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Agriculture, Ecosystems and Environment 180 (2013) 5467

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Regulation of pesticides in Australia: The Great Barrier Reef as a case study for
evaluating effectiveness
Juliette King a , Frances Alexander b , Jon Brodie b,

WWF-Australia, Ground level, 129 Margaret Street Brisbane, Queensland 4000, Australia
Catchment to Reef Research Group, Australian Centre for Tropical Freshwater Research, James Cook University, Townsville, Queensland 4811, Australia

a r t i c l e

i n f o

Article history:
Received 22 February 2011
Received in revised form 25 May 2012
Accepted 1 July 2012
Available online 2 August 2012
Great Barrier Reef
Coral reefs

a b s t r a c t
Globally coral reefs are at threat from land-sourced pollution. In Australia it is well established that the
largest reef system in the world, the Great Barrier Reef, has been seriously damaged by land-sourced pollution primarily from agricultural activities. The Great Barrier Reef is Australias best documented case of
contamination of an ecosystem by pesticides. We describe Australias current regulatory arrangements
for managing pesticide risks to the environment at both national and state level and evaluate the regulatory response to pesticide pollution of the Great Barrier Reef (GBR) and its catchments as a case study. It
is argued that the relatively advanced state of knowledge about the problem and the Great Barrier Reefs
World Heritage status means that it presents the best case scenario for Australias ability to respond to
pesticide risks to the environment. Yet the only regulatory action taken to date restricted conditions
of use for particular chemical products introduced by the Queensland Government has occurred outside of the dedicated regulatory regime for managing pesticide risks. Other lower prole and less-studied
Australian water bodies are likely to be even less protected. The ad hoc, case-by-case and very slow chemical review process administered by Australias national pesticide regulator has not effectively assessed
or addressed chemical risks to the GBR. Some failures of the current system would be addressed by a
systematic re-registration program of the kind in place in the European Union and United States. We
conclude that to adequately protect the GBR, given its marine protected area and World Heritage status,
both the special management provisions for the area already existing plus an effective national pesticide
regulatory regime of the standard of the European Union are the minimum requirements.
2012 Elsevier B.V. All rights reserved.

1. Introduction
The Great Barrier Reef (GBR) lies along the north eastern coast of
Australia (Fig. 1) and was designated as a marine protected area by
the Australian Government in 1975 (the Great Barrier Reef Marine
Park (GBRMP)) with an Authority set up to manage the Park (the
Great Barrier Reef Marine Park Authority (GBRMPA)) under the
Great Barrier Reef Marine Park Act 1975 (Cth). It was included on the
World Heritage List in 1981 (the Great Barrier Reef World Heritage
Area (GBRWHA)). The extent of the two areas is generally similar
with notable differences along the coast. The GBRMP extends up
to the low water mark generally but with numerous exclusions in
port areas and in enclosed waters whereas the GBRWHA extends
completely to the high water mark along the whole coast thus
including estuarine areas. The GBRWHA contains more than 3000
coral reefs but also extensive areas of seagrass meadows, mangrove forests, soft bottom communities and open water ecosystems

Corresponding author. Tel.: +61 7 4781 6435; fax: +61 7 4781 5589.
E-mail address: (J. Brodie).
0167-8809/$ see front matter 2012 Elsevier B.V. All rights reserved.

(Brodie, 2003). The management arrangements for the GBR are

complex with the GBRMP managed by GBRMPA in collaboration
with the Queensland Government and the GBRWHA overseen by
the Commonwealth Department of Sustainability, Environment,
Water, Populations and Communities (SEWPaC).
Globally most coral reefs are threatened by human activities
(Burke et al., 2011) and many show signs of degradation (e.g.
Pandol et al., 2003). Reefs are exposed to a combination of anthropogenic stresses including destructive shing practices, overshing
or loss of herbivorous sh and other grazing organisms, increased
discharge from the land of sediment, nutrients and pesticides,
coral predator outbreaks linked to trophic changes in the system, increased bleaching associated with global climate change,
and increased incidence of and severity of coral diseases. These
pressures have led to precipitous declines in coral cover on many
coral reef provinces from values near 60% more than 50 years ago
to near 20% recently, and led to persistent shifts from coral dominance to non-coral and algal dominance (e.g. Norstrm et al., 2009;
Maina et al., 2011).
Similarly on the GBR over recent decades coral reefs and seagrass meadows in the central and southern GBR have been in severe

J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467


Fig. 1. The Great Barrier Reef and catchment area showing the Wet Tropics, Burdekin and Mackay-Whitsunday regions.

decline (Brodie and Waterhouse, 2012; Sweatman et al., 2011;

Hughes et al., 2011). Overall on the GBR coral cover has declined
from 28% in 1986 to 22% in 2004 (Sweatman et al., 2011) with
even greater declines estimated in the period from the 1960s to
1986 (Hughes et al., 2011) while further declines from 22% (2004)
to a current 16% are estimated from, as yet, unpublished analysis
of AIMS monitoring data. Seagrass is also in decline, with chronic
stresses driving decline especially in the Townsville region (Brodie
and Waterhouse, 2012) and the impacts of severe weather exacerbating the decline (Devlin et al., 2012) with subsequent stress and
mortality of dugongs and turtles through starvation. The causes
of the declining ecosystem health are well established as being
associated with a similar set of culprits as for global reefsshing
impacts, terrestrial runoff from agriculture of sediment, nutrients
and pesticides, and global climate change impacts (Brodie and
Waterhouse, 2012).

Water quality issues for the GBR arising from discharge of pollutants from the adjacent catchment areas (known as the Great
Barrier Reef Catchment Area (GBRCA)) have long been recognised,
see for example Brodie and Fabricius (2008), Brodie et al. (2001a,
2008a,b, 2011a, 2012), Death and Fabricius (2010), Furnas (2003),
Waterhouse et al. (2009). Water quality issues are recognised as one
of the main contributing factors to the loss of coral cover on the GBR.
The weight of scientic evidence of the severity of the issue (e.g.
Brodie et al., 2001b; Furnas, 2003) eventually led the Australian
and Queensland Governments to develop the Reef Water Quality
Protection Plan (Anon., 2003), updated in 2009 (Anon., 2009), to
halt and reverse the decline in water quality entering the GBR from
non-point sources of pollution. The Australian Government initiated the Reef Rescue program in 2008 which provides nancial
incentives for farmers to adopt improved management practices,
while the Queensland Government introduced its Reef Protection


J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Package of legislative reforms in 2009 (Brodie et al., 2012) which

included new obligations and restrictions for sugarcane growers
and beef cattle graziers in certain GBR catchments.
There is a long history of pesticide studies in the GBR. Due to its
World Heritage status many more research and monitoring studies have been carried out in the GBR and the GBRCA than in most
equivalent areas in Australia. While early studies focused on the
organochlorine insecticides, from 1999 widespread studies along
most of the GBR coast discovered pesticide residues, particularly
herbicides such as diuron and atrazine, in coastal sediments, seagrass and irrigation tailwaters (Haynes et al., 2000b; Mller et al.,
2000). Further studies showed that all rivers discharging to the GBR
which were examined and which drained agricultural and urban
areas showed extensive pesticide contamination frequently above
water quality guidelines (Bainbridge et al., 2009; Davis et al., 2008,
2012, 2013; Ham, 2007; Lewis et al., 2009; McMahon et al., 2005;
Mitchell et al., 2005; Packett et al., 2009; Smith et al., 2012) while
studies in the GBR lagoon waters also showed widespread pesticide contamination with levels occasionally above water quality
guidelines (e.g. Kennedy et al., 2012a,b; Lewis et al., 2009, 2012;
Shaw et al., 2010). Estimates of the loads of pesticides discharged
from GBR rivers are available (Kroon et al., 2012), with a total of
30,000 kg/year of PSII herbicides discharged from the GBRCA. Most
recently as a result of the Reef Plan Paddock to Reef Integrated
Monitoring, Modelling and Reporting Program (Carroll et al., 2012)
more systematic monitoring of pesticide residues across the GBR
and its catchments have shown very wide spread contamination of
waterways with a range of pesticides, with frequent exceedance of
Australian water quality guidelines often to the extent of 1050
times the guideline (trigger value) (Smith et al., 2012; Kennedy
et al., 2012a).
Further to these eld studies an extensive series of laboratory
based studies have claried the toxicity of the relevant herbicides to
local marine species including corals (e.g. Cantin et al., 2007; Jones,
2005; Negri et al., 2005), seagrass (e.g. Haynes et al., 2000a; Gao
et al., 2011), coralline algae (Harrington et al., 2005), mangroves
(e.g. Duke et al., 2005), microphytobenthos (e.g. Magnusson et al.,
2012) and foraminifera (van Dam et al., 2012). The authority of this
published work led the GBRMPA to conclude (GBRMPA, 2009a) that
pesticide runoff poses a very high risk to the Reef ecosystem, nding that nearly a third of the GBR is now exposed to herbicides.
This assessment is supported by recently published work showing the level of risk to coastal wetland habitats (specically in the
lower Burdekin region) using the PERPEST model (Davis et al., 2013)
and more widely in the marine waters of the GBR (Lewis et al.,
2012). Concern about the risk pesticides pose to GBR organisms
and ecosystems also made it imperative that a set of specic water
quality guidelines for the GBR be developed (Moss et al., 2005).
Using the best available information and standard guideline setting procedures regionally relevant water quality guidelines were
developed for the GBR (GBRMPA, 2009b). These guidelines provide
a benchmark for assessing risk to the GBR from a range of pollutants
including pesticides. Work is continuing to update and improve
the guidelines (Lewis et al., 2012). The pesticides most commonly
cited as being of concern are the group of PS-II herbicides including atrazine, diuron, tebuthiuron, hexazinone, ametryn, simazine.
Other pesticides in wide use in the GBR catchment area include
chlorpyrifos, imidacloprid, metolachlor, paraquat and gyphosate,
as well as 2,4-D, a non-PSII herbicide that interferes with plant
growth, which is also of concern as it is widely detected in runoff
from cropping. The risk to the freshwater and estuarine wetlands
vitally connected to the GBR may involve a somewhat different
priority set of pesticides (Davis et al., 2008, 2012).
Pesticides are also recognised as an issue for reefs globally. Studies in Central America (Castillo et al., 1997), the Ryuku Islands,
Japan (Kitada et al., 2008; Sheikh et al., 2009), French Polynesia

(Roche et al., 2011) and Martinique (Bocquen and Franco, 2005),

for example, have all detected pesticide residues in coral reef
systems. However interpretation of the risks to reefs from these
residues is difcult given the lack of research globally on the effects
of pesticides on coral reef organisms. There have been few attempts
to address pesticide pollution of coral reef systems, particularly
as this issue is more common in developing states with limited
scientic expertise and regulatory sophistication. One example of
an apparently successful management response is in Honduras,
Guatemala and Belize where pesticides (and sediment and fertilizers) were washing off large-scale banana, pineapple, oil palm,
citrus and sugarcane plantations onto the Mesoamerican Reef.
WWF (World Wildlife Fund) worked with the major agricultural
producers and chemical companies to introduce Best Management
Practices which under eld test conditions showed reduced loss of
pesticides (McLaughlin, 2011).
This paper reviews Australias pesticide regulatory system, as it
relates to Queensland and the GBR. The regulatory system does not
appear to working adequately to protect the GBR given the high
frequency of pesticides found at above trigger values in many GBR
waterways over several years of monitoring and the lack of effective action to reduce these exceedances by the national regulator,
the APVMA. The paper examines the regulatory response to pesticide pollution of the GBR both within and outside of Australias
dedicated regime for managing pesticide risks to the environment.
Pesticide pollution of the GBR provides a good case study because
of the relatively advanced state of knowledge about the problem
and because of the specic management attention it has received
(Brodie et al., 2008a) due to the GBRs status as a marine park
and World Heritage Area and the recognition that pollutant runoff
from agriculture is one of the main factors in the severe decline in
condition (as measured by coral cover) of the GBR.
We compare the Australian regulatory regime, including the
special arrangements available for management of the GBR, with
other economically advanced states, in particular the European
Union (EU), which we consider to have as good a system as currently exists for environmental protection from pesticide impacts.
We assess whether the adoption of such an advanced regulatory
regime, which places as much emphasis on environmental protection as agronomic productivity (in contrast to our assessment of
the Australian system) would be sufcient to adequately protect
the GBR from the adverse effects of pesticide pollution.
2. The regulatory framework for pesticides in Australia
2.1. The general framework
In Australia, agricultural and veterinary (agvet) chemicals
including pesticides are regulated under the National Registration
Scheme (NRS), a partnership between the Australian and state and
territory governments. Since 1991 the Commonwealth has regulated agvet chemicals up to and including the point of retail sale,
while states and territories are responsible for controlling the use of
agvet chemicals after retail sale. This shared structure has been the
subject of a number of reviews, including one by the Productivity
Commission (2008) that made recommendations to replace it with
a single national framework for agvet chemicals incorporating both
pre- and post-registration activities. Different regulatory models
for implementing those recommendations are currently being considered by the Council of Australian Governments (COAG) (COAG,
2010; PSIC, 2011).
2.2. Assessment and registration
The Commonwealths assessment and registration responsibilities in relation to agvet chemicals are administered by the

J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Australian Pesticides and Veterinary Medicines Authority (APVMA)

(previously the National Registration Authority (NRA)), an independent statutory authority within the portfolio of the Commonwealth
Agriculture Minister. The APVMA was established under the Agricultural and Veterinary Chemicals (Administration) Act 1992 (Cth). In
accordance with the Agvet Code contained in the Agricultural and
Veterinary Chemicals Code Act 1994 (Cth), the APVMA assesses the
suitability of new agvet chemicals and products and the conditions
of use for product labels. The criteria for registration contained in
section 14(3)(e) of the Agvet Code are that chemicals and products would not be an undue hazard to the safety of people exposed
during handling or to their residues; would not be likely to have
an effect harmful to human beings; would not be likely to have an
unintended effect harmful to animals, plants or the environment;
and would not unduly prejudice Australias international trade or
commerce. There are presently more than 800 agvet chemicals and
8000 agvet chemical products registered for use in Australia.
In addition to assessing new chemicals, the APVMA may reconsider the registration or approval of an existing chemical or product
at any time under section 31 of the Agvet Code. These powers
are generally administered through the APVMAs Chemical Review
Program when new research or evidence raises safety concerns.
In conducting reviews, the APVMA relies on specialist advice from
government agencies including SEWPaC and the Ofce of Chemical
Safety. Once a review has been initiated, a chemical may only be
deregistered if an unacceptable risk cannot be adequately managed,
such as by changing its label conditions. For example in relation
to environmental concerns, if the APVMA is satised following
reconsideration that continued use of the chemical or product in
accordance with the instructions for its use would not be likely to
have an unintended effect that is harmful to animals, plants or the
environment, the APVMA must afrm the registration under section 35 of the Agvet Code. Under section 40, the APVMA may only
suspend or cancel a registration if the conditions of use could not
be varied to ensure compliance with the requirements for registration. In other words, deregistration is the last option of the APVMA
during a chemical review.

2.3. Control of use

Responsibilities for controlling the use of pesticides (i.e. after the
point of retail sale) are currently administered under various pieces
of state and territory legislation, generally by primary industries
departments. In Queensland, the relevant legislation is the Chemical Usage (Agricultural and Veterinary) Control Act 1988 (Qld) and
the Chemical Usage (Agricultural and Veterinary) Control Regulation
1999 (Qld). The Act regulates the use of registered agvet chemicals
and section 13A prohibits the use of unregistered chemicals. Under
sections 13 and 13B of the Act it is an offence to use a registered
agvet chemical other than in accordance with its label conditions
but there are broad exceptions, for example if using a lower concentration, rate or frequency, mixing a chemical with another chemical
or fertilizer, and applying the chemical to a different pest than
specied, provided the label does not explicitly prohibit it. These
exceptions are allowed in most other Australian states and territories (Productivity Commission, 2008, p. 220). Victoria allows the
broadest diversion from product label conditions, even permitting
use on different crop and use situations than those specied on the
The Agricultural Chemical Distribution Control Act 1966 (Qld) regulates the application of agricultural chemicals from aircraft and
on-ground equipment in Queensland. Section 39 generally requires
a person applying agricultural chemicals to hold a licence to do so,
except when using on-ground equipment on land owned or occupied by himself or herself, or a relative or employer. This exemption


would apply in most farming situations other than where spraying

is conducted by contractors.
2.4. Other legislation relevant to the pollution of the Great Barrier
The above legislation specic to pesticides is part of a much
broader framework of international, national and state laws relevant to the GBR and the activities that may pollute it (Baxter, 2006).
For example, there is Commonwealth legislation regulating the
discharge of oil and other harmful substances from ships, the Protection of the Sea (Prevention of Pollution from Ships) Act 1983 (Cth).
The Great Barrier Reef Marine Park Act 1975 (Cth) creates an offence
for the unauthorised discharge of waste in the marine park, but
it also allows for management action outside its boundary where
activities occurring there, for example on the GBRCA (Fig. 1), will
impact on the GBRMP. Section 66(2)(e) enables the Commonwealth
Environment Minister to develop regulations pertaining to activities (whether in the marine park or elsewhere) that may pollute
water in a manner harmful to animals and plants in the GBRMP.
In reality however that Act has not been an effective way to control external activities impacting the GBR. The provision in section
66(2)(e) has only been used once, to introduce the Great Barrier Reef
Marine Park (Aquaculture) Regulations 2000 (Cth) for aquaculture
discharges in waters contingent to the GBRMP.
At the state level, there are offences under the Environmental
Protection Act 1994 (Qld) for causing serious or material environmental harm and environmental nuisance but historically they
have not been used in relation to non-point sources of pollution such as pesticide runoff. Likewise both Queenslands and
the Commonwealths development impact assessment legislation,
the Sustainable Planning Act 2009 (Qld) and the Environment Protection and Biodiversity Conservation Act 1999 (Cth), respectively,
cannot adequately regulate non-point source pollution from agriculture because of the indemnity provided to existing lawful uses
(McGrath, 2007). For example, the Environment Protection and Biodiversity Conservation Act regulates the assessment and approval of
actions that may have a signicant impact on the values of a World
Heritage Area and other matters of national environmental significance but sections 43A and 43B protect existing lawful uses and
activities that were fully approved at its commencement on 16 July
3. The regulatory response to pesticide pollution of the
Great Barrier Reef
3.1. Response of the Australian Pesticides and Veterinary
Medicines Authority
All of the contemporary pesticides of concern detected in the
GBR are authorised for use in Australia, although most were initially registered under the previous state-based arrangements and
grandfathered into the NRS when it was established in the mid1990s. For example, atrazine was rst registered in Australia in
19601961 (NRA, 1997), diuron in the 1960s (NRA, 2002). The rst
products containing hexazinone and tebuthiuron were registered
in Queensland in the late 1970s and 1980s, respectively.
The APVMAs Chemical Review Program is the principal mechanism for reviewing the safety of existing chemicals and their
potential adverse effects on the environment. A review of atrazine
was nalised in March 2008 following a 13-year review period, but
despite a large body of scientic studies showing the presence of
atrazine in the GBR and its catchments, both in surface waters and
in groundwater, by the early 2000s (Haynes et al., 2000a,b Mller
et al., 2000; McMahon et al., 2005; Mitchell et al., 2005; Shaw and


J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Mller, 2005), the review did not specically consider risks to the
GBR. The GBR is not mentioned in any of the APVMAs atrazine
review reports. Two years into the review the APVMA introduced a
number of new conditions for atrazine products designed to reduce
chemical handling by workers and as well as drift and runoff into
water bodies. They included reduced application rates, a ban on
use in channels and drains and on waterlogged soil and if heavy
rains or storms likely to cause surface runoff are forecast within
two days of application (NRA, 1997). Two further amendments
were introduced in 2008 including a ban on its use in drainage
lines and in areas susceptible to run-off where drainage results in
rapid entry into waterways (APVMA, 2008, p. 20). These additional
conditions were designed to reduce the risk of atrazine contamination of waterways (APVMA, 2008), although were not intended to
address risks to the GBR specically.
A review of diuron was initiated by the APVMA in 2002 and
is ongoing, partly in response to concerns raised that its use in
agriculture, particularly sugarcane, could cause damage to marine
environments such as the GBR (NRA, 2002). In conducting that
review, the APVMA has considered impacts on GBR marine species
including corals and seagrass. In July 2005, the APVMA made preliminary review ndings that the risk posed by diuron to the GBR
was unacceptable because of likely impacts on juvenile marine
organisms, seagrasses and therefore also, dugongs (APVMA, 2005).
The preliminary report stated that diuron adsorbed to the suspended sediments and carried by rivers to the inshore reefs was
considered to impact on the inshore reefs and that due to the
high conservation values within the [GBRMP], the level of diuron
in inshore regions is unacceptable (APVMA, 2005, p. 25). It concluded that a 75% reduction in the maximum annual application
of diuron in sugarcane crops is needed to reduce the environmental load to an acceptable level (APVMA, 2005, p. 36). Incidentally,
the APVMA found that there are unacceptable risks to the environment associated with 12 of diurons 22 other registered uses,
including on cotton, apples and pears, bananas, citrus, coffee, pawpaws, pineapples, bore drains, irrigation channels and commercial
and industrial areas (APVMA, 2005). As this paper was in the nal
stages of preparation the APVMA announced, on 15 July 2011, a proposed suspension of all uses of diuron (except for antifouling paints
and algal control products) pending the completion of its review.
The proposal followed release of its environmental risk assessment
report (APVMA, 2011a,b) which concluded that diurons current
uses pose some unacceptable risks to the environment including
acute risks to birds and to algae and aquatic plants in primary
streams, but not to the GBR. In contrast to the APVMAs 2005 preliminary ndings, its 2011 report states that the presence of diuron
in coastal waters is considered undesirable because of its persistence and very high toxicity, but is acceptable due to dilution
of diuron in the ocean (APVMA, 2011a,b, p. 75). It appears no
account was taken in the report (APVMA, 2011a,b) of the extensive research on diuron carried out and published (or known to
be in pre-publication stage) over the last three years (20092011)
(e.g. Packett et al., 2009; Davis et al., 2012, 2013; Shaw et al., 2010;
Lewis et al., 2009, 2012; Kennedy et al., 2012a; Magnusson et al.,
2010, 2012; Negri et al., 2011) or the existence of the GBRMPA
2009 guidelines. The APVMA allowed a 30-day period for the registrants and users of diuron to show cause as to why the APVMA
should not suspend the registration of diuron products on the basis
of the environmental concerns but since extended that period to
30 September 2011. A nal decision was still pending as this paper
was being nalised in November 2011.
A review of 2,4-D has been ongoing since 1995, again in part
because of concerns over its potential risk to the environment,
including its potential to contaminate waterways and pose a hazard to non-target animals and plants (APVMA, 2003). The APVMA
has not specically considered risks to the GBRMP as part of its

review but did introduce a ban on applying products containing

2,4-D ethyl, butyl or isobutyl ester (high volatile, short chain esters)
to sugarcane in October 2006. The chemical exists in a number of
forms, including these esters, but these forms transform in the environment to the acid which causes the impact. The different forms
now have different regulatory requirements in Australia. It has been
detected in a number of studies in GBR waterways (Davis et al.,
2008; Hunter et al., 2001; Lewis et al., 2009; Mitchell et al., 2005)
but due to cost constraints on the analysis of this herbicide it is often
not included in monitoring programs. When it is monitored, current
analytical techniques generally only detect total 2,4-D. This may be
satisfactory from an environmental risk perspective but makes it
difcult to assess the actual use of the different forms of 2,4-D.
Two other chemicals relevant to the GBR hexazinone and
simazine have been nominated for review by the APVMA because
of environmental concerns, although it is unknown whether their
detection in the GBR contributed to those nominations. It is also
unknown when hexazinone and simazine were rst nominated but
their reviews had not commenced at the time of completing this

3.2. Response of the Queensland Government

In September 2009 the Queensland Government introduced a
Reef Protection Package of legislative reforms in the Great Barrier Reef Protection Amendment Act 2009 (Qld), with the object of
reducing the impact of agricultural activities on the quality of water
entering the GBR. The amendments inserted a new Chapter 4A in
the Environmental Protection Act 1994 (Qld) and created a new class
of environmentally relevant activity for sugarcane growing and
beef cattle grazing in the Wet Tropics, the Burdekin Dry Tropics
and Mackay-Whitsundays catchments. Several strict requirements
were introduced for affected operators including a requirement to
keep records in relation to the application of agricultural chemicals and fertilizers. Certain high-risk operators are now required
under Part 3 of Chapter 4A to have an accredited environmental
risk management plan (ERMP) to reduce risks to GBR water quality
by sediment, herbicide and nutrient runoff.
The reforms also included amendments to the Chemical Usage
(Agricultural and Veterinary) Control Act and Chemical Usage (Agricultural and Veterinary) Control Regulation to amend the conditions
of use for prescribed agricultural chemical products in sugarcane
growing and beef cattle grazing in the relevant catchment areas.
For diuron, ametryn and hexazinone in sugarcane growing, the new
label conditions were modelled on the APVMAs existing label conditions for atrazine products, for which the APVMA had completed
its review in 2008. They included reduced application rates and
a ban on application if heavy rains are forecast and in areas susceptible to runoff. Unlike the APVMAs existing ban on spraying
atrazine within 20 m of a watercourse, for diuron, ametryn and hexazinone the Queensland Government requires either a minimum
20 m no-spray area from the edge of a water body or a minimum 5 m
effective vegetated treatment area (EVTA) adjacent to the crop at
the points where surface run-off would exit the crop area to a downslope water body. As a further alternative, sugarcane growers may
opt to develop a chemical ERMP to minimise the risk of herbicide runoff entering the GBR. For products containing tebuthiuron
used in tree regrowth suppression in the cattle grazing industry,
the new conditions included reduced application rates, a prohibition on use between 1 November to 31 March and a requirement
for operators to produce, prior to application, a map of the application area indicating drainage lines. Training qualications now
apply under the Chemical Usage (Agricultural and Veterinary) Control Regulation for persons who may prepare or use the prescribed

J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

4. Effectiveness of the regulatory response

4.1. Efcacy of management actions implemented
It is still unclear whether the Queensland Governments
amended label conditions for diuron, ametryn and hexazinone in
sugarcane growing will reduce pesticide runoff to the GBR. Monitoring data will conrm this in future years. A concern is that
they have been modelled on the APVMAs 1997 conditions for
atrazine that have not prevented atrazine runoff to the GBR since
that time, although that failure may be partly attributed to the historical lack of enforcement of agvet chemical label conditions in
Queensland. The Queensland Governments EVTA provisions for
diuron, ametryn and hexazinone in sugarcane growing circumvented strict 20 m no spray areas, even though such set-backs
had been required for atrazine since 1997. The effectiveness of
those 5 m EVTAs for trapping signicant amounts of herbicides
like atrazine and hexazinone has been questioned, particularly in
the extreme tropical rainfall regimes of the Wet Tropics (Brodie
et al., 2011b).The APVMAs 2008 label condition prohibiting the
application of atrazine to areas susceptible to run-off also has
questionable efcacy in the case of sugarcane growing in the GBRCA
given that industrys predominance on lower oodplain lands that
are naturally subject to rapid runoff in the intense tropical rainfall
regimes common in sugarcane growing regions. If actually enforced
these controls would have likely prevented the use of atrazine
in many sugarcane growing regions of Queensland. Similarly, the
1997 prohibition on applying atrazine if heavy rains..likely to cause
surface runoff are forecast within two days of application should
have theoretically prevented use for much of the year in areas such
as the Wet Tropics where these weather conditions occur very frequently. These remarkable label conditions may be explained by the
APVMAs obligation under section 40 of the Agvet Code to rst try
to nd a risk mitigation solution before deregistering or suspending
a chemical or product.
The APVMAs ban on applying products containing 2,4-D ethyl,
butyl or isobutyl ester (high volatile, short chain esters) to sugarcane since 2006 means that the continued detection of 2,4-D in the
GBRCA (e.g. Davis et al., 2008) should be from the remaining permitted uses in sugarcane and from other crops allowed to use 2,4-D.
But current analytical techniques utilised in existing GBR monitoring programs cannot distinguish between the different chemical
forms of 2,4-D, making it difcult to assess whether the actual use
of 2,4-D is in compliance with the restrictions.
The Queensland Governments new label conditions applying in
the GBRCA are likely to be better enforced than conditions applying in the rest of Queensland, and arguably Australia, because
of specialist ofcers employed as part of the Reef Protection
Package, but nonetheless a new culture of compliance with
chemical label conditions will be required. The requirements to
undergo training, to keep records in relation to the application
of certain products and for some operators to develop ERMPs
should also contribute to improved chemical management practices.
4.2. Responsiveness of the system
Even prior to considering the efcacy of the actual conditions
imposed on pesticide use and their enforcement, an important
measure of the effectiveness of a pesticide regulatory system, if
it is to manage risks to the environment, should be its responsiveness, that is, how quickly potential risks are identied and
assessed and then measures implemented to address those risks
deemed to be unacceptable. Yet within the dedicated program for
identifying, assessing and addressing pesticide risks to the environment, the APVMA has so far completed a review of only one


of the chemicals of concern for the GBRatrazineand even with

knowledge of the presence of atrazine in the GBR and its catchments in the early 2000s, that 13-year review did not consider
risks to the GBR. The APVMAs only action specically directed to
managing pesticide risks to the GBR has been its ongoing review
of diuron. Unacceptable risks to the GBR were identied in 2005
but in 2011 the APVMA downgraded its concerns about the presence of diuron in coastal waters to being merely undesirable. It
is unclear whether the APVMA will proceed with its recent proposal to suspend the registration of diuron products (as a result
of other environmental concerns) but the additional time given to
industry to show cause why they should not be suspended suggests that implications for industry will be an important factor in
its decision. It is also uncertain when the APVMA will nalise its
review of diuron and whether that will result in permanent use
restrictions or deregistration of the chemical. Risks to the GBR may
have contributed to the nomination of hexazinone and simazine
for review but it is likely to be several years before those reviews
are even commenced. Indeed the Queensland Governments chemical reforms for diuron, ametryn, hexazinone and tebuthiruon can
be seen as an example of where, because of unresponsiveness
of the APVMAs chemical review program and the importance of
protecting the GBR as World Heritage Area, intervention was necessary to impose better pesticide management practices in the
The APVMAs Chemical Review Program has been criticised by
a number of NGOs such as CHOICE (
reviews-and-tests/food-and-health/general-health/safety/apvmawwf.aspx) for the exceptional length of chemical reviews,
which are at least partly attributable to the lack of statutory
timeframes within which reviews must be completed and the
absence of cut-off dates for data provision by registrants. At
least 10 of the chemicals currently under review by the APVMA
have been under review since 1996 or earlier (Table 1) and the
average period of review for those pesticides is greater than
11 years (Table 1). In 2010 the Federal Agriculture Minister
notably criticised the lengthy period for the review of atrazine
( and ordered
APVMA to immediately act on the label changes for the controversial herbicide that were recommended four years ago. At
the time of writing there were over 40 chemicals nominated
for review because of concerns about their safety but there are
no statutory timeframes within which those reviews must be
commenced or completed. The APVMA has powers under section
41 of the Agvet Code to suspend or cancel the approval of a
chemical or product at any time directly, i.e. outside of its review
process, but they are rarely utilised in practice for pesticides.
The decisions to suspend the registration of quintozene in April
2010 and to deregister endosulfan in September 2010 are two
recent exceptions, the latter of which followed endosulfans nomination under the Stockholm Convention on Persistent Organic
Pollutants and its deregistration in the USA (Cone, 2010; USEPA,
Another consequence of extended chemical reviews is of course
uncertainty for manufacturers and users. There is some evidence
of the growing use of alternative herbicides in sugarcane cultivation such as Soccer (metribuzin), Flame (imazapic), Balance
(isoxautole), STOMP (pendimethalin) and Krismat (ametryn and
trioxysulfuran sodium) instead of diuron and atrazine (Rob Milla
pers. com.). These herbicides are registered for use in sugarcane cultivation but due to the incomplete nature of the registration process
in Australia we have very little data on their likely effectiveness at
controlling the relevant weeds in sugarcane and almost no data at
all as to their likely ecological effects in tropical coastal Australian


J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Table 1
Length of chemical reviews in Australia.

Reason for review a

Review commenced

Preliminary review ndings

Interim regulatory action


H; OH&S; E


2006 (for high volatile esters only)

Label warnings strengthened to

minimise spray drift in 2004
Registrations and label approvals
for high volatile ester forms of
2,4-D suspended in 2006 with new
instructions for use


Tox; H; OH&S; E; R; T
H; R

Unknown (nominated 1994)


2004 (for home uses); 2006 (for
agricultural uses)


H; OH&S; R





1999; 2000


Tox; OH&S; H; E


2000; 2009


H; OH&S; E; T


2000; 2002; 2003; 2006


H; OH&S; E; R; T
Tox; OH&S; R; T
H; OH&S; E; R
Tox; E
H; OH&S; E; R

2004 (nominated 1995)
2003 (nominated 1994)

2000; 2008


H; OH&S; E; R


2005 (non-food producing uses


Macrolide antibiotics
Maldison (malathion)

Tox; OH&S
Efcacy; H
Tox; H
Tox; H
Tox; H; OH&S; R
H; OH&S; E; R
Tox; OH&S; E
R; T
Tox; OH&S; R; T
Tox; OH&S; E; R

2003 (nominated 1995)
2002 (nominated 1995)
2002 (nominated 1995)
2007 (nominated 2002)
2004 (nominated 1995)




Sheep ectoparasiticides

OH&S; E; T


Review of home garden, home

veterinary, poultry and domestic
uses completed in 2007, some uses
cancelled and concentrations
restricted and label warnings
strengthened for home garden
Label approvals suspended in 2007
with new instructions for use
issued and birth defect warning on
product label;
New suspension in 2010 extending
product warnings and amending
instructions for use and label
Interim use regime implemented
in 2000
Home and garden uses restricted
and label warning strengthened in
Water-based formulations and
companion animal products
cancelled in 2003;
Sheep dipping and jetting uses
suspended in 2007

1999; 2004

Variations to existing use patterns

and product labels in 1999 to
minimise chemical handling and
worker exposure and reduce the
potential for contamination of
water bodies



Interim-use regime implemented

in 1999 to address potential risks
to workers and the environment
Product recall and amended
conditions of use issued in 2004


Tox = toxicity; H = public health; OH&S = occupational health and safety; E = environment; R = residues; T = trade.

5. Opportunities to improve the regulatory system

5.1. The case for a pesticide re-registration program
We could not nd any cases of comparisons of the effectiveness of pesticide regulatory regimes across jurisdictions in the peer
reviewed literature and our comparison of the Australian regime
internationally was also difcult due to inherent differences in
governmental systems. However we attempt below to make some

comparisons between the regime in Australia and those in the EU,

USA and Canada.
Both Europe and the USA now have systematic chemical review
systems mandated by re-registration requirements for new and old
chemicals. In 1993, the European Union commenced a Communitywide programme to evaluate the safety of all chemicals used in
plant protection products (about 1000 in total) (European
Commission, 2009) as required by European Commission Directive
91/414/EEC. Each active substance had to be proven safe in terms of

J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

human health (including consumers, farmers, local residents and

passers-by) and the environment (including to groundwater and
non-target organisms) in order to obtain European authorisation
under the new system. Now only chemicals authorised at the
European Commission level may be used in plant protection products (which are in turn regulated at the member country level),
with certain exceptions to allow for the phase out of unauthorised
chemicals. The programme was completed in 2009 and led to the
removal of hundreds of substances from the European market,
most because of incomplete data sets or because their applications
were actively or passively withdrawn by the manufacturers. A key
part of the system is re-registration (also referred to as sunset
registration). All of the new European pesticide authorisations
have an expiry date, after which the chemicals safety must be
reevaluated. In the United States, a similar one-time safety review
of older pesticides (those originally registered before November
1984) was recently completed by the Environmental Protection
Agency (
and there is now a requirement for each pesticide active
ingredient to be reviewed every 15 years. The same type of
system exists in Canada, where pesticides must be reviewed
every ve years and Canada is currently re-evaluating about
400 active ingredients that were registered prior to 1995
( corp-plan/naftaalena-2003-2008/index-eng.php#reass). Of note is that an even
stricter hazard-based system is now being implemented in
Europe, as provided for in Regulation EC No 1107/2009, which
seeks to eliminate exposure to pesticides with certain hazard
characteristics (such as mutagens, carcinogens, reproductive
toxicants, and endocrine disruptors). This may signal the future
direction of pesticide regulation in Northern America.
Australia in contrast does not yet require any form of reregistration for pesticides. Agvet chemicals and products are
registered in perpetuity unless de-registered as a result of chemical
review or by some extraordinary decision-making process. About
75% of the pesticides approved for use in Australia were grandfathered into the NRS in the mid-1990s, having been registered under
the previous state-based arrangements (Productivity Commission,
2008). Many of those chemicals were subject to less rigorous risk
assessments than are required today, some even dating back to the
1950s (Productivity Commission, 2008). Whilst it is reasonable to
expect that Australias pesticide registration system would deliver
a somewhat unique suite of chemicals suited to our climatic conditions and agricultural industries, we have identied almost 100
chemicals remaining in Australia that were previously, but are no
longer, registered in Europe, indicating some proactive decision to
end their use there (Table 2). In Australia, some of them are under
review or have been nominated for review by the APVMA, so while
their potential risks have been acknowledged, Australian management action has not yet been taken or completed (see for example
azinphos-methyl, carbaryl, chlorfenvinphos, diazinon, dichlorvos,
fenitrothion, fenthion, methidathion, omethoate and paraquat in
Tables 1 and 2).
In August 2010 the Australian Government committed to
reforms to better protect human health and the environment and
to bring Australia into line with most regulators in the United
States and Europe, recognising that our pesticide regulatory system is not working as effectively as it should (Anon., 2010). The
proposed package of reforms to implement this commitment was
released by the Australian Government in November 2010 and
included a re-registration system for all agvet chemicals and legislated timeframes for the completion of assessments and reviews.
New legislation is expected to be introduced into Parliament in
2012. Some of the factors affecting the regulatory response to
pesticide pollution of the Great Barrier Reef are expected to be
addressed by the proposed Australian re-registration system. Most


importantly, re-registration requirements should ensure regular

safety reviews are conducted and in effect, place on pesticide
registrants the burden of proving safety in accordance with contemporary standards. A comparison of the data requirements and
methods used for the assessment of pesticide safety in Europe and
the United States with those used in Australia is beyond the scope
of this paper, but even if they were found to be very similar, or
indeed if Australia applied the most rigorous procedures for the
assessment of pesticide risks to the environment, we still lack the
legal mechanism to bring about those assessments systematically.
5.2. Other gaps in the current Australian system
We argue that some failures of the current system will not simply be addressed by a re-registration program however. One is the
existing obligation on the APVMA to nd a risk mitigation solution
before deregistering or suspending a chemical. Another key problem is that neither the current system nor the proposed one allow
for the assessment of additive, cumulative and synergistic environmental effects of multiple chemical exposures, which are relevant
in the context of the GBR. Studies in the GBR show that in most
cases where pesticides are detected, more than one chemical is
present. In the case of the PS-II herbicides it is well known that the
effects of these compounds which act via the same mechanism
are additive (Bengston Nash et al., 2005; Chvre et al., 2006; Lewis
et al., 2009; Magnusson et al., 2008; Shaw et al., 2009, 2012). Risk
assessment of such chemicals requires consideration of the additive
effects (Lewis et al., 2012). Continuing inputs of the same pesticides, as occurs in the GBR situation where cropping systems and
pesticide types are relatively constant, suggests cumulative effects
are also possible (Davis et al., 2008, 2013). Additive and possibly
synergistic effects have also been shown in GBR studies to occur
between pesticides as stressors and other stressors such as sediment for coralline algae (Harrington et al., 2005) and temperature
for corals (Negri et al., 2011).
There is also no comprehensive pesticide usage reporting system in Australia. The National Pollutant Inventory, Australias
national database of pollutant emissions, does not include agvet
chemicals. Pesticide sales data collected by the APVMA is not made
publically available. A review of pesticide use in Australia was carried in 2002 (Radcliffe, 2002), estimating total use amounts of
different chemical types, but has not been repeated. This means
our ability to predict pesticide residue concentrations and loads in
water bodies using models is very limited, as is the scope for verifying the efcacy of label conditions for reducing contamination
of the environment. Usage reporting systems have been recommended generally (Radcliffe, 2002) and for the Great Barrier Reef
catchment particularly (Fuller et al., 2008) but have not yet been
implemented. However, a national system of record keeping controls is being considered by COAG for inclusion in the national
scheme for the registration, assessment and control of use of agvet
chemicals (COAG, 2010).
With the exception of the considerable research undertaken
for GBR marine species, there are limited independent ecotoxicology studies demonstrating pesticide effects on Australian plants
and animals in typical Australian climatic and hydrological conditions. Notable exceptions include the extensive work examining the
toxicity of endosulfan to cladocerans, macroinvertebrates and sh
and the exposure regime of endosulfan in irrigated cotton growing
regions of NSW over the last two decades (Sunderam et al., 1994;
Leonard et al., 1999, 2000, 2001; Kennedy et al., 2001; Hose et al.,
2002, 2003a,b; Napier et al., 1998; Pablo and Hyne, 2009; Raupach
et al., 2001). This work contributed to the discontinuation of use of
endosulfan in Australia in 2010. Risk assessment for aquatic organisms in these irrigated areas (where 14 pesticides were detected
during monitoring) has also been carried out (Muschal and Warne,


J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Table 2
Some of the chemicals registered for use in Australia that are no longer authorised by the European Union.

Status under EU Regulation 1107/2009

Relevant EU legislation

Cadusafos (aka ebufos)
Ethion (aka diethion)
Methyl bromide

Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved

Regulation 1335/2005
2008/934, Regulation 943/2011

J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467


Table 2 (Continued)

Status under EU Regulation 1107/2009

Relevant EU legislation


Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approveda
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved
Not Approved


Essential use allowed.

2003). Some work has also been carried out on the effects of atrazine
in Australian conditions but principally its toxicity to animals (e.g.
Davies et al., 1994), with little attention to herbicidal effects on
aquatic plants, and some consideration also on its possible role as
an endocrine disrupting substance (Hyne et al., 2009). Experimental
studies to assess toxicity and likely effects are generally still sourced
from overseas and thus may not be entirely relevant for Australias
unique environmental conditions, for example tropical rather than
temperate climates (Kookana and Simpson, 2000; Damm and Van
den Brink, 2010); temperate marine ecosystems versus coral reefs;
highly variable hydrological regimes and intermittently wet/dry
wetlands; very high rainfall regimes in, for example, the Wet Tropics and western Tasmania; and unique species assemblages and
species life cycle styles. Another consequence of the lack of monitoring and publically funded ecotoxicology studies is that most of
the data relied on by the APVMA are provided by pesticide registrants and regarded as condential. This lack of transparency and
the reliance on industry data also contribute to effectiveness of
Australias regulatory system for protecting the environment.
6. Implications for other Australian water bodies
Australias pesticide regulatory system has failed to adequately
respond to pesticide pollution of the GBR despite the very large
body of published and mostly peer-reviewed research undertaken
to understand the problem. But the GBR arguably presents the best
case scenario for the Australian systems ability to respond to pesticide risks to the environment. Other Australian ecosystems which
are lower prole and less studied (or unstudied) are likely to be even
less protected because they will not attract the special management
attention that the GBR has. Even in the Moreton Bay Marine Park
(an important large marine embayment and ecosystem adjacent to
the city of Brisbane and immediately to the south of the GBR), for
example, pesticides are not currently included in the monitoring
program for that area (Healthy Waterways, 2009). In the Ramsarlisted Bowling Green Bay site south of Townsville evidence showing
extensive pesticide contamination is available (Davis et al., 2008,
2012, 2013; Smith et al., 2012; Davis unpublished data) however
although some of this data has been available to the Australian
Government (responsible for the management of Ramsar sites) for
several years no action or further ofcial risk assessments have
been undertaken.

There is considerable evidence that Australian rivers, streams,

groundwater, marine waters and drinking water (both raw
and treated) are regularly contaminated with pesticide residues
although much of the data and analysis to support this contention
have not been published in peer reviewed literature, not properly analysed or interpreted with any level of statistical rigour
and often not in the public domain available for assessment by
scientists independent of government. Results from state and territory government agencies monitoring programs, often ad hoc and
reactive, may not to be written up in publicly available technical
reports and the raw data is often only released through right to
information processes rather than proper public reporting. In many
of the released reports pesticide concentrations are not assessed
against the appropriate guidelines, for example pesticide concentrations in rural streams assessed against drinking water guidelines
rather than ecological guidelines (e.g. Beattie et al., 2004). Partial exceptions to this pattern are seen in: (1) Tasmania, with
data recently published by the Tasmanian Government on its ve
year stream monitoring program (Tasmanian Government, 2011)
(although with almost no interpretation of what the results mean
for the aquatic health of streams); and (2) Victoria, with a number
of regional technical reports in the grey literature summarised
by Wightwick and Allinson (2007, 2009). Victoria has a more comprehensive monitoring program but results have so far only been
reported in the scientic literature for selected study areas (Schafer
et al., 2010).
Whilst studies relating to concentrations of pesticide residues in
rivers, streams, oodplains and wetlands by academic and research
institutions (e.g. CSIRO) have appeared in the peer reviewed literature, these form only a small sample of the complete picture with
respect to pesticides in Australian waters. Kookana et al. (1998)
describes the information available on surface waters in Australia
as far from comprehensive. Nonetheless, properly designed and
implemented pesticide studies, generally run by organisations such
as CSIRO and universities, nd pesticide residues are ubiquitous
in Australian water bodies in areas where pesticides are used (e.g.
Thoma and Nicolson, 1989; Davies et al., 1994; Muschal and Warne,
2000; Haynes et al., 2000a; Rose and Kibria, 2007; Wightwick and
Allinson, 2007). Recent examples include a study of sites around
Melbourne, Victoria (Schfer et al., 2011a,b) as well as those previously described from the GBR (e.g. Lewis et al., 2009; Shaw et al.,
2010; Smith et al., 2012; Kennedy et al., 2012a,b).


J. King et al. / Agriculture, Ecosystems and Environment 180 (2013) 5467

Partly as a result of this lack of ofcial government monitoring

and the infrequent publication of data from existing government
programs (and despite the peer reviewed information available
from research organisationssee above), there are no overall
recently published assessments of pesticide residues in Australian
waters. This is in contrast to the situation in the United States
where such assessments have recently been published in the peer
reviewed literature for groundwaters and drinking water sources
(Barnes et al., 2008; Focazio et al., 2008), in public reports and book
chapters for both surface and groundwaters (Gilliom et al., 2007;
Nowell et al., 1999) and similarly in the European Union for groundwaters and river waters (Loos et al., 2009, 2010) and in New Zealand
for groundwater (Close and Flintoft, 2002; Gaw et al., 2008). The
most comprehensive reviews in Australia are those composed for
the Australian State of the Environment reporting. The 2001 report
(Australian State of the Environment Committee, 2001) noted that
the monitoring of pesticides in inland waters is not undertaken
routinely in Australia and apart from the irrigation districts of New
South Wales, there was little recent information.

7. General discussion
The Great Barrier Reef is Australias best documented case
of contamination of an ecosystem by pesticides. The relatively
advanced state of knowledge about the problem, as well as the
GBRs ecological and economic importance and iconic status mean
that it arguably presents the best case scenario for Australias ability to respond to pesticide risks to the environment. Yet the only
regulatory action taken to date in the form of the Queensland
Governments Reef Protection Package has occurred independently of the formal APVMA processes designed to manage risks
posed by existing chemicals and can arguably be seen as a necessary intervention in those processes. The ad hoc, case-by-case and
very slow Chemical Review Program administered by the APVMA
has not effectively assessed or addressed chemical risks to the GBR.
The APVMA has considered the risks to the GBR posed by only one
chemicaldiuron. Despite making strong statements in its preliminary review ndings (APVMA, 2005) regarding hazard to the GBR
after four years of review, no immediate action was taken and it
took a further six years for the APVMA to propose suspension of
the chemical (APVMA, 2011a). But reference to the GBR concerns
was omitted its latest report and the assessment on which the suspension proposal was made (APVMA, 2011b) while dated July 2011
appears to only be current to about 2009 (based on the literature
cited), thus disregarding the large body of work specically relevant
to the GBR published (or available in pre-publication forms) in the
period between 2009 and 2011 (Bainbridge et al., 2009; Davis et al.,
2012, 2013; Packett et al., 2009; GBRMPA, 2009b; Lewis et al., 2012;
Rohde et al., 2008; Shaw et al., 2010; Smith et al., 2012; Kennedy
et al., 2012a; Magnusson et al., 2008, 2010; van Dam et al., 2012;
Negri et al., 2011). Almost ten years since its commencement, a
nal decision on the review of diuron is still pending. In addition
to the other chemicals of concern to the GBR that have not been
reviewed, the APVMA has also not considered their potential cumulative effects, which in the case of PS-II herbicides are known to be
The tightened restrictions on the use of chemical products
introduced by the Queensland Government in 2009 resulted from
the considerable research attention and investment the GBR has
received, but other lower prole and less studied ecosystems in
Australia are unlikely to receive the same protection. Outside of
the GBRMP and GBRCA there is very little monitoring of pesticides residues in Australian rivers, streams, wetlands and marine
environments but the few properly designed and implemented
monitoring studies have found that they are ubiquitous in water

bodies where pesticides are used. There is clearly a need for better
monitoring of pesticide residues in Australian environments, more
independent studies on their toxicity to local species as well as the
collection of usage data to inform research and monitoring priorities. Lack of adequate monitoring in Australia means it is difcult to
verify the effectiveness of chemical label conditions in preventing
contamination of the environment. This is particularly concerning
in the context of the APVMAs tendency to add increasingly complex label conditions rather than deregister chemicals (such as in
the case of atrazine), as well as the difculty of properly enforcing
product label conditions. Whilst it may be possible to manage the
use of certain chemicals to prevent farm runoff, in the absence of
veriably effective conditions of use and their proper enforcement,
deregistration will denitely lead to reduced presence in water
Whist the Queensland Government is not the rst Australian
state to have introduced its own restricted conditions for the use of
certain pesticides, the APVMA is, and should be, principally responsible for restricting and removing access to dangerous chemicals.
It is essential for the proper protection of all Australian ecosystems
to have an independent national pesticide regulator that responds
quickly and decisively to implement effective management action
when unacceptable risks are identied (including suspending or
cancelling chemical registrations when necessary). This remains
true for the protection of the GBR, even given its unique position
having been the subject of extensive pesticide monitoring over
many years, extensive toxicity testing on local species and special management consideration through specic Commonwealth
and Queensland legislation. A systematic re-registration program
of European standard is the minimum requirement as it would at
least ensure regular reviews of the environmental risks of currently
registered pesticides. For the GBR, this would ensure the continued
review of the chemicals restricted by the Queensland Government
such as ametryn and hexazinone (and the effectiveness of those
restrictions in reducing runoff to the GBR), as well as the systematic review of other chemicals that are of concern now (such as
simazine) or become so in the future.
We would like to thank Stephen Lewis, Aaron Davis and Martin
Taylor for comments on the paper. Stephen Lewis and Jane Waterhouse helped with the production of Fig. 1. We also acknowledge
two anonymous reviewers for their helpful comments and the Special Editor Peter Thorburn for his patience in getting this paper in a
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