Off-label use of agricultural chemicals
In Victoria, you must have an off-label permit to use an agricultural chemical:
- at a rate higher than the maximum application rate for that use, as stated on the label
- at intervals more frequent than the intervals for that use, as stated on the label
- in a way that is contrary to any specific label statement (for example, 'DO NOT' statements on the product label)
- if it is a 'restricted use' chemical
- that is an unregistered chemical.
APVMA permits
If you wish to use a chemical off-label in any of these ways, you must get an off-label permit from the Australian Pesticides and Veterinary Medicines Authority (APVMA).
When you apply to the APVMA for a permit, you must include field and laboratory data that supports the use on efficacy, safety and trade grounds.
Low-risk, off-label use
In Victoria, an APVMA permit is not required when using ‘restricted use’ chemical products in low-risk circumstances.
Low-risk off-label circumstances only apply when a registered agricultural chemical product is:
- used at a lower application rate, lower concentration or lower frequency than the label for that use
- to control a different pest than stated on the label
- mixed with another registered chemical
- used in accordance with a label use approved for two or more other states or territories.
The above exemptions do not apply to chemicals used for pest animal control.
A ‘restricted use’ chemical cannot be used in low-risk circumstances if the product label includes critical comments or restraints in relation to geographical location, timing or other restriction that would otherwise prohibit that use at any time or any place or any other specified circumstance in Victoria.
Off-label use at a lower application rate, concentration or frequency may pose a resistance risk during pest management. Resistance management and industry stewardship strategies exist that promote the safe and correct use of chemical products.
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, you must have a permit for off-label use from Agriculture Victoria.
For all other off-label uses of 1080 or PAPP, you must apply for a permit from APVMA.
Permits for off-label use of insecticides on harvested grain
To apply insecticide to stored grain, grain during transit, or immediately before transit by means of a road transport vehicle in an off-label manner, you must have a section 25A permit from Agriculture Victoria.
Check if your chemical is registered
APVMA's Public Chemical Registration Information System database lists all:
- currently registered chemical products
- off-label permits.
Managing residues
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.