All substances that fit the definition of agricultural and veterinary chemicals under the Chemical and Veterinary Chemicals Code Act 1994 must be registered by the National Registration Authority before they can be supplied, sold or used in Australia. In addition, any produce derived from livestock that has been treated with such substances must comply with Maximum Residue Limits as specified in Part 14 of the ANZFA Food Code.
The cost of generating data and assembling submissions for registration of substances is high. Aquaculturists frequently suffer from a lack of legal access to livestock protection products. The problem is hath whilst their produce is valuable, the industries are too small individually for agrochemical or veterinary companies to bear the high cost of registering products for use on them.
Growers affected by the problem are increasingly trapped in a situation where they face severe losses from pests and diseases if they do nothing to protect their fish, or have their produce rejected by the marketplace if they use a product that is not registered. Poor publicity arising from such occurrences would severely damage the "clean and green" image that the industry wishes to a project. The lack of access to registered products that employ new technologies is also likely to hamper the competitiveness and sustainability of the industry in the future.
There is a need to establish a system in which the needs of the aquaculture industry sectors are met on a continuing basis through industry consultation, cost sharing and efficient project direction and execution.
Final report
This project was preceded by Project 96/314 “Registration of Aquaculture Chemicals”, which was conducted to identify the most appropriate and industry-accepted drugs and chemicals for each sector of the aquaculture industry, to maximize the cost-effectiveness and efficiency of the registration processes, and to establish registration of key drugs. This project was designed to establish a system that will serve the ongoing needs of the aquaculture industries.
The minor use system developed by CPA Research for horticulture was used as a model for an aquaculture-specific system in which industry sectors identify and prioritise their needs for veterinary chemical products and pass them to an appointed consultant co-ordinator. The individual items are analysed by the consultant in terms of the availability of alternatives, environmental considerations etc. and, where possible, combined with similar requests from other industries. The data requirements for a registration/permit are determined in consultation with the APVMA, and the items are costed and passed back through NAC in the form of proposals for funding.
Ongoing maintenance of the system would be contracted by the NAC to a suitable consultant.
Pilot projects included the consolidation of existing and expired permits for formalin into a single permit for aquaculture industries, permits for hydrogen peroxide and for benzalkonium chloride.
The system is not yet fully operational, because issues in regard to ongoing funding through NAC are still being resolved. Questions regarding intellectual property and the legal liability for misuse are being considered by the NAC. The NAC also has yet to resolve issues concerning administration of the chemical registration process in regard to cost recovery.
