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AgVetLink October 2003

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Transfer of hazardous substances into the main framework of the HSNO Act

The ACVM Group has been advised by ERMA NZ of the latest intentions to transfer hazardous substances that are agricultural compounds into the main framework of the HSNO Act. This is important from an ACVM perspective because it will have an impact on the updating of veterinary medicine and plant compound registrations due in July 2004.

When the ACVM (Transitional Provisions) Regulations 2002 came into force there was an expectation that updating registrations could be done with HSNO controls in mind.

Registrants have to apply for updated ACVM registration before 1 July 2004, but they still do not know for certain what labelling requirements will be imposed as a result of substances being transferred into the main framework of the HSNO Act.

Pesticides

ERMA NZ has advised that they expect to have the technical work on the transfer of pesticides under the HSNO Act completed by 1 January 2004. This will allow the Authority to issue transfer reports specifying the controls that will be placed on those substances. ERMA NZ has also advised that they will be providing sufficient guidance to allow parties to know how to comply with the controls, particularly in regard to labelling.

While the substances will actually be transferred on about 1 July 2004, registrants will be able to determine the HSNO labelling requirements and submit their new label content to the ACVM Group early in the new year. This will allow them not only to meet their obligations under the ACVM (Transitional Provisions) Regulations 2002 but also to incorporate the labelling requirements under the HSNO Act.

Veterinary medicines

The situation is not as fortunate for veterinary medicines. ERMA NZ has advised that the transfer reports for hazardous substances that are veterinary medicines are not likely to be available until mid-2004 at the earliest. The classification of substances and, consequently, the controls that will be applied to them may not be known before registrants have to apply to update their ACVM registrations.

Nevertheless, they must lodge their applications with the ACVM Group for new ACVM registrations early in 2004, given that it must be done before 1 July 2004 in order to comply with the ACVM (Transitional Provisions) Regulations.

Advice

The advice that the ACVM Group offers to registrants is to either:

• apply for the updating of the ACVM registrations without consideration of the future HSNO controls and make the necessary changes in labelling whenever the relevant substances are transferred; or
• anticipate the likely HSNO labelling requirement for their products and lodge the appropriate label content for ACVM registration updates.

Workshops

The ACVM Group recommends that registrants discuss the issues with ERMA NZ to help them anticipate appropriate label changes. We understand that this is likely to impact significantly on the compliance costs for registrants who need to update their products to the ACVM Act prior to the HSNO transition date.

For this reason we have undertaken to organise workshops with industry representatives and ERMA NZ to see what can be done to minimise unnecessary costs for veterinary medicines.

A similar workshop will also be run for products covered by the Pesticides Act, but it is likely that all of these products will be transitioned prior to 1 July 2004. The main topic for discussion is how the issue of product in the market with outdated labels will be managed.

MRL update

In May the NZFSA consulted on a new MRL for pymetrozine in lettuce and an exemption from an MRL for 9,10- anthraquinone when used as bird repellent on grapes. The MRL for pymetrozine was gazetted on 17 July 2003. The NZFSA is currently refining its policy on MRL exemptions, so the proposed exemption for 9,10-anthraquinone is being held back until the policy is finalised.

The third round of public consultation for MRLs is underway (the final date for submissions is 6 October 2003), and proposes new MRLs for lasalocid sodium in poultry and doramectin in pigs. Refer to the NZFSA website ( http://www.nzfsa.govt.nz/policy-law/consultation/archive/mrl-2003-09/index.htm ) for details.