APVMA WORKING GROUP ON LABELLING OF AGRICULTURAL CHEMICAL PRODUCTS

CONCEPT LABEL FOR PESTICIDES

• A redesigned label has been developed for large pack pesticide products with eight panels that reflects the requirements of Agvet Code Section 14 criteria.
• Label information / statements will be in a new sequence grouped together under mostly renamed headings. Important restrictions on use of a product (which will be mandatory in all jurisdictions under all circumstances) will be clearly identified through the use of “DO NOT” statements in a box on the front panel and also in boxes under the respective sections of the label.
  

Front Panel
The front panel is the most prominent panel of the label and is required to display certain statutory and other essential or important information which intending purchasers and users need to know. Most of the information which will be required to appear on the front panel of the proposed label is the same as that which appears on current labels. The significant changes to this panel are the inclusion of a box which will list important restrictions on the use (if applicable) of the product, and a statement clearly indicating if the product is not registered for use in all States and Territories.

The information required to appear on this panel is:

· Signal Heading (as defined in the SUSDP)
· Cautionary statements (as defined in the SUSDP)
· Product name (it is proposed that where applicable the letters (eg, EC, ULV, SC, etc) identifying the formulation type will be required to be included in the name of the product)
· Active constituents/other poisons including solvents
· Resistance Management Group for herbicides, insecticides and fungicides
· Statement of intended uses (old general claims statement)
· States where registered (if not registered nationally)
· Statements of important restrictions on use, or standard reference to them (if applicable). (Important restrictions on the use of a product must be prominently shown within a box, surrounded by a border (preferably red), on the front panel of the label Such statements will be required by the APVMA and based on information presented to the APVMA which demonstrates that the aspect of use that is to be restricted is either known, or can reasonably be expected, to cause an adverse effect to third parties, ie with respect to trade, public health, or the environment. If there is insufficient space for all the restrictions to be listed in the box on this label panel, a statement is to be included in the box advising that such restrictions are listed in certain panels on the label. In all locations on labels, the boxes must include the heading “IMPORTANT RESTRICTIONS ON USE”)
· Restricted Chemical Product statement (if applicable)
· Reference to leaflets (if applicable) and direction to read them
· The statement “USE ONLY AS INSTRUCTED ON THIS LABEL”
· Contents
· Batch number/ DOM/ Expiry date
· APVMA label approval number
· Registrant name and address details (optional for this panel; see back panel)
· Graphics are acceptable providing they are relevant, do not obscure text and do not contradict the product name or intended uses.

Health and Safety Panel
After the front panel, the health and safety panel is the next most important panel which intending purchasers and users should see. This panel will consolidate into one panel all the health and safety instructions and other information located in various areas on current labels. It is proposed that there will be information about the Poison Schedule classification of the product contained in this panel, the listing of any health and safety important restrictions on use in a box as well as any health hazard warnings relevant to the users of the product.

The information required to appear on this panel is:

· Poison Schedule statement (The poison signal heading including the scheduling number (ie DANGEROUS POISON S7, POISON S6 or CAUTION S5) for the product must be included on the same line on the right hand side of the label as the heading “Health and Safety”. The print size and font will be the same as that used for the heading. In the case of a product which is exempt from poison scheduling, the words “Exempt from poison scheduling” and “Keep out of reach of children” must appear in the abovementioned position on the label)
· Important restrictions on use box (if applicable)
· Handling and transport (if applicable)
· Storage (if applicable)
· Health hazard statements (specifically relating to public health and OHS risks such as drift warnings for human health, use of human markers, etc)
· Safety directions
· First aid
· Re-entry and re-handling periods
· Reference to MSDS
· Hazardous substance status (a short statement indicating if the product is a declared hazardous substance and / or a Dangerous Good – full details will appear on the “Other Information” panel.)

Product Use Instructions and Information
This panel is basically the directions for use section appearing on current labels. This label panel provides specific details of the uses for the product which are set out in a three or four box format. The first two boxes and the last box are optional and will only be used if there is a need to include them on the label. The limitations on use statements which currently follow the directions for use table will no longer be used. There will be no important restrictions on use applicable to this panel.

The information required to appear on this panel is:

· A box at the top of the table headed “General Use Information” (this includes the old restraint statements [which are no longer to be worded as "DO NOT" statements because “DO NOT” is to be used in important use restriction statements], crop safety information, plant back periods and other information relevant to all uses of the crops/pests/rates)

· If applicable, a second box at the top headed “Integrated Pest and Resistance Management”, to include:

1. information in relation to product specific integrated pest and resistance management required by the APVMA (eg, special requirements determined for insect pest resistance management in cotton)

2. chemical group integrated pest management and resistance management information (eg, advice that the chemical should only be used once or twice per season, etc)

· Product Use Instructions table

o five columns: Crop or Situation/WHP/Pest /Rate/Specific Use Details in this order
o Specific Use Details column is the current “critical comments” column renamed and includes details in relation to integrated pest and resistance management for specific crops
o table may (should) have subcategories (separate sub- tables) where major use differences occur and can be logically grouped, eg cereals and fruit trees, crops and buildings, crop groups
o states/territories column only included in specific circumstances essential for clarity of use patterns

· Box at the bottom of the table headed “Additional Specific Use Details” (this will only be used when there is insufficient space in the “Specific Use Details” column in the table, including for integrated pest and resistance management)

Residues and Trade
This panel groups together the withholding periods and export information such as ESI’s which appear on current labels. As well as including a box for important restrictions on use (if applicable), this section will include other instructions / information relating to possible causes of unacceptable residues in produce such as spray drift, application rates / frequency, etc .

The information required to appear on this panel is:

· Important restrictions on use box (if applicable)
· Withholding Periods (listed by crop/animal species and/or as per instructions table groupings)
· Export Information

o Specific EASI, EHI, ESI (etc) information should be provided, or
o Generic export statement

· Maximum application and frequency (based on residue concerns)
· Spray drift residue issues (including any risk areas etc, where these have been identified)
· Location issues (based on residue concerns)

General Application Advice
This panel of the label details the general information, advice and warnings relating to the use of the product which have not been provided in the “Product Use Instructions and Information” panel. There will be no important restrictions on use applicable to this panel but any restrictions on e.g. equipment because of environmental concerns may be identified here.

The information required to appear on this panel is:

· General application advice (time of year, climatic or soil conditions, etc)
· Mixing
· Application methods and equipment to be used
· High and low volume recommendations
· Compatibility
· Maintenance and cleaning of equipment
· Drift management advice (not required elsewhere on the label)
· Other permitted information

Environmental Protection
This panel consolidates all the instructions / information that will help the user avoid causing environmental harm.

The information required to appear on this panel is:

· Important restrictions on use (if applicable)
· Maximum application rates and frequency (based on environmental concerns)
· Product specific spray drift issues, including location issues, weather conditions and buffer zones .
· Protection of livestock (bees etc)
· Protection of the environment (including wildlife, fish, crustacea, water, and non-target animals and plants)

Disposal
This panel of the label will provide instructions and advice that will enable the user to properly dispose of unwanted mixed product (including spent dips, washes or baits), unwanted concentrate product and empty containers.

The information required to appear on this panel is:

· Disposal of waste chemical (including spent dips, washes, baits)
· Disposal of unwanted concentrate chemical
· Disposal of empty containers

Other information
In this panel of the label information of a more general, non-specific nature, which does not belong in other panels of the label, can be included. The information to appear on this panel can include:

· Chemical group resistance management disclaimer (it is proposed that current standard AVCARE type statements should be shortened – review of them is needed)
· Dangerous Goods information and UN numbers
· Company warranty statements
· Registrant’s name, address, telephone numbers (including emergency contacts)
· Printing identification number/code
· drumMuster and other logos;
· any other general information.