Dear SOFA team,
Please see my submission below.
Use of dangerous agrochemicals: The increased use of dangerous agrochemicals in Uganda presents adverse effects on environmental safety and human health. Uganda is required to update and register agricultural chemicals as mandated under the legal framework- Section 4 of Agricultural Chemicals (Control) Act, 2007 and as according to the updated register (As of October, 2021), agrochemicals containing mancozeb as an active ingredient are listed and still traded to date.
The increased use of and trade in highly hazardous agro-chemicals is partly attributed to the absence of the Regulations to facilitate enforcement of the legal framework, porous borders that open up to the sell and trade of dangerous agrochemicals. Worse still, small scale farmers lack knowledge on the application, dangers of agrochemicals for instance, a study in Uganda showed that 24.5% of farmers were not aware of any health risks of spraying tomatoes close to harvest time, almost 50% of farmers (45.8%) sprayed their tomatoes less than a week to harvest time, 29.2% sprayed their tomatoes on harvesting, with intentions to extend the shelf-life while 50% did so to attract consumers.[1] Another study conducted in 2015 shows how farmers sprayed tomatoes 6 times beyond the manufacturer’s recommended dosage and harvested these tomatoes 2–3 days after the last spraying session compared to the recommended pre-harvest interval of 4–7 days.[2]
The continuous use of agrochemicals in the agrifood system by small holder farmers undermines the achievement of Sustainable Development Goals especially, eradicating extreme poverty for all people everywhere. This is because most of the would be profit is spent in procuring and applying agrochemicals.
With this in consideration, the SOFA report should demystify the double standards in the export and trade in and use of dangerous agrochemicals in developing and low income countries. In December 2020, the E.U parliament classified mancozeb as toxic for reproductive category 1B and also it concluded that non-dietary exposure to mancozeb cannot be considered negligible. Subsequently, the approval of active substance mancozeb was not renewed under Article 1.
It is our considered submission that whereas the use of agro-inputs in the food system is important for food productivity, the negative impacts outweigh the positives with reference to the hidden cost. Agrochemicals are leading to illnesses among farmers, cause climate crisis, unsafe food among other costs. The report should demystify the dangers of agrochemical use and suggest the sustainable agriculture practices like agroecology for small scale farmers. It should reflect the urgent call for the implementing and developing legal frameworks to promote sustainable agrifood systems.
Land: There is a lot of speculation on sustainable land use in Uganda. A large percentage of land in Uganda is privately owned and hence many small scale farmers have limited access to land. This has created a growing trend of land fragmentation and accessing land for rent. This has created an environment of human rights violations over land matters, low productivity. Renting costs are not considered in determining the true cost of food. On the same note, despite Uganda having a well streamlined legal framework on land matters, many people especially the vulnerable/rural small scale farmers still face violations in form of destruction of food, and illegal evictions by large investors for plantations hence leaving many landless and/or with small portions of land for agriculture.
To comprehensively protect farmers and their interests in land, decision makers should monitor and implement land laws and curb any sort of violations over land. Decision makers should also develop policies to promote issuance of premium prices/incentivize small scale agrifood producers.
Mr. LUBEGA JONATHAN