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AgVetLink December 2003

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Change in policy in regard to agricultural context for plant compounds

The ACVM Group intends to adjust its operational definition of an ‘agricultural compound’ to incorporate a broader interpretation of agricultural context.

This change affects the class determination of a number of products (i.e. some home garden products) that are not presently regarded as agricultural compounds.

While the current policy (Operational definitions of agricultural compounds and prescribed risks areas – February 2000) does not include an operational interpretation of agricultural context, the ACVM Group has interpreted the word ‘agricultural’ to mean production of primary produce for sale. It has based exclusion of home garden products on this interpretation. Consequently, only products that were formulated and packaged for use on plants for commercial production and for the production of food offered for sale were considered agricultural compounds.

The interpretation was based on the overall regulatory environment prior to the commencement of the ACVM and HSNO Acts and the establishment of the New Zealand Food Safety Authority.

Some assumptions were made at that time:

• Management of the safety of domestic food supplies was a Ministry of Health focus, not a Ministry of Agriculture and Forestry focus.
• Regulatory control under the ACVM Act would be additive to control imposed under the HSNO Act.
• Public health risks in the home environment appeared to be more within the scope of the HSNO Act than the ACVM Act, while risks related to commercially traded produce appeared to be more relevant to the ACVM Act.
• Home garden products that had previously been controlled under the Pesticides Act 1979 would be adequately controlled under the HSNO Act with no need for additional controls being imposed under the ACVM Act.
• Characteristics that could be used to make a clear distinction between home garden and commercial production products related to the impractical commercial use of the products (i.e. small weight/volume pack size, low concentration etc.).

The inclusion of the word ‘agricultural’ in the ACVM Act seemed to reinforce these assumptions. It seemed to imply that ACVM regulatory attention could concentrate on agrichemicals used in commercial production. After consultation on this interpretation at the time it was proposed, it was accepted with reservations. Consequently, when it came to making class determinations of products used to manage plants (i.e. plant compounds), the ACVM Group determined that trade name products that had the characteristics of home garden products would not be agricultural compounds.

A number of developments have prompted the ACVM Group to reconsider its operational policy in this area.

With the creation of the New Zealand Food Safety Authority, the ACVM Group’s interests in the safety of the home grown foods for personal consumption as well as domestic and international trade in both foods and primary produce has been heightened.

The responsibility for setting maximum residue limits, along with development and maintenance of domestic food safety standards, has now been placed with the NZFSA.

The assumption that there were characteristics that could distinguish home garden from commercial production products is no longer valid because more produce from small production units is being marketed either by the producers or by larger retailers.

It has also become apparent that the management of food safety risks posed by the use of agrichemicals in the home garden are not likely to be adequately managed via HSNO regulatory controls alone – the management of residues is a primary focus of the NZFSA rather than of ERMA New Zealand.

Updated documents

The following documents have been updated and the new versions are available on the ACVM website:

• ACVM Registration Standard and Guideline for the Chemistry of Veterinary Medicines
• Registration and Product Data Sheet – Veterinary Medicines
• Registration and Product Data Sheet – Plant Compounds
• New Zealand Labelling Guide for Veterinary Medicines Requiring Registration
• New Zealand Labelling Guide for Plant Compounds Requiring Registration