Obligation to record the use of Animal Remedies

Recording information about on-farm use of animal remedies is becoming an important component of programmes to:

• ensure the safety of animal products; and
• provide the basis for export certification.

The Animal Remedies Act does not impose any generic recording obligations on the users of trade name products or on health care advisers. The ACVM Act, when it commences, will not impose such obligations either.

Apart from some specific trade name product types, such as hormone growth promotants or antibiotics, the ACVM Group is not likely to impose conditions on the registration of trade name products for routine recording of on-farm uses.

Consequently, recording of on-farm use of animal remedies on food producing animals will remain a requirement of either risk management programmes (Animal Products Act 1999) for meat and meat products or product safety programmes (Dairy Industry Regulations 1990) for milk and milk products. Those programmes place the obligation to keep on-farm health records on the livestock producer.

Prosecutions can be taken against producers who do not keep adequate records.

However, it is more likely that non-compliance will lead to rejections of animals or produce during processing, or reluctance on the part of meat or dairy companies to purchase and process the animals or produce in the first place.

Veterinarians and other health care providers are advised that, while failure to provide on-farm treatment information will not, in most instances, be an offence under either the Animal Remedies or ACVM Acts, it would be considered unprofessional behaviour. Failure to provide the information for recording could result in a civil suit taken by the livestock producer against the veterinarian or health care provider to recover losses due to rejected produce or lost sales. In the case of veterinarians, the unprofessional behaviour may also result in breaches of the Code of Professional Conduct under the Veterinarians Act 1993.

It is hoped that, independent of whatever regulatory action might be taken in response to non-compliance, all parties would recognise that it is to their benefit (and New Zealand’s) to ensure that on-farm use recording requirements specified in risk management programmes or product safety programmes are met in the most practical and efficient manner possible.