Chemical Industry News
No. 78 2015
Inside

Crackdown on poor record keeping

Fruit contamination case provides reminder to manage residues

What are ‘restricted use’ chemicals?

Dithiocarbamates and stone fruit

Preventing sheep meat carcass contamination

Protecting bees from pesticides

Using pindone pest animal baits in Victoria

Aluminium phosphide in grain transportation

Cancellation of fenthion
Off-label pyraclostrobin use raises market concern
Neil Harrison, Chemical Standards Officer
The Department of Economic Development, Jobs, Transport and Resources (DEDJTR) is warning growers who treat broccoli
with chemical products containing the active ingredient, pyraclolstrobin, to manage any resulting chemical residues.
While the use is permitted under Victorian’s off-label chemical use legislation, growers must ensure treated produce is free from
unacceptable residues to maintain market access. There is currently no maximum residue limit (MRL) for pyraclostrobin in
broccoli, hence any detection of this chemical violates MRL standards and requires investigation.
There are no approved label directions for the use of pyraclolstrobin on broccoli, however since it is not a ‘restricted use’
chemical, it can be used off-label in Victoria providing the maximum label rate is not exceeded, prohibitive statements (i.e. DO
NOT’s) are followed and the label’s frequency of use (i.e. the number of applications of chemical to a crop) is not exceeded. An
Australian Pesticides and Veterinary Medicines Authority (APVMA) permit is required to use a registered chemical contrary to
these rules. Visit http://apvma.gov.au for information on off-label permits and MRLs.
During 2014, several reports of unacceptable pyraclolstrobin residue detections were investigated by Authorised Officers. The
most common use was to control ‘white blister’ on broccoli, which can impact the aesthetics and marketability of broccoli and
lower its value. Severe infestations can render crops unsaleable.
DEDJTR recommends growers conduct chemical residue testing of produce to ensure
their off-label use does not result in unacceptable residues, making sure to include
pyraclostrobin in the testing screen.
DEDJTR also reminds growers that under section 52AA of the Agricultural and Veterinary
Chemicals (Control of Use) Act 1992 it is a breach of legislation to sell or offer for sale
contaminated agricultural produce.
For further information on white blister treatments, contact your local agronomist or
chemical reseller. Information on off-label chemical use is available at www.depi.vic.gov.au/chemicaluse
Chemical Industry News - No 78 2015
Crackdown on poor record keeping
Steven Field, Statewide Specialist - Chemicals
The Department of Economic Development, Jobs, Transport and Resources (DEDJTR) is taking stronger enforcement action on
individuals found not complying with record keeping requirements. Recently, the former Department of Environment and Primary
Industries (DEPI) issued five infringement notices to chemical users for failing to keep the required records of agricultural
chemical use.
Keeping agricultural chemical use records is not only a legal requirement in Victoria; it is
also best practice for growers. Good record keeping provides useful information that can
assist users with their business, allows users to keep track of chemical use and can
demonstrate that a duty of care was taken when applying chemicals, which also provides
a good defence if facing accusations of misuse (e.g. spray drift of chemicals onto
neighbouring crops or houses). In addition, with pesticide resistance management
strategies of increasing importance to growers, good record keeping also makes rotating
through different Modes of Action easier.
The main issues found related to recording wind speed and direction, use of full product
trade name and application rate. Some growers only recorded incomplete trade names,
e.g. copper, which does contain sufficient information to allow the individual product used
to be identified. Other growers were found recording the quantity of chemical applied, but
not the application rate, which should be recorded as per the label e.g. 100ml/100L.
It is compulsory to record the following records within 48 hours of using an agricultural chemical product, and keep these
records for two years from the date of use.
1. Product trade name
2. Date the product was used*
3. Application rate of the product
4. Crop/commodity that was treated (e.g. pasture, apples) or the situation in which the product was applied (e.g.
roadway, channel spraying)
5. Extent of use (the area of land treated, or the volume of water treated, or the volume of stored commodity
treated, or the weight of the commodity treated)*
6. Specific location where the product was used (e.g. paddock name)
7. Name and address of the applicator/supervisor
8. Name and address of the person for whom the application was carried out
9. Wind speed and direction at the time of application**
If using products that are poison baits intended for pest animal control (e.g. 1080 or pindone baits), two additional
records are required:
10. Date the baiting period began***
11. Date the baiting period ended***
* not required when using poison baits for pest animal control
** only required where a product is being sprayed outdoors (excludes hand-held devices that are operated
manually e.g. knapsacks)
*** only required when using poison baits for pest animal control.
There are also record keeping requirements which apply to individuals who use certain veterinary chemical products to treat
stock animals. Information on veterinary chemical use records can be found on www.depi.vic.gov.au/chemicaluse
Chemical Industry News - No 78 2015
You can keep records in a format that suits your individual business (e.g. hand written, computer generated, included in your
quality assurance program records). The only requirements are that they contain all the required information, are clear, accurate
and must be readily available to a DEDJTR authorised officer upon request.
For more information on agricultural chemical record keeping and downloadable record keeping templates, visit
www.depi.vic.gov.au/chemicaluse
Fruit contamination case provides reminder to manage residues
Steven Field, Statewide Specialist - Chemicals
The successful prosecution of a Kyabram fruit grower last September for selling contaminated quince provides a timely reminder
for growers to ensure they use agricultural chemicals correctly to minimise any chance of unacceptable chemical residues
occurring.
The investigation conducted by the former Department of Environment and Primary Industries found the grower had applied a
registered product containing propiconazole to the quince. As there was no maximum residue limit (MRL) set for propiconazole
in quince or pome fruit, the residues detected were unacceptable, and the produce was defined as ‘contaminated’ under the
Agricultural and Veterinary Chemicals (Control of Use) Act 1992.
Unacceptable residues may impact on human health and market access and could have serious repercussions for trade
markets, both domestic and international. Managing chemical residues is essential, especially where a chemical has been used
off-label.
Off-label use refers to situations when an agricultural chemical is used in a manner that is not specified on the chemical’s
product label. Examples of off-label use include when a chemical is used to control a different pest or to protect a different crop,
at a different rate, or in a different manner to that listed on the label.
Penalties may be imposed on growers found selling produce that is contaminated with unacceptable chemical residues.
The Kyabram grower was given a two year good behaviour bond without conviction and was required to contribute $1000 to the
court fund for the breaches in the Melbourne Magistrates’ Court recently. The court also ordered that the accused pay service
costs.
Simple methods growers can use to minimise the risk of contaminating produce include:

Always use a chemical product that is registered for the intended use.

Read and follow the label directions for use.

Check for, and comply with any withholding periods (WHPs) and use restrictions detailed on the label. A WHP is the
minimum length of time that must elapse between the last application of an agricultural chemical to a crop and the
harvest, sale or use of the agricultural produce to which the chemical was applied.

Use analytical chemical testing to check treated produce for unacceptable chemical residues.

Manage the risk of chemical spray drift.
The Department of Economic Development, Jobs, Transport and Resources (DEDJTR) will continue to monitor the Kyabram
grower to ensure adequate systems and processes have been implemented to prevent contamination of their produce occurring
again. Likewise, DEDJTR will continue monitor agricultural and veterinary chemical use in Victoria, and investigate situations
where Victorian chemical use legislation is believed to have been breached.
For information on agricultural chemical use in Victoria, visit www.depi.vic.gov.au/chemicaluse
What are ‘restricted use’ chemicals?
In Victoria, certain types of agricultural chemicals are classified as ‘restricted use’ chemicals. These chemicals are restricted
because they present a higher risk to users, the environment and other crops.
Chemical Industry News - No 78 2015
‘Restricted use’ chemicals are:

Schedule 7 Poisons (Dangerous Poisons)

ester formulations of 2,4-D, 2,4-DB, MCPA and triclopyr

formulations of atrazine and metham sodium.
‘Restricted use’ chemicals can only be authorised under one of the following conditions: The user must:

hold an Agricultural Chemical User Permit (ACUP)

work under the direct supervision of an ACUP holder

hold a Commercial Operator Licence or Pilot Chemical Rating Licence issued by DEDJTR or a Pest Control Operators
Licence issued by the Department of Health

have completed a recognised training course in agvet chemical use, operates under an accredited quality assurance
program and the chemical use is independently audited at regular intervals of less than two years.
The product label of a ‘restricted use’ chemical will either have a signal heading, ‘DANGEROUS POISON’, or list one of the
abovementioned active constituents.
‘Restricted use’ chemicals must only be used in strict accordance with label directions. It is illegal to use a ‘restricted use’
chemical off-label unless a Section 25A permit has been issued by DEDJTR.
For more information on ‘restricted use’ chemicals and Section 25A permits, visit www.depi.vic.gov.au/chemicaluse
Dithiocarbamates and stone fruit
Maresa Heath, Project Officer, Plant Residues
A national produce monitoring program conducted in 2013/14 identified unacceptable residues of dithiocarbamates in Victorian
grown apricots. Dithiocarbamates are a group of fungicides commonly used in the horticulture industry to control various fungal
diseases. In the stone fruit industry, this group of fungicides is mostly used to control brown rot and freckle.
A total of 238 Victorian grown apricots were sampled and analysed in this financial year. Of these, 36 were found to have
dithiocarbamate residues exceeding the Australian Pesticide and Veterinary Medicines (APVMA) maximum residue limit (MRL)
of 3 mg/kg for stone fruit, indicating the possible misuse of a dithiocarbamate product. As a result, traceback investigations were
conducted to identify the growers of the produce.
With the exception of one, all of these produce samples originated from the Goulburn Valley (GV) region. The 36 samples with
unacceptable residues were taken from 24 growers in the GV. The concentration of the unacceptable residues ranged from 3.2
mg/kg to 10 mg/kg. The residues were detected in various apricot varieties. It is important to note that the safety margin used
when establishing an MRL means that none of the residues posed any concern to human health.
The tracebacks revealed:

All growers had used a dithiocarbamate product. The most commonly used product contained mancozeb as the active
constituent.

Multiple applications had been made to crops.

The harvest withholding period was observed by all growers.

Most uses were according to label directions.
There was no single reason identified as the cause for the unacceptable residues. It was interesting to note that the
unacceptable residues were only detected in apricots grown in the GV. Apricots had also been sampled from other regions of
Victoria, including Swan Hill and the Yarra Valley.
While conducting the tracebacks, the Department of Economic Development, Jobs, Transport and Resources (DEDJTR) field
officers discussed the use practices of these products with each of the affected growers. All growers were very cooperative and
forthcoming with information regarding these detections DEDJTR wishes to extend its appreciation to them for their assistance.
Chemical Industry News - No 78 2015
The previous department (Department of Environment and Primary Industries (DEPI)) conducted a webinar with relevant
industry and government stakeholders on 17 November to discuss these findings and their potential impact on the stonefruit
industry. DEDJTR will continue to monitor Victorian-grown stone fruit for dithiocarbamate residues as part of their internal
produce monitoring program.
Preventing sheep meat carcass contamination
Robert Suter, Statewide Veterinary Officer - Sheep
Sheep meat and wool is Victoria’s largest agricultural export industry. In 2013-14, Victoria exported $1.4 billion of wool (fortyseven percent of Australia’s total) and $0.9 billion of sheep meat from a flock of 17 million sheep. Nearly 15 million sheep were
slaughtered, with only forty per cent of the total produced in Victoria exported – Victoria is a net importer of sheep.
Sheep and lamb meat is exported to premium overseas markets and earns an attractive price because of Australia’s high level
of assurance that the product is free of contagious animal disease, unacceptable chemical residue contamination, and that
sheep have been slaughtered under humane and hygienic conditions.
As a large percentage of Victorian abattoirs are export certified, there is a real chance that some part of a sheep that is sent for
slaughter will end up in an export market. Given this likelihood, producers need to be mindful when treating sheep with
veterinary chemicals.
Chemical contamination of meat is monitored intensively at abattoirs, and includes monitoring for antibiotics, hormones and
heavy metals. Carcass contamination from veterinary chemicals, such as antibiotics occurs when a sheep is injected with, or fed
veterinary chemicals and the sheep is then slaughtered before the meat withholding period (WHP) has expired.
It is important to recognise that Australian WHPs are used to ensure compliance with Australian maximum residue limits (MRLs)
only. This makes observing that the WHP has expired before slaughtering sheep even more critical given that the meat is likely
to be exported overseas. Many products also have an Export Slaughter Interval (ESI) listed on the label, which is usually longer
than the WHP because export markets have even lower tolerance levels to contaminants. An example is Russia and their
perspective on the use of oxytetracycline antibiotics, hence the need to specify ‘Russia eligible’ on National Vendor Declarations
(NVDs).
Australia’s sheep traceability system demands that abattoirs can trace sheep to the saleyard of origin, but not to the original
producer who sold the sheep. Sheep sourced from saleyards are slaughtered as ‘boxed’ lines, meaning that they cannot be
identified from individual producers any longer.
If a contaminated carcass is detected, the abattoir may be forced to condemn all of the carcasses processed from that one
batch if the sheep originated from a boxed line from a saleyard.
Producers are reminded to ensure they declare their chemical use when completing a NVD to move sheep to processors,
saleyards or between properties, including that WHPs and ESIs have been observed. More information can be found on the
Meat and Livestock Australia (MLA) website, http://www.mla.com.au/Meat-safety-and-traceability
Protecting bees from pesticides
Bees are important pollinators of flowering crops, and play an integral role in many horticultural and broadacre industries.
Certain pesticides are very toxic to bees, therefore it’s important to plan your chemical use to minimise the risk to foraging bees.
Poisoning can occur when:

a chemical has been used on flowering crops and bees are exposed to contaminated foliage, nectar and/or pollen

a chemical has been used on a crop and other plants in the target area are flowering e.g. weeds in flower in a lucerne
crop

a chemical is directly applied or drifts onto bees, hives or flowering plants, or

bees access pesticide contaminated water.
Chemical Industry News - No 78 2015
Bees can also take contaminated pollen and/or nectar back to the hive, which can kill the entire colony.
Many agricultural chemicals contain prohibitive statements under the ‘Protection of Livestock’ section of the label that relate to
bees. For example: ‘DO NOT apply where bees from managed hives are known to be foraging, and crops, weeds or cover crops
are in flower at the time of spraying, or are expected to flower within 28 days (7 days for pastures and sorghum)’. Always check
these statements before using a product. Under Victorian legislation, it is an offence to use an agricultural chemical contrary to
prohibitive label statements.
Some steps users can take to protect bees are outlined below.
Steps for landholders and chemical users

Discuss chemical use plans with your agronomist and pollinating apiarist. Honeybee Pesticide Poisoning – A risk
management tool for Australian farmers and beekeepers is available from https://rirdc.infoservices.com.au/items/12043 and is a useful guide to managing pesticide risks to bees.

Advise the apiarist of your intention to spray so they may take steps to protect bees (e.g. remove hives). Prior notice of
48 hours is recommended.

Conduct a risk assessment to identify and address any risks before spraying (e.g. ensure no bees are foraging).

Spray in appropriate conditions to avoid spray drift onto potential pollen, nectar and water sources.

Notify licensed spray contractors of any hives located near the target area.
Steps for apiarists

Before placing hives, work with the grower to establish an agreed chemical program (e.g. apply chemical before bees
are introduced).

Provide the grower with your full, written contact details so they can contact you if needed.

Position signs near hives to notify others that bees are located in the area.

Ensure signs and at least one hive lists your contact details so others can contact you. Use lettering of at least 25 mm
high on hives.

Don’t place hives where chemicals are routinely used without notifying neighbouring landholders.

Place hives in sheltered areas to reduce the risk of spray drift.

Establish a holding area located a sufficient distance away from the crop where the hives may be temporarily placed
whilst spraying occurs.

Ensure bees have access to water that does not contain pesticide residues.

Inspect hives regularly to enable early detection and reporting of symptoms of bee poisoning.
For more information on pesticide use and bees, visit www.depi.vic.gov.au/chemicaluse
Using pindone pest animal baits in Victoria
Jane Rhodes, Leading Chemical Standards Officer
Pindone pest animal bait products are one of the many control methods available for minimising the impact of rabbits on
agricultural land, the environment and urban areas. The Department of Economic Development, Jobs, Transport and Resources
(DEDJTR) advocates an integrated approach to rabbit control involving a number of tools such as warren destruction,
fumigation and the use of poison baits (e.g. pindone or 1080).
Pindone is an anticoagulant chemical that is usually applied to oats and carrots and is commonly sold as ready to use bait which
does not require the user to hold a chemical use licence or permit. Pindone is also sold as a concentrate from chemical resellers
(i.e. products containing >2.5% pindone) and requires the user to hold an Agricultural Chemical User Permit or Commercial
Operator Licence.
Prior to using pindone, an unpoisoned ‘free’ feed should be used to gauge how much poisoned bait needs to be applied. Over
application of poisoned bait is a waste of money and creates additional risks to wildlife.
Rabbits need to ingest the poison bait on at least two separate occasions, with the chemical having a cumulative effect. To kill a
high proportion of rabbits, bait must be laid on at least three occasions, at two to three day intervals.
Chemical Industry News - No 78 2015
Pindone has an effective antidote, vitamin K1, which can be administered as an injection or a tablet, in the event a non-target
animal, such as a domestic or native animal, was put at risk. As with all chemicals but particularly with vertebrate pesticides, all
users should conduct a risk assessment prior to use. Although pindone is not subject to same distance restrictions as 1080 (e.g.
5 metres from an adjoining fenceline), it may be inappropriate or too risky to use it in some circumstances.
When choosing a pest animal bait, it is important to read and understand the directions stated on the product label. Labels
contain specific directions for use and prohibitive statements that users are required to legally follow to ensure the safe and
effective use of the product. For example, many pindone bait product labels include the prohibitive statement, ‘DO NOT heap
baits’ and ‘DO NOT lay bait in the vicinity of kangaroos, bandicoot and native rodent refuge areas’, which intends to protect nontarget native animals from exposure to bait.
While pindone may be more appropriate to use in urban or semi urban areas, it cannot legally be used in urban areas on
residential blocks less than 1000 square metres in size. Chemical users cannot use the bait in a collective manner (e.g.
amalgamating several adjacent house blocks) to avoid this prohibitive statement, as this would be considered an illegal use and
penalties would apply under the Agricultural and Veterinary Chemicals (Control of Use) Act 1992.
More information on rabbit control can be found at www.depi.vic.gov.au (search ‘integrated rabbit control in urban and semiurban areas’)
Aluminium phosphide in grain transportation
Source: Victorian WorkCover Authority
This Safety Alert highlights the hazards of working with aluminium phosphide (an insecticide used to eliminate pests in grain),
which produces highly toxic phosphine gas when it reacts with moisture.
A worker in Victoria became seriously ill after handling aluminium phosphide tablets while not wearing personal protective
equipment (PPE). The worker was admitted to hospital for treatment.
The company was prosecuted under the Occupational Health and Safety Act 2004 (OHS Act) and fined for failing to maintain a
safe working environment.
Background
Aluminium phosphide is an insecticide used to eliminate pests such as weevils in Australian grain. It is sold under various
names including Fumitoxin, Gastion, and Phostoxin.
Aluminium phosphide is a toxic and volatile hazardous substance and is classed as a ‘dangerous good’. Aluminium phosphide
tablets react with moisture in the air to give off highly toxic phosphine gas. If not used correctly, aluminium phosphide
(phosphine) can pose a serious risk to health.
Risks of phosphine in grain transport
Phosphine is absorbed into the body by inhalation. The presence of phosphine in loads of grain may create a risk for the
following people who may come into contact with the insecticide:

transport operator

grain depot workers

the general public if loads contain phosphine – note that trucks containing phosphine should not ventilate in populated
areas

emergency services workers if there is a grain spill and the load contains phosphine.
Control measures
Employers must provide and maintain, so far as is reasonably practicable, a workplace for employees, and contractors, that is
safe and without risks to health. This includes ensuring:

aluminium phosphide is used according to the product label and material safety data sheet (MSDS) from the chemical
supplier

fumigated grain is fully ventilated prior to being transported

aluminium phosphide is never introduced to road transport vehicles (including a truck or road hauled container) i.e.
grain is never fumigated in transit
Chemical Industry News - No 78 2015

all workers when handling or exposed to aluminium phosphide or phosphine, wear appropriate PPE including a
respirator and impervious gloves.
Note that employers may also have duties under the Dangerous Goods Act 1985 and associated regulations as aluminium
phosphide is classed as a ‘dangerous good’. Also note that legislation administered by other regulatory authorities, such as the
Department of Economic Development, Jobs, Transport and Resources (DEDJTR), may also apply to the use of aluminium
phosphide.
Further information on agricultural chemical use, visit www.depi.vic.gov.au/chemicaluse For more information on occupational
health and safety, visit Victorian WorkCover Authority’s website, www.vwa.vic.gov.au
Cancellation of fenthion
Melinda Bowen, Project Officer, Domestic Quarantine and Market Access
In October 2014, the Australian Pesticides and Veterinary Medicines Authority
(APVMA) took regulatory action regarding the use of products containing fenthion.
Assessment of available data concluded that the use of products containing fenthion
may, in most situations, pose undue risks to human health (via dietary and
occupational exposure) and the environment. The APVMA has taken the following
regulatory actions to manage these risks:

cancellation of the cattle lice control product Tiguvon Spot-on Cattle Lice
Insecticide

cancellation of all pest control and home garden products including Lebaycid
Fruit Fly and Insect Killer (APVMA permit 13843)

variation of the label of the pest control 1% fenthion dust product to update the safety directions and to delete use in
ceilings, wall spaces and crawl spaces

variation of the label of the horticultural product Lebaycid Insecticide Spray to update the safety directions and
warnings and to delete all horticultural uses except post-harvest dipping of tropical and subtropical inedible peel fruits
(see APVMA Special gazette Thursday 16 October 2014 and APVMA permit 13841)

variation of the label to include restricted cover spraying requirements of inedible and edible peel varieties of
persimmons, nectarines, plums, apples, pears, capsicums and tropical and subtropical inedible peel fruit varieties (see
APVMA permit 13841).
The APVMA is allowing a phase-out period of 12 months, ending on 15 October 2015 which enables the continued use of
cancelled products.
The Department of Economic Development, Jobs, Transport and Resources (DEDJTR) will amend the two affected Interstate
Certification Assurance (ICA) arrangements relating to pre-harvest treatment and inspection of Queensland fruit fly host produce
for trade to interstate markets.
Further details regarding the fenthion review decision can be found on the APVMA website, http://apvma.gov.au
DEDJTR Chemical Standards
Visit www.depi.vic.gov.au/chemicaluse for more information about:

Rules and regulations on the use of agricultural and veterinary chemicals in Victoria

Licence and permit application forms

Agricultural Chemical Control Areas

Previous issues of CIN
Chemical Industry News - No 78 2015
DEDJTR Chemical Standards contacts
Contact
Region
Phone
Mobile
Email
Steve Field
Statewide
(03) 5824 5532
0407 258 433
steven.field@ecodev.vic.gov.au
Felicity Collins
North East
(03) 5833 5203
0407 267 912
felicity.collins@ecodev.vic.gov.au
Neil Harrison
South West
(03) 5336 6616
0400 827 596
neil.harrison@ecodev.vic.gov.au
Jane Rhodes
Gippsland
(03) 5147 0832
0438 072 465
jane.rhodes@ecodev.vic.gov.au
© The State of Victoria Department of Economic Development, Jobs, Transport
and Resources 2015
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