Australian Pesticides and Veterinary Medicines Authority
Via Email: ua.vog.amvpa@weiverlacimehc
RE: Chemical Review of Neonicotinoid Approvals and Registrations
To Whom It May Concern,
Grain Growers Limited (GrainGrowers) welcomes the opportunity to provide comment regarding the APVMA’s notification of reconsideration of neonicotinoid approvals and registrations.
GrainGrowers is a leading voice for Australian grain farmers, representing their interests at a national and international level. Our vision is a more efficient, sustainable and profitable grains industry for all Australian grain farmers. Working with the grains sector and broader agricultural community, GrainGrowers aims to set a progressive agenda to drive positive change for Australian grain farmers across the national and global landscape.
Access to safe, effective chemistry and associated technologies is essential for agriculture and the production of food and fibre, contributing to food safety, food security and environmental sustainability. Australian grain growers understand the importance of stringent chemical management, handling and application to ensure safety of the environment and people, to meet market requirements, and to achieve effective crop protection and pest control.
We acknowledge that ongoing reform in chemical regulation, new technologies and improved knowledge and understanding of key agronomic practices has contributed to safe handling, and mitigated worker exposure, environmental risks and impact to non-target organisms associated with the use of insecticides, including those of the neonicotinoid class. The appropriate regulation of agricultural and veterinary chemicals is critical to the ongoing development, innovation and support for the Australian agricultural sector.
GrainGrowers supports the robust regulatory and science-based framework used by the APVMA in its assessment of all chemicals for agricultural use, and in the APVMA’s independence and autonomy in relation to chemical evaluation and registration of products which are safe, efficacious and fit-for-purpose.
Reconsideration of Neonicotinoid Approvals and Registrations
In response to notification of Reconsideration of Neonicotinoid Approvals and Registrations in Gazette No. 23, 19 November 20191, GrainGrowers provide the following comment.
Neonicotinoids are a critically important group of chemistry used in cropping rotations to aid in crop protection and pest control across the country. GrainGrowers is aware of the global regulatory interest in neonicotinoids associated with concerns regarding environmental impact, including bee and pollinator health. Australian honey bee colonies and other Pollinators are responsible for the pollination of many of Australia’s crops, and their health and exposure risk are important considerations for growers when making agronomic decisions and planning integrated pest management (IPM) strategies.
GrainGrowers is concerned about the implications that may arise from the reconsideration or review of chemistries, including neonicotinoids, particularly as they relate to the perception of agriculture and production practices if the premise of these reviews and justification of any subsequent decisions is not effectively conveyed to the general public by the APVMA.
Australian farmers are stewards of the land and are trained professionals with strong proficiency in the safe and responsible use of agricultural and veterinary (agvet) chemicals used in the sustainable production of safe, high-quality grain products. Growers undertake mandatory training and must comply with stringent domestic and international food safety, trade and work health and safety (WHS) regulations in order to access and use agvet chemicals. This is demonstrated by industry stewardship programs of chemical use in Australia, including the National Residue Survey, the Pollinator Protection Initiative (PPI)2, and the safety of Australian grain products.
During current and future reconsideration and assessment of chemicals by the APVMA, it is imperative due diligence is applied to avoid unjust restraint on the access and use of agricultural and veterinary chemicals. This includes the appropriate assessment of the active constituent, formulation or product under reconsideration under common (label registered) use patterns and methods, rates and cropping situation, and environmental context.
Neonicotinoids are a critically important class of insecticides used in cropping rotations to aid in crop protection and pest control across the country. We acknowledge that ongoing reform in chemical regulation, new technologies and improved knowledge and understanding of key agronomic practices has contributed to safe handling, and mitigated worker exposure, environmental risks and impact to non-target organisms associated with the use of insecticides, including those of the neonicotinoid class. The appropriate regulation of agricultural and veterinary chemicals is critical to the ongoing development, innovation and support for the Australian agricultural sector.
We thank the APVMA for the opportunity to comment on the notification of reconsideration of neonicotinoid approvals and registrations and express our interest in participating in ongoing consultation with the APVMA and industry regarding this process to ensure that neonicotinoids remain a long-term viable control option for grains pests.
Should you require any further information in relation to this submission, please contact Lucy Darragh, Policy Officer, on (02) 9286 2000 or email@example.com
Chief Executive Officer