study in rats. This NOEL is based on developmental effects, reduced food consumption and clinical signs (tonoclonic convulsions and hypersalivation. However, concerns have been arisen on residue levels of endosulfan in drinking water and food. There are potential mixer, loader, applicator as well as post-application exposures to occupational handlers. Based on current use patterns, there are some short-term dermal and inhalation risks of concern for workers who mix, load and apply endosulfan to agricultural sites, as well as to those workers who re-enter a treated area following application of endosulfan. Regulatory decisions have been made to mitigate these risks, for example, the US EPA mandated changes to packaging, deleted aerial application of WP products for some crops, and stipulated closed mixing/loading systems, closed cabs for air- blast equipment and restricted re-entry periods. References for adverse effects on human health information: California DPR. 2008. Endosulfan Risk Characterisation Document Volume 1 Medical Toxicology and Worker Health and Safety Branches. Department of Pesticide Regulation, California Environmental Protection Agency. Damgaard IN, Skakkebaek NE, Toppari J, Virtanen HE, Shen H, Schramm KW, Peterson JH, Jensen TK & Main KM. 2006. Persistent pesticides in human breast milk and cryptorchidism. Environ Health Perspect 114: 1133-1138.

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Fernandez MF, Olmos B, Granada A, Lopez-Epinosa MJ, Molina-Molina JM, Fernandez JM, Cruz M, Olea-Serrano F & Olea N. 2007. Human exposure to endocrine-disrupting chemicals and prenatal risk factors for cryptorchidism and hypospadias: a nested case-control study. Environ Health Perspect 115(Suppl 1): 8-14. Gilmore RG, Sheets LP & Hoss HE. 2006. A Developmental Neurotoxicity Study with Technical Grade Endosulfan in Wistar Rats. Bayer CropScience LP, Toxicology, Stilwell, KS; Report No. 201563; 26/9/06. DPR Volume/record #067070. Paul V, Easwaramoorthy B & Kazi M. 1994. The neurobehavioural toxicity of endosulfan: a serotonergic involvement in learning impairment. Euro J Pharmacol-Environ Toxicol Pharmacol 270: 1-7. Paul V, Easwaramoorthy B, Arumugam RJ & Kazi M. 1995. A sex-related difference in the neurobehavioural and hepatic effects following chronic endosulfan treatment in rats. Euro J Pharmacol-Environ Toxicol Pharmacol 293: 355-360. Paul V, Sheela S, Balasubramaniam E & Kazi M. 1993. Behavioural and biochemical changes produced by repeated oral administration of the insecticide endosulfan in immature rats. Indian J Physiol Pharmacol 37: 204-208. Rao M, Narayana K, Benjamin S & Bairy KL. 2005. L-ascorbic acid ameliorates postnatal endosulfan induced testicular damage in rats. Indian J Physiol Pharmacol 43(3): 331-336. Saiyed H, Dewan A, Bhatnagar B, Shenoy U, Shenoy R, Rajmohan H, Patel K, Kashyap R, Kulkarni P, Rajan B & Lakkad B. 2003. Effect of endosulfan on male reproductive development. Environ Health Perspect 11: 1958-1962. Sheets LP, Gilmore RG & Fickbohm BL. 2004. A Subchronic Neurotoxicity Screening Study with Technical Grade Endosulfan in Wistar Rats, Bayer, CropScience LP, Toxicology, Stilwell, KS; Lab ID#: 02-N72MJ; Report #: 201069; Report ID#: B004881. US EPA 2007. Endosulfan. Hazard Characterization and Endpoint Selection Reflecting Receipt of Developmental Neurotoxicity Study and Subchronic Neurotoxicity Study, Docket ID No. EPA-HQ-OPP-2002-0262-0065, April 2, 2007. Canada Please see attachment: a-endosulfan and b-endosulfan data from the Niagara River and Great Lakes. Great Lakes Data: Re: Lake Ontario, Lake Erie, Lake Huron, Georgian Bay, Lake Superior; The values included in this data set represent surface water measurements ( 0-3m). Organic contaminants are measured only in the spring, when the lakes are isothermal, and surface measurements are representative of the entire water column. Experience on Lakes Erie and Ontario in the early 1990s had demonstrated that there would be insufficient suspended particulate material (at least 10 g of SPM) for reliable, routine analyses of particulate phase concentrations (Williams et al 2001). As a result, only the dissolved phase has been analyzed for organic contaminants since 1995. Before 2003, large volume samples were collected during spring cruises and immediately centrifuged to separate the dissolved and particulate fractions, and the dissolved fraction only was extracted onboard using the Goulden large volume continuous extractor (Goulden 1985). Extracts were stored at 4°C, and returned to the Canada Centre for Inland Waters (CCIW), Environment Canada’s facilities in Burlington, Ontario, for analysis. Since 2003, a specialized, clean sampler has been used to collect the samples from surface waters instead. This sampler, called the PoPCart, was developed by Environment Canada and consists of a Grundfos groundwater pump fitted with Teflon-lined flexible hosing attached to a filter system and bottle-filling station. All components are contained within a stainless steel cart to mitigate contamination. The system uses no valves, quick-connects, no contact with any lubricants. The system is a direct in-line flow, so that there is no opportunity for external contamination. Sixteen litre samples are collected from the lower Great Lakes and 24 L samples are collected from the upper Lakes for analysis. Samples are collected into 4 L amber glass bottles and are stabilized with dichloromethane (DCM; 50 mL DCM per four litres of sample) immediately upon collection. Samples are stored on the ship and returned to CCIW for extraction and analysis in an ultra-trace clean laboratory. Liquid-liquid extraction is conducted with the Goulden large volume continuous extractor.

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Niagara on the Lake Station Location: The station is located on the Canadian side of the river about 2.5 kilometres upstream of Lake Ontario. The sampling equipment is situated in a lighthouse at the foot of Collingwood St. Water and suspended sediment samples are collected biweekly and analysed for a suite environmental parameters. Fort Erie Station Location: The station is located on the Canadian side of the river about 0.25 kilometres downstream of the international railroad bridge. The sampling equipment is housed in a mobile trailer at the foot of Jarvis St. Water and suspended sediment samples are collected biweekly and analysed for a suite environmental parameters. The Niagara River has a significant influence on Lake Ontario; it is responsible for more than 83% of the total tributary inflow to the lake, 85% of the total input water budget, and about 50% of all incoming fine grained sediment. Because of this influence, Environment Canada established a monitoring station in 1975 at the mouth of the Niagara River at Niagara- on-the-Lake (NOTL) to estimate the annual chemical loads and changes/trends in these loads from the river to Lake Ontario. A second station was established at the head of the Niagara River at Fort Erie (FE) in October 1983, to estimate the loads of chemicals to the river from Lake Erie. This Upstream/Downstream Program, as it became known, was a key component of the Niagara River Long Term Monitoring Plan recommended by the Niagara River Toxics Committee. It has been formally incorporated into the Niagara River Toxics Management Plan (NRTMP) to determine whether concentrations of specified chemicals at NOTL are statistically different from concentrations at FE, and to assess trends over time. Concentrations and loads have been summarised in annual data reports by the River Monitoring Committee and a trend report summarising changes in contaminants over the 1986 – 1997 period was released by Environment Canada in 2000. Sampling procedures and analytical methodologies for the Upstream/Downstream Program have been documented thoroughly (NRAP 1992; NRSP 1995; Data Interpretation Group 1997; Data Interpretation Group 1999, NRAP 2000, NRSP 2003, SOP 06-6001); however, in general, the Upstream/Downstream Program measures the concentrations of trace metals in whole water and trace organic contaminants in both water and suspended solids. Over the eleven-year period 1986/87 – 1996/97, sampling was conducted weekly. Since that time, the sampling frequency has been bi-weekly. Sampling times at the two stations are offset by approximately 15-18 hours to allow for the travel time of water between the head and mouth of the river. India POPRC member from India Dr.G.K Pandey had at the POPRC-4 & 5 submitted a dissent note. Information therein may be considered. Similarly the Conference Room Paper submitted by India at the COP-4 shall also be considered. This has following annexures: Dissent notes submitted during POPRC-4 and POPRC 5------Annexure II and III Confrence Room Paper (UNEP/POPS/POPRC-4/CRP.9) ------Annexure IV Monaco It is recalled that the Principality of Monaco and France are a Customs Union. Therefore, pesticides and other chemicals whose sales are prohibited in France can not be imported and sold in Monaco.

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ANNEX-I Analysis of benefit costs of restricting endosulfan use on strawberries provided by Canada:

Impact Analysis: Use of Endosulfan on Strawberries (July 25, 2008) Issue: Estimated impacts to Ontario growers of restricting endosulfan use on strawberries as a case study for the use of applied economic analysis in PMRA re-evaluation activities. Context and Purpose: In 2007, the PMRA published a Preliminary Risk and Value Assessmentclxvii of endosulfan that indicated a level of concern for workers and proposed the pesticide as a Track 1 substance under the federal Toxic Substances Management Policy. The Agency sought information from stakeholders on the use and importance of endosulfan for a broad range of commodities, and noted the possibility of a long-term phase-out (“virtual elimination”) should the Track 1 status of endosulfan be confirmed. Publication of the Preliminary Risk and Value Assessment document followed the release in 2004 of an Interim Mitigation Measures documentclxviii. In this document the Agency proposed implementation of a number of measures in advance of completing a full re-evaluation of endosulfan, as a precautionary approach to mitigate potential worker and environmental risks. The mitigation measures proposed included the introduction of a maximum rate per application of 1.1 kg active ingredient per hectare for strawberries and a maximum seasonal application rate of 2.2 kg active ingredient per hectare for strawberries (i.e., 2 applications at 1.1 kg ai/ha).clxix In submissions to PMRA with respect to the Preliminary Risk and Value Assessment, the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) and the Ontario Berry Growers Association provided details on the importance of endosulfan for the strawberry industry, given the limited number of currently registered alternative products available for the control of key pestsclxx; specifically: • tarnished plant bug, restriction on the use of endosulfan would lead to greater reliance on the use of synthetic pyrethroids, increasing the risk of mite outbreaks and pest resistance. • cyclamen mite is a sporadic but important pest. Growers noted that the most likely alternative, abamectin, is significantly more expensive and regard the product as less effective than endosulfan. The purpose of this analysis is to examine the potential per hectare and Ontario-wide impacts associated with the possible restriction of endosulfan on strawberries. The analysis focuses on the impact to strawberry growers of implementing the application limits for endosulfan proposed in the 2004 Interim Mitigation Measures document and, for illustrative purposes, also explores a more restrictive scenario. Scope of Analysis and Limitations The main questions are to what extent restricting endosulfan use on strawberries would: increase production costs and decrease net cash returns due to the expected shift to the use of a higher cost alternative product; and reduce the overall quantity of endosulfan used on strawberries in Ontario. Limitations in the analysis need to be acknowledged, including the following: • strawberry production is a complex system that can be influenced by a variety of parameters, such as weather and variable pest pressure across regions and over time. • information on the use of the alternative product (abamectin) for the control of cyclamen mite is limited. Growers have minimal experience with the use of the product to control this pest, and have expressed concern that it may not provide comparable control. This uncertainty is addressed by testing impacts if more than one application of the alternative product (abamectin) is required to achieve comparable control. • the analysis focuses on short-term (i.e., one year) impacts. However, reliance on a single product or chemistry elevates the risk of resistance which, while difficult to predict, can lead to adverse impacts on yield and revenue.

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Commercial Strawberry Production Strawberries are an important fruit crop that can be grown successfully in many parts of the country. The farm gate value of strawberries in Canada totalled $60.5 million in 2007, with almost 5,000 hectares under cultivation. Quebec and Ontario accounted for nearly 75% of production nationally ($25M and $20M respectively).clxxi Exports of fresh, frozen, and processed strawberries totalled almost $3 million in 2006. An export market also exists for Canadian strawberry plants in the United States. Strawberry plants produce well for several years but fruit size tends to decline over time. Plants do not bear fruit in their establishment year and are usually replaced after three seasons of bearing fruit. In a typical operation, strawberries tend to be one of several fruit and vegetable crops under cultivation. Only three strawberry growers in Ontario have operations exceeding 30 hectares; the remainder are much smaller in size. The proportion of pick-your-own, wholesale, and grower retail (e.g., roadside or farmer’s market) sales is unclear, although some suggest that grower retail is gaining popularity because of its higher potential profitability. Most strawberries grown in Canada are June-bearing varieties picked in June and July. The matted row system continues to be the most common production method. There is growing interest in cultivation of “day-neutral” varieties, since these varieties can produce berries continuously over a growing season, although less than 80 hectares are currently cultivated in Ontario. Early growing and late harvest varieties can enable growers to extend the harvest period from June until late summer. Berry prices vary considerably depending on location and time of year: producing an earlier crop than competitors (e.g., through use of plastic sheeting to accelerate growth) can command high prices; while prices drop in mid-harvest when supply is high. Key Pests Controlled by Endosulfanclxxii Tarnished Plant Bug Tarnished plant bug is a major pest of strawberries. Tarnished plant bugs are a true bug with piercing/sucking mouth parts that pierce plant tissue. Adults are greenish or brownish with a yellow triangular mark on the wing. They are 6 to 6.5 mm long and become active in early to mid-May. Adults overwinter in protected areas such as leaf litter and plant debris. Females lay 5 eggs per day over 10 to 31 days in grasses, broadleaf weeds and strawberry plants. Eggs hatch into nymphs and nymphs undergo five instars before becoming adults in 12-34 days. There are 2 to 3 generations of tarnished plant bug per year. Both the adults and nymphs feed on strawberry flowers and fruit beginning before bloom through to petal fall. Feeding can cause strawberry flowers to die or cause fruit to be severely deformed called apical seediness or cat-facing. Monitoring Monitoring begins when nymphs first appear, usually around first bloom and continue every 3-4 days from start of bloom until harvest begins. Varieties that flower later tend to have higher populations of nymphs and a higher potential risk of injury. Sequential sampling is used to determine if the population has exceeded the economic threshold. Insecticide is applied when the number of infested clusters is equal to or more than the “above threshold” number. Applying an insecticide as soon as this threshold is reached will result in less than 2% severely cat-faced fruit. If insecticide applications are delayed for 3-5 days after the threshold is reached, the percentage of cat-faced fruit could increase to 5%. Tarnished Plant Bug Control Currently, endosulfan is used at a rate of 1 kg ai/haclxxiii to control tarnished plant bug. Two applications of endosulfan at this rate are allowed per season and effectively control tarnished plant bug. The most commonly used alternative for tarnished plant bug control is the use of pyrethroids which offer effective control. However, the repeated use of pyrethroids can lead to resistance problems. When endosulfan is applied to control tarnished plant bugs, it also controls other insect pests, including mites. Pyrethroids do not have the same broadspectrum control and their repeated use can lead to mite outbreaks. Cyclamen Mites Cyclamen mites are very small and cannot be seen with the naked eye. The adults are oval, pinkish orange and shiny while the nymphs are more translucent. Cyclamen mites overwinter as adult females in the strawberry crown. The mites prefer high humidity so when the leaflets unfold the change in temperature and humidity cause the mites to migrate down the petiole to new leaflets. There are multiple generations per season and newly hatched mites develop into adults within two weeks. Females can produce eggs without males which can lead to rapid growth in their numbers. They feed on the growing point of the strawberry plant. Strawberry plants infested with cyclamen mites are stunted with wrinkled, distorted leaves. This injury can be confused with herbicide or winter injury. The fruit on infested plants is small, bronzed and has prominent

107 UNEP/POPS/POPRC.6/INF/24 seeds. If left uncontrolled, it can prevent new growth and severely affect fruit quality. Cyclamen mites are easily spread to clean plants by workers and tools. Monitoring Monitoring should be done through the season by walking the field looking for signs of damage. If damage is suspected, the newest leaves in the crown should be pinched out and the mid vein and lower leaf should be examined. Since cyclamen mites cannot be viewed by the naked eye samples should be viewed under a microscope at 30 to 40 times magnification. Cyclamen Mite Control Currently, growers use endosulfan at a rate of 2 kg ai/ha to control cyclamen mite. The proposed mitigation measures for endosulfan recommend removing this high rate for endosulfan from the label. Abamectin is the alternative for cyclamen mite control and its registration was recently amended to include both pre-harvest and post-harvest applications. A drawback to the use of abamectin is that it is over 5 times more expensive to use per application than endosulfan to control cyclamen mites. Abamectin may not be as effective as endosulfan for the control of cyclamen mites. Resistance may become an issue when using only one product to control a pest. If both cyclamen mites and two-spotted spider mites are present, then abamectin is the product that is expected to be used even with the registration of endosulfan. Aphids Nymphs of aphids overwinter in strawberry crowns or weeds. Aphids move to strawberry plants when the weeds are removed in the spring. Aphids are most abundant in the spring when plants are rapidly growing. Aphids are small, soft- bodied, pear-shaped insects. Aphids reproduce rapidly and produce multiple generations per year. Aphid nymphs look very similar to tarnished plant bug nymphs and can be distinguished by their slow movement and cornicles (backward-pointing “tubes”) found near the end of the aphid. Aphids suck plant sap which removes nutrients and can reduce yields. In some cases, aphids can also cause disease. Symptoms of damage include leaf discolouration and dying or dead patches in the field. Monitoring Monitoring should be done through the season by walking the field looking for signs of damage. Severe infestations are often easily visible from the edge of the field. Later in the season, infested patches may appear as thin stands. Monitoring for aphids can be done at the same time as monitoring for tarnished plant bugs. Aphid Control The applications of endosulfan for the control of tarnished plant bugs will also control aphids in strawberries. Endosulfan use is important in plant propagation in order to control aphids and prevent the spread of viruses. It is very important in plant propagation to ensure that the planting stock is clean. Endosulfan Use Estimate for Ontario (2007) In correspondence to PMRA, OMAFRA provided estimates of the percent crop treated with endosulfan to control for key pests: specifically, tarnished plant bug and cyclamen mite. An overall estimate of the quantity of endosulfan used can be extrapolated from these figures, based on the percent crop treated, different application rates for these pests, and Statistics Canada data on hectares of bearing area for strawberries in Ontario. Table 2: Estimated Endosulfan Use on Strawberries in Ontario (2007). Pest Hectares Estimated Bearing Application Number of Pest Pressure Requiring Quantity Used Area (ha) Rate(kg ai/ha) Applications (%) Control (ha) (kg) Tarnished 1,453 100 1,453 1 1 - 2 1,453 - 2,906 plant bug Cyclamen 1,453 25 - 40 363 - 581 2 1 726 - 1,162 mite Total Estimated Quantity Used (kg) 2,179 - 4,068

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Assumptions: · Total strawberry bearing area in Ontario: 1,453 hectares (StatsCan, 2007). · Endosulfan use: 2-3 applications per season, of which 1-2 for tarnished plant bug, and where 25%-40% of growers apply endosulfan to control for cyclamen mite (OMAFRA estimate). Impact of Endosulfan Use Restrictions on Strawberries Per Hectare Economic Assessment “Sample budget” information published by OMAFRA on expected costs and revenues for strawberry production served as a starting point for the analysis. Production costs of a matted row method of production, which represents the most widespread production method for strawberries in the province, were assumed. An OMAFRA official provided a “best estimate” of typical pesticide products and number of applications commonly used in order to add precision to a baseline budget. Fixed costs such as financing/interest costs for land are excluded, since these tend to fluctuate considerably from farm to farm. Costs incurred in the establishment year (when plants do not bear fruit and therefore do not generate revenue) are assumed to be absorbed by revenues generated during the three subsequent harvest years.clxxiv Expected costs were adjusted to 2007 values using Statistic Canada’s Farm Input Price Index. The cost of pesticides was based on prices quoted in a price guide published by a large Ontario distributor. It was also assumed that growers received $2 per quart for their strawberries. Annex A sets out detailed information on baseline input costs for scenario one. The discussion below sets out potential impacts associated with two endosulfan restriction scenarios. In each, the per hectare impacts for a “hypothetical” grower, are discussed based on assumptions regarding this grower’s current use of endosulfan and crop pest pressure. Scenario One: Seasonal Endosulfan Restriction to Two Applications of 1 kg a.i./ha (2 kg ai/ha total) Under this scenario, seasonal application limits proposed in the 2004 Interim Mitigation Measures document are assumed to have come into force. Impacts associated with the other mitigation measures proposed in the document (i.e., increased re- entry intervals, vegetative buffer strips) were not considered for the purpose of analysis. This scenario allows the use of two applications of endosulfan at a maximum application rate of 1 kg ai/ha. The main impact under this scenario would be the loss of endosulfan for the control of cyclamen mite (i.e., removal of the 2 kg ai/ha rate). Since the current label allows for the use of two applications of endosulfan at 1 kg ai/ha for tarnished plant bug, there would presumably be no change in control strategy or costs with respect to the control of tarnished plant bug. In order to estimate per hectare impacts for illustrative purposes, a “base case” where both cyclamen mite and tarnished plant bug require control is outlined. In the scenario, it is assumed that a grower would replace the use of endosulfan with abamectin to control cyclamen mites, with other costs remaining unchanged. Minimal grower experience in using abamectin for the control of cyclamen mite makes a precise determination of impacts difficult. Table 2 estimates impacts under two assumptions: comparable control of cyclamen mites with one application of abamectin; and comparable control with two applications of abamectin. Grower impact: Under these assumptions, expected total pesticide costs would increase 22.8% and net cash returns would be reduced by 6.2% if one application of abamectin is used, whereas expected total pesticide costs would increase by 50.3% and net cash returns would be reduced by 13.6% if two applications of abamectin are required. Table 3: Impact of Restricting Endosulfan Use to Two Applications of 1 kg a.i./ha. Agri-Mek (Abamectin) used to control cyclamen mites Base Comparable control with 1 Comparable control with 2

Scenario application applications $ % change $ % change Production (qt/ha) 14,826.00 14,826.00 14,826.00 Gross Returns (assuming 29,652.00 29,652.00 29,652.00 $2/qt)

Control of Tarnished

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Plant Bug Thiodan - Endosulfan 77.26 77.26 77.26 Control of Cyclamen

Mites Thiodan - Endosulfan 77.26 Agri-Mek - Abamectin 453.25 486.7 906.50 1,073.3 Other Pesticide Costs 1,494.95 1,494.95 1,494.95 ($/ha) Total Pesticide Costs 1,649.47 2,025.46 22.8 2,478.71 50.3 ($/ha) Other Harvest Costs ($/ha) 18,093.57 18,093.57 18,093.57 Total Operating Costs 19,743.04 20,119.03 1.9 20,572.28 4.2 ($/ha) Establishment Costs ($/ha) 3,800.99 3,800.99 3,800.99 Net Cash Return ($/ha) 6,107.97 5,731.98 -6.2 5,278.73 -13.6

Limitations of per hectare analysis In the per hectare analysis, it is assumed that growers will replace the application of endosulfan at 2 kg ai/ha with either one application or two applications of abamectin to control cyclamen mites. On a cost basis, one application of endosulfan at 2 kg ai/ha ($77.26) is significantly less expensive than one application ($453.25) or two applications ($906.25) of abamectin. Therefore, the control of cyclamen mites would significantly increase the total pesticide cost and would be the driver in the reduction of net return. The assumption that the shift to abamectin would entail comparable control of cyclamen mite – especially under different levels of pest pressure – may not be valid. For example, it is possible that control of cyclamen mite at low- to mid-pressure may be adequate, but control at high pressure levels could be reduced. Reduced control of cyclamen mite could result in yield loss and therefore trigger reduced grower net revenues beyond the amounts identified in Table 2. [Reliance on a single product – in this case abamectin – for the control of a pest could lead to the risk of resistance. However, it is unclear whether overall resistance risk actually increases under this scenario. Due to the low price of endosulfan and greater grower experience with this pesticide, endosulfan is effectively the “single product” currently used to control this pest. Resistance risk can therefore only be said to increase if the chemistry of abamectin is such that pests are more likely to develop resistance to this product as opposed to endosulfan.] Strawberry plant propagation operations – There are several considerations of note regarding propagation plants and the need to retain the 2 kg ai/ha application to control for cyclamen mites at strawberry plant propagation operations: • Two such operations exist in Ontario, which in addition to selling plants domestically also export plants to the US, principally Florida. Strawberry crops in the US typically experience greater mite pressure than those in Canada because of the warmer climate and, as a result, US growers prefer to purchase plants that have not already been treated with miticide in order to mitigate resistance risk. Loss of endosulfan for the control of cyclamen mites in propagation stock intended for US export could therefore adversely affect this market segment.clxxv • With respect to propagation stock intended for domestic cultivation, the continued ability for plant propagation operations to use endosulfan at the high rate (2 kg ai/ha) for the control of cyclamen mite, though limited in terms of the total amount/quantity likely to be used, would ensure clean stock and potentially help diminish the risk of mite problems once plants are planted by growers. • Aphids are of concern in these operations since they can spread viruses to strawberry plants which can reduce yields.

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Scenario Two: Seasonal Endosulfan Restriction to One Application of 1 kg a.i./ha This scenario assumes that the use of endosulfan had been restricted further. In this scenario, growers would be restricted to one application of endosulfan at 1 kg ai/ha per season, as compared to the two applications of endosulfan at 1 kg ai/ha per season assumed in scenario one. Two main impacts can be expected from such restriction: greater reliance on pyrethroids for the control of tarnished plant bug; and the prospect of mite outbreaks (including cyclamen mite and two-spotted spider mite) arising from the use of pyrethroids, for which abamectin would be relied upon for control. In this scenario, it is assumed that the grower would apply the permitted one application of endosulfan and substitute a second application of endosulfan with two applications of pyrethroids to control tarnished plant bug. Since pyrethroids are regarded as having a shorter residual than endosulfan, it is assumed that one application of endosulfan would have to be replaced with two applications of pyrethroids in order to achieve a comparable level of control. The scenario also assumes that mite outbreaks (i.e., two-spotted spider mites and cyclamen mites) would be controlled with either one or two applications of abamectin. Grower Impact – Under these assumptions, expected total pesticide costs would increase 30.9% and net cash returns would be reduced by 7.9% if one application of abamectin is used to control a mite outbreak, whereas expected total pesticide costs would increase by 59.8% and net cash returns would be reduced by 15.2% if two applications of abamectin are required. Table 4: Impact of Restricting Endosulfan Use to One Application of 1 kg a.i./ha. Mite Pressure - Agri-Mek (Abamectin) used to control cyclamen mites Base Scenario (no mite Comparable control with 1 Comparable control with 2 pressure) application applications $ % change $ % change Production (qt/ha) 14,826.00 14,826.00 14,826.00 Gross Returns (assuming 29,652.00 29,652.00 29,652.00 $2/qt) Control of Tarnished

Plant Bug Thiodan - Endosulfan 77.26 38.63 38.63 Ripcord-Cypermethrin 71.90 71.90 Control of Cyclamen

Mites Agri-Mek - Abamectin 453.25 906.50 Other Pesticide Costs 1,494.95 1,494.95 1,494.95 ($/ha) Total Pesticide Costs 1,572.21 2058.73 30.9 2,511.98 59.8 ($/ha) Other Harvest Costs 18,093.57 18,093.57 18,093.57 ($/ha) Total Operating Costs 19,665.78 20,152.30 2.5 20,605.55 4.8 ($/ha) Establishment Costs 3,800.99 3800.99 3800.99 ($/ha) Net Cash Return ($/ha) 6,185.23 5,698.71 -7.9 5,245.46 -15.2

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Limitations of per hectare Analysis In the per hectare analysis, it is assumed that the grower will replace the second application of endosulfan with two applications of a pyrethroid in order to control tarnished plant bugs. On a cost basis, one application of endosulfan ($38.63) is slightly more expensive than one application of a pyrethroid ($35.95). Therefore, two applications of a pyrethroid ($71.90) will not increase the total pesticide cost significantly. Endosulfan has been used to control both tarnished plant bugs and cyclamen mites unlike pyrethroids which only control tarnished plant bugs. The increased use of pyrethroids may lead to mite outbreaks which will need to be controlled using abamectin. Table 3 compares the cost of using 1 application versus the cost of using 2 applications of abamectin to control mites. An application of abamectin ($453.25) is expensive and two applications ($906.50) are very expensive. Therefore, the control of cyclamen mites would significantly increase the total pesticide cost and would be the main driver in the reduction of net return. It is also uncertain whether the frequency and extent of mite outbreaks will increase with the continued use of pyrethroids or if there will be any issues arising from the use of a single product to control the mites. Both factors could raise negative impacts on a regional basis that are not captured by the analysis. Potential Estimated Endosulfan Use Reduction in Ontario The estimates outlined below are based on estimates of endosulfan use provided by an OMAFRA official (see discussion on page 6) and reflect the potential overall reduction in endosulfan use associated with the two endosulfan application restriction scenarios already discussed. Cyclamen Mites Assuming 25% to 40% of bearing hectares per year are treated with one application of endosulfan for the control of cyclamen mites, the elimination of the use of endosulfan for the control of cyclamen mites would lead to a reduction in the total estimated quantity of endosulfan used on strawberries of between 28% and 33% (726 kg to 1162 kg). Tarnished Plant Bug It is unclear how frequently growers apply two applications of endosulfan for the control of tarnished plant bugs. Therefore, the elimination of one application of endosulfan at 1 kg ai/ha may lead to between 0% and 36% (0 to 1453 kg) reduction in the amount of endosulfan used since those that were only using one application would still be allowed to apply one application but those that were using two applications would have to reduce their use by one application. Total Potential Reduction Given the uncertainties regarding the number of applications of endosulfan used, the following total potential reduction is possible: • The reduction in the amount of endosulfan used in Ontario could be as high as 2615kg (assuming that the reduction for cyclamen mites is 1162kg (40% of growers no longer spray endosulfan for cyclamen mites) and assuming that the reduction for tarnished plant bug is 1453 kg (removal of one application); and • The reduction in the amount of endosulfan used in Ontario could be as low as 726 kg (assuming that only 25% of growers used endosulfan for the control of cyclamen mites) and assuming that there is no reduction in applications for the control of tarnished plant bug because growers only applied one application of endosulfan. Conclusion Applied analysis can serve to inform decision-making by estimating the potential tradeoffs of a regulatory decision under consideration – e.g., the negative economic impacts on growers versus a reduction in use of a product. This document has explored the potential impacts on growers associated with a restriction on the use of endosulfan and the anticipated shift to the use of other alternatives for the control of tarnished plant bugs and mites. Such analysis is speculative and hinges on the validity of the assumptions made; efforts were therefore made to identify limitations in order to encourage further discussion. The utility of the estimates provided in this document is an outstanding question for discussion, given the uncertainty surrounding the use pattern of the product and its alternatives and the frequency of pest outbreaks.

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Annex A: Commercial Strawberry Budget - Baseline data for Scenario One

Number of Hectares = 1

Expected Revenues

Yield (qts) 14,826

Price ($/qt) 2.00

Total Expected Revenues ($) 29,652.00

Annual Production Costs Unit Number Cost/Unit $/Hectare

Seasonal Labour hours 1,103.08 9.18 10,122.29

Operator Labour hours 65.48 13.21 865.17

Fertilizers:

Ammonium Nitrate kg or L 247.11 0.565 139.66

Muriate of Potash kg or L 98.84 0.358 35.35

Pesticides:

Insecticide - Thiodan (TPB) (endosulfan) kg or L 2.00 38.63 77.26

Insecticide - Thiodan (CM) (endosulfan) kg or L 1.00 77.26 77.26

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Insecticide - Furadan (SCW) kg or L 1.00 44.66 44.66

Fungicide - Maestro kg or L 2.00 65.66 131.32

Fungicide - Pristine (new) kg or L 2.00 222.40 444.80

Herbicide - Dacthal (pre-emergent) kg or L 1.00 787.73 787.73

Herbicide - Venture (grass) kg or L 1.00 65.40 65.40

Herbicide - 2,4-D (emerged) kg or L 1.00 7.54 7.54

Herbicide - 2,4-D (renovation) kg or L 1.00 13.50 13.50

Other Expenses:

Straw tonnes 7.41 71.69 531.48

Crop Insurance $ 1.00 690.17 690.17

Irrigation times 4.00 265.74 1,062.96

Custom Work, Rentals:

Comfort Station Rental number 2.00 29.87 59.75

Containers number 14,826.00 0.25 3,720.27

Fuel $ 679.36

Machinery Repair & Maintenance $ 187.11

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Total Annual Production Expenses $ 19,743.04

Total Establishment Expenses/3 * $ 3,800.99

Total Expenses $ 23,544.03

Net Revenues per hectare $ 6,107.97

* It is assumed that costs incurred in the establishment year (when plants do not yield fruit/generate revenue) are absorbed out of gross revenues over the course of the three subsequent years during which plants bear fruit and thus generate revenues. This is a simplification as most growers will replace a portion of plants at the end of each season; however, doing so serves to avoid overstating revenues in the model.

ANNEX-II Annex F information provided by Colombia – restriction, prohibition and suspension of registered plant protection products with endosulfan as active ingedient for use in agriculture in Colombia.

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i http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/tabid/588/mctl/ViewDetails/EventMod ID/871/EventID/69/xmid/2107/language/en-US/Default.aspx ii http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5Followupcommunications/En dosulfanAnnexFadversehumanhealtheffects/tabid/655/language/en-US/Default.aspx iiihttp://www.comlaw.gov.au/ComLaw/Legislation/ActCompilation1.nsf/current/bytitle/A06DDA96E680781ECA257312008 2EBE6?OpenDocument&mostrecent=1 iv http://www.apvma.gov.au/products/review/completed/endosulfan.php v http://www.apvma.gov.au/products/review/docs/endosulfan_final_summary.pdf vi http://www.apvma.gov.au/products/review/docs/endosulfan_user_brochure.pdf vii http://www.apvma.gov.au/products/review/docs/endosulfan_user_brochure.pdf viii http://www.apvma.gov.au/products/restricted.php ix MOEW – Ministry of Environment and Water of Bulgaria x EEA – Executive Environmental Agency at MOEW xi RIEW- Regional Inspectorate of Environment and Water at MOEW xii SG – State Gazette xiii UNEP/POPS/POPRC.5/3. xiv Stockholm Convention POPs Review Committee. 2009. General guidance on considerations related to alternatives and substitutes for persistent organic pollutants. UNEP/POPS/POPRC.5/L.1/Add.3. xv Nair SK. 2009. Does Endosulfan have an alternative? Non Pesticidal Management – A large-scale success story from Andhra Pradesh, India. IPEN, and Thanal, Thiruvananthapuram. http://thanal.co.in/files/enabavi-final-report-may.pdf. xvi PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. xvii Manuweera G, Eddleston M, Egodage S, Buckley NA. 2008. Do targeted bans of insecticides to prevent deaths from self- poisoning result in reduced agricultural output? Environ Health Perspect 116(4):492-5. 125

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xviii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.panna.org/files/Folleto%20resumen%20Endosulfan%20ing.pdf. xix Jia H, Li Y-F, Wang D, Cai D, Yang M, Ma J, Hu J. 2009. Endosulfan in China 1—gridded usage inventories. Environ Sci Pollut Res 16:295-301. xx UNEP/POPS/POPRC.5/CRP.7/Rev.1. xxi UNEP-POPS-POPRC.5-ENDOSU-PANAP-20080601.pdf xxii PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. xxiii Nair SK. 2009. Does Endosulfan have an alternative? Non Pesticidal Management – A large-scale success story from Andhra Pradesh, India. IPEN, and Thanal, Thiruvananthapuram. http://thanal.co.in/files/enabavi-final-report-may.pdf. xxiv Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. xxv Manuweera G, Eddleston M, Egodage S, Buckley NA. 2008. Do targeted bans of insecticides to prevent deaths from self- poisoning result in reduced agricultural output? Environ Health Perspect 116(4):492-5. xxvi Fay, H. 1997. Egg parasites for fruit spotting bug control. HRDC Final Report HG308. xxvii Baker, J.T., Blake, J.D., MacLeod, J.K., Ironside, D.A., and Johnson, I.C. 1972. The volatile constituents of the scent gland reservoir of the fruit-spotting bug, Amblypelta nitida. Aust. J. Chem. 25:393-400. xxviii http://www.ars.usda.gov/is/pr/2009/090313.htm. xxix Aldrich, J.R., Waite, G.K., Moore, C.J., Payne, J.A., Lusby, W.R., and Kochansky, J.P. 1993. Male-specific volatiles from Nearctic and Australasian true bugs (Heteroptera: Coreidae and Alydidae). J. Chem. Ecol. 19:2767-2781. xxx Williams et al. 2009. IPM and supply chain improvements for mangoes in the Philippines and Australia. ACIAR Final Report FR2009-27 xxxi PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf xxxii PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. xxxiii PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf xxxiv Subramani MR. 2008. India tops in world organic cotton output. The Hindu Business Line. Nov 1st. http://www.blonnet.com/2008/11/01/stories/2008110150302100.htm. xxxv Subramani MR. 2008. India tops in world organic cotton output. The Hindu Business Line. Nov 1st. http://www.blonnet.com/2008/11/01/stories/2008110150302100.htm. xxxvi Eyhorn F. 2007. Organic farming for sustainable livelihoods in developing countries? The case of cotton in India. vdf Hochschulverlag AG. ISBN:978-3-7281-3111-9. xxxvii Eyhorn F, Ratter SG, Ramakrishnan M. 2005. Organic Cotton Crop Guide. A manual for practitioners in the tropics. FiBL, 1st edition, 2005, ISBN 978-3-906081-67-0. xxxviii PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. xxxix Bissdorf JK. 2008. How to Grow Crops Without Endosulfan. Pesticide Action Network (PAN) Germany, Hamburg. http://www.oisat.org/downloads/field_guide_without_endosulfan.pdf. xl Bissdorf JK. 2005. Field Guide to Non-chemical Pest Management in Cotton Production. Pesticide Action Network (PAN) Germany, Hamburg. http://www.oisat.org/downloads/field_guide_cotton.pdf. xli Bissdorf JK. 2005. Field Guide to Non-chemical Pest Management in Cotton Production. Pesticide Action Network (PAN) Germany, Hamburg. http://www.oisat.org/downloads/field_guide_cotton.pdf.

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xlii U.S.EPA. 2002. Reregistration Eligibility Decision for Endosulfan. http://www.epa.gov/pesticides/reregistration/REDs/endosulfan_red.pdf. xliii U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry Intervals and Eliminating Aerial Spraying for Endosulfan on Cotton (DP# 358333). Document ID No. EPAHQ OPP 2002 0262 0112, April 16, 2009. xliv U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry Intervals and Eliminating Aerial Spraying for Endosulfan on Cotton (DP# 358333). Document ID No. EPAHQ OPP 2002 0262 0112, April 16, 2009. xlv California Pesticide Use Reporting Database: http://pesticideinfo.org/List_CA_Chem_Use.jsp?chk=259&cok=00&sk=29121 xlvi U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry Intervals and Eliminating Aerial Spraying for Endosulfan on Cotton (DP# 358333). Document ID No. EPAHQOPP 2002 0262 0112, April 16, 2009. xlvii Chen Yinfang. 2005. Stop using endosulfan and its strategies. Guangdong Tea 5: 20-21. xlviii Shi Chunhua. 2006. The status quo, problems and countermeasures in application of endosulfan. Journal of Tea 32(1):36- 37. xlix Tea export face new barriers in North Fujian http://www.fj.xinhuanet.com/dszx/2005- 10/25/content_5426970.htm. l Pesticide alternatives to endosulfan. http://www.qhd.heagri.gov.cn/qinhd/inc/detail.jsp?id=15867&typeid=102. li Indigenous Methods of Tea Pests Management. http://www.tangkou.gov.cn/DocHtml/1/2009/8/6/20090806954506139.html. lii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. liii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. liv Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lv Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lvi Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lvii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lviii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lix U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry Intervals for Endosulfan on Potato (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0111, March 16, 2009. lx U.S. EPA. 2009. Assessment of the Impact on Producers of Extending the Restricted Entry Intervals for Endosulfan on Cucumber (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0114, April 17, 2009. 127

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lxi U.S. EPA. 2009. Assessment of the Impact on Producers of Melons of Extending the REI for Endosulfan (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0115, April 17, 2009. lxii U.S. EPA. 2009. Assessment of Benefits of Endosulfan to Producers of Pumpkins (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0116, April 17, 2009. lxiii U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry for Endosulfan on Squash (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0117, April 17, 2009. lxiv U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxv U.S. EPA. 2009. Assessment of the Impact on Producers of Extending the Restricted Entry Intervals for Endosulfan on Cucumber (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0114, April 17, 2009. lxvi U.S. EPA. 2009. Assessment of Benefits of Endosulfan to Producers of Pumpkins (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0116, April 17, 2009. lxvii U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxviii Pesticideinfo.org, “Pesticide Use in California: Endosulfan on Tomatoes” http://pesticideinfo.org/List_CA_Chem_Use.jsp?chk=259&cok=00&sk=11005,29136,11008 lxix U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxx U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxxi U.S. EPA. 2002. Biological and Economic Analysis of Endosulfan Benefits on Selected Crops: Impacts of a Cancellation. Document ID No. EPA-HQ-OPP-2002-0262-0016, July 12, 2002. lxxii U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxxiii U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxxiv U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxxv Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives _english.pdf. lxxvi U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry for the Use of Endosulfan on Apples (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0113, April 17, 2009. lxxvii U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry for the Use of Endosulfan on Apples (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0113, April 17, 2009. lxxviii Please note that it is not PAN and IPEN proposing the alternative chemicals, but the sources cited, and they are included here to demonstrate that cost-effective endosulfan alternatives are available in India. lxxix Recommended PP Chemicals, Bio-Pesticides and Micronutrients by the Expert Committee 2008-09. Annexure –I. http://india.gov.in/allimpfrms/alldocs/10051.pdf. NB: the URL does not open directly. It can be accessed at http://india.gov.in/citizen/agriculture/agri_cont_doc.php, scroll down to Orissa in the left column and find the document titled “Use of pesticides Recommended by Expert Committee 2008-09”. lxxx Castor Semilooper [Achaea janata, Parallelia algira]. Taking Roots, Farming Sustainable Way. India. http://www.takingroots.in/ipm_castor_semilooper. lxxxi Stem borer in finger millet. The Hindu. Thursday, January 25, 2001. http://www.hindu.com/2001/01/25/stories/0825002d.htm. lxxxii Millet Research Station, Junagadh Agricultural University Jamnagar-6. http://www.jau.in/res_millet.asp. lxxxiii Astridge, D. (2008) New pesticide application methods; Investigating environmentally friendly methods of pesticide application for insecticide reduction. In Mango Matters, Autumn 2008 p18-20 lxxxiv Stockholm Convention POPs Review Committee. 2009. General guidance on considerations related to alternatives and substitutes for persistent organic pollutants. UNEP/POPS/POPRC.5/L.1/Add.3.

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lxxxv U.S. EPA. 2009. Quantitative Impact Assessment for the use of Endosulfan on Fresh and Processed Tomatoes (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0119, April 17, 2009. lxxxvi PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. lxxxvii Nair SK. 2009. Does Endosulfan have an alternative? Non Pesticidal Management – A large-scale success story from Andhra Pradesh, India. IPEN, and Thanal, Thiruvananthapuram. http://thanal.co.in/files/enabavi-final-report-may.pdf. lxxxviii Manuweera G, Eddleston M, Egodage S, Buckley NA. 2008. Do targeted bans of insecticides to prevent deaths from self-poisoning result in reduced agricultural output? Environ Health Perspect 116(4):492-5. lxxxix Eyhorn F. 2007. Organic farming for sustainable livelihoods in developing countries? The case of cotton in India. vdf Hochschulverlag AG p.106-107. ISBN:978-3-7281-3111-9. xc Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. xci Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. xcii Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. xciii Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. xciv Stockholm Convention POPs Review Committee. 2009. General guidance on considerations related to alternatives and substitutes for persistent organic pollutants. UNEP/POPS/POPRC.5/L.1/Add.3. xcv Manuweera G, Eddleston M, Egodage S, Buckley NA. 2008. Do targeted bans of insecticides to prevent deaths from self- poisoning result in reduced agricultural output? Environ Health Perspect 116(4):492-5. xcvi PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. xcvii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives_english.pdf. xcviii Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives_english.pdf. xcix U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry for the Use of Endosulfan on Apples (DP# 358333). Document ID No. EPA HQ OPP 2002 0262 0113, April 17, 2009. c Bejarano et al. 2009. Alternatives to Endosulfan in Latin America. International POPs Elimination Network (IPEN) and Pesticide Action Network in Latin America (Red de Acción sobre Plaguicidas y sus Alternativas en América Latina, RAP- AL). http://www.ipen.org/ipenweb/documents/ipen%20documents/summary%20endosulfan%20alternatives_english.pdf. ci Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. cii UNEP-POPS-POPRC.5-ENDOSU-PANAP-20080601.pdf ciii Kishi M. 2002. Initial Summary of the Main Factors Contributing to Incidents of Acute Pesticide Poisoning. Report to IFCS Forum Standing Committee Working Group. civ Roberts DM, Karunarathna A, Buckley NA, Manuweera G, Sheriff MH, Eddleston M. 2003. Influence of pesticide regulation on acute poisoning deaths in Sri Lanka. Bull World Health Organ 81(11):789-98. cv Wesseling C, Corriols M, Bravo V. 2005. Acute pesticide poisoning and pesticide registration in Central America. Toxicol Appl Pharmacol 207(2 Suppl 1):697-705. cvi Glin LJ, Kuiseau J, Thiam A, Vodouhe DS, Dinham B, Ferrigno S. 2006. Living with Poison: Problems of Endosulfan in West Africa Cotton Growing Systems. Pesticide Action Network UK, London. http://www.pan-uk.org/. cvii GFEA-U. 2007. Endosulfan. Draft Dossier prepared in support of a proposal of endosulfan to be considered as a candidate for inclusion in the CLRTAP protocol on persistent organic pollutants. German Federal Environment Agency – Umweltbundesamt, Berlin.

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cviii PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN). http://www.ipen.org/ipenweb/documents/ipen%20documents/endosulfan_wa_cop4.pdf. cix Quijano RF. 2002. Endosulfan Poisoning in Kasargod, Kerala, India: Report on a Fact-Finding Mission. Pesticide Action Network Asia and the Pacific, Penang. http://www.panap.net/uploads/media/endosulfan_report_Kerala.pdf. cx NIOH. 2003. Final Report of the Investigation of Unusual Illnesses Allegedly Produced by Endosulfan Exposure In Padre Village of Kasargod District (N Kerala). National Institute of Occupational Health, Indian Council for Medical Research, Ahmedabad. cxi Mathew R. Endosulfan: panel for more studies. The Hindu. December 13, 2009. http://www.thehindu.com/2009/12/13/stories/2009121355420100.htm. cxii Mathew R. 2009. Endosulfan trauma still haunts them. The Hindu, October 26. http://www.thehindu.com/2009/10/26/stories/2009102657570700.htm. cxiii Special Correspondent. 2009. Yeddyurappa for ban on use of endosulfan in the legislature. The Hindu. Bangalore. December 24. http://www.thehinudu.com/2009/12/24/stories/2009122454210400.htm cxiv NRS Annual Reports containing these statistics for 2004-2005 to 2008-2009 are available at: www.daff.gov.au/agriculture-food/nrs/publications/annual-reports. cxv The LOR is the minimum concentration of a residue used for reporting purposes by NRS. Typically, the LOR is set at 10- 20% of the respective Australian maximum residue limit (MRL), which for endosulfan is 0.2 mg/kg. The MRL is the maximum concentration legally permitted or recognised as acceptable in or on a food, agricultural commodity or animal feed. Australian MRLs are listed in Section 1.4.2 of the Australian Food Standards Code www.foodstandards.gov.au/foodstandards/foodstandardscode/standard142maximumre4244.cfm cxvi U.S. EPA. 2001. EFED Risk Assessment for the Reregistration Eligibility Decision on Endosulfan. Document ID No. EPA-HQ-OPP-2002-0262-0066, April 13, 2001. cxvii UNEP/FAO. 2006. Endosulfan. Documentation received from the European Commission to support its notification of final regulatory action on endosulfan. United Nations Environment Programme and Food and Agriculture Organisation. UNEP/FAO/RC/CRC.3/10/Add.1. http://www.pic.int/incs/crc3/j10-add1)/English/K0654655%20CRC3-10-ADD-1%20final.pdf. cxviii Decourtye A, Devillers J, Genecque E, Le Menach K, Budzinski H, Cluzeau S, Pham-Delegue MH. 2005. Comparative sublethal toxicity of nine pesticides on olfactory learning performances of the honeybee Apis mellifera. Arch Environ Contam Toxicol 48(2):242-50. cxix Health Canada. 2009. Re-evaluation of Endosulfan Interim Mitigation Measures. Rev2009-03, April 15, 2009. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_rev2009-03/endosulfan-eng.php. cxx Washington State Department of Agriculture. 2009. Pollinator Protection Requirements for Section 18 Emergency Exemptions and Section 24(C) Special Local Need Registrations Washington State. June 17, 2009. http://www.agr.wa.gov/pestfert/Pesticides/docs/PollinatorSLNSect18.pdf. cxxi “Thionex 3EC Insecticide” specimen label. http://www.cdms.net/LDat/ld5Q1022.pdf; “Thionex 50W Insecticide” specimen label, http://www.cdms.net/LDat/ld5Q2002.pdf. Both viewed December 15, 2009. cxxii Mossler M, Aerts MJ, Nesheim ON. 2006. Florida Crop/Pest Management Profiles: Tomatoes. CIR 1238, University of Florida, Institute for Food and Agricultural Science, March 2006. http://edis.ifas.ufl.edu/pdffiles/PI/PI03900.pdf. cxxiii Bastos CS, de Almeida RP, Suinaga FA. 2006. Selectivity of pesticides used on cotton (Gossypium hirsutum) to Trichogramma pretiosum reared on two laboratory-reared hosts. Pest Manag Sci 62:91–8. cxxiv Bostanian NJ, Akalach M. 2004. The contact toxicity of indoxacarb and five other insecticides to Orius insidiosus (Hemiptera: Anthocoridae) and Aphidius colemani (: ), beneficials used in the greenhouse industry. Pest Manag Sci 60(12):1231-6. cxxv Elzen GW. 2001. Lethal and sublethal effects of insecticide residues on Orius insidiosus (Hemiptera: Anthocoridae) and Geocoris punctipes (Hemiptera: Lygaeidae). J Econ Entomol 94(1):55-9. cxxvi Bostanian NJ, Akalach M. 2006. The effect of indoxacarb and five other insecticides on Phytoseiulus persimilis (Acari: Phytoseiidae), Amblyseius fallacis (Acari: Phytoseiidae) and nymphs of Orius insidiosus (Hemiptera: Anthocoridae). Pest Manag Sci 62:334–9.

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cxxvii Schneider MI, Pineda P, Smagghe G. 2006. Side effects of conventional and non-conventional insecticides on eggs and larvae of Chrysoperla externa (Hagen) (Neuroptera: Chrysopidae) in Argentine. Commun Agric Appl Biol Sci 71(2 Pt B):425-7. cxxviii Benamú MA, Schneider MI, Pineda S, Sanchez NE, Gonzalez A. 2007. Sublethal effects of two neurotoxican insecticides on Araneus pratensis (Araneae: Araneidae). Commun Agric Appl Biol Sci 72(3):557-9. cxxix Alizadeh A, Samih MA, Izadi H. 2007. Compatibility of Verticillium lecani (Zimm.) with several pesticides. Commun Agric Appl Biol Sci 72(4):1011-5. cxxx Health Canada. 2009. Re-evaluation of Endosulfan Interim Mitigation Measures. Rev2009-03, April 15, 2009. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_rev2009-03/endosulfaneng.php. cxxxi Choo LPD, Baker GH. 1998. Influence of four commonly used pesticides on the survival, growth, and reproduction of the earthworm Aporrectodea trapezoides (Lumbricidae). Aust J Agric Res 49(8):1297–303. cxxxii Vig K, Singh DK, Agarwal HC, Dhawan AK, Dureja P. 2008. Soil microorganisms in cotton fields sequentially treated with insecticides. Ecotoxicol Environ Saf 69(2):263-76. cxxxiii Joy VC, Chakravorty PP. 1991. Impact of insecticide on nontarget microarthropod fauna in agricultural soil. Ecotoxicol Environ Saf 22(1):8-16). cxxxiv U.S. EPA. 2009. Assessment of the Impacts of Extending the Restricted Entry Intervals and Eliminating Aerial Spraying for Endosulfan on Cotton (DP# 358333). Document ID No. EPAHQ OPP 2002 0262 0112, April 16, 2009. cxxxv Whalon ME, Mota-Sanchez D, Hollingworth RM, Duynslager L. 2004-09. Arthropod Pesticide Resistance Database. Michigan State University. http://www.pesticideresistance.org/. cxxxvi Whalon ME, Mota-Sanchez D, Hollingworth RM, Duynslager L. 2004-09. Arthropod Pesticide Resistance Database. Michigan State University. http://www.pesticideresistance.org/. cxxxvii Health Canada. 2009. Re-evaluation of Endosulfan Interim Mitigation Measures. Rev2009-03, April 15, 2009. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_rev2009-03/endosulfaneng.php. cxxxviii Adithya P. 2009. India’s Endosulfan Disaster. A review of the health impacts and status of remediation. Thanal, Thiruvananthapuram cxxxix Mathew R. 2009. No outlay for rehabilitation of endosulfan victims. The Hindu, October 26. http://www.thehindu.com/2009/10/26/stories/2009102656950400.htm cxl Mathew R. 2009. No outlay for rehabilitation of endosulfan victims. The Hindu, October 26. http://www.thehindu.com/2009/10/26/stories/2009102656950400.htm cxli Mathew R. 2009. Endosulfan trauma still haunts them. The Hindu, October 26. http://www.thehindu.com/2009/10/26/stories/2009102657570700.htm cxlii Scheme for rehabilitation of endosulfan victims. The Hindu, December 17th. Thiruvananthapuram. http://www.hindu.com/2009/12/17/stories/2009121750190100.htm cxliii Govt announces relief for endosulfan victims. Asianet.com. December 12th, Thiruvananthapuram. http://www.asianetindia.com/news/governemnt-announces-releif-endosulfan-victims_109532.html. cxliv Govt announces relief for endosulfan victims. Asianet.com. December 12th, Thiruvananthapuram. http://www.asianetindia.com/news/governemnt-announces-releif-endosulfan-victims_109532.html. cxlv Express New s Service. Relief package for endosulfan victims. December 13th, Thiruvananthapuram. http://www.expressbuzz.com/edition/story.aspx?Title=Relief+package+for+endosulfan+victims&artid =/0NIgXXt3iY=&SectionID=lMx/b5mt1kU=&MainSectionID=lMx/b5mt1kU=&SEO=&SectionNam e=tm2kh5uDhixGlQvAG42A/07OVZOOEmts. cxlvi Special Correspondent. 2009. Yeddyurappa for ban on use of endosulfan in the legislature. The Hindu. Bangalore. December 24. http://www.thehinudu.com/2009/12/24/stories/2009122454210400.htm cxlvii Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. cxlviii http://www.chem.unep.ch/saicm/ cxlix UNEP Press Release, New Global Chemicals Strategy Given Green Light by Governments, 7 February 2006. http://www.chem.unep.ch/saicm/iccm_sec.htm. 131

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cl http://www.chem.unep.ch/saicm/SAICM%20texts/SAICM%20documents.htm. cli New Initiative for Pesticide Risk Reduction. COAG/2007/Inf.14. FAO Committee on Agriculture, Twentieth Session, Rome, 25-28 April 2007. ftp://ftp.fao.org/docrep/fao/meeting/011/j9387e.pdf. clii Recommendations. First Session of the FAO/WHO Meeting on Pesticide Management and 3rd Session of the FAO Panel of Experts on Pesticide Management, 22-26 October 2007, Rome, Italy. http://www.fao.org/ag/agp/agpp/pesticid/Code/expmeeting/Raccomandations07.pdf. cliii Kumar TV, Raidu DV, Killi J, Pillai M, Shah P, Kalavadonda V, Lakhey S. 2009. Ecologically Sound, Economically Viable Community Managed Sustainable Agriculture in Andra Pradesh, India. The World Bank, Washington DC. cliv http://www.comlaw.gov.au/ComLaw/Legislation/ActCompilation1.nsf/BrowseProof2/5B95C95EB3FF5284CA25703E0022 68CE?OpenDocument&mostrecent=1 clv http://www.comlaw.gov.au/comlaw/Legislation/LegislativeInstrumentCompilation1.nsf/0/D46CF53F85578946CA25768D00 12F0A3?OpenDocument clvi http://www.apvma.gov.au/news_media/news/2008/2008_01_endosulfan_monitoring.php clvii http://www.austlii.edu.au/au/legis/nt/consol_act/aavcoua2004510/ clviii http://www.austlii.edu.au/au/legis/vic/consol_reg/aavcour2007619/ clix http://www.environment.nsw.gov.au/resources/pesticides/2000endosulfan.pdf clx http://www.dpiw.tas.gov.au/inter.nsf/Attachments/CART- 62MVRX/$FILE/Restrictions%20on%20supply%20&%20use%20of%20certain%20chemicals.pdf clxi http://www.apvma.gov.au/products/review/completed/endosulfan.php clxii http://www.apvma.gov.au/products/restricted.php clxiii (UNEP/POPS/POPRC.5/CRP.7/Rev.1 clxiv Burkina Faso, Cape Verde, Chad, Gambia, Guinea Bissau, Mali, Mauritania, Niger, and Senegal. clxv PAN/IPEN. 2009. Endosulfan in West Africa: Adverse Effects, its Banning, and Alternatives. POPs Pesticides Working Group, Pesticide Action Network (PAN) and International POPs Elimination Network (IPEN) clxvi http://www.apvma.gov.au/news_media/news/2008/2008_01_endosulfan_monitoring.php clxvii PMRA Re-evaluation Note: Preliminary Risk and Value Assessments of Endosulfan, October 2007. clxviii PMRA Proposed Acceptability for Continuing Registration: Re-evaluation of Endosulfan - Interim Mitigation Measures, June 2004. clxix The Agency also proposed reduced re-entry intervals and vegetative buffer strips/zones. Our analysis focuses on application rate restrictions rather than these other measures. clxx The Executive Director of the Ontario Berry Growers Association suggested that “Endosulfan could very well be the most important insecticide for strawberry growers in Ontario and other jurisdictions”. clxxi Figures from Statistics Canada, Fruit and Vegetable Production, February 2008. clxxii Information obtained from OMAFRA: Publication 513, Growing Strawberries in Ontario; and OMAFRA factsheets: Tarnished Plant Bug: A major pest of strawberry; and Cyclamen mite: a pest of strawberries. clxxiii The endosulfan application rates cited here and later in the analysis relate to the emulsifiable concentrate formulation, which strawberry growers prefer over the wettable powder formulation for ease of use. clxxiv This is a simplification as many growers replace a portion of their plantings at the end of each season; however, doing so serves to avoid overstating revenues in a model focussed on annual costs/revenues. clxxv The endosulfan use estimates / use reductions cited elsewhere in this document are based on bearing acres. By definition, propagation plants are non-bearing. The extent of endosulfan use in propagation facilities is not known (follow up). ______

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