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The registrations of vertebrate pest control products have been transferred to ACVM registrations. While the ACVM (Transitional Provisions) Regulations 2002 provide for the ongoing importation, manufacture and sale of these products under their present conditions and labels, the registrations are being reviewed to ensure that the conditions of registration adequately manage the ACVM risk areas.

The ACVM Group considers it essential to maintain a comprehensive control programme without interruption. It is also essential to review present regulatory arrangements to ensure that present controls are necessary and sufficient, and that all the products are controlled adequately, even those that were not scheduled in the Pesticides (Vertebrate Pest Control) Regulations 1983.

The ACVM Group is also concerned that, at least in the short term, there may be difficulty maintaining some aspects of the present programme under the controls that can be imposed under the Hazardous Substances and New Organisms Act 1996.

The important components of the programme that may be put at risk from a food safety perspective are:

• the ability to revoke user approvals;
• the obligation to maintain a compulsory national database of approved users;
• the requirement for users to be confirmed as fit and proper persons before licensing;
• the ability to ensure compliance and enforce ACVM Act conditions.

To ensure continuity in regulatory control the ACVM Group will contact all product registrants and advise them that additional conditions are being applied to the registration of their products. Under section 23 of the ACVM Act, the ACVM Group will impose specific conditions on the importation, manufacture, sale and use of vertebrate pest control products. This will create statutory obligations similar to those imposed under the Pesticides (Vertebrate Pest Control) Regulations 1983. The difference will be that the obligations will be applied directly to the registrations of the products themselves. Inserts must be provided with the products specifying the statutory obligations for distributors, pest control agencies and users.

The conditions will also include a requirement for users to be approved. This will be similar to the present VPC licence but it will be valid only for up to five years. Licensees will have to contact the ACVM Group to convert their existing licences into ACVM approvals. They will have to show they are competent. This can be done by reference to an approved handler certificate issued under the Hazardous Substances and New Organisms Act 1996, or by reference to the existing VPC training programme. 'Fit and proper person' assessment will still be a requirement, and approvals will be revoked if parties fail to comply with their statutory requirements.

The ACVM Group is working closely with ERMA NZ to ensure that regulatory control is exactly what is needed and does not impose redundant and unnecessary compliance costs. As the approved handler system becomes operational and the VPC substances are transferred into the main framework of the HSNO Act, there are likely to be opportunities to streamline to two systems. Until then the ACVM Group will administer a programme that maintains adequate control.

To ensure efficient processing of any payments made by direct credit, we ask you to include the following information as a narrative/description so that monies can be allocated quickly and correctly:

• Name of company
• Customer Number
• Invoice Number

If we do not have the correct information, there may be delays in processing applications. If you have any further queries, or wish to pay by direct credit in the future, please contact:

Sarah Smyth
Coordinator (Business Services)
Phone: 04 463 2553
Fax: 04 463 2566
Email: sarah.smyth@nzfsa.govt.nz