Spraying adjuvants and the urgency of regulating these products

Spraying adjuvants are important inputs as a tool for improving the effectiveness or reducing costs of phytosanitary treatment in modern agriculture. For years there has been a discussion about whether or not such products should be considered a “like” in the Agrochemicals Law (Law no.^o 7.802/89 regulated by Decree n^o 4.074/02) and therefore subject to the same registration process to which such products are subject. When in doubt, products classified as adjuvants were registered. This discussion was concluded with the publication on November 20, 2017, by the Ministry of Agriculture, Livestock and Supply (MAPA), of Act n^o 104 which cancels the registration of products registered exclusively as adjuvants, “given that there is no obligation to register in Law no.^o 7.802 and in Decree n^o 4.074”. This attitude, while correct, is reckless.

By definition, an adjuvant is “any substance or compound without phytosanitary properties, except water, which is added to a pesticide preparation, to facilitate application, increase effectiveness or reduce risks”. Therefore, if it “does not have phytosanitary properties” and if it is developed to be “added to a pesticide preparation”, by itself it does not exert any control and, therefore, is not a pesticide. On the other hand, to “facilitate application, increase effectiveness or reduce risks” it interferes with the characteristics of the mixture (mixture of pesticide with water) and can alter important aspects of the spraying. This interference can be positive or negative in the spraying process, in the effectiveness of the product and also in the safety of workers, the environment and food. As examples, an adjuvant can change the surface tension and/or viscosity of the spray mixture. Changing these characteristics will interfere with factors such as droplet size, spreading and evaporation speed, interfering with the technology and safety of the application. If the adjuvant increases droplet size it can reduce drift (carrying the pesticide out of the target area) which is a positive point, however, it can also reduce droplet size, increasing drift and the risk of contamination. worker and environmental. Increased spreading, on the other hand, can be an excellent resource as a tool for reducing the volume of water used in spraying, without loss of effectiveness and with a significant reduction in cost, however, some adjuvants even increase the wetted area for the same drop. more than 30 times. In this situation, drops that initially would not coalesce start to coalesce on the target, increasing runoff, reducing the amount of product in the plant and consequently the effectiveness of the phytosanitary treatment, leading to a loss of productivity or the need for a greater number of sprays per harvest. Finally, reducing the speed of water evaporation can also be an important factor, both economically, since it can increase the period of use of sprayers depending on climatic conditions, and safety and effectiveness, since drops that would evaporate before from reaching the target, resulting in the possibility of producer and environmental contamination, they start to reach it, increasing the amount of product on it. An opposite effect to this, however, will be observed if the adjuvant, even having other positive functionalities, increases the water evaporation rate. Thus, knowledge of the functional characteristics of an adjuvant can limit its use or even change the way it is adjusted and the conditions of use of the sprayer.

Based on the above, if the adjuvants do not qualify as “defensive or similar”, they also cannot be “over-the-counter products, without the need for any authorization by MAPA” as specified in item 5 of Act no.^o 104. In solving the problem, re-registering as a pesticide would not be a viable alternative, since the efficacy tests required in the registration process do not reflect the functionality of the adjuvants. Therefore, if not registration, adjuvants need at least regulation. Initiatives in this regard have already been taken in the past by the Brazilian Association of Generic Defensives (AENDA) and by MAPA itself, but they did not have an effective result. Basic functionalities need to be scientifically analyzed to serve as technical parameters for recommendation and use. As there are no national or international standards for testing and classifying such functionalities, a joint action between MAPA, the National Health Surveillance Agency (ANVISA), the Brazilian Institute of the Environment and Renewable Natural Resources (IBAMA), manufacturers, users and researchers, even as a Study Committee of the Brazilian Association of Technical Standards (ABNT) seeking to develop Brazilian standards, is necessary. If this is not done, and quickly, the damage to agriculture, farmers, workers and the environment could be significant.

*The authors are researchers in the area of ​​Adjuvants at the Engineering and Automation Center of the Agronomic Institute (CEA-IAC), a body of the Secretariat of Agriculture and Supply of the State of São Paulo located in the city of Jundiaí (SP).