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AgVetLink April 2004: Page 3

VPC products under the ACVM Act

Users of vertebrate pest control (VPC) products are required to be ‘approved handlers’ under the HSNO Act. A system of authorising Test Certifiers to approve handlers, i.e. persons involved with the manufacture, distribution, transportation, storage, sale and use of VPC products, is being implemented by ERMA New Zealand.

Different risks

Because the HSNO and ACVM Acts manage different risks, the ACVM Group continues to have a direct interest in the control of the use of VPC products as agricultural compounds for management of risks under the ACVM Act. ERMA New Zealand will be authorising Test Certifiers to carry out activities that impinge on ACVM Group responsibilities. However, not all VPC products trigger HSNO controls, so the ACVM Group has developed a new standard (see page 4) that includes all of the VPC products and has redesignated them as vertebrate toxic agents (VTAs).

ACVM criteria

The Group has also prepared the following criteria to be included in the ERMA New Zealand authorisation process to be assured that the ACVM requirements are met. Test Certifiers need to have an understanding of:

• the purpose of the ACVM Act;

• what is meant by risks as defined by the ACVM Group for management under the Act;

• the definitions of an agricultural compound, a veterinary medicine and a VTA product;

• risk control areas relevant to the control programme for the approval of VTA product users (competence of users, application of products by users, secure storage of products, documentation, compliance activities).

‘Fit and proper person’

While ERMA New Zealand will authorise Test Certifiers, from 1 July 2004 the only part of the approval process that will be handled by the ACVM Group is the ‘fit and proper person’ component, which is the first step for any person who applies to become an ‘approved handler’. The Group will maintain a database of ‘fit and proper persons’ and supply this information to ERMA New Zealand.

Historical error policy

Early in 2001 the ACVM Group advised registrants that notifications of historical errors in the information held about a trade name product would be sufficient to correct the error. An application to vary a registration may not be necessary if the error did not affect the level of risks posed by the product and it could be corrected without in-depth assessment. Because there was plenty of time before the deadline for updating registration, such changes could be made without updating the registration. The updating could occur later.

The time for updating is rapidly running out. The ACVM Group is processing an increasing number of applications to update existing registrations and there is no time available to change files separately from updating the registration. Therefore, applicants are advised that the policy of correcting historical errors by notification is no longer operational. Any request to adjust the information held on products will have to be in conjunction with an application to update the registration.

Updating products

Please be aware that products submitted for updating as from March are unlikely to be processed by 1 July 2004. The ACVM Group is working through updates as quickly as possible; however, with so many applications coming in at the 'tail end' of the time period, we are getting a huge backlog. Companies must not expect them to be completed within 3 - 4 months because the priorities are general applications and review/evaluation assessments. Your only concern should be getting update applications IN THE DOOR to us on or before 1 July 2004. You are not required to have the PDS, label and certificate of updated products by this date.

PRODUCTS NOT SUBMITTED BY THIS DATE WILL BE ILLEGAL.