discussion paper - agricultural veterinary chemicals ... · web viewhormonal growth promotants...

Review of the Agricultural and Veterinary Chemicals (Control of Use) Act

DISCUSSION PAPERAugust 2018

DEPARTMENT OF PRIMARY INDUSTRY AND RESOURCES

INDEX1 INTRODUCTION..............................................................................................................................................21.1 PURPOSE OF DISCUSSION PAPER.......................................................................................................................21.2 PROCESS..............................................................................................................................................................21.3 HOW TO MAKE A SUBMISSION...........................................................................................................................22. BACKGROUND................................................................................................................................................42.1 REVIEW OF THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT...........................42.2 PURPOSES OF THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT......................42.3 OPERATION OF THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT.....................52.4 ADMINISTRATION OF THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT...........63. CONSULTATION ISSUES..............................................................................................................................73.1 SCOPE OF THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT.............................73.2 RESPONSIBILITIES UNDER THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT. . .93.3 PUBLICLY AVAILABLE DATA UNDER THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF

USE) ACT..........................................................................................................................................................103.4 LICENSING FEES UNDER THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT. . .103.5 ADOPTION OF NATIONAL LEVEL ARRANGEMENTS UNDER THE AGRICULTURAL AND VETERINARY

CHEMICALS (CONTROL OF USE) ACT.............................................................................................................113.6 SPRAY DRIFT UNDER THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT.........123.7 SECTION 58 (2) (C) AND 58 (2) (D) COMMENCEMENT UNDER THE AGRICULTURAL AND VETERINARY

CHEMICALS (CONTROL OF USE) ACT.............................................................................................................133.8 PILOT LICENSING UNDER THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT. .123.9 HORMONAL GROWTH PROMOTANTS (HGP)..................................................................................................133.10 CONTROL AND USE OF VERTEBRATE POISON................................................................................................143.11 OTHER IMPROVEMENTS TO THE AGRICULTURAL AND VETERINARY CHEMICALS (CONTROL OF USE) ACT

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DEPARTMENT OF PRIMARY INDUSTRY AND RESOURCES Page 1 of 19


1 INTRODUCTION

1.1 Purpose of discussion paper

A review of the NT Agricultural and Veterinary Chemicals (Control of Use) Act (the Act) is proceeding in 2018. The purpose of this paper is to direct discussion about a number of themes and issues previously raised by stakeholders relating to the purpose and provisions of the Act, and to elicit public comment on these themes and issues.

The suite of issues documented in this paper is not intended to be exhaustive, and commentators are invited to identify other themes and issues in their submissions.

1.2 Process

Policy options and recommendations for legislative change may be further developed by the Department of Primary Industry and Resources (DPIR) from the submissions received. Further consultation (either broad or targeted) may be necessary, depending on the level of complexity or the scope of any proposed changes to the Act.

1.3 How to make a submission

Anyone can make a submission. It can be as short and informal as a letter or email, or it can be a more substantial document. A submission does not have to address all of the themes and issues identified in the paper, nor is it required to be confined to the themes issues identified in the paper. Electronic copies of submissions should also be sent whenever possible. Submissions will be publicly available unless clearly marked as “confidential”.

Submissions should be sent to:

Chemicals CoordinatorDepartment of Primary Industry and ResourcesGPO Box 3000DARWIN NT 0801

Or by email to [email protected]

Closing date for submissions is 30 September 2018.

Any submission, feedback or comment received by DPIR will be treated as a public document unless clearly marked as ‘confidential’. In the absence of a clear indication that a submission, feedback or comment is intended to be confidential, the submission, feedback or comment will be treated as non-confidential.

Non-confidential submissions, feedback or comments may be made publicly available and published on the Northern Territory Government website, from



which content and quotes may be drawn or referred to in reports for the purpose of the review of the Act, which may also be made publicly available.

Any requests made to DPIR for access to a confidential submission, feedback or comment will be determined in accordance with the NT Information Act.

Note: Although every care has been taken in the preparation of the discussion paper to ensure accuracy, it has been produced for general guidance only to persons wishing to make submissions to the review. The contents of the paper do not constitute legal advice or legal information and they do not constitute Government policy documents.



2. BACKGROUND

2.1 Review of the Agricultural and Veterinary Chemicals (Control of Use) Act

The Agricultural and Veterinary Chemicals (Control of Use) Act (the Act) has not been significantly reformed since 2004, at which time it was primarily amended to firmly resolve that the states and territories are responsible for the control of use of agricultural and veterinary chemicals, and to introduce the regulation of fertilisers and stockfoods into the Act.

The Act has been operating effectively since this time in providing a one-stop shop for the regulation of agricultural and veterinary chemical products, fertilisers and stockfoods in the Northern Territory (NT), in conformance with nationally agreed principles informed by the Agricultural and Veterinary Chemicals Code Act 1994 (Cwlth) [Agvet Code]. The Agvet Code is adopted in the Northern Territory as the Agvet Code of the Northern Territory.

The legislation has a continuing relationship to parallel activities in the Medicines Poisons and Therapeutic Goods Act administered by the NT Department of Health and also on the conduct of persons registered through the Veterinarians Act

The Act is included in the regulatory reform agenda under the Northern Territory Government’s Economic Development Framework that aims to provide a globally competitive environment to attract private sector investment and sustainable development, also to simplify the process of transacting with government. Specifically this refers to improved flexibility around key components of the 1080 Wild Dog Management Program.

More broadly, a review will inspect the contemporary capacity of the Act to govern and regulate the use of chemicals in the NT, including consideration of its current scope and functions. Food safety is a key driver for Australia’s market competitiveness. The NT must ensure it is managing the risk of chemical residues and environmental contaminants in animal and plant products, to maintain its reputation as a producer of clean safe food and facilitate access to markets. Due to the passage of time since the 2004 amendment, this review seeks to respond to changes in national codes of practice. It also provides an opportunity to scrutinise and modernise offence provisions to ensure compliance with Part 2AA of the NT Criminal Code.

The review of the Act is being conducted on behalf of DPIR by the Chemicals Coordinator who leads the chemical services program within the Biosecurity and Animal Welfare Division of the Department.

2.2 Purposes of the Agricultural and Veterinary Chemicals (Control of Use) Act

Section 3 of the Act provides for Purposes.



(1) The purposes of this Act are:

(a) to impose controls relating to the possession, sale, use and application of chemical products, and the manufacture, sale and use of fertilisers and stockfoods, that ensure sustainable agriculture by protecting:

(i) the health of the general public and the users of those substances;

(ii) the environment;

(iii) the health and welfare of animals; and

(iv) domestic and export trade in agricultural produce; and

(b) to promote the harmonisation of legislation in Australia controlling the use of chemical products by regulating the possession and use of those products in accordance with labels and permits under the Agvet Code.

(2) The controls referred to in subsection (1)(a) include the following:

(a) the prohibition and regulation of the possession and use of chemical products, including the prescription and supply of chemical products by veterinarians and pharmacists;

(b) the regulation of ground and aerial spraying and the use of S7 chemical products;

(c) the declaration of chemical control areas and agricultural emergencies;

(d) the management of land and agricultural produce contaminated by chemicals.

2.3 Operation of the Agricultural and Veterinary Chemicals (Control of Use) Act

The Australian Pesticides and Veterinary Medicines Authority (APVMA) administers the Agvet Code on behalf of the states and territories, and is responsible for the evaluation, registration and control of agricultural and veterinary chemical products to the point of sale in Australia. The Agvet Code applies as a law of the NT as part of the cooperative statutory scheme. It is a state and territory responsibility to control the use of agricultural and veterinary chemical products, stockfoods and fertilisers.

Consequently, NT agricultural and veterinary chemicals legislation is harmonised to a great degree in adopting nationally agreed principles for control of use of agricultural and veterinary chemicals and agreed maximum levels of heavy metal



impurities in fertilisers (with some minor variations). The governance of the Act uses definitions that are consistent with those in the Agvet Code. Similarly, the regulation of the use of agricultural and veterinary chemical products is consistent with the APVMA risk management processes.

Part 2 of the Agricultural and Veterinary Chemicals (Control of Use) Act provides for general duty of care principles relating to chemical use and safety of fertilisers and stockfoods, and non-compliance carries significant penalties.

The Act is, in the main, designed to be self-regulating in so far as it sets out fairly prescriptive rights, responsibilities and processes.

2.4 Administration of the Agricultural and Veterinary Chemicals (Control of Use) Act

General and financial administration of the Act is allocated to the Minister for Primary Industry and Resources, and the Department of Primary Industry and Resources as the relevant agency. Under section 85 of the Act, the Minister must appoint a Chemicals Coordinator whose functions and powers are prescribed in the legislation to enable the administration of the Act, perform functions under the Agvet Code and provide a communication channel with the APVMA about the administration and enforcement of the Agvet Code. Additionally the statutory position may have other functions conferred by another law of the Territory. Importantly, the Chemicals Coordinator may give a person a written direction to take specified action, or to stop or not commence a specified action on the grounds of protecting human health, the environment or domestic or export trade.

The Chemicals Coordinator may delegate in writing to a person any of his or her powers under the Act or another Act (section 89).

The Chemicals Coordinator may appoint Chemical Advisers. A Chemical Adviser has several powers under the Act to enter premises (section 94), inspect premises (section 95), seize substances or things (section 96), retain substances or things (section 97), exercise the power of an inspector under the Livestock Act (section 98) and investigate complaints (section 99), amongst others. The Chemicals Coordinator is a Chemical Adviser under the Act.



3. CONSULTATION ISSUES

3.1 Scope of the Agricultural and Veterinary Chemicals (Control of Use) Act

The Department is seeking comment on the scope of the legislation. The current description of the Act is “An Act to control the use of agricultural and veterinary chemicals and the manufacture, sale and use of fertilisers and stockfoods, to manage land and agricultural produce contaminated by chemicals, and for related purposes”.

Section 3 of the Act (Purposes) expands on the description and appropriately uses definitions that comply with the Agvet Code, such as chemical product means an agricultural chemical product or veterinary chemical product, and substance has the same meaning as in section 3 of the Agvet Code1.

Pursuant to subsection 3(1)(a) of the Act, controls are specific to the possession, sale, use and application of chemical products, and the manufacture, sale and use of fertilisers and stockfoods. Further, subsection 3(2)(d) refers to the management of land and agricultural produce contaminated by chemicals specifically in relation to the controls referred to in subsection 3(1)(a).

In the NT there has been a small number of instances where agricultural produce has been contaminated by environmental pollutants giving rise to exceedance of Maximum Residue Limits (MRL) that are regulated by national food standards. Specifically this refers to exposure to heavy metals (such as lead or mercury) found in soil or accessed from waste dumps. There is minimal tolerance for such contaminants making their way into the food chain, and this issue also raises questions about legislating controls over other harmful environmental contaminants that could affect the safety of agricultural produce. These pollutants may be broadly defined as industrial or mining waste or naturally occurring, including radioactive material.

Heavy metals do not fall under the definition of chemical product as registered for agricultural or veterinary purposes under the AgVet Code, nor under the mirror definition in the NT Act. As chemical product has a general meaning as an accepted product with remedial qualities, a heavy metal such as lead would be generally counterintuitive to the purposes of the current Act. The legislative

1 substance includes:

(a) any gas, liquid, mixture or compound of gases, or mixture or compound of liquids; and

(b) an organism or part of an organism, including a genetically manipulated organism or part of a genetically manipulated organism; and

(c) material that is produced from an organism; and

(d) matter whose production involves the use of an organism;

but does not include an excluded organism or part of an excluded organism, or material that is produced from, or matter whose production involves the use of, an excluded organism.



instrument ‘Agricultural and Veterinary Chemicals Code Instrument No. 4 (MRL Standard) 2012 (MRL Standard) does not include heavy metals in any of its Tables and its references to extraneous residue limit (ERL) are limited to substances in accordance with the AgVet Code definition.

The instrument ‘Australia New Zealand Food Standards Code – Standard 1.4.1 – Contaminants and natural toxicants’ is a standard under the Food Standards Australia New Zealand Act 1991 (Cth). The code sets out levels of contaminants and natural toxicants in food, and the corresponding Schedule 19 includes maximum levels (ML) of metal contaminants in section S19—4 of the Schedule (www.legislation.gov.au/Details/F2017C00333).

Arguably, the control of contamination by environmental pollutants has its place in biosecurity or environmental protection legislation for the live animal and n horticultural products. For example Queensland uses the Chemical Usage (Agricultural and Veterinary) Control Act to control the use of agvet chemical products, but its Biosecurity Act 2014 includes the management of risks associated with biological, chemical and physical contaminants in carriers, including heavy metals and other waste materials. The NSW Biosecurity Act 2015 also contains provisions in relation to animals or plants chemically affected by a ‘non-living’ contaminant to the point of unsuitability for sale, export or human consumption.

At this point in time the NT has not commenced a broad-ranging review of its agricultural biosecurity legislation, the Livestock, Plant Health and Fisheries Acts. Biosecurity is relevant where there is economic impact as a result of chemically affected livestock or horticulture that is unfit for sale, or export for human consumption; however this is also picked up in subsection 3(1)(a)(iv) of the Agricultural and Veterinary Chemicals (Control of Use) Act. Views are sought on expanding the scope of the Act to provide for the regulation of controls for environmental contaminants such as heavy metals where they affect the safety of edible plant and animal produce.

A provision for control of the presence of substances other than chemical products, fertilisers and stockfoods could be introduced into the purposes of the Act, noting that the description of the Act could potentially remain unchanged. This change would impact definitions and other provisions in the Act, complementing the process of contemporising and standardising all aspects of the Act.

1. Should the Agricultural and Veterinary Chemicals (Control of Use) Act reference Australian Food Standards when enacting powers in relation to Maximum Residue Limits, further providing for the regulation of environmental contaminants such as heavy metals where they affect the safety of agricultural produce that may enter the food chain?

2. In considering expansion to the scope of the Agricultural and Veterinary Chemicals (Control of Use) Act to include controls over environmental contaminants where they affect the safety of agricultural produce, in what way should the legislation interact with NT legislation such as the


http://www.legislation.gov.au/Details/F2017C00333


Livestock Act, Plant Health Act, Waste Management and Pollution Control Act, Pastoral Land Act, Land Title Act and others.

3. In considering expansion to the scope of the Agricultural and Veterinary Chemicals (Control of Use) Act to include controls over environmental contaminants, what contaminants should be included as relevant to product integrity and why?

3.2 Responsibilities under the Agricultural and Veterinary Chemicals (Control of Use) Act

Part 2 of the Act provides for general duties, which require a person to ensure harm does not result from the use of chemical products, fertilizers or stockfoods, and that inputs manufactured elsewhere are safe for use.

The Department is aware of various industry and commercial-based accreditation and testing programs through the supply chain. It does not currently undertake residue surveys on its own behalf and the National Residue Survey does not cover many of the relevant produce streams into interstate markets and wholesalers.

The data from some programs has identified occasions when chemical resides have exceeded the MRL or where chemicals have been used on or contaminated produce where there is no approval for use or permit in place. Examples have included the exceedance of permethrin on mango fruit, a key NT product. As the data collected by these programs is proprietary there is no explicit right to access this information.

The time between sample collection, data analysis and third party assessment can be critical to maintaining good farm practices.

A point for discussion is whether data collected by an individual or an organisation relating to an exceedance of an MRL for produce consigned for sale, should be reported to the Department (notification), and in what timeframe.

4. Should MRL ‘exceedance reporting’ by external operators be a requirement of the Agricultural and Veterinary Chemicals (Control of Use) Act and are there any specific barriers from a commercial viewpoint?

5. What reporting requirements could the Department consider introducing to support the general duties of care prescribed in Part 2 of the Agricultural and Veterinary Chemicals (Control of Use) Act?

6. How else could the Agricultural and Veterinary Chemicals (Control of Use) Act be improved from a risk management perspective to give



consumers confidence in the safety of our primary produce?

3.3 Publicly Available Data under the Agricultural and Veterinary Chemicals (Control of Use) Act

The Act provides the statutory authority for the Department to issue licenses and authorisations to applicants under various sections of the Act, including section 48 (possession or use of restricted chemical products), section 49 (possession or use of S7 chemical products), section 57 (ground spray businesses must be licenced), section 58 (ground spray applicators must be licenced), section 59 (aerial spraying businesses must be licenced) and section 60 (pilots carrying out aerial spraying must be licensed).

The Department maintains a database of licenses and authorisations, including applicant information, applicant training records, property details, chemical approvals, chemical allocations (where mandated) and the term or expiry date of a license or authorisation.

License or authorisation data has potential commercial use to suppliers of chemicals, for the purpose of verifying a client’s license or authorisation, and business data could benefit the general community who often approach the Department seeking knowledge on approved service providers.

7. Should license and authorisation information be made available to chemical suppliers and the general public and to what extent?

8. Should any regulatory provisions apply over and above those of the Information Act, including exemptions? https://legislation.nt.gov.au/en/Legislation/INFORMATION-ACT

3.4 Licensing Fees under the Agricultural and Veterinary Chemicals (Control of Use) Act

The Department has not implemented a fee structure for the issuing of licenses at this time with the exception of the Pest Animal Management Authorisation and Permit to Take or Interfere with Wildlife (PAMA and Permit) which is a charge gazetted under the NT Parks and Wildlife Conservation Act.

The NT Department of Health issues Schedule 7 Authorisations and Pest Management Technician Licenses with a fee of 50 revenue units per year (2018/19 - $59).



9. What considerations for should be taken into account for the issue of licenses and authorisations under the Act?

10. To what extent should any fees be applied?

3.5 Adoption of national level arrangements under the Agricultural and Veterinary Chemicals (Control of Use) Act

There is capacity in the legislation (Section 128) for the adoption of Codes of Practice for use of chemical products. Section 128 (6) requires the Minister to give notice of a proposal and invite comment. Advice received from stakeholders about the Code of Practice in question will fulfil the legislated process to procced with the preparation of a final proposal that may be approved by the Minister for gazettal.

Since 2015 the National Code of Practice for Fertiliser Description and Labelling has been considered for gazetting and has been supported by the NT Government. In the absence of any critical faults identified by stakeholders the incorporation is proposed as an outcome of this consultation.

A national code of practice allows for consistent information to be provided to users of fertilisers in all Australian jurisdictions. Description and labelling of fertilisers provides users with important information on nutrient content and form that enables informed decision making on use rates, application methods and timing. These decisions can have significant impacts on productivity and on losses to the environment. Users are also provided with information on impurities that may result in food safety or environmental problems if fertilizer products are used inappropriately.

State and Territory Acts and regulations contain provisions for important food safety and environmental controls such as the setting of maximum permissible concentrations for certain impurities.

In addition, the Department has a Code of Practice for the Handling of Pesticides information sheet and is engaged in developing a Code of Practice for Spraying Activities.

11. What objections are there to the National Code of Practice for Fertilizer Description and Labelling being gazetted?

12. Should the National Code of Practice for Fertilizer Description and Labelling or any other code be enforceable by regulation?

13. What Codes of Practice for use of chemicals would you like adopted in the Northern Territory?



3.6 Spray Drift under the Agricultural and Veterinary Chemicals (Control of Use) Act

The majority of correspondence received and issues investigated in regards to the Act relate to spray drift and its alleged impact on amenity. It is particularly an issue in rural residential settings and public complaints mainly refer to alleged impacts on the health and welfare of humans and pets, the safety of edible plants grown for domestic consumption, the vigour of general garden plants, fears of water contamination and distasteful chemical smells. Section 56 of the Act limits offences to agricultural chemical spraying that injuriously affects plants and stock with a commercial value.

Sections 57–60 of the Act provide protections to manage the risk of unwanted impacts, through a suite of licensing provisions to ensure only authorised businesses or persons carry out the activity of ground or aerial spraying.

14. Do sections 56-60 of the Act provide appropriate controls for spray drift activities for potential impacts on commercially produced plants and animals?

15. Is the Agricultural and Veterinary Chemicals (Control of Use) Act the most suitable legislation to address other potential impacts caused by agricultural chemical spraying, that could be broadly classified as environmental or nuisance impacts? (noting that section 12 of the NT Waste Management and Pollution Control Act contains provisions around a general environmental duty)

16. What could “Damage by Spray drift” mean in revised section 56 provisions?

3.7 Pilot Licensing under the Agricultural and Veterinary Chemicals (Control of Use) Act

In recent times the use of unmanned aerial vehicles (UAV) has increased to allow serviceability and availability to apply agricultural chemicals using these methods.

The Harmonisation of Agvet Chemicals Control of Use Task Group (HACCUT) assists the Agriculture Senior Officials’ Committee (AGSOC) in developing and implementing policies to harmonise control-of-use requirements for agricultural and veterinary (agvet) chemicals.

HACCUT has developed and provided guidelines to the minimum training and licensing requirements of persons wanting to use UAV technology.

Amendments to sections 60, 62 and 63 (5) of the Act are to be considered to reflect that licenses for aerial spraying may be issued to operators of UAV that may not necessarily have a commercial pilots license.



17. Are there any changes to Pilots Licensing that should be considered?

3.8 Section 58 (2) (c) and 58 (2) (d) Commencement under the Agricultural and Veterinary Chemicals (Control of Use) Act

When it was last significantly reviewed, the Act added provisions for classes of ground spray applicators that have not yet commenced, namely:

(c) a person who carries out pest control operations on behalf of a public authority; or

(d) a person who uses an agricultural chemical product to treat turf on a sporting ground or other recreational area, other than a person who uses the product in a container of a type and size normally purchased from retail outlets by members of the public.

18. Do these classifications remain appropriate for inclusion in section 58?

19. Are there any additional occupations using agricultural chemicals that may need to be considered for licensing?

3.9 Hormonal Growth Promotants (HGP)

The Department invites discussion on the reporting requirements and legislative requirements on the use of Hormonal Growth Promotants.

The Stock (Control of Hormonal Growth Promotants) Act was repealed in 2006 on the commencement of the Livestock Act. General provisions of the marking of cattle (and marking for HGP use) are covered within the Livestock Act.

General record keeping under the Agricultural and Veterinary Chemicals (Control of Use) Act requires chemical use information to be kept for two years. This two year timeframe may not be satisfactory for meeting the requirements for identifying cattle on which HGP have been used and so specific regulation could be developed to maintain records for animal identification and for making false declarations.

20. How can HGP use be captured by the legislation?

21. Would the current legislated requirements for keeping information



be satisfactory for the use of HGP?



3.10 Control and Use of Vertebrate Poison

A range of vertebrate poisons are used in the NT including sodium fluoroacetate (commonly known as 1080).

The ‘Directions for Use for 1080 for Wild Dogs’ published by the Department is the guiding document for people who wish to access and use this chemical in the NT

https://nt.gov.au/industry/agriculture/farm-management/controlling-pest-animals-wild-dogs-with-1080-poison

The Direction is issued by the Chemicals Coordinator in accordance with section 87 of the Act.

Access to vertebrate poison is generally controlled by the volume of concentrate or the number of baits available to use in relation to large animals such as cats, foxes, pigs and dogs.

At this time, the maximum allocation of vertebrate poison a property may have for wild dogs is calculated through an area assessment. The historical formula is “area in km2 divided by three and multiplied by two”. (eg an area 3000km2 could be Authorised to acquire 2000 doses annually).

Some Authorisations are currently in place where the allocation may approach the maximum permitted allowable 10 baits per km2.

A Pest Animal Management Authorisation and Permit to take or interfere with wildlife (PAMA and Permit) is the essential document authorising the use of 1080 under strict requirements. PAMA and Permit Holder must complete the appropriate training, supervise people involved in the preparation of vertebrate poison baits, notify baiting programs to stakeholders, manage the materials involved and adhere to specific record keeping.

Each Authorisation allows for a maximum amount to be acquired or used on a calender year basis, and currently a PAMA and Permit is issued for five years.

The minimum size container of 1080 vertebrate poison commercially available is 120ml. As the vertebrate poison may not be fully utilised on a single occasion it is common for stocks up to this volume to be carried over on properties for some months.

The Chemicals Coordinator may make reviewable decisions, such as the allocation of vertebrate poison. An affected person for a reviewable decision may apply to the Local Court for a review of the merits of the decision

22. Are there additional Directions that can be developed to guide the use of vertebrate poisons?

23. Are there any recommendations that can be made about storage





and handling of vertebrate poisons?

3.11 The Regulation of Manufactured Pet Foods

The Northern Territory Meat Industries Act and Meat Industry Regulations are in place to oversee the production of pet meat from the fresh, chilled or frozen body, carcass, flesh or other products derived from an animal that is intended to be fed to pets.

No complementary requirement for manufactured pet foods is outlined in the Act and no reference is made to codes of practice.

The Australian Standard for the Manufacturing and Marketing of Pet Food, AS 5812-2011 is currently voluntary for Pet Food Industry Association of Australia Inc. members, but compliance is strongly encouraged.

24. What additional measures may be taken to control the manufacture and supply of pet foods in the Northern Territory?

25. Could the regulation of pet food have a place in agricultural and veterinary chemicals legislation?

NB: On 20 June 2018, the Senate moved that the following matters be referred to the Rural and Regional Affairs and Transport References Committee for inquiry and report by 30 August 2018: Possible regulatory approaches to ensure the safety of pet food, including both the domestic manufacture and importation of pet food.

3.12 Other Improvements to the Agricultural and Veterinary Chemicals (Control of Use) Act

The Department welcomes consultation in regards to the overarching operation of the legislation and invites notification of other topics for consideration.

Experiences from the operation of complementary legislation in other jurisdictions is of use.

References

Agricultural and Veterinary Chemicals (Control of Use) Act

https://legislation.nt.gov.au/Legislation/AGRICULTURAL-AND-VETERINARY-CHEMICALS-CONTROL-OF-USE-ACT

Agricultural and Veterinary Chemicals (Control of Use) Regulations





https://legislation.nt.gov.au/Legislation/AGRICULTURAL-AND-VETERINARY-CHEMICALS-CONTROL-OF-USE-REGULATIONS




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