Costa Rica “Legislation has helped to promote sustainable agriculture, including Agroecology. For example, Payments for Ecosystem Services schemes have been implemented for practices such as agroforestry. Criteria have been developed to certify coffee growers that are carbon neutral. The legal/policy approach has benefited, however, Agroecology needs to be up-scaled and extended further.” H.E. Minister Arauz-Cavallini (Costa Rica), 2015, International Symposium on Agroecology, FAO
Selling organic vegetables in a market in Thies, Senegal. PAN Africa
also fails to recognise the existence of safer alternatives. Substitution One improvement on this is the substitution approach which has begun to appear in legislation in some countries. At its most basic level, this approach requires the substitution of a hazardous pesticide with a less hazardous one. Broadly, if there is a less toxic product that is available and
effective, then it should be registered/used instead of a more toxic product. However this ‘limited’ or ‘chemical’ substitution approach only considers replacing one pesticide with another, an approach which this book has argued is not in the best interests of farmers and society. It is an incomplete application of the substitution principle, which has been defined by the Swedish Chemical Agency, Kemi, as:353 “If risks to the environment and human health and safety can be reduced by replacing a chemical substance or product either by another substance or by some non-chemical technology, then this replacement should take place.” Kemi expanded on this by adding: “All decisions on such substitutions should be based on the best available evidence. This evidence can be sufficient to warrant a substitution even if quantitative risk estimates cannot be made.” The European Union Pesticide regulation for authorizing agricultural pesticides, 1107/2009,354 does partially address this issue. Article 50 requires that, for pesticides which have been identified as of some concern (List of Candidates for Substitution), each member state must evaluate in a comparative assessment if they can be replaced (substituted) by safer chemical and non-chemical control or prevention methods. Most of the substances on the list have met two of three criteria for persistence, bioaccumulation, and toxicity; there are also other criteria for listing, including neurotoxicity, immunotoxicity, carcinogenicity, reproductive toxicity or endocrine disruption. However, the regulation still starts with the premise that pesticides be registered unless they trigger certain thresholds of toxicity; and still weighs on the side of pesticides by requirements that the alternatives must be “significantly safer” and not present “unacceptable” economic or
353 Kemi. 2007. The Substitution Principle. Report Nr 8/07. Swedish Chemicals Agency, Stockholm. 354 Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the
placing of plant protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC.
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