PAN Philippines’ Position in the Upcoming TriCOPs 2019

The use of highly hazardous pesticides put workers at risk as they often lack access to personal protective equipment. Photo: PAN Philippines

PAN Philippines Supports the Inclusion of Listed Pesticides and Chemicals in the Rotterdam and Stockholm Conventions, and urges a Pro-Active Stance from the Philippine Delegation

The Pesticide Action Network Philippines together with its partners[1]  strongly support the listing of pesticides and chemicals below in the Annex III of the Rotterdam Convention (RC), and in the Stockholm Convention (SC). All meet the requirements of the SC/RC and their inclusion in the Conventions’ respective Annexes should proceed.

For RC Annex III

  • Acetochlor (CAS# 30560-19-1): Herbicide, banned in 38 countries, PAN HHP[2], WHO III, GHS 5; not in the 31 December 2016 FPA-registered pesticides list
  • Carbosulfan (CAS# 55285-14-8): Benzofuranyl methylcarbamate insecticide, banned in 40 countries, PAN HHP, WHO II, GHS 3; trade names are Marshal 25 ST, Advantage 5 G, and Marshall 200 SC; registration expiration dates are 21 March 2020, 15 September 2017, and 17 May 2020 respectively
  • Fenthion (CAS# 55-38-9): Organothiophosphate insecticide, avicide, and acaricide; banned in 30 countries, PAN HHP, WHO II, GHS 3; registration of fenthion in the Philippines expired in 28 October 2011
  • Paraquat (CAS# 4685-14-7) and Paraquat dichloride (CAS# 1910-42-5):  Dipyridilium herbicide, banned in 38 countries, PAN HHP, WHO II, GHS 3; registration of paraquat dichloride in the Philippines expired in 13 June 2017
  • Phorate (CAS# 298-02-2): Organophosphate insecticide and acaricide, banned in 37 countries, PAN HHP, JMPM HHP[3],  WHO Ia, GHS 1; not in the 31 December 2016 FPA-registered pesticides list
  • Chrysotile Asbestos (CAS No. 12001-29-5): a fibrous hydrated magnesium silicate mineral
  • Hexabromocyclododecane (CAS# 3194-55-6): a brominated flame retardant

For SC Annex

  • Dicofol (CAS# 115-32-2): Organochlorine miticide, banned in 45 countries, PAN HHP, JMPM HHP, WHO II, GHS 4; not in the 31 December 2016 FPA-registered pesticides list
  • Perfluorooctanoic acid (PFOA; CAS# No 335-67-1), its salts and PFOA-related compounds


Characteristics of pesticides recommended for listing

PAN International considers all these pesticides as highly hazardous since they have at least one of these characteristics: (1) high acute toxicity (including inhalative toxicity); and/or (2) long-term toxic effects at chronic exposure (carcinogenicity, mutagenicity, reproductive toxicity, endocrine disruption); and/or (3) high environmental concern either through ubiquitous exposure, bioaccumulation or toxicity; and/or (4) known to cause a high incidence of severe or irreversible adverse effects on human health or the environment.

As what on-the-ground investigations in the Philippines and other countries[4] have shown, highly hazardous pesticides are heavily used by farmers and plantation workers putting them, their families and communities at high risks of adverse effects. Plantation workers and farmers do not wear the standard personal protective equipment that will shield them from pesticide exposure as this is not convenient in humid and hot climate which we have in the country; and that they normally wash their spray equipment in water courses since their companies do not provide enough/appropriate washing facilities. They are not given enough training and duly forewarned of the hazards of pesticides (there were workers who even de-clog spray nozzles with their mouth).

Acetochlor is a chloroacetanilide herbicide with restricted usage for pre-emergent control of grasses and broadleaf weeds on agricultural crop land, mainly corn. It remains in soils for up to three months, and has been detected in watersheds of agricultural lands. It leaches into the groundwater and enters the food chain. Metabolism leads to the formation of genotoxic metabolites such as Nor-acetochlor.  According to the Japan GHS classification, this substance is a carcinogen, and US EPA considers it as a likely human carcinogen. It is very toxic to all groups of aquatic organisms and a high risk to non-target terrestrial plants was identified. Risk mitigation requires s a 5m infield no spray buffer zone.

It produced testicular atrophy, renal injury, and neurologic movement abnormalities in chronic animal studies. In some species and at doses above maximum tolerated doses, animals have demonstrated tumors of the lung, nasal epithelia, and thyroid.

Carbosulfan is toxic to humans when inhaled and highly toxic to birds, fish, aquatic invertebrates and bees. Its major metabolite, carbofuran, is more toxic and presents unacceptable risks to plantation workers carrying out certain tasks such as mixing, loading, application and post-application. Together with its metabolite, it poses risks to human health and the environment.

Dicofol is persistent and bioaccumulative.  It is used to control mites on field crops, fruits, vegetables, ornamentals, cotton, and tea. Prolonged or repeated exposure to dicofol can cause skin irritation, hyperstimulation of nerve transmissions along nerve axons. It is highly toxic in fish, aquatic invertebrates, algae and in birds is tied to eggshell thinning and reduced fertility.

Phorate controls pests by systemic, contact, and fumigant action. It is used in pine forests and on root and field crops (e.g. corn, cotton, coffee, brassicas, potatoes, beans) and in some ornamental and herbaceous plants and bulbs. It is extremely toxic – fatal if swallowed, inhaled or in contact with skin. It targets the eyes, skin, respiratory system, central nervous system, cardiovascular system and blood cholinesterase. It poses high acute and chronic risks to birds, fish, and mammals.

Brazil banned phorate in 2015 because they found it to be of higher toxicity to humans than animals, an endocrine disruptor, neurotoxic, to have caused a number of poisonings in India, and because Brazilian farmers do not wear the personal protective equipment necessary for such a toxic pesticide.[5]

Fenthion and paraquat have been found to cause human health problems to the applicators under conditions of use in developing countries like Chad and Burkina Faso, respectively. The acute and chronic effects of paraquat are also observed in the oil palm plantations in Mindanao, Philippines.

Paraquat has no known antidote. The European Commission has described its acute hazard as very toxic by inhalation; toxic in contact with skin and if swallowed; irritant to the eyes, respiratory system and skin; and danger of serious damage to health by prolonged exposure. It can cause severe acute and long term health problems such as severe dermatitis, kidney failure, respiratory failure, rapid heart rate, second degree burns, skin cancer and Parkinson’s disease. Paraquat sold under the trade name Gramoxone has been implicated in the death of about 1,000 people every year in Vietnam.[6]

Alternatives to pesticides

PANAP have two downloadable publications Replacing Chemicals with Biology: Phasing out highly hazardous pesticides with agroecology and Alternatives to Synthetic Chemical Herbicides which give a range of strategies to manage weeds and pests without the use of chemical pesticides, and which proved to be effective based on our global partners’ experience as compiled in Stories from the Field: Women Working Towards a Non-toxic Environment. Most popular now are thermal weed control and the use of ducks in farms and gardens.

A 2018 study of IDDRI also showed that Europe can phase out chemical pesticides and fertilizers and be fully agroecological by 2050 if the region’s population shifts to plant-based proteins and pasture-fed livestock.

Characteristics of chemicals recommended for listing

Chrysotile asbestos, used as cement building material, component of friction materials and textiles can cause lung cancer, mesothelioma and asbestosis, as well as cancer of the larynx and ovary. More than 50 countries have banned its use. The International Agency for Research on Cancer (IARC) established that there is sufficient evidence of carcinogenicity in humans for all types of asbestos.

Hexabromocyclododecane is used in expanded polystyrene foam in the building and construction industry, and in consumer products. Exposure is through its products and dust in the home, workplace and environment. US EPA has classified it as a persistent, bioaccumulative, and toxic chemical; has determined that it can reasonably be anticipated to cause developmental and reproductive effects in humans; and that it is highly toxic to aquatic and terrestrial organisms. It has been found in human breast milk, adipose tissue, and blood.

Perfluorooctanoic acid (PFOA) a per- and polyfluoroalkyl substance (PFAS) is of very high concern because it meets the criteria of Article 57 (c) of E. U. Regulation as “toxic for reproduction” (category 1B); and meets the criteria and provisions of the E.U. REACH Regulation as persistent, bioaccumulative and toxic. PFOA has been linked to a number of health problems in humans, including diagnosed high cholesterol, ulcerative colitis, thyroid disease, testicular cancer, kidney cancer, and pregnancy-induced hypertension, and animal studies indicated adverse developmental effects.

Recommendation to review the current classification of pesticides

We also hope that the same delegation will make a dent in the 2019 TriCOPs by forwarding a resolution that the COPs review the current classification of pesticides as recent studies [7], [8] have shown that such has been based on outdated science. The most prominent of these pesticides is glyphosate, which epidemiological studies have shown to be a potential human carcinogen. This was affirmed by a US court of law in the case of De Wayne Johnson Vs Bayer/Monsanto.[9]

Concluding statement

We urge the Philippine Delegation to stand by the Precautionary Principle, and work for the adoption of an agricultural system that will not poison our people, our food and our environment. Let us protect and advance the wellbeing of our people, especially the vulnerable – the women, children and agricultural workers – who are most susceptible to the hazards of chemical pesticides.

We hope that you will uphold and adhere to the following Human Rights Instruments and frameworks as you state our country’s position in the TriCOPs:

  • The Universal Declaration of Human Rights clearly states that “every individual and every organ of society” shall strive to promote respect for the rights and freedoms set out therein. It recognises the rights to just and favourable working conditions (Article 23), a standard of living favourable to health and well-being (Article 25) and imposes a duty on all, including corporations to meet its obligations.
  • The International Covenant on Economic, Social and Cultural Rights 1966 (ICESCR) includes the rights to safe and healthy working conditions, protects children from hazardous working conditions and exploitation, and requires steps to improve health and living conditions. The ICESCR Articles 6 and 7 specifically recognises the right to fair wages and safe and healthy working conditions.
  • The Constitution of the WHO calls for “the enjoyment of the highest attainable standard of health as one of the fundamental rights of every human being.”
  • The Convention on the Rights of the Child Articles 6 and 24 that “every child has the inherent right to life”; that survival and development of the child must be ensured to the maximum extent possible; and that children’s right to the enjoyment of the highest attainable standard of health must be safeguarded and upheld.
  • The International Code of Conduct on Pesticide Management Article 3.6 that “Pesticides whose handling and application require the use of personal protective equipment that is uncomfortable, expensive or not readily available should be avoided, especially in the case of small-scale users and farm workers in hot climates.”

And most specially, the Philippine Constitution State Policies Section 15 The State shall protect and promote the right to health of the people and instil health consciousness among them; and Section 16 The State shall protect and advance the right of the people to a balanced and healthful ecology in accord with the rhythm and harmony of nature.

May the upcoming TriCOPs be a victory for the Filipino people and the long-suffering rural communities whom you will represent.



  1. EU Pesticides Database. Paraquat. Retrieved from
  2. Extension Toxicology Network (Extoxnet). Paraquat. Retrieved from
  3. FAO. 2013. International Code of Conduct on Pesticide Management. Retrieved from
  4. GOVPH. The Constitution of the Republic of the Philippines. Retrieved from
  5. GreenFacts. Hazards and risk associated to Perfluorooctanoic acid (PFOA), its salts and PFOA-related substances. Retrieved from
  6. ICOH Statement: Global Asbestos Ban and the Elimination of Asbestos-Related Diseases. Retrieved from
  7. IARC, WHO. Asbestos (Chrysotile, Amosite, Crocidolite, Tremolite, Actinolite and Anthophyllite). IARC Monographs, Volume 100C, 2012. Retrieved from
  8. IDDRI. 2018. An agroecological Europe in 2050: multifunctional agriculture for healthy eating – Findings from the Ten Years For Agroecology (TYFA) modelling exercise. 74pp. Retrieved from
  9. InforMEA. Dicofol. Retrieved from
  10. IPCS INCHEM. Chrysotile Asbestos. Retrieved from
  11. PANAP. 2017. Community Pesticide Action Monitoring in Mindanao, Philippines. Retrieved from
  12. PAN International. 2018. List of Highly Hazardous Pesticides. Retrieved from
  13. POPRC-14/2: Perfluorooctanoic acid (PFOA), its salts and PFOA-related Compounds. Retrieved from
  14. SC.UNE. Candidate POPS:Dicofol. Retrieved from
  15. Sullivan KDM. 2016 June 17.  Duck Patrol: using ducks as pest control. Labroots. Retrieved from
  16. Towards a Non-toxic Southeast Asia. 2016. Stories from the Field: Women Working Towards a Non-toxic Environment. Retrieved from
  17. UNEP/FAO/RC/CRC.12/3/Rev.1. Rationale for the conclusion by the Chemical Review Committee that the notifications of final regulatory action submitted by the European Union, Burkina Faso, Cabo Verde, Chad, the Gambia, Mauritania, Niger, Senegal and Togo in respect of carbosulfan meet the criteria of Annex III to the Rotterdam Convention. Retrieved from
  18. UN. 1989. Convention on the Rights of the Child. Retrieved from
  19. UN. 1966. International Covenant on Economic, Social and Cultural Rights. Retrieved from
  20. UN. 1948. Universal Declaration of Human Rights. Retrieved from
  21. UNEP/FAO/RC/CRC.13/3. Acetochlor: notifications of final regulatory action. Retrieved from
  22. UNEP/FAO/RC/CRC.13/INF/7. Acetochlor: supporting documentation provided by the European Union. Retrieved from
  23. UNEP/FAO/RC/CRC.13/INF/8. Acetochlor: supporting documentation provided by Burkina Faso, Cabo Verde, Chad, the Gambia, Guinea-Bissau, Mali, Mauritania, the Niger, Senegal and Togo. Retrieved from
  24. UNEP/FAO/RC/CRC.11/7. Carbosulfan: notifications of final regulatory action. Retrieved from
  25. US EPA. Basic Information on PFAS. Retrieved from
  26. US EPA. Risk Management for Hexabromocyclododecane (HBCD). Retrieved from
  27. Watts M. 2017. Alternatives to Synthetic Chemical Herbicides. PANAP. Retrieved from
  28. Watts M, Williamson S. 2015. Replacing Chemicals with Biology: Phasing out highly hazardous pesticides with agroecology. PANAP. Retrieved from
  29. WHO. 2006. Constitution of the WHO. Retrieved from
  30. WHO. 2010. The WHO recommended classification of pesticides by hazard and guidelines to classification: 2009. Retrieved from
  1. WHO. 2014. Chrysotile Asbestos. Geneva, Switzerland. 44pp. Retrieved from
  2. Winer J. 2014. Holistic weed control practice for urban storm water catchments. Global trends, methods, limitations and cost benefits. Retrieved from


[1] Includes Kilusang Magbubukid ng Pilipinas (KMP), Kilusang Mayo Uno (KMU)-CARAGA, Citizens Alliance Unified for Sectoral Empowerment Davao del Sur (CAUSE-DS), Sitio Buloy Indigenous People’s Organization, Davao del Sur BAYAN (Bagong Alyansang Makabayan)-SOCSKSARGEN, Community Primary Health Care (CPHC)-SOCSKSARGEN, KALUMBAY (Indigenous People’s Organization, Northern Mindanao), and SENTRA (Sentro para sa Tunay na Repormang Agraryo) among others.

[2] Considered as a highly hazardous pesticide by Pesticide Action Network International.

[3] Considered as a highly hazardous pesticide by FAO/WHO Joint Meeting on Pesticide Management.

[4] PANAP. (2018). Of Rights and Poisons: Accountability of the Agrochemical Industry. Jutaprint Penang, Malaysia. Retrieved from

[5] Watts, M. (2017, October 31). Syngenta Expects Its Pesticides To Poison People. Retrieved from

[6] Viet Nam News . (2017 February 17). Paraquat poisoning kills 1,000 every year. Retrieved from

[7] Defargea N.,  Spiroux de Vendômois J. & Séralini G.E. (2018). Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides. Toxicology Reports 5: 156-163. Retrieved from

[8] Zhang L, Rana I, Shaffer RM, Taioli E, Sheppard L. (2019).  Exposure to Glyphosate-Based Herbicides and Risk for Non-Hodgkin Lymphoma: A Meta-Analysis and Supporting Evidence, Mutation Research-Reviews in Mutation Research, Retrieved from

[9] Rosenblat J. (2018, October 23). Judge Upholds Bayer/Monsanto Roundup Cancer Liability But Slashes Award. Retrieved from

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