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Compliance under the ACVM Act 1997

Twelve submissions have been received on the discussion paper Compliance under the ACVM Act 1997. These submissions are summarised below, with respect to the main issues raised. The comments received will be considered in the development of ACVM policy on compliance.

The main issues covered in the submissions were:

• linkages between the ACVM Act and other legislation (eg HSNO, Meat and Dairy Acts) should be explained with respect to compliance processes and residues;
• a detailed definition of the purpose and scope of compliance activities under the Act is required, including explanations of their justification with reference to sections 55 (Offences) and 75 (Regulations);
• there are strong concerns that off-label use as outlined in the discussion paper will limit the availability of products to producers and add significant costs in the primary sector;
• questions have been raised concerning the legal and practical basis of approving an application from an overseas company that is not a registered company in New Zealand nor subject to New Zealand law;
• greater detail is requested on most sections of the paper, but in particular those sections dealing with accreditations and approvals, off-label use and delegations under the Act.

A full analysis of comments received on the discussion paper, together with a draft of the compliance policy paper, will be prepared and made available for comment.