Who is to pay Brazil’s loss by ANVISA?

It has been a long time since the productive sector has been fighting for unlocking the registration system of agrochemicals in Brazil. Unlike what many may think, this is about a struggle for sustainability of agricultural business in the country. After all, in a tropical climate country like Brazil it is impossible to do large scale farming without pesticides. The delay in registering pesticides takes the competitiveness of the agricultural business and undermines the sustainability of Brazilian agriculture.

The continuous usage of a single insecticide product leads to the isolation of resistant insects in the field, which has been reported to happen in five years and in some cases up to three years. This means that the farmer may even increase the dosage of the product, but the inevitable result is that the insect is no longer susceptible to the defensive, and the only way to control it is through another product which shows efficiency in controlling the pests.

In practice, to prevent from pests getting resistant, the companies themselves rotate products in the market, but once this is no new products come up or insects prevail, it will cause major damages in crops.

In Brazil, the registration of a new product in line for analysis takes, according to industry data, about 39 months, in other words a little more than three years. It would be a time limit compared to data deadline for insects to acquire resistance.

According to IPEA (Institute of Applied Economic Research) data, published in the Boletim Radar (Bulletin of Radar) in June 2012, there are now 1041 cases in the agrochemical registry system of Brazil. And according to IPEA, ANVISA (The National Health Surveillance Agency) is an organ of the government whose processes take the longest and assesses only 150 cases per year. Once said that, it is crystal clear that the last process in line will only be analyzed after seven years.

The delay in registering pesticides has discouraged companies to research new, more efficient and less toxic products. Because of this delay, they claim that when they find a new product to control a particular pest, it may not exist any longer.

After all, here in Brazil the registering has taken an average of five years and the cost is very high, whereas in other countries it takes a maximum of two years. And what is even more complicated: in Brazil the registration of a generic product takes longer than a new one. Why is that?

For all these reasons, we are convinced that if producers depend on pesticide registration system, and in particular on ANVISA, they will control pests with anything but high-tech products developed for that purpose. It is absurd producers have to live with this reality.

We know that ANVISA technicians are competent and dedicated people and that they are not the problem, but the managers who are in charge of the entire inefficient system and have staying power of that agency for simply not working. The ideological bias is clear, just see who the main character of the film ‘O veneno está na mesa’ (‘The poison is on the table’) is; Dr. Leticia Rodrigues, the manager responsible for registering agrochemicals, exposing her repulsion for the products that she registers. This is not the role of a public manager, but militants from NGOs.

To prove that there is a loose end in agility of registering pesticides, we did a study of Pesticides Decree (Decree 4074/2002) and here I say out and clear that the number of process in the system registration analysis is not efficient due to unwillingness to do so. Just see what the Article 25-A of the Act says: 'The special temporary registration for technical products, premixes, pesticides and related whose active ingredients have already been registered in Brazil will be granted automatically by the registration agency, upon enrollment in computer system integrated to Information System to Agrochemicals - SIA'. But for general indignation, there is no integrated information system up to date, and a temporary record cannot be done automatically. No one is complying with the decree! Not to mention the fact that according to the decree, 120 days is the deadline for analyzing each case.

When pressed, managers say the problem is the lack of professionals, but it is clear that it is a lack of professionalism on their part. And this ideology mixed with incompetence is costing dearly in the end. The clearest case is soy rust one. We have made a pilgrimage on the terrace since April 2012; we gathered Embrapa technical note, economic studies and technical meetings, and proved it to the Government: we have only one active ingredient that controls the main disease of Brazilian agribusiness, and this ingredient is losing effectiveness each year. Our poll was simple; it was to give priority to the analysis of new products in line. But nothing worked, and ANVISA kept ignoring it.

We had political meetings, took the experts to the field and filed everything. Soon, the decision of the Casa Civil (Civil House is the body directly linked to the Chief Executive of a federation or federal unit) came: 'registration agencies must give priority to new products for controlling of soybean rust.' ANVISA promptly replied that by the end of the year of 2012 they would have already analyzed the product.

It is March 2013 already; yet, nothing has happened so far. And at this point it no longer seems an absurd for the Technical Advisory Committee of Pesticides of December 2012 meeting - CTA was extended the deadline for registering of a new product for rust control to the 1st half of 2013.

Do you know how many pretty pennies this incompetence has cost to producers of the main agricultural commodity in the country and how much the government has lot in revenue? Nothing less than 2.5 billion dollars a year! The problem has worsened dramatically in the last two seasons.

According to the field surveys in 2011/2012 season, by technicians, rust reduced soybean productivity in Mato Grosso in two bags per hectare. This season was five bags per hectare, more than double as much. Now considering that the state plants eight million hectares, we are talking about nothing less than 40 million bags.

If we consider an average price of US$ 25 dollars per bag of soybean, rust damage has reached a figure of US$ 1.0 billion dollars to producers this season. It gets worse every year. According to the technicians, if we add the implementation costs of products which no longer control the rust, the value will reach US$ 1.5 billion dollars to producers, the state and the country.

We cannot afford to pay this bill alone. We are going to go back to Brasilia and go to Casa Civil in order to talk to the President, Dilma, and tell her this bill is no longer on us; it's time to give this bill to ANVISA.