For PXS, as the executing arm of PROCOMER's One-Stop Investment Window project, it has been a pleasure to support the State Phytosanitary Service, the Ministry of Health and the Ministry of Environment and Energy in the redesign of the agrochemical registration processes.
When the redesign project started in 2018, we found a highly complex process, where registrants physically delivered an application consisting of approximately 7,000 pages. In other words, registrants arrived with suitcases to the phytosanitary service in order to submit an application. This application was received and, according to our estimates, it spent 13.68 years in
review and approval queue. This means that before starting an agrochemical registration, you first had to undergo medical examinations to be sure that you were going to be able to withstand the process. At that time, there were 159 dossiers queued for processing at different stages, these had been received between the years 2008 and 2018.
It should be noted that farmers are the ones who suffer the most from this situation, since they do not have access to latest-generation molecules that are more effective against pests and less polluting for the environment and human health. This leads them to extensively use older molecules that are not as effective and can also pollute the environment to a greater extent.
What to do to solve a problem with so many years of existence and with so much complexity as this one? Definitely by segmenting it into small scopes that would resolve each issue. We started working with the hierarchs, the Minister of Agriculture, the Minister of Health and the Minister of Environment, where we defined the general vision of the transformation. In this particular case, the challenge was to break with the tyranny of the "or" (either we take care of the environment or we deliver registrations, or we take care of health or we deliver registrations) to transform it into the genius of the "and"; we had to ensure the care of the environment and human health and good agricultural practices and at the same time have an efficient and effective process as established in our constitution. A process that would give legal certainty to all those involved about the necessary requirements and that would quickly resolve the approval or rejection of the registration.
From an operational point of view, we worked with the team to question the value of all the requirements requested and the process steps necessary to deliver a record. This led us to eliminate 31% of the activities performed in the process.
We then sat down with the teams to organize the process steps so that there would be clarity of roles and functions in the admissibility analysis of an application, the chemical analysis of the Active Ingredient, the toxicological and eco-toxicological analysis, the agronomic analysis and the process of granting or rejecting the registration.
The team was able to identify different avenues of analysis for those registration applications that had already been previously registered with regulatory agencies that are highly recognized for their care for the environment and human health, such as those of OECD countries.
In this way, specific paths were defined for Registrations of Active Ingredient Technical Grade by OECD Recognition, Registrations of Complete Data, Registrations by Equivalence and finally Registrations of Formulations.
On April 6, 2022, the decree was signed that gives legal support to this new process design, which, unlike the 13 years that were necessary to receive a resolution on a registration, establishes terms of 43 working days for OECD recognition registrations, 134 days for full data registrations, 68 days for threshold I equivalence registrations and 63 days for threshold II equivalence registrations, and 135 days for formulated registrations.
Some may wonder whether these deadlines will be realistic or whether they will be a dead letter? The evidence shows that having designed the processes prior to the design of the regulation allows us to demonstrate the technical feasibility of the proposal. This is demonstrated with the registrations of Active Ingredient by OECD Recognition which since January 2021 when the decree was signed to date, has received 3 applications for registration and they have been resolved in less than 45 days, definitely a milestone if we look at the history of the last 20 years.
Best of all, it doesn't end here, this transformation is just beginning. One of the terms we use in the process of cultural transformation is the Japanese word Kaizen (Kai = change = Zen = good), some define it as continuous improvement, Masaki Imai defines it as improving every day, everywhere and everyone.
So as Kaizen is done every day, upon completion with the signing of this decree, the next iteration of Kaizen begins, where we enter the digital transformation phase. A redesigned process and with updated regulations enters the automation phase, where we hope to continue reducing the time it takes to resolve records, improve the user experience and give our farmers better tools for their work.
As Shigeo Shingo said, improvement and excellence are not so much about how much money I count but about using our ingenuity, it is about asking ourselves every day how do we do our job better every day without falling into the forbidden solutions: do not ask for more budget (there is none), do not ask for more employees (there is none), do not ask for more assets (there is none), do not ask for overtime (there is none), do not ask for new systems (there is none)? The only way out is to work with what we have making things faster and better. This is definitely what Arlette's team at SFE, Shirley's team at DIGECA and Illiana's team at MS have done.
Congratulations to all those who have contributed to this great achievement and let's continue working on the transformation of Costa Rica's paperwork. We are close to this issue ceasing to be a blocking factor for competitiveness and investment. We can really make VUI's motto come true: Let's go for 1.
If we believe it, we can be at the forefront of the process as when we were the third city with public lighting after Paris and New York or when we wanted to have a theater as beautiful as those in Paris and we built our National Theater.