Some very pertinent thoughts from Grant Hagerty
Recently I have fielded a number of enquiries regarding the use of two of our products on lucerne, namely Sharpen and Pulsar. Neither is registered for use on lucerne and before we can recommend their use we need a registration and to achieve this we need to establish crop selectivity, optimum timing for weed control, especially size and most importantly establish grazing withholding periods. In summary they need to be registered.
Whilst it is legal for growers to apply unregistered products on their own farmers under the "own use" provisions of the ACVM Act, it is also clearly stated no illegal residue can enter the food chain as a result of that use. In the case of produce for local human consumption this is qualified by establishing a default MRL (maximum residue level) of 0.1 ppm or mg/kg. The situation is different for produce grown for export or animal feeds. In the latter case the animal may be slaughtered and processed for export or is producing milk for processing and export. In all cases the exporters own standards must be complied with.
It may be the exporter Quality Assurance programme forbids the use of unregistered product, or there are protocols in place to administer such activities. There could also be guidelines for preferred WHPs that are more stringent than those approved by the ACVM. Overall the risk is that there may be unacceptable residues following use of unregistered products in lucerne.
New products for lucerne are far and few between, I believe we have some new alternatives but if untoward residues pop up in local and export produces, meat and milk those innovations may not be released.
The irony of the ACVM Act is that it is illegal for us to offer for sale a product we know will be used off label, but the ACVM Act allows users to do just that and suggest we are first point of contact should users want information regarding best practise for off label uses. Catch 22!
In summary can I suggest lucerne growers contain their enthusiasm for a season and let us complete the legal process, without surprises like residues getting in the way.