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Use of Animal Remedies on Minor Species

There has been some confusion lately, especially from goat farmers, about what can and cannot be legally used on minor species such as goats in light of the Meat (Residue) Regulations and the implementation of the Animal Products Act. The ACVM Group has prepared an information sheet (included in this issue and also available on the website) covering this fairly complex area.

If you or your organisation have any queries, please direct them to Gill Culliford (phone: 04 474 4245 or email: cullifordg@maf.govt.nz ) who will arrange for a response.

Essentially, there are a number of commonly available substances or chemi-cals (such as copper sulphate) that farmers may purchase and use on their own animals. Unless the substance purchased is imported, manufactured, sold (which includes ‘gifting’) or advertised as an animal remedy, it does not have to be licensed under the Animal Remedies Act.

Under the Meat Act and the Animal Products Act, a licensed product may also be used in a species not on the label as long as there is no specific label instruction to the contrary. This means that licensed animal remedies may be used in minor species, such as goats and emus, providing the guidelines issued by the Animal Products Group of MAF Food are followed.

The ACVM Group strongly recommends that any ‘off label’ use is done under veterinary advice.

Regulations Review Committee

Recently there was a challenge made to the Regulations Review Committee of Parliament concerning the legality of the Meat (Residue) Regulations and the application of them by MAF. Questions were raised by the complainant over the definition of an animal remedy and the use of licensed products ‘off-label’. Following a hearing in November 2000 and some subsequent correspondence, the report of the committee has been tabled to the House of Representatives. The complaint was unsuccessful. The report has the recommendation: "We have examined these regulations and conclude that the regulations are not in breach of any of the grounds in Standing Order 382(2). We recommend that the House take note of this report".

Ethylene bis-dithiocatbamates (EBDCs)

The Pesticides Board has finally resolved the issues surrounding the re-evaluation of the EBDC fungicides, carried out under section 28 of the Pesticides Act 1979.

Proprietors will shortly receive  (and may already have) a letter detailing the outcome of the review which began in 1993, but has been dogged with issues arising from the changes made to  the Act after the GATT-Uruguay Round agreements relating to confi-dentiality of the data submitted by proprietors. Resolution of these issues was imperative if any further reviews were to be carried out either under the Pesticides Act 1979 or the ACVM Act 1997.

In the process, the Board has reconfirmed its policy that data submitted after a call-in by the Board will be given five years exclusive use to the submitter, from the time of notification of the outcome of the review.

This is in line with the provi-sions for innovative pesticides, inserted in the Act in 1994.

Transition for Animal Remedies to the HSNO Act

Because there are limited transitional provisions in the HSNO Act for animal remedies, it is important that licensees ensure that any products and their components are notified as toxic substances. Forms are available on the ERMA NZ website: www.ermanz.govt.nz

(See AgVetLink articles on transition in the June and August 2000 issues.)