Analysis of the Code
The Code has some very good provisions, particularly around registration, packaging, labelling, advertising, etc; but also, some major flaws, including the following.
There is no mechanism or process for addressing non-compliance.
Promotion of pesticide use
Several articles seem designed to promote pesticide use:
1.7.4 ensure that pesticides are used effectively and efficiently and in a manner that contributes to the sustainable improvement of agriculture, public and animal health and the environment
This is in fact contrary to some of the Guidelines developed to assist implementation of the Code such as the Guideline on HHPs which states that the first step is to reduce reliance on pesticides by determining “to what extent current levels of pesticide use are actually needed and eliminate unjustified pesticide use”; and to “make optimum use of non-chemical pest management practices”.
It is also contrary to the SAICM Dubai Declaration which declared that:
6. The need to take concerted action is accentuated by a wide range of chemical safety concerns at the international level, including … dependency on pesticides in agriculture
IPM as the only alternative
The standards of conduct set out in the Code:
1.7.6 are designed to promote Integrated Pest Management (IPM) and Integrated Vector Management (IVM);
The problem with this is that the Code specifically does not support organic agriculture or agroecology, although it does mention “non-chemical pesticides and pest control methods at Article 3.10. This is despite FAO itself supporting agroecology, as does the SAICM resolution discussed in the first session.