Off-label use of agricultural chemicals
In Victoria, no permit is required to use an agricultural chemical off-label, provided the following constraints are complied with:
- The product is NOT a 'restricted use' chemical.
- The chemical is NOT used at a rate higher than the maximum application rate for that use, as stated on the label.
- The chemical is NOT used at intervals more frequent than the intervals for that use, as stated on the label.
- The chemical is NOT used contrary to any specific label statement (e.g. 'DO NOT’ statements).
If you wish to use a chemical off-label contrary to the constraints listed above, you must obtain an off-label permit from the Australian Pesticides and Veterinary Medicines Authority (APVMA).
Users cannot apply a veterinary chemical product to a plant, place or thing unless they have been issued an appropriate permit.
An APVMA off-label permit is required to use:
- an agricultural chemical contrary to the constraints listed above
- an unregistered chemical or
- a ‘restricted use’ chemical in any way that is not listed on the chemical product label.
To apply for a permit, an application must be submitted to the APVMA which includes field and laboratory data that supports the use on efficacy, safety and trade grounds.
The APVMA website has a searchable database for all currently registered chemical products, off-label permits and maximum residue limits (MRLs).
Permits for off-label use of 1080 and PAPP
To use pest animal bait products containing 1080 or PAPP contrary to the Directions for the use of 1080 and PAPP pest animal bait products in Victoria, a section 25A permit from Agriculture Victoria is required.
One of the main issues with using a chemical off-label relates to the ability to manage chemical residues in treated produce.
When a chemical is used off-label, how it interacts with the crop being treated, and how long it will take before the residue reaches an acceptable level is unknown.
As there is a greater likelihood that produce treated off-label will contain unacceptable residues, care must be taken to manage residue risks.
Agriculture Victoria recommends that growers confirm the residue status of their produce through pre-harvest residue testing by an accredited laboratory.