Based on my complaint AR-MICI004-2012 (https://www.iadb.org/es/mici) Argentina - Agrifood Health and Quality Management Program (CCLIP), which forced Senasa to update the manuals Regarding agricultural practices, to date nothing has changed with respect to Argentine regulations, much less Senasa's resolutions.
The project is rude
The project in a state of consultation is such rudeness, from the beginning, citing Decrees of 1996 of absolute nullity, as the same Resolution No. 167 that introduces the technological package through the window, to stay and kill everything alive, in silence , without comptroller, with provincial feudal laws and ordinances that horrify the most naive student of law.
And it is rude, because it pretends that all readers are stupid or distracted, that we do not know how to distinguish when the wording is imposed and is not born from an authority with sufficient knowledge, respecting the regulations as a whole, with a scientific basis, and not a copy and sticking with other resolutions just as inefficient, just as inconsistent, just as illegal.
Coming to article 4 of the project, the reading becomes an ignominy: Continue applying the acute toxicological classification established according to the criteria of the World Health Organization (WHO) of 2009, after a decade of studies and scientific tests that demonstrate the toxicity of the pesticides in question, knowing that this classification is obsolete, not knowing that the WHO only suggests it as a "guide" to take into account and not as "the rule to follow."
It's easier to extend your permit than to take serious action
But nobody is interested in upgrading the regulations, it is easier to extend the permission to use the new DDT called glyphosate, than to accept that "In general, - as I said in my last published article - the results suggest that exposure to low doses of Chemical mixing could induce liver damage as a result of the combination of different toxic mechanisms. Something that we have been denouncing for decades in Argentina, regarding the synergy of the cocktails that are applied in the fields and that are prescribed by agronomists, ignoring their effects on human health and diversity as a whole. " (https://www.alainet.org/es/articulo/193736) “Glyphosate: cocktail of chemicals even at “safe” levels can cause liver damage“.
Proof of this is that there is no doctor for epidemiological studies, for work-related illnesses and accidents, toxicologists and biochemists in any key position at Senasa, they are all either veterinarians or agronomists, neophytes in terms of synergies of the mixtures used in the Argentine countryside.
For this reason, Senasa has no moral or scientific authority for any decision and / or drafting of resolutions on pesticides, biocides, poisons, toxins to which we are exposed. Nor do they ask independent scientists for help in their supine ignorance before making decisions that affect us all. Otherwise, it would be an obscenity to continue exposing human life and biodiversity, to powerful biocides, knowing their effects. Proof of this is that the bill reads: "That the Directorate of Legal Affairs of this National Service has taken the appropriate intervention, finding no legal objections to formulate." What objection can they make when they were able to add their signature to the file of Resolution No. 167 of 1996, three days after its approval, without blushing.
Public consultation is only the search to legitimize decisions taken in advance that only favor one sector. Minor crops use the same herbicide, as a desiccant in food and as a pesticide in so-called major crops. What is the difference? It is the ANMAT that should worry about the foods that mostly contain chemical remains, it is Consumer Defense who should control the non-existent labels and denounce the deception to which the consumer is exposed in the gondolas.
The health of all Argentines in danger
We must not leave this issue where the health of Argentines is in danger, in the hands of Senasa.
I demand as a citizen the elevation to the National Congress of an urgent draft of National Law and / or Framework, according to current scientific advances, long-term tests and reference to cases such as the 400 lawsuits where the case of “DeWayne Johnson vs / Monsanto Company ET AL s / Product Liability ”N ° CGC16550128 (https://law.justia.com/cases/federal/district-courts/california/candce/3:2016cv01244/296571/52/) on first to be heard by a judge in San Francisco USA.
There are an estimated 4000 lawsuits of that tenor, whose actors are non-Hodgkin cancer patients due to exposure to the Monsanto product, which are part of the court case (https://usrtk.org/pesticides/mdl-monsanto-glyphosate-cancer -case-key-documents-analysis /) with conclusive and unobjectionable evidence. The cases have been combined for handling as multidistrict litigation (MDL) under Judge Vince Chhabria, the lead case being 3: 16-md-02741-VC. California law allows expedited proceedings when a party faces imminent death, and that is the case with Johnson who used that law to go to trial.
In 1986, voters in California, USA passed an initiative to address growing concerns about exposure to toxic chemicals. Proposition 65 requires the release of chemicals known to cause cancer or birth defects. This list must be updated once a year and has grown to 800 chemical names since 1987. Following the classification of glyphosate as a probable human carcinogen by the International Agency for Research on Cancer (IARC), the research arm of the World Organization of the Health (WHO), in May 2015 the OEHHA added the chemical to the state's Proposition 65 list.The decision was finalized in early 2017, making California the first state to take this step to protect its citizens, even their pets exposed to the same poisons applied in gardens, parks and squares. The day Senasa adheres to an identical regulation, we will begin to believe that the body really works.
Should not be approved
While that doesn't happen, my response to your public query is:It should not be approved.
Consultation project No. 322 on minor products is sterile, futile, and unconstitutional from beginning to end (art 41 CN) It has no scientific basis, it refers to analogies of other resolutions and decrees in force, with manifest legal defects and lacking in all empirical reality. Absolute current scientific ignorance and legal ignorance of comparative law and jurisprudence that leads them to the error of deceiving the public in this rude way.
* Dr. Vizcay Gomez Graciela - Lawyer (UBA) -Scribana (UNR-UCA) - Zero Biocides - Buenos Aires- Argentina
Source: Villa Ocampo, Santa Fe, Argentina