A/HRC/45/12/Add.4 Report of the Special Rapporteur on the implications for human rights of the environmentally sound management and disposal of hazardous substances and wastes (Advance Unedited Version) — Comments from Brazilian authorities 1. The present document is a manifestation of the Brazilian state concerning the preliminary version of the report on the visit of the United Nations Special Rapporteur on Waste and Toxic Substances, Baskut Tuncak, to Brazil, held in December 2019. It is based on comments from the National Agency of Health Surveillance (Anvisa1), Brazilian Institute of the Environment and Renewable Natural Resources (IBAMA), Ministry of Health (MS), and Ministry of Justice and Public Security (MJSP). Duties and responsibilities to protect life and prevent exposure (Pesticides, Forest Fires and Industrial Chemicals) 2. First, it is necessary to present information about the pesticides regulation in Brazil. According to Law 7,802, of July 11, 1989, the regulatory process for pesticide products is a complex act involving the Ministry of Agriculture, Livestock and Supply (MAPA), the Ministry of the Environment (MMA), through IBAMA, and the Ministry of Health, through Anvisa. Each agency analyzes the registration request according to its competence. MAPA, as the registering body, is responsible for issuing the registration certificate. 3. The toxicological assessment for the sake of safety in the use of a pesticide is a highly specific and complex technical report. In this context, due to this particularity of the process, the evaluation is multidisciplinary and interdependent. Such practice contributes to the safe assessment of a product used in the production process, which can affect Brazilian society through occupational exposure or dietary exposure to its residues in food. Hence, it is necessary to estimate, as precisely as possible, the amount of pesticides to which individuals are exposed. 4. From the consumer's point of view, this estimate is made by assessing dietary risk, which involves analyzing the likelihood of adverse effects on human health, resulting from the ingestion of food containing pesticide residues. From this assessment, different parameters are established, among which the Dose of Acute Reference (DRfA), the Acceptable Daily Intake (IDA), and the Residue Maximum Limit (LMR) in food. Therefore, the assessment of dietary risk is part of Anvisa's assessment routine. 5. Anvisa also monitors the levels of pesticides in food within the Food Pesticide Residue Analysis Program (PARA). The Program is an action of the National Health Surveillance System (SNVS), coordinated by the Anvisa, in conjunction with the state health surveillance agencies and the Central Public Health Laboratories (Lacen). Created in 2001, initially as a project, it became a program in 2003, through the Resolution of the Collegiate Board - RDC 119, of May 19, 2003. Since then, the Project analyzed more than 35 thousand samples of various foods representative of the diet of the Brazilian population. 6. The program's main objective is to monitor pesticide residues in food, aiming to mitigate the health risk resulting from exposure to these substances through the diet, evaluating irregularities and health risks, based on the analysis of samples collected across the country. 7. Anvisa evaluates the program's analysis outcomes and maps the distribution of pesticide residues in food so that mitigating measures are adopted when irregularities or health risks are verified. Consequently, it contributes to food security, guiding the production chains on the existing non-conformities in their production process, and encouraging the 1 2 Note on translation: the initials and acronyms of Brazilian governmental bodies, agencies, projects, and programs reflect their original names in Portuguese.