In December, the federal Department of Agriculture, Water and the Environment released the draft report of an indpendent panel reviewing the regulatory framework for agricultural
and veterinary (agvet) chemicals.

In 2020, AFSA collaborated on submissions to the consultation informing the review, and last Friday attended the review meeting on the draft report. AFSA’s intervention advocated for a regulatory approach that encourages agroecological food systems and the protection of biodiversity over the vested interests of corporations and industrial farming.

Read AFSA’s full intervention below:

Independent Review of the Agvet Chemical Regulatory Framework Consultation Meeting – 12 Feb 2021. 

I join you all today from the unceded lands of the Dja Dja Wurrung in the central highlands of Victoria, where I pay my respects to elders past, present, and emerging. I would like to start my comments by noting the absence of any mention of Indigenous peoples in the draft report – there is no acknowledgment that decisions are being made about the regulation of chemical use on Aboriginal land, and no apparent consultation with First Peoples and their organisations. AFSA would welcome information on whether the Panel has sought the views of Indigenous peoples as part of its review? 

The routine use of pesticides and veterinary chemicals in farming is a relatively recent phenomenon, arising during the Green Revolution from the 1950s onwards, and yet it is now such accepted practice that a review such as this does not even ask whether we should continue our rate of chemical use, but instead asks how to make chemicals more readily accessible. And yet this is quite out of step with discourses taking place in global governance processes, which makes sense given I could find only one reference to the United Nations in the 279 page draft report – there appears to have been no review of international advice on the use of agvet chemicals.  

Let me survey some of this advice:  

In 2019, the FAO released the State of the World’s Biodiversity for Food & Agriculture Report, which highlights the problems of ‘pollution and overuse of external inputs,’ and calls for improved monitoring of recognised threats to biodiversity for food and agriculture, of which agvet chemicals are one such threat.  

The 2019 report by the High Level Panel of Experts on Agroecological and Other Innovative Approaches for sustainable agriculture calls for ‘strengthening the regulations on the use of chemicals harmful for human health and the environment in agriculture and food systems, promoting alternatives to their use and rewarding practices that produce without them.’ 

In that same year, IPBES released The Global Assessment Report on Biodiversity & Ecosystem Servicesproviding evidence that ‘Harmful economic incentives and policies associated with unsustainable practices in […] agriculture (including fertilizer and pesticide use), [and] livestock management […] are often associated with land-use change and overexploitation of natural resources[…]. Vested interests may oppose the removal of subsidies or the introduction of other policies. Yet policy reforms to deal with such causes of environmental harm offer the potential to both conserve nature and provide economic benefits, including when policies are based on more and better understanding of the multiple values of nature’s contributions. 

I would like to especially highlight the point about vested interests, as we note that CropLife is cited no less than 14 times in the report, and represents the interests of some of the world’s biggest agvet chemical manufacturers. Can there be a more obviously vested interest than chemical companies advising an ‘independent review’ on the regulation of chemicals? As the world faces unprecedented losses of biodiversity, CropLife’s website tells us they are here to help wage a war on nature. I quote: ‘food crops compete with up to 30,000 species of weeds, 3,000 species of nematodes (microscopic worms) and 10,000 species of plant-eating insects, as well as viruses, fungi, mites and mice. Against these foes, as well as an increasingly volatile climate, our farmers are tasked with growing enough food, feed and fibre to serve a booming population. They need all the help they can get.’ End quote – and CropLife are here to help – by selling them biodiversity-destroying solutions. When we read the Panel’s enthusiasm for more ‘co-regulation’ with industry, the fox in the henhouse comes strongly to mind.  

The UN’s Convention on Biological Diversity is currently drafting a post-2020 Global Biodiversity Framework to replace the failed Aichi Biodiversity Targets. You can see the Zero Draft on the CBD website, where draft Target 6 calls for the reduction of biocides, and Target 17 aims to ‘by 2030, redirect, repurpose, reform or eliminate incentives harmful for biodiversity, including [X] reduction in the most harmful subsidies, ensuring that incentives, including public and private economic and regulatory incentives, are either positive or neutral for biodiversity’. Australia has committed to the earlier Aichi Targets and now the GBF process, but we see little awareness of these aims in the recommendations in this review.  

I will finish with the use of antimicrobials in livestock production, and the rise of antimicrobial resistance. We welcome the acknowledgement of the issue of AMR in the report, and we also welcome Recommendation 19 to improve surveillance of chemical use. We urge the Panel to go further specifically in regards to the use of antimicrobials and require more thorough reporting of the use of antibiotics. I myself am a livestock farmer, so I am subject to reporting requirements, and so am aware that we only have to report any medicines administered that would not meet a withholding period when we send animals to the abattoir.  

The FAO’s Committee on Agriculture has urged countries ‘to take action to continue the development of sustainable food production systems taking into consideration their social, economic and environmental dimensions, in order to reduce the risk of diseases, prevent the unnecessary use of antimicrobials, including the phasing out of antimicrobials as growth promoters  and promote good animal husbandry management, biosecurity and biosafety.’ We urge the Panel to include this recommendation to phase out antimicrobials as growth promoters in its advice to Government. 

Finally, the UN Committee on World Food Security last week released its draft Voluntary Guidelines on Agroecological and Other Innovative Approaches for Sustainable AgricultureIn it, the CFS reminds us that ‘Over 1.3 billion people rely on degrading agricultural land, and globally, 33% of soil is moderately to highly degraded due to erosion, nutrient depletion, acidification, salinization, compaction and chemical pollution. Ruptures to the interlinkages between human and planetary health compromise the well-being of both biodiversity and people.’  

The Draft Report makes frequent mention of ‘social licence’ and the need to educate the community about the importance of agvet chemicals. AFSA respectfully submits that the public and the global scientific community are pretty well across the dangers of over-use of chemicals, and the inherent vulnerabilities of monocultures of crops or animals. There are major problems in the very way we farm – farming against nature rather than with it. So long as CropLife is a key source of information on how best to manage the risks of chemicals in agriculture, we will never address these deeper issues so well understood by the various governing bodies of the UN, and so long understood by the Original Owners of this land.  

Published On: 15 February, 2021Categories: Legal Defence Fund, News, Submissions