Document Sample
                   ABN 42 861 675 81                                            Acting ARGA Secretary
                   Registered No. A0015035W                                     Alison Brinson
                                                                                25 White St
                                                                                Silvan, Vic, 3795

8 February 2010

Product Safety and Integrity Committee Secretariat
Innovation, Productivity and Food Security Branch
Department of Agriculture, Fisheries and Forestry
GPO Box 858
Canberra, ACT, 2601

Subject: Discussion paper on a National Scheme for Assessment, Registration and Control of
Use of Agricultural and Veterinary Chemicals

The Australian Rubus Growers Association (ARGA) supports the introduction of a single integrated
national framework for the effective and efficient registration and control of use of AgVet

As the peak industry body representing Australian Rubus growers (growers of raspberry and hybrid
blackberry crops), ARGA is concerned about the impact of some of the proposed changes on a very
minor crop in terms of production area but a very profitable crop. Some of the proposed changes to
the cost of and access to new chemistry, if implemented, would make the industry unviable.

ARGA requests that full consideration be given to the following aspects of the proposed
 Under the current registration scheme, the lack of Australian registration for internationally
   available chemicals for use on minor crops creates many problems and can lead to increased
   environmental and public risk. New products generally involve new chemistry which is by
   development and necessity less risky to public health.
   Economic reality generally means in smaller crops such as Rubus, chemical companies do not
   seek label registration for these minor crops. Growers are faced with using old chemistry that
   can be ineffective due to resistance and is a greater public risk. Older products are generally
   non target specific and do not fit into Integrated Pest Management (IPM) strategies that involve
   biological controls. The costs of generating residue data to support an application to the
   APVMA to obtain a Minor Use Permit, is a great financial impost on industry associations of
   minor crops

   If a full cost recovery model is implemented to cover the costs of processing applications for
    Minor Use Permits, this too, will be a severe impost on small industries. These industries have
    the potential to be expand and increase production, but they must have timely and cost effective
    access to new chemistry.

   If a Minor Use Permit system is to be implemented nationally under a full cost recovery system,
    it seems obvious that the system must be outsourced. The paper states that full cost of a permit
    application is of the order of $2,000 which demonstrates just how inefficient a government
    agency can be. A permit fee of $2,000 would guarantee significant widespread abuse of the

   Given that FSANZ sets food standards for Australia and New Zealand, it is perplexing that New
    Zealand growers have access to a far greater range of modern pest and disease controls than
    Australian growers, particularly for minor crops such as berries. Free trade between Australia
    and New Zealand means that fruit can generally cross borders without food safety concerns.
    Much of the frozen berry market in Australia is supplied by New Zealand. New Zealand
    growers have a competitive advantage over Australian growers in that they can access a greater
    range of more effective, target specific chemicals. These new chemicals are usually available to
    New Zealand growers several years before they become available in Australia.

    It is interesting to note that the discussion paper talks about protocols in UK, USA and Europe,
    but apparently has not investigated how chemicals are regulated and used in New Zealand.
    If small industries do not have access to chemicals those industries may become unviable and
    unable to develop into worthwhile economic industries.

    For example, New Zealand has a proliferation of small crops such as tamarillos, feijoa,
    cherimoya, avocado, boysenberry etc that have developed into significant industries in a country
    with such a small population and have become sizeable contributors to their export economy.

    Lack of an Off-Label Use mechanism in the proposed new Framework is a significant
    impediment to businesses whose crops are classified as “minor crops”.

    Under the current Victorian Control of Use regulations, provided that the chemical is registered
    for use in Australia, Victorian growers of minor crops have been able to gain timely access this
    new chemistry while the APVMA and chemical companies sometimes take years to issue Minor
    Use Permits, by which time New Zealand growers have achieved considerable competitive
    advantage in international markets.

    ARGA urges this Review to investigate the protocols so effectively adopted in New Zealand,
    that enable growers of minor crops to have timely access to new low risk chemicals and thus
    support New Zealand growers in demonstrating world’s best production practices.

    The APVMA should also give serious consideration to adopting New Zealand registrations in
    Australia, given that FSANZ sets food safety requirements for both countries.

   There is considerable scope for improving the efficiency of the APVMA and reducing the cost
    to all industries of generating residue data.
        o Under the Victorian Off-Label Use system, as mentioned in the paper, monitoring has
             shown that the Victorian system is effective in protecting public health.
        o Most berry production comes from farms that operate under Quality Assurance schemes.
             These QA schemes require growers to maintain spray records and regularly test berries
             for chemical residues

    It would seem that there is significant potential to expand the role that independent monitoring
    and Quality Assurance systems play in use of chemicals, training and licensing of operators and
    recording of chemical use. Most Quality Assurance systems cover all of those aspects of
    chemical use. They are independently audited and have widespread adoption. The residue data
    collected by growers, as part of their QA compliance, could be made available for used by the
    registration authority.

    Where operators do not operate under a Quality Assurance system, they could still conform to
    government standards under their own verification procedures. This is not dissimilar to the
    registration required for pest controllers and is an extension of the SA minor use system.

    There is also significant scope for government agencies to access MRL databases, generated by
    the independent residue monitoring programs and by the QA systems. Reports could be collated
    that respected the individual business confidentiality and privacy concerns. This should increase
    public access, transparency and confidence in MRL testing, outcomes and procedures. Most
    producers would be willing to share their residue testing results with a body such as the
    APVMA, provided confidentiality was maintained and the processes involved for non-
    compliance are constructive. These constructive non-compliance processes have been a feature
    of the residue monitoring program in Victoria, for many years.

    Potentially there would also be scope to use the MRL database to add to verification data for
    registration and eventual label registration for minor use crops.

    Given that environmental auditing is on the horizon via Quality Assurance, further scope to
    monitor environmental impact of chemicals is also a possibility.

    A further benefit of the APVMA working with QA auditors is that these businesses are private
    and competitive and therefore outside the realm of unrealistic government cost structure.
    Government’s role would be to dictate the controls required. Quality Assurance auditors would
    enforce the standards set by government.

   Labelling as it applies to chemical application rates and methods can also reduce efficiencies
    and adoption of new technologies. Off-label use with respect to application rates would benefit
    from the same type of regulations that allow off-label use of the chemical. Lower water volumes
    can increase spray efficiencies and reduce spray drift. Attract-and-Kill formulations in
    conjunction with pheromones are being increasingly used. New applications being trailed by
    scientists include fungicide powders being delivered by bees to the exact specific target flowers.
    Registration and hence label information does not always include the most efficient technology

    Label application rates should have sufficient flexibility that they will not limit adoption of
    technologies that reduce risk or increase efficiency.

    Page 33 of the discussion paper states……”growing of specialty crops in intensive horticultural
    areas at the rural-urban interface increases the possibility of negative externalities…..”

    To the contrary it is also logical that the negative externalities would be decreased. Chemicals
    not registered are generally newer chemistry that is more target specific, safer and less harmful
    to humans and the environment. Label application specifications do not always take into
    account the production methods used in intensive horticultural areas eg undercover cropping,
    hydroponics. Again, label application rates need to be sufficiently flexible to cover these
    emerging patterns of use that have lower overall environmental impacts.

   Minor Use Permits are not required in Victoria and as mentioned in the paper, monitoring has
    shown that the Victorian system is effective in protecting public health. A permit system
    detracts significantly from efficiency and in some cases could increase the control of chemicals,
    as stated in the discussion paper.

Australian agriculture will become uncompetitive if technology stagnates. Flexibility, innovation
and adoption of new science and new technology are vital and have been a major contributor to the
reputation of Australian farmers as some of the most efficient in the world. It is important that the
new framework for the control and use of agricultural chemicals does not limit the constant
improvement required by Australian farmers to remain profitable.

1. ARGA supports the maintenance of an Off-Label Use model similar to that operating in
   Victoria and recommends that Off-Label Use, as it applies to Minor Crops, be adopted under the
   proposed new National Scheme so that it is available to all Australian farmers
2. The Control of Use system currently in place in South Australia could be a viable alternative
3. A permit system detracts significantly from the efficient access to new chemistry
4. The new National Scheme could work in partnership with existing Quality Assurance auditing
   processes and harnesses the residue monitoring data already available in the agricultural
5. The new National Scheme must recognize the importance of supporting industries whose crops
   are classified as “Minor” or “Specialty”. It is imperative that growers in these industries have
   affordable and timely access to new chemistry that reduces risk to public health and the

Again, I reiterate that ARGA supports the introduction of a single integrated national framework for
the effective and efficient registration and control of use of AgVet chemicals, provided that there
are adequate safeguards to protect the continued profitability of minor and emerging crops.

ARGA would be pleased to elaborate on any of the above points. Please contact the ARGA
Secretary, by phone or email.

Yours faithfully,

Stephen Chapman                                             Alison Brinson
Vice-President                                              Acting ARGA Secretary