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AFRICA MUST BAN GLYPHOSATE NOW! August 2019 ALLIANCE FOR FOOD SOVEREIGNTY IN AFRICA

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Page 1: AFRICA MUST BAN GLYPHOSATE... August 2019 ALLIANCE FOR FOOD SOVEREIGNTY IN AFRICA. The African Centre for Biodiversity (previously ‘Biosafety‘) was established in 2003 and registered

ALLIANCE FOR FOOD SOVEREIGNTY IN AFRICA

AFRICA MUST BAN GLYPHOSATE NOW!PO Box 29170, Melville 2109, South Africa

www.acbio.org.za

P. O Box 571 , Kampala, Ugandawww.afsafrica.org

August 2019

ALLIANCE FOR FOOD SOVEREIGNTY IN AFRICA

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The African Centre for Biodiversity (previously ‘Biosafety‘) was established in 2003 and registered in 2004. ACB carries out research and analysis, learning and exchange, capacity and movement building, and advocacy to widen awareness, catalyse collective action and influence decision-making on issues of biosafety, genetic modification (GM) and new technologies, seed laws, farmer seed systems, agricultural biodiversity, agroecology, corporate expansion in African agriculture, and food sovereignty in Africa.

www.acbio.org.za PO Box 29170, Melville 2109, Johannesburg, South AfricaTel: +27 (0)11 486 1156

The Alliance for Food Sovereignty in Africa (AFSA) is a broad alliance of different civil society actors that are part of the struggle for food sovereignty and agroecology in Africa. These include: African farmers’ organisations, African NGO networks, specialist African NGOs, consumer movements in Africa, international organisations which support the stance of AFSA, and individuals. Its members represent smallholder farmers, pastoralists, hunter/gatherers, indigenous peoples, faith based institutions, and environmentalists from across Africa. It is a network of networks, currently with 30 active members.

P. O Box 571 , Kampala, Ugandawww.afsafrica.org

This publication is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License

This publication may be shared without modification for non-commercial use provided the African Centre for Biodiversity is acknowledged as the source. Prior written agreement is necessary for any commercial use of material or data derived from this publication.

August 2019

Cover image: Helen DayCopy editor: Liz SpargDesign layout and graphics: Adam Rumball, Sharkbuoys Designs, Johannesburg

AcknowledgementsWe acknowledge the research and writing contributions of Sasha Mentz-Lagrange and contributions by Lim Li Ching, Eva Sirinathsinghji and Mariam Mayet. We are grateful to various donors for their loyal support.

The views and opinions expressed in this report are those of the ACB and do not necessarily reflect the official policy or position of the donors.

92 IPES Food. 2016. From uniformity to diversity: A paradigm shift from industrial agriculture to diversified agroecological systems. http://www.ipes-food.org/_img/upload/files/UniformityToDiversity_FULL.pdf

93 IPES Food. 218. Breaking away from industrial food and farming systems: Seven case studies of agroecological transition. http://www.ipes-food.org/topics/Agroecology

94 Watts, M. 2011. Paraquat. http://www.panna.org/sites/default/files/Paraquat%20monograph%20final%202011-1.pdf

95 Watts, M. 2011. Paraquat. http://www.panna.org/sites/default/files/Paraquat%20monograph%20final%202011-1.pdf

96 African Centre for Biodiversity. 2015. What’s next after a ban on glyphosate – more toxic chemical and GM crops? Or the transformation of global food systems? https://acbio.org.za/sites/default/files/documents/Objection%20against%20general%20release%20of%20three%202%204%20D%20GM%20maize%20varieties.pdf

97 Bennett, D. 2018. Monsanto responds to increased dicamba drift reports. Published 3 July 2018. https://www.farmprogress.com/soybean/monsanto-responds-increased-dicamba-drift-reports

98 African Centre for Biodiversity. 2019. Objectives against general release of three 2,4-D GM maize varieties: Corteva’s 2,4-D herbicide tolerant maize: DAS-40278-9; Corteva’s Stacked 2,4-D and glyphosate herbicide tolerant maize: NK603 x DAS-40278-9; Corteva’s Stacked 2,4-D, glyphosate and glufosinate herbicide tolerant, and Bt insecticidal maize: MON89034 x TC1507 x NK603 x DAS-40278-9. https://acbio.org.za/sites/default/files/documents/Objection%20against%20general%20release%20of%20three%202%204%20D%20GM%20maize%20varieties.pdf

99 GM Watch. 2019. Palmer amaranth resistance to 2,4-D and dicamba confirmed in Kansas. https://www.gmwatch.org/en/news/latest-news/18796-palmer-amaranth-resistance-to-2-4-d-and-dicamba-confirmed-in-kansas

ALLIANCE FOR FOOD SOVEREIGNTY IN AFRICA

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Table of ContentsAbout this paper 3Summary 3Introduction 5What is glyphosate and how does it work? 6Where and how widely is glyphosate used? 7How is glyphosate being used and how can people get exposed? 8

Front line victims: farmers and farm workers 9Second-line victims: people living close to treated areas 9Third-line victims: consumers ingesting or exposed to glyphosate and GBH residues 9

Unpacking the myths 10Myth #1: Glyphosate is innocuous to humans and mammals 10 Myth #2: Monsanto genuinely believed Roundup to be safe 11Myth #3: Any exposure to glyphosate and GBHs is ‘below the limits‘ 12

Whose ‘science’ should Africans trust? 12New overwhelming evidence confirming glyphosate toxicity 13What is Africa’s position? 15Call for immediate action 16

The time is now 16The next pesticide frontier 18

Recommendations for immediate action 19Acronyms and abbreviations 20Glossary of terms 20References 21

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2 AFR ICA MUST BAN GLYPHOSATE NOW! Photo credit: Joseph Ntawumeny, Développement des Horticulteurs au Burundi

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About thispaper Worldwide, be it in the Global South or in the northern hemisphere, restrictions and outright bans on the use of glyphosate have grown at an incredible pace over the past few months, as a result of significant new evidence of the chemical’s toxicology.

In this paper, we examine this hotly contested issue from an African perspective and make compelling arguments why African governments should immediately ban glyphosate and glyphosate-based herbicides (GBHs) in their respective countries. This call for a ban on glyphosate and GBHs is rooted in the overwhelming evidence of the chemical’s toxicity and the fact that its current ubiquity may become far more pronounced with the rise in the use of genetically modified (GM) herbicide-tolerant (notably Roundup, Monsanto’s brand name for glyphosate) crops, while at the same time being promoted as ‘non-toxic’.

Beyond a ban on glyphosate, African decision-makers must address the risks posed by

the ineluctable increase in the use of other pesticides (at times equally or more toxic than glyphosate) that are likely to flood markets as substitutes to glyphosate and GBHs, especially as industrialised countries incrementally ban these substances in their countries. Herbicides that are cause for great concern include 2,4-Dichlorophenoxyacetic acid (2,4-D) (especially in the light of the recent approval of 2,4-D Dicamba tolerant crops) as well as paraquat. The only way for African countries to escape this ‘lock in‘ of the agro-chemical pathway is to actively develop and promote agroecological and other non-chemical farming alternatives for their agricultural sectors and to adopt proven alternative weed control agents for urban areas.

Summary• Globally, glyphosate and the additive used

in formulations have penetrated all spheres of our environment and food chains. The persistence and ubiquity of these chemicals place us at the cusp of one of the biggest health crises humankind might face. This crisis is already strongly manifesting, as evidenced by the plethora of health conditions and chronic diseases that have increased at the same pace as GBH use

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globally – especially in Latin America where widespread poisonings have been reported (resulting from aerial application) – and as legally recognised by three recent court cases in the USA.

• Between 2015 and 2019, there has been a marked increase in countries putting in place either full bans or partial bans on the use of glyphosate and GBHs. In July 2019, Austria became the first European country to fully ban glyphosate.1 But many countries, especially in the Global South, had already made this move. Nationwide bans are in place in Oman, Saudi Arabia, Kuwait, the United Arab Emirates, Bahrain, Qatar, Sri Lanka (with a partial lift for specific crops), Saint Vincent and the Grenadines and Vietnam. Sub-national bans are also in place in many counties where federal states (Punjab and Kerala in India) or municipalities (Brussels and many English and Spanish towns) have banned the use of glyphosate. The private use of GBHs was banned in the Netherlands (2015), Sweden (2017), Belgium (October 2018) and France (2019), and restricted use is also in place in many countries.

• In Africa, only one country, Malawi, has temporarily suspended the importation of GBH, although it would appear the Ministry of Agriculture is considering resuming importations in the near future.

• On the African continent, a silent crisis is unfolding, as the attribution of illness and mortality to pesticides is more difficult to establish than anywhere else in the world, as there is a paucity of documented cases of acute and chronic poisoning, and significant under-reporting. This is particularly worrying as GBHs (including Roundup) are used extensively in Africa – in agriculture as well as in urban and rural settings – as a broad-spectrum weed killer.

• Although poorly documented, the use of glyphosate in Africa has followed the global sky-rocketing trend, with South Africa accounting for the lion’s share of glyphosate and GBH consumption on the continent.

• Current approvals of glyphosate and GBHs rest on hopelessly out-dated data that is often the product of the agro-chemical industry’s interference.

• A fact largely unknown by the public and especially decision makers is that the

‘inert‘ ingredients or adjuvants used in the formulation of Roundup make it more toxic than glyphosate alone.

• But this does not exempt glyphosate from remaining on the danger list. In 2015 the World Health Organization’s International Agency for Research on Cancer (IARC) announced that glyphosate is ‘probably carcinogenic to humans‘.2 As this finding was constantly being probed and disputed by other agencies and the industry, the IARC had to repeatedly confirm ‘it ha(d) found “strong” evidence for genotoxicity, both for “pure” glyphosate and for glyphosate formulations‘.3 This means that glyphosate is to be construed as genotoxic (i.e. that it causes cancer) in its own right, while co-formulants make it an even more dangerous substance.

• Other independent research has strongly established the genotoxicity of glyphosate and GBHs and unquestionably linked glyphosate to many chronic illnesses.

• It has been established that glyphosate bio-accumulates, resulting in a concentration in our bodies that is greater than what may be excreted. This was shown in a sample testing of mothers’ breast milk and in urine. We still don’t know the long-term adverse health consequences that these residues inhabiting our bodies may have.

• Most exposed in Africa are farm workers, who are not given access to sufficient personal protective equipment and sometimes none at all, and where youths are often used as the main applicators of pesticides. As 90% of pesticides are known to penetrate the body through the skin, this should raise a resounding alarm bell in terms of the health risk this population group is exposed to.

• The cumulative evidence of GBH’s toxicity to humans and animals calls for immediately discontinuing the use of Roundup and other GBHs.

• However, this poses a double threat. On the one hand, as industrialised countries ban glyphosate and GBHs, product manufacturers will seek to dump these in countries where they are permitted.

• This may already be happening with the phasing out of polyethoxylated tallow amine (POE-T), one of the hazardous co-formulants found in Round-Up, for which

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the European Union (EU) has called a ban in 2016. POE-Ts will, in all likelihood, flood countries where these chemicals are not banned and where, in fact, they are heavily used to manufacture GBHs.

• On the other hand, in the aftermath of a ban on glyphosate and GBHs in Africa, other pesticides (at times equally or more toxic than glyphosate) will flood markets as substitutes.

• Herbicides that are cause for great concern include 2,4 Dichlorophenoxyacetic acid (2,4-D) – especially in the light of the recent approval of 2,4-D Dicamba tolerant crops – as well as paraquat. These active ingredients should also be banned in Africa.

• The only way for African countries to escape this ‘lock in‘ of the agro-chemical pathway is to actively develop and promote agroecological and other non-chemical farming alternatives for their agricultural sectors and to adopt proven safe and non toxic alternative weed control agents for urban areas.

IntroductionWorldwide, the use of glyphosate is reaching a tipping point: in the United States, over 13,400 glyphosate-related lawsuits against manufacturers, sellers, and users are in the pipeline.4 There is mounting public demand for protective regulation, despite all the counter-evidence Monsanto (now Bayer) generates to muddle the science. This paper aims to rally African decision makers to take a strong stance against the pesticide, which is in high use on African soil. The ACB and the Alliance for Food Sovereignty in Africa are calling for outright bans of glyphosate and glyphosate-based herbicides (GBHs) across the continent and caution that 2,4-D and paraquat should be next in line for banning.

Worryingly, save for the one exception of Malawi, which has in early 2019 temporarily suspended the importation of GBHs, no African country has yet placed any form of restriction on the use of glyphosate and GBHs. The IARC’s reclassification of glyphosate as ‘probably carcinogenic‘ has been pointedly ignored, and the toxicity of the product

Photo credit: Erich Westendarp, Pixabay

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to human health and the environment on which their populations depend to sustain themselves, is disregarded. Instead, incredibly, individuals overseeing plant protection in some African countries have made calls for the public to be ‘less emotional‘ about pesticides.5

As confirmed by a recent gathering in Tanzania that examined the issue of ‘pesticide politics in Africa‘,6 there is a dire shortage of research in Africa documenting the extent of acute and chronic exposure to pesticides. The attribution of illness and mortality to pesticides on the continent is more difficult to establish than anywhere else in the world, due to an insufficient number of documented cases and under-reporting. Therefore, it is the responsibility of our African leaders to look beyond the rhetoric of industrial pesticide companies and immediately embrace the precautionary principle by imposing a ban on glyphosate and GBHs and starting the process of phasing out the use of all agricultural chemicals.

What is glyphosateand how does it work? Glyphosate is the active ingredient found in most commonly used herbicides worldwide7 and is by volume the most produced herbicide globally.8 However, glyphosate is seldom used alone and is accompanied by surfactants (which generally represent 5%-15% of concentrated products by weight), which are added to increase the efficacy of the active ingredient.9 Each formulation varies slightly in chemical composition and surfactant composition. Many studies indicate that glyphosate is only slightly toxic to plants at the recommended dilutions in agriculture and that the toxic effects and endocrine disrupting properties of the formulations are mostly due to the inert adjuvant added to the main ingredient.10

Glyphosate acts by shutting down an enzyme involved in the shikimate metabolic pathway (the enzyme inhibited is called 5-enolpyruvylshikimate-3-phosphate, or EPSP synthase), which ensures the synthesis of aromatic amino acids. Glyphosate was originally used for its chelating properties (removal of metals) in the USA in the 1960s and was subsequently patented as a herbicide by Monsanto (1974). Glyphosate also binds (chelates) vital nutrients such as iron, manganese, zinc and boron in the soil, preventing plants from taking them up.11

Glyphosate has a low persistence, so it requires repeated applications for weed control. It strongly binds to soils and breaks down by photolysis (through the action of light) and microbial degradation,12 which is used as the key argument by industry that glyphosate doesn’t leach into water (glyphosate has high water solubility). However, high levels of water contamination occur during heavy rainfall, where leaching into water bodies has been reported.13 The chemical can persist in the aquatic environment, with a half-life of up to nearly five months, and still be present in the sediment of a pond after one year.14 Evidence of glyphosate presence in groundwater, as well as in bottled water, at levels above those permitted in the European Union, highlights that the persistence of glyphosate is more prevalent than claimed by the industry.15

Photo credit: Donna Cleveland

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Where and how widely is glyphosate used? The sale of GBHs has grown exponentially because of the extensive cultivation of genetically engineered glyphosate-tolerant crops, essentially maize, soya and cotton. When Monsanto’s patent protection over glyphosate came to an end in 2000, new GBHs flooded global markets. The total worldwide glyphosate use (both agricultural and non-agricultural) rose more than 12-fold, from about 67 million kilograms in 1995 to 826 million kilograms in 2014. Over the 1974–2014 period, a total of 6.1 billion kilograms of glyphosate was applied, which represents 71.6 % of total use worldwide.16 The upward trend in glyphosate use is likely to continue, increasing the glyphosate levels present in the environment and potentially increasing animal and human exposure to the herbicide.17

Some African countries certainly follow a similar trend, although it is very challenging to track the exact use of glyphosate and GBHs in African soils. On the one hand, data on imported volumes at the national level is hard to come by. On the other hand, in many African countries, regulations are circumnavigated and the borders at times are very porous, so that many pesticides enter countries illegally and use as well as adverse impacts might be widely under-reported.

Nonetheless, a simple review of registered pesticides in many African countries points to the prevalence of glyphosate. In Uganda, among the estimated 300 chemicals on the market, 42 are glyphosate based. In this same country, recent research looking at the prevalence of pesticide residues in water bodies across 17 districts in four regions found

glyphosate to be one of the pesticides with the highest concentrations.18 In Kenya, the most commonly imported active ingredients are glyphosate and its salts, imidacloprid and mancozeb.19

South Africa, which accounts for 2% of global pesticide use, is the largest consumer of pesticides in Africa. Its pesticide expenditure rose by 55% in the period 2009 to 201320 and it is obviously the most voracious consumer of glyphosate on the continent. The country has 96 glyphosate formulations registered and the use of glyphosate in South Africa is highly correlated to glyphosate herbicide-tolerant (HT) crops, namely maize and soya. GM cultivation of white and yellow maize rose from around 69% of all plantings in 2011/12 to 89% in 2015/16.21 In 2012, more than 23 million litres of glyphosate were sold at an estimated value of R641 million.22 More up-to-date information could not be found and verified at the time of writing.

It can be argued that cotton-producing countries on the continent rank among the top consumers of glyphosate, as GBHs are widely used in the production of this crop. The continent’s main cotton producers are Mali, Burkina Faso and Benin. In April 2018, Benin’s Ministry of Agriculture defended the importation of 900,000 litres (480 tonnes) of glyphosate for the 2018/19 growing season as being key to the country’s cotton production.23 In West Africa, the Sahelian Committee for Pesticide Management (linked to the Bamako-based Sahelian Institute), registers pesticides for the entire West Africa and a few central African countries. Among the 434 pesticides registered for use by the committee, 54 are glyphosate based. These are essentially manufactured in China and sold under various alluring brands, such as ‘Piranha‘, ‘La machette‘ (meaning ‘machete‘), or ‘Rafale’ (in reference to the fighter aircraft). Monsanto’s Roundup 360 K and Roundup 450 K feature on its list.24

Analysts report that the total global production of glyphosate, fuelled by China’s huge production capacity, is twice that of the global demand. Africa constitutes a highly sought-after market for selling off the global oversupply.25 Consequently, there is a significant push to use the herbicide, which

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can be directly correlated with the push for glyphosate-tolerant GM crops globally. The build-up of weed resistance to glyphosate has been widely documented. By 2018, 38 weed species distributed across 37 countries had evolved resistance to glyphosate. Although glyphosate-resistant weeds have been identified in orchards, vineyards, plantations, cereals, fallow and non-crop situations, it is the glyphosate-resistant weeds in glyphosate-resistant crop systems that dominate.26 This will only lead to further herbicide use, totally contradicting the proffered rationale for the use for HT crops, which were purported to lead to a decrease in herbicide applications. Although glyphosate is now reported to represent only a minor share of Bayer’s profit, by developing glyphosate-tolerant GM seeds the multinational firm is still clearly riding the glyphosate wave.27

How is glyphosate being used and how can peopleget exposed? There are three levels of exposure to glyphosate mixtures: farmers and farm workers are highly exposed as they handle the pesticides directly; then indirect exposure happens when GBHs drift into areas where people may be living close to treatment areas; and glyphosate residues can be found in the food we eat.

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Photo credit: USAID, Africa Bureau

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Front line victims: farmers and farm workers

The use of GBHs takes many forms: they are used as generic weed killers in agricultural and non-agricultural settings. GBHs are heavily used in Africa to control weeds in rural and in urban environments and are widely applied in forests, parks, public spaces, school grounds, home gardens, and on lawns and roadsides. For use in domestic environments, GBHs are readily available off the shelves of building warehouses, small pesticide merchants and agro dealers.

In the agricultural context, glyphosate is used for weed control. It is often reported as one of the top five pesticides used by farmers in case studies throughout Africa.28 With the push for GM glyphosate-tolerant crops on the continent, this use will increase, as evidenced by experiences elsewhere, notably in South Africa, where glyphosate has become the most used herbicide, mostly in the application on HT GM crops.29

It is important to emphasise that in sub-Saharan Africa, about 55% of the workforce is employed in agriculture. This illustrates how much more of a public concern this issue of exposure is for Africa, compared to industrialised countries (for instance, this share is 4% in the European Union and 1% in North America).30 In the African context, applicators are more often than not farm labourers or contractors. These people are very often adolescents whose duty it is to spray the fields; many examples of such practices can be found in Burkina Faso’s cotton production fields, for example.31 In these contexts, personal protective equipment is often inadequate or – especially in hot conditions – not used at all.

But another invisible, unmonitored use of glyphosate is the ‘regulation’ of plant growth. This refers to the spraying of the chemical on a wide range of crops, including wheat, barley, oats, canola, flax, peas, lentils, soybeans, dry beans and sugar cane, to fast track the ripening of these crops (known as desiccation) prior to harvest.32 This typically constitutes an ‘off-label‘ use of GBHs, which means that glyphosate is not specifically approved for the use on a host of non-GMO crops.

Second-line victims: people living close to treated areas

Non-target exposure can happen to millions of people around the world living or working in or near areas heavily treated with formulated GBHs. They can be exposed to ‘elevated levels’ because of application equipment problems, wind conditions, human error, or negligence.33 There are many documented cases of the illnesses caused by aerial applications of glyphosate in Latin America. In Argentina, a study looking at the concurrence of glyphosate exposure and reproductive disorders in an Argentine agricultural town found that spontaneous abortion and congenital abnormality rates were three and two times higher than the national average. This was due to the very high environmental exposure to glyphosate (79 kilograms per person per year).34 DNA damage caused by glyphosate has been recorded as far as 10 kilometres away from the supposed spray zone in the case of coca fields where glyphosate was used to eradicate weeds in Colombia.35

Indirect exposure is also likely to take place after spraying, when people are exposed to a contaminated agent. An example includes that of a child playing with a dog that has recently spent time in an area sprayed with a GBH.36

Third-line victims: consumers ingesting or exposed to glyphosate and GBH residues

Humans may be exposed to glyphosate residues from consuming fruits, vegetables and other agricultural products, especially cereals, as a result of desiccation, as well as from contaminated drinking water. Importantly, glyphosate residues have been found to be higher in GM soybeans than conventional soybeans, as a result of the intense spraying regime these HT GM crops are subjected to. The nutritional content of GM (and conventional) soya is also found to be much poorer than organic soya.37 This is a very important parameter for countries such as South Africa, where almost all the soya planted is GM. The same conclusion can be made for GM maize, which is the country’s staple food. Several studies demonstrate the presence

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of glyphosate in the urine38 and breast milk of the general population in many countries where glyphosate has been used for years.39 And when it comes to food, glyphosate is there to stay; it cannot be removed by washing and is not broken down by cooking or baking. Glyphosate residues can remain stable in food for a year or more, even if the foods are frozen or processed.40

Glyphosate’s chelating properties could have serious implications for humans, farm animals and pets that consume genetically engineered Roundup Ready crops, as it could negatively affect the nutritional value of food by reducing the bioavailability of critical nutrients.41

But glyphosate is not only in our food; research done mostly in Europe has found alarming levels in nappies (diapers) and tampons. In France, following the discovery of glyphosate and other chemicals in baby nappies by the consumer watchdog body ANSES in January 2019, which pointed to the risk that compounds migrate through urine and enter into prolonged contact with babies’ skin, the government called on the manufacturer and retailers to eliminate these substances from babies’ nappies within 15 days.42

The discoveries of the wide extent of glyphosate contamination begs the question of whether, if such similar testing is to be done in Africa, would the same or more dangerous levels of glyphosate be found?

Unpacking themyths Decision makers and the public at large need to understand the web of myths that have led to the popular belief that glyphosate is safe. There is overwhelming evidence to the contrary and pesticides manufactures such as Monsanto (now Bayer) are feeling the heat like never before.

Myth #1: Glyphosate is innocuous to humans and mammals

The commonly held dogma is that the shikimate pathway is only found in plants but not in humans or other mammals,43 which is why glyphosate has been promoted as safe to people and vertebrates if used according to product labels. However, this shikimate pathway is present in human gut bacteria, which play an important role in human physiology.44 By aiding digestion, the gut microbiota synthesise vitamins and are essential to the immune system’s health and the gastrointestinal tract functions.45

But another critical aspect that our African decision makers need to be aware of is that glyphosate is never used alone in agriculture but is mixed with formulants, which are mainly composed of various oxidised petroleum distillates or derivatives. Over the past few years, extensive research has demonstrated that the on-target effects below toxicity thresholds are not due to the declared active ingredient glyphosate but, undoubtedly, to the formulants.46, 47 The strong herbicidal and toxic properties of its formulations are exerted by the polyethoxylated alkylamines (POEA) formulant family alone. If commercial products contain the same form and concentration of glyphosate, but different co-formulants, their toxicity can vary by up to 100-fold.48 A 2016 study found Roundup was 125 times more toxic than glyphosate.49

These studies present overwhelming evidence that the glyphosate-based herbicides, especially those containing formulants from the family of POEA, which are found extensively on the shelves of agrodealers throughout Africa, including South Africa, are slowly but surely killing African people, and this is going unnoticed. In 2017 the South African Department of Agriculture indicated that polyethoxylated tallow amine, or POE-T, would be phased out by 2020. At the time of writing, the Department has not responded to the ACB’s query about the alternatives identified and whether it would consider a ban on glyphosate.

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There is very limited evidence of the toxicity of these formulations, mainly because the information about the surfactant formulation is classified as confidential business information by manufacturers and accepted as such by regulators, which means that the exact formulations are hardly ever disclosed on the label.50 As regulatory studies only assess active ingredients, it is challenging to assess the real toxicological examination of individual herbicides.

That being said, the IARC Working Group’s classification of glyphosate as ‘probably carcinogenic to humans‘ (Group 2A) is supported by ‘strong‘ evidence for genotoxicity, both for ‘pure‘ glyphosate and for glyphosate formulations.51 This means that ‘pure‘ glyphosate is a dangerous genotoxic compound and that it should be regarded as such, despite the toxicity of co-formulants being much greater than that of pure glyphosate.

Myth #2: Monsanto genuinely believed Roundup to be safe

Monsanto has falsified data on Roundup’s safety, and marketed it to parks’ authorities and consumers as ‘environmentally friendly‘ and ‘biodegradable‘, to encourage its use on roadsides, playgrounds, golf courses, schoolyards, lawns and home gardens.52 In 2009, a French court ruled that these marketing claims amounted to false advertising. It is very important to take stock of the mountain of evidence that American lawyers have compiled against Monsanto in the latest federal lawsuit. In the Pilliod v. Monsanto case, the jury awarded the plaintiffs US $2 billion in punitive and compensatory damages. The jury came to their decision based on evidence, not only of the herbicide’s carcinogenicity, but also of Monsanto’s role in suppressing and discrediting independent findings regarding Roundup toxicity. This legal precedent is hugely significant in that is clearly establishes the ‘science’ that Monsanto

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Photo in public domain

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has been systematically manufacturing about the alleged safety of Roundup as false. And why should it stop there?

Myth #3: Any exposure to glyphosate and GBHs is ‘below the limits‘

It is contended that glyphosate residues found in grains and foods are often below the set maximum residue limits. This begs the question of how these limits were set and by whom. These limits have been extensively criticised for being outdated and inadequate to local contexts and for industry interference in setting them.53

In the US, the acceptable daily intake (ADI)i limit for glyphosate is set at 1.75 milligrams per kilogram of bodyweight per day (1.75 mg/kg bw/day) versus 0.3 mg/kg bw/day in the European Union. In South Arica, the ADI was set at 1 mg/kg bw/day per day. Credible independent, peer-reviewed scientific evidence now shows that the levels of harm to human health could begin at the ultra-low levels of 0.1 parts per billion of glyphosate.54 A 2012 study called for a much lower ADI to be set at 0.025 mg/kg bw/day or ‘12 times lower than the ADI‘ currently set in Europe.55

Basing ADIs on active ingredients alone (i.e. glyphosate) prevents any genuine toxicology risks from being assessed. In the light of the overwhelming evidence that surfactants are much more toxic than glyphosate alone and that potential toxicity can arise from ingestion of co-formulants, ADIs should be based on the daily intake of co-formulants.

Whose ‘science’ should Africanstrust?Since the global arbitration about whether glyphosate and GBH formulations are toxic or not seems to be still very contentious, African policy-makers need to obtain a good understanding of why there is conflicting evidence about the issue.

In 2015, the International Agency for Research on Cancer (IARC) classified glyphosate as ‘probably carcinogenic to humans (Group 2A)‘. This was ‘based on “limited” evidence of cancer in humans (from real-world exposures that actually occurred) and “sufficient” evidence of cancer in experimental animals (from studies of “pure” glyphosate)‘.56 Essentially the IARC found that GBHs can cause cell damage through at least two mechanisms of action (DNA damage and oxidative stress), which act as triggers or accelerators of the progression of cancerous cell growths.57 This critical finding was disputed by another landmark study by the US Environmental Protection Agency (EPA), which concludes that glyphosate is unlikely to be carcinogenic to humans.58 A comparative assessment of how these two bodies came to their conclusions was undertaken and aptly explains the reasons for these conflicting findings.59

Key reasons why the findings are at odds with each other:

i) Unpublished versus peer-reviewed evidence as a source: The EPA selectively relied on unpublished regulatory studies, 99% of which reported negative findings of genotoxicity, while the IARC relied mostly on peer-reviewed studies, of which 70% found positive results of genotoxicity.ii

i. The ADI intake of a pesticide refers to the safety limit determined by the regulator, based on long-term toxicity studies on the active ingredient of the pesticide, and implies they are safe levels that can be ingested over an entire lifespan.

ii. For the evaluation of glyphosate genotoxicity, the EPA took fully into account the results of only 23% of the assays considered by IARC (27/118) (Benbrook 2019)

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ii) Glyphosate pure versus glyphosate + surfactants as the studied source of genotoxicity: The EPA’s evaluation was largely based on data from studies on glyphosate alone, whereas the IARC’s review focused on the results of formulated GBHs. The latter is much closer to real life scenarios, as glyphosate is always used in combination with surfactants.

iii) Narrow exposure versus broad-spectrum exposure. The EPA’s evaluation was focused on typical, general population dietary exposure, assuming legal, food crop uses, and did not address occupational exposures and risks, which are generally higher. The IARC’s assessment encompassed data from typical dietary, occupational, and elevated exposure scenarios.

The occupational health component is very critical in the African context, where farm workers are found to be critically exposed to pesticide usage. On the continent, pesticides are essentially applied with a hand-held appliance connected to a backpack, all-terrain vehicles, and in some instances truck-mounted sprayers that require a person to hold and direct an application wand. GBHs are often applied under hazardous conditions that result in high dermal exposure. As the skin is the main channel through which pesticides penetrate the body, the health risk is therefore significantly higher. Risks include leaky hoses or valves that lead to the applicator manually handling the pesticide, a leaky backpack drenching the applicator’s lower back, windy conditions, being instructed to apply the pesticide barefoot,60 etc. The risks are compounded by lack of control over the workplace, lack of facilities for washing, lack of medical treatment, and repeated exposure.

Hence, the IARC Working Group’s findings that GBHs are ‘probably carcinogenic to humans‘ are highly relevant to the African context.

New overwhelming evidence confirmingglyphosate toxicitySince the IARC’s findings, many additional studies have demonstrated overwhelming evidence of genotoxic effects and oncogenic potential of glyphosate and GBHs. There is compelling evidence from laboratory research and epidemiological studies that exposure to glyphosate or GBHs causes autism,61, iii, 62 cancer,63 teratogenic effects (birth defects),64 reproductive toxicity (infertility),65 and liver disease.66

With regards to cancer, several studies corroborate the findings by the IARC. Research assessing the genotoxic risk in agricultural workers in Colombia found a relationship between glyphosate exposure and non-Hodgkin’s lymphoma (NHL).67 In the ‘fumigated towns‘ of Argentina, where Roundup is used, NHL is widely reported.68 In early 2019, a team of US scientists published a meta-analysis of studies on GBHs. Their research concludes that there is a ‘compelling link between exposures to GBH and increased risk of NHL’.iv Statistical analysis revealed there to be a 41% increased risk of NHL resulting from high exposure to GBHs.69 In July 2019, echoing this overwhelming evidence, International Federation of Gynaecology and Obstetrics (FIGO) called for a global phasing out of GBHs. 70

iii. An American study found a compelling correlation in the sky-rocketing number of children with autism and the volume of glyphosate on corn and soy crops in the USA between 1990 and 2010 (see reference 63).

iv. Zhang, L., Rana, L., Shaffer, R.M., Taioli, E., Sheppard, L. 2019. Exposure to glyphosate-based herbicides and risk for Non-Hodgkin Lymphoma: a meta-analysis and supporting evidence, Mutation Research/Reviews in Mutation Research. ISSN 1383-5742, https://doi.org/10.1016/j.mrrev.2019.02.001 (219:284)

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Box 1. Where is glyphosate banned? There has been a spate of countries where action as been taken to ban or restrict the use of glyphosate since the court cases in America, which highlighted the dangers of glyphosate. Below is a brief outline of the full bans, partial bans or restrictions that have been put in place globally to date.74

Nationwide bans:• Oman, Saudi Arabia, Kuwait, the United Arab Emirates, Bahrain and Qatar all banned the import and

use of GBHs (between 2015 and 2016).• Sri Lanka banned the importation of all GBHs (2015), which was subsequently partly lifted (2018) only for

use in tea and rubber plantations.• St Vincent and the Grenadines suspended all use of GBHs (August 2018).• Vietnam banned the import of all GBHs (March 2019).• On 2 July 2019 Austria voted for an outright ban on glyphosate, which represents the strongest action

a EU country has taken against the chemical so far.75 Interestingly, this ban was passed when Austria was led by a provisional government of civil servants ahead of a parliamentary election expected in September 2019. This illustrates how, when members of the public are given the reigns of leadership, they make decisions in the interests of the people, not industry.

Sub-national bans:Bans have also been put in place by municipal or regional territories. • The city of Brussels banned the use of glyphosate within its territory as part of its ‘zero pesticides‘ policy.• In the UK, several boroughs and townships have issued bans or restrictions on the use of glyphosate.• In Spain, several cities have banned glyphosate. • In India, the government of Punjab banned the sale of glyphosate in the state (October 2018) and the

state of Kerala issued a ban on the sale, distribution, and use of glyphosate (February 2019). • Many school and universities in Australia and in the USA have halted the use of GBHs and are actively

seeking alternatives. In May 2019, for example, the University of California halted the use of glyphosate on all 10 of its campuses, which serve over 200,000 students.76

Selective bans:The private use of GBHs was banned in Belgium (October 2018), as well as in the Netherlands (2015), Sweden (2017) and France (2019).Private and commercial sale of all GBHs was banned in Bermuda (2017) and in Vancouver, except for public roadside weed management.Portugal has prohibited the use of glyphosate in all public spaces.In June 2019, Germany announced its plan to discontinue all use of GBHs for the maintenance of its railway tracks.

Restricted use:• Italy banned the use of glyphosate in public areas and as a pre-harvest spray (2016).• In the Czech Republic, GBH-based pre-harvest spraying was also banned (2018).• In Denmark, the use of glyphosate on all post-emergent crops was banned to avoid residues on foods

(2018).• In France, the use of glyphosate and all other pesticides in public green spaces was banned (2017).

(In May of 2019, France announced it would eliminate the use of glyphosate by 2021 with limited exceptions77.)

• In Argentina, more than 400 towns and cities have passed measures restricting glyphosate use.• In Canada, eight out of the 10 provinces have some form of restriction on glyphosate.• In the USA, many towns (especially in California, which now lists glyphosate as a known carcinogen)

have initiated pesticide reduction plans and integrated pest management programmes or have outrightly banned the use of Roundup and other glyphosate-based weed killers in city parks.78

• In Switzerland and Luxembourg, supermarket chains have removed GBHs from their shelves in response to public outcry.

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Critically, some of these effects were detected in the range of the recommended acceptable daily intake. Recent research on ‘Roundup GT plus‘, possibly the only glyphosate formulation tested for its long-term toxic effects, showed that doses of 0,1 parts per billion of the formulation, equivalent to 0,4 mg/kg bw/day, led to non-alcoholic fatty acid liver disease in rats over a two-year feeding trial. According to this research, this ultra-low environmental dose can result in liver and kidney damage with potential significant health implications for animal and human populations.71 This dose is 250 000 below the ADI determined in South Africa.72 A 2012 study calls for a much lower ADI to be set, at 0.025 mg/kg bw/day; this is equivalent to ‘12 times lower than the ADI currently set in Europe‘.73

African leaders need to urgently take stock of what these bans in many other countries around the globe signify for Africa, especially in a context of oversupply of glyphosate. Where will the ‘excess‘ glyphosate and co-formulants go?

In 2016, the European Commission called for a ban on polyethoxylated tallow amine (POE-T), a co-formulant found in many Roundup formulations. This means that member states will have to adjust their national legislation to phase out POE-T from all GBH formulations.79 This will result in manufacturers dropping the price of POE-T to get rid of stocks in countries where POE-T is still in use80, and may further ‘lock-in‘ African countries into using POE-T instead of less hazardous co-formulants in GBH formulations.

What is Africa’s position?While the debate around a potential ban of glyphosate in many Northern countries is now rifer than ever, with many countries taking unprecedented measures against the use of glyphosate and GBHs (see Box 1), regulators and politicians on the African continent essentially remain supportive of glyphosate and pointedly ignore the pleas from civil society organisations. They are quick to refer to studies that conveniently find glyphosate to be non-toxicv (as evidenced above, the biased meta data used by these studies is highly questionable). Civil servants in the agricultural sector also vehemently defend a herbicide judged critical to the agricultural economy of African countries, citing its efficacy and that it can easily be used directly on crops.81, vi

Some African leaders have even argued that the Roundup used in their country is ‘not as dangerous as the Roundup used in Europe and in America (…) because it is a class III (WHO)‘ – as Gaston Dossouhoui, Benin’s Minister of Agriculture was reported as saying about Killer 480 SL, the GBH used in Benin.82 These are very dangerous and misleading statements.

First, any glyphosate-based formulations, whether they are found in the United States or in Europe, would be classified as a class III (slightly hazardous) as this is the class assigned to glyphosate by the WHO’s classification of active pesticide ingredients.83 However, the IARC reclassification means that any glyphosate-based formulation is highly hazardous, as defined by a WHO-FAO Joint Meeting on Pesticide Management.

v. For instance, following the 2016 IARC report classifying glyphosate as a class IIa ‘probably carcinogenic to humans’, the South African Department of Agriculture, Forestry and Fisheries was quick to refer to the counter evidence studies generated by the United States Environmental Protection Agency (US EPA), Australian Pesticides and Veterinary Medicines Authority (APVMA), and the European Food Safety Authority (EFSA), which as discussed have a much narrower focus than the IARC (DAFF Media release dated 22 May 2015). Mention can also be made of the case of Sylvain Ouedraogo, Sahelian Committee for Pesticide Management Permanent Secretary, who, following the Monsanto landmark judgement in 2018 in favour of Dewane Johnson, referred to the 2016 WHO-FAO Joint Meeting on Pesticide Residues (JMPR) which found ‘glyphosate to probably show little genotoxicity to anticipated food exposures’.

vi. Comments made by Athanase Yara, head of the agronomy service of the National Union of Cotton Growers of Burkina-Faso (UNCB), speaking about the use of glyphosate on cotton (see reference 82)

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Second, arguing that some formulations may be more deleterious than others is correct, but this begs the question of whether the regulators in Benin and elsewhere know which potentially toxic inert ingredients are in the formulations that they purchase, as these are kept confidential by the industry.

Third, co-formulants in a brand name product can vary geographically and over time, with no warning or indication on product labels, in material safety data sheets or other publicly available sources of information.84

To date, the only African country that seems to have taken a stand against glyphosate and GBHs is Malawi. In April 2019, Malawi’s ‘national’ newspaper reported that Malawi had suspended GBH imports, including Roundup, with immediate effect. The paper quotes Gray Nyandule-Phiri, Principal Secretary of the Ministry of Agriculture, saying that this suspension would take place with immediate effect, until ‘such time as everything has been officially resolved‘.85 Unfortunately, in this news report, the Ministry also indicated that glufosinate ammonium would be replacing glyphosate. This illustrates how banning glyphosate alone does not suffice and that countries need to astutely identify viable and ecologically sustainable solutions. Furthermore, in response to the ACB’s query on the current status of the suspended importation of GBH in the country, the Ministry of Agriculture spokesperson indicated that “It (was) very likely that resuming of importation would be considered soon”.86

A very confusing story surrounds the ban/non-ban in Togo. In April 2018, the Minister of Agriculture, Ouro-Koura Agadezi, released a communiqué stating that, ‘In order to preserve not only the environment, but also human and animal health, it is strictly forbidden for farmers to import and market unregistered pesticides, including glyphosate throughout the country according to the law number 96-007/PR of 03 July 1996 on the protection of plants‘.87 Although this communiqué sounds unambiguous, Atsou Tagba, Togo’s Director of Plant Protection, later in the year explained that this was a ‘misunderstanding‘ by stating that, ‘In Togo, unlicensed glyphosate is banned like all the other unregistered pesticides.

Normally, glyphosate is not banned in Togo‘.88 The general public may wonder whether this cacophony wasn’t about a ban that was retracted under the pressure of industry.

Call for immediate actionThis evidence stemming from the industrial world – and some countries from the Global South – cannot be ignored by our African leaders. We in Africa critically lack such localised evidence, let alone studies attributing cancer to GBH usage because of the lack of research, documentation, and under-reporting. However, given the conditions of use, especially for applicators using inadequate protective equipment and often, because of the intense heat, no protection at all, it can be reasonably concluded that our farmers and farm workers are worse off. It follows logically thus, that the food systems in African countries are as critically – if not more – contaminated by GBH residues as in the SA or in the EU.

The time is now

It is imperative that African leaders heed the precautionary principle now and take urgent steps towards protecting their people and the environments of which they are custodians, against any further damage. There is sufficient evidence that GBHs have genotoxic effects on human health and animals.

African leaders will hear alarming discourses that if they should ban glyphosate, their food security will be threatened and that there is currently no viable alternative to replace glyphosate with. Nothing can be further from the truth. The reality is that there are viable alternatives, as has been thoroughly documented by the UK Pesticide Action Network,89 which bring in their wake genuine food sovereignty, and that lessen the burden of non-communicable disease, which is

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sky-rocketing on our continent.90 It is critically urgent that African civil society calls for an immediate ban on glyphosate and GBHs in their countries. But, it is equally important that they keep a very watchful eye on even more toxic chemicals the industry will quickly push forward as alternatives.

The United Nations Special Rapporteur on the right to food, Hilal Elver, has denounced the myth that pesticides are necessary to feed the world. In this regard, she has emphasised that ‘without or with minimal use of toxic chemicals, it is possible to produce healthier, nutrient-rich food, with higher yields in the longer term, without polluting and exhausting environmental resources‘.91

The hazardous over-reliance on pesticides can be overcome with strong political will and the steering of countries onto agroecological pathways. Agroecology (as a set of practices and as a science) is emerging as a critically important alternative to socially unjust and ecologically unsustainable ‘business-as-usual‘, dominant Green Revolution approaches to agricultural development. Through replacing chemical inputs with organic materials and processes and optimising biodiversity, agroecology can enable smallholder farmers to overcome the ‘lock-ins’ inherent in large-scale, agribusiness-led industrial agriculture that undermine resilience.92 There is a growing base of evidence across many contexts that proves that agroecology is capable of delivering sufficient yields to feed and nourish the entire world population.93, vii

vii. There are a plethora of documented alternatives to the agrochemical pathway. In Africa, the Alliance for Food Sovereignty in Africa (AFSA) and Groundswell International have generated a wealth of resources documenting how to go about embarking on the agroecological pathway. For resources and case studies of this agroecological transition, refer to https://www.agroecology-pool.org/showcases/

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Photo credit: Pochogh, Pixabay

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The next pesticide frontier

This paper focuses specifically on glyphosate and GBHs, given the ubiquity of these products and the misperception that glyphosate and GBHs are safe. However, when looking at banning hazardous substances, African governments should also take into account the extensive toxicology research that was done in Europe and that led to the ban of several active ingredients. Some of these active ingredients that no longer have approval for use in the EU are listed below and should come under urgent scrutiny similarly in Africa (Box 2). Note that this list is based on active ingredients still used in many African countries, but some may be banned in some African countries.viii

Other active ingredients, which are still approved in the EU, need to come under similar scrutiny by African governments, because they are earmarked to potentially

replace glyphosate. These undoubtedly constitute the next ‘pesticide frontier‘ that our governments will need to tackle, as they are also extremely hazardous.

Paraquat, listed in Box 2 above, as it is banned in the EU, is being promoted as an alternative to glyphosate to overcome the ‘increasing problem of glyphosate resistance in countries with widespread use of Roundup on GM crops‘.95

But what we also need to look out for is the development and approval of new generation GM crops that are resistant to other herbicides; these herbicides will in turn become ubiquitous in our environments.

In 2015, the ACB responded to the IARC’s prognosis on glyphosate being a probable human carcinogen in a report that flagged the danger that loomed after a potential ban on glyphosate.96 The fear is that more toxic

Box 2. List of pesticides banned in the EU and still in use in many African countries• Paraquat: The Pesticide Action Network describes paraquat as ‘the most highly acutely toxic herbicide

to be marketed over the last 60 years (but one of the) most widely used herbicides in the world‘. They further indicate that ‘The World Health Organisation classifies paraquat as class II, moderately toxic; but PAN believes it should be reclassified as class I because of its acute toxicity, delayed effects and lack of antidote.‘94

• Carbendazim: A fungicide reported as a reproduction/developmental toxicant that is highly toxic to earthworms.

• Acephate: An organophosphate insecticide, highly soluble in water, that is toxic to mammals with a low potential for bioaccumulation.

• Diazinon: A highly volatile general-purpose insecticide considered to be a potential groundwater pollutant and neurotoxic to humans and other mammals.

• Permethrin: A contact insecticide that is moderately toxic to humans and highly toxic to most aquatic species and honeybees.

• Dimethoate: An organophosphate insecticide that may have serious health implications for humans as it may affect reproduction or development. It is highly toxic to birds and honeybees.

• Atrazine: A systemic herbicide that is moderately toxic to most aquatic life, earthworms and honeybees and can leach into water.

• Fenoxaprop: Classified as an ‘obsolete herbicide‘ by the EU.• Thiram: A multi-use carbamate fungicide, which is also used as a mammal repellent.

viii. Detailed information about these pesticides was found on the University of Hertfordshire’s pesticide properties database: https://sitem.herts.ac.uk/

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chemicals would be introduced and replace glyphosate, a scenario for which the industry has already prepared; not so much because of a looming ban on glyphosate, but because of incremental weed resistance to glyphosate.

This has started with the approval of new GMO crops designed to be resistant to 2,4-D and Dicamba in the USA and other countries. A common systemic herbicide, 2,4-D is a synthetic auxin (plant hormone) that is highly drift prone, being responsible for the third highest incidents of crop damage in the USA.97 The IARC itself has recently classified 2,4-D as ‘possibly carcinogenic to humans’. In early 2019, Corteva (formally known as Dow AgroSciences) applied for the general release of three staked GM maize varieties in South Africa. These three varieties are tolerant to 2,4-D, and two are also tolerant to glyphosate. This development is a great cause for concern, as such GM crops will expose consumers to more toxic combinations of persistent pesticide residues in their food. The ACB strongly objected to these releases, out of concern about increased non-target drift associated with 2,4-D, and increased exposure to a toxic pesticide, the efficacity of which will, in any event, prove to be short lived, with the inevitable rise of herbicide-tolerant weeds.98 In fact, in early 2019, the first resistance to Dicamba and 2,4-D in a Palmer amaranth weed population was confirmed in Kansas.99

GM HT crops that have been developed and approved show tolerance to other toxic herbicides, such as: glufosinate (a herbicide banned in the EU); 2,4-D; Dicamba; and Isoxaflutole.

Recommendations for immediate actionThe ABC and the AFSA hereby calls on African governments to:• issue immediate bans on all uses of

glyphosate and GBHs;• issue immediate bans on other active

ingredients that are banned in the EU;• take adequate measures to ensure other

more toxic chemicals do not replace glyphosate; and

• initiate a shift from chemical, input-intensive weed management and agriculture in general, to agroecological practices.

We also call on park management boards, schools, universities and municipalities to take immediate measures to do away with GBHs for the sake of the healthy of the people who frequent their spaces.

Municipalities can also be easily rallied and requested not to use GBHs.ix But most of all, farmers could and should be supported to discontinue the use of GBHs and refrain from resorting to dangerous pesticides.

These actions form part of the essential steps that need to be taken to rethink our food systems. Relying on pesticide is a choice and the choice must be made to move away from substances that harm our environment and our people and compromise the wellbeing of future generations and our planet.

ix. For consumers wanting to take action, the US-based Institute for Responsible Technology has issued a nation-wide campaign alerting to the dangers of glyphosate and other dangerous herbicides in public areas. Visit https://rounduprisks.com and see the specific resources developed to get Round Up banned in your community.

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Acronyms and abbreviations 2,4-D 2,4-Dichlorophenoxyacetic acid ADI Acceptable Daily Intake EPA Environmental Protection Agency (USA)EU European UnionEPSP synthase 5-enolpyruvylshikimate-3-phosphate synthaseGBHs Glyphosate-based herbicidesGM Genetically modified GMO Genetically modified organismHT Herbicide tolerant IARC International Agency for Research on Cancer mg/kg bw/day Milligrams per kilogram of bodyweight per dayNHL Non-Hodgkin’s lymphoma POE-T Polyethoxylated tallow aminePOEA Polyethoxylated alkylamines

Glossary of terms genotoxic: chemical agents that damage the genetic information within a cell causing mutations, which may lead to cancer

inert: chemically inactive

oncogenic potential: causing development of a tumour or tumours.

oxidative stress: an imbalance of free radicals and antioxidants in the body, which can lead to cell and tissue damage.

surfactant: a substance which increases the spreading and wetting properties

teratogenic: which causes malformation of an embryo

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https://www.reuters.com/article/us-austria-glyphosate/austrian-parliament-backs-eus-first-total-ban-of-weedkiller-glyphosate-idUSKCN1TX1JR

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14 Watts, M., Clausing, P., Lyssimachou, A., Schütte, G., Guadagnini, R., Marquez, E. 2016. Glyphosate. Pesticide Action Network, October 2016. http://pan-international.org/wp-content/uploads/Glyphosate-monograph.pdf

15 Rendón-von Osten, J. & Dzul-Caamal, R. 2017. Glyphosate residues in groundwater, drinking water and urine of subsistence farmers from intensive agriculture localities: A survey in Hopelchén, Campeche, Mexico. International Journal of Environ Research and Public Health. 2017 Jun; 14(6): 595. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5486281/

16 Benbrook, C. 2016. Trends in glyphosate herbicide use in the United States and globally. Environmental Sciences Europe 28(1): 1–15 https://doi.org/10.1186/s12302-016-0070-0

17 Ibid. 18 Uganda National Association of Community and Occupational Health (UNACOH). 2018. The pesticides use, health

and environment project (PHE). Water and crops were sampled for pesticide residues in the following 17 districts: Northern region – Gulu, Adjumani, Nebbi and Kitgum; Eastern region – Kumi, Pallisa, Kapchorwa, Budaka and Bugiri; Western region – Ntungamo, Bushenyi, Kamwenge and Masindi; and Central region – Rakai, Sembabule, Wakiso and Kayunga districts. [Unpublished]

19 Swiss Programme for Research on Global Issues for Development. n.d. Highly hazardous pesticides (HHPs) in agro-industrial and smallholder farming systems in Kenya. [Unpublished]

20 United Nations Environment Programme. 2013. Global Chemical Outlook. https://sustainabledevelopment.un.org/index.php?page=view&type=400&nr=1966&menu=35

21 Esterhuizen, D. 2016. Agricultural biotechnology annual: Biotechnology in South Africa. United States Department of Agriculture Foreign Information Service Global Agricultural Network. https://www.fas.usda.gov/data/south-africa-agricultural-biotechnology-annual-0

22 Gouse, M. 2014. Assessing the value of glyphosate in the South African agricultural sector. https://ageconsearch.umn.edu/record/206520/?ln=en

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23 France 24. 2018. Jugement Monsanto: en Afrique, la fin du glyphosate n’est pas pour demain. [Monsanto’s trial: in Africa, the end of glyphosate is not for tomorrow]. Published in France 24 on 15 August 2018. https://www.france24.com/fr/20180815-jugement-monsanto-afrique-utilisation-glyphosate-roundup

24 Comité Sahélien des Pesticides. 2018. Liste globale des pesticides autorisés par le comité Sahélien des Pesticides – version de Novembre 2018. [Authorised pesticides – version November 2018]. http://www.insah.org/doc/liste_globale_pesticides_autorises_par_CSP_version_Nov-2018.pdf

25 Watts, M., Clausing, P., Lyssimachou, A., Schütte, G., Guadagnini, R., Marquez, E. 2016. Glyphosate. Pesticide Action Network, October 2016. http://pan-international.org/wp-content/uploads/Glyphosate-monograph.pdf

26 Heap, I. & Duke, S. 2018. Overview of glyphosate-resistant weeds worldwide. Pest Manag Sci. May, 74(5):1040–1049. doi: 10.1002/ps.4760. https://www.ncbi.nlm.nih.gov/pubmed/29024306

27 Reuters. 2019. Glyphosate use will eventually end, Merkel says. Published in Reuters, on 26 June 2019. https://www.reuters.com/article/us-bayer-glyphosate-merkel/glyphosate-use-will-eventually-end-merkel-says-idUSKCN1TR1QN

28 Proceedings from the pesticides politics in Africa. 2019. Conference held in Arusha, May 2019. http://iris.ehess.fr/index.php?4187

29 Gouse, M. 2014. Assessing the value of glyphosate in the South African Agricultural Sector. https://ageconsearch.umn.edu/record/206520/?ln=en

30 World Bank. 2018. Employment in agriculture. https://data.worldbank.org/indicator/SL.AGR.EMPL.ZS31 Luna, J.K. 2018. Getting out of the dirt: racialized modernity and environmental inequality in the cotton sector of

Burkina Faso, Environmental Sociology, 4(2): 221–234. DOI: 10.1080/23251042.2017.1396657 32 EcoWatch. Why is glyphosate sprayed on crops right before harvest? 5 March 2016,. http://www.ecowatch.com/

why-is-glyphosate- sprayed-on-crops-right-before-harvest-1882187755.html. 33 Benbrook, C.M. 2019. How did the US EPA and IARC reach diametrically opposed conclusions on the genotoxicity

of glyphosate-based herbicides? Environmental Sciences Europe 31:2 https://doi.org/10.1186/s12302-018-0184-7 34 Avila-Vazquez, M., Difilippo, F.S., Mac Lean, B., Maturano, E. & Etchegoyen, A. 2018. Environmental exposure to

glyphosate and reproductive health impacts in agricultural population of Argentina. Journal of Environmental Protection 9(03): 241. DOI: 10.4236/jep.2018.93016

35 Leahy, S. 2007. Colombia-Ecuador: Studies find DNA damage from anti-coca herbicide. Inter Press Service, Toronto, 16 June. http://www.ipsnews.net/news.asp?idnews=38205

36 Benbrook, C.M. 2019. How did the US EPA and IARC reach diametrically opposed conclusions on the genotoxicity of glyphosate-based herbicides? Environmental Sciences Europe 31:2 https://doi.org/10.1186/s12302-018-0184-7

37 Bøhn, T., Cuhra, M., Traavik, T., Sanden, M., Fagan, J., Primicerio, R. 2014. Compositional differences in soybeans on the market: Glyphosate accumulates in Roundup Ready GM soybeans. Food Chemistry 153: 207–215. ISSN 0308-8146, https://doi.org/10.1016/j.foodchem.2013.12.054

38 Conrad, A., Schröter-Kermani, C., Hoppe, H-W., Rüther, M., Pieper, S., Kolossa-Gehring, M. 2017. Glyphosate in German adults – Time trend (2001 to 2015) of human exposure to a widely used herbicide. International Journal of Hygiene and Environmental Health 220(1): 8–16. ISSN 1438-4639. https://doi.org/10.1016/j.ijheh.2016.09.016.

39 Food Democracy Now! 2016. Glyphosate: Unsafe on any plate Available from: https://usrtk.org/wp-content/uploads/2016/11/FDN_Glyphosate_FoodTesting_Report_p2016-3.pdf

40 Ibid.41 Cakmak I, Yazici A, Tutus Y, Ozturk L. Glyphosate reduced seed and leaf concentrations of calcium, manganese,

magnesium, and iron in non-glyphosate resistant soybean. Eur J Agron. 31:114–11942 French Agency for Food, Environmental and Occupational Health & Safety (ANSES). 2019. ANSES recommends

improving baby diaper safety. https://www.anses.fr/en/content/anses-recommends-improving-baby-diaper-safety

43. Dill, GM., Cajacob, C.A., Padjette S.R. 2008. Glyphosate-resistant crops: adoption, use and future considerations. Pest Management Science. 2008 Apr;64(4):326-31.

44 Samsel, A & Seneff, S. 2013. Glyphosate’s suppression of Cytochrome P450 Enzymes and amino acid biosynthesis by the gut microbiome: Pathways to modern disease. Entropy, 15: 1416–1463. doi:10.3390/e15041416

45 Littman, D.R., Pamer, E.G. 2011. Role of the commensal microbiota in normal and pathogenic host immune responses. Cell Host Microbe 10: 311–323

46 Defarge, N., Spiroux de Vendomois, J. & Séralini, G.E. 2018. Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides. Toxicology reports 5: 156–163. https://doi.org/10.1016/j.toxrep.2017.12.025

47 Nobels, I., Spanoghe, P., Haesaert, G., Robbens, J., Blust, R. 2011. Toxicity ranking and toxic mode of action evaluation of commonly used agricultural adjuvants on the basis of bacterial gene expression profiles. PLoS ONE 6: e24139. https://doi.org/10.1371/journal.pone.0024139

48 Mesnage, R., Bernay, B., Seralini, G.E., 2013. Ethoxylated adjuvants of glyphosate-based herbicides are active principles of human cell toxicity. Toxicology 313: 122–128

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49 Defarge, N., Takacs, E., Lozano, V.L., Mesnage, R., Spiroux de Vendomois, J., Séralini, G-E., & Székacs, A. 2016. Co-formulants in glyphosate-based herbicides disrupt aromatase activity in human cells below toxic levels. International Journal of Environmental Research and Public Health, 13(3): 264. http://doi.org/10.3390/ ijerph13030264

50 Mesnage, R., Benbrook, C., Antoniou, M.N. 2019. Insight into the confusion over surfactant co-formulants in glyphosate-based herbicides. Food and chemical toxicology 128: 137–145

51 International Agency for Research on Cancer (IARC). 2015. IARC Monograph on Glyphosate. https://www.iarc.fr/featured-news/media-centre-iarc-news-glyphosate/

52 Food Democracy Now! 2016. Glyphosate: Unsafe on any plate . Available from: https://usrtk.org/wp-content/uploads/2016/11/FDN_Glyphosate_FoodTesting_Report_p2016-3.pdf

53 African Centre for Biodiversity. 2017. No safe limits for toxic pesticides in our food. African Centre for Biodiversity. 2017. No safe limits for toxic pesticides in our food.

54 Seralini, G.E., Clair, E., Mesnage, R., Gress, S., Defarge, N., Malatesta, M., Hennequin D., de Vendomois, J.S. 2014. Republished study: Long-term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize. Environ Sci Europe. 26(1):14. http://enveurope.springeropen.com/articles/10.1186/ s12302-014-0014-5

55 Antoniou, M., Habib, M.E.M., Howard, C.V., Jennings, R.C., Leifert, C., Nodari, R.O., Robinson, C.J., Fagan, J. 2012. Teratogenic effects of glyphosate-based herbicides: Divergence of regulatory decisions from scientific evidence. Journal of Environmental and Analytical Toxicology S4:006. https://pdfs.semanticscholar.org/8e51/fcf27a85f70653366a6e45c5798c32ba349b.pdf?_ga=2.265619849.726383174.1563883908-1804739333.1563883908

56 International Agency for Research on Cancer (IARC). 2015. IARC monograph on glyphosate. https://www.iarc.fr/featured-news/media-centre-iarc-news-glyphosate/

57 Guyton, K.Z. et al. 2015. Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate. Lancet Oncol 16: 490–491. https://doi.org/10.1016/S1470-2045(15)70134-8

58 Environment Protection Agency (EPA). 2016. Glyphosate issue paper: Evaluation of carcinogenic potential. https://www.epa.gov/sites/production/files/2016-09/documents/glyphosate_issue_paper_evaluation_of_carcincogenic_potential.pdf.

59 Benbrook, C.M. 2019. How did the US EPA and IARC reach diametrically opposed conclusions on the genotoxicity of glyphosate-based herbicides? Environmental Sciences Europe 31:2 https://doi.org/10.1186/s12302-018-0184-7

60 Ngowi, V. 2019. Presentation made during the pesticides politics in Africa. 2019. Conference held in Arusha, May 2019. http://iris.ehess.fr/index.php?4187

61 Beecham, J. & Seneff, S. 2016. Is there a link between autism and glyphosate formulated herbicides? Journal of Autism. Volume 3, Article 1. http://www.hoajonline.com/journals/pdf/2054-992X-3-1.pdf

62 Swanson, N.L., Leu, A., Abrahamson, J. & Wallet, B. 2014. Genetically engineered crops, glyphosate and the deterioration of health in the United States of America. Journal of Organic Systems. 9(2). http://www.gmofreepartners.com/wp-content/uploads/2015/04/Swanson.pdf

63 Williams, G.M., et al. 2016. A review of the carcinogenic potential of glyphosate by four independent expert panels and comparison to the IARC assessment. Crit Rev Toxicol 46:3–20. https://doi.org/10.1080/10408444.2016.1214677

64 Antoniou, M., Habib, M.E.M., Howard, C.V., Jennings, R.C., Leifert, C., Nodari, R.O., Robinson, C.J., Fagan, J. 2012. Teratogenic effects of glyphosate-based herbicides: Divergence of regulatory decisions from scientific evidence. Journal of Environmental and Analytical Toxicology S4:006. https://pdfs.semanticscholar.org/8e51/fcf27a85f70653366a6e45c5798c32ba349b.pdf?_ga=2.265619849.726383174.1563883908-1804739333.1563883908

65 Owagboriaye, F., Dedeke, G.A., Olutoyin, A., Olujimi, O., Ashidi, J.S., Aladesida A. Reproductive toxicity of Roundup herbicide exposure in male albino rat, Experimental and Toxicologic Pathology, 69(7): 461–468. ISSN 0940-2993, https://doi.org/10.1016/j.etp.2017.04.007.

66 Mesnage, R., Renney, G., Seralini, G.E., Ward, M., Antoniou, M.N. 2017. Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra- low dose of Roundup herbicide. Sci. Rep. 7, 39328. https://www.ncbi.nlm.nih.gov/pubmed/28067231

67 Bolognesi, C., Carrasquilla, G., Volpi, S., Solomon, K.R., Marshall, E.J. 2009. Biomonitoring of genotoxic risk in agricultural workers from five Colombian regions: association to occupational exposure to glyphosate. J Toxicol Environ Health Part A 72: 986–997. https://doi.org/10.1080/15287390902929741

68 Acquavella, J., Garabrant, D., Marsh, G., Sorahan, T., Weed, D.L. 2016. Glyphosate epidemiology expert panel review: a weight of evidence systematic review of the relationship between glyphosate exposure and non-Hodgkin’s lymphoma or multiple myeloma. Crit Rev Toxicol 46: 28–43. https://doi.org/10.1080/10408444.2016.1214681

69 Zhang, L., Rana, L., Shaffer, R.M., Taioli, E., Sheppard, L. 2019. Exposure to glyphosate-based herbicides and risk for Non-Hodgkin Lymphoma: a meta-analysis and supporting evidence, Mutation Research/Reviews in Mutation Research. ISSN 1383-5742, https://doi.org/10.1016/j.mrrev.2019.02.001

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70 Sustainable Pulse. 2019. Global Women’s Health Federation FIGO Calls for Phasing Out of Glyphosate Herbicides. Published on 31 July 2019. https://sustainablepulse.com/2019/07/31/global-womens-health-federation-figo-calls-for-phasing-out-of-glyphosate-herbicides/#.XUfYmC2Q3_T

71 Mesnage, R., Renney, G., Seralini, G.E., Ward, M., Antoniou, M.N. 2017. Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra- low dose of Roundup herbicide. Sci. Rep. 7, 39328. https://www.ncbi.nlm.nih.gov/pubmed/28067231

72 African Centre for Biodiversity. 2017. No safe limits for toxic pesticides in our food. https://acbio.org.za/wp-content/uploads/2017/07/No-Safe-Limits-for-Toxic-Pesticides-in-Our-Food.pdf

73 Antoniou, M., Habib, M.E.M., Howard, C.V., Jennings, R.C., Leifert, C., Nodari, R.O., Robinson, C.J., Fagan, J. 2012. Teratogenic effects of glyphosate-based herbicides: Divergence of regulatory decisions from scientific evidence. Journal of Environmental and Analytical Toxicology S4:006. https://pdfs.semanticscholar.org/8e51/fcf27a85f70653366a6e45c5798c32ba349b.pdf?_ga=2.265619849.726383174.1563883908-1804739333.1563883908

74 Information for this section was gleaned from Sustainable Pulse. 2019. Glyphosate Herbicides Now Banned or Restricted in 17 Countries Worldwide – Sustainable Pulse Research. https://sustainablepulse.com/2019/05/28/glyphosate-herbicides-now-banned-or-restricted-in-17-countries-worldwide-sustainable-pulse-research/#.XRC3ay2Q06g and Baum Hedlund Aristei Goldman Pc. 2019. Where is Glyphosate banned? https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/

75 Reuters. 2019. Austrian parliament backs EU’s first total ban of weedkiller glyphosate. Published on 2 July 2019. https://www.reuters.com/article/us-austria-glyphosate/austria-set-to-be-first-eu-country-to-ban-all-uses-of-weedkiller-glyphosate-idUSKCN1TX1JR

76 Independent Science News. 2019. University of California system halts use of glyphosate herbicide. Published on 17 May 2019. onhttps://www.independentsciencenews.org/news/university-of-california-system-halts-use-of-glyphosate-herbicide/

77 France 24. 2019. Glyphosate : la justice interdit la vente et l’utilisation d’un Roundup de Monsanto. https://www.france24.com/fr/20190116-france-justice-interdiction-vente-utilisation-round-up-360-bayer-monsanto

78 For a detailed listing of all anti-GBHs measures in the USA, see Baum Hedlund Aristei Goldman Pc. 2019. Where is Glyphosate banned? https://www.baumhedlundlaw.com/toxic-tort-law/monsanto-roundup-lawsuit/where-is-glyphosate-banned/

79 Euractiv. 2016. EU agrees ban on glyphosate co-formulant. Published on 12 July 2016. https://www.euractiv.com/section/agriculture-food/news/eu-agrees-ban-on-glyphosate-co-formulant/

80 Narbonne, J. 2019. Pers. Com. Held on 19 July 2019. (J. Narbonne is toxicologist at the French Association Toxicologie Chimie ATC).

81 Fance 24. 2018. Jugement Monsanto: en Afrique, la fin du glyphosate n’est pas pour demain. [Monsanto’s trial: in Africa, the end of glyphosate is not for tomorrow]. Published in France 24 on 15 August 2018. https://www.france24.com/fr/20180815-jugement-monsanto-afrique-utilisation-glyphosate-roundup

82 Agratime. 2018. Le Bénin n’utilise pas le glyphosate comme les pays industrialisés rassure le ministre de l’agriculture [Benin does not use glyphosate the same way as industrialised countries reassures the Ministry of Agriculture]. Published in Agratime , 2018 (date not specified) https://www.agratime.com/2018/09/05/le-benin-nutilise-pas-le-glyphosate-comme-les-pays-industrialises-rassure-le-ministre-de-lagriculture/

83 WHO. 2009. The WHO recommended classification of pesticides by hazards and guidelines to classification. https://www.who.int/ipcs/publications/pesticides_hazard/en/ (2009:71)

84 Mesnage, R., Benbrook, C., Antoniou, M.N. 2019. Insight into the confusion over surfactant co-formulants in glyphosate-based herbicides. Food and chemical toxicology 12: 137–145

85 The National. 2018. Government suspends Monsanto’s roundup import permit. Published in The National https://sustainablepulse.com/wp-content/uploads/2019/04/55935239_1104096843115305_8380267426914238464_n.jpg

86 Chimala, H. 2009. Pers. Correspondence received on 6 August 2019. Hamilton Chimala is Spokesperson of the Ministry of Agriculture Irrigation & Water Development.

87 Agri Digitale. 2018. Le glyphosate n’est pas interdit au Togo ! [Glyphosate is not banned in Togo!] https://www.agridigitale.net/art-le_glyphosate_n_est_pas_interdit_au_togo_.html

88 Ibid. 89 Pesticide Action network UK. 2018. Alternatives to glyphosate in weed management. New edition, 11 July 2018.

http://www.pan-uk.org/alternatives-to-glyphosate-in-weed-management/ 90 World Health Organization. 2016. Research shows higher risk of developing Non-communicable diseases in Africa.

Available from: https://www.afro.who.int/news/research-shows-higher-risk-developing-non-communicable-diseases-africa

91 United Nations Human Rights Council. 2017. Thirty-fourth session. 27 February–24 March 2017 Agenda item 3. Promotion and protection of all human rights, civil, political, economic, social and cultural rights, including the right to development. https://reliefweb.int/report/world/report-special-rapporteur-right-food-ahrc3448

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The African Centre for Biodiversity (previously ‘Biosafety‘) was established in 2003 and registered in 2004. ACB carries out research and analysis, learning and exchange, capacity and movement building, and advocacy to widen awareness, catalyse collective action and influence decision-making on issues of biosafety, genetic modification (GM) and new technologies, seed laws, farmer seed systems, agricultural biodiversity, agroecology, corporate expansion in African agriculture, and food sovereignty in Africa.

www.acbio.org.za PO Box 29170, Melville 2109, Johannesburg, South AfricaTel: +27 (0)11 486 1156

The Alliance for Food Sovereignty in Africa (AFSA) is a broad alliance of different civil society actors that are part of the struggle for food sovereignty and agroecology in Africa. These include: African farmers’ organisations, African NGO networks, specialist African NGOs, consumer movements in Africa, international organisations which support the stance of AFSA, and individuals. Its members represent smallholder farmers, pastoralists, hunter/gatherers, indigenous peoples, faith based institutions, and environmentalists from across Africa. It is a network of networks, currently with 30 active members.

P. O Box 571 , Kampala, Ugandawww.afsafrica.org

This publication is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License

This publication may be shared without modification for non-commercial use provided the African Centre for Biodiversity is acknowledged as the source. Prior written agreement is necessary for any commercial use of material or data derived from this publication.

August 2019

Cover image: Helen DayCopy editor: Liz SpargDesign layout and graphics: Adam Rumball, Sharkbuoys Designs, Johannesburg

AcknowledgementsWe acknowledge the research and writing contributions of Sasha Mentz-Lagrange and contributions by Lim Li Ching, Eva Sirinathsinghji and Mariam Mayet. We are grateful to various donors for their loyal support.

The views and opinions expressed in this report are those of the ACB and do not necessarily reflect the official policy or position of the donors.

92 IPES Food. 2016. From uniformity to diversity: A paradigm shift from industrial agriculture to diversified agroecological systems. http://www.ipes-food.org/_img/upload/files/UniformityToDiversity_FULL.pdf

93 IPES Food. 218. Breaking away from industrial food and farming systems: Seven case studies of agroecological transition. http://www.ipes-food.org/topics/Agroecology

94 Watts, M. 2011. Paraquat. http://www.panna.org/sites/default/files/Paraquat%20monograph%20final%202011-1.pdf

95 Watts, M. 2011. Paraquat. http://www.panna.org/sites/default/files/Paraquat%20monograph%20final%202011-1.pdf

96 African Centre for Biodiversity. 2015. What’s next after a ban on glyphosate – more toxic chemical and GM crops? Or the transformation of global food systems? https://acbio.org.za/sites/default/files/documents/Objection%20against%20general%20release%20of%20three%202%204%20D%20GM%20maize%20varieties.pdf

97 Bennett, D. 2018. Monsanto responds to increased dicamba drift reports. Published 3 July 2018. https://www.farmprogress.com/soybean/monsanto-responds-increased-dicamba-drift-reports

98 African Centre for Biodiversity. 2019. Objectives against general release of three 2,4-D GM maize varieties: Corteva’s 2,4-D herbicide tolerant maize: DAS-40278-9; Corteva’s Stacked 2,4-D and glyphosate herbicide tolerant maize: NK603 x DAS-40278-9; Corteva’s Stacked 2,4-D, glyphosate and glufosinate herbicide tolerant, and Bt insecticidal maize: MON89034 x TC1507 x NK603 x DAS-40278-9. https://acbio.org.za/sites/default/files/documents/Objection%20against%20general%20release%20of%20three%202%204%20D%20GM%20maize%20varieties.pdf

99 GM Watch. 2019. Palmer amaranth resistance to 2,4-D and dicamba confirmed in Kansas. https://www.gmwatch.org/en/news/latest-news/18796-palmer-amaranth-resistance-to-2-4-d-and-dicamba-confirmed-in-kansas

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AFRICA MUST BAN GLYPHOSATE NOW!PO Box 29170, Melville 2109, South Africa

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