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Comparison of Sector Interim Recommendations or Preferred Options - 23 February 2006

Appendix 2

Summary of Recommendations from thePest Management Regulatory Agency (PMRA)

With the principle of the building block approach in mind, and in keeping with the intent to maintain the existing level of coverage, the PMRA is recommending the following:

• adoption of all GHS physical hazard classes and categories;
• adoption of the GHS hazard class for acute aquatic toxicity but not the hazard criteria for chronic aquatic toxicity since the GHS chronic criteria are not as rigorous as the chronic risk assessment conducted by the PMRA; and
• adoption of those human health hazard classes and categories consistent with the PMRA's current approach to classification and labelling of pesticides.

It is recognized that for several of the physical hazard classes, products that meet the hazard classification criteria are not expected to be used as pesticides; however, the PMRA is proposing to adopt these classes as placeholders in the event that such products are manufactured as pest control products.

With respect to human health hazards, the PMRA intends to use the GHS criteria for all the hazard classes to identify and classify the health hazard. However, not all aspects of labelling will be applied in every instance. This reflects the current practice of classification and labelling of pesticides based on identified acute hazards while addressing other health hazards (for example, reproductive toxicity) through a risk assessment process. The PMRA is proposing to adopt the GHS criteria for the latter health hazard classes for the sole purpose of classifying and communicating the hazard on the Material Safety Data Sheet (MSDS). The GHS labelling elements for these hazard classes would not be adopted.

General Considerations

The criteria used in the GHS for classification of chemicals into physical hazard classes are based largely on United Nations Test Methods required by authorities regulating the transportation of dangerous goods. It is anticipated that these tests will already have been conducted by manufacturers of pest control products; therefore it is not likely that additional testing will need to be conducted for classification into most physical hazard classes where the criteria used by the GHS differ from those currently used by the PMRA.

PMRA may take different approaches when it comes to the submission of data for classification of registered products versus new products.