A/HRC/45/12/Add.4
Analysis requests submitted previous to 2011
Analysis requests
PF (Formulated Product)/PFE (Formulated Product based on Equivalent Technical Product with access letter)
PFC (Formulated Product with access letter)/PFEC (Formulated Product based on Equivalent Technical Product with access
letter)
PT (Technical Product)
PTE (Equivalent Technical Product)
PM (Premix)
Denied and filed requests
Total of concluded requests
32.
During the period considered in the graph, investments were made in information
technology tools, personal inputs, and management systems, which led to a reduction in
individual processes' analysis time.
33.
In this way, the figures should be interpreted considering that since 2011, Ibama and
the other competent bodies have improved and harmonized several administrative routines,
which interfere with process management's dynamics to streamline the workflow.
34.
It is important to stress that these changes do not represent the “flexibilization” of
technical and scientific criteria used to evaluate products. On the contrary, over the years,
there has been an increase in technical rigor for completing environmental assessments, such
as the application of additional and more sophisticated analysis methodologies for New
Technical Products (Risk Assessment), the definition of criteria for a product more toxic to
the environment not to be approved when another product for the same purpose is already in
the market4, and the establishment of criteria for risk assessment aimed specifically at
protecting pollinators5.
35.
It should also be noted that these numbers correspond to the analyzes made by Ibama,
but not necessarily all resulted in products registered by MAPA. A product may have met the
environmental criteria and be considered suitable for registration by Ibama, but it may not
have met the health criteria and be deemed unfit for registration by Anvisa. And vice-versa.
36.
Due to the great demand for evaluation requests received by Ibama and other federal
agencies involved in the pesticide registration process, MAPA published, in the Official
Union Gazette of August 12, 2015, Ordinance 163, of August 11, 2015. It establishes
criteria for prioritizing pesticide products' analysis with a view to the health of plants,
taking into account the most dangerous pests, the main crops, and the list of active
ingredients, agricultural products and technologies subject to registration. In 2016, 2017
4
5
6
Normative Instruction 27, of 12/27/2018 and amendments by NI 3/2019.
https://www.ibama.gov.br/phocadownload/agrotoxicos/reavaliacaoambiental/2017/2017-07-25Manual-IBAMA-ARA-Abelhas-IN0217-WEB.pdf.
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