SA Pesticide Compendium Documents Widespread and Worrying Human and Environmental Risks and Impacts
First of its kind South African pesticide compendium documents 100 CASES of widespread and worrying human and environmental risks and impacts
JULY 2025
The African Centre for Biodiversity (ACB) is committed to dismantling inequalities and resisting corporate industrial expansion in Africa’s food and agriculture systems.
PO Box 29170, Melville 2109, Johannesburg, South Africa.
Tel: +27 (0)11 486-1156
Researched and written by Sasha Mentz-Lagrange
Editorial oversight and input by ACB executive director Mariam Mayet Design and layout: Xealos Design Consultancy
Acknowledgments
The ACB gratefully acknowledges the financial support of several donors, though the views expressed may not necessarily reflect the views of our donors.
Acronyms and abbreviations
BRS Basel, Rotterdam, and Stockholm Conventions
CANSA Cancer Association of SA
CBD Convention on Biological Diversity
CEOHR UCT’s Centre for Environmental and Occupational Health Research
CMR Carcinogenic, mutagenic, and reproductive toxic substances under the GHS
CSIR Council for Scientific and Industrial Research
CSO Civil society organisation
DALRRD Department of Agriculture, Land Reform and Rural Development
DDE Dichlorodiphenyldichloroethylene
DDT Dichlorodiphenyltrichloroethane
DEFF Department of Environment, Forestry and Fisheries (now part of DFFE)
DFFE Department of Forestry, Fisheries and the Environment
DoH Department of Health
EDCs Endocrine-disrupting chemicals
EU European Union
FAO United Nations Food and Agriculture Organization
GBF CBD’s Global Biodiversity Framework
GHS United Nations Global Harmonized System of Classification and Labelling of Chemicals
HHPs Highly hazardous pesticides
IRS Indoor Residual Spraying
JMPM FAO/WHO Joint Meeting on Pesticide Management
MCCM Multi-Stakeholder Committee on Chemicals Management
NGOs Non-governmental organisations
NRF National Research Foundation
OCPs Organochlorine pesticides
RAs Risk assessments
SA South Africa
SAPToA South African People’s Tribunal on AgroToxins
UCT University of Cape Town
VHEMBE Venda Health Examination of Mothers, Babies and their Environment
WHO World Health Organization
WRC Water Research Commission
This pesticide compendium provides compelling evidence of the harm caused by pesticides and HHPs in South Africa, in support of ACB’s ongoing campaigning to ban all HHPs and for the urgent transition of industrial agriculture to ecologically sustainable and socially just systems.
Context: pesticides, power, and public risk – government intransigence and the pervasive use of HHPs
For over 20 years, scientists and civil society in South Africa (SA) have been undertaking research showing the human and environmental harm caused by highly hazardous pesticides (HHPs),1 including deaths from street pesticides freely available, and, more recently, their proliferation in urban areas. This research has been brought to the attention of the South African State repeatedly, through peer-reviewed scientific publications, and numerous formal and informal channels.
“How could intelligent beings seek to control a few unwanted species
by a method that contaminated the entire environment and brought the threat of disease and death even
to their own kind?”
Rachel Carson, Silent Spring
1 HHPs are pesticides that present particularly high levels of acute or chronic hazards to health or the environment according to internationally accepted hazard classification systems. Their HHP listing can be found in relevant binding international agreements or Conventions, or under conditions of use in a country. They are typically characterised by their acute toxicity, their potential to cause chronic health effects or their persistence in the environment and are commonly highly restricted or banned in many countries of the world.
The Department of Agriculture, Land Reform and Rural Development (DALRRD) is the primary department responsible for the registration of “chemical remedies”2 in SA and therefore responsible for the fact that today, shockingly, 195 HHPs can still be legally imported into and used in the country.3
In 2010, 15 years ago, the Pesticide Management Policy conveyed the government’s intention to ban or phase out HHPs. In this regard, the policy stated that it took cognisance “that special attention should be given to pesticides that pose an unmanageable risk, with an understanding that such pesticides should be considered for phase-out, severe restriction and bans.”Those that would be considered for banning included persistent organic pollutants (POPs), endocrine-disrupting chemicals (EDCs), those with carcinogenic and immunologic potential, formulations classified by the World Health Organization (WHO) as Extremely Hazardous (class 1a) and Highly Hazardous (class 1b), as well as pesticides associated with frequent and severe poisoning incidents.4 In the intervening period, DALRRD issued two discussion papers on pesticide legislation, indicative of its knowledge that the current antiquated legislation must be replaced to be fit for purpose (London 2019; ACB 2024; UnPoison 2024a, b, c). However, nothing has been done to advance legislative reform, to which the state committed.
Then, in 2023, the Registrar, acting under the auspices of Act 36 of 1947 (Farm Feeds, Agricultural Remedies and Stock Remedies Act), the antiquated apartheid legislation now more than 80 years old, promised to phase out 116 HHPs by June 2024. However, under tremendous undue influence from the agrochemical industry, the department reneged on this undertaking, and only 28 were identified for phasing out. Adding insult to injury, regulations were passed to allow the industry to apply for exemptions – known as derogations – to continue to use these same toxic chemicals under certain circumstances.
Over the past two decades, South African researchers, academics, and civil society have consistently and persistently raised concerns, presented evidence, and demanded accountability regarding the human and environmental harm caused by HHPs and pesticides more broadly. A recent publication, which investigated the rise in food-borne illnesses and related child deaths by comparing data from 2017 and 2020/21, found that pesticides were the leading cause of poisoning deaths, accounting for 42% of child fatalities and 29% of adult fatalities (Prinsloo et al. 2025).
Despite these alarming findings, neither the Registrar nor the Department of Agriculture, nor any other organ of state, for that matter, has adequately or at all acknowledged this body of work. The recent and welcome ban on Terbufos, 5 by way of a Cabinet decision, in June 2025, came about mostly because of the public outcry and activism that followed the tragic deaths of several primary school children from Naledi, Soweto, in October 2024. Yet, calls for the banning of Terbufos predated this unfortunate tragedy, as researchers and civil society had long been calling for the prohibition of Terbufos following the deaths of street children in 2009 in the Western Cape.6
2 This is the antiquated term to refer to pesticides, a term only SA is known to use, imbuing the concept with a reassuring medicinal connotation, which of course pesticides are far removed from.
3 This figure is now down to 194, as Terbufos has recently been banned.
4 Notice 1120 of 2010 no.33899 37 Department of Agriculture, Forestry and Fisheries Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (act no. 36 f 1947) adoption of pesticide management policy for SA, at page 4 see https://www.gov.za/sites/default/files/gcis_document/201409/338991120.pdf
7 Other pesticides classified by the WHO as Class 1a and 1b remain merely restricted (restricted for agricultural rather than domestic use) as opposed to being banned outright (London, personal communication, 2025).7 This reliance on the “restricted” category means these highly hazardous substances are still in use under so-called management protocols. However, this raises serious concerns about whether they are truly being managed effectively, especially in light that the primary enforcement mechanism is a system of complex labelling. There is also a chronic lack of comprehensive data on the actual use of these restricted pesticides in SA and their impacts on human health and the environment.
7 Professor Leslie London is the head of Public Health Medicine in the School of Medicine at the University of Cape Town
Pesticide compendium: compelling scientific evidence supporting the case of State gross negligence
Comprehensive database listing over 100 papers produced over 20 years!
The ACB conducted an in-depth review of scientific publications, working papers, and reports that we could find, published since 2005 on acute and chronic pesticide exposure in SA, and the associated human health and environmental impacts. These publications are captured in an accompanying Compendium or database, currently containing over 100 entries, which is intended to remain a living document.8 It sets out peer-reviewed scientific publications, working papers, reports, and petitions related to pesticide exposure in SA, spanning the period from 2005 to 2025. 9
In addition to scientific research, the compendium incorporates a significant number of papers addressing severe policy and regulatory failures, many of which also include explicit recommendations to the State aimed at addressing institutional and regulatory shortcomings. This 20-year record focuses specifically on research conducted within the South African context, documenting evidence of human and environmental harm attributed to pesticide use.
While comprehensive, the Compendium may not be exhaustive, and it will need updating as new research becomes available. The compendium also includes a small number of entries focusing on dichlorodiphenyltrichloroethane (DDT) and dichlorodiphenyldichloroethylene (DDE), for malaria vector control, so that evidence on this critical issue remains at the forefront. However, given the voluminous number of studies on DDT and DDE and the complexities that are linked to DDT usage in SA (see Annex 1 for more details), we decided not to include all these studies in the compendium.
The compendium identifies the specific types of pesticides examined in each study and indicates whether they fall under the classification of HHPs, as defined by the UnPoison Network’s framework (latest update: February 2025).10 (Also, see Annex 1). This classification system provided by Unpoison represents the most comprehensive and contextually appropriate understanding of HHPs.
8 https://t2m.io/Pesticide_Compendium
9 Many papers on the topic were published prior to 2005, and should ideally also be taken into account as evidence, but for practical purposes, we opted to focus on the latest 20 years.
10 https://unpoison.org/wp-content/uploads/2025/02/UnPoison-SA-HHPs-Database-JMPM-criteria_GHS_ECHA_FEBRUARY-2025.. pdf
Explanatory notes to the Compendium: a user-friendly resource for researchers, advocates, and civil society
Each entry in the Compendium is systematically organised by authorship, title, publication date, and journal, with links provided where the publications are free and easily accessible. This database enables users to easily search for evidence related to pesticides (including HHPs, where these have been researched) according to their use and the evidence of harm linked to their use.11
The user-friendly database includes full abstracts, the specific pesticides studied in each paper, and their HHP status is specified in a table below the Compendium. It also includes key findings on harm, the research timeline, geographical focus, and research methodology. Additionally, the compendium captures each paper’s technical or policy recommendations, suggestions for further research, and references to useful tools or methodologies. Where available, it notes instances where the evidence was formally presented to the government, including how it was received, though such information is limited (see discussion below for further details). In cases of human harm, the type of harm suffered is specified. Similarly, instances of environmental harm include details on the nature of the pollution or ecological concern.
The compendium categorises studies focused on human health according to the type of pesticide use under investigation. Most of the papers examine the exposure resulting from agricultural activities, particularly chemicals used for crop protection, as well as from domestic pest control. A smaller number of pesticides are used in alien vegetation control.
A significant portion of the research focuses on children, who are particularly susceptible to pesticide toxicity due to their smaller body size (resulting in higher exposure per kilogram), immature metabolism, and developing organ systems.
In addition, the database allows one to search for papers falling into categories as follows:
• Source of the pesticide and its potential use:
- agricultural use for crop protection
- animal dipping
- weed control in public spaces
- domestic use of pesticides for insect and rodent control
- domestic use for gardening purposes
- alien vegetation control
- malaria control
- pesticides linked to wastewater contamination
- pesticides from the manufacturing of pesticides
• In the case of human harm, the nature of the study:
- workplace study
- residential study
- dietary study
- market study
• In the case of human harm, the source of human exposure:
- inhalation
- pesticide ingestion
- soil ingestion and inhalation
- dermal exposure
- In utero exposure
- a combination of several sources
• When environmental or human harm is suffered due to agricultural activity, the source of pesticide contamination or exposure is:
- crop residue
- direct exposure in the field
- exposure to fomites
- spray drift, pesticide runoff from fields
- combination of the three above sources of contamination
- pollution from sewage works
• In the case of environmental harm, the environmental element affected:
- soil
- freshwater
- seawater
- air
- combination of the above
Compendium compilation and its methodological challenges
One of the most significant methodological challenges encountered during this research was the lack of response from officials at DALRRD, the Department of Forestry, Fisheries and the Environment (DFFE), and the Department of Health (DoH). This occurred despite multiple attempts by civil society and experts to engage these organs of state. Only one official, from the DFFE, responsible for the registration of
pesticides used in alien vegetation control, responded (Muir, pers. comm., 2025). ACB’s investigation also confirms the State’s consistent lack of response to mounting evidence of harm, and a general disinterest from some public research institutions in dedicating resources to this critical area of study.
This lack of accountability and unwillingness to engage with civil society indicates an abject abdication of the government’s administrative justice obligations and responsibilities, including paying heed to public oversight, public participation, and consultation.
Securing interviews with some of the scientific experts in the field also posed challenges, largely due to their demanding schedules. However, the majority of those contacted did respond, either through written questionnaires or by agreeing to telephonic interviews.
Moreover, the original research design also sought to systematically track whether, and how, each piece of scientific evidence had been presented to the government, and where possible, how the government responded. However, there is only one formal platform – the Multi-Stakeholder Committee on Chemicals Management (MCCM) – through which such findings are known to be officially presented to relevant organs of the state.
We discuss below how some critical evidence presented to the MCCM has been left unaddressed by the government/key regulatory bodies. In cases where informal engagements may have occurred, such as workshops attended by government representatives, there is often a lack of documentation regarding attendance or outcomes, making it difficult to verify or systematically include such instances in the Compendium. As a result, only a limited number of such occurrences have been recorded.
Noteworthily, we have found that researchers tend to focus on pesticides for which reliable biomarkers exist, enabling easier detection and monitoring in human biological samples. However, one of the most notable gaps in the South African research landscape is the limited documentation of chronic pesticide exposure and its correlation with increased cancer risk
Although the global scientific literature presents substantial evidence linking pesticide contamination and exposure to higher rates of cancer and other chronic health conditions, SA continues to suffer from a significant lack of locally generated research in this area and the reasons for this were not specified (CANSA, pers. comm., 2025).12
What ACB did establish is that the lack of epidemiological research to make a correlation between cancer risk and pesticide exposure is because these studies are very expensive and require large cohorts to be monitored over long periods (Fuhrimann, pers. comm., 2025; see also section on research challenges)
Thus, the compendium should not be viewed as an exhaustive record of all research conducted on the harms of pesticides in SA. Rather, it offers a representative illustration of the volume and quality of evidence generated over the past two decades, including numerous studies that provide clear and often urgent recommendations to policymakers to address identified risks and provide redress.
Finally, while this paper and the accompanying compendium primarily aim to support the banning of HHPs, it is of paramount importance that we point out that the ACB’s advocacy work has historically extended beyond the scope of pesticides but also to their co-formulants that, although not currently classified as HHPs, are nevertheless highly toxic to human and environmental health. This, for instance, concerns the adjuvants that are used in the formulation of glyphosate (ACB 2019).
Key findings from the Compendium
Proof of Human harm
The compendium includes 44 peer-reviewed papers evidencing human harm linked to pesticide use. Many of these document evidence of harm linked to pesticides that are not authorised in the EU and still in use in SA. The broad categories of human harm for which the papers provide evidence include:
- Accidental poisoning due to the ingestion of unlabelled, often illegally traded, so-called “street pesticides” to control domestic pests. These accidents predominantly affect children.
- Self-harm is linked to acute poisonings by pesticides, with ingestion of pesticides being one of the most common methods of suicide deaths and suicide attempts.13
• Health impacts associated with acute exposure include peripheral and central neurotoxicity. Acute exposure is often reported and documented in the context of agricultural activity, with farm workers bearing the brunt of exposure.
• Chronic exposure risks to HHPs are also documented, but as explained below, this research is more limited in the South African context and often supported by global case studies. Chronic exposure can result in “effects on the skin, eyes, nervous system, cardiovascular system, gastrointestinal tract, liver, kidneys, reproductive system, endocrine system, immune system, and blood. Some HHPs may cause cancer, including childhood cancer.” (WHO, undated).
• Endocrine disruption is another manifestation of chronic exposure.
12 Cancer Association of SA
13 The peer reviewed papers based on data from the South African poison centres and hospitals which document these unintentional and self-inflicted poisonings have been systematically reported to the State via the MCCM over the past (personal communication with Rico Euripidou of groundWork and Dr Cindy Stephen, 2025), with no instances of any concrete action plan ever being formulated to act on this evidence (see below for more detail).
13
In his expert submission to the South African government, London (2019) highlighted several pesticides still legally in use despite evidence of carcinogenic risk. These include glyphosate (which is notably not classified as an HHP), malathion, diazinon, and ethylene dibromide. All these pesticides are listed in the compendium as studied pesticides.
London also mentions the following pesticides still legally in use as being EDCs: endosulfan*, carbaryl, mancozeb, methamidophos, parathion*, atrazine*#, 2,4-D, fipronil, and ipriodione. (All these pesticides are HHPs save for ipriodione. Pesticides marked with an * are not authorised in the EU and are on UnPoison’s priority list for banning, and # indicates an HHP whose use is not supported by DALRRD).14
In residential settings, most documented cases of harm are linked to accidental or intentional ingestion of pesticides. On farms, workers are primarily exposed through inhalation, skin contact, and contaminated surfaces or materials (fomites).
While pesticide application is often carried out by male farmworkers, female farmworkers are also highly vulnerable. Their exposure occurs in multiple ways, including working in fields during spraying without appropriate protective equipment or being required to re-enter treated areas, such as vineyards, too soon after pesticide application.
Environmental health risks
The compendium includes 21 peer-reviewed papers showing evidence of environmental health risks linked to pesticide use. Overall, the studies paint a bleak picture of deteriorated soil health and the dismal condition of SA’s water bodies, including rivers and coastal ecosystems. These environmental degradations have serious implications for ecosystem integrity and pose significant risks of exposure to humans through contaminated water and food, and waterborne diseases.
14 This is terminology used in DALRDD’ (2017) “banned remedies”. There are but a few remedies listed there that are described as not supported, which appears to mean that the remedy in question is not fully banned but subject to a crop specific or geographic restriction, and thus is still being used but that the department does not encourage or support its use.
Pesticide contamination in rivers has reached such alarming levels that many communities are at increased risk of cancer due to the consumption of fish from polluted rivers and oceans Machete and Shadung (2019), for example, found atrazine, alachlor, and simazine in the tap water consumed by primary school children in the Lomati catchment, situated in the eastern part of Mpumalanga province, highlighting a serious human health exposure risk.
Only the Water Research Commission (WRC) and the Council for Scientific and Industrial Research (CSIR) have undertaken notable work. In 2015, the WRC commissioned an investigation of the Contamination of Water Resources by Agricultural Chemicals and the Impact on Environmental Health in SA (Dabrowski 2015a; 2015b). This two-part report offers one of the most comprehensive pictures of the extent of water contamination by a wide range of pesticides countrywide (Volume 1) and proposes a prioritisation matrix focused on human health effects, combined with a mapping of sources of agricultural pesticides used in South Africa (Volume 2).
The priority list of pesticides produced in the WRC report (2015a) was combined with a mobility index to identify pesticides for inclusion into the development of risk-based water quality guidelines for irrigation. The report also recommended the production of a manual providing guidelines on choosing agricultural chemicals that minimise effects in non-target environments (both in terms of human and ecological health). The legacy and uptake of this research by the government could not be determined. Dabrowski reported no knowledge of mechanisms for communicating results from the WRC or CSIR to the relevant authorities, nor any resulting policy actions (pers. comm., 2025). The CSIR, when contacted, indicated it no longer works in this field (Mtamzeli, pers. comm., 2025).
Coastal waters are not exempt. Multiple studies confirm high levels of pollution from a variety of sources, including pesticides. Even elite marine environments are not exempt. Ojemaye et al. (2020) conducted a risk assessment of herbicides in Camps Bay and found that the carcinogenic risk associated with consuming seafood from the area exceeded acceptable levels.15 It is important to note that the pesticide contamination observed in Camps Bay is not linked to agricultural activity, as the area is primarily residential. Instead, the chemical load discharged via marine outfalls into this popular “Blue Flag” beach is largely attributed to pesticide use in ornamental gardening by both households and municipal services. As Petrik points out, considering the substantial contribution of domestic pesticide use to overall pollution levels, it is essential to “curb the domestic use and accessibility of these pesticides.” (Petrik, pers. comm., 2025). The Environmental and Nano Science Research Group, Department of Chemistry of the University of the Western Cape, has conducted extensive research looking into pharmaceutical and pesticide-contaminated fish caught along the coastline of South Africa (Ojemaye et al, 2020). Research is currently underway by the same group to ascertain the extent to which SA’s fish stocks are contaminated by persistent chemicals found in sewage. The July 2021 UPL agrochemical warehouse explosion in Durban was likely to have been a significant source of contamination of aquatic resources on the KwaZulu-Natal coastline, even affecting deep water fish species (Petrik, pers. comm., 2025), and requires further investigation.
The studies investigating the extent of pesticide contamination in water bodies (both soft water and the ocean) and drinking water call for intervening measures to adequately monitor levels of pesticide contamination, especially endocrine disruptors (Patterton 2012) and to define guidelines and monitor of the use, storage and disposal of these chemicals (Ojemaye et al. 2020). Many papers call for the need to expand the correct use of less harmful alternatives (e.g., Quin et al. 2011).
Studies also show that imidacloprid, a systemic neonicotinoid insecticide, is one of the most prevalent pesticides in the environment. It has been consistently detected in surface water, often exceeding environmental safety thresholds. However, it is contended that should imidacloprid is phased out, the likely alternatives would be pyrethroids and organophosphates, which carry significantly higher risks for human health, including neurotoxicity (Fuhrimann, pers. comm., 2025). This underscores the need for systemic transformation of SA’s industrial food and farming systems to those that are ecologically sustainable and socially just.
15 Their findings suggest that “an average-sized human (70 kg) might suffer significant health risks should any of the seafood analysed herein be consumed on a daily basis (54 g) over a lifetime period (life expectancy of 70 years).”
EU export standards drive HHP phase-out, shifting risk to the domestic market
A further key finding is that the phasing out of HHPs on large-scale, export-oriented farms in SA is primarily driven by increasingly stringent European Union (EU) food regulatory standards, rather than domestic political decisions informed by scientific evidence of harm
As the EU continues to tighten its pesticide regulations, South African exporters are being compelled to adapt accordingly to maintain their access to European markets. A clear example is the banning of chlorpyrifos in SA, which followed its prohibition in the EU, not as a direct response to the growing body of scientific literature documenting its harmful effects in SA but as a trade-related compliance measure (Fuhrimann, pers. comm., 2025).
Nonetheless, HHPs remain in high use in smaller, non-European exporting farms, particularly producers catering to markets such as the United States and China, where pesticide regulations are comparatively less stringent. In these contexts, the continued reliance on individual, often poorly regulated pesticides poses significant challenges for monitoring, risk assessment, and safeguarding human and environmental health.
“A Who’s Who of pesticides is therefore of concern to us all. If we are going to live so intimately with these chemicals eating and drinking them, taking them into the very marrow of our bones - we had better know something about their nature and their power.”
Rachel Carson, Silent Spring
Weak governance structures governing pesticide regulations in SA
The fragmented nature of pesticide legislation in SA, combined with institutional dispersion (London, 2019; Proceedings of the South African People’s Tribunal on Agrotoxins [SAPToA]),16 and the absence of a statutory multi-stakeholder body to oversee pesticide regulation, are key factors explaining why scientific evidence of pesticide-related harm has not led to mandatory government action.
The Department of Environment, Forestry and Fisheries (DEFF)’s 2021 draft Strategic Approach to International Chemicals Management (SAICM) calls for the “establishment of an intergovernmental statutory body to ensure the effective and efficient management of pesticides” (2021). Consequently, the MCCM was established under the auspices of the DEFF, now DFFE, which is the designated national authority for the implementation of international conventions on pesticides (Euripidou, pers. comm., 2025). The MCCM’s mandate is to oversee compliance with the International Conventions that SA ratified (London 2019) and to provide a platform for participants to share the outcomes of their research, policy work, and other related activities. While various government departments, non-governmental organisations (NGOs), and industry representatives are invited to participate in the quarterly meetings convened by the MCCM, the MCCM is not a statutory body. The lack of formal status limits the consistency and effectiveness of participation and, indeed, action.
It has been reported that both the DoH and DALRRD attend only sporadically (Stephen 2025; Rother 2025). Also, the DFFE’s limited authority and capacity were openly acknowledged during the SAPToA. There, testimonies by impacted people demonstrated that although DFFE is fully aware of the serious risks posed by many HHPs, they are unable to take decisive action, as the legal authority for pesticide registration and regulation rests solely with DALRRD) (Rother 2025; Stephen, pers. comm., 2025).
The civil society representatives participating in the MCCM all concur that making the MCCM a statutory body would ensure that all government departments would attend and take responsibility (Rother, 2025; Stephen; Euripidou, pers. comm. 2025) and that there would be accountability for inaction.
The ACB formally requested an interview with the Registrar to clarify the department’s participation in the MCCM and to assess the extent to which the department acknowledges scientific evidence and responds to civil society concerns. No response was received.
Experts consulted by the ACB noted that DALRRD generally showed weak participation not only in the MCCM but also in other workshops or conferences focused on pesticide safety, with little follow-up or development of action plans to address the issues raised (Dalvie; Euripidou, pers. comm., 2025).
Dr Cindy Stephen, now retired and formerly the director of Red Cross War Memorial Children’s Hospital, has been actively participating in MCCM meetings for several years. In her quarterly submissions, she has regularly presented data from the Poison Information Helpline on pesticiderelated harm and fatalities (see an example of such a submission in Stephen et al., 2018). Dr Stephen has consistently advocated for the banning of paraquat, along with various pesticides classified under WHO hazard classes Ia, Ib, and II. Despite the ongoing presentation of this evidence, there has been no official response from government departments to communicate the development of a programme of work or policy response in light of the data presented (Euripidou, pers. comm., 2025).17 This lack of response on the part of the Registrar seems to be a recurrent and ongoing stratagem, as testified by the ACB’s experience with DALRRD’s ongoing lack of response to repeated requests concerning the review of the registration of the toxic chemical, 2,4-D.18
The dysfunctionality of the MCCM has rendered this voluntary body ineffective as a mechanism for elevating medical evidence on registered pesticides in SA. This also means that this body is ineffective in serving to inform regulatory decision-making in the public interest. Terbufos, for example, made national headlines in late 2024 following the tragic deaths of six children in Soweto in November (Daily Maverick, 2024). As a known HHP, Terbufos has long been the subject of warnings from medical and public health bodies, including formal alerts issued as recently as February 2024 (see below). Despite its documented risks, it remained approved for use in SA and was not notified under the Rotterdam Convention, as would have been expected for such a substance. The ban on Terbufos was only implemented in June 2025, far too late to prevent avoidable harm, including the deaths of children.
17 Only recently (2024) did the Registrar’s office request that Dr Stephen submit further information on paraquat, presumably as part of efforts to include it on DALRRD’s list of HHPs for potential phase-out.
18 The ACB has submitted multiple formal requests to the Registrar calling for regulatory action on 2-4,D, including a request to have it classified as an HHP (ACB 2024a). Despite these efforts, no response was received over a one-year period, prompting the latest formal appeal to the Minister (ACB 2024b).
20 Terbufos – a staggering example of State failure to heed scientific evidence
An illustration of this regulatory failure was given by Professor Andrea Rother, Head of the Environmental Health, School of Public Health and Family Medicine, UCT, who testified at the South African People’s Tribunal on AgroToxins (SAPToA) in March 2025. She explained that a paper published in 2023, which she co-authored, based on a retrospective case review of child and adolescent mortality associated with pesticide toxicity in Cape Town between 2010 and 2019, attributed over 50% of deaths from pesticide poisoning in SA to Terbufos (Davies et al. 2024).
The paper explicitly alerts to the danger caused by Terbufos and methamidophos (both HHPs) and includes the following policy recommendation:
Reducing access and availability of toxic pesticides, especially through the illegal selling of street pesticides, and providing low-toxic alternatives to poorer communities, may support mortality reduction initiatives. (Davies et al. 2024).
Experts attending the MCCM alerted the government about this finding in February 2024. In her testimony, Professor Rother underscored that the government did not respond to the evidence shared and that CropLife and DALRRD trusted what the industry relayed. The relentless denial regarding this problematic chemical resulted in the Naledi tragedy, when six children were poisoned and killed by this HHP.
Rother explains:
Despite the crystal-clear evidence provided, our government has chosen to prioritise the corporate profits of the chemical industry over constitutional rights to our health and the right to a clean and healthy environment. (Rother 2025)
Inadequate reporting of Basel, Rotterdam, and Stockholm Convention focal points to MCCM
The focal points of the Basel, Rotterdam, and Stockholm (BRS) conventions are required to develop national assessments, a National Action Plan (NAP), and a National Implementation Plan (NIP). The focal points were contacted to obtain a copy of the scientific evidence used to develop these assessments. A report, dated 2018 and titled, Development of an inventory and management strategy for Highly Hazardous Pesticides in South Africa: final report, was shared. In this report, Ogwini
Environmental Solutions (Pty) Ltd, the firm appointed for the HHP inventory and strategy development, identified 459 products,19 being assigned HHP status based on the joint FAO/WHO Joint Meeting on Pesticide Management (JMPM) criteria for defining HHPs. The report only speaks of environmental and human harm in a broad manner, but highlights the need to reduce the presence and use of HHPs at the national and regional level and identifies alternatives to HHPs, including Integrated Pest
19 The study numbers are aligned to the generated database, in that it identified at the time 459 HHPs divided under the following categories: 61 pesticides in la category, 89 pesticides constituting lb category, and 41 pesticides in JMPM criteria 2-4. The 309 remaining pesticides (not included in the UnPoison database) were found to be harmful to the environment and include: 42 pesticides identified with active ingredients listed as chemicals under the Multilateral Environmental Agreements (MEAs) included in the JMPM criteria and 37 pesticides identified with active ingredients listed as chemicals on Pesticide Action Network (PAN)’s list.
Management (IPM). These recommendations are aligned with what SA civil society has been calling for and which the government has failed to implement. London noted in his 2019 opinion piece that the last chemical profile of SA had been compiled in 2005, meaning any planning of preventive action would be based on outdated information.20
Challenges to pesticide research in SA
In SA, researchers face significant constraints in conducting studies at the scale necessary to adequately assess the impacts of pesticide use in agriculture. Limited access to research funding hampers locally driven investigations, often leaving better-resourced external institutions to shape the research agenda. These external actors typically adopt a system-level perspective, with most assessments relying on approximated risk thresholds derived from EU standards.
Research efforts by South African institutions have been described as fragmented, with a notable lack of comprehensive data on pesticide exposure and related health risks. Existing studies primarily demonstrate levels of exposure but fall short of establishing conclusive links to specific health outcomes. Given the scale and intensity of farming in the country, robust, long-term evidence is essential. (Fuhrimann, pers. comm.., 2025).
Only recently have researchers begun to gather meaningful data, particularly about exposure assessment. These early findings are laying the foundation for future work on health risk analysis (Fuhrimann, pers. comm., 2025). In 2016, epidemiological studies were initiated by UCT’s Centre for Environmental and Occupational Health Research (CEOHR), in partnership with the Swiss Tropical and Public Health Institute. These studies have focused on pesticide biomarkers and their links to neurological and reproductive outcomes in school-aged children in the Western Cape (Chetty-Mhlanga et al. 2021; Fuhrimann et al. 2022). In 2017, researchers from these institutions initiated a cohort study involving 1,000 children to assess long-term health effects. While the results are still pending, early findings from cross-sectional analyses already suggest associations between pesticide exposure and neuro-behavioural changes, as well as endocrine disruption. Additionally, ongoing research involving women farmworkers has revealed preliminary evidence of respiratory health impacts associated with pesticide exposure (Dalvie, pers. comm., 2025).
Many universities in SA have done, or are currently doing, research on the harms linked to pesticides, with UCT’s CEOHR in the School of Public Health, Faculty of Health Sciences, having spearheaded a great deal of it. The universities of Western Cape, Pretoria, Johannesburg, Stellenbosch, and Northwest, and the Cape Peninsula University of Technology have also made important contributions to this field. Also, there has been systematic work undertaken by the Poisons Information Centre at the Red Cross War Memorial Children’s Hospital, which has systematically been documenting accidental or volunteer poisoning cases. Foreign research institutions, such as Wageningen University, the Swiss Federal Institute of Aquatic Science University, the Swiss Tropical and Public Health Institute, and Utrecht University, to name a few, have also been very involved in collaborative research.
Other institutions that one would expect to be carrying out research work in the field of pesticide harm is the South African Medical Research Council,21 which indicated that it is not working in this area
21 The SAMRC focuses on improving the health of the South African population through research, development, and technology transfer, with a particular focus on the top 10 causes of mortality, morbidity, and disability. non-communicable diseases feature among their priority research areas, which one would assume include exposure to chemical contaminants.
(Street, pers. comm., 2025). The Cancer Association of SA (CANSA), a non-profit organisation focused on research, education, and advocacy in “leading SA towards a cancer-free society”, has not been investigating the cancer risks caused by pesticides, despite the flurry of international studies that make that correlation. UCT initiated a research initiative focusing on cancer, but the manager indicated that pesticides were also not a research focus of this initiative (Moodley, pers. comm., 2025). The National Research Foundation (NRF), under the auspices of the Department of Arts, Culture, Science and Technology, has funded pesticide-related harm research. However, attempts to clarify the NRF’s role in relaying research outcomes to the state received no response.
Weak science-policy interface
Most of the studies focusing on human health include broad recommendations aimed at improving policies and raising public awareness to reduce pesticide exposure among vulnerable groups. Many also emphasise the urgent need for further research into the health impacts of EDCs. But research findings are often published without effective communication or engagement with policymakers, leaving regrettable missed opportunities for policy change. Critically lacking, are open channels or formal platforms to facilitate dialogues or collaboration between scientists and government departments. Field researchers frequently lack the resources to initiate or sustain these conversations, as there is a clear need for dedicated mediators to help translate research findings into actionable policy, since there is a noticeable absence of expertise in translating scientific evidence into policyrelevant formats. This siloed approach means that science and policy remain disconnected. A more integrated model – where research is co-designed with government stakeholders – would foster shared ownership of evidence and support the joint development of practical, evidence-based solutions.22 Establishing strong links with these stakeholders would be a game-changer in promoting safer pesticide practices and even the local phasing out of HHPs, as the product of localised Action Plans.
Recent developments
Two important developments were brought to the ACB’s attention in the aftermath of the pesticide Terbufos poisoning of children (Daily Maverick 2024):
• In November 2024, a Ministerial Advisory Committee on Foodborne Illnesses was established, with foodborne pesticide poisoning included in its scope. This committee, appointed by the Minister of Health, will Provide expert advice, guidance, and recommendations to inform evidence-based decision-making. The committee will focus on developing medium- and long-term prevention measures and will include experts in various fields like toxicology, paediatrics, and epidemiology. (DoH 2025)
• Although there was considerable debate around the committee’s name, it was ultimately retained to reflect the role of food as a primary vehicle for pesticide exposure (Rother, 2025). The committee has met four times since its inception in December 2024 and is viewed by some,
22 More extensive government support would greatly assist with also addressing issues relating to ethical clearance, which is required for continuous monitoring. The above mentioned UCT-Swiss Tropical and Public Health Institute researchers faced ethical restrictions that prevented them from monitoring children during the spraying season (December to February), due to limitations imposed by the education department. This restricted access meant critical exposure data could not be collected when pesticide levels were likely at their peak. (Fuhrimann, pers. comm., 2025)
including Dr Stephen (pers. comm., 2025), as a valuable and promising initiative. It indicates that the government is beginning to take the issue of pesticide-related health risks more seriously.
• As of January 2025, pesticide poisoning has been elevated to a category 1 Notifiable Medical Condition (NMC) in SA, according to the National Institute for Communicable Diseases (NICD).23 This designation requires healthcare providers to report cases within 24 hours of diagnosis. However, awareness of this reporting obligation among medical professionals remains limited. Once a case is reported, it prompts an environmental health practitioner to investigate the source of exposure and implement measures to prevent further harm (Stephen, pers. comm., 2025).
Conclusion: Call for compensation and farm input subsidy programme reorientation
The ACB’s research into the body of evidence on the human and environmental harms caused by pesticides, particularly HHPs, confirms that, for over two decades, the South African government has consistently failed to respond to the scientific findings produced by the research community, despite the persistent advocacy efforts of civil society organisations to draw attention to this. This prolonged inaction not only highlights the deep dysfunction at the science–policy interface in SA but also reflects a troubling level of complacency on the part of the government. Meanwhile, the agrochemical industry continues to apply pressure and to exert influence over pesticide registration, manufacture, import, and use processes in SA. Arguably, industry has fully captured these processes.
Considering this, we are compelled to ask:
- What is the constitutional duty of the South African government when it comes to responding to such evidence?
- What responsibility does it bear in protecting its people and environment from harm that is well-documented, preventable, and sustained by outdated legislation and regulatory inertia?
Should the State maintain that it is not wilfully permitting ongoing contamination and environmental degradation, it must demonstrate this by concrete action. Further, there is a need to establish a dedicated compensation and remediation fund, designed to finance the clean-up of pesticidecontaminated sites and compensate for environmental damage and the health impacts suffered by exposed individuals and communities.
SAPToA, which in March 2025 called on experts to present testimonies of harm caused by pesticide exposure, has served as a platform to demand government accountability for its failure to protect citizens from HHPs. It represents a viable vehicle for applying the principle of compensation to cases of pesticide-related harm.
25 Furthermore, SA urgently needs to develop a comprehensive Pesticide Action Plan, which should:
• Repeal Act 36 of 1947 and replace it with legislation in line with our Bill of Rights, Constitution, post-1994 relevant legislation, and international obligations.
• Be aligned with international best practices.
• Push for the phase-out or ban of the most hazardous pesticides.
• Outline a clear roadmap for supporting farmers to transition out of industrial chemical-based food, fibre, and crop production systems to systems that are grounded in agroecological principles, social justice, equity, and job creation.
The Convention on Biological Diversity (CBD)’s Global Biodiversity Framework (GBF) Target 7 calls for governments to reduce pollution risks and the negative impact of pollution from all sources by 2030, to levels that are not harmful to biodiversity and ecosystem functions and services, considering cumulative effects, including:
a. by reducing excess nutrients lost to the environment by at least half, including through more efficient nutrient cycling and use;
b. by reducing the overall risk from pesticides and highly hazardous chemicals by at least half, including through integrated pest management, based on science, taking into account food security and livelihoods; and
c. by preventing, reducing, and working towards eliminating plastic pollution (CBD 2022:10).
Flying in the face of these international commitments to reduce excessive synthetic fertiliser and toxic pesticide use, commercial agriculture in South Africa still receives a VAT zero-rating on chemical farm inputs, with exemptions in place since 1991 (SARS Value-Added Tax Act No. 89 of 1991, Schedule 2). The result has been an increase in import volumes and a 28% increase in fertiliser use per hectare over the past 20 years (UNDP BIOFIN, 2024:20). The zero-rating includes agrochemicals and fertilisers, which constituted over 15% of farm purchases in 2019 at an estimated revenue loss to the state of ZAR 3.2 billion annually (UNDP BIOFIN, 2024:21).
This has produced inefficient consumption and long-term environmental damage, and has not stemmed food price inflation (UNDP SA, 2022:22). As the GBF also highlight, excessive use of synthetic fertilisers and toxic agrochemicals results in pollution through toxic bioaccumulation throughout the food chain, eutrophication in aquatic ecosystems and soil acidification, and an increase in transport emissions resulting from imports (UNDP BIOFIN, 2024:23). Currently there are no policy filters to limit the quantities of chemical farm inputs used.
Reassessing the restructuring of South Africa’s farmer support programmes and transitioning away from input-intensive support models is urgently needed. This must also include a ban on the growing and distributing of genetically modified seeds and associated synthetic agrochemicals, such as glyphosate, 2,4-D, and glufosinate ammonium, which have exacerbated corporate control and capture; dependency; environmental harm, and health risks.
Instead, the State must redirect its resources toward enabling a national agroecological transition. This includes targeted and sustained financial, technical, training, research and institutional, and other resource support to smallholder farmers, who lack the capital of large-scale, export-oriented enterprises, to adopt ecologically sustainable and less toxic farming systems. DALRRD should actively initiate, and support pilot programmes focused on agroecological practices, ensuring that this transition is viable, inclusive, just, and equitable.
“As crude a weapon as the cave man’s club, the chemical barrage has been hurled against the fabric of life - a fabric on the one hand delicate and destructible, on the other miraculously tough and resilient, and capable of striking back in unexpected ways. These extraordinary capacities of life have been ignored by the practitioners of chemical control who have brought to their task no “high-minded orientation,” no humility before the vast forces with which they tamper.”
Rachel Carson, Silent Spring
Annex 1: Classification of HHPs
The United Nations Food and Agriculture Organisation (FAO), in collaboration with the WHO, has established eight criteria for identifying HHPs. These include pesticides and active ingredients – along with their formulations – that are classified as carcinogenic, mutagenic, or toxic to reproduction, as well as those associated with severe or irreversible adverse effects on human health or the environment (WHO, undated).
Various international classification systems are used to assess these chemicals, and many are listed as highly hazardous under global agreements, such as the Rotterdam Convention, the Stockholm Convention, and the Montreal Protocol. SA is a signatory to all these treaties. However, within SA, it remains challenging to determine how many HHPs are currently registered for use. This is largely because different systems of pesticide classification exist across regions and institutions, and, in the very specific case of SA, is due to the absence of a publicly accessible database of registered chemicals. Even government departments do not have direct access to this information, as the proprietary database is controlled by CropLife, the industry’s umbrella body
Act 36 of 1974
SA’s UnPoison network24 in 2023 took the initiative of compiling a comprehensive database of SA’s HHPs registered (UnPoison 2023), and the latest version of the database was updated in February 2025 (UnPoison 2025a, 2025b).25
As stated by UnPoison:
“Access to UnPoison’s HHP database ensures that the South African agricultural sector, policymakers, researchers, and the public are empowered with accurate data and [globally harmonised] classifications to inform our policies with best practices.” (UnPoison 2025a)
UnPoison uniquely combines these systems used by DALRRD into one database and identifies pesticides following global best practice, to ensure harmonisation for governance, trade, and export. The database was developed based on an integration of three different HHP classification systems, namely: the eight criteria of the FAO/ WHO Joint Meeting on Pesticide Management classification
24 UnPoison is a network of civil society organisations “united behind the common goals of effecting legislative reform of agrichemical policy, ensuring effective regulation and monitoring of agrichemical use, transparent registration processes and access to product information, freeing the agricultural sector from industry capture, and ensuring a healthy, clean, just, and safe SA for all of us” (UnPoison.org)
25 https://unpoison.org/wp-content/uploads/2025/02/UnPoison-SA-HHPs-Database-JMPM-criteria_GHS_ECHA_FEBRUARY-2025.. pdf
28 system,26 the Global Harmonized System (GHS) of classification and labelling of chemicals developed by the United Nations (and used by the Department of Labour to classify Hazardous Chemical Agents),27 and an additional classification, the European Chemicals Agency (ECHA) classification,28 used by DALRRD (UnPoison 2025b).
The UnPoison database reports a total of 195 HHPs,29 legally in use in SA, including those restricted for certain uses. These refer to active ingredients, which are then used in hundreds of different brand-name products in SA. Of these,
- 116 HHPs are legally used in SA, despite having been banned in the EU due to their health and environmental risks, rights violations, and harm to the health of farm workers and their families, even though a large proportion of these same pesticides are manufactured in Europe.
- 36 HHPs belong to the most hazardous class, a class known as WHO Group 1a and 1b, which are substances known to have carcinogenic potential for humans, based on human health evidence, and in acute poisonings can cause death.
- To date, only 43 agricultural remedies have been fully banned in SA (DAFF 2017), of which 2930 are HHPs (UnPoison 2025).31
The pesticides in the compendium were assessed against this HHP database for SA.
Annex 2: Controversy around DDT use for malaria control
Dichlorobiphenyl trichloroethane (DDT) was banned for agricultural use in SA in 1987, but it is still authorised for the control of malaria vectors 32 The sheer volume of the scientific literature focusing on DDT and its breakdown product dichlorodiphenyldichloroethylene (DDE)33 warrants a dedicated compendium, which is well beyond the scope of this paper. Nevertheless, we highlight the continued and deeply concerning use of DDT in SA.
While Anopheles funestus, one of the primary malaria vectors of Plasmodium falciparum – the parasite responsible for the most severe form of malaria in Africa – is highly resistant to pyrethroids, it remains extremely susceptible to DDT (UCT 2024). Thus, despite being banned for agricultural use due to well-documented environmental and health risks, DDT continues to be used in SA as part of the Indoor Residual Spraying (IRS) programmes for malaria control by provincial health authorities in Limpopo and KwaZulu-Natal, in combination with pyrethroids such as deltamethrin and cypermethrin.
A 2009 literature review by Eskenazi et al. highlighted a growing body of evidence linking exposure to DDT and DDE with a range of adverse health outcomes, including breast cancer, diabetes, reduced semen quality, spontaneous abortion, and impaired neurodevelopment in children. The study also pointed to a critical gap in understanding the health effects of DDT exposure in communities where it is used for malaria control.
To address this, a research consortium led by the Berkeley School of Public Health at the University of California, in collaboration with South African universities, launched a birth cohort study in 2012, known as the Venda Health Examination of Mothers, Babies and their Environment (VHEMBE) in Limpopo.
The study enrolled pregnant women between 2012 and 2013 and investigated the multiple environmental and human health impacts of DDT and DDE. Among its findings, VHEMBE provided the first evidence that prenatal exposure to DDT and DDE through IRS may negatively impact the immune system of children. The study found that such exposure was associated with a higher prevalence of allergic outcomes – including skin rashes, food allergies, and dust allergies – as well as an increased likelihood of wheezing or chest whistling among children living in IRS-treated homes. Given the high burden of respiratory conditions among African children, such outcomes are deeply concerning.
The VHEMBE cohort has yielded a range of studies, offering valuable insight into the human health consequences of continued DDT use. Notably, women who reported living in homes sprayed with DDT had DDT and DDE serum concentrations five to seven times higher than those who had not. Despite this, DDT use in SA persists.
32 Government Notice No. R. 384 of 25 February 1983.
33 DDE is a persistent organochlorine pesticide, which is the breakdown product of DDT, which forms when DDT is metabolised in the environment
Globally, only 10 countries still rely on DDT for malaria control.34 In contrast, more than 50 countries have shifted toward what some consider safer alternatives, including other classes of insecticides like pyrethroids and carbamates (WHO, 2024).
This situation raises serious questions about the South African Ministry of Health’s failure to act on emerging evidence and its reluctance to phase out DDT in favour of ostensibly less harmful insecticides and more holistic, sustainable approaches to malaria control. Observations during IRS campaigns have further raised concerns about compliance with safety protocols, suggesting that residents are being exposed to DDT at levels that violate both best practice and human rights standards (Chevier, pers. comm. 2025).
Worryingly, the contamination is not confined to IRS-treated homes or even nearby areas. A 2022 study published in Chemosphere found that p,p’-DDE and chlorpyrifos had the highest air concentrations among tested compounds in SA (Veludo et al. 2022), further underscoring the pervasive nature of DDT contamination and its long-lasting threat to public health and the environment.
A key challenge is that once DDT is available within a country, it is often diverted for non-public health uses. In any event, local communities are exposed to DDT residues through multiple pathways, including indoor air, dust, soil, food, and water.
DDT is used in traditional mud homes, meaning that poorer households bear the brunt of exposure to this persistent and harmful chemical. These communities are also often more vulnerable due to pre-existing conditions like poor health and malnutrition. Typically, pyrethroids are used in more modern, hard-built homes.
34 Several African countries, including Botswana, Eswatini, Mozambique, Namibia, South Africa, Zambia, and Zimbabwe, still employ DDT in IRS programs for malaria control. Other African nations, such as Ethiopia, Uganda, and Madagascar, have also been reported to use DDT for malaria control.
A great challenge resides in the fact that the phasing out of DDT might result in an incremental use of pyrethroids, with evidence to suggest these have even more deleterious human health effects.
While there are studies suggesting DDT can act as an endocrine disruptor, pyrethroids are shown by some to be more dangerous to human health. According to Fuhrimann (Pers. comm. 2025), phasing out DDT may lead to increased reliance on pyrethroids, potentially exposing populations to higher levels of toxicity.
Thus, it is clear that the issue of DDT is not straightforward. On the one hand, South African scientific evidence irrevocably points to the lasting environmental damage of DDT, as well as to its deleterious health effects (Chevrier 2025, pers comm.). On the other hand, there is also evidence that human health is far more impacted by the use of pyrethroids (Fuhrimann, pers. comm. 2025), which is the promoted alternative to DDT.
The answer lies in a strategic approach that allows for limited and targeted use of DDT to minimise the risk of mosquito resistance, while simultaneously working towards a gradual and safe transition to less harmful alternatives.
While the call for the government to phase out DDT in favour of safer insecticides and more holistic malaria control strategies is not the central focus of this paper (see Annex 1 for more detail), the need for a progressive phasing out of DDT in favour of less harmful insecticides and more holistic, sustainable approaches to malaria control must be acknowledged in this context, including access to clean water and sanitation.
Beyond DDT, although the production of several organochlorine pesticides (OCPs) such as lindane, heptachlor, aldrin, dieldrin, endrin – and DDT itself – was halted in SA in the 1980s, numerous studies included in the compendium confirm the ongoing presence and persistence of these chemicals in the environment and possibly in the bodies of animals, humans and aquatic lifeforms. Their persistence has resulted in dangerous residual levels and an alarming risk of cancer and other chronic illnesses (Pheiffer et al. 2018). These findings underscore the urgency of phasing out all HHPs – both organophosphates and organochlorides – still in use in the country: the longer we delay action, the greater the cumulative chemical burden on our ecosystems and human bodies.
Annex 3. Long history of demands for overhauling pesticide regulation and management in SA - proof of exhaustion of remedies
Over the past several decades, civil society organisations (CSOs), researchers, and affected communities have repeatedly called on the South African government to reform its outdated and inadequate pesticide regulatory framework.
The advocacy work undertaken to hold DALRRD accountable to the phasing out of HHPs and to have it uphold its commitment to banning HHPs and accelerating the approval of safer alternatives required significant work and allocating resources to review the legal and regulatory intricacies of HHP regulations.
Our demands have included stricter controls on HHPs, improved transparency, independent risk assessments, and greater alignment with international health and environmental standards. Despite ongoing advocacy, meaningful regulatory change has been slow and often reactive, paying lip service to evidence of harm and demands being made for urgent legal reform, is the norm on the part of the state.
In 2024 and 2025, this work was supported by overt calls to have Terbufos banned, in the aftermath of the tragedy that befallen six children, who died after eating snacks bought at a spaza shop in Naledi, Soweto. In June 2025, the Cabinet finally banned Terbufos but stayed silent about the dozens of other HHPs listed for banning.
Below is a brief chronological summary of the numerous appeals and interventions made to the government, urging action to address the outdated institutional and legal frameworks governing pesticide regulation in SA.
October 2019: The Real Thing, via Trevor Simon of Fluxman Attorneys, handed a submission to government for a Law reform on Chemical Remedies in SA (The Real Thing 2019a). The request to the Ministers (Simon 2019) was supported by the expert opinion and analysis of Professor Leslie London on chemical remedies and their regulation (London 2019). This opinion piece offers a comprehensive overview of the known and potential health and environmental risks linked to chemical pesticides. It draws on international reviews and meta-analyses that examine the associations between pesticide exposure and specific types of cancer. As such, the paper stands as one of the most compelling pieces of evidence highlighting the dangerously outdated regulatory framework governing pesticide use in SA.
2021: DALRRD invited comments on the Draft Regulations under the Fertilizers, Farm Feeds and Agricultural Remedies Act 36.
In response, UnPoison, published a series of legal submissions on the Regulations relating to Draft Agrichemical Policy, essentially finding fault with the draft Regulations as retaining the status quo of weak management of pesticides and agricultural remedies, and failing to allow for public participation or transparent access to information in the registration process.
June 2021: On 3 June, for UnPoison, Professor Leslie London submitted a Memorandum titled, Repeal of Colonial and Apartheid Legislation (SALRC Project 149): The Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act No. 36 of 1947), which denounces how the
“Act is a piece of legislation that exclusively promotes the interests of the racist colonial state and the farming sector at the expense of workers and impoverished black people in rural areas,” pointing out that “no amount of amending can make it fit for purpose in a democratic SA.”
(London 2021)
August 2021: UnPoison requested the withdrawal of the draft Regulations,35 and the initiation of a consultative process with civil society and interested and affected parties, with a view to promulgating Regulations that will protect public health and the environment.
September 2021: Having received no response from the department, UnPoison reiterated this request
34 to the Portfolio Committee on Agriculture, Land Reform and Rural Development on 13 September.36 No response was received.
April 2022: The Registrar of Act 36 of 1947, who regulates the use and registration of agrochemicals in SA, stated his intention to phase out a group of chemicals by June 2024. The notice37 said that “an assessment of active ingredients and the formulations has been carried out of CMR (carcinogenic, mutagenic, and reproductive toxicity) categories 1a and 1b of GHS has been carried out at an international level,” and stipulated that “the assessment identified the need to reduce risks to human health associated with such products.”
This gave the agrochemical industry two years to adapt and find alternative solutions.
April 2022: ACB held a two-day colloquium on agrochemicals in SA in Johannesburg on 6-7 April, where various presentations were made on the obsolete legislative and institutional frameworks governing pesticides in SA, effectively resulting in a complete control of this sector by the industry, with CropLife de facto handling the database of SA’s registered chemical “remedies”.
December 2022: On 8 December, a legal letter was issued by attorney Angela Andrews on behalf of UnPoison requesting the Registrar to ensure that the phase-out process was transparent and
37 Note that the previous hyperlinks to the DALRRD page are all broken, such as this link: https://www.dalrrd.gov.za/doaDev/ sideMenu/ActNo36_1947/Phase Out of Active Ingredients and Formulations that meet the criteria of carcinogesity.pdf or this link: http://www.old.dalrrd.gov.za/doaDev/sideMenu/ActNo36_1947/Phase Out of Active Ingredients and Formulations that meet the criteria of carcinogesity.pdf. A search of the term “HHP” on the DALRRD website yields no result.
procedurally fair, and that the constitutional rights of interested and affected parties would be protected in the process.38 The letter denounced the vagueness of the notice and its failure to include the list of chemicals, or the methodology used for identifying them, or a detailed plan with a timeframe to phase the chemicals out:
“The group of chemicals referred to in the Registrar’s letter included several highly hazardous chemicals, but [was] by no means a comprehensive list of highly hazardous agricultural chemicals and pesticides, or even a list of those chemicals currently banned for use in agriculture in the USA and European Union,” i.e., those that fall into WHO 1a and 1b.
August 2023: On 21 August, UnPoison called on the state to urgently intervene by taking prompt action and highlighting that the initial list of HHPs proposed for banning by the Registrar was a very different group of chemicals to the 36 highly hazardous pesticides that fall into the WHO group 1a and 1b that are registered and still legally in use in SA.39
UnPoison noted that the chemicals on the Registrar’s list belonged to an entirely different classification, CMR 1a and 1b of the GHS. Of the 29 chemicals on the Registrar’s list, only four fall into criteria 1 WHO group 1a and 1b, which means that 32 of the 36 WHO 1a and 1b HHPs were not included in this proposed ban list. UnPoison published SA’s List of Highly Hazardous Pesticides as part of this communication, to put the record straight in terms of what constitutes HHPs in SA. (After the list was corrected on 23 August, it was further updated in February 2025.)40
June 2023: Since 2019 and continuing to the present, the Woman on Farms Project, supported by UnPoison, has run a Double Standards campaign. The release of a chilling video was part of sharing the stories of victims of pesticide exposure.41 This petition alerts to the issue of pesticide poisonings being grossly under-reported due to fear of job loss or loss of income by farmworkers, as well as to the issue of inadequate reporting process for poisonings or knowledge thereof by health practitioners and the public.
April 2024: DALRRD initiated an exemption process, just two months before the first group of HHPs was meant to be phased out, as per DALRRD’s 2022 phase-out notice.
September 2024: At the 57th Human Rights Council Session in Geneva, on 17 September, the UN Special Rapporteur on Toxics and Human Rights, Dr Marcus Orellana, presented his report on the implications for human rights of the environmentally sound management and disposal of hazardous substances and wastes, which was compiled after he visited SA in June-July 2023.42
His findings encapsulated the reality of what the agrochemical load in SA represents:
[T]he [persistence of]the crude legacy of pre-1994 environmental racism persists, exacerbated by outdated laws and inadequate enforcement. The negative impacts of toxic pollution from mining, coal-fired power plants, greenhouse gas-intensive projects, landfills, pesticides, and other hazardous substances disproportionately affect marginalized and low-income communities along racial lines.
He found that pesticide-related deaths in SA were caused by lapses in regulations and enforcement and warned of the outsize power the chemical industry has in regulatory decision-making.
Orellana’s recommendations to the government were as follows:
a. Prohibit aerial spraying;
b. Take decisive action to ensure the environmentally sound management and disposal of pesticide containers and obsolete stockpiles, including traceability mechanisms;
c. Promote sustainable agricultural practices and small farming;
d. Ban imports of pesticides that are banned in their country of origin;
e. Ensure access to sanitation services in informal settlements to eliminate demand for street pesticides;
f. Outline clear mechanisms for public participation in pesticide registration processes;
g. Find alternative solutions to toxicological testing requirements to tackle the issue of the backlogs in State toxicology centres;
h. Enhance labelling requirements to include specifications for buffer zones and non-target areas;
i. Initiate a training programme for farm workers on:
- Their rights and obligations under the law;
- The dangers of pesticide misuse;
- Safe handling of pesticides;
- How to read labels;
j. Make pesticide labels available in more languages, particularly those accessible to farm workers; k. Ensure access to adequate health care for farm workers.
Although the state responded to his report, it did not acknowledge Orellana’s findings in this regard or show any urgency to remedy the regulatory problems he identified.
November 2024: ACB supported SAPToA in addressing a petition to the government on 22 November, titled: Reckless endangerment: hold South African government and chemical industry to account for deaths and serious illnesses from toxic pesticides on the farm and in food, calling for the banning of Terbufos with immediate effect, and the institution of mechanisms for banning all HHPs within three months.43 This petition denounced the misleading decree by President Ramaphosa at the time, requiring that all spaza shops re-register within 21 days. Such a response, the petition argued, distracted
attention from the real issue, the presence of HHPs on the South African market, (and the failure to regulate their sale and use), and instead just placed the blame on spaza shops, the lifeblood of most communities in SA, fanning xenophobic flames.
December 2024: ACB, on behalf of a group of organisations, academics, and unions, sent a letter of demand to the Minister of Agriculture, Mr John Steenhuisen, on 5 December, requiring him to
immediately ban the lethal chemical that has been implicated in the deaths of six children – Terbufos.44 In the 16-page letter of demand, a history of ongoing regulatory failure and commercial conflicts of interest in the governance of hazardous substances is laid out, showing how these have resulted in highly toxic, restricted chemicals ending up in domestic settings and informal food outlets. The letter brought forth compelling evidence of harm linked to the use of pesticides in SA. The petition further demanded that the Minister ban all HHPs that are already banned in the EU within six months, putting him on notice to implement these actions or face legal action within 21 days.
December 2024: Industry derogations requests were initiated.
February 2025: On 27 February, the ACB submitted substantive objections to the government’s attempt to backtrack on phasing out HHPS despite its prior commitment, through the derogation process, which was demonstrated as spurious and potentially unlawful, and thus providing avenues for the persistent and sustained use of HHPs based on the interests of the agrochemical industry.45
March 2025: UnPoison echoed these concerns on 6 March, calling on DALRRD to immediately halt and review the flawed derogation process. A legal analysis conducted by UnPoison also highlighted the same serious legal and procedural flaws in the DALRRD’s guidelines for pesticide derogations, which it denounced as lacking “scientific integrity, legal compliance, and transparency”.46
They denounced the flood of 28 derogations published for public comment in December, putting an unfair burden on civil society to undertake an in-depth scientific assessment of the derogation requests.
Both the ACB and UnPoison denounced the mockery made of the request for exemptions made by industry players, including UPL SA, Enviro Biochem, Kwelanga SA, Rainbow Agrosciences, AECI, and Villa Crop Protection, by way of the publication of risk assessments (RAs) in all submissions, in support of why glufosinate ammonium (GLA) should not be phased out as an HHP. Adding insult to injury, the companies mostly used the same risk assessment report, with all 12 reports copying and pasting the same fraught arguments developed by one company, with only minor editorial differences. The crux of the argument of these RAs was that if a chemical is handled ‘safely’, it will not be a risk The ACB highlighted that these products, however, have differing co-formulants and active ingredient ratios, and that they in no way can be construed as similar products.
UnPoison flagged that this approach raises concerns about the integrity of the risk assessments, and whether the companies seemingly coordinated amongst each other to have their risk assessments conducted as a batch, rather than conducting independent risk assessments.
It further denounced a fraught derogation process based on the very poor derogation guidelines issued by the department, which clearly seem to serve the interests of the industry,47 and called for the
47 UnPoison inventoried many shortcomings in these derogations guidelines. Among the most striking loopholes are the lack of adequate justification required by industry in their requests for derogations; the fact that there is no legitimate ground to grand exceptionality, with reported cases of industry producing alleged counter evidence on the hazardousness of the pesticides for which they want derogations, despite the solid evidence produced by regulatory authorities in Europe; and the fact that companies seeking derogations are not required to disclose all chemical components of their formulations which undermines any transparency requirement.
full legal and procedural revisions to ensure that derogations are only granted when truly necessary – and never for highly hazardous pesticides already identified as too dangerous.
(UnPoison 2025c)
ACB demands submitted to the Government regarding HHPs
In its objection to the derogation process, ACB made the following demands to the registrar, which signal the current state of play on the issue of HHPs in SA today:
• Reject these applications, prioritising human and environmental health over business interests and false claims, and prioritising alternatives to chemical-based agriculture, thus setting the tone for the future of agricultural production in SA.
• Maintain its commitments to phase out and ban HHPs. Linked to this, the criteria used for regulatory purposes must be made available, including how chemicals are identified for phase-out and related periods.
• Make available information regarding assessing the viability of using alternative products/ techniques, as the United Nations Special Rapporteur recommends.48
• Urgently repeal Act 36 and its regulations. The incremental, contradictory, and delayed reforms that have taken place, including the 2023 Regulations, undermine the Constitution and the 2010 Pesticide Management Policy.
• Begin an expedited, open, and transparent process for a comprehensive and complete overhaul of the legislative framework governing agricultural remedies to reflect the realities of SA.
• As part of a complete repeal and restructuring of the pesticide regulatory framework in SA, an independent body should be established, made up of multidisciplinary experts, to make decisions regarding pesticide use, registration, renewal, etc. Currently, the decision-making structure is inherently unconstitutional as it does not guarantee fair administrative justice and decision-making.
• Ensure the smooth transition towards a socially just and ecologically sustainable food system, which considers SA’s socio-economic, cultural, and ecological realities and shifts its current wholly inequitable food system towards one that recognises and aligns the agricultural and food system in the country with the rights enshrined in the South African Constitution.
March 2025: SAPToA put the government on trial in the court of public opinion, in Stellenbosch in the Western Cape on 22 and 23 March, for gross dereliction of its constitutional duties to protect the right to life.49 Farm workers and community members shared harrowing testimonies of how the government has persistently failed to protect them and their families, and low-resource communities from the catastrophic consequences of exposure to HHPs. The tribunal was adjudicated by a panel of three highly influential South African women – Judge Navi Pillay, Dr Sophia Kisting-Cairncross, and Human Rights Commissioner Philile Ntuli.
The government did not respond an invitation to attend the Tribunal, but CropLife SA, now the customary mouthpiece of the Government when it comes to Agrotoxins, put out a press release, days before the Tribunal Key Messages on SAPToA court of public opinion.
When it comes to HHPs, it is important to note that the Government has already committed to phasing out all HHPs by 2035, with many substances of concern already
being phased out as of 1 June 2024, so the process is well underway. The reason why the date of 2035 has been chosen is that removing HHPs cannot just happen overnight. … To phase out certain products, growers must have alternative solutions to protect their crops, but developing these solutions also takes time because we must ensure that they are effective and safe, and also able to be placed on the market.”
(CropLife 2025)50
This communication is an attempt to delegitimise the Tribunal and water down the dire concerns raised by civil society and the scientific community, serving as a brutal dismissal of the sense of urgency to have HHPs banned by justifying that those identified will only be effectively phased out 10 years from now, in 2035, on the back of the common argument that farmers need those pesticides. However, we know that this same industry has locked our farmers into using these chemicals. Ironically, it points to the lead time needed to develop safe alternatives when the existing products are unsafe in Europe.
50 https://t2m.io/CropLife
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