Introduction
On the 29th of March 2021 the Department of Employment and Labour, (DoEL) introduced the GHS for classification and labelling of chemicals into South African Legislation.
Note: GHS was developed by a UN international team, to be used globally, to communicate the hazard class or risk of chemicals. (Interestingly, our neighbor, Namibia, is currently rejecting the GHS, supposedly for reasons of costs associated with making the change and a lack of training to implement said changes).
On the 14th of April 2022 the Registrar published his intention to phase out the CMR chemicals on 1 June 2024.
On the 24th of August 2023 DALRRD, (the Department of Agriculture, Land Reform and Rural Development) published the regulation whereby 1A,1B and CMR classified products may not be re-registered after 1 June 2024.
As a result of these, CropLife initiated the set-up of a CMR working group to:
- Assess the impact of the potential loss of these chemicals on farmers’ production capabilities.
- Ensure farmers have sufficient (chemical) tools to effectively control pests and diseases to continue to produce food.
The Process
Registration holders have the option to defend their products by either:
- Amending the 1A or 1B CMR classification with scientific proof.
- Applying for a temporary extension to the Registrar. (Until suitable replacements are available).
- Proving that their product does not have CMR characteristics.
- Showing that the product is an essential use and there are no suitable replacements.
- Do a risk assessment to provide data proving that their product can be safely used despite the 1A or 1B CMR characteristics.
It remains at the discretion of the Registrar whether the product defense will be successful or not. Currently of the 27 actives, the following 21 are being defended by various suppliers.
Active ingredients currently ‘supported’:
Note: Not all of these are crop protection actives, there are other organizations apart from CropLife who are defending their active ingredients.
A positive for the industry is that the Registrar has said he will fast track the registration dossiers of replacement products, especially where no suitable alternatives are available.
Other product cancellations – Cartap Hydrochloride and Chlorpyrifos
Chlorpyrifos and Cartap Hydrochloride have for some time been under threat of banning in South Africa. A few years ago Chlorpyrifos was banned for use by Pest Control Operators (PCOs) for household pests.
On the 30th of September 2020 the Registrar informed registration holders that the DoH had based on risk assessments, revoked the MRLs for these 2 insecticides. After this the Registrar announced he intended to cancel RSA registrations for these 2 actives.
On 26 June 2023, the Minister of Agriculture published her intention to disallow the use of agricultural remedies containing these 2 actives.
So, we are waiting for the DoH to invoke the ban, which, as of the time of writing, has not yet happened. This could happen at any time when publication in the Government Gazette occurs.
Paraquat
On the 27 February 2024, the Registrar announced his intention to ban the use and sale of Paraquat due to deaths caused by poisonings. At the time of writing, he has not yet published this intent. After publication, the public will be invited to provide comment.
Due date and obsolete stock
If by the 1st of June 2024 some of the listed products have been banned and Distributor companies, their Crop Advisors or their customers are still in possession of the now banned product, the destruction and incineration becomes their responsibility. Estimated costs for this is in the region of R50 000 per ton.
Conclusion
The production and supply of agricultural produce is difficult and risky enough without the added challenge of reduced crop protection chemical options to counter serious pests and diseases. There are fewer and fewer research-based companies, all of whom are faced with increasingly stringent regulations, meaning that new solutions are more expensive and less likely to find their way to registration.
On the upside, there are promising biological remedies, both already registered and awaiting registration. Laeveld Agrochem has always promoted IPM (Integrated Pest Management) programs. Now it is even more important to adhere to the stewardship principles as stipulated by CropLife and the member supplier companies. We need to protect our existing chemistry by following anti-resistance guidelines and committing to GAP – Good Agricultural Practices.
Your local Laeveld Agrochem Crop Advisor and area Business Manager will willingly assist you in drawing up effective and responsible pest and disease control programs.
Chris Thompson
Technical and Business Development Manager – Laeveld Agrochem
084 555 1350
