Following label comments for WHP and ESI

Posted in Agronomy alert on Oct 18, 2015

Fungicides (especially chlorothalonil) used on pulse crops have withholding periods (WHP) and Export Slaughter Intervals (ESI) that must be followed. This article clarifies some of the label comments on fungicide products and the grower’s legal responsibilities.

Following label comments for WHP and ESI

by Mary Raynes, Industry Development Manager—Southern Australia

Why the different labels with different WHP comments?

Currently there are two different types of labels:

  1. Generic labels—these are older labels and all data supporting the label is publically available and anyone can use this data to support label comments.
  2. Proprietary labels—these are newer labels that draw on supporting data that is currently protected and is not publically available for other companies to use.

There are currently proprietary labels on three fungicide products used on pulses. They are:

  1. Barrack Betterstick Fungicide
  2. Crop Care Barrack 720 Fungicide
  3. Nufarm Unite 720 Fungicde

Under ‘State Control of Use Legislation’, all users are required to follow the label instructions and conditions of use of the product applied and not those of any similar product.

Logic may suggest that if two products have the same active ingredient and the same application rate then it wouldn’t matter which label conditions you followed. However sensible this may seem it is not what the law says. The law states that you must follow the directions and conditions of the label of the product used.

Generic labels for chlorothalonil

The generic labels have registered claims for their use on beans – broad (faba), peanuts and peas. There is no claim for their use on lentil or chickpea and as such these products cannot be legally used on either of these crops.

If these products are used on beans (broad/faba) then the following conditions apply:

  1. Withholding period (WHP) to harvest is 7 days.

This means that once a crop has been treated, no form of livestock may graze on that crop residue. This condition applies whether it is a failed crop, crop cut for hay or a harvested crop.

Proprietary labels for chlorothalonil

The proprietary labels have registered claims for their use on beans – broad (faba), chickpea, lentil, peanuts and peas (processing).

If these products are used then the following conditions apply:

  1. Withholding period (WHP) to harvest is 14 days.
  2. Withholding period (WHP) to grazing is 14 days. (NB: This grazing withholding period applies only to stock slaughtered for sale in domestic markets.
  3. Some export markets apply different standards and to meet these standards in addition to complying with the grazing withholding period of 14 days, the Export Slaughter Interval (ESI) of 63 days needs to be observed before stock are sold or slaughtered. An ESI of 63 days means that livestock that have grazed on, or been fed treated forage, silage, fodder or stubble, should be placed on clean feed for 63 days (9 weeks) prior to slaughter. If a treated crop is cut for hay/silage, livestock fed the hay/silage must meet the 63 day ESI before they can be sold for slaughter and sale to export markets.
  4. DO NOT graze or feed treated forage or fodder to livestock that may be used to produce milk for human consumption.

Operate within the law

The differences between the two label types will continue until at least 14 December 2015 when the data protection will be lifted. After this date other companies can access this data for the purpose of changing their labels and it is likely that many of the generic products will carry the new label claims for chickpea and lentil along with the WHP and ESI requirements as outlined above.

More information: Pulse Australia and APVMA

Mary Raynes, Pulse Australia (Industry Development Manager – Southern)
T: 0408 591 193 E:

Pulse Australia blog home | Subscribe