The labels of agricultural chemical products aim to be clear and precise. There are circumstances, however, where specific statements on the label may appear ambiguous and open to interpretation.

This document contains guidelines to assist in the interpretation of agricultural chemical product labels. The information was derived from NSW Agriculture's "Giving Advice on Farm Chemicals: Guidelines for NSW Agricultural staff".

The use of chemical products for a purpose or in a manner not in accordance with the label directions generally requires a permit issued by the Australian Pesticides and Veterinary Medicines Authority (APVMA) or the Tasmanian Registrar of Chemical Products.

---

1. Restraints Statements

Restraints are usually the first item in the Directions for Use section of the product label. Restraints are limitations which apply to all approved uses of the product.

Restraint statements are usually, but not exclusively, written as DO NOT... statements and each appears on a separate line. All restraints which appear on the product label must be observed. Some examples include:

DO NOT apply if rain is expected within 2 hours.

DO NOT apply to plants suffering stress.

DO NOT apply by Aircraft.

This last restraint would make it illegal to apply the product by air. In the absence of such a restraint, aerial application of the product would be permitted (although aerial application may in some situations be specifically restricted under the Agricultural and Veterinary Chemicals (Control of Use) Act 1995.

Therefore, it cannot be assumed that in the absence of the restraint, the chemical product is necessarily appropriate for application by air or that it is legal to do so. The label of the product will generally provide some indication as to whether the product is suitable or unsuitable for aerial application.

The absence of a rate per hectare would suggest that broad scale application might not have been anticipated. Certain crop types are also less likely to be suitable for aerial application.

Some consideration will also need to be given to the circumstances in which the crop is grown including aspects of the local environment and whether aerial application might represent a nuisance to neighbours or a risk of contamination to the immediate environment. The Code of Practice for Aerial Spraying details restrictions that apply to these matters.

Where there is uncertainty as to whether or not the label of the product would support the aerial application of the chemical, growers/aerial applicators should seek clarification from the Product Integrity Branch (AgVet Chemicals Program) of the Department of Primary Industries, Parks, Water and Environment (DPIPWE).

---

2. Directions for Use Table

2.1 The Crop or Situation

The crop or situation is usually the first column of the Directions for Use table on the product label. This column describes the crop on which the chemical can be used or the situation in which the chemical may be applied.

You must not advise the use of, or use, a chemical product on a crop or in a situation which does not appear on the label unless the use and situation is authorised by a permit issued by the APVMA or the Registrar of Chemical Products, or it is a type of off-label use that is permitted under the Agricultural and Veterinary Chemicals (Control of Use) Act 1995.

The terminology used to describe a crop or agricultural commodity should be consistent with the Codex Classification of Foods and Animal Feeds. This is generally the case for new chemical products but older chemicals (and old labels) may still include a range of alternative crop descriptions. For further information on which crops belong in each Codex classification, contact the Product Integrity Branch (AgVet Chemicals Program) of the DPIPWE.

The crop on which the chemical may be used can be expressed in very specific or in general terms.

The following examples demonstrate the possibilities and how they should be interpreted:

Leafy vegetables	Would allow application of the chemical to all crops in this classification including lettuce, silver beet, spinach, celery, endive, chard, beet leaves and all other leafy vegetables which fall into this classification.
Leafy vegetables including: lettuce, silver beet, endive	Note that the use of the term including makes this description all-encompassing and can be interpreted as all leafy vegetables, including... The list of crops which follow merely serves as an example of what is included in this class. It therefore carries the same meaning as the leafy vegetables description above.
Leafy vegetables: lettuce,silver beet	Written in this form, Leafy vegetables is the category and the only crops within the category on which the chemical may be used are lettuce and silver beet.
Lettuce	Only to be used on Lettuce

Other references that can sometimes cause confusion include:

Cereal grains	This category includes barley, wheat, oats, rice sorghum and buck-wheat. It does not include oilseeds such as canola or any of the pulses such as chickpeas, mung beans or navy beans.
Forage crop	A crop grown specifically for the purpose of being grazed by, or fed to, livestock, but excluding pasture. The term excludes crops such as cereals, oil seeds, vegetables and cole crops which may be grazed as opportunity crops. If any of these crops are to be grown for forage they will be specifically referred to as, for instance "cereals for forage".
Pasture	Herbage grown specifically for the purpose of being grazed by, or fed to, livestock. Pasture includes lucerne, medics, clovers and grasses, whether for grazing or seed crops. The word 'herbage' excludes crops such as cereals, oilseeds, vegetables and cole crops.

Where the label refers to a non-crop situation a range of more generic terms may be used. The following examples serve to illustrate the point:

• Agricultural buildings: Storage buildings, silos, hay sheds, milking sheds, pig sties, intensive animal houses, barns, poultry houses and machinery sheds.
• Commercial and industrial areas: Factories, factory land, industrial sites, parking lots, fuel storage sites, outside chemical storage areas and adjoining areas.
• Domestic and public service areas: Houses, residential subdivisions, schools, hospitals, restaurants, hotels, motels, cafes, playground and recreational areas (golf courses, municipal parks and gardens, etc.), rubbish tips.
• Crop land: Land which may be used to produce agricultural or horticultural crops such as vegetables, fruits, poppies, pyrethrum and including livestock (pasture and forage crops).
• Non-crop areas: Areas of land not being used or not intended to be used for cropping or grazing. These areas include areas around farm buildings, along fences and roadsides, rights-of-way, storage areas and wastelands.
• Structural treatments or grain storage treatment: Clearly, these situations will involve treatments to structures and not to the stored commodities. The implication in these situations is that commodities should not be contaminated directly by these treatments.

2.2 The Pest Controlled

The pest controlled is usually listed in the second column of the DIRECTIONS FOR USE table. Herbicide labels are often very complex with numerous weed species and control options provided. Particular care should be taken in reading herbicide labels in order to ensure that use patterns are interpreted correctly.

The description of the pest can be specific or general depending on the circumstance and these are illustrated in the following examples:

Aphids, stored product pests leaf spots, fungal diseases grasses, broad leafed weeds	When generic terms such as these are used to describe the pest, the product could be used to control all species which fall into these classifications. Whether or not a particular species falls into a particular generic class is a question of scientific judgement.
Annual weeds including: amaranth barley grass barnyard grass canary grass Stored product insect pests including: saw toothed grain beetle, grain weevils and Indian meal moth	Note that the use of the term including makes these descriptions all-encompassing. They can be interpreted as covering all of the pests in the class , including... The list of pests which follow merely serves as an example of what is included in this class of pest. As a consequence, the use of the term including has the same effect as just listing the class or generic group of pests as in the previous example.
Green peach aphid cabbage aphid black spot and shot hole barnyard grass, canary grass	When the accepted common name of a particular species is given, the product can only be used to control these species. In some cases, several pest species may share the same common name as a result of regional differences in the usage of the common name. In these cases some scientific judgement is required to identify the target pest. Where it is necessary to avoid confusion, product labels will include the full scientific name of the pest.
Annual weeds controlled: amaranth, barley grass, barnyard grass, canary grass Bacterial diseases controlled: bacterial canker, bacterial spot	In these examples a class of pest is first defined with the specific species listed below. The term including is absent and the use pattern would therefore only apply to those species listed.

2.3 State Use Patterns

Where there is no State column or no other reference to States you may assume that the uses on the label are approved for all States.

In many cases, the product label will identify which use patterns are applicable to which States. Only those use patterns that identify Tas or 'All States', can be used in Tasmania unless the use is allowed under a permit issued by the APVMA or the Registrar of Chemical Products.

2.4 Rate of Application

The rate of application of the chemical can be expressed in a number of ways including:

• as quantity of product per unit area, for example:- g, kg or L/ha
• as product dilution, for example:- g, kg or L/100L; or
• per volume treated, for example:- g, kg or L/m³

You must not advise the use of, or use, a registered product at a rate which is greater than or more frequent than the rate on the label unless the use is approved by a permit issued by the APVMA or the Registrar of Chemical Products. However, you may use an agricultural chemical product at lower rate of application or less frequently than advised on the label, if you accept the risk the product may not provide effective control at a lower rate or frequency of application.

Circumstances are arising where application rates, particularly on older labels, do not reflect modern application techniques, particularly for low volume spraying. Advisers and users need to apply some professional judgement in determining whether the proposed application rate (using the newer technology) is still consistent with the label application rate. Particular care should be taken where the rate of application of product increases or where farmers are required to handle and apply more concentrated spray solutions. Growers should seek clarification from the Product Integrity Branch (AgVet Chemicals Program) and obtain a permit if the change in the application technique will lead to an illegal change in the application rate.

2.5 Critical Comments

The critical comments column contains information which guides the user on aspects of the application which are relevant to a specific use pattern. The type of information which can appear in the critical comments includes the following:

• timing and frequency of application, including crop growth stage, pest stage or pressure
• instructions relating to integrated pest management
• the influence of weather and other meteorological factors
• guidance on selecting the appropriate rate when a range of rates is shown
• comments on crop or animal safety
• volume of prepared spray needed for proper application
• other appropriate information.

Much of the information which appears in the critical comments is there to provide guidance to the user on how to manage the pest population and obtain maximum efficacy. This information will often mirror advisory messages which are being communicated to growers through other means.

There may be circumstances, however, where the information which appears in the critical comments on the label can no longer be considered best practice. An example could be where, as a result of recent research or expert information, a new pest population threshold is proposed.

Before using a chemical product in a manner contrary to an instruction or information in the critical comments of a label, advisers and users should consider whether the instruction or information is there to avoid harm to the health or property of any person. Advisers and users may wish to seek advice from the Product Integrity Branch (AgVet Chemicals Program) in making this determination. Ultimately, the situation may warrant the issue of a permit to allow the instruction to be modified.

---

3. Withholding Periods

The purpose of withholding periods (WHPs) is to avoid residues of agricultural chemicals and their metabolites which exceed Maximum Residue Limit (MRLs) in raw agricultural commodities and in foods for humans or animals.

The withholding period statements will usually appear below the Directions for Use table. Where there are two or more withholding periods (WHPs) and the Directions for Use are in tabular form, a `WHP' column may be included in the table in addition to the statements below the table.

If a use requires both harvest (H) and grazing (G) withholding periods, the label will identify these by including in the table either (H) or (G) after the appropriate figures.

Following are some examples of common withholding period statements:

DO NOT HARVEST FOR [...] DAYS AFTER APPLICATION

DO NOT GRAZE OR CUT FOR STOCK FOOD FOR [...] DAYS AFTER APPLICATION

REMOVE STOCK FROM TREATED AREA [...] DAYS BEFORE SLAUGHTER

DO NOT USE TREATED PRODUCE FOR HUMAN CONSUMPTION OR FOR STOCK FOOD WITHIN [...] DAYS OF TREATMENT

NOT REQUIRED WHEN USED AS DIRECTED

Where a product has no grazing withholding period, crops treated with the product should not be grazed prior to harvest. In these circumstances it is also uncertain whether stock that graze the stubble or are fed by-products of the treated crop will develop detectable residues of the chemical. Where appropriate, advisers and users should contact the chemical manufacturer for advice on managing chemical residues in the crop or in stock.

You must not advise, or apply, withholding periods other than those that appear on the label of a registered product or a permit issued by the APVMA or the Registrar of Chemical Products.

Keep in mind that withholding periods are often formulation specific as well product/active specific. For example, you must not assume that the emulsifiable concentrate (EC) formulation of a chemical will have the same withholding periods as the ultra low volume (ULV) formulation.

---

4. General Instructions

Other information available to the user and not already included in the Directions for Use will appear as general instructions on the product label under various headings. Instructions may be given about the modes of application of the product and usually make it clear what methods of application (eg, aerial application) are acceptable. If you are unsure about which modes of application are acceptable, advice should be sought from the product manufacturer or the Product Integrity Branch (AgVet Chemicals Program).

4.1 Compatibility

This includes information on products which could be tank-mixed, or other products that should not be mixed.

You must not tank mix, or advise the tank-mixing of chemicals where the label specifically warns against it.

Where there is no such prohibition on the label, growers may use the chemical in a tank mix. The 'Rate of Application' of each component remains as if each chemical were to be used on its own. Advice to increase the rate of application of any component should only be given if the use is allowed under a permit from the APVMA or the Registrar of Chemical Products.

The use of tank-mixes, other than those identified on the product label is at the user's risk. Agricultural advisers should avoid recommending tank-mixes unless they have direct evidence that the chemicals are compatible and the mixture will be effective for the purpose intended.

It should be noted that formulations may change without being reflected in a label change. This could lead to previously compatible products becoming incompatible.

4.2 Resistance and IPM Statements

These statements are used by manufacturers to raise awareness of how the product can be used in a manner that avoids the development of resistance, or in more sophisticated pest management strategies. Occasionally manufacturers will use this section to disclaim liability for control failures arising from the treatment of resistant populations of the pest.

Advisers should remind their clients to take note of, and users should note any resistance statement which might appear on the product label and consider how their past history of chemical use might impact on the development of resistance in the target pest.

4.3 Protection Statements

Protection statements aim to minimise hazards to crops, native or other non target plants, livestock, wildlife, fish, crustacea and the environment through approved use of a registered product. Protection statements will usually appear under the following headings as appropriate:

Protection of crops, native and other non target plants

Protection of livestock

Protection of wildlife, fish, crustaceans and environment

There is a long list of protection statements which can appear on product labels with the following examples amongst the most common:

DO NOT apply under weather conditions, or from spraying equipment, that may cause spray to drift onto nearby susceptible plants/crops, cropping lands or pastures.

DO NOT contaminate streams, rivers or waterways with the chemical or used containers.

In most cases protection statements convey a clear message to the user of what they should not do or an outcome they should avoid. As a group, the protection statements go a long way towards defining the responsibility of the user to avoid harm and are consequently seen as an important tool in enforcement. Specific prohibitions on the label must be followed.

There are however a few protection statements which have at times caused some confusion amongst advisers and their clients, for example:

DO NOT graze any treated area or cut for stock food

This statement has been interpreted by some to restrict in perpetuity the grazing of areas treated with the particular chemical.

Such statements generally appear on the label where insufficient data was provided at the time of registration to set an MRL or grazing withholding period. This prohibition should therefore be seen as an attempt to avoid harm to stock or to avoid violative residues in the absence of more specific label instructions.

The responsibility rests with the user to decide whether, at some future point in time, the treated area still represents a risk to stock. If unsure about the residual properties of the product, advice should be sought from the manufacturer or the Product Integrity Branch (AgVet Chemicals Program).

Dangerous to bees. DO NOT spray any plants in flower while bees are foraging.

The purpose of this statement is to warn the user that the chemical is particularly toxic to bees. Bees are an important aid to pollination in some crops and it is usually in the interests of the grower to protect foraging bees from harm. Chemicals which may be toxic to bees should be applied early in the morning or in the evening when bees are not foraging. Growers should notify commercial apiarists with bee hives in the vicinity of the crop prior to the application of chemicals which might harm foraging bees.

---

5. Safety Directions

The safety directions relate to the safe handling, use and storage of the product and will usually include a number of statements warning of specific hazards as well as instructions on preventing exposure. These warnings and instructions are expressed in a standardised format and content which reflects the hazard posed by the chemical product. Chemical products which pose a similar hazard will have the same warnings and instructions.

Where the directions refer to specific personal protective equipment or protective clothing, that equipment or clothing must be worn and used in the situation and manner described. Other directions should be used in assessing the health and safety risks associated with using the product and in identifying appropriate risk management strategies to be implemented to control those risks.

---

6. Storage and Disposal

The product label includes instructions on the proper method for storing the product and for disposing of the empty container and any unused spray solution. These instructions are of a generic type and do not necessarily reflect the constraints that might apply to these actions in Tasmania.

Advisers and users should be aware that the storage of products that are dangerous goods are subject to Dangerous Goods legislation. The disposal of used containers, or waste agricultural chemical product is subject to waste disposal legislation administered by the EPA Division. Contact EnvironmentEnquiries@environment.tas.gov.au or call 03 6165 4599 for advice.

---

7. First Aid Instructions

Most agricultural chemicals are required to be labelled with directions for first aid attention in case of poisoning. First aid instructions will usually involve actions that can be taken immediately to reduce the effects of poisoning and are expressed in terms which can be followed by persons with little or no first aid training.

Agricultural advisers should not attempt to interpret, qualify or explain the first aid instructions when giving advice to clients. Any issues relating to first aid statements should be referred to the Department of Health & Human Services or Workplace Standards Tasmania.

---

Further Information