Submission to the review of Paraquat and Diquat

We have provided a submission to the review of Paraquat and Diquat by the Australian Pesticides and Veterinary Medicines Authority.

Organic Operators Australia calls on the Department of Agriculture, Forest and Fisheries to take urgent action in regard to the regulation of agvet chemicals in Australia.

Slow assessment of chemical safety in some cases up to thirty years (30) and approved use despite obvious community concerns points to one very clear deficiency in Australia’s chemical regulation which is not within the scope of the APVMA.

As is the case for most product and service providers, harm caused to the community and, or the environment from commercial products must be remediated with victims compensated for harm where causal links can be established.

Sadly, this is not the case for agvet chemical manufacturers / distributors. Instead, the duty of proof of causal link falls on victims. The complex, expensive, and time-consuming task requiring preeminent qualification and peer review, is a burden for egregiously harmed victims, and not the perpetrators.

The era of agvet chemical distributors shifting the cost of community and environmental harm onto the community must end. All agvet chemicals distributors must include the true cost of their products’ impact onto their balance sheet.

OOA calls for urgent action to mandate new regulations of agvet chemicals including:

1. Agvet chemical products are obligated to prove NIL causal link in all cases where correlation of agvet chemicals and community or environment harm is evident.
2. Agvet chemical products are at least severally liable for all community and or environmental harm including off-label use.
3. Correlation of agvet chemicals and community or environmental harm mandates levies on all associated agvet chemical products to fund independent research to disprove causal link.
4. Reparation and compensation where any agvet chemical has caused harm.
5. Agvet chemical levies cannot constitute or be considered a component of funding of APVMA.

All new products must be accompanied with environmental and health risk assessments completed within a reasonable period of the submission to ensure applicability of the research.

We urge the APVMA to prioritise protection of the environment and the community from harm.

Read the submission