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AgVetLink, October 2004

Transfer of veterinary medicines to the HSNO Act

INFORMATION FROM ERMA NEW ZEALAND

Veterinary medicines are being transferred to the Hazardous Substances and New Organisms (HSNO) Act 1996.

Over the last eight months, the Environmental Risk Management Authority (ERMA) has released consultation documents listing the products that will be transferred to HSNO. These documents have dealt with product groupings such as benzimidazole and imidathiazole endoparasiticides, anaesthetics, analgesics etc. The full set of consultation documents is listed on the ERMA New Zealand website

(http://www.ermanz.govt.nz/consultations/index.html).

ALL registrants should check these documents and inform us urgently if there are any products in production and use that have NOT been included.

Email

If a product is not included in any of the documents, please email us (transfer@ermanz.govt.nz). If a product is not listed, it may possibly be because it falls within one of the groups for which a document has not yet been issued. These groups appear at the bottom of the list given on the website. However, if you are in any doubt, please email ERMA regardless, so that we can confirm the exact status of the product.

It is absolutely critical that all products that need to be transferred are covered by one of the consultation documents. If a product is not transferred, it may not be possible to continue to supply and use it at the end of the transitional period without first having obtained a new approval from ERMA.

Incorrect views

We are aware that some registrants believe that a product with ACVM registration does not require HSNO approval. There is also a belief in some industry circles that if a product does not require ACVM registration it does not require HSNO approval. Neither of these views is correct. A product that contains any hazardous component and triggers any of the HSNO thresholds will require ERMA approval regardless of the requirements that may apply under the ACVM Act.

Transfer dates

With the likely exception of feed additives and electrolytes, all veterinary medicines will be transferred to HSNO on 1 July 2005. Feed additives and electrolytes are being processed for transfer differently to other veterinary medicines because the level of HSNO controls for these products is expected to be less in comparison, and because they lend themselves to transfer via a group standard. A group standard approvals pathway is currently being developed as part of an amendment to the HSNO Act. Feed additives and electrolytes will be transferred no later than 1 July 2006.