New off-label use poster to help guide vegetable growers

Words by Rebecca Fisher : Market Access Solutionz Ltd crop protection manager

The Vegetable Research & Innovation Board commissioned Market Access Solutionz to design a poster summarising the important steps that vegetable growers must follow when using crop protection products off-label to ensure that off-label use complies with regulations.

While off-label use is legal for most products, growers are responsible for ensuring that off-label use is necessary, safe and compliant with all regulatory controls. Off-label use occurs when growers need to use a product to control a pest, disease or weed – but the label does not carry a claim for that crop or target organism. While the flexibility of being able to use crop protection products off-label is critical to New Zealand growers, they are unable to rely on label directions to ensure regulatory controls are complied with. Without label guidance, there is a risk that off-label use may result in exceedance of Maximum Residue Levels (MRLs). Off-label use is severely restricted, especially for newer actives and some older products that have been reassessed by the Environmental Protection Agency (EPA). This poster provides a step-by-step guide to off-label use and highlights the key steps that all growers should follow when using products off-label.

Step 1: Check the Agricultural Compounds & Veterinary Medicines (ACVM) regulations which provide guidance on food residues for MRL compliance, and the Environmental Protection Authority (EPA) for environmental compliance first.

Step 2: Growers should record their considerations. NZGAP (Good Agricultural Practice) has a template for off-label use that is available on the NZGAP website. Growers should be aware there may be further restrictions on products and should also check the WorkSafe website for restricted entry intervals. Step 3: It is important to check if any control prohibits off-label use. Actives with off-label restrictions include: Organophosphate and carbamate insecticides such as acephate, diazinon, fenamiphos and methamidophos.

Step 4: When designing or updating spray plans, growers should carefully consider what products may need to be used off-label. Growers are strongly encouraged to design a spray programme ahead of the season and to account for any off-label uses that may be required as a result of unanticipated pest or disease outbreaks.

This poster should be read in conjunction with the NZGAP off-label guidance document.

This information is updated annually and available on the NZGAP website: www.nzgap.co.nz. This includes a decision tree and checklist.

This poster is available to download from the Vegetable Research & Innovation website: www.vri.org.nz, or can be obtained by contacting your Product Group Manager.