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Human and environmental risks from pesticides used in SA’s food systems – ACB submission to SAHRC

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South Africa continues to allow the use of numerous highly hazardous pesticides (HHPs ) many of which are banned in the European Union (EU) due to outdated legislation and weak regulatory oversight. These agrochemicals are now widespread in the nation’s food, environment, and human bodies , despite clear, long-standing scientific evidence of harm.

This submission focuses on two aspects:

i. Our compilation of the first South African Pesticide Compendium, which documents over 100 cases of human and environmental impacts from the use of pesticides in South Africa's agriculture and food systems, and ii. The recently published regulations on pesMcide derogaMons.

South African Pesticide Compendium

In July 2025, the African Centre for Biodiversity (ACB) synthesised 20 years of evidence documenting the human and environmental harms caused by pesticides in South Africa, compiled and published in the first South African Pesticide Compendium , a database of over 100 scientific and advocacy studies 1 The Compendium demonstrates that although researchers and civil society have repeatedly submiSed evidence to government structures, these efforts have not resulted in meaningful policy change , indicaMng government inacMon and insMtuMonal breakdown

The Compendium provides overwhelming scientific evidence of state negligence, systemic regulatory failure, and significant human rights violations linked to pesticide use. Immediate and decisive regulatory reform is essential to protect human health, environmental integrity, and the rights of all South Africans.

Key evidence from the Compendium

A. Human health risks

ScienMfic studies reveal:

• Documented cases of acute poisoning and long - term chronic condiMon s, including carcinogenic, mutagenic, and reproducMve (CMR) toxicity impacts

• DisproporMonate harm to farmworkers , rural populaMons, pregnant women, and children.

• Hazardous residues in food and water that affect both rural and urban consumers.

1 https://t2m.io/Pesticide_Compendium

B. Environmental risks

Evidence across ecosystems includes:

• Biodiversity decline affecMng pollinators, soil organisms, aquaMc life, birds, and mammals.

• The persistence of organochlorine pesMcides , such as dichlorodiphenyltrichloroethane (DDT) and its metabolites, which contaminates ecosystems long a[er use.

• Widespread contamination of soil, rivers, and air near agricultural zones

C. Structural inequalities and market dynamics

• Hazardous pesMcides banned in the EU conMnue to be marketed and sold in South Africa , shi[ing global chemical burdens onto African populaMons.

• Export-driven standards in the EU push HHPs out of European markets while leaving South Africans exposed through domesMc consumpMon and environmental contaminaMon.

Regulatory and governance failures

D. Outdated legislation

• RegulaMon sMll rests on the FerMlizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act 36 of 1947 (Act 36 of 1947) , which is inadequate for modern toxicological science.

E. Ine?ective oversight mechanisms

• The state body responsible for pesMcide oversight, the Department of Agriculture, Land Reform and Rural Development ( DALRRD ) , frequently fails to aSend or engage in the MulM-Stakeholder CommiSee on Chemicals Management (MCCM).

• As a result, scienMfic evidence submiSed via these channels has produced negligible policy outcomes .

F. Weak compliance with international conventions

• Poor reporMng and follow-up under the Basel, RoSerdam, and Stockholm ConvenMons further undermine state accountability.

G. Barriers to scientific impact

The Compendium highlights systemic obstacles:

• Limited funding for independent pesMcide research

• A broken science - policy interface , with research findings rarely translated into regulatory reforms

• Repeated aSempts by researchers to formally present evidence to the government have had minimal impact

Policy recommendations

Immediate regulatory actions

1. Ban all HHPs in line with global standards (parMcularly those banned in the EU).

2. Phase out other hazardous pesMcides and replace them with safer agroecological alternaMves.

Legislative overhaul

3. Replace the outdated Act 36 of 1947 with a modern regulatory framework grounded in:

a. The precauMonary principle

b. Independent risk assessment

c. Transparency and public accountability

Strengthen oversight and enforcement

4. Transform the MCCM into a mandatory, accountable regulatory pladorm with enforcement powers.

5. Improve compliance with the obligaMons of the Basel, RoSerdam, and Stockholm ConvenMon s

Protect workers and communities

6. Establish a naMonal compensaMon mechanism for workers and communiMes harmed by pesMcide exposure.

7. Mandate the disclosure of all pesMcide use, residues, and poisoning incidents.

Agricultural transformation

8. Redirect subsidies and public investment toward agroecology to reduce reliance on chemical inputs.

9. Provide farmers with training and transiMon support to reduce reliance on pesMcides

Pesticide derogation regulations

The ACB has submitted comprehensive objections to the South African government’s proposal to allow the continued use of the HHP glufosinate ammonium (GLA) through recently drafted “derogation” regulations. These regulations create legal loopholes, enabling pesticides earmarked for phase-out to continue being used under the pretext of exceptional circumstances.2

GLA use has risen sharply following two decades of widespread glyphosate application on genetically modified crops, resulting in extensive glyphosate-resistant weed populations. Several agrochemical companies, including United Phosphorus Limited (UPL) South Africa and Enviro Biochem, have supported derogation applications using nearly identical, copy-andpaste risk assessments aimed at preventing the phase-out of GLA.

Legal and governance failures

The ACB argues that the derogaMon framework is unlawful , resulMng from an anMquated legislaMve regime that undermines the state’s regulatory responsibiliMes and ConsMtuMonal obligaMons. Key governance concerns include:

• Excessive opaque decision-making power held by the Registrar of Act 36 of 1947

• Lack of transparency, such as failure to publish required quarterly lists of registered pesMcides.

• Evidence of corporate capture in pesMcide assessment and registraMon.

Public health, environmental, and social impacts

The derogaMon system perpetuates the conMnued exposure of farm workers, rural communiMes, children, and the broader public to hazardous chemicals. It also delays South Africa’s transiMon toward agroecological systems, widely recognised in global fora as necessary for sustainable food producMon.

Undermining national and international commitments

Although the South African government has commiSed to phasing out HHPs, the proposed derogaMons funcMonally reverse this commitment and contradict global norms. In the EU, derogaMons are reserved for true emergencies, rather than for sustaining long-term use of hazardous pesMcides.

2 https://t2m.io/GLAderogation_submission

Key recommendations

The ACB calls on government to:

1. Reject all derogaMon applicaMons for GLA and other HHPs.

2. Uphold and accelerate HHP phase - outs and make publicly available the criteria used in such decisions.

3. Publish evidence on feasible, safer alternaMves

4. Repeal Act 36 of 1947 and overhaul the pesMcide regulatory framework.

5. Establish an independent mulMdisciplinary decision - making body for pesMcide approvals.

6. PrioriMse a socially just, ecologically sustainable food system grounded in ConsMtuMonal rights.

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Human and environmental risks from pesticides used in SA’s food systems – ACB submission to SAHRC by African Centre for Biodiversity - Issuu