Trade Advice Notice
on Tulathromycin in the Product Draxxin Injectable Solution
APVMA Product Number 60018

© Australian Pesticides and Veterinary Medicines Authority 2013
ISSN: 2200-3894 (electronic)
ISBN: 978-1-922188-35-9 (electronic)
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Contents
Preface
About this document
Making a submission
Further information
1	Introduction
2	Residues in Livestock
2.1	Proposed Australian use pattern
2.2	Residue trials
3	Residues-Related Aspects of Trade
3.1	Commodities exported
3.2	Destination and value of exports
3.3	Overseas registrations
3.4	Comparison of the (proposed) Australian MRLs with Codex and overseas MRLs
3.5	Potential risk to trade
3.6	Trade advice statements
4	Conclusions
List of tables
Table 1:	Proposed use pattern
Table 2:	Dairy Products Exported in 2010–2011

Preface
The Australian Pesticides and Veterinary Medicines Authority (APVMA) is an independent statutory authority with responsibility for assessing and approving agricultural and veterinary chemical products prior to their sale and use in Australia.
In undertaking this task, the APVMA works in close cooperation with advisory agencies, including the Department of Health and Aging, Office of Chemical Safety and Environmental Health (OCSEH), 
Department of the Environment, Water, Heritage and the Arts (DEWHA), and State Departments of Primary Industry.
The APVMA has a policy of encouraging openness and transparency in its activities and of seeking stakeholder involvement in decision making. Part of that process is the publication of Trade Advice Notices for all proposed extensions of use for existing products where there may be trade implications.
The information and technical data required by the APVMA to assess the safety of new chemical products and the methods of assessment must be undertaken according to accepted scientific principles. Details are outlined in the APVMA’s publication Vet MORAG: Manual of Requirements and Guidelines.
About this document
This is a Trade Advice Notice. 
It indicates that the Australian Pesticides and Veterinary Medicines Authority (APVMA) is considering an application to vary the use of an existing registered agricultural or veterinary chemical. It provides a summary of the APVMA’s residue and trade consideration.
Comment is sought from industry groups and stakeholders on the information contained within this document.
Any advice the APVMA receives through this consultation which it relies on to grant this application will be noted in a subsequent Advice Summary.
Advice Summaries can be found on the APVMA website: www.apvma.gov.au.
Making a submission
The APVMA invites any person to submit a relevant written submission as to whether the application to vary the registration of Draxxin Injectable Solution should be granted. Submissions should relate only to matters that the APVMA is required by legislation to take into account in deciding whether to grant the application. These grounds relate to the trade implications of the extended use of the product. Submissions should state the grounds on which they are based. Comments received outside these grounds cannot be considered by the APVMA.
Submissions must be received by the APVMA by close of business on Tuesday, 16 July 2013 and be directed to the contact listed below. All submissions to the APVMA will be acknowledged in writing via email or by post.
Relevant comments will be taken into account by the APVMA in deciding whether to grant the application. A summary of relevant comments and the APVMA’s response will be published on the APVMA website.
When making a submission please include:
•	contact name
•	company or group name (if relevant)
•	postal address
•	email address (if available)
•	the date you made the submission.
All personal and confidential commercial information (CCI) material contained in submissions will be treated confidentially.
Written submissions on the APVMA’s proposal to grant the application for registration that relate to the grounds for registration should be addressed in writing to:
Linden Moffatt
Veterinary Medicines Program 
Australian Pesticides and Veterinary Medicines Authority
PO Box 6182
Symonston ACT 2609
Phone:	 +612 6210 4736
Fax:	+612 6210 4741
Email:	vetmedicines@apvma.gov.au 
Further information 
Further information on trade advice notices can be found on the APVMA website: www.apvma.gov.au
.

1	Introduction
The Australian Pesticides and Veterinary Medicines Authority (APVMA) has before it an application from Zoetis Australia Pty Ltd, to vary the registration of Draxxin Injectable Solution, which contains 100 mg/mL of tulathromycin.
The product is administered subcutaneously to cattle to treat bovine respiratory disease caused by Mannheimia haemolytica, Pasteurella multocida, Histophilus somni and Mycoplasma bovis. Draxxin is also administered to pigs intramuscularly to treat swine respiratory disease caused by Pasteurella multocida, Mycoplasma hyopneumoniae and Haemophilus parasuis.
The application involves consideration of the proposal to extend the use of tulathromycin to dairy heifers without the establishment of a Maximum Residue Limit (MRL) for tulathromycin in milk.

2	Residues in Livestock
2.1	Proposed Australian use pattern
The proposed Australian use pattern of Draxxin Injectable Solution is given below.
Table 1:	Proposed use pattern for Draxxin’s extension of use
Host	Purpose	Dose rate	
Cattle, including dairy heifers up to the point of first mating.
	For the treatment of bovine respiratory disease.
	Nominal
2.5 mg tulathromycin/kg bodyweight by a single subcutaneous injection high on the neck.	
			
Restraints
DO NOT USE in lactating cows which are producing milk, or dry cows that may in the future produce milk, or where milk products will be produced, for human consumption in each case.
Re-treatment interval
DO NOT RE-TREAT dairy heifers.
Withholding periods
Milk: DO NOT USE in lactating cows which are producing milk, or dry cows that may in the future produce milk, or where milk products will be produced, for human consumption in each case.
Trade advice
DO NOT USE less than 35 days before slaughter for export.
The ESIs on this label was correct at the time of label approval. Before using this product, confirm the current ESI from Zoetis Australia Pty Ltd on 1800 814 883 or the APVMA website (www.apvma.gov.au/residues).

2.2	Residue trials 
In support of their application, Zoetis Australia Pty Ltd provided details of two residues trials conducted with Draxxin Injectable Solution. In one trial (Study 1531N60-09-770), dairy heifers were administered a single subcutaneous injection of 2.8 mg tulathromycin/kg bodyweight 211 to 251 days before calving. Following calving, the heifers were milked twice daily for 10 consecutive days. Tulathromycin residues in milk were quantified as the common fragment CP-60,300, expressed as tulathromycin equivalents. This study showed that tulathromycin residues in whole milk were less than 3.4 µg/L, which was the method LOD, at all sampling times after calving. 
An MRL for tulathromycin in milk was not established; therefore any detection of common fragment CP-60,300 in milk will constitute a food safety and/or trade violation. The approach to not set a milk MRL for the use of Draxxin Injectable Solution in dairy heifers is consistent with that taken by regulatory agencies in the USA and the EU. When taken in conjunction with a default nine-month milk withholding period (i.e. the interval between treatment up to the point of mating to the commencement of lactation), the extension of Draxxin Injectable Solution to dairy heifers does not pose a risk to food safety or trade.
The second study (Study 1531R-60-05-477), determined the concentration of tulathromycin common fragment CP-60,300, expressed as tulathromycin equivalents, in milk of cows after freshening and in the liver of neonatal calves. The dairy cows were treated subcutaneously with Draxxin Injectable Solution at 
2.5 mg/kg bodyweight, during the dry period. Tulathromycin common fragment CP-60,300 residues in milk from the dry cows ranged from 146–800 µg/L at first milking after freshening, compared to <3.4 µg/L in dairy heifers (see Study 1531N60-09-770). This residue depletion study did not reflect the use pattern proposed for dairy heifers. In the neonatal calf study, animals were sacrificed between 2.6–15 hours and liver samples taken at necropsy. Residues measured as the common fragment CP-60,300, expressed as tulathromycin equivalents, in liver ranged from 160–1,240 µg/kg. 
In the second study, 21 to 39 days were available for the depletion of tulathromycin common fragment 
CP-60,300 residues from the liver of neonatal calves prior to calving and slaughter, and the resultant residues were less than the Australian MRL of 3 mg/kg for tulathromycin in cattle liver. In the case of dairy heifers treated no later than at first mating, tulathromycin common fragment CP-60,300 residues in liver from neonatal calves will be even lower since tulathromycin common fragment CP-60,300 residues will have approximately 270 days in which to deplete before first calving. Consequently, tulathromycin common fragment CP-60,300 residues in liver from calves born to treated dairy heifers are likely to comply with 
the Australian MRL for tulathromycin in cattle liver.
Milk MRL considerations
Milk from treated cattle, including dairy heifers treated after first mating, is prohibited from being supplied for human consumption. Heifers treated up to the point of the first mating will undergo a gestation period of about nine months (~270 days) before they begin to produce milk for human consumption. The first study described above showed that tulathromycin common fragment CP-60,300 in whole milk from heifers treated during the first trimester was below the method LOD. It was considered, therefore, that the extension of use of Draxxin Injectable Solution in dairy heifers up to the point of the first mating does not require an MRL for tulathromycin in milk to be established.
Withholding period Milk
As heifers do not produce milk until the first calving and since tulathromycin common fragment CP-60,300 residues in milk from heifers was less than the method LOD before calving, the following milk withholding period is recommended: DO NOT USE in lactating cows which are producing milk, or dry cows that may
 in the future produce milk, or where milk products will be produced, for human consumption in each case.
Re-treatment interval
The use pattern of Draxxin Injectable Solution in dairy heifer is a once only treatment prior to mating. Consequently, the following restriction on re-treating applies: DO NOT RE-TREAT dairy heifers.

3	Residues-Related Aspects of Trade
3.1	Commodities exported
Australian exports of dairy produce could be affected by the use of Draxxin Injectable Solution in dairy cattle if residues were detected in exported products. The residue-related trade implications of the extension of use to dairy heifers must therefore be considered.
3.2	Destination and value of exports
Dairy product exports
In 2010–2011, Australia exported $AUS 2.27 billion of dairy products, including cheese, butter and butterfat, skin and whole milk powder. Details of the top export destinations, total exports and the dollar value of exports are provided in Table 2.
Table 2:	Dairy Products Exported in 2010–2011 (Source: ABARE 2011) 
Rank
(by $ value)	Importing Country	Quantity
(ktonne)	Value
($AUS million)	
Cheese	
1	Japan	84.5	355.8	
2	Korea, Republic of	8.8	36.8	
3	Saudi Arabia	6.9	31.7	
Total		163.2	732.2	
Butter and Butterfat	
1	Singapore	5.7	27.9	
2	Philippines 	6.4	27.4	
3	Malaysia	3.8	18.5	
Total		56.0	251.6	
skim milk powder				
1	Singapore 	15.7	51.6	
2	Thailand	11.5	37.9	
3	China	11.7	37.1	
Total		155.7	504.5	
casein				
1	Japan	1.7	22.0	
2	USA	1.4	13.1	
Total		4.7	52.7	
whole milk powder				
1	Singapore 	15.5	58.4	
2	China	13.7	51.6	
3	Indonesia	10.2	39.7	
Total		108.4	402.5	
other products				
Fresh milk		77.2 ML	96.4	
Other fresh products		0.3 ML	1.3	
Condensed milk		47.2	108.2	
Other powders		27.8	125.0	
Total			331.0	
3.3	Overseas registrations
Draxxin Injectable Solution is currently registered in the European Union (EU), USA, Canada, Switzerland, Bulgaria, Croatia, Romania, Turkey, Ukraine, Ecuador, Mexico, Peru, Argentina, Chile, Venezuela, Korea, Japan, Vietnam and the Philippines. Its use in dairy heifers is authorised in the EU and the USA.
3.4	Comparison of the (proposed) Australian MRLs with Codex and overseas MRLs
The Codex Alimentarius Commission (Codex) is responsible for establishing CXLs for pesticides and veterinary medicines. Codex CXLs are primarily intended to facilitate international trade, and accommodate differences in Good Agricultural Practice employed by various countries. Some countries may accept 
Codex CXLs when importing foods. Codex has not considered tulathromycin. No country has established MRLs/tolerances for tulathromycin in milk.
3.5	Potential risk to trade
Export of dairy products containing measurable residues of tulathromycin may pose a risk to Australian trade in situations where: (i) no residue tolerance is established in the importing country, or (ii) where residues 
in Australian produce are likely to exceed a residue tolerance established in the importing country. As none of the importing countries of Australian dairy products has established an MRL/tolerance for tulathromycin in milk, any detection of tulathromycin residues in these commodities would constitute a potential trade violation.
The use pattern of Draxxin Injectable Solution worldwide is 2.5 mg tulathromycin/kg bodyweight by subcutaneous injection in cattle. A common fragment analytical method is validated to quantify residues 
in milk. This analytical method was used to quantify tulathromycin residues in Study 1531N60-09-770.
Given the results of this trial and that tulathromycin residues in milk from treated heifers are likely to deplete below the method LOD during the nine months between the time of first mating and parturition, the risk to trade is considered to be low.
3.6	Trade advice statements
A trade advice statement is already approved for edible tissues. For the extension of use to dairy heifers, a trade advice statement for milk is not required as milk from treated primiparous (first-calf) heifers is not expected to contain measurable quantities of tulathromycin residues.

4	Conclusions
The APVMA has considered whether the extension of use of Draxxin Injectable Solution to dairy heifers in accordance with the proposed label instructions, could potentially unduly prejudice trade and commerce between Australia and places outside Australia, as per Section 14(3)(e)(iv) of the Agvet Codes.
The risk to Australia’s export trade in dairy products of allowing the use of Draxxin Injectable Solution up to the point of mating in dairy heifers is considered to be low when only a single treatment is permitted.
The APVMA is seeking comment from relevant industry groups and stakeholders in relation to the perceived level of risk to Australia’s export trade in dairy products.