Proposed amendments to APVMA webpages that mention END products
FIAAA letter to the APVMA 26 April 2018:
END Product Regulatory Reform – three years after implementation:
- From the industry side: some people have forgotten the win (or weren’t there at the beginning) and instead of seeing industry self-regulation as a reduction in regulatory burden they just see it as a burden.
- From the APVMA side: At the FIAAA General Meeting held in March 2018 in Canberra, the APVMA told us that 50-70% of compliance issues they deal with are related to END products.
The feed ingredients and additives industry must understand what is required for their products to comply with AgVet regulations; the industry must understand why compliance is importance and be confident that compliance will be enforced.
How can the APVMA and FIAAA work together to reduce APVMA workload while ensuring de-regulation of END products remains viable?
- The guidance on the APVMA website needs to be corrected, updated, strengthened and streamlined.
- The industry has an ongoing responsibility to ensure products that can fit the definition of END products comply with ALL requirements that enable exemption from registration. Updated guidance on the APVMA website will greatly aid industry understanding of products that must not be sold without compliance with END requirements.
- The industry needs the support of the APVMA in enforcing compliance so that the market place is fair for all.
If the steps above are put in place the workload of the APVMA should decrease while the increase in compliance across the industry will enhance the safety and quality of feed used in Australia’s important agricultural sector.
Understanding the APVMA’s resource challenges, the FIAAA has developed revised guidance.
This revised guidance has been put on a private page of the FIAAA website for the relevant APVMA staff to access. As the hard work of re-wording has been done, we hope the APVMA can review the documents in the short term, with a view to updating their website as soon as possible.
We look forward to your response.
Feed Ingredients and Additives Association of Australia (FIAAA)