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Minor Uses for Agricultural Compounds and Vetinary Medicines

In the February issue of AgVetLink MAF reported on its strategy to minimise illegal use of agricultural compounds and veterinary medicines.

A working party established under the Agricultural Compounds and Veterinary Medicines Advisory Council (AVMAC) has been assisting MAF to develop appropriate mechanisms to recognise safe minor uses. The working party has suggested that the present provisions under the Animal Remedies and Pesticides Acts have been, for the most part, adequate to avoid hazards to public health due to residues.

Possible options

It has also suggested that, since it would be an offence under the ACVM Act to use a product outside the conditions of registration, conditions could be applied to allow for minor uses. MAF is investigating this option. Some of the things it is considering are:

1. Specifying the food crops/food-producing animals and particular application/administration (including withholding times) for which the product has been assessed and approved.

2. Allowing the product to be used on other food crops if the user ensures that residues do not exceed either:

the default maximum residue limit specified in the New Zealand Food Residue Standard; or

the most stringent trade maximum residue limit specified by MAF for any substance in the product, whichever is less.

MAF would have to provide (in some public place) the default maximum residue limit that must be met for the crop for any product. This limit would be set at a conservative level to ensure that, in the face of uncertainty associated with limited information, there would be no significant residues present. There would also have to be a statement in regard to restrictions on grazing animals that would be used for production of food for humans or pharmaceuticals.

    3.    Allowing the product to be used on other food-producing animals if the user ensures that residues              do not exceed either:

• the default maximum residue limit specified in the New Zealand Food Residue Standard; or

• the most stringent trade maximum residue limit specified by MAF,whichever is less.

MAF once again would have to provide (in some public place) the maximum residue limit that must be met for a particular species. As stated in 2 above, this would be a conservative limit. In the case of animals MAF would provide a table of default withholding times for different species (eg 60 day withholding time for horses that could be used for the production of human food or pharmaceuticals).

    4.    Allowing the use of any product on any animals or plants that are not used to produce food for              humans because the issue of residues would not be relevant. For non-food crops there would also              have to be a statement in regard to restrictions on grazing animals that could be used for production              of food for humans or pharmaceuticals.

The conservative residue requirements would encourage affected parties to provide sufficient data to support a more sensitive withholding time. MAF would look to the industry sectors to prompt an application to assess additional crop/animal species uses and application/administration specifications. This can be done by MAF in consultation with the registrant for the product.

Welfare requirements

The conditions suggested above address the hazards associated with residues and for plant compounds this would be sufficient. However, for veterinary medicines the imposition of conditions that would provide for safe alternative uses would also have to ensure that the welfare of the animals treated was adequately protected.

MAF is proposing to include a condition that would allow any person to use a non-prescription veterinary medicine in a manner not specified under the condition that the user must seek veterinary advice if, after treatment:

• the animal(s) show increased or additional pain or distress; or

• the product fails to work and the animal(s) continue to suffer pain or distress.

Such a condition would not be applied to a product that can be used only by or under the authority or prescription of a registered veterinarian. The discretionary use of such products is entirely the responsibility of the registered veterinarian. No other person should choose to use the product in a manner not specified by the prescribing veterinarian.

If MAF applies the kinds of conditions suggested, it would have to make it clear to all parties exactly what has been assessed. The responsibility and liability for use of a product in a manner not recommended by the proprietor of that product must fall on the user. There will be no endorsement or warranty on the part of MAF or the proprietor of the product expressed or implied in regard to the unrecommended, unassessed use.

If MAF applies the kinds of conditions suggested, it would have to make it clear to all parties exactly what has been assessed. The responsibility and liability for use of a product in a manner not recommended by the proprietor of that product must fall on the user. There will be no endorsement or warranty on the part of MAF or the proprietor of the product expressed or implied in regard to the unrecommended, unassessed use.

Imposing conditions such as these would virtually eliminate the dilemma that arises when considering the use of effective treatments for animal and plants in circumstances that would not prompt sufficient commercial interest from the proprietors of products to apply for an extension of the existing approved uses. MAF will continue to develop its proposals in this area.

If anyone wishes to comment on what has been suggested so far, please direct your comments to:

Chris Boland
Special Advisor (Technical Policy)
ACVM Group
Ministry of Agriculture and Forestry
Post Office Box 40063
UPPER HUTT