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WILDLIFEDIRECT

Evidence for revoking


registration of carbofuran
in Kenya
Report to the Ministry of Agriculture Task Force
on the impact of Pesticides on Wildlife and the
environment in Kenya.

Paula Kahumbu
5/17/2010
Evidence for revoking registration of carbofuran in Kenya

Contents
Summary ....................................................................................................................................................... 3
Carbofuran and its recommended use in Kenya ...................................................................................... 5
Carbofuran impacts to wildlife..................................................................................................................... 6
Lion poisoning with Furadan ..................................................................................................................... 8
Effects on vultures .............................................................................................................................. 12
Pesticide fishing and bird hunting for human consumption............................................................... 13
Misuse of Furadan for general pest control ....................................................................................... 14
Reporting of incidents of pesticide poisoning of wildlife to the PCPB................................................ 14
Recommendations on reporting of pesticide poisoning incidents ..................................................... 15
The potential impact of Carbofuran use on international trade in horticultural products ........................ 17
Current status of Carbofuran in USA ...................................................................................................... 17
Current status of Carbofuran use in the EU, Kenya’s most important export market ........................... 17
Recommendations .............................................................................................................................. 18
Public health considerations of carbofuran to users and consumers ........................................................ 18
Recommendations for public health................................................................................................... 20
Legal basis for revoking tolerance to carbofuran ....................................................................................... 21
Recommendations .............................................................................................................................. 23
Conclusions ................................................................................................................................................. 23
Acknowledgements............................................................................................................................. 24
Literature Cited ........................................................................................................................................... 25
List of Appendices ....................................................................................................................................... 29
Appendix I : Concentrations of residues of Carbofuran and its metabolytes in soil, water and plants in
Kenya from study by Otieno et al. (2010b). ............................................................................................ 29
Appendix II: Incident report of pesticide poisoning of wildlife in Tsavo ................................................ 32
Appendix III: Incident report of bird poisoning in Bunyala .................................................................... 34
Appendix IV Proposed Wildlife Poisoning data collection form ............................................................. 35

2
Evidence for revoking registration of carbofuran in Kenya

Summary
This report examines evidence of risks and impacts associated with carbofuran use in Kenya and
concludes that this deadly toxic pesticide is too dangerous for use and should be eliminated from use as
an agricultural pesticide in order to protect farmers, consumers and wildlife. Below are the bullet points
of key findings followed by a list of recommendations:

Carboruran is too dangerous for use in Kenya


o Pesticides are used throughout out Kenya, including extremely toxic compounds that
could kill many non target organisms including humans. Carbofuran, sold as Furadan in
Kenya is one of the most toxic chemicals used anywhere in the world,
o Carbofuran, though registered for “restricted use” is sold over the counter in Kenya.
There is no control over how carbofuran is distributed or used in the Republic of Kenya.
o Carbofuran is deadly toxic to humans and in November 2009 a 3 year old child died from
accidentally ingesting Furadan. Easy access has allowed it to be used in murder and
suicide.
o Dangerous concentrations of carbofuran and it’s metabolites have been found in soil,
ground water and on some crops in agricultural areas of Kenya.
o The risks associated with carbofuran exposure in Kenya are unacceptably high for
humans resulting in sickness and fatalities. The Kenyan health facilities (especially in
rural areas) are inadequate to cater for pesticide poisoning.
Carbofuran is not permitted in major export nations therefore it’s use in Kenya poses
unacceptable risks to the horticultural export industry
o Concentrations of carbofuran and it’s metabolites have been found in soil, water and on
peas grown in areas that produce crops for export.
o Residues of carbofuran are not permitted on food in USA, including imported food crops
o Carbofuran is not permitted for use in the European Union which regularly tests for
pesticide residues.
The Kenyan Government cannot enforce the safe use of highly toxic pesticides
o The PCPB in Kenya is responsible for the registration of pest control products and
ensuring their safe use, and mitigating potential harmful effects to the environment.
o It’s is unreasonable to expect the PCPB to implement their mandate given the resource
limitations of that institution in terms of staffing and finances.
o Though unlawful, pesticide misuse is widespread due to lack of enforcement
Carbofuran threatens wildlife and associated tourism industry
o Even when used according to label, carbofuran has caused mass die offs of wetland
birds in Kenya.
o Carbofuran is widely used, misused and abused in Kenya for vermin control and can be
found in pastoral areas of with no agriculture where it is primarily misused against
predators.

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Evidence for revoking registration of carbofuran in Kenya
o Kenya’s lion population is declining rapidly mainly as a result of poisoning with
carbofuran. Conservationists warned that lions in the country could go extinct within
ten years
o Even in highly regulated countries, Carbofuran is the leading cause of fatality for birds of
prey eg. in Scotland, USA, and Canada.
o Carbofuran is being misused in for fishing in lake Victoria and for hunting birds in
irrigation schemes, both for human consumption.

WildlifeDirect presents key benefits of revoking registration of products containing carbofuran in Kenya

1. To protect Kenyan farmers and consumers from the harmful effects of Carbofuran
residues on food and in the soil and water.
2. To protect international trade in Kenyan horticultural exports to regions where
Carbouran use and chemical residues on food items are not permitted.
3. To halt the unacceptable harm that Carbofuran is causing to key wildlife species
including lions, vultures, wetlands birds, fish and wetland invertebrates, and valuable
non target insects like bees and other pollinators and natural predators.

Recommendations

WildlifeDirect on behalf of members of the Stop Poisoning Task Force1 makes the following
recommendations to the Government of Kenya regarding the pesticide Carbofuran

1. In line with Europe and USA, immediately revoke registration of products containing
carbofuran and other carbamates in Kenya to protect users, consumers and wildlife.
This will also protect horticultural exporters.
2. Promote and incentivize farmers to use safer alternatives for pest control in agriculture
including Integrated Pest control methods (IPM) and natural pest control products like
neem Tephrosia vogelii (Azam et al. 2008)
3. Strengthen the capacity of the PCPB to provide effective nation wide pesticide training
and awareness creation for farmers and the general public
4. Strengthen enforcement of the law and ensure stiff penalties for pesticide misuse and
abuse
5. Significantly increase funding to the PCPB to ensure that this important institution can
achieve it’s mandate in full, including the establishment of mechanisms to track
pesticide use monitor the impact of pesticides on agriculture and the environment
6. Initiate and promote the use of a pesticide poisoning hotline and circulate approved
reporting forms for pesticide incidents from the general public and organizations to all
concerned.
7. Make public, quarterly reports of pesticide residue monitoring on food, water and
environment
8. Immediately enlist Kenya Wildlife Service on the board of the PCPB

1
The Stop Poisoning Wildlife Task Force comprises individuals representing the East African Wildlife Society,
Nature Kenya, Living with Lions, Raptor Working Group, Green Dreams, WildlifeDirect, Forest Action Network,
WWF, The Wildlife Foundation, and many other individual conservationists

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Evidence for revoking registration of carbofuran in Kenya

Carbofuran and its recommended use in Kenya

Carbofuran is one of the most poisonous carbamate pesticides and is a broad spectrum carbamate
pesticide that kills insects, mites and nematodes on contact or after ingestion (Wikipaedia 2010). It is
used against soil and foliar pests of field, fruit, vegetable and forest crops. It is sold in liquid and granular
formulations and is odourless and tasteless. In Kenya it is marketed as Furadan 5g which is sold over the
counter in local Agrovet stores, in 200gm containers for around Ksh 100. The Furadan 5G label (See
Figure 1) states that it is for the control of many important soil and foliar pests of agricultural crops. Its
active ingredient is carbofuran at a concentration of 5%. The label states that Furadan “is a systematic
insecticide/nematicide for the control of soil insects and nematicides/pests as well as early foliar feeding
insects on coffee, bananas, vegetables, maize, pineapple and beans”. On coffee2 it controls leaf miner,
root knot nematodes, rot mealy bugs, scales and white grubs. It is recommended for potatoes, maize
and vegetables (cabbage, turnips, beans, peppers, peas, okra, brinjals, cabbage, onions, and tomatoes),
bananas, pyrethrum, tobacco, and in nurseries including kale.

Figure 1. Furadan 5G Product label.

2
“Furadan®5G is soil applied in coffee, place 40 gm Furadan® granules in a circular band under tree canopy and
work the soil to incorporate.” Juanco. Website http://juancogroup.com/?id=4&spg=30

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Evidence for revoking registration of carbofuran in Kenya
The packaging of Furadan in Kenya suggests that this product is not particularly dangerous. The label3
which is in English and Kiswahili, simply states that the product is “harmful” and this is indicated below
the word CAUTION and next a yellow square with diagonal cross through it. It says keep locked away out
of reach of children. Additional precautions on the container can be found on the inner label which
notes that the product can be used “with minimum protective clothing ( ie. Light overalls, boots, and
cloth-lined rubber gloves).

On the inside label of the carbofuran container, are the warnings about environmental hazards “Furadan
5G is toxic to fish and should not be poured directly into water courses. The product is toxic to birds,
livestock and wild game if ingested. However, crops treated at recommended rates do not present any
hazard to livestock or foraging bees.” The label also warns “do not use on paddy rice in order to avoid
bird poisoning”.

More detailed information about the product and it’s action can be found in FAO (2002)

Carbofuran impacts to wildlife


According to FMC officials, carbofuran is a valuable pesticide for agriculture, and it became a pesticide of
choice following the global ban on DDT as a result of the long term devastating impacts of DDT on the
environment and wildlife (Linda Froelich FMC pers com4). This cataylsed the development of new
insecticides and short-lived poisons such as Carbofuran were brought in to replace DDT. However, over
time serious safety, environmental and health impacts of carbofuran have been documented. There is
growing evidence around the world that the environmental costs of using Carbofuran may exceed the
agricultural value generated. Carbofuran is highly toxic to wildlife including fish, mammals, birds and
many non target invertebrates due to unintended effects of labeled use, misuse due to farmer
ignorance, and abuse. In Kenya, conservationists warn that carbofuran poisoning is the leading cause for
the catastrophic decline of lions, vultures, birds of prey and wading birds.

Carbofuran first came under scrutiny in USA in the 1980s after EPA estimated that more than a million
birds were killed each year by the granular formulation that looked like seeds to birds. Following a
special review which began in 1985 the product began to be phased-out on September 1, 1991 with a
ban on the use of granular Carbofuran in certain ecologically sensitive areas (EPA 2009). The EPA then
initiated a ban on all granular formulations of Carbofuran, with five minor-use exceptions effective on
September 1, 1994. Prior to 1991, 80% of the total usage of Carbofuran in USA was in granular
formulations and the ban was established to protect birds and was not related to human health
concerns. Bird kills have occurred when birds ingested Carbofuran granules, which resemble grain seeds
in size and shape, or when predatory or scavenging birds have ingested small birds or mammals which
had eaten carbofuran pellets.

In its 2005 ecological risk assessment on carbofuran, EPA found that all legal uses of the pesticide were
likely to kill wild birds. If a flock of mallards were to feed in a carbofuran treated alfalfa field, EPA

3
The label for Furadan 5G sold in Kenya is available on the FMC website here
http://www.furadanfacts.com/ProperUse.aspx
4
The Minutes of a meeting between FMC officials and conservationists in Kenya can be found at
http://www.furadanfacts.com/LinkClick.aspx?link=Content%2fDocs%2fWildlifeDirect%2520FMC%2520meeting%2
520minutes%252015th%2520April%25202009.pdf&tabid=3787&mid=8190

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Evidence for revoking registration of carbofuran in Kenya
predicted that 92% of the birds in the flock would quickly die. According to Mineau (1993) it takes only
one granule of carbofuran to kill a small bird. Bird kills have occurred when birds ingested carbofuran
granules, or when predatory or scavenging birds have ingested small birds or mammals which had eaten
carbofuran pellets.

Similar reports of carbofuran impacts on birds have been made by Kenyan scientists who report that the
country’s vulture populations are plummeting due to unintentional poisoning of vultures (Ogada and
Keesing 2010, Virani 2010). It has been used as a pest control for ravens in Vipingo Kenya (N. Rottcher
pers com), as well as a potent means of hunting birds in Kenya’s irrigation schemes (Odino 2009).

Carbofuran is highly toxic to cats and other mammals. A survey by Odino and Ogada in 2008 reveals that
carbofuran is widely used, abused and misused in Kenya for pest control (Odino and Ogada 2008).
Reports received by WildlifeDirect confirm that a variety of pests are targeted in agricultural areas as
well as pastoral areas including mice, rats, ravens, stray cats and dogs, baboons and other primates,
moles, buffalo, lions, jackals, hyenas and even crocodiles

Figure 2. Furadan container in bucket of poisoned birds - Bunyala

Kenyans have been raising concern about Carbofuran impacts on birds since as early as the mid 1990’s
(Odino and Ogada 2008) (See Figure 2). Ornithologists at the National Museums of Kenya (NMK)
reported that carbofuran had killed large numbers of wild fowls (ducks) in Ahero and Mwea rice
schemes. Since that time the use of carbofuran has increased in Kenya and it’s impact on Kenyan wildlife
has been escalating. In their survey, Odino and Ogada (2008) revealed that carbofuran was being widely
used and misused in Kenya by farmers and was widely abused for killing lions in pastoralist areas. Many
other species were also affected including wading birds in irrigation schemes that were being hunted for
human consumption using bait laced with Furadan (see Figure 2). Non target species were also severely
affected including hundreds or thousands of vultures.

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Evidence for revoking registration of carbofuran in Kenya
In 2008, WildlifeDirect received numerous reports of carbofuran pesticide poisoning of a variety of
species which led to the hosting of a workshop on the 25th of April 2008 titled “Stop Wildlife Poisoning”
to bring government and NGO stakeholders together to examine the scale of the pesticide poisoning
problem. The meeting confirmed that the misuse of carbofuran was occurring a significant scale
country-wide, and was targeting a variety of pests in agricultural areas as well predators in pastoral
areas (WildlifeDirect 2009)5.

The awareness raised about pesticide poisoning by WildlifeDirect attracted further reports of pesticide
misuse in the country including cases of moles, mice, rats, ravens, stray cats and dogs, jackals, baboons
and other primates, moles, buffalo, lions, jackals, hyenas, crocodiles and even elephants using Furadan,
suggesting that Furadan is the pesticide of choice for vermin control and is commonly sought after and
used against a variety of pests (WildlifeDirect 2009)6.

Lion poisoning with Furadan


Poisoning of lions in Kenya is now a regular occurrence. On the 22nd of April 2010 three lions were killed
adjacent to Kenyas most important conservation area, the Masai Mara (see Figure 3). This brings to 8
the total number of known lion poisoning incidents in southern Kenya this year. Incidents of lion
poisoning using carbofuran is of global interest and has led to much local and international media
attention (eg. Barley 2008, CBS 60 Minutes 2009, Kemei 2009) and KWS confirm that poisoning is the
main threat to the survival of Kenya’s lions (KWS 2010) (see Figure 4). Communities claim that they
resort to using poison to kill lions in revenge for livestock loss through carnivore depredation. Typically,
the communities use the insecticide Furadan by applying it on livestock carcasses7 because this pesticide
works very rapidly and cannot be detected by the predators. Although suspects have admitted to
poisoning carcasses to kill lions, we are not aware of any culprits having ever been brought to justice8. In
addition, at least one case of suspected secondary poisoning has been documented after lions ate
hippos that had died from carbofuran poisoning in the Masai Mara (Heath et al. 2008). Scientists believe
that the rapid decline of Kenya’s lions is due to poisoning; Kenya’s lions have declined by 28% since 2002
(see Figure 5).

5
Although the minutes of the “Stop Wildlife Poisoning” workshop were shared with relevant government institutions including
the Ministries of Environment, Wildlife, Fisheries, Agriculture, and Livestock, WildlifeDirect received no acknowledgement of
receipt of these reports nor any response from any Ministry.
6
See Http://Wildifedirect.org, http://baraza.wildlifedirect.org, http://stopwildlifepoisoning.wildlifedirect.org,
http://lionguardians.wildlifedirect.org
7
This is according to Oguge in Kenyas Lions could vanish in 10 years. (Barley 2009).
http://www.newscientist.com/article/dn17648-kenyas-lions-could-vanish-within-10-years.html?full=true&print=true”
8 nd
According to sources at KWS a suspect admitted to killing three lions near Lemek on 22 April 2010 and was
arrested by KWS but released shortly thereafter.

8
Evidence for revoking registration of carbofuran in Kenya

Figure 3. One of 3 lion poisoned in Masai Mara April 2010

Figure 4. Causes of lion mortality 2008. Source KWS.

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Evidence for revoking registration of carbofuran in Kenya

Year Lion Population


2002 2,749
2004 2,280
2008 2,000
2010 1,970

Figure 5. Kenya's total lion population since 2002Source of data: Kenya Wildlife Service

Cats, birds and fish are especially sensitive to carbofuran poisoning – very low concentrations of the
pesticide can be fatal. At a stakeholder workshop coordinated by WildlifeDirect, government officials
heard many reports of lion, fish and bird poisoning in Kenya. Further reports of lion poisoning using
carbofuran emerged from Laikipia, Tsavo, Amboseli , Nairobi and Samburu have since emerged.

After lion poisoning incidents received international media attention through a popular USA News
program CBS 60 minutes in March 2009 (CBS 60 Minutes 2009), FMC Corporation agreed to withdraw
the product from the shelves in East Africa and to cease distributing the product in the region. FMC have
now initiated a Furadan buy-back program across East Africa, but do not admit that their product was
associated with the lion deaths9.

The Kenya Wildlife Service has also raised the alarm regarding the poisoning of lions which is a major
cause of the decline of Kenya’s lions with 76 being poisoned between 2002 and 2009. The impact of lion
poisoning on Kenyas image and tourism has led to debates in Kenya’s parliament regarding Furadan.
According to a report submitted to parliament in response to questions from MP for Naivasha and Chair
of the Agricultural Committee, Hon. John Mututho10 (National Assembly Official report, 2009), Furadan
was responsible for at least 40 lion deaths in 2008.

In response to the Parliamentary questions from Hon. John Mututho, Parilamentary Question 087, The
Minister for Wildlife, Hon. Noah Wekesa reported on the known scale of the pesticide poisoning
impacts on wildlife11.

9
In an FAQ on their website FMC state that their own investigations concluded that there was no connection
between the deaths of the lions and Furadan. http://www.furadanfacts.com/FAQs/tabid/3787/Default.aspx
10
John Mututho asked the Minister for Forestry and Wildlife whether he was aware of the damaging documentary
on Kenya which aired on CBS 60 Minutes, and if he could confirm the poisoning of lions as a result of Furadan
poisoning. Mr Mututho requested that the Minister for Forestry and Wildlife to effect an immediate ban on
Furadan pending further investigations.
11
Further details on questions and answers on this issue can be obtained from the official Hansard report (National Assembly
2009).

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Evidence for revoking registration of carbofuran in Kenya
“Our major concern is that the number of reports of Furadan associated wildlife deaths in Kenya are on the
increase. Moreover, Furadan is an agrochemical that should be used in agriculture but majority of the cases
reported occurred far away from agricultural areas indicating that Furadan is intentionally used to kill wildlife,
especially carnivores” said Noah Wekesa. The attached tables gives a summary of wildlife killed by Furadan
poisoning since 1995 to date . and table two indicates the lions killed by Furadan poisoning from 2002 to date
(See Figures 6 & 7).

Figure 6. Lion paralysed from secondary poisoning of carbofuran - Masai Mara 2008

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Evidence for revoking registration of carbofuran in Kenya

Figure 7. Table of wildlife affected by Furadan. Obtained from the official Hansard report (National Assembly 2009).

Effects on vultures
Dr. Muneer Virani, Dr. Darcy Ogada and Mr. Simon Thomsett, all Kenyan scientists and members of the
Raptor Working Group of Nature Kenya, have documented an alarming decline of up to 60% of Kenya’s
vultures primarily due to the abuse of the pesticide Furadan (Ogada et al. 2010). Vultures are the
unintended victims of efforts to kill lions and as a result, three vulture species, Hooded, Egyptian and
Lammergeyers are of critical concern in Kenya due to rapidly declining populations . Birds are especially
sensitive to this poison and being scavengers vultures are extremely vulnerable as they gorge
themselves on carcasses and in large numbers. In one incident 187 vultures died minutes after eating a
cow carcass laced with Furadan in Athi River near Nairobi (Thomsett 2006).

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Evidence for revoking registration of carbofuran in Kenya

Figure 8. 187 vultures poisoned after eating a carcass laced with Furadan in Athi River

Vulture poisonings have been recorded in Laikipa (Wildife Extra 2008), Tsavo, Athi River, Masai Mara
and Amboseli and this has been confirmed through toxicological tests (Otieno et al. 2010a). The
significance of vulture declines cannot be over stated, these birds are long lived and are essential to
ecosystem functioning in Kenya’s wild areas (Virani 2010). Ogada has documented significant declines of
other birds of prey including eagles and owls (Ogada and Keesing 2010). Virani (2010) warns of the dire
consequences of the vulture decline in Kenya considering the important ecological role that these
species play.

Pesticide fishing and bird hunting for human consumption

Carbofuran is also being misused to procure human food in fishing and bird hunting. Kenyan Scientist
Dino Martins revealed that the use of pesticide fishing in Lake Victoria not only kills fish which are sold

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Evidence for revoking registration of carbofuran in Kenya
for human consumption, but also kills a wide variety of insect larvae that fish depend on. Mr. Martins, a
Harvard University PhD candidate, warns that the existing as well as future fish stocks are at risk
(Martins 2010). Pesticide fishing not only threatens the users who handle Furadan with bare hands, but
it also poisons water bodies and all the organisms within it. Snails and invertebrates that die are in turn
consumed by fish and birds which are also subsequently poisoned.

National Museums of Kenya associate, Martin Odino reporting on WildlifeDirect’s website


(http://stopwildlifepoisoning.wildlifedirect.org) has documented the misuse of Furadan for poisoning
thousands of birds by lacing snails and other bait to catch wading birds in Ahero, Bunyala and Mwea rice
irrigation schemes. Snails are laced with Furadan granules that are left in the irrigation fields to be eaten
by a variety of wading birds including storks, snipes, egrets, ducks and others. After eating the laced
snail baits, large birds lose their balance and are killed with clubs. The birds crops are removed, the
feathers plucked and the meat sold in local markets as human food. Many of the affected birds are
migratory species, and some are rare. Mr. Odino has documented the sale and the consumption of
poisoned birds in local markets (Odino 2009). It is very likey that the consumers of these products are
exposed to dangerous levels of carbofuran.

Misuse of Furadan for general pest control

Other reports indicate that carbofuran is used widely for poisoning any pest including mice, rats, moles,
stray dogs and cats, primates, ravens, ungulates as well as predators. Apart from the abuse of the
product in poisoning pests. Farmers even use Furadan and other pesticides to ‘dust’ lambs to kill fleas
and ticks in areas around Masai Mara (Thomsett pers comm.).

Reporting of incidents of pesticide poisoning of wildlife to the PCPB


At the Stop Poisoning Wildlife meeting held on 25th April 2008, PCPB representatives challenged the
findings of scientists and toxicological reports from the Government Chemist that associated the use of
carbofuran in poisoning wildlife. The PCPB representatives requested that all pesticide poisoning
incidents be reported directly to the PCPB. The Executive Director of WildlifeDirect was verbally
requested to submit detailed written incident reports giving location, date, incident type and other
specific information. Several reports have subsequently been submitted (see Figure 9. Appendix I and II
as examples of reports submitted by WildlfeDirect and colleagues). Copies of all reports were also sent
to FMC representative Linda Froelich who had requested to be copied in on all wildlife poisoning
incidents in which Furadan was suspected to have been used.

However, to date, efforts to obtain information regarding actions taken by the PCPB in response to
these reports have been in vain. Various conversations with individuals at the PCPB confirm that the
reports have been received, though it is not clear if any actions have been taken on these incident
reports. At a recent meeting at the Ministry of Agriculture, a PCPB officer noted that there is no
mechanism for feedback, and that incident reports should not be made in writing but by phone to
ensure swift action though no feedback would be provided. There is no information on the PCPB
website about how to report suspected pesticide poisoning incidents, or any other pesticide related
incidents. As a result the PCPB records may underestimate the scale of the problem of pesticide
poisoning of wildlife.

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Evidence for revoking registration of carbofuran in Kenya

Figure 9. Table of reports submitted to the Pest Control Products Board by email and hard copy

Date reported to Response from


PCPB Incident type and victims Author PCPB
Minutes of Stop Wildlife Poisoning meeting
circulated to PCPB containing details of
presentations revealing the poisoning of lions
(Laurence Frank), Vultures (Peter Otieno Simon
Thomsett and Munir Virani), Fish (Dino Martins),
wetland birds (Martin Odino), lions in Masai Mara
2008.4.30 (Asuka Takita) (WildilfeDirect 2008) WildlifeDirect None
Letter to CEO of PCPB Gladys Maina requesting
follow up on WildlifeDirecdt hosted Stop Poisoning
2009.4.117 Wildlife Task Force meeting asking 5 questions Paula Kahumbu None

2009.5.20 Incident report on pesticide fishing in Lake Victoria Paula Kahumbu Dino Martins None

Incident report of bird hunting using Furadan in Paula Kahumbu and Martin
2009.5.22 Bunyala (see Appendix II) Odino None
Incident report of wildlife poisoning using Furadan Paula Kahumbu from Friends of
2009.5.23 in Tsavo killing numerous animals (see Appendix I) Tsavo None
Incident report of bird hunting (cattle egrets) using
2009.7.8 Furadan in Bunyala Martin Odino None

Apart from efforts to raise awareness about the impact of carbofuran on wildlife with the PCPB,
WildlifeDirect has also been hosting a series of meetings called “Stop Poisoning Wildlife” with key
stakeholders including Government and non government agencies including KWS, EAWLS, Nature
Kenya, Living with Lions, WWF, Tour companies and individuals (WildlifeDirect 2009). Numerous letters
and reports have been sent to relevant government agencies regarding the problem of pesticide
poisoning of wildlife with specific reference to the role of Furadan.

Recommendations on reporting of pesticide poisoning incidents


WildlifeDirect and other conservation groups would like to collaborate with the PCPB in order to collate
wildlife pesticide poisoning incident reports. Members of the WildlifeDirect coordinated Stop Poisoning
Wildlife Task Force have prepared a template for incident reporting to be considered for use by
scientists and conservationists in submitting reports to the PCPB (See Appendix IV).

We have also been contacted by concerned conservationists in South Cfrica, Uganda and Tanzania
where pesticide poisoning of wildlife using Furadan and other carbofuran based pesticides is also a
major threat to predators and other animals.

We recommend that pesticide incident reports submitted by WildlifeDirect and other organizations to
the PCPB become a part of the national record and are acknowledged on receipt and examined and
investigated on their merit. Given the seriousness of pesticide poisoning incidents which put public
health and wildlife at risk, we recommend that a mechanism be put in place to facilitate the submission
of pesticide poisoning incident reports by the general public. WildlifeDirect and other conservation

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Evidence for revoking registration of carbofuran in Kenya
partners look forward to working positively with the PCPB to refine a pesticide poisoning reporting form
(see Appendix IV). We also recommend that the PCPB initiate discussions with regional authorities on
the problem of pesticide poisoning. We are aware that any actions regarding pesticide poisoning using
Furadan and carbofuran/carbamate based pesticides in Kenya can succeed only if similar actions are
taken in neighbouring countries where similar problems have been reported. We are aware of specific
incidents in Ethiopia, Uganda, and Tanzania. One case of suicide has also been reported from Uganda. As
a leader in agriculture and conservation in the region, it is right that the Kenyan authorities take the lead
on this.

Finally, given the serious impact of pesticide poisoning of wildlife as a result of use, misuse and abuse,
we recommend that the KWS be given a permanent seat on the PCPB to ensure that the considerations
of wildlife are always taken into account by the Board.

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Evidence for revoking registration of carbofuran in Kenya

The potential impact of Carbofuran use on


international trade in horticultural products
Current status of Carbofuran in USA
On December 31st 2009 the Environmental Protection Agency in the United States (EPA) implemented a
decision to revoke all tolerance for carbofuran residues on food products due to dietary, safety and
environmental concerns (EPA 2009). Carbofuran is therefore no longer permitted for use in USA where it
is marketed as Furadan and manufactured by FMC Corporation in Philadelphia. This landmark decision
means that traces of the pesticide carbofuran can no longer remain on food sold in the United States,
whether sourced domestically or imported. EPA has concluded that "dietary, worker, and ecological
risks are unacceptable for all uses of carbofuran." This action eliminates residues of carbofuran in food,
including all imports, in a move to protect people, especially children, from dietary risk. EPA analysis has
also confirmed that carbofuran is a threat to human health through contaminated food, drinking water,
and occupational exposure.

The recent decision to eliminate the use of carbofuran in USA was not a surprise. Liquid formulations of
carbofuran in USA were already classified as Restricted Use Pesticides (RUP) because of their acute oral
and inhalation toxicity to humans. According to the EPA “Exposure to the pesticide carbofuran resulting
from existing legal uses is unsafe—unsafe for the general population, and particularly unsafe for infants
and children. EPA reached this conclusion in 2006 after an exhaustive multi-year review of the data on
carbofuran as part of its effort to determine whether carbofuran should be reregistered under the
Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”), and whether the tolerances allowing
carbofuran residues on certain foods met the revised safety standard in section 408 of the FFDCA. (Gov
Pulse 2009).

Although these finding have been challenged by the FMC Corporation, a government Scientific Advisory
Panel reviewed the decision and agreed with the EPA in 2008 that the pesticide poses an unreasonable
risk to the environment, particularly birds, and that there was no evidence to recommend reversing
EPA’s decision to cancel carbofuran.

Current status of Carbofuran use in the EU, Kenya’s most important export
market
Carbofuran has not been registered for use in the European Union and it has not been permitted for use
in UK since 2001 following extensive evaluations by the European Food Safety Authority (European Food
Safety Authority 2009). This is not surprising as consumers in Europe are increasingly concerned about
the presence of even trace amounts of pesticide residues in food as well as the negative environmental
effects of pesticide use (Jaffee 2003).

The evolution of increasingly higher standards in Europe means that “when actual residues are detected
– even of very low magnitude and even for approved uses - this residue would constitute a violation of
European Union standards and potentially lead to the detention and withdrawal of the consignment
from the market” (Jaffee 2003 pg. 14). If any residues of unapproved chemicals are detected, exported

17
Evidence for revoking registration of carbofuran in Kenya
products could be withdrawn and producers could face other penalties (Jaffee 2003). To date Kenya has
held very high standards and is known for high quality, clean horticultural exports. However, as the use
of pesticides increases country wide, exporters must ensure that only approved pesticides are used. In
the UK’S Pesticide Residues monitoring report First Quarter report for 2009, three samples of green
beans imported from Kenya contained residues of pesticides above the maximum permitted residue
level (MRL) (Pesticide Residues Committee 2009). This could potentially damage Kenya’s good
reputation which could lead to greater vigilance on Kenyan exports12. The growing use of pesticides in
Kenya may have benefits in terms of horticultural production levels, but it could have negative
consequences for sensitive export markets like the EU.

Recommendations
Kenya needs to maintain her reputation of clean, high-quality horticultural produce in order to maintain
her market leadership and should therefore mirror European Union standards for pesticide use in order
to maintain export market leadership in Europe and the USA.

We recommend that Kenya withdraw all certificates of registration of products containing Carbofuran
and other carbamates, in order for producers to comply with export market standards.

We also recommend that the Kenya Government explore and provide incentives for farmers to use low
pesticide agricultural practices such as Integrated Pest Management (IPM), Organic agriculture, and
promote the use of natural pesticides to protect users, consumers, markets and the environment.

Public health considerations of carbofuran to


users and consumers
Global concerns for the risks and hazards that workers and consumers are exposed to from toxic
pesticides have been summarized in a scholarly article published in 2007 by Dr. Konradson (2007). He
writes that

“Acute pesticide poisoning has become a major public health problem worldwide, following the
intensification of agriculture and the promotion of agro-chemicals in low and middle income countries,
with more than 300.000 deaths each year. The easy availability of highly toxic pesticides in the homes of
farming communities has made pesticides the preferred means of suicide with an extremely high case
fatality. Similarly, the extensive use of pesticides exposes the community to both long-term and acute
occupational health problems. A concerted effort is urgently needed to address the situation. In addition
The World Health Organization (WHO) estimates that three million people suffer from severe pesticide
poisoning episodes occur annually across the world. Of these, at least 300,000 die. Ninety nine percent of
the victims come from low and middle income countries”

12
The pesticide residues found were profenofos, acephate and demothoate which are not carbamates and levels
found were not thought to be harmful to humans. The secretariat action was to write to suppliers (Pesticide
Residues Committee, 2009).

18
Evidence for revoking registration of carbofuran in Kenya
The Kenya Government understandably seeks to intensify agricultural production as a means of feeding
the nation, but it must not do so at any cost. Given what is known about the dangerous side effects of
pesticides, the responsible way for Kenya to develop agriculture, is to take a precautionary approach
given the high stakes, low levels of farmer education, poor health facilities, and weak monitoring
facilities in country. At present the PCPB is inadequately resourced to undertake the necessary
monitoring to ensure compliance with pesticide use requirements, and monitoring of the environmental
impacts (Pest Control Products Board, 2007)

The negative effects of Furadan can be tragic. In November 2009, a 3 year old child, Nelson Kimutai,
passed away after accidentally ingesting Furadan granules in Sobokeret village, near Kitale. It took his
father 4 hours to reach a clinic, and even then efforts to save his life failed as the doctors did not treat
him with injections of atrophine sulphate which, according to the Furadan label, can reverse the effects
of carbofuran poisoning. No post mortem was conducted and this incident, though reported in the
press, was not reported to any Poison Center (Maina 2009)13.

The story of Nelson Kimutai illustrates that even educated Kenyan farmers like his father failed to
understand the need to store this dangerous pesticide in locked cabinets out of reach of children. He
believes that the manufacturer of Furadan misled him and failed to inform him of the potential dangers
associated with using Furadan14.

Figure 10. Nation Feature Article reports the deaeth of Kimutai

13
The doctor who handled the case was recorded on video and uploaded on Youtube here
http://www.youtube.com/watch?v=u0HhYK4oK0w&feature=player_embedded
14
In a phone conversation Mr Nahashon Kigai (Nelsons father) stated that he had kept the Furadan container in
the kitchen.

19
Evidence for revoking registration of carbofuran in Kenya
Kenya does not enforce limits on Maximum Residue Levels for pesticides, however, the exposure levels
of workers and consumers to carbofuran may exceed that of developed nations by several orders of
magnitude due to the methods in which the product is handled, and the purposes to which it is
employed (Otieno et al. 2010b). Furadan 5G is sold in small containers of 200 g for Ksh 100/- to a market
of mainly subsistence farmers. Although the product is supposed to be a restricted use product, it (and
other Class I and II pesticides) can be purchased easily over the counter at Agrovet stores. No training
for users is offered, no warnings about the required protective clothing, or warnings against misuse are
offered, no qualifications are required for use of this product, and no guidance is given on handling spills
or the disposal of containers (personal experience) 15. According to users in some rural areas, the
product is sometimes decanted into smaller packets and sold without any product information.

It is hard to imagine how a product like Furadan can be used safely in a developing country like Kenya.
Subsistence and domestic market horticultural producers in Kenya are generally poor and many are
illiterate and unable to read the labeled instructions. Few of these farmers in Kenya employ proper full
protective clothing and do not store agricultural products in locked cabinets, or launder their clothes
after application of pesticides. Many do not realize the dangers that they expose themselves and their
families to, by the handling of the products with bare hands, bare feet, or in terms of storage and in
using the product for non labeled use.

In an ICIPE report, French Bean farmers revealed that 21% of farmers reported have visited clinics for
treatment for maladies related to pesticide usage (ICIPE 2003). This may be an underestimate as the
Kenyan health system generally lacks the capacity to manage the many cases of acute poisoning such as
antidotes, respirators, trained staff and ambulances. In a 2008 workshop at ICIPE, experts agreed that
pesticide externalities exist in the vegetable subsector in Kenya affecting bees and other natural pest
enemies, domestic animals, birds and human health. 65% of the participants expected negative
externalities to their own health due to pesticide residues on the vegetables that they consume, and
74% of the experts identified pesticide/chemical run off and leaching as a key source of water pollution
in vegetable production systems.

Even if carbofuran use could be better regulated it may still not be safe enough as the USA EPA has
found. Recent research in Kenya reveals that even where the product has been used for agriculture
according to labeled instructions, carbofuran and its key metabolytes 3-hydroxycarbofuran and 3-
ketocarbofuran, have reached dangerous levels in soil and in ground water (Otieno et al 2010b) (See
Appendix I for detailed table of results). Carbofuran is soluble in water and has a moderately lengthy soil
half-life of 3-60 days (or longer), it therefore has a high potential for groundwater contamination. One
recent study in Laikipia (Otieno et al. 2010b) found soil and ground water contamination of carbofuran
as high as 1.823 mg/l - several orders of magnitude higher than the World Health Organization
recommendation of 20 micrograms per liter of water (World Health Organization 2004)16. See Table in
Appendix I.

Recommendations for public health


We recommend that Kenya adopts a precautionary approach to the use and distribution of dangerous
pesticides. We recommend that the overall aim of Kenya’s agricultural policies should be to eliminate
the most dangerous pesticides and to reduce the use of pesticides to the lowest level feasible by

15
I have personally been offered Furadan in a Kiserian Agrovet to kill jackals that I claimed were disturbing me.
16
The USA Environmental Protection Agency has recently revoked all tolerances for carbofuran in water and food.

20
Evidence for revoking registration of carbofuran in Kenya
investing in integrated pest management programs. This is in line with the United Nations
recommendations on the reduction and or elimination of POP pesticides which recommends that we do
not simply replace pesticide A with pesticide B but instead use this as an opportunity to re-think
strategies used in pest and vector control. Farmers can maintain or increase production levels using less
toxic and less pesticides when they understand the ecology of their systems. The Inter Organization
Program for the Sound Management of Chemicals (IOMC) recommends pesticide policy reform in
support of Integrated Pest and Vector management as the most cost effective and environmentally
sustainable approach (IOMC 2002).

The easy access to extremely toxic pesticides in the homes of the rural population throughout Kenya has
made misuse and deliberate abuse of pesticides a common means of dealing with pests and wildlife
conflicts. The availability of toxic pesticides may be causing widespread exposure to dangerous
substances especially in the occupational environment, and children, resulting in short and long-term
health impacts.

We recommend that the Government of Kenya identifies suitable, safe and environmentally friendly
alternatives to Furadan, and promotes integrated pest management practices that use minimal amounts
of pesticides.

Legal basis for revoking tolerance to


carbofuran
Leadrs in Kenya have expressed concern about the impact of carbofuran including Hon. John Mututho
MP for Naivasha and Chair of the Parliamentary Agricultural Committee, and Hon. Dr. Noah Wekesa the
Minister for Forestry and Wildlife17.

However, in various statements, officers of the PCPB have indicated that the misuse of carbofuran is not
a basis for it to be banned. Nevertheless, the Pesticide Control Products Act of Kenya (Laws of Kenya
1985) clearly empowers the PCPB to revoke the registration of any pesticide.

17
In December 2008 Mr John Mututho requested that the Minister for Forestry and Wildlife to effect an
immediate ban on Furadan pending further investigations. The Minister for Forestry and Wildlife stated
“We are therefore, concerned and would like to have it banned” Pg. 9 National Assembly Official report
2009.

21
Evidence for revoking registration of carbofuran in Kenya
Under The pest control product (registration) regulations

No. 8 (1) A certificate of registration issued under these Regulations shall, be valid for a period of three
years from the date of issue and may thereafter be renewed for periods not exceeding two year at any
one time”. Thus the PCPB could simply refuse to register the product.

Under section 10. The board may refuse to register a pest control product if in its opinion – (b) the
information provided to the board by the applicant is insufficient to enable the pest control product to
be assessed or evaluated;

(d) the use of the pest control product would lead to an unacceptable risk or harm to-

(i) things on or in relation to which the pest control product is intended to be used; or

(ii) public health, plants, animals or the environment.

11. (1) The board may suspend or revoke a certificate of registration issued under these Regulations
for such time as the Board may determine.

(2) The powers conferred in paragraph (1) shall not be exercised by the Board except on one or more
of the following grounds –

(b) that new information has become available to the Board which renders the pest control
product unsafe or dangerous.

Given the volume of research conducted in USA, the EU and Kenya revealing the scale of impact and
potential impact of carbofuran, we believe that the provision for revoking a certificate of registration
Clause 11. (2) (b) has been met.

Several conservation organizations, and thousands of Kenyan and global citizens are calling for the
withdrawal of registration of all products containing carbofuran in Kenya. The Defenders of Wildlife
have created an online Petition that has attracted tens of thousands of signatures (Defenders of Wildlife
2010). Care2 (2009) has 51,671 signatures as of 15 May 2010. WildilfeDirect collected hundreds of
signatures in Nairobi during the Pride of Kenya exhibition

22
Evidence for revoking registration of carbofuran in Kenya

Defenders of Wildlife, EAWLS (2009), ICIPE, Nature Kenya (Munguti 2009), WildlifeDirect, and others
have written independently to various ministries seeking a ban on the use of carbofuran in Kenya.

Recommendations
We recommend that the Government of Kenya acknowledge and address the public concerns raised
regarding the health and safety of farm workers, the health and safety of consumers of vegetables and
water, and the effects of carbofuran on wildlife and the environment. We urge the government to use
the provisions in the Pest Control Products Act (1985) that allow for suspending and revoking certificates
of registration while considering a total ban on carbofuran and carbamate based pesticides. Kenya
should consider taking the global lead on this issue to demonstrate the seriousness with which she takes
occupational health and wildlife conservation concerns.

Conclusions

It is our view that the Kenya Government should take a precautionary approach to the use and
distribution of dangerous pesticides. We recommend that the overall aim of Kenya’s agricultural
policies should be to eliminate the most dangerous pesticides and to reduce the use of pesticides to the
lowest level feasible by investing in integrated pest management programs. The easy access to
extremely toxic pesticides in the homes of the rural population throughout Kenya has made misuse and
deliberate abuse of pesticides a common means of dealing with pests and wildlife conflicts. The
availability of toxic pesticides may be causing widespread exposure to dangerous substances especially
in the occupational environment, and children, resulting in short and long-term health impacts.

For decades conservationists have been warning about pesticide impacts on wildlife. It is our view that
the Kenya Wildlife Service should be on the board of the PCPB in order to advise on the potential impact
of any pesticide being considered for registration.

While our primary recommendation is to remove carbofuran and carbamate based pesticides from use
in Kenya, we realize that this alone will not save Kenya’s lions and other wildlife. Even in Scotland where
carbofuran is not authorized for use, it is the main cause for raptor deaths (Hunter et al 2003). Removing
carbofuran from the shelves is an important step towards dealing with the underlying problem of
wildlife conflict with humans. We believe that the poisoning of wildlife would be reduced significantly
following the removal of this toxic pesticide. This will provide opportunities for the authorities and
NGO’s to work with communities on other solutions to the conflict problem. In addition, the Kenyan
farmers and consumers of Kenyan horticultural crops be safer.

23
Evidence for revoking registration of carbofuran in Kenya
In our opinion, action is required at a national level to reduce pesticide poisoning as a national public
health and wildlife conservation problem.

WildlifeDirect makes the following recommendations to the Government of Kenya regarding pesticide

9. In line with Europe and USA, immediately revoke registration of products containing
carbofuran and other carbamates in Kenya to protect users, consumers and wildlife.
This will also protect horticultural exporters.
10. Promote and incentivize farmers to use safer alternatives for pest control in agriculture
including Integrated Pest control methods (IPM) and natural pest control products like
neem Tephrosia vogelii (Azam et al. 2008)
11. Strengthen the capacity of the PCPB to provide effective nation wide pesticide training
and awareness creation for farmers and the general public
12. Strengthen enforcement of the law and ensure stiff penalties for pesticide misuse and
abuse
13. Significantly increase funding to the PCPB to ensure that this important institution can
achieve it’s mandate in full, including the establishment of mechanisms to track
pesticide use monitor the impact of pesticides on agriculture and the environment
14. Initiate and promote the use of a pesticide poisoning hotline and circulate approved
reporting forms for pesticide incidents from the general public and organizations to all
concerned.
15. Make public, quarterly reports of pesticide residue monitoring on food, water and
environment
16. Immediately enlist Kenya Wildlife Service on the board of the PCPB

Acknowledgements
WildlifeDirect would like to thank the Secretary for Agriculture, Dr. Wilson Songa, and the members of
the Pesticide Task Force including the Chair, the PCPB, for this opportunity to present our concerns
regarding the impacts of Carbofuran to wildlife and to public health in Kenya. We hope that our
recommendations will be considered and look forward to working closely with this team in the future on
addressing this other issues of shared concern. We also thank the members of the Stop Poisoning Task
force, all of whom have volunteered their time to collaborate in this joint effort to address the problem
pesticide products that threaten our national economy through impacts to our most valuable wildlife
species. We thank all of those in Kenya and abroad who have generously shared information and data to
assist in this effort to make Kenyan farmers, consumers and the environment safer.

24
Evidence for revoking registration of carbofuran in Kenya

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28
Evidence for revoking registration of carbofuran in Kenya

List of Appendices
Appendix I : Concentrations of residues of Carbofuran and its metabolytes in
soil, water and plants in Kenya from study by Otieno et al. (2010b).
Table 3
Seasonal, regional and site concentrations (mean±sd) of carbofuran and its metabolites (in
(mg/L) in water samples from Isiolo and Laikipia districts in Kenya
site season carbofuran 3-ketocarbofuran 3-hydroxycarbofuran
Isiolo
1 1 0.038±0.005 0.086±0.011 0.183±0.031
1 2 0.016±0.002 0.423±0.072 0.194±0.024
2 1 0.016±0.003 0.013±0.001 0.114±0.031
2 2 0.010±0.005 0.088±0.021 0.186±0.014
3 1 0.026±0.010 0.052±0.014 0.172±0.033
3 2 0.050±0.010 0.077±0.020 0.282±0.046
4 1 0.015±0.002 0.025±0.003 0.218±0.026
4 2 0.060±0.020 0.040±0.010 0.068±0.022
5 1 bdl bdl bdl
5 2 bdl bdl bdl
6 1 bdl 0.013±0.001 bdl
6 2 bdl bdl bdl
Laikipia
1 1 0.992±0.199 0.274±0.039 0.252±0.113
1 2 0.018±0.030 0.764±0.171 1.022±0.192
2 1 1.034±0.0314 0.359±0.049 0.403±0.101
2 2 0.070±0.010 0.742±0.028 0.487±0.067
3 1 0.747±0.178 0.236±0.018 0.576±0.042
3 2 0.023±0.010 0.734±0.023 0.377±0.180
4 1 0.546±0.038 0.148±0.022 0.334±0.047
4 2 0.012±0.001 0.427±0.173 0.220±0.070
5 1 1.232±0.300 0.406±0.117 bdl
5 2 0.430±0.012 0.800±0.256 1.482±0.580
6 1 1.823±0.478 0.516±0.111 0.355±0.101
6 2 0.237±0.111 0.894±0.321 1.546±0.421
Mean (Isiolo) 0.011 0.068 0.118
Mean (Laikipia) 0.592 0.525 0.646
CV% 4.93 2.01 2.14
Note: for the names of the sites, refer to Table 1
bdl: below detection limit, n=3

29
Evidence for revoking registration of carbofuran in Kenya

Table 4
Mean concentrations (mgkg-1 dry weight) of carbofuran and its metabolites in
plant samples and their statistical analysis
Regions Season I Season II Regional
mean
Carbofuran
Isiolo 0.197±0.010 0.001±0.005 0.099
Laikipia 0.417±0.121 0.122±0.017 0.269
Means seasons 0.307 0.061
CV% 13.444
LSD (<0.05) 0.074
Interactions 0.104
3-ketocarbofuran
Isiolo 0.112±0.012 0.177±0.110 0.145
Laikipia 0.185±0.040 1.098±0.230 0.641
Means seasons 0.149 0.637
CV% 1.07
LSD (<0.05) 0.013
Interactions 0.018
3-hydroxycarbofuran
Isiolo 0.136±0.100 0.257±0.130 0.196
Laikipia 0.237±0.151 0.761±0.169 0.499
Means seasons 0.186 0.509
CV% 0.98
LSD (<0.05) 0.011
Interactions 0.014

30
Evidence for revoking registration of carbofuran in Kenya

Table 5
Mean concentrations (mgkg-1 dry weight) of carbofuran and its metabolites in
soil samples and their statistical analysis
compound Season 1 Season II Regional
mean
Carbofuran
Isiolo 0.276±0.045 0.015±0.005 0.146
Laikipia 0.344±0.030 0.013±0.010 0.176
Means seasons 0.310 0.014
CV% 7.46
LSD (<0.05) 0.036
Interactions 0.052
3-ketocarbofuran
Isiolo 0.239±0.120 0.729±0.280 0.484
Laikipia 0.158±0.062 0.467±0.177 0.313
Means seasons 0.199 0.598
CV% 12.13
LSD (<0.05) 0.146
Interactions 0.205
3-hydroxycarbofuran
Isiolo 0.191±0.073 0.676±0.057 0.433
Laikipia 0.207±0.074 1.181±0.190 0.694
Means seasons 0.199 0.928
C% 0.61
LSD (<0.05) 0.011
Means seasons 0.014

Table 6
Comparing concentrations (mgkg-1 dry weight) of carbofuran and metabolites found in this study
(whole plant samples) with values reported for various parts of Zea mays plant 117 days after
application.
carbofuran 3-ketocarbofuran 3-hydroxycarbofuran
*
Zea mays
Leaves 0.43 0.40 4.57
Stalks 0.24 0.00 0.04
Cobs 0.04 <0.02 <0.02
Kernels 0.00 <0.01 0.02
Plants this study
Whole plant samples (range) 0.12 ˗ 0.54 0.11 - 1.33 0.04 - 0.93

31
Evidence for revoking registration of carbofuran in Kenya

Appendix II: Incident report of pesticide poisoning of wildlife in Tsavo

From: Paula Kahumbu <paula@wildlifedirect.org>

Date: Sat, May 23, 2009 at 8:08 AM


Subject: INCIDENT REPORT POISONING OF WILDLIFE IN TSAVO USING FURADAN
To: pcpboard@todays.co.ke

Cc: Linda Froelich <LINDA.FROELICH@fmc.com>, Richard E Leakey <


leakey@swiftkenya.com>, AbdulAziz <abdulaziz@pollmans.co.ke>, martin odino <
martinchael@yahoo.com>

Ms. Gladys N. Maina


The Chief Executive Officer
Pest Control Products Board
P.O.Box 13794-00800,
Waiyaki Way,
Westlands Nairobi Kenya

23 May 2009

Dear Mrs Maina,

*INCIDENT REPORT OF WILDLIFE POISONING USING FURADAN IN TSAVO*

I hereby submit a third incident report on wildlife poisoning *in the Taita
Tsavo* area adjacent to the Tsavo West National Park. Witnesses identified
Furadan granules in the zebra carcass that was laced and left out as bait to
kill predators. A variety of animals were killed during this incident.

*Incident:* Poisoning of numerous animals including predators in the Taita


Hills/Salt Lick boundary with Murumba Ranch

*Date of report: 22nd April* 2009 – Incident occurred in March 2009

*Threat:* Lions, jackals, predators, scavengers

*Method:* Dead zebra laced with Furadan granules left out for scavengers and predators

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Evidence for revoking registration of carbofuran in Kenya

This letter is to request your offices conduct independent investigations into this incident. We would like
to emphasize that this is just one of several other recent reports of wildlife poisoning using Furadan in th
Taita/Tsavo area which we will forward as soon as we get further details.

I attach the original report from the Friends of Tsavo which contains graphic images of the incident. For
more information contact Abdul Aziz fot@africaonline.co.ke, or abdulaziz@pollmans.co.ke

Yours Sincerely

Dr.Paula Kahumbu on behalf of the Stop Wildlife Poisoning Task Force.


Executive Director - Wildlifedirect
Tel 0722 685 106, email paula@wildlifedirect.org

33
Evidence for revoking registration of carbofuran in Kenya

Appendix III: Incident report of bird poisoning in Bunyala

INCIDENT REPORT OF POISONING OF BIRDS IN BUNYALA (JUNE 2009)

Please find below a report of witnessed bird poisoning from Bunyala, Busia in June 2009. I wish to bring
to your attention that between June and July (2009) I have been Ahero Rice Scheme and Mwea Rice
Schemes where witnesses say there is ongoing poisoning of birds using Furadan. In Mwea and Ahero,
the species of birds poisoned are the White-faced Whistling Ducks and Fulvous Whistling Ducks in
addition to doves in Ahero. In all the sites the birds were intentionally poisoned for human
consumption.

Please also find attached photos taken during June 2009 survey of the poachers with the poisoned birds
in sacks and about them; also a photo of a torn off Furadan label by the poachers to conceal the identity
of the Furadan poison they are using.

We also had some dove samples whose contents (gut-crop, gizzard and intestinal- contents) tested for
carbofuran poisoning as well as the sampple of the bait that was used to poison them tested for
carbofuran and I have also attached the certificate of analysis.

BUNYALA POISONING

Incident: Poisoning of Cattle Egrets (8 birds)


Date incident occurred: 04/06/2009
Threat: 3 species of Egrets(Cattle Egrets, Yellow-billed Egrets and Little Egrets), Hadada Ibis, Sacred ibis,
Sandpipers and humans that handle the furadan and those that feed on the poisoned birds.
Method:termites and small fish laced in Furadan

Incident: Poisoning of African Open-billed storks (22 birds)


Date incident occurred: 06/06/2009
Threat: Humans that use Furadan for poisoning and those that consume the birds.
Method: Snails (Species Pila ovata) laced in Furadan

Incident: Poisoning of Cattle Egrets (4 birds)


Date incident occurred: 06/06/2009
Threat: Other Egrets (Yellow-billed Egrets and Little Egrets), Sacred Ibises and Hadada Ibises. Humans
that use Furadan for poisoning and those that consume the birds.
Method: termites and small fish laced in Furadan.

34
Evidence for revoking registration of carbofuran in Kenya

Appendix IV Proposed Wildlife Poisoning data collection form


Wildlife Poisoning Data Collection Form

A. General Information
1. Name of recorder: 2. Date:
3. Organization:
4. Names of other persons gathering information:

B. Incident Contact Information


5. Name of person reporting incident:
6. Address: 7. Phone:

C. Location and Date of Incident


8: District 9. Nearest town or park (ex: Isiolo, Amboseli NP):
10. Location description (ex: 15 km outside Isiolo along Marsabit road, 100 m from Meshanani Gate)

11. What type of land use describes the immediate area where the incident was?
town near human habitation park or other natural area agricultural grazing
12. Date of incident (if known) or approximate exposure time:

D. Description of Incident
13. Describe the incident, include why you suspect it was caused by poisoning:

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Evidence for revoking registration of carbofuran in Kenya

E. Animals Collected
Number Sex Age Status
Species (be as specific as possible,
(m/f/u) (c/sa/ad/u)
include species names for birds if known)

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

alive died at scene

euthanized

Sex: m = male, f = female, u = unknown

Age: c = calf/cub, sa = sub-adult, ad = adult, u = unknown

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Evidence for revoking registration of carbofuran in Kenya
F. For animals collected alive and rehabilitated
Species Number Evidence of recovery Did symptoms Present location
within 8-24 hrs improve
yes no yes no died euthanized in captivity

where?

yes no yes no died euthanized in captivity

where?

yes no yes no died euthanized in captivity

where?

yes no yes no died euthanized in captivity

where?

yes no yes no died euthanized in captivity

where?

G. Animals Observed and Not Collected


Number Sex Age Status
Species
(m/f/u) (c/sa/ad/u)
alive dead
alive dead

alive dead

alive dead

H. Field Signs* Species Collected


Observed
14. Muscular incoordination/weakness Abnormal walking Inability to walk Wing spasms/shivers
Wing droop Weak flying Inability to fly Blindness Dialation of pupils Contraction of pupils
Tremors/convulsions Salivation/drooling Vomiting Diarrhea Emaciation Head trauma
Difficulty breathing Gaping Rapid breathing Exhaustion Bleeding from orifices Attacked by
predator
Discharge (Describe location and appearance)___________________________________________________
_________________________________________________________________________________________
15. Other observations ______________________________________________________________________
_________________________________________________________________________________________

37
Evidence for revoking registration of carbofuran in Kenya
*Please use this section for one species exhibiting the same signs. If necessary, use additional copies of this section
for multiple species.
I. Other Field Evidence
16. Type of bait animal used: cow/calf camel goat/sheep other, specify
17. Physical evidence of poisoning (ex: empty containers or packaging nearby): yes no
If yes, collect or take photos
18. Substance in or around bait animal: liquid granule powder
19. Presence of granules in or on animal: stomach mouth feet
20. Presence of granules around animal in: soil water
21. Colour of product: blue purple grey white other, specify
22. Are granules a consistent size? yes no
23. Have granules been submitted for chemical analysis? yes no
24. Were photographs taken of the site? yes no
J. Human-wildlife Conflict

25. Is poisoning suspected as a result of livestock predation? yes no


26. How many and types of livestock were lost? ____cow ____ calf ____ camel ____ goat ____ sheep
27. Over how many days has livestock been lost? 1 day 2-5 days 6-14 days 14-30 days >1 month
28. Estimated cost of livestock loss in Ksh: 0-20,000 20,000-50,000 50,000-100,000 >100,000
29. How many livestock owners were affected? 1 2-5 5-10 10-20 20-50 >50
30. Were livestock losses previously reported to KWS or other authorities? yes no

K. Collection of Tissue Samples


31. Were tissues taken for chemical analysis? yes no
32. Which other samples were taken for analysis? feet teeth other, specify
33. Method of preservation: frozen, preferred other, specify
34. Name of laboratory(s) performing analysis:

38

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