Dear NDA, where is your science on Tick-Off?

The National Drug Authority (NDA) recently accused Pastor Robert Kayanja and claimed to have found three dangerous and potentially carcinogenic chemicals in his organic Tick-Off product.

Due to the serious allegations being made, I waited for the report released by the Directorate of Government Analytical Laboratory (Lab Reference Number: PRL 009/2023) to conclude whether the claims could be scientifically justified.

Based on my experience and research on each of the chemicals listed by the NDA, Diazinon, Fipronil and Benalaxyl, such claims cannot be scientifically supported. To understand the calculations and scientific research provided, it is important to note that Tick-Off is packaged as 50 grams which is to be diluted by the farmer in 20 litres of water for use on the cow.

If a farmer was to use one kilogram of the product, it would contain 20 50gram packets which should be diluted in 400 litres of water.

DIAZINON

This is the first of the three banned chemicals that the NDA raised red flag about. According to their statement, ‘Diazinon is a highly-concentrated fumigant used to kill bedbugs, bats and termites.’

Diazinon is a pesticide commonly used to control various soil, crops, and livestock pests. It is applied as a spray on plants and livestock, where it interferes with the pest’s nervous system and, as a result, dies.

In terms of any chemical, the concentration of such compounds needs to be considered to understand its effect fully. The commercially-available forms are concentrated at 60%, 50% and 25%, and the intended outdoor concentration is recommended to be a 0.05% solution.

NDA states they found 0.59 milligrams (mg) per kilogram (kg) of Diazinon in Tick-Off, equivalent to 0.00000295% even before further dilution of 20 liters of water. Once it is diluted, the final concentration is 0.0000001475% which is sprayed on the animal.

FIPRONIL

The second accusation by the NDA stated that ‘Fipronil; [is] a spray banned for food producing animals because of long withdrawal period due to the potential risks it could have on human health.”

According to the NDA register, as of February 2022, Fipronil is an authorized active ingredient in PESTIGON (FIPRONIL 100MG), an approved drug for pesticide control Reg No; NDA/MAL/ VDP/1594.

Fipronil was found by NDA at a concentration of 0.56mg/kg in Tick-Off. Once diluted in 20 liters of water this gives 0.0000000014% as the final concentration amount applied to the cow. This is different from the active concentrations for most.

BENALAXYL

They stated, “Benalaxyl; a systemic fungicide which is carcinogenic (cancer- causing potentials).”

Benalaxyl is a fungicide and is primarily used for the control of plant diseases caused by oomycete fungi, such as downy mildew and late blight. While Benalaxyl may have some activity against certain pests, including insects and nematodes, it is not typically used as a pesticide for these purposes.

The public relations manager (PRM) for NDA, Abiaz Rwamwiri stated that ‘science is science.’ He emphasized how the product, Tick-Off, had carcinogenic properties that cause cancer called Benalaxyl.

However, we would like to compare its level of carcinogenicity to that of already approved tick products on the market. According to the NDA register, as of ebruary, 2022, Amitraz is an authorized active ingredient in MILBITRAZ (12.5% concentration), an approved acaricide Reg No; NDA/MAL/VDP/5696.

This drug has been registered since 1998 by the NDA. According to the NDA register, as of April 2022, Chlorfenvinphos is an authorized active ingredient in DUODIP (50.5% concentration), an approved acaricide Reg No; NDA/MAL/VDP/2881 (Made in UK).

This drug has been approved since 2013 by the NDA. In conclusion, the scientific report released by the Directorate of Government Analytical Laboratory does not support the claims and statements made since the concentrations found to be present in Tick-Off are far too low to have the type of effect they were alleged to have.

The only plausible explanation for the presence of these compounds in the product are the existing chemical contaminants that could be present in our environment.

Ironically, some of these chemicals presented by the NDA are available in much higher concentrations in their approved products today. What are the maximum residual levels presented by NDA for each chemical?

So, the questions remain. Were the claims by NDA scientifically based or were they based on a stereotype? Can a concentration of less than 1mg of each compound found in Tick-Off, kill ticks, harm animals, or cause cancer? Are these contaminants already in our environment?

And to what extent have we been exposed?

The author is the veterinary officer, Lakang sub-county, Amuru district.