MINUTES OF THE OPEN HOUSE SESSION “PROBLEMS FACED BY PESTICIDES INDUSTRY IN THE PROCESS OF REGISTRATION OF PESTICIDES” HELD ON 19-05-2010 IN THE CONFERENCE HALL OF CENTRAL INSECTICIDES LABORATORY (CIL), FARIDABAD

An open house session to deliberate upon the various issues and problems of Pesticides Industry in the registration process of pesticides was held in the Conference Hall of Central Insecticides Laboratory (CIL) at 11.00 AM on 19-05-2010 under the Chairmanship of Dr. Gurbachan Singh, Agriculture Commissioner & Chairman, Registration Committee. Dr. P.S. Chandurkar, Plant Protection Adviser to the Government of India, Shri S.K.G. Rahate, I.A.S., Secretary (CIB&RC), experts from the secretariat of CIB&RC and representatives of various Pesticides Industry Associations were also present.

At the outset Secretary (CIB&RC) extended a very warm welcome to Agriculture Commissioner, PPA, representatives of different Pesticides Industry Associations and experts of CIB&RC. He emphasized the importance of such an interaction which was long overdue as it would serve as an effective platform to have a first hand feedback on the various issues concerning the pesticide industry thereby helping the system to gear up by improving its efficiency, accountability and transparency. Later, Chairman expressed his gratitude and also extended a warm welcome to all the participants who have come from far off places. The presence of large number of participants from Industry Associations clearly indicated the interest of the Industry for resolving the issues by sitting across the table. Chairman also emphasized that the basic objective for conducting such an open-house session is to crystallize and resolve the various issues/problems so as to increase the transparency and efficiency in the pesticide registration system which would ultimately result in the benefit of Indian farmers. He acknowledged the tremendous contribution made by Pesticide Industry in Indian agriculture and stressed that there is still enough potential to contribute to the overall growth of agricultural productivity. Such an interaction helps in bringing together different group having diverse opinion which ultimately would help in bringing more transparency and improving the overall system to the satisfaction of all. After a brief introduction by all the participants, Secretary, CIB&RC requested the representatives of each Pesticides Associations to raise the issues concerning them.

2. List of participants is at Annexure-A.

3. Issues raised by Crop Care Federation of India (CCFI)-

The representative of CCFI appreciated the initiatives taken by CIB&RC and DAC for simplifying the registration process by doing away with the preliminary scrutiny of applications u/s 9(4) Technical Import (TI), Formulation Import (FI) and

Formulation Indigenous Manufacture (FIM); Export Category and Extension of Validity of Certificate of Registration (CR) of Biopesticides u/s 9(3B) of Insecticides Act 1968; implementation of online filing of registration of pesticides (Computerized Registration of Pesticides-CROP). Thereafter, the following suggestive measures were given by the representatives of Pesticides Industry Associations:-

(i)    Organising such Open-House Session with the Pesticides Industry Associations at least once in every six months be institutionalized.

(ii)   The Guidelines for registration of technical import of pesticides are very old and needs to be reviewed .

(iii)  Data on Metabolism Study on technical grade of pesticides with reference to radio labelled compounds should be considered according to the studies conducted with other methods due to advancement of science as is being done and accepted in foreign countries.

(iv) The letter for ICAR comments should be sent parallel along with the scrutiny under bioefficacy instead of sending the letter after the completion of scrutiny.

(v)  To avoid the reported lacing of several bio-pesticides with chemical pesticides, an undertaking in the form of an affidavit may be asked from the manufacturers of bio-pesticides.

(vi) Patent Act/Data Protection- Registration Committee should do away with this condition and resolve this issue.

(vii) Registration Guidelines for use of surfactant with herbicides- The word ‘Registration’ should be replaced with ‘endorsement’ as it is a endorsement of already registered herbicides with surfactant .

(viii)   The cases for any kind of endorsement on Certificate of Registration and Label/Leaflet claims may not be taken to RC.

(ix) Certain day-to-day operational issues were also raised for the information of the house so as to find a suitable redressal.

(x)  The registration for import of formulation without registering technical should be dispensed with in the interest of the Indian industry.

4. Issues raised by Crop Life of India (CLI)

The representative of Crop Life of India appreciated the efforts of regulators for streamlining and bringing transparency in the registration system by introducing online registration of Pesticides. Thereafter, the following suggestions were made by the representative:-

(i) Facility of a    preliminary Interactive Session with the concerned technical expert be given before submission of applications U/s 9(3).

(ii)   Issuing of Import Permit on priority to allow initiation of data generation well in time.

(iii)  Accelerated Storage Stability data should be allowed in registration of new molecules which would fasten the registration process as is being done and accepted in foreign countries.

(iv) ICAR comments should be dispensed with as the data submitted for registration is generated through ICAR system and/or State Agricultural Universities.

(v)  Revival of Guidelines for registration of safer formulation of pesticides(vi) Standardization of Protocols for bioefficacy studies.(vii) Streamlining of endorsement cases(viii) Harmonization of Guidelines in accordance with OECD Guidelines.(ix) To encourage introduction of new molecule in the country the guidelines for

Formulation Import without registering its technical should remain effective in the overall interest of Indian agriculture.

5. Issues raised by Pesticides Manufacturer and Formulators Association of India (PMFAI)

The representative of PMFAI appreciated the efforts made by the Secretariat for bringing improvement in the registration system. Thereafter, the representative submitted the following suggestions:-

(a)  The Guidelines for import of formulation without registering technical should be dispensed with in the interest of Indian industry. This issue was also raised in the Prasad Committee 2005 and the Committee also recommended for doing away with these Guidelines.

(b) Patent and Data Protection- This should not be allowed as the Patent Act is dealt by different Ministry for different purpose.

(c) Guidelines for new source - In the Guidelines the data on bio-efficacy is required on all the crops. It was suggested that data on representative crops only may be asked for under this category. They also suggested single season bioefficacy data in place of two seasons.

(d) In the Certificate of Registration issued for Export purpose in the caption ‘For Export Only’ the word ‘only’ be deleted.

(e) Technical Import for making its formulation for export be allowed in Export Category.

6. Issues raised by Confederation of All India Small & Medium Pesticides Manufacturers Association ( CAPMA)

(a)  The representative of the Association has requested to extend the cut-off date for on-line submission beyond 31-05-2010 as they are facing difficulty in e-Payment of Registration Fee and requested for continuation of manual submission of applications for registration for another few months.

(b)  The enclosures pertaining to establishment of bona-fide of the manufacturers/firms like PAN Card, SSI registration, Company Incorporation Certificate etc be stored in the data bank of the Registration Secretariat and may not be asked from the applicant every time.

(c)  Removal of restriction for submission of three applications in a month U/s.9(4) Category.

(d)  Removal of Consent Letter in case of FI and/or TI U/s.9(4).(e)  In the guidelines of Technical Import from new source only one season data

on bioefficacy be allowed for acceptance instead of two season data.(f)   In data requirement for formulation import, the environmental dependent

toxicology data should be dispensed with.(g)  Patent Act/Data Protection- This should be stopped by RC. Let the matter be

taken up by the concerned Ministry governing Patent Act.(h)  Dual Use Pesticides- Suggested for review of existing Guidelines.(i)    Condition for two-year validity on Certificate of Registration be deleted.

7. Issues raised by Federation of pesticides Manufacturers’ Association (SSI) (FOPMA)

(i) The natural extracts are to be registered without much rigor. With Bioefficacy and acute toxicity it can be registered as provisional registrants.

(ii) If food additives and drugs in large dose act as pesticide, they are suitable for immediate registration, provided biological efficacy is produced.

(iii) Some brand new extracts will be good but to determine the chemicals in it and structure may take time. And if they are satisfactory on other aspects they can be registered. .

(iv) Industries at crossroads in pesticides and meaningful unorthodox approach is needed. Regulatory authorities should not throttle natural innovation.

8. Issues raised by Home Insect Control Association (HICA)

(i)    Suggested for separate channel/dispensation for scrutiny of applications for house-hold insecticides.

(ii)   Accelerated Storage Data be accepted for approving shelf-life of the product for registration as is done in other countries which would reduce the currently required time of two years to a mere two weeks.

(iii)  At present data on bioefficacy is accepted from National Laboratories. It was suggested that data be accepted from any GLP accredited laboratories.

(iv) In cases where inert ingredients/adjuvants are changed and a. i. remains the same, such applications for registration should be considered without any scrutiny.

(v)  Speeding the process of issuing deficiencies, so that after rectification of deficiencies Registration Certificates are issued at the earliest.

9. Issues raised by All India Biotech Associations

(i) To curtail the contamination of bio-products/bio-pesticides with chemicals an undertaking be taken from the manufacturer/firms so that genuine manufacturers should not suffer.

(ii) For granting extension in registration certificate of bio-pesticides U/s.9(3B) the time period should be counted from the date of issue of the extension letter.

(iii) Since the research institutes like TNAU, IIHR, KAU etc., are engaged in generation of data package for registration of bio-pesticides u/s 9(3B)&9(3) and as they are not ready with the data package the cut off date i.e. 1st July 2010 for the implementation of new guidelines be extended by another one year.

10. Issues raised by Haryana Pesticides Manufacturers Association (HPMA)

(i) Request for generation of Bio-efficacy data for one season instead of two seasons for registration of pesticides u/s 9(3) TI New Source.

(ii) Repeated trials on different animals pertaining to toxicological environment dependent data for the same product may not be asked.

(iii) Registration for Formulation Import of pesticides without registering technical grade is against the interests of Indian economy and the industry is engaged in the formulation of pesticides. Hence, RC should do away with Formulation Import.

(iv) Under the category Formulation Import (FI) Vs Formulation Indigenous Manufacture (FIM) no data should be asked from the applicant for this purpose.

(v) Since India is a signatory to Patent Protection under WTO, data protection should not be given to the MNCs.

(vi) Under Category 9(4) TIM the requirement for drawal in-process sample and analysis in CIL be dispensed with.

(vii) The registration applications pending more than 6 months u/s 9(3) for want of deficiency reply from the applicant should be rejected at the Secretariat level.

(viii) To curb illegal imports of pesticides and lacing of bio-pesticides with chemical pesticides a stable mechanism be evolved at DAC level.

11. Issues raised by Maharashtra Biocontrol

(i) New guidelines for registration of bio-pesticides under different categories are very harsh and requested for applying these provisions for registering new

molecules only.

(ii) The Secretariat of CIB&RC is not accepting the data on bioefficacy generated by other institutes except TNAU, IIHR, KAU.

(iii) Blaming contamination of bio-pesticides with chemical pesticide is scientifically incorrect as chemical pesticides will affect the potency of the so called contaminated bio-pesticide.

12. Issue raised by Gujarat Pesticides Association

Import of Formulation without registering technical should not be allowed in the interest of Indian industry.

13. Issues raised by Andhra Pradesh Pesticides Manufacturers Association

(i) Import of Formulation without registering technical should not be allowed which is just an exploitation of Indian farming community and indigenous manufacturers. There is no quality control of technical used for the formulation being imported into India.

(ii) The requirement of a Consent Letter from source of technical import and formulation import for registration u/s9(4) should be dispensed with.

(iii) Enclosures required for establishing the bona fide of the applicant under the online filing of registration applications may not be asked every time from the applicant. Once the bona fide of the applicant has been established with the Secretariat a Unique Identification Number (UID) may be assigned which can then be used in subsequent applications by the same applicant.

14. Bio Agri Pesticides Association (BIPA)

(i) Since the research institutes like TNAU, IIHR, KAU etc., are engaged in generation of data package for registration of bio-pesticides u/s 9(3B) & 9(3) and as they are not ready with the data package for registration u/s9(3) the cut off date i.e. 1st July 2010 for implementation of new guidelines be extended by another one year.

(ii) BIS specifications may be formulated for allowing the level of contaminants in bio-pesticides.

(iii) Separate guidelines may be formulated for registering botanical extract in case they are required to be regulated under Insecticides Act 1968.

15. Issues raised by MGR Industry Association

(i) Inadequacy in Form-I during e-filing of applications. (ii) Review of guidelines for registration u/s 9(4).(iii) Preliminary Scrutiny be dispensed with in all the categories of applications.(iv) Speeding up of the pending Endorsement cases(v) Removal of two-year validity condition from Certificate of Registration u/s9(4).

After due deliberations on the above issues raised by various Industry Associations, the issues can be classified into following three categories on which action points that emerged are summarized below :-

A. Common issues affecting industry Associations

      I.        Metabolism study

There is requirement for accepting data on metabolism studies in plant and animals with radio labelled technical grade material of the pesticides. Industry Associations was of the view that with the advancement of science certain new methodologies have come up for such studies. It was decided that Industry Associations should provide base material along with international scientific evidence for considering this issue in its entirety by the Registration Committee.

(Action - Pesticide Industry Associations-CCFI )

    II.        Accelerated Storage Stability study for shelf-life of pesticides

This was deliberated in detail and clarified that this study can be accepted for granting provisional shelf-life for any product to be registered to curtail time for registering any new molecule. However, the applicant has to generate shelf-life of the product in ambient conditions as per the requirement of Registration Committee guidelines for granting regular shelf-life to the product.

(Action- As clarified by the Sectt. of CIB&RC)

   III.        Primary Interactive Session with Experts of CIB&RC before filing of applications.

Secretariat of CIB&RC has already fixed Tuesdays and Thursdays for the pesticide industry representatives to visit the Secretariat and meet experts/Secretary to discuss and seek clarifications on any issue concerning the registration process. In fact it is a routine practice of pesticide industry representatives visiting Secretariat of CIB&RC(Tuesdays & Thursdays) to discuss various issues including the introduction of new molecules in India as per the need arising from time to time. As such, there is no need to frame any specific guidelines/yardstick for this purpose.

Action- - As clarified by the Sectt. of CIB&RC )

  IV.        Seeking ICAR comments

As per the existing practice the letter for seeking ICAR comments are sent after the file is scrutinized and found complete from bio-efficacy discipline. As per the decision of RC the ICAR comments should reach to Secretariat of CIB&RC within 30 days. But mostly the ICAR comments are delayed and the cases are pending in the Secretariat for consideration of RC. It is well known that the bio-efficacy data is generated through ICAR and/or SAU system and the ICAR comments are basically the verification of generation of this data from various institutes. In order to avoid delays arising from the receipt of ICAR comments, it is proposed that if ICAR comments are not received within 30 days, it will be deemed that ICAR has no comments to offer and the case would be taken to RC for necessary deliberation/approval. This is in consonance with RC decision taken in 222nd meeting.

Action- Secretariat of CIB&RC and Registration Committee)

    V.        Harmonization of data requirement as per OECD and EU Guidelines.

This is very scientific and broad issue which needs to be discussed in a group of high level scientists in the field of medical toxicology, chemistry, bio-efficacy as well as environmentalists and scientists from Industry Associations. Accordingly, a Committee may be constituted by the RC for this purpose.

(Action- Registration Committee &Pesticides Industry Associations)

  VI.        Registration Certificates kept pending due to Patent issue

It was clarified by the Secretary that as on date no Registration Certificates are pending due to any patent related issue. In an appeal, recently heard by the Hon’ble Appellant Authority in the DAC, it has been decided that Registration Committee cannot hold up the process of granting the Registration Certificates on the basis of the patent infringement claim. Thus, RC may issue a Certificate of Registration with a stipulation that any liability arising out of an infringement of any other law including the Patent Act 1970 shall be the sole responsibility of the registrant. The above decision was in consonance with the advises received from Department of Industrial Policy and Promotion (DIPP) and Ministry of Law.

(Action- As clarified by the Secretariat of CIB&RC)

VII.      Relaxation in bio-efficacy data in Technical Import/Formulation Import - New Source Category

As per the existing guidelines two seasons multi-location data on bio-efficacy is required for the above category of registration. Industry Associations requested that one season data on bio-efficacy may be accepted instead of two seasons. A suitable justification along with scientific justification/ basis may be submitted by the Pesticide Industry Associations for the consideration of the Registration Committee.

(Action- Secretariat of CIB&RC and Pesticides Industry Associations)

VIII.        Issuance of Import Permit for Research, Test and Trial Purpose (data generation)

The Pesticides Industry Associations were of the view that a lot of time is being taken by the Registration Secretariat for issuing import permit for research, test and trial purpose. This delay affects their planning and even at times a crop season is missed for the required experimentation. Accordingly, they requested that these applications may be scrutinized on priority and a proper time frame be decided for this purpose. The Sectt. of CIB &RC has taken adequate measures in expediting the issuance of import permit for research, test and trial purpose. However, the applicant is required to carry out the complete information with reference to quantity required for carryout the test in respect of various disciplines along with justification. Also, this issue would be taken up for discussion in Registration Committee meeting.

(Action- Pesticides Industry Associations and Registration Committee)

  IX.        Patent and Data Protection

There have been diverse opinion of the Pesticide Industry Associations on this issue. All Associations except Crop Life India opined that RC should avoid interference in the Patent Act and Data Protection as appropriate provisions have already been made in the said Act. A suitable justification quoting the relevant provisions in the Patent Act may be submitted by the Pesticides Industry Associations for taking appropriate decision by RC.

(Action- Pesticides Industry Associations)

B. Issues having policy ramifications

(i)            Import of formulation of pesticides without registering technical.

This issue was deliberated in detail. Most of the Associations except Crop Life Association was of the opinion that formulation import of pesticides

without registering technical may not be allowed in the interest of Indian farmers and Indian Pesticides Industry. A suitable scientific justification giving factual position may be submitted by the Pesticides Industry Associations for taking appropriate decision by RC.

(Action- Pesticides Industry Associations and Registration Committee)

(ii)          Guidelines for Safer Formulations

In the past RC has formulated guidelines for registering safer formulations of the already registered pesticides. But, there has been problems in establishing the definition of safer formulation of an insecticide. Thus, RC dispensed with the above guidelines. However, in case Industry/Associations can submit some scientific justification as well as criteria for identifying safer formulations, RC may reconsider this on the basis of appropriate scientific justification.

Action - Pesticide Industry Associations and Registration Committee )

(iii) Extension of date of implementation i.e., 1st July 2010 of new Guidelines for registration of bio-pesticides.

Since the research institutes like TNAU, IIHR, KAU etc., are engaged in generation of data package for registration of bio-pesticides U/s. 9(3B), 9(3) and they are not ready with the data package for registration U/s.9(3) hence, the cut off date i.e., 1st July 2010 for implementation of new guidelines be extended for another one year. A suitable scientific justification giving factual position may be submitted by the Pesticides Industry Associations for taking appropriate decision by RC.

Action- Bio- Pesticides Industry Associations and Registration Committee)

(iv) Evolution of mechanism to prohibit illegal import of pesticides and lacing of bio-pesticides with chemical pesticides

This issue was deliberated in detail. Considering the sensitivity, danger and illegal activities it was decided that a suitable proposal may be submitted by Pesticides/Bio-Pesticides Industry Associations for curbing this menace for further necessary action at appropriate level.

Action- Pesticide/Bio- Pesticides Industry Associations.

(v) In the Certificate of Registration issued for Export purpose in the caption ‘For Export Only’ the word ‘only’ be deleted.

This matter was raised by almost every Pesticides Industry Associations that their members engaged in export of pesticides facing

difficulty with the caption ‘Export Only’ written on the Registration Certificate. Therefore, they requested for removal of the word ‘Only’ from ‘Export Only’. The appropriate decision in this regard would be taken by the Registration Committee.

(Action-Registration Committee)

(v) Registration of Botanical Pesticides

Federation of Pesticides Manufacturers’ Association (SSI) (FOPMA) requested that the natural extracts may be registered as provisional registrants on the basis of bioefficacy and acute toxicity data and emphasized that regulatory authorities should not throttle natural innovation. This issue would be discussed in the Registration Committee.

Action-Registration Committee)C.           Specific day-to-day issues

(i) Speedy issuance of 9(4) Certificates of Registration(ii) Quick disposal of Endorsement cases(iii) Grant of Import Permit on Priority for data generation(iv) Standardization of UID system for establishing bona fide of applicants(v) Sorting of some teething problems faced by industry in E-Filing of applications

The suggestions of the Pesticides Industry Associations on the above points were noted. Keeping in view the in-flow of applications for registration and relevant workload the above issues will be reviewed at the Secretariat level and appropriate measures shall be undertaken. For the issues pertaining to e-filing of applications, NIC shall be requested for rectifying the same at the earliest.

Action- Secretariat of CIB&RC and NIC.

The meeting ended with vote of thanks to the Chair.

ANNEXURE-A.

LIST OF PARTICIPANTS OF OPEN HOUSE SESSION ON PROBLEMS FACED BY THE PESTICIDES INDUSTRY ASSOCIATIONS IN REGISTRATION OF PESTICIDES HELD AT 11.00 AM ON 19-05-2010 IN CONFERENCE HALL, CENTRAL INSECTICIDES LABORATORY (CIL), FARIDABAD.

S.NO NAME DESIGATION/ORGANISATION

a. Dr. Gurbachan Singh Agriculture Commissioner & Chairman (Registration Committee), Government of India, Ministry of Agriculture

2. Dr. P. S. Chandurkar Plant Protection Adviser to the Government of India, Directorate of PPQ&S.

3. Shri S.K.G. Rahate, I.A.S.

Director (PP) & Secretary, Central Insecticides Board & Registration Committee .

4. Dr. Sushil K. Khurana Joint Director (Medical), Central Insecticides Board & Registration Committee.

5. Dr.(Mrs.)Sandhya Kulsreshtha,

Specialist Grade-I (Pharmacology), MOHFW, Nirman Bhavan, New Delhi.

6. Dr. Hari Prasad Joint Director (Chemistry), Central Insecticides Board & Registration Committee.

7. Dr. A.K. Sinha Joint Director (Plant Pathology), Central Insecticides Board & Registration Committee.

8. Dr. B.S. Phogat Joint Director (Weed Science), Central Insecticides Board & Registration Committee

9. Dr. R.M. Shukla Deputy Director (Entomology), Central Insecticides Board & Registration Committee.

10. Er. S.K.Ghosh, Consultant,(Packaging), Central Insecticides Board & Registration Committee

11. Shri Rajvir Singh Deputy Director (Chemistry), Central Insecticides Board & Registration Committee.

12. Dr. Subhash Kumar Assistant Director (Weed Science), Central Insecticides Board & Registration Committee

13. Dr. Vandana Seth Assistant Director (Chemistry), Central Insecticides Board & Registration Committee

14. Ms. Kamlesh Miglani Assistant Director (Chemistry), Central Insecticides Board & Registration Committee.

15. Shri S.K. Sharma S.O.(CIR.I), Central Insecticides Board & Registration Committee

16. Shri S.K. Verma S.O.(CIR.II), Central Insecticides Board & Registration Committee

17. Sh. D.S. Sehrawat PPO(Packaging),Central Insecticides Board &

Registration Committee18. Sh. Niraj Kulshrestha Assistant (Legal), Central Insecticides Board &

Registration Committee19. Sh. R.D. Shroff Chairman, CCFI20. Sh. P.P. Dave President, PMFAI21. Dr. RBL Bhaskar Adviser (Registration CCCFI matter)22. Sh. K.U. Kamath HICA, Mumbai23. Sh. KNG Mathan Secretary, Home Insect Control Association24. Dr. M.P.Prasad Home Insect Control Association(HICA)25. Sh. R.G.Agarwal Dhanuka Agritech Ltd.26. Sh. V.K. Agrawal MGRI Industry Association27. Sh. N.K. Aggarwal HPMA (Haryana)28. N.N. Mishra President, MGR Industries Association, Delhi.29. Dr. K.N. Singh Crop Care Federation30. Ajit Kumar Crop Care Federation31. S.N. Gupta CCFI32. Raj Kumar Singh Regional Executive Director (PMPAI)33. Sh. Uttam Gupta Resident Director, Crop Life India34. Sh.Rajesh Dhawan Crop Life India (CLI)35. Sh. Bhupender Sharma Crop Life India36. Sh. S.S. Manhas Rop Life India37. Abraham Mathew Crop Life India/DuPont India38. Ravindranath S. Hegde Crop Life India

(Makteshim Agan India)39. Sh. P.S. Rawat United Phosphorus Ltd.40. Dr. Venkatesh Devanur BIPA (BIO-Agri) Inputs Producers Association,

Hyderabad41. Sh. Manjula T.R. BIPA (BIO-Agri) Inputs Producers Association,

Hyderabad42. Sh. Sanjay Gupta Member, Pesticides Manufacturer Association43. Sh. Sanjay Jindal -do-44. Sh.Ramesh Bansal Monsoon Agrochemical45. Sh.Subhash Khurana President Pesticide Manufacturer Asso.,Karnal46. Sh. Pankaj Drolia Pesticide Manu.Association47. Dr.A. Sanyal P.I. Industries Ltd.48. Dr. S.K.Biswas Indofil Chemicals Co.49. Dr.S.Bedi Rice Co.International inc.50. Dr.P.Roychowdry M/s.Sumitomo Chemical India Pvt. Ltd.51. Sh.Dinesh Prajapati M/s.Punjab Chemical & Crop Protection

Ltd.,Mumbai.52. Sh.S.S.Bhatnagar M/s.Ecosense Lab, Mumbai.53. Dr.Muralikrishna M. M/s.Nagarjuna Agrichem Ltd.54. Sh.Sushil Gather M/s.Indofil Chemicals55. Dr.Kusta Vaingankar M/s.P.I. Industries56. Sh. S.M. Ahsan -do-

57. Dr.Vijay Jha M/s.Rallis India Ltd.58. Dr. Anand Jha M/s.UPL59. Dr.M.Krishnan M/s.Rallis India Ltd.60. Dr.Brij Uberoi Crop Care Federation61. Dr.Suresh Pittehra M/s.Sulphur Mills Ltd.62. Dr.Sandeep Narwal M/s.Dow Agrosciences India Pvt.Ltd.63. Sh.Ramesh Singh M/s.Punjab Chemicals & Crop Crop Protection

Ltd.64. Dr.B.V.Niranjan Kumar M/s.Dow Agroscience India Pvt. Ltd.65. Sh.Yatin J.Mokal M/s.Cheminova66. Sh. Ashwani Saluja M/s.Yogi CropScience P.Ltd.67. Sh.Vinod Bhatt M/s.Agrochemical Association of India.68. Sh.M.Rajamahender

ReddyPresident CAPMA

69. Sh. Ganga Sahay Pathak

Vice President Gujarat Pesticides Formulation Association,Ahmedabad.

70. Sh.Jitendra Mohan M/s. Willowood Chemicals71. Sh.Vipin Saini Member, CCFI72. Sh.Gorakh Gadeker Member, Maharashtra Biocontrol Asso.,

Nashik73. Sh.Ramdas Patil President ,Maharashtra BioControl Association74. Sh. Rajendra Patil Vice Presidnet, MBMA, Nashik75. Sh.Y.Nayudamma Member, M/s. A.P.Pesticides Mfg .Association76. Sh.K.K.Gupta M/s.Haryana Pesticides Mfg.Asso.77. Sh.Soumen Khatua Member, M/s.Insecticides India Ltd.78. Sh. Rajiv Dhingra Member, All India Biotech Association,New

Delhi.79. Sh. Gunjan Verma Regulatory Affairs, M/s. Rickitt Benckiser80. Sh. Anuj V.S.N. Marketing, M/s. Rickitt Benckiser (HICA)81. Dr. V.K. Dingra ABMA, Hyderabad, Director Biorganics82. Dr.R.K.Singh M/s. Meghmani Agriscience83. Sh.S.K. Misra M/s.Crystal Phosphate84. Dr. Rajeev Goel M/s.Crystal Phosphate85. Dr.S.Sundaresan M/s.Ramcide(FOPMA)86. Dr.P.S.N.Srinivasn -do-( FOPMA)87. Sh.Subhash Singh M/s.Dhanuka,Delhi.