AGVET chemicals are a demonstrable ongoing problem causing significant harm to aquatic environments and are linked to wildlife diseases, according to Dr Matt Landos Director of Future Fisheries and Veterinary Services.
Under statutory authority the Australian Pesticides and Veterinary Medicines Authority (APVMA) oversees the Agricultural and Veterinary Chemicals Code Act 1994, with a charter to protect human health, trade, and, the environment. This could prove a difficult task especially considering a number of international toxicologists believe we don’t yet have the ability to test the thousands of new chemicals constantly entering the marketplace.
The APVMA does conduct periodical review on chemicals. These reviews are instigated by triggers from the scientific community and treaties with international forums like the Stockholm Convention. Nonetheless chemicals do get re-appraised, and sometimes they are de-registered.
In the late 90’s the APVMA placed 75 glyphosate products under review when it received advice from the Commonwealth Environmental Protection Agency (EPA) suggesting that glyphosate formulations were toxic to tadpoles.
APVMA requested toxicity date from the 27 manufacturers. This is what they wanted to know:
- the application methods, particularly around aquatic environments.
- that there were sufficient warnings against the use of the formulation around or adjacent to waterways; and
- toxicity data.
Presumably toxicity data would need to assess formulation recipes, or registrants provide their own toxicity data. Only two registrants submitted data. Some registrants even suggested that the APVMA provide them with their list of acceptable surfactants.
With the scant information provided APVMA concluded that the aquatic toxicity of registered glyphosate formulations were undesirably high. The reason– surfactants. In particular a surfactant called polyetylated tallow amine (POEA) a chemical derived from animal fat.
Surfactants are added to aid the active ingredient (glyphosate) to penetrate the waxy cuticle of plant leaves. Except, according to Dr Joseph Bidwell a Professor with the University of Newcastle “It’s not necessary for glyphosate that’s supposed to be formulated for spraying on aquatic weeds because it does not add to the permeability.”
Bidwell was involved in publishing the report that prompted the review. 
The APVMA made the following recommendations after its review:
“All products that had not supplied toxicity data would be relabelled or reformulated. If they were not reformulated then their use would be restricted to dry drains and channels, dry margins of dams, lakes and streams.
All other registrants who did not supply data either for current or reformulated products also required the above labelling, and, the final recommendation: Any glyphosate product with no registered use must have the label Do NOT contaminate dams, rivers or streams with the product or used container. Do NOT apply to weeks growing in or over water. Do NOT spray across open bodies of water.”
Put simply one of two things must happen. The registrant was to reformulate the product or add the new label recommendations.
Did any of the recommendations take place? It is unclear as when the writer asked the APVMA to provide information as to how many products were reformulated, how many products left the market, what surfactants replaced POEA and how many of the 75 products were now considered able to be used in aquatic environments they said they did not consider this request a priority and could not indicate when they would be able to reply.
A search on the APVMA website shows 92 products currently registered for use in aquatic environments. This list includes many if not all of the chemicals listed in the original review. It is impossible, to determine from the labels what surfactants or other chemicals, apart from the active ingredient, are in the products. Some labels are not available for viewing.
In the US Beyond Pesticides and many of its signatory organisations have long advocated for the full disclosure and evaluation of all chemical ingredients in pesticide products.
They say that these ingredients are neither inert nor inactive, and are responsible for serious human health implications and that their exemption during the registration process highlights the primary flaw with their agencies (EPA) regulatory process.
According to Dr Rick Relyea, Professor and Director, of Pymatuning Laboratory of Ecology, “…. small temporary wetlands that may appear to be unimportant and only have 6″ (15 cm) of water can, in fact, produce thousands of tadpoles including many species that breed only in temporary wetlands.
“These small, temporary pools are either not avoided or not avoidable by aerial pesticide applications.”
In Australia, Dr Landos has been investigating Qx disease in oysters and is scathing of our chemical regulator believing this disease is a direct result of agricultural chemicals entering waterways. He says in a submission Agvet chemicals need to be better managed. He has made a number of recommendations including toxicity testing for existing and new chemical products, including those submitted for ‘research permits.’
He proposed that compounds other than the active ingredient should be mandatorily listed on labels and should be included in the toxicity testing of chemicals. Toxicity testing should extend to metabolites, including all surfactants, adjuvants, plasticisers (phthalates; including Bisphenol A known as xenoestrogens).
Xenoestrogens are a category of chemicals that have been shown to be disrupting to the endocrine system of humans and wildlife. The endocrine system effectively controls hormone regulation within our bodies. Research has implicated glyphosate as an endocrine disruptor.
Another example of the inadequacies of regulation has been demonstrated by Jon Brodie (and ors) from The Centre for Tropical Water and Aquatic Ecosystem Research at James Cook University.
Brodie co-authored a paper with Juliette King and Frances Alexander which shows how the Great Barrier Reef (GBR) is being severely impacted by agricultural chemicals.
The paper states that no action has been initiated to respond to the risks to this environment, except for some limited restrictions on chemical use by the Queensland government. The authors continue:
“Other lower profile and less-studied Australian water bodies are likely to be even less protected. The ad hoc, case-by-case and very slow chemical review process administered by Australia’s national pesticide regulator has not effectively assessed or addressed chemical risks to the GBR.”
Will labelling protect the health of aquatic animals or the environment? According to Dr Rick Relyea, Professor and Director, of Pymatuning Laboratory of Ecology, “…. small temporary wetlands that may appear to be unimportant and only have 6″ (15 cm) of water can, in fact, produce thousands of tadpoles including many species that breed only in temporary wetlands.
“These small, temporary pools are either not avoided or not avoidable by aerial pesticide applications.”
The Australian government states that it is committed to reform the regulation of agricultural and veterinary chemicals to improve the efficiency and effectiveness of the current system and provide better protection for human health and the environment.
A bill was drafted with invitations for consultation. Despite much despair over the short period for consultation, considering the complexity of the issues, there have been some submissions.
NSW farmers are alarmed at the cost of the reform and the lack of addressing the potential for pest damage if a chemical is not used, and its replacement.
Reiterated, in some submissions, is the need for better management, including addressing the interpretation of words used in the bill, reforms of risk management processes, including mandatory labelling of products, and easier and quicker identification of registrations and de-registrations. With submissions lamenting the time taken to do either.
Landos says, “ The reforms did not embrace the concerns that were placed in front of the Department of Agriculture, Fisheries and Forestry (DAFF) group in community meetings around the country.”
He says they introduced a re-registration requirement, but not a data requirement to ensure that the data packages supporting products were brought up to contemporary standards. The changes also failed to mandate that sufficient funding to undertake the reviews would be forthcoming from raising the chemical sales levy. The list awaiting review is already years old.
“More data will only be asked for, if problems are reported with a product,” says Landos.
Then he continues saying that this process doesn’t work. He says he placed an adverse event report for Noosa.[fish hatchery incident] He says this was a lay down case of offsite pesticide impacts — but with a sham of a government scientific investigation.
“The regulator dismissed the adverse event reports and filed them.
“I have a folder of their unscientific responses, after complaining repeatedly to the Minister for Agriculture,” says Landos.
He goes on saying: “[this just shows] …it will be a miracle if there ever a sufficiently detailed adverse event report lodged that will trigger the requirement for the extra data.
“For example, to see if a product registered 30 years ago, still measures up and is safe to contemporary testing standards.”
Landos says, there needs to be a managed risk strategy, but with no effective outcome monitoring, no adequate disclosure of public health data — it cannot deliver good public health outcomes.
In summary as the authors of the book Our Stolen Future point out, “…….The simple truth is that the way we allow chemicals to be used in society today means we are performing a vast experiment, not in the lab, but in the real world, not just on wildlife but on people.”
1. Dr Matt Landos “Submission to Better Regulation of Agricultural and Veterinary Chemicals: Policy discussion paper” 23 November 2010
 Chemical Review Section National Registration Authority for Agricultural and Veterinary Chemicals
Canberra AUSTRALIA NRA Special Review of Glyphosate June 1996 NRA Special Review Series 96.1
 In June 1995, Bidwell and Gorrie, on behalf of the Department of Environmental Protection, WA (WA DEP), published a report on the acute toxicity of Roundup® to selected frog species.
 Dr Matt Landos “Submission to Better Regulation of Agricultural and Veterinary Chemicals: Policy discussion paper” 23 November 2010
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