by Mr. Mario Abó Balanza

With the recognition that chemical substances are indispensable for economic and social development and that they can be utilized safely with a minimum of risk, the country has developed a set of programs and fundamental activities, which include the creation and strengthening of institutional capabilities, the establishment of a framework to regulate them, and the preparation of appropriate legislation.

A clear expression of the political will of the government during recent years is manifested in the implementation of a variety of health programs and the execution of significant environmental activities. Relevant to the latter are the approval of the National Program for the Environment and Development, the creation of the Ministry of Science, Technology, and the Environment, and the preparation of the new Law on the Environment and the National Environmental Strategy.

The National Program for the Environment and Development, approved by the government in late 1993, constitutes one of the country’s principal actions in response to the agreements reached in the United Nations Conference on the Environment and Development, held in Rio de Janeiro in 1992, specifically in regard to the preparation of national programs for preventing or minimizing the damages to the planet from human activity geared toward economic and social development.

The program is basically the national response to the objectives and goals proposed in Agenda 21 and the complete projection of Cuban environmental policy. It includes a series of proposed guidelines for action that, in essence, constitute the organization of sectoral economic activities and of management in the social sphere, incorporating the dimension of environmental protection and rational use of natural resources for sustainable development.

Although in Chapter 20, Rational Management of Chemical/Toxic Products, the significant progress made by the country in the management of these products is acknowledged, there is also recognition of the need to reinforce the existing coordinating mechanisms, promote information exchange on chemical products, and improve the activities to reduce risks, while taking the entire life cycle of these products into account.

The sustained economic recovery currently under way in our country, combined with the institutional changes that are taking place, provides a solid foundation for us to advance with optimism toward the establishment and management of a national environmental strategy, whose guidelines take to us to higher levels of safety in the management of chemical products.

In Cuba, where agricultural activity is a basic component of the national economy, pesticides are utilized intensively on numerous crops and, to a lesser extent, in Ministry of Public Health campaigns to eliminate insects.

The growing use of chemical methods for health and plant protection purposes has been a decisive factor in the establishment of regulations geared toward reducing the negative impact of pesticide use.

Growing demand for the adoption of health and safety measures, combined with the national experience in pesticide management, led to creation of a national agency to guide policy governing national certification and use of pesticides. Thus in 1987 a joint resolution by the Ministries of Public Health and Agriculture creating the Central Pesticide Registry and its Technical Advisory Committee took effect.

As antecedents to a registry system in Cuba, various ministerial resolutions can be cited governing the use, storage, and transportation of pesticides, which undoubtedly served as the basis for the current legislation governing these activities.

However, the fact that there was no available registry was not an obstacle. Action was taken to apply good agricultural practices and other measures designed to guarantee the safe handling of these products, which demonstrated the will and the interest of the authorities in minimizing the risks associated with the use of pesticides.

Among the main provisions of the resolution creating the registry is the ban on the use in the national territory of every pesticide whose active ingredient, commercial brand name, or formulation are not listed in the Central Registry, as well as the requirement that every legal entity, national or foreign, that intends to introduce a product in the national territory register it.

The decisions resulting from the registry of such products are compiled in an official list of authorized pesticides, which is published annually and which lists the authorized uses and requirements for the application of these products.

The evaluations conducted as part of the registration process are based on an analysis of the technical information provided by the interested party, as well as information from other sources in national and international agencies. In Cuba, however, the preparation of an experimental evaluation is compulsory. The indicators of the quality of the product and its biological effects must be determined; the analytical methods must be verified, and the breakdown curve must be determined in order to determine the safe waiting period. Under this procedure, it is possible to evaluate the feasibility of utilizing a product under national conditions, based on its effectiveness and the hazards it poses, and also to consider the identification and adoption of possible alternatives in the event that registry of a given product is denied.

It is significant that the work of the Technical Advisory Committee, attached to the Central Pesticide Registry, has made it possible to establish over 450 maximum residue levels for different foods, as well as the safe waiting periods in accordance with Cuban agricultural practices and the definition of the measures and equipment necessary to protect people based on the characteristics of each pesticide.

Another important mechanism for the control of persistent organic compounds is the national application of the Procedures for Prior Informed Consent, based on the adoption by our country of the FAO International Code of Behavior for the Distribution and Utilization of Pesticides and the London Directives for the exchange of information on chemical products involved in international trade and of concern to UNEP.

The commitments acquired by the country through these international instruments have led to the development and entry into force of Resolution 159/95 of the Ministry of Science, Technology, and the Environment. This Resolution contains provisions governing the national application of the Procedures for Prior Informed Consent. Two national authorities were named to apply these Procedures, the Central Pesticide Registry for these products and the Center for Environmental Management and Inspection for chemical products for industrial and consumer use.

Similarly, through national application of these procedures, it has been possible to assess the feasibility of importing and using a product in the country on the basis of the dangers it poses and a thorough consideration of the various environmental, economic, technical, legal, and administrative factors.

At present, the country decisions adopted within the framework of the Procedures for Prior Informed Consent reflect the establishment of regulations for 18 agricultural and 4 industrial chemicals, 19 of which are banned and 3 have severe restrictions on use.

In practical terms, national application of the Procedures for Prior Informed Consent has made it possible to establish regulations governing specific chemical products that constitute an unacceptable risk for human health and the environment under national conditions of use.

It should also be noted that two ministerial resolutions (268/90 and 181/95) have been drafted to date in the country, banning the use of 20 agricultural chemicals. Among them are 10 chemicals subject to the Procedures for Prior Informed Consent, and 6 of the 12 persistent organic compounds, for which the need for the immediate adoption of worldwide measures has been recognized.

The beginning of a new qualitative stage in the environmental efforts of the country made possible the creation, establishment, and development of new institutional structures and work tools directed basically toward elevating the task of the national environmental management to a higher plane.

With the creation of the Ministry of Science, Technology, and the Environment and the Environmental Agency, as the executive organ of the environmental policy laid out by the Ministry, two significant resolutions were drafted and implemented that involve the establishment and development of important procedures aimed at guaranteeing preparation and control of the environmental regulations.

Resolutions 130/95 "Regulation for the State Environmental Inspection" and 168/95 "Regulation for Conducting and Approving Environmental Impact Assessments and Granting f Environmental Licenses" presuppose two important tools for environmental management which, with other existing state procedures and bodies, make it possible to guarantee effective control of the management of chemical products in the context of the national economic and social development plans.

Along with these successes, the country has created a large number of scientific institutions and associations, directed toward creating the capacity to rehabilitate individuals suffering from the effects of poisoning and facilitate the introduction of biological and technical integrated pest management that would permit a substantial reduction in the use of toxic chemicals in agriculture.

The available scientific infrastructure has made possible the development of risk assessment procedures and mechanisms for toxicological evaluation of the pesticide formulations developed by the national industry, as well as a body of research on the following topics:

·Principal clinical manifestations in workers exposed to organophosphorus, organochlorine, and carbamate pesticides.

·Biochemical changes in workers exposed to organochlorine pesticides.

·DDT and its metabolites in man and the environment.

·Evaluation of the daily intake of chlorinated pesticides in the diets of different population groups.

·Methodology for epidemiological studies of the infant population exposed to agricultural pesticides.

·Morbidity and mortality due to acute poisoning from agricultural products.

Other experiments aimed at reducing the risks of chemical products envisage the creation of subsystems for monitoring contaminants in food, water, and air and the workers exposed to risks and the population in general through several institutions of the national health system, as well as the establishment of a regulatory framework to prevent and deal with accidents, with active participation by local authorities and participation in the Codex Alimentarius system addressing pesticide residues in food.

With respect to the PCBs, the country has found the largest quantities in electric transformers and has therefore established a temporary management strategy consistent with the lack of treatment and disposal capacity.

In accordance with the foregoing, importation of electronic equipment with a PCB content higher than 50 ppm has been prohibited as a first step. A management standard that sets the requirements for the storage, transport, and temporary confinement of electronic equipment containing PCBs is being prepared and distributed.

Several specialized facilities, whose personnel have been properly trained in the safety measures and requirements for handling these substances, have been designated for the maintenance and preparation of this equipment.

The lack of treatment capacity has caused the electronic equipment withdrawn from service to be confined in predetermined areas with strict observance of the safety requirements established, until real numbers of these units and the alternative treatments to be applied in the country are determined.