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Changes to Endosulfan Use Requirements

September 1999

General Information

Important changes have been made to the endosulfan label and to the way endosulfan is supplied.

The changes are required as a result of the NRA comprehensive review of endosulfan and the NRA's consideration of the 1998/1999 problems of endosulfan residues in beef.   The changes affect all products containing endosulfan.

After 30 September 1999, all endosulfan products must carry the new label and all users must follow new label instructions.

Endosulfan can now ONLY BE SUPPLIED TO OR USED BY AN AUTHORISED PERSON.

An authorised person is one who;

  • conducts the business of selling or supplying agricultural chemical products or
  • is a State licensed spray contractor or
  • is Farmcare Australia certified, holding a valid National Farmcare Chemical User Certificate (known in Victoria as Victorian Farm Chemical Users Course and in Queensland as ChemSmart or Chemsafe Training Queensland Certificate or Certificate of Agricultural Chemical Application issued by QLD Ag Chemicals Accreditation Committee).

Farmcare is currently in the process of changing its name to ChemCert Australia.  The Farmcare qualification will soon be known as ChemCert Australia Farm Chemical User Accreditation.  At the present time, no other certification is recognised by the NRA.   In future the NRA will recognise other certifications when they are shown to meet an acceptable standard.

State-based Farmcare (ChemCert) committees are responsible for delivering training in each State.  Contact details for Farmcare (ChemCert) are:

State Phone Fax
Qld 07 5460 1295 07 5460 1283
NSW 02 9251 1700 02 9231 5249
NT 08 8946 6328 08 8946 6690
SA 08 8226 1842 08 8226 1844
Tas 03 6331 2131 03 6331 4344
Vic 03 5622 2055 03 5622 2199
WA

 08 9341 5325

 08 9341 5325

Note that both the person who purchases endosulfan, and all those involved in mixing and applying it must be certified.
In Victoria, users of S7 chemicals such as endosulfan must also hold an Agricultural Chemicals User Permit (ACUP).
In Queensland, note that certificates older than 5 years will only be valid until 1 July 2000.

Non-resident owner, the farm manager or whoever is ultimately responsible for the crop is regarded as the "grower" and carries the responsibilities of the grower.

Growers must now keep detailed records of endosulfan use.

The new rules require every grower using endosulfan to keep a record for each application.  The new label defines the particulars which must be recorded.  These include details of the grower and person applying the chemical (if not the grower), the field and crop, the weather and application methods.  For convenience, the NRA and endosulfan product manufacturers have produced an "Endosulfan Spray Record" form, which contains all of the required particulars (available from the NRA or endosulfan retailers).  Completed records must be retained for 2 years from the application date.

Growers should be aware that they have the primary responsibility for keeping each application record.  For example, if a grower hires an aerial operator to apply endosulfan on a crop, the grower cannot simply rely on the records of the aerial operator as being adequate.  The grower must take care to obtain from the aerial operator any information called for by the grower's application record form such as weather information and application details.  The grower must ensure that his or her own spray record is completed for each application.

The grower, of course, is also responsible for ensuring that all other aspects of the label instructions are followed.  Cotton growers have a number of additional responsibilities.

Retailers also have new mandatory responsibilities.

Retailers are required to:

  • display an "Endosulfan Users' Notice" in a prominent position in the premises from which endosulfan supply occurs.
  • satisfy themselves that the purchaser of endosulfan is an authorised person. Other people may collect the endosulfan on behalf of the authorised person, for example a relative or employee, but the "growers" certificate must still be sighted by the retailer before the sale can be made.
  • keep  certain records of each endosulfan sale.  (See the section "Special Information for Endosulfan Retailers and Resellers".)

Grower, applicator and reseller records are subject to audit to ensure compliance with the regulations.

Only authorised regulatory authorities may inspect or audit retailer, grower or applicator records.  Authorised regulatory authorities include the NRA and the appropriate State authorities such as Departments of Agriculture, Primary Industries and Environmental Protection authorities.

Old labels have been cancelled and the new label instructions must be followed.

From 30 September 1999, all endosulfan products purchased from resellers must bear the new label incorporating all of the new requirements.  After 30 September 1999, users possessing endosulfan products with old labels need to pick up copies of new labels from their endosulfan dealers or retailers and must follow the new directions for all endosulfan uses.

There is now a limit on how many endosulfan applications that can be made.

A limit of 2 full coverage applications of endosulfan per crop per growing season has been placed on all crops except orchards unless irrigation tail water and up to 25 mm of rainfall can be captured on farm.  In addition, use in cotton is further limited to an absolute maximum of 3 full coverage  sprays.

The term "full coverage" application means the amount of product specified on the label for complete coverage of any particular crop. This term is intended to accommodate the practice of band spraying.  Band spraying is done early in the crop's growth when the plants are small and a significant amount of bare earth between rows is still not covered by the crop's canopy.  Nozzles held directly over the row can apply spray to the small plants in the row and not to the bare earth in between.  For example, nozzles might be set so that only 1/3 of the field's area was actually sprayed. Three 1/3 area band sprays would be equivalent to a single full coverage application.

There are changes to withholding periods and slaughter intervals for endosulfan.

All information relating to Withholding Periods (WHPs) and animal slaughter intervals for endosulfan is now found in a new section of the label under "RESIDUE MANAGEMENT".

This includes a section "FOR HUMAN FOODS" which lists WHPs that apply to produce destined for human consumption.  An important change concerns WHPs which were previously less than two days but which have now been increased to two days (includes vegetables such as cucurbits and tomatoes).

The new label text also provides information to help avoid endosulfan residues in animal produce that exceed established limits (Maximum Residue Limits or MRLs).   The section "FOR ANIMAL FEEDS" details crop WHPs and the necessary animal management measures required for various crops which may be fed to or grazed by animals.  It is important to note that:

  • sorghum and maize fodder now require an 8 week period from the time of the last endosulfan application until grazing or harvest, with an additional 42 day interval from last feeding until slaughter.
  • for several commodities, feeding to animals is not permitted following treatment with endosulfan.
  • for grain legumes and pulses, a 42 day slaughter interval only needs to apply where endosulfan applications have been made to foliage.  Applications prior to seedling emergence (bare earth treatments) have a nil slaughter interval.

New statements on Front Panel

RESTRICTED CHEMICAL PRODUCT - ONLY TO BE SUPPLIED TO OR USED BY AN AUTHORISED PERSON.

A CONDITION OF REGISTRATION OF THIS PRODUCT IS THAT IT WILL ONLY BE SUPPLIED TO AN AUTHORISED PERSON.  TO DO OTHERWISE IS AN OFFENCE UNDER THE AGVET CODE.

Revised Safety Directions

Additional warning statements, and upgraded protective clothing requirements have been added.  Refer to SAFETY DIRECTIONS on the label.

Additional Protection statements

Three new statements prohibit application under certain conditions.  Refer to Protection of Wildlife, Fish, Crustaceans and Environment on the label.

New Re-entry Period restrictions

Specific instructions on the time interval between application and re-entry into the treated field and necessary clothing requirements have been added.  Refer to Re-entry Period on the label.

Additional Precautions

Precautions

  • To minimise exposure, a vehicle equipped with an enclosed cab should be used for ground spraying operations when practicable.
  • Do not use in confined spaces eg. glasshouse, greenhouses, igloos or tunnels
  • Your local distributor of endosulfan products
  • Your State Department of Agriculture, Department of Primary Industries or Environmental Protection Authority.
  • Aerial Agricultural Assoc. of Australia  (AAAA)  or your local aerial operator
  • Local groundrig operator
  • Local Cotton BMP facilitator
  • The National Registration Authority(NRA) - Phone: 02 6272 3213 or visit the NRA website.

Cotton Specific Requirements

Endosulfan use in cotton has additional requirements.

Over 70% of all endosulfan used in Australia is used on cotton.  The NRA review of endosulfan found that this use required special restrictions.  Since then further restrictions have been added due to problems associated with spray drift and residue violations in cattle experienced in the 1998/1999 cotton season.

  • A limit on the amount of endosulfan that can be applied in a single season.
  • Applications of endosulfan must be in accordance with the current cotton BMP manual and its associated spray and drift management plan.  If any conflict exists between the label and BMP, the printed label directions must be followed.
  • Cotton growers must notify their neighbours prior to spraying endosulfan according to instructions on the label.  Exactly who their neighbours are is defined on the label.
  • Cotton growers must observe downwind no-spray zones unless written consent to waive the downwind no-spray zone is obtained from the appropriate neighbour.
  • A crop height restriction applies to cotton when sprayed with endosulfan by air.

*         Endosulfan EC    3/4 20 cm minimum height of cotton plants

*         Endosulfan ULV 3/4 30 cm minimum height of cotton plants

This restriction has been imposed to reduce the potential for drift by stopping aerial application to cotton crops which are too small to provide an adequate catching surface for the spray droplets.  Growers will still be able to treat small plants with EC formulations of endosulfan by ground, preferably by band spraying.

  • Specific application methods to cotton for both ULV and EC formulations are now required and are detailed on the label
  • Endosulfan may only be applied on cotton during specific time periods.  This period is different for different formulations, application methods and geographical areas.

There is a limit on the number of applications of endosulfan allowed to cotton.

For cotton there is a special limit on the amount of endosulfan that can be applied per crop, in a single season.  Where irrigation tailwater and up to 25 mm of rainfall can be captured and contained on farm, up to 2205 grams of active ingredient can be applied.  This is equivalent to 3 full coverage, full label rate sprays of endosulfan.

Where tailwater and 25mm of rainfall cannot be contained, the number of sprays is limited to 1470 grams active ingredient which is equivalent to 2 full coverage, full label rate sprays.

Ground application using a banded spray method can extend the actual number of applications of endosulfan (see previous explanation of band spraying in the "General Information" section under "There are now restrictions on how many endosulfan applications that can be made").

  • 1500 metres for ULV formulations
  • 750 metres for EC formulations applied by air
  • 200 metres for EC formulations applied by ground

The label allows a grower and neighbour to arrange a mutually preferred method of notification; such a method must be in the form of a written agreement and can be arranged before the growing season.  If the grower and neighbour cannot agree on a method, then the grower must follow the detailed method of notification specified on the label.

Mandatory notification does not imply a veto power by the neighbour over the application.  It is intended to allow neighbouring cattle producers or neighbouring residents to take remedial steps in the event of an accident or a sudden wind change during spraying which might result in contamination of pasture or a home.  For example, the cattle producer might quickly move the cattle to a different area before endosulfan residues could build up in the animals or alternatively might choose to delay movement of those cattle to market until any possible residues have been cleared from their bodies.

The NRA has produced a standard form to use for notifying neighbours and for endosulfan spray record keeping.  The forms can be obtained through the NRA or through endosulfan product retailers.

Downwind no-spray zones must be observed unless written consent to waive them has been obtained from the neighbour.

Downwind no-spray zones are zones of higher risk for spray drift effects where spraying cannot take place without written consent from the downwind neighbour.  The width of the downwind no-spray-zone is the same as specified for neighbour notification and is determined in the same way according to formulation and application type.  The no-spray zone begins at the nearest downwind property boundary or residence and extends toward or into the cotton field to be sprayed.  It only applies to the downwind direction at the time of spraying.

If a neighbour is not concerned about possible spray drift, the grower can negotiate for that neighbour's written permission to waive the protective zone.  Such an agreement is allowed to be in effect for an entire season.

Since ultra-low-volume (ULV) formulations have the greatest tendency to drift, the larger ULV downwind-no-spray zone will not only help protect downwind properties, but will also limit the use of ULV to the very largest or isolated of properties and effectively reduce its use overall.

Specific application methods are now required by the new label.

The new label specifies in much greater detail how endosulfan must be applied for both ULV and EC formulations.  There are specifications for meteorological conditions, equipment and application criteria.  Some specifications such as which types of nozzles must be used, allowable boom lengths, volumes and pressures are mandatory while others are advisory.

These requirements and instructions are all designed to limit the amount of endosulfan moving off the intended target.

Refer to Application in GENERAL INSTRUCTIONS on the label, and the specific new sections HIGH VOLUME LARGE-DROPLET-PLACEMENT TECHNIQUE SPECIFICATIONS FOR EC FORMULATIONS and ULV APPLICATION BY AIR.

Application of endosulfan on cotton can only take place during certain time windows.

The allowed time windows are determined by the formulation used, the method used and by the geographic area where the application takes place.  They are summarised in the table below.

October November December January

1st - 15th

16th - 31st

1st - 14th

15th - 30th

1st - 14th

15th - 31st

1st - 15th

16th - 31st

Endosulfan EC - Ground application

  
               
     

Endosulfan EC - Aerial Application1

 
               
   

Endosulfan EC - Aerial Application2

   
               
       

Endosulfan ULV - Aerial Application1

 
               
     

Endosulfan ULV - Aerial Application2

   
               
  1. All cotton growing areas except for the areas listed in (2) below.
  2. Shire council areas Bourke and Walgett in NSW, and Balonne, Banana, Bauhinia, Belyando, Broadsound, Dalrymple, Duaringa, Emerald, Peak Downs, Richmond and Waroo in QLD.

Special Information for Endosulfan Product Retailers and Resellers

Changes to endosulfan labels and restrictions on the supply of endosulfan require all those who sell endosulfan to take on certain new responsibilities.  These responsibilities are described below.

Supply Only to Authorised Persons

Endosulfan must only be supplied to a person who is an authorised person (the Recipient).  An authorised person is a person:

  1. who conducts the business of selling or supplying agricultural chemical products or
  2. who is a State licensed spraying contractor or
  3. who holds a National Farm Chemical User Certificate accredited by Farmcare Australia Farm Chemical User Training Program Incorporated, a ChemCert Australia Farm Chemical User Accreditation or another accreditation as published in the NRA Gazette as acceptable to the NRA (the Authorising Certificate).

Suitable Training

The NRA will recognise all valid certifications issued through Farmcare or ChemCert Australia (Farmcare is currently in the process of changing its name to ChemCert).  Note that the Farmcare Australia accreditation is known by a different name in Victoria and Queensland:

  • in Victoria 3/4 Victorian Farm Chemical Users Course,
  • in Queensland 3/4 ChemSmart Training Queensland Certificate of Accreditation, (formerly Chemsafe Training, and prior to 1996 the Certificate of Agricultural Chemical Application issued by the Queensland Agricultural Chemicals Accreditation Committee). In Queensland, note that certificates older than 5 years will only be valid until 1 July 2000.

The NRA also regards any State licensed spraying contractor/ chemical applicator  as appropriately certified.  At this time no other certification or qualification is recognised by the NRA.

Verifying Accreditation

The supplier (reseller) of endosulfan will need to see the actual certificate or licence of the purchaser for the first sale and record the unique number of that certificate or licence into the sales record.  For convenience, the supplier should photocopy the certificate or licence and keep it on file for future sales (such as telephone orders and deliveries to the grower) until that certificate expires.

When it is not convenient or possible for the purchaser to pick up the product directly and a copy of the certificate is not already on file, the grower may send someone else as long as the person acting for the grower takes the grower's certificate to show the reseller.  The supplier must confirm that the person paying for and receiving the product is the person identified on the certificate.

Determining "the recipient"

Whoever is invoiced for the product is generally regarded as the purchaser or recipient.  Some additional special examples are presented below.

  • where a grower is invoiced for a product, but it is delivered to a spraying contractor for application, the grower is the recipient and must be suitably accredited.  This is the case even where the grower does not sight the product, and where he or his direct employees are not involved in its application.
  • where the sale is to an aerial applicator, who is contracted to apply endosulfan to a grower's crop, the applicator is regarded as the recipient.  If the applicator invoices the grower for the endosulfan product and the application separately, the applicator is considered to be supplying endosulfan, and the applicator would need to ensure the grower was suitably accredited and record the sale of endosulfan.
  • in the case of endosulfan invoiced to a company or non-resident farm owner, the farm manager or whoever is ultimately responsible for the crop requires suitable accreditation so that the supply can occur.

Keep Records Relating to Each Sale

Any person who supplies endosulfan must make, on each occasion on which the product is supplied to a Recipient, a record containing the following particulars:

  1. the distinguishing name of the product;
  2. the name and address of the supplier;
  3. the name and address of the Recipient;
  4. if the Recipient is not a person who conducts the business of selling or supplying agricultural chemical products, the distinguishing number or identifying mark of the Authorising Certificate or spraying contractor's license;
  5. the date of supply of the product to the Recipient and
  6. the quantity of the product supplied to the Recipient.

Note that the "name and address of the supplier" above refers to whoever is supplying endosulfan in this instance, that is, the details of the wholesaler or retailer concerned.

The NRA has produced a model form of an "endosulfan Sales Record" for recording sales of endosulfan products.  In addition, the NRA will accept copies of invoices as long as the invoice contains all of the information required in the sales record as noted above.

These sales records must be retained for at least 2 years from the date of sale and may be audited or inspected by regulatory authorities.

Display an "Endosulfan Users Notice"

Each person supplying or intending to supply this product must display an "Endosulfan Users' Notice" in a prominent position in the premises from which the supply occurs or is intended to occur.

The "Endosulfan Users Notice" is designed to alert potential users of endosulfan who visit retail chemical outlets of the following;

  • that changes have been made to endosulfan labels and that supply restrictions are in force
  • that endosulfan product must be used in accordance with the new approved label
  • some of the key new requirements and label changes

These notices have been produced by the NRA and will be sent to product retailers.

Supply of Product with the "Old Label"

All endosulfan products supplied by retailers after 30 September 1999 are required to bear new labels incorporating changes to the directions and requirements for the use of endosulfan.

Endosulfan products with the old label already in the retail network must be relabeled by the manufacturer before being sold.  All old endosulfan labels have been cancelled and users must follow the new labels from 30 September 1999.  Endosulfan product manufacturers will supply copies of new labels to retailers for distribution to end-users who hold stocks of endosulfan product with the old label.