MINUTES OF THE OPEN HOUSE SESSION WITH PESTICIDES INDUSTRY ASSOCIATIONS ON “COMPUTERIZATION OF REGISTRATION OF PESTICIDES” HELD ON 8th APRIL , 2010 IN THE AUTIDORIUM OF CIL, FARIDABAD
An open house session on “Computerization of Registration of Pesticides” was held with representatives of Pesticides Industry Associations on 8th APRIL , 2010 at 10.30 P.M. in the auditorium of CIL, Faridabad . The session was chaired by PPA to the Government of India and co-chaired by Director (PP) & Secretary (CIB & RC).
II. List of participants who attended the meeting is at Annexure.
III. Outcome of the discussions/decisions taken in the Session are summarised as follows:
1. Confidentiality & Security of online data: Representatives of M/s Crop Life India raised their concern about online data security and confidentiality of their documents & dossiers submitted online for registration of pesticides. An apprehension was also expressed about the possibility of data getting copied or getting transferred on pen drive which could then be used against the interests of the applicant by making it available to others including their competitors. It was decided that NIC should provide in the software a full proof security against data copying/transfer by incorporating a suitable disabling mechanism so to maintain security and confidentiality of the data.
(Action: NIC)
2. Application on combination products: Issue regarding submission of online application for combination products also came up and some industry representative informed that there is no provision online in Form-I for applying for registration of combination products. Sr. Technical Director (NIC) stated that this facility has now been incorporated in Form-I and an applicant can now apply online for combination products too.
3. Data Bank updation for newly registered pesticides: One of the representative of the industry stated that the newly registered products are not updated on the existing website of CIB&RC. It was informed to the participants that the work of updating the newly registered products is in progress with the assistance of NIC and the same would be completed on priority.
(Action: CIB & RC , NIC)
4. Submission of online applications for registration of products not included in the Schedule to the Act: Representatives of Pesticides Association informed that there is no provision in the online system for submission of application for registration of products, which are not included in the schedule to the Insecticides Act, 1968 whereas such an option is available in the manual mode of submission. It was informed to the participants that in the existing system of manual submission though there is an option for submission of an application for a product not included in the Schedule it is generally not treated in queue unless the product is notified in the Schedule to the Act. It was decided that NIC may work out suitable modifications/improvisation in the software to provide for this aspect too.
(Action: NIC)
5. Applications on all categories of formulation: One of the representatives of a Association raised the issue that one cannot log on to certain categories of formulation which are not given in Form-I. Sr. Tech. Director (NIC) assured that a provision for a separate sub-head ‘Others’ will be made so as to enable applying for the missing categories of formulation.
(Action : NIC)
6. Authentication/signature of every page of the dossier and page numbering: At present, in the manual mode, while submitting a hard copy of an application all pages of the application are required to be signed/authenticated by the authorized representative of the company. Concern has been expressed by many of the representatives of the association that since the dossiers which are generally very voluminous in nature would be sent online in pdf/docs by their principals directly to the CIB&RC , hence to ensure compliance of authentication of every page and its numbering they would be required to take printouts of each page followed by scanning and then again uploading for the final submission and the entire process would then become very cumbersome and inconvenient. The matter was deliberated at length and a consensus emerged whereby it was decided that initially the applicant/authorized person need not sign/authenticate each paper of the application but instead submit an index of the contents reflecting list of documents with titles and number of pages in each dossier of respective disciplines ie. Chem/Tox/Bio/Packg/Legal. In the meantime NIC may introduce a suitable improvisation in the software to resolve this issue of signature/authentication of all pages by the applicant.
(Action: NIC & All Associations)
7. Increasing the size of electronic file in the current software system from 5 MB to 10 MB: Most of the representative of the pesticides association have raised this issue of increasing the electronic file size to 10 MB. Actually in the current software there is a provision of a maximum file size of only 5MB due to which each dossier consisting of voluminous data is required to be split into several files of 5 MB size which is a very tedious & cumbersome process and not in consonance with the concept of seamless submission of data. To overcome this the system needs to be improvised for allowing each file size of atleast 10 MB. It was decided that NIC may resolve this issue at the earliest.
One of the representatives of the industry while recalling his experience, has informed the House that TIFF format (Tagged Image File Format) should be used in place of PDF. Use of TIFF format accelerate the work of copying, cutting and pasting easily.
(Action: (NIC/Pesticide Industry)
8. Access to refer, view and recall of the applications on online: Many representatives of the Associations shared their view on this particular aspect and informed that recalling the data/applications after rejection in preliminary scrutiny is not possible. Sr. Technical Director, NIC informed that there is a sufficient provision under ‘view’ to access the application. Attachments and office copy can also be viewed. It has been decided that the matter relating to recalling /withdrawing of data/application by the applicant after rejection in preliminary scrutiny should be examined by the NIC, so that the applicant can easily retrieve his application /data.
But the addition/deletion in the application after making online submission is not practical and cannot be provided for.
(Action: (NIC/Pesticide Association )
9. Endorsement Cases: One of the representative of the pesticide industry stated that provision for different kinds of endorsement cases in respect of combination products etc. are not available in the system of online submission. Participants were informed that the provision of ten different kinds of endorsements is already available in the online submission of application. However, Sr. Tech Director assured that other endorsements cases may also be applied through sub-head ‘others’.
(Action: NIC)
10. Training: One of the members of Pesticide Industry opined that there should be a provision for exposure training to the members of the industry on the online registration of pesticides. On this aspect, the participants were duly informed that ‘User Guidelines’ have already been made available on the website for consultation and members of industry may use it for imparting training.
As regards organising a workshop for further interactive session, as requested by the representatives of the Pesticide Associations, PPA to GOI assured that such sessions/workshop would be organized as and when the need arises in future.
(Action: Industry Associations & CIB&RC)
11. Following issues were also raised by the participants:-
a. Endorsements – certain categories missing in the software like alternate packaging, change in factory address, enhancement of shelf-life of pesticides under section 9(4), etc.
b. Label Expansion Application Submission – certain label expansion applications are not accepted due to in-built tool in the software i.e. non-acceptance of file of certain product name, a.i. content, formulation code, etc. not updated.
c. For saved files (not submitted) – no provision for “delete” in present online system;
d. Re-submission of applications rejected during preliminary scrutiny;
e. Submission of additional data subsequent to submission of application;
f. Access of already submitted dossiers by the applicant;
g. Updating “Search” option – information of all the registered molecules cannot be accessed since list with relevant details not updated due to which applicants face difficulties in uploading Form I under section 9(4).
h. Withdrawal/Rejection of Registration Application / Dossier after submission;
i. Information about the MRL status to the applicant.
The aforesaid issues were also deliberated and it was decided that Sr. Technical Director, NIC may examine the issues and accordingly improvise the software for incorporating the relevant requests.
( Action: NIC / CIB&RC)
12. Miscellaneous
Various practical difficulties and queries raised by the participants , regarding issues related to more than one user name , change of company name , use of more than one SSI numbers by the applicant , log in problems due to password getting missed or forgotten, were duly explained by the Sr. Technical Director, NIC to the satisfaction of the individual participants.
It was also informed to the participant that since a suitable system of making available instant online acknowledgement after submission of application is available in the present system, the existing system of displaying the applications numbers on the website of CIB&RC will be dispensed with in case of online applications.
(Action: NIC/CIB&RC)
13. Conclusion
PPA & Secretary, CIB&RC informed the open house that the software for on-line filing of registration of pesticides would be stabilized by end of May 2010 after which CIB&RC would stop receiving applications in manual mode and only on-line applications under different categories of registration would be accepted. The representatives of the Industry were requested to accordingly make necessary preparations of submitting only on-line applications as the manual system would be dispensed with very shortly. The Industrial representatives were assured that the suggestions emanating from today’s open house session would be appropriately addressed resolved, to the satisfaction of all, by NIC and CIB&RC Secretariat. Since the process of improvisation of software is a continuous one, the participants were requested to keep sending their valuable suggestions /ideas based on their experience of on-line filing so that NIC and CIB&RC could take further necessary action in making the software more user- friendly, inclusive and efficient. If need be,another interactive session with Industry representatives would be held in due course of time once the various suggestions are incorporated in the software and the software gets stabilized and before the system of manual submission of applications is totally dispensed with.
LIST OF PARTICIPANTS OF OPEN HOUSE SESSION WITH PESTICIDES INDUSTRIES ASSOCIATIONS ON COMPUTERIZATION OF REGISTRATION OF PESTICIDES ON 8.04.2010
1. / Dr. P. S. Chandurkar / Plant Protection Adviser to the Government of India, Directorate of PPQ&S,
2. / Shri S.K.G. Rahate, I.A.S. / Director (PP) & Secretary, Central Insecticides Board & Registration Committee
3. / Dr. A.K. Choubey / Senior Technical Director, National Informatics Centre
4. / Dr. Sushil K. Khurana / Specialist Grade-I, Central Insecticides Board & Registration Committee
5. / Dr. Hari Prasad / Joint Director (Chem.),Central Insecticides Board & Registration Committee
6. / Dr. A.K. Sinha / Joint Director (PP),Central Insecticides Board & Registration Committee
7. / Dr. B.S. Phogat / Joint Director (Bio.),Central Insecticides Board & Registration Committee
8. / Dr. R.M. Shukla / Deputy Director (Ento.),Central Insecticides Board & Registration Committee
9. / Shri Rajvir Singh / Deputy Director (Chem.), Central Insecticides Board & Registration Committee
10. / Dr. Subhash Kumar / Assistant Director (WS),Central Insecticides Board & Registration Committee
11. / Dr. Vandana Seth / Assistant Director (Chem.), Central Insecticides Board & Registration Committee
12. / Ms. Kamlesh Miglani / Assistant Director (Chem.), Central Insecticides Board & Registration Committee
13. / Shri S.K. Sharma / S.O.(CIR.I), Central Insecticides Board & Registration Committee
14. / Shri S.K. Verma / S.O.(CIR.II), Central Insecticides Board & Registration Committee
15. / Sh. D.S. Sehrawat / PPO(Packaging),Central Insecticides Board & Registration Committee
16. / Sh. Niraj Kulshrestha / Assistant (Legal), Central Insecticides Board & Registration Committee
17. / Sh. Raj Singh / SSA.III, Central Insecticides Board & Registration Committee
18. / Engg.S.K.Ghosh, / Consultant,(Packaging), Central Insecticides Board & Registration Committee
19. / Ms Tulika Debnath / Senior Software Analyst , National Informatics Centre
20. / Shri Manoj Lingeri / BASF India Ltd.
21. / Shri Venu Gopal / Isagro (Asia) Agrochemicals, Mumbai
22. / Shri Bhupender Sharma / Syngenta India Ltd.
23. / Shri Vijay R. Menon / Adviser, Product Development & Regulating Affairs, FMC India, Banglore
24. / Shri Kishor Nahar / G.M., Regs. Regulatory Affairs, Bayer Crop Science
25. / Shri Uttam Gupte / Director, Crop Life India
26. / Ms Abhilasha P. Tripathi / E.I. DuPont India Pvt. Ltd., Gurgaon
27. / Shri Rajesh Dhawan / Bayer Crop Science , Gurgaon
28. / Shri Shekhar Varshney / Bayer Crop Science , Gurgaon
29. / Shri Kailash Bhargava / Director , PMFAI
30. / Shri D. Srinath / PCI/IPCI
31. / Shri Raj Kumar Singh / Reg. Exec. Director, PMFAI
32. / Shri Brij Oberoi / Exe. Director , Crop Care Federation of India (CCFI)
33. / Dr. R.K. Singh / Manager (Regulatory Affairs & P.D.), Meghmani Organics Ltd., Ahmedabad
34. / Shri Manish Jain / Reg. Specialist, Chemtgura Chem.
35. / Shri Kusta Vaingankar / PI Industries Ltd., Gurgaon
36. / Shri Chirag Patel / United Phosphorus Ltd.
37. / Dr. S.S. Bhagnagar / Ecoscience Lab., Mumbai (PMFAI)
38. / Shri Vijay Jha / Rallis India Ltd., Delhi
39. / Shri M. Krishnan / Rallis India Ltd., Bangalore
40. / Shri Ilesh Mistry / Regicon, Mumbai
41. / Shri Vipin Singh Bisht / Registration, CPL
42. / Shri S.K. Misra / Manager, Liaison Crystal Phos. Ltd.
43. / Dr. Rajeev Geol / Manager, Registration, Crystal Phosphate Ltd.
44. / Shri M.S. Paprikar / Microbiologist, Nirmal Seeds Pvt. Ltd., Maharashtra Bio-Control
45. / Shri Gajanan Tote / Secretary (ACARDA), Agricos Association,
46. / Shri G.S. Walia / BASF India Ltd., Manager SPD & Reg. Affairs
47. / Shri Vijay Hegde / Administrator, PD& Regulatory Affairs, FMC India Pvt. Ltd.