Phasing out agricultural remedies

International and local pressure “The EU still strives to be the first continent to be carbon neutral, so they came up with this idea of the Green Deal,” said Bell. “The facet of the Green Deal that impacts us is the Farm to Fork strategy, which has targets to reduce pesticides and fertilisers and grow organic production.” The most significant European initiative under the Green Deal is revoking import tolerances for crop-protection solutions used in SA but not registered in Europe. “A number of our crops are not grown in Europe, and we have pests that they don’t,” said Bell, “so saying we shouldn’t use any products here that aren’t registered there is a bit silly.” South African activists are becoming more vocal and lobbying our government to regulate agricultural remedies more strictly. Several of our ministries are mandated to legislate crop-protection solutions and will ban products that pose unacceptable risks. Bell discussed the example of chlorpyrifos in this context. Its use to control pests in a public health setting was phased out many years ago due to unintended environmental effects. More recent assessments found unacceptable risks to workers, consumers, and the environment when chlorpyrifos is used in agriculture, even when complying with the label directions. Internationally, chlorpyrifos has already disappeared in many countries. The South African Department of Health communicated that they planned to revoke the maximum residue limits for chlorpyrifos in 2020, and DALRRD (now split into the Department of Agriculture and the Department of Land Reform and Rural Development) consequently announced the revocation of registration of chlorpyrifos-containing products. “This is the result of new information from studies showing that there are very few safe uses of chlorpyrifos in agriculture,” said Bell.

The Globally Harmonized System
The Globally Harmonized System (GHS) is a standardised international system for classifying and labelling industrial and consumer chemicals – it doesn’t only apply to agricultural remedies. The GHS differs from previous systems in that it considers a product’s entire formulation instead of only focusing on the active ingredient. It also takes into account all exposure routes, including eye and skin contact, ingestion, and inhalation. “The system wasn’t designed to phase out plant-protection products,” emphasised Bell. “That’s a misconception we need to clear up.” However, the GHS made the carcinogenic, mutagenic, and reproductive toxicity of certain products explicit. These so-called CMRs are categorised as 1A if there is human evidence and 1B if there are mainly animal studies showing their potentially harmful effects. “After GHS was introduced and all regi-stration holders reclassified their products according to this system, our government said we don’t want CMR Category 1A or 1B in South Africa anymore,” said Bell. The August 2023 regulations supporting Act 36 of 1947 indicated that DALRRD would phase out any agricultural remedy falling in CMR Category 1A or 1B. Revoking the registration of specific crop-protection solutions will remove some of the tools growers have for controlling pests and diseases. Stricter requirements from our overseas markets could empty growers’ toolboxes even further. Fewer active ingredients translate into fewer options for controlling quarantine pests and managing resistance. “The alternation of different classes of chemistry is essential for preventing resistance,” said Bell. “Resistance management will be difficult if we don’t have a sufficient range of products with different modes of action.”

Negotiating the new reality
Bell shared some positive developments regarding international and local regulations. “If you follow the press, you would have seen that European farmers didn’t much like the EU Green Deal and drove their tractors through the streets of Paris, Brussels, and some other European cities.” Green parties lost support overall in recent European elections, and the European Parliament has not accepted the Farm to Fork strategy. This doesn’t mean the Green Deal is going away, cautioned Bell, but it delays the implementation of the Farm to Fork strategy and gives South Africa more time to find alternative crop-protection solutions. The agricultural sector is also working with the Department of Trade, Industry and Competition to push back against specific aspects of the Green Deal, especially the diplomatic export of European Green aspirations and mirror clauses. According to these, farmers that trade with Europe must abide by the same rules and restrictions as European farmers. In SA, DALRRD had agreed to grant derogations – temporary exemptions from or relaxations of the law – for clearly defined crop-pest uses of specific products. “This is a great outcome, allowing us to keep some products on the market until alternative solutions are registered,” said Bell. “So, kudos to DALRRD.” Furthermore, DALRRD has established a fast-track system for registering low-risk and biological agricultural remedies. Although increasing pragmatism abroad and government support locally give our agricultural industry breathing room to adapt and find new crop-protection products and strategies, Bell advised growers to stay informed of the latest developments. For example, new legislation on container management prescribes how empty crop-protection product containers must be handled. Growers can visit the CropLife website for details on this and other relevant topics, such as the GHS. CropLife also hosts the Agri-Intel crop-protection product database, which includes product labels, safety data sheets, maximum residue limits, and withholding periods. “Yes, we are facing a loss of agricultural tools, but it’s not all doom and gloom,” concluded Bell. “At the same time as our local regulations are taking away some of our older solutions, they are also providing the legal basis for new technologies to come to the market sooner.”

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Table Talk Grape Conversations 2024 This and the following two articles summarise presentations from the Table Talk event jointly hosted by SATI and SASEV in Paarl on 26 July 2024 (as well as in Groblersdal and Kakamas). Table Talk stakeholder information days aim to provide a platform for exploring topics that impact the table-grape industry.