COMMISSION FOR ENVIRONMENTAL COOPERATION
THREE COUNTRIES WORKING TOGETHER TO PROTECT OUR SHARED ENVIRONMENT
The objective of this North American Regional Action Plan (NARAP) on DDT is to reduce the exposure of humans and the environment to DDT and its metabolites through joint efforts of the three countries and a cooperative approach that includes the sharing of experiences with other countries of the Americas. This NARAP proposes to accomplish this program through the phased reduction, leading to the eventual elimination, of DDT used for malaria control in Mexico, as well as the elimination of illegal uses of DDT.
This NARAP supports:
DDT is a persistent, broad spectrum pesticide that in the past has been widely used in agriculture and for the control of mosquitoes, black flies and other insect pests and disease vectors. Some developing countries still use it in malaria campaigns, not only because of its effectiveness, but also because of its low cost and lack of acute toxicity for applicators, compared to alternative chemical pesticides that are more costly or more toxic. However, DDT and its metabolites are persistent, bioaccumulative and can be transported long distances through the atmosphere. Residues of DDT and its metabolites in the environment have been shown to result in adverse effects on wildlife reproduction. They continue to occur at reduced levels in environmental media in the North American region. The 114 member countries of the Intergovernmental Forum on Chemical Safety (IFCS) agreed that there was sufficient evidence to warrant international action on Persistent Organic Pollutants (POPS), including DDT (IFCS/Forum-II/97). This was the basis for the decision of the Governing Council of UNEP (in January 1997) that a legally binding, international instrument be developed for the control of POPs. This NARAP is intended to serve as a basis for a coordinated regional response to these international initiatives.
The manufacture, sale and use of DDT has been eliminated or substantially reduced in North America. Current DDT production is restricted to one facility in Mexico, which supplies DDT for authorized government use in malaria vector control. Mexico continues to operate a comprehensive malaria control program that has substantially reduced the incidence of this disease, while gradually decreasing the reliance on DDT. It is estimated that, thanks to this program, an additional 80 percent reduction in DDT use will be achieved in five years.
This NARAP was developed by the Parties to the North American Free Trade Agreement (NAFTA), working with the Secretariat for the (North American) Commission for Environmental Cooperation (CEC), under Council Resolution #95-05, Sound Management of Chemicals, agreed to by the Council of the CEC. New research on the human health effects of long-term exposure to DDT, and the continuing need for an effective and comprehensive malaria control program in Mexico, provide additional incentives for regional action. This NARAP could serve as a guide to other countries in Latin America, be a useful template for action by other regions, and support global initiatives. This also represents an opportunity for other countries to benefit from a better understanding of Mexico's holistic approach to malaria control. The practical experience gained in responding to the socio-economic realities in implementing this NARAP may serve as a useful example to other countries in Central America and to other regions.
DDT was first registered in 1946 and used in Canada to control insect pests in crops as well as in domestic and industrial applications. DDT was never manufactured in Canada. In response to environmental and safety concerns, most uses of DDT were phased out by the mid-1970s. Registration of all remaining uses of DDT was discontinued in 1985 with the understanding that existing stocks would be sold, used or disposed of by 31 December 1990. After this date, any sale or use of DDT in Canada represents a violation of the Pest Control Products Act.
The gradual restriction of the range of permitted uses of DDT was facilitated by the availability of effective alternatives. The phased reduction was also important in that it helped to avoid the creation of a large-scale disposal problem.
Provincial legislation provides additional regulatory powers to control the transportation, storage, disposal and use of pest control products, taking into account regional conditions and concerns. Municipalities may also control aspects of pesticide use and disposal. Some of the earliest pesticide collection programs at the municipal-level were set up in the 1960s and 1970s to collect and dispose of DDT. These programs were developed to manage unused stocks of certain formulations of DDT, resulting from the regulatory decisions to limit the permitted uses.
Pesticides that are not legally registered in Canada are refused entry and returned to the exporter. The Importation for Manufacturing and Export Programme for Pest Control Products does not allow for the importation of DDT for the purposes of reformulation and subsequent exportation. In addition, exports of DDT would be subject to notification according to the Canadian Environmental Protection Act, and no such notifications have been received.
Since the mid-1980s, programs have been set up at the provincial and municipal level across Canada to collect hazardous wastes. These programs generally include pesticides that are no longer used, have been discontinued, or were banned. Hazardous waste management facilities handle the products in accordance with federal and provincial guidelines.
In most provinces, rural collection programs have been established at different times specifically to collect pesticides that were no longer being used. One example is the Ontario Ministry of Agriculture and Food and Rural Affairs which in 1991-92 conducted the Ontario Waste Agricultural Pesticide Collection Programme. This program was widely publicized and collected approximately 1,180 kilograms of DDT. A subsequent pilot project, the Pesticide Disposal Pilot Project to dispose of waste registered and unregistered pesticide products, was initiated in August 1995. As of August 1996 no DDT had been brought forward for disposal. Limited quantities (e.g., 300 grams) of DDT have been reported in municipal collections of Household Hazardous Waste Collection programs, though information on specific chemicals is not available from all sites.
There are no maximum residue levels for DDT in Canada. Action levels for residues of DDT and its metabolites in foods have been established, ranging from 0.5-1.0 ppm in eggs, fresh vegetables, dairy products, meat and meat byproducts to 5 ppm in fish. These levels have been established based upon monitoring information collected on domestic and imported foods and are periodically revised as new information becomes available.
In 1969, the US Department of Agriculture (USDA) cancelled the registration of certain uses of DDT (on shade trees, on tobacco, in the home, and in aquatic environments) after studying the persistence of DDT residues in the environment. Applications on crops, commercial plants, wood products, and for building purposes were cancelled by the USDA in 1970. Under the authority of the EPA, the registrations of the remaining DDT products and DDT-metabolites were cancelled on 4 January 1973, with the following exemptions: public health use for control of vector-borne diseases, USDA or military use for health quarantine, and use in prescription drugs for controlling body lice. All of these remaining uses were voluntarily cancelled (due to failure to pay maintenance fees) by October 1989. The fact that there are no registrations means that DDT cannot be used in the United States, nor can it be imported for use as a pesticide product. At present, the United States does not have the legislative authority to prohibit production of DDT if a manufacturer wanted to initiate such production in the future.
However, DDT is not currently manufactured in the United States. There have been recent reports of DDT exports and imports entering or leaving the United States. The EPA believes that the exports are actually small quantities of reference standards being shipped between laboratories and as such, they are subject to the export notification requirements of the Toxic Substances Control Act (TSCA), which has no de minimis cut-off for notification. The imports may also have occurred when the Department of Defense (DOD) recalled its existing stocks for destruction. The DOD no longer uses DDT in any of its operations abroad and does not maintain a stockpile. No maximum residue levels are in effect, although there are numerous action levels for a wide variety of crops, ranging from 0.05 ppm to 5 ppm.
The introduction of DDT in Mexico in the early 1950s for its use in agriculture followed the pattern ahown by Canada and the United States. In the 1970s, DDT use in agriculture production began to decline as a result of environmental concerns and the introduction of stricter limits on residues of DDT on foods.
Today, DDT is registered in Mexico only for use in government-sponsored public health campaigns. It continues to be an important tool in the fight against malaria transmission. Mexico's malaria control program restricts the use of DDT to selective applications in dwellings. There is only one private company producing DDT in Mexico, and its production is subject to government approval. DDT requirements for malaria control have been reduced significantly in recent years because of changes in Mexico's malaria campaigns.
It is important to understand that malaria is a long-standing public health problem that has inhibited development in large areas of the country. Sixty percent of Mexico's territory from sea level to 1,800 meters above sea level, presents favorable conditions for malaria transmission. This includes the Pacific coast, the Gulf of Mexico slopes, the Yucatán peninsula and interior basins of the high plateau. Some 45 million people live in these areas. In the 1940s and 1950s, malaria was one of the main causes of mortality, responsible for an average of 24,000 deaths annually and afflicting an estimated 2.4 million others. In recent years, the incidences of malaria have declined significantly, to less than 5,000 cases, indicating the success of Mexico's malaria control program. Since 1982 there have been no deaths from malaria. The Appendix provides more detailed background on malaria and DDT use in Mexico.
The creation in 1987 of an Interministerial Commission for the Control of Production and Use of Pesticides, Fertilizers, and Toxic Chemicals (Cicoplafest), formed by the Ministries of Health, Urban Development (now Environment), Agriculture, and Trade, has been instrumental for the banning of the use of six organochlorine pesticides and the restriction of DDT use. The production of DDT has declined steadily and is presently less than 600 tonnes per year.
In 1995, Mexico decided that an integrated pest management approach for malaria could substitute for the heavy dependence on pesticides. Improved sanitation, surveillance and minimum use of pesticides to control mosquitoes and larvae are considered key elements in this new approach. Furthermore, in 1996, Cicoplafest implemented a new initiative to control pesticides with a life-cycle approach, and the new Health Law, published in 1997, introduced the concept of safe management of chemicals throughout the entire life cycle. In April 1997, the Ministry of Environment, Natural Resources and Fisheries, through its National Institute of Ecology, published a Program for the Environmental Management of Priority Toxic Chemicals that mentions the development of this DDT NARAP. Under all these initiatives, organochlorine pesticides have been considered priorities for regulatory action due to their persistence and tendency to bioaccumulate.
Supported by Canada, Mexico and the United States, DDT is one of the initial targets of the Sound Management of Chemicals initiative under the North American Agreement for Environmental Cooperation (NAAEC), and through the joint efforts of the three countries it will be assured that malaria continues to be controlled.
The following specific goals provide a baseline against which to measure progress. The identification of proposed target dates does not preclude the possibility of achieving these goals within a shorter time period.
The specific goals of this NARAP, directed at its overall objective, include:
The Task Force on DDT and chlordane has acknowledged that achieving the goals of this NARAP will be a iterative learning process where efforts will be concentrated on initiatives shown to have the greatest potential for success. Adjustments to the initiatives may be required as experience is gained during their implementation. In undertaking to follow the steps proposed in this NARAP, the Parties are committing themselves to ongoing cooperative activities and the yearly reporting on progress made on the initiatives and objectives. Such reporting will be made to the North American Working Group for the Sound Management of Chemicals, and subsequently disseminated to the Council of the Commission for Environmental Cooperation and the public.
The initial geographical emphasis of the action plan will be placed on selected sites within those areas identified as foci of persistence by the current malarial control program, as they are already well characterized. The studies in this phase will be used to develop and validate relevant methodology. The experience gained will be used to review the proposed approaches and consider how they might be extrapolated to other sites in Mexico.
A regional perspective that encourages the active involvement of other Central and South American countries in the implementation of this NARAP is seen as important to its success. This will require sharing Canadian and US experience in the combat of malaria, and close cooperation with existing programs and activities for malaria control throughout the region and subregion, including those coordinated by the Pan American Health Organization (PAHO) and other regional and bilateral initiatives.
It will be important to establish priorities and timeframes for all of the activities initiated under this NARAP, develop precise estimates of costs, have a clear understanding of how to measure progress in achieving goals, and promote all means of cooperation that can aid the process.
Alternative methods for malarial control in Mexico will be developed to support the continuous reduction and eventual elimination of DDT use. In assessing the acceptability of alternative chemicals, full consideration will be given to their potential impacts on human health and the environment throughout their life cycle under the conditions of use in Mexico. The first step will focus on the development of clear baseline information on current activities and previous experience with alternative chemicals and biological vector controls.
The initial phase of this NARAP will test alternatives to DDT, including biological controls and public health and education initiatives, and will continue to focus on the interruption of malaria transmission. More specifically, projects will include consideration of the following points:
Developing these initiatives will include considering the possibility of their integration into the current malaria control program. Canada and the United States will work closely with Mexico in providing available risk assessments for those alternatives (chemical and biological) identified as likely candidates. In the longer term, the ongoing efforts of the NAFTA Technical Working Group on Pesticides will assist Mexican authorities.
This NARAP represents an opportunity to strengthen existing intersectoral cooperation in the provision of public health services. Regional cooperation will be pursued to promote the early detection and immediate treatment for workers infected with malaria and others migrating from Central America to Mexico who may be infected, to reduce malaria transmission, and to improve malarial control in surrounding countries. The following points summarize the initiatives to be undertaken in Mexico:
As spelled out in the following points, this NARAP will seek to promote public participation in the development and implementation of special activities in affected communities, as well as to increase public awareness. This will include cooperation with industry, public interest groups and other nongovernmental organizations.
North American industry will be encouraged to support the identification and evaluation of alternative pesticides compared to DDT. It is suggested that industry support could include:
The production of DDT in Mexico will be maintained according to the needs of the Mexican malarial control program. Phase-out of DDT and cancellation of its registration as a pesticide will occur after viable, effective alternatives have been financed and tested.
Intersectoral, cooperative programs will be strengthened to control illegal and non-authorized uses of DDT, partially through the control of illegal importation, sale and use of DDT in the North American region, and partially by Cicoplafest reinforcing DDT-surveillance activities.
The gradual phase-out and use of DDT, and the controlled reduction in production, will for the most part avoid the creation of stockpiles of an obsolete pesticide, thereby avoiding the need for an extensive waste management program.
Canada and the United States will continue to support DDT-inclusive hazardous waste collection programs at the federal, provincial/state, or municipal level, as appropriate. The information on how these programs are run will be shared with Mexico, which in turn will administer its own hazardous waste collection programs.
Canada, Mexico and the United States and the CEC will work cooperatively to develop scientific and otherwise detailed proposals for NARAP initiatives and approach aid and technical cooperation agencies for obtaining the substantive funding needed to implement the actions in this NARAP.
[Note: The report upon which this edited text is based was provided by Mexico and presented (Document IFCS/EXP POPs 11) on 14 June 1996 to the Intergovernmental Forum on Chemical Safety at the opening session of the IFCS Experts Meeting on POPs, held 17-19 June in Manila, Philippines.]
For many years malaria has been a major public health problem in Mexico-one that has hindered the development of large areas of the country. In the 1940s and 1950s it was one of the main causes of death, causing an average of 24,000 mortalities annually and afflicting some 2.4 million individuals.
At the end of the 1940s, a program of selective spraying of DDT in dwellings was begun in some urban and rural areas, yielding results that supported the international eradication proposal presented by Mexico in 1955. Even though this national campaign for malaria eradication did not accomplish all its objectives, the transmission of Plasmodium falciparum was halted, the death rate from the disease was greatly reduced, and efficient technical and operational procedures were established which allowed other public health programs to be introduced in rural locales with difficult geographical access.
The widespread introduction of DDT in Mexico followed the pattern of many other countries. During the early 1950s, DDT was introduced throughout Mexico and extensive agricultural use followed. As much as 1,000 tonnes per year were applied to large agricultural areas, and application rates in the Laguna region in central Mexico were among the highest in the world.
The success of DDT spraying in the household to reduce malaria transmission became strategic in the 1960s, and the evolution of the spraying campaign typifies the intensity placed in the campaign against the disease. From the selectively based campaign of the 1940s, the use of DDT and other newly developed organochlorine pesticides grew steadily through the 1960s. Finally, in 1968, DDT production was bought by the government for state control. This was also the time in which organochlorine production peaked in Mexico, with more than 80,000 tonnes produced annually.
The controlled production of DDT resulted in increased availability and lowered cost for its use in malaria control and agriculture. However, production was maintained at about 25,000 tonnes per year. During the early 1970s the US Food and Drug Administration (FDA) began rejecting the importation of commodities due to high residue levels, especially of DDT.
The growing concern about DDT persistence has had a significant impact on agricultural practices in Mexico. The northern area of the country, more developed and highly dependent on exports, changed to newer and even more toxic pesticides in order to comply with FDA/EPA regulations on DDT residue content. The southern area of Mexico, largely devoted to local production, continued the use of organochlorine pesticides. However, the use of DDT in agriculture started to decline. In 1987 the Ministries of Agriculture, Commerce, Urban Development (now Environment) and Health joined efforts by forming an interministerial commission to control the use of pesticides, fertilizers and toxic substances. In 1990 this commission (Cicoplafest) banned the use in Mexico of six organochlorine pesticides and DDT use was severely restricted. Organochlorine production declined steadily and DDT was limited to campaigns addressing public sanitation (about 3,000 tonnes per year).
In the early 1980s, the economic crisis and reductions in program activities caused a significant deterioration in public health, leading to the temporary increase of malaria transmission. In 1985, 133,700 cases were registered in 14,000 localities. As a result, the malaria control program was strengthened with additional human, material and financial resources. The technical strategy was reoriented to address the simultaneous elimination of the plasmodium parasite in humans and the anopheline mosquito as disease vectors. From 1985-89, the annual average had declined to 117,000 cases. Still, in 1989, among 21 countries in the American hemisphere with active programs against malaria, Mexico reported nine percent of the cases, second only to Brazil in number. By 1994, after the reinforcement of the anti-malarial program, the number of cases had decreased to only one percent of those reported in the Americas.
In 1991, Fertimex, the national producer of DDT, was privatized and additional restrictions were placed on organochlorine production. Changes in malaria campaigns have further reduced DDT use and production.
In 1996, Cicoplafest undertook a new role. Pesticide control through the life-cycle approach has been implemented and new governmental areas (transportation and labor) have been included to integrate every area of the chemical life cycle. Elimination of organochlorine pesticides is a priority, due to their persistence and tendency to bioaccumulate.
The anti-malarial program is geographically oriented, since 60 percent of the territory from sea level to 1,800 m above sea level presents favorable conditions for the transmission of the disease. This includes the Pacific coast and Gulf of Mexico slopes, the Yucatán peninsula and interior basins of the high plateau. The area encompassed is inhabited by close to 45 million people. The strategy focuses on entomological and epidemiological stratification of the malarial areas, since studies have revealed that 70 percent of malaria cases were located in approximately one thousand pockets of persistence, distributed throughout five states that have high receptivity and vulnerability due to national and international migration. Thus program activities have been divided into two areas:
Currently DDT use is severely restricted in Mexico and has been registered and approved only for anti-malarial control programs. The pesticide is classified as a persistent compound with an acute toxicity that is low for humans and but high for animals. Chronic effects, though, are a serious consideration, due to its possible link to breast cancer and reproductive abnormalities.
Legally DDT production is limited to public health needs and for international trade. Two certified concentrations are available: technical grade (100 percent pure) for use in mixing formulations and 75 percent for household application. Commercial products are labeled "only for use in public health programs" and are not available for pest control management or agricultural use. Imports are banned, due to high levels of contaminants in the DDT available from other countries (especially China and India). Exports are regulated by Cicoplafest and every shipment is registered.
Malaria was a major public health problem in Mexico from 1950 to 1989. The disease is endemic in more than 60 percent of the country's land area, a fact which is reflected in the high incidence and mortality statistics. The use of pesticides has markedly diminished the number of cases, from more than 120,000 per year to less than 5,000. Malaria mortality has declined sharply: it was one of the top ten causes of death in Mexico during the 1950s, but since 1982 there have been no deaths from the disease. These results show that an integrated approach is highly effective in the control of the vectors responsible for the spread of malaria and dengue fever. The low acute toxicity for humans has also promoted the use of DDT.
Public health programs involve a large number of workers, with more than 10 percent of the Health Ministry workforce currently involved in malaria control. More than 7,000 workers have been trained and equipped for DDT household spraying. The investment is considerable, with the exception of the pesticide, substitutes for which are seven or eight times more expensive. The employment of DDT substitutes has been ineffective and sporadic. It has been stated that DDT should be replaced by another pesticide, but in fact a more integrated approach to vector control is required.
In 1995, Mexico decided that an integrated pest management for malaria could substitute for the heavy reliance on pesticides. Improved sanitation, epidemiological surveillance and a minimum use of pesticides to control adult mosquitoes and larvæ are considered key elements. When the CEC began working on limiting human exposure to toxic and persistent substances, DDT became one of the four initial targets.
Reduction of human and environmental exposure to DDT will be accomplished through a gradual organized approach that will focus on: