Prior Informed Consent Update
April 18, 1992
A progress report on implementation of the Prior Informed
Consent (PIC) procedure was presented at the seventh meeting
of the United Nations Joint Group of Experts on PIC in Rome
on March 22-25, 1994. Prior Informed Consent is an
international procedure that requires that importing
governments be informed of the hazards of specific pesticide
products and give explicit consent for their import before
the pesticides are shipped.
PIC is jointly operated by the United Nations Food and
Agriculture Organization (FAO) Plant Protection Division and
United Nations Environment Programme (UNEP) through its
International Register of Potentially Toxic Chemicals (IRPTC)
in Geneva. The FAO is the lead agency for operating the PIC
scheme for pesticides. The joint FAO/UNEP panel of experts,
which includes NGO observers, was established to develop and
guide the process, and now meets about every nine months.
At the recent experts' meeting, it was reported that
approximately 120 governments, including all major industrial
countries, are now participating in the PIC process. To
participate in PIC, governments must appoint a Designated
National Authority (DNA) to both receive information and
convey to exporting industries within their country the
decisions of other governments.
Although participation in PIC is high, there are still
countries that need to appoint DNAs to become part of the
process. At present, some significant exporters, notably
Taiwan and South Korea, have not appointed DNAs, and
therefore, are not participating in the scheme. These
countries will not be notified of the decisions of other
countries to allow or prohibit the import of PIC pesticides,
and are not under any obligation to abide by the decisions of
importing governments. In contrast, the European Union has
made PIC legally binding on exporters, and the Clinton
Administration is currently considering similar legislation.
Some importing countries, for example Mali and some countries
of the former USSR, have not yet appointed DNAs. In other
instances, though DNAs have been appointed, their governments
have not given the scheme the backing it needs to work
effectively. This may be the result of several factors such
as a lack of resources or an insufficient understanding of
the procedure.
Pesticides and chemicals included in the PIC process have
been banned or severely restricted for health or
environmental reasons in five or more countries or in any one
country after January 1, 1992. Pesticides can also be
included if they cause health or environmental problems under
conditions of use in developing countries. IRPTC provides
participating governments with information about PIC-listed
pesticides and the reasons for any control actions in the
form of a Decision Guidance Document (DGD). Government
import decisions whether or not to allow import of PIC-listed
chemicals are then conveyed to the FAO/UNEP secretariat,
which informs the DNAs of all government decisions on each
compound every six months. Participating governments are
then required to inform their own export industries of these
decisions.
To date, Decision Guidance Documents have been completed for
twelve pesticides. There are currently an additional 39
pesticides and chemicals that are either in the process of
being confirmed for PIC or awaiting completion of DGDs.
Pesticides causing problems under conditions of use in
developing countries continue to be a major concern, since
many of the pesticides initially included were not
necessarily those most responsible for health hazards.
Implementation of PIC has been difficult for many reasons,
only one of which has been a lack of FAO personnel assigned
to PIC. Other problems facing many of the participating
governments range from establishing decision-making
structures to understanding what information is important to
include on forms. To facilitate implementation, DNA training
workshops have been held in Chile and Thailand in the past
year, and another is scheduled for Andean Pact countries in
July 1994. Non-governmental organizations are generally
invited. No workshops have been scheduled for Africa, though
European Union funding may be available for such workshops in
the future.
Designated National Authorities have expressed concern
regarding a perceived lack of alternatives to many of the
pesticides in the PIC procedure and consistently ask for more
information. Although the governments banning or severely
restricting a pesticide are asked to name what they recommend
as an alternative, this information is rarely given and is
not always helpful. Some recommended alternatives have been
more hazardous than the pesticide in question, while others
may not be appropriate for the different climatic conditions,
agricultural practices, etc. Those attending the experts'
meeting suggested that attempts should be made to integrate
PIC activities with other related programs such as IPM and
the FAO/OECD initiative for developing pesticide use
reduction programs.
The FAO has now appointed Bill Murray in the Plant Protection
Division to work on PIC, and things are beginning to move
more quickly. Priorities set at the meeting include
finalizing and circulating the next set of DGDs, improving
the quality of DGDs, and revising the Guidance for
Governments, a basic PIC manual.
Source/contact: Barbara Dinham, The Pesticides Trust,
Eurolink Business Centre, 249 Effra Road, London, SW9 1BZ,
England; phone (44-71) 274-8895; fax (44-71) 274-9084; email
pesttrust@gn.apc.org.
Resource: Putting PIC in Place. 1993. A guide for public
interest groups to the PIC procedure as it relates to
pesticides. 17 pp. Free to NGOs. Available from The
Pesticides Trust (see above).
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