A/HRC/45/12/Add.4
23.
The statement mentioned on page 8 of the preliminary report is also noteworthy,
namely:
8. Brazil continues to use and export sulfuramid to other countries, a pesticide banned
in other jurisdictions for decades, which degrades into “forever chemical” substances
contaminating people around the world.
24.
The source of information highlighted regarding the export of the substance
“sulfluramide” by Brazil has not been identified.
25.
In any case, it is vital to inform that “sulfluramide” is 81st among the active ingredients
marketed in Brazil in 2018, according to Ibama’s Pesticide Marketing Bulletin. According to
the bulletin mentioned above, the volume of sulfluramide sold corresponds to 0.01% of the
total amount of active ingredients sold in 2018.
26.
Another relevant fact is that researches for the active ingredient sulfluramide in more
than seven thousand samples of different foods, from 2013 to 2018, within the scope of the
PARA program, did not detect residues in any sample. Currently, the substance is authorized
in Brazil as an insecticide and ant killer in the control of ants of the species Atta spp or
Acromyrmex spp.
27.
Also, page 9 of the preliminary report indicates the following:
To the contrary, Brazil has increasingly pursued deregulatory measures to authorize
additional hazardous pesticides through legislative and regulatory changes promoted
by industry.
In recent years, the “flexibilization” of pesticides regulations points to a tendency of
misplaced interests. In 2019 alone, Brazil permitted the introduction into the market
of 474 new pesticides products.
28.
It is recalled that the registration of pesticides, their components, and the like is an
assignment shared between three federal agencies: the Ministry of Agriculture, Livestock and
Supply, the Ministry of Health, represented by Anvisa, and the Ministry of the Environment,
represented by Ibama. All have equal decision-making power over whether or not to grant
registration, safeguarding their respective areas of activity and institutional competencies.
29.
It is essential to highlight that the three federal agencies have been looking for
solutions specific to their internal realities, to obtain increased productivity when evaluating
pesticide registration requirements. As a result of this joint effort, it is natural that there will
be an increase in the number of assessed products and, in many cases, registered, following
the trend of growth in demand for registration presented by the regulated sector.
30.
In this context, it must be reiterated that all registered products are previously
subjected to a rigorous technical evaluation carried out by those bodies concerning aspects
related to health and the environment. Thus, the number of products registered per year
should not be considered a negative indicator, since it refers only to the insertion in the market
of new safe alternatives for rural producers, including chemical and biological products,
which were approved because they met the requirements toxicological criteria.
31.
The chart below shows the total number of evaluation requests filed by companies
interested in obtaining their registration, the number of favorable analyzes by type of
registration and the number of analyzes not granted, as they were registered or rejected,
which, added together, total the number of requests processed by Ibama:
5
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