We present observations to the “good practices” of agrochemical application

The Final Report of the Interministerial Working Group on Good Practices in the Field of Phytosanitary Applications was submitted to public consultation from July 20 to August 20. From FUNDEPS we present our observations and objections to it.

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Through Joint Resolution No. 1/2018, the Ministries of Agribusiness and Environment and Sustainable Development of the Nation created an Interministerial Working Group on Good Practices in the Field of Phytosanitary Applications.
The objectives of the working group were:
• Elaborate the principles for ordering national public policies on phytosanitary applications, especially in buffer zones, and
• Make recommendations regarding how to improve the adoption, control and monitoring of good practices in the application of phytosanitary products.

The Working Group is made up of representatives of both ministries, the National Service of Agrifood Health and Quality (SENASA) and the National Institute of Agricultural Technology (INTA), who had two representatives each. In addition, the Ministry of Health, the Ministry of Science, Technology and Productive Innovation, the Federal Council of the Environment (COFEMA) and the Federal Agricultural Council (CFA), who participated with only one representative, formed a part. He met six times between April 5 and July 5, 2018.

The final result was a document that proposes 12 principles and 23 recommendations, which was open to public consultation for a month through a web platform with consultative status. The participation of the society was very low, only 180 people left settled their contributions, which accounts for the little publicity that was given to the report and the public consultation carried out by both ministries.

From FUNDEPS we make some considerations and objections to the document, including:
– The Interministerial Working Group is composed mostly of representatives of agriculture;
– Absence of participation in the work process of qualified technical professionals, universities, NGOs and civil society in general.
– The need for a law as a public health issue is not analyzed;

– It is not taken into account that sprays can not be controlled. No matter how much “good agricultural practices” are adopted and climatic conditions are taken into account, the chemical products that are used have persistence in the environment and are mobilized through water and air even after the application is made;
– There is no clarity regarding the technical criteria that would be used to delimit the “buffer zones”, nor how they would be respected;
– The carrying out of epidemiological surveys from the Ministry of Health is not effectively ensured in order to know the situation of the populations near cultivation areas;
– It does not consider the principles of the General Environmental Law No. 25,675 that governs any national environmental policy, in particular the principles of prevention and precaution;
– It does not contemplate an inescindible sanctioning regime to the control and monitoring of “good agricultural practices”, among others.
One of the proposals presented in the report is to promote a national law on the application of phytosanitary products, complementary to the regulation on product registration and the law on empty pesticide containers. From FUNDEPS we support the enactment of a national law of minimum budgets referred to the application of agrochemicals guided by the precautionary principle and to establish a reference framework that protects the fundamental rights to the environment, health and quality of life of people .

More information:

Observaciones al informe sobre buenas prácticas en aplicaciones de Fitosanitarios



Lourdes Aparicio, Juan Bautista López y María Pérez Alsina


María Pérez Alsina – mariaperezalsina@fundeps.org