CropLife South Africa is the industry body that represents responsible manufacturers, suppliers and distributors of sustainable crop protection and public health solutions in the agricultural, public health, non-crop and consumer sectors of South Africa.
The recent media coverage based on a report released by Oxfam Germany and Women on Farms Project (WFP) has prompted CropLife SA to respond with sound information so as to place these findings into the correct context.
Wine, like all other foods and beverages, is produced in a highly competitive environment, not just for market share, but also against plant pests, plant diseases and weeds that not only threaten agricultural crops, but may also inoculate agricultural crops with very dangerous pathogens that may prove highly toxic to consumers. Responsible crop protection, therefore, plays a pivotal role in ensuring a crop reaches its potential with little or no risk to its consumers.
There are three areas that need to be elaborated on if one is to understand the crop protection landscape in South Africa, specifically in reference to the WFP/Oxfam Germany report. The first is the South African regulatory environment, the second is the matter relating to pesticides that are banned in the EU but not in South Africa, and the third is the subject of Maximum Residue Limits (MRLs) and what it means for South African producers who export their products.
The South African Regulatory Environment
The Fertilisers, Farm Feeds, Agrochemicals and Stock Remedies Act (Act Nr. 36 of 1947) requires that all agrochemicals be registered and packaged in approved containers that display an approved label. The product’s composition and physical properties must also satisfy the requirements that were submitted upon application for registration and the product’s efficacy must match that of the registration application.
When a company develops an agrochemical, there’s a broad spectrum of required research that is needed for the composition of the product registration, including a full toxicological report that will identify any risks as well as specify the maximum allowable human consumption.
Once the product is registered, the Act continues to regulate all other aspects pertaining to agrochemicals, including the sale of the product, transportation, storage, application and disposal of empty containers and obsolete stocks. When it comes to application, a producer must ensure that all workers handling, mixing and applying pesticides wear appropriate protective clothing as instructed by label warnings, precautions and pictograms.
There are two points worth noting at this stage. Firstly, as long as a product complies with all the necessary standards and has obtained a registration (L) number, it is a legal product in South Africa. Whether or not the product is banned in the EU is irrelevant as there are many factors differentiating the various regions. If produce is exported, the Maximum Residue Limit (MRL) for pesticides used during the field production cycle of the produce, must be below the export destination’s set limits, which is discussed in more detail further in this document.
Secondly, the Occupational Health and Safety Act, 1993 (Act No. 85 of 1993) requires that all workers handling, mixing and applying pesticides wear appropriate protective clothing. Any person who does not comply with this, transgresses this Act. In other words, the producer must ensure access to the protective clothing and the farm worker must wear it. The responsibility lies with both parties. A fact that is not promoted often enough though, is that the manufacturers of the agrochemical products often supply complimentary PPE kits to the farm workers. In one year alone, a single CropLife SA member already distributed 4 000 of these kits, and CropLife SA has over 40 supplier members. In addition, both supplier and distributor members of CropLife SA repeatedly provide technical and safety training on the farm, free of charge.
South African fruit growers are acutely aware of these regulations and must comply with them if they are to meet production standards set by, for instance, GLOBAL GAP. In addition, they provide training on responsible pesticide use by skilled people and are audited annually to authenticate adherence to this.
Use of pesticides banned in the EU
One cannot compare the production areas in South Africa with those of the EU. Certain products have no other suitable alternatives. Certain pesticides such as paraquat dichloride may be highly toxic but with appropriate safety measures pose very little risk to human health. Paraquat is a desiccant that is used to prepare firebreaks. It only dries out the vegetative plant parts above the soil which is then burned down to make firebreaks. Due to the entire plant not dying off, gully erosion during rain is avoided.
When considering glyphosate, a basic glycine amino acid molecule, most people will be surprised to find out that table salt is ranked as more carcinogenic than glyphosate. The International Agency for Cancer Research (IARC) declared glyphosate as a probable carcinogen under category 2A due to a study that found that mice had developed cancer when exposed to very high levels of glyphosate, however, it is important for the public to take note of the research protocol that was followed in that study.
The researchers chose mice that were genetically prone to cancer and were dosed with more than 1 403 milligrams per kilogram body mass glyphosate. In other words, they were subjected to glyphosate levels that were completely irrational. While on the subject of irrational doses, even if you consumed 140 glasses of wine per day, every day, for 70 years, you would still be under the level of glyphosate considered “no significant risk”.[i]
Two other teams of researchers used ordinary mice and couldn’t bring about cancer, not even with doses higher than the first study. The results are consistent with other research around the world, one of which involved more than 5 000 farm workers, where cancer could not be linked to glyphosate.
In this context, one should note that the European Food Safety Authority (EFSA) stated in 2015 that they have done a comprehensive review on all research concerning glyphosate and cancer and found that it is unlikely that glyphosate poses a cancer risk to people. Amongst various others, the German Federal Institute for Risk Assessment (BfR) for the European Commission on the Annex 1 renewal of glyphosate evaluated the complete genotoxicity, carcinogenicity, and human epidemiology databases and also concluded that glyphosate is unlikely to pose a carcinogenic risk to humans[ii].
The decision to cancel certain pesticide registrations in the EU may be due to a number of factors such as inefficacy in certain climatic conditions or resistance build-up and does not necessarily have anything to do with toxicity or risk to users. South Africa assesses these products separately, based on local production environments. Merely banning these products because they are banned in the EU, without reasonable cause in the local environment or any suitable alternatives, will inevitably have disastrous results for South African agriculture, including job losses.
If the exported product complies with the set MRLs of the export destination, there is no transgression of any regulations.
Maximum Residue Limits
Pest control is a given in modern agriculture with crop protection products being integrated into agronomic practices, cultivar selection, mechanical pest management and biological pest management. It is thus expected that food commodities may have traces of pesticide residues, albeit it at very low concentrations. Analysis conducted by third parties (other than growers or regulators) may very well detect pesticide residues, but to call alarm over such pesticide residues is not pragmatic nor scientific. For each pesticide active ingredient, including natural pesticides and pesticides labelled for use in organic agriculture, there is an allowed daily intake (ADI) for consumers that is determined by international regulatory agencies. The ADI is a tangible quantity of an active ingredient measured against human body mass which may be consumed by a person each day of such a person’s life, without any reasonable expectation of clinical harm caused to the person. It is prudent for any third-party making statements about pesticide residues to do the calculations of residues in a commodity like wine, as they will most likely find that the residues are within the limits if a person consumes a normal quantity of the commodity per day.
South African law (Act 36 of 1947) dictates that an agricultural remedy may only be applied during the label instructed window of application to ensure that the MRL, which complies with WHO standards, is not exceeded if the commodity is harvested after the pre-harvest interval (PHI). Should there be a zero level MRL for a particular active ingredient in export destinations, such an active ingredient may not be applied at all during the field production phase of the commodity.
As an industry we have the responsibility to ensure sustainable, safe and affordable food production, and therefore food security, in South Africa, and the regulatory environment supports this. It is also of paramount importance that we collectively ensure responsible communication of complex matters affecting various role players and place them in the appropriate context.
[i] Carl Winter, Ph.D., Professor of Food Toxicology, University of California at Davis. Based on the level set by the State of California, using the glyphosate amount measure 51.4 parts per billion
[ii] Markard C. 2014. Ergebnisse der Vorstudie HBM von Glyphosat. Dessau-Roßlau (Germany): Federal Environmental Agency (UBA), Umweltprobenbank des Bundes [Unpublished Report provided to] Berlin (Germany): German Federal Institute for Risk Assessment (BfR). [Google Scholar])