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Proactive Disclosure
Pre-submission Consultations
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Richard Kenny
A/Section Head
Screening and Pre-submission Consultation Section
Submission and Information Management Division, Registration Directorate
Overview
Pre-submission Consultation
- An opportunity for a registrant or applicant to request information on the application requirements and process prior to data generation and submission.
- Facilitate progress through the screening and review process.
- A means to obtain advice on a study protocol.
- The objective is to aid the registrant/applicant in preparing a complete, high quality submission package.
When to request a Pre-submission Consultation?
- New Registrants
- Joint Review
- A pre-submission consultation is mandatory for a Joint Review
- Biopesticides
- Mandatory for Microbials as per Section 3.0 of DIR2001-02, Guidelines for the Registration of Microbial Pest Control Agents and Products
- Novel Product Types
- e.g. essential oils, some swimming pool products
- Actives with issues (e.g. Re-evaluation)
Complete Pre-submission Consultations package
- Completed Pre-submission Consultation Form
- Outlines the purpose of the applicant request and identifies target questions.
- Will be available on the PMRA website in the future. Currently available upon request.
- Proposed label
- Required to identify proposed uses, rates, method of application, etc.
- Product Specification Form (Form 6003)
- Indicates active ingredients.
- Required to verify formulation and identify any formulant issues.
Process Steps
- Applicant submits a request for a pre-submission consultation with all information.
- Mail
- E-mail - pmra-arla_presubs@hc-sc.gc.ca
- The PMRA assigns a pre-submission number for tracking purposes and acknowledges receipt of request.
- Pre-submission Consultation Coordinator verifies all components are present.
- If clarifications are required the applicant is contacted.
- Coordinator screens the request. Consults with Science Review Divisions for advice if necessary.
- A PMRA written advice response is prepared and forwarded to the applicant. The advice is intended to provide a focus for discussion at a subsequent meeting or conference call, if one is necessary.
- The PMRA advice includes the submission category, timelines, fees, DACO tables and science advice.
- Examples of Science advice may include:
- Identifying additional data requirements
- Data requirements that are conditionally required may become required.
- Providing guidance on the number of efficacy trials
- Caveats
- Advice provided under a pre-submission consultation is valid for a 24-month period. It is recommended that a second request be made if a submission is not provided within the 24-month period.
- Data Waivers: advice provided is based on the limited information provided. The waiver can only be fully assessed in the context of the subsequent data submission.
Common Issues
- Missing documentation (e.g. application form, label or PSF)
- Incomplete information on forms
- Active ingredient/formulants missing from PSF
- Label uses or rates are vague or not specified
- Applicant not providing clear and concise questions
- Purpose of the pre-submission
- What type of advice is being requested
e.g. specific questions for an area of PMRA expertise
- Time delays in clarification responses
Pre-submission Consultation Contacts
Telephone
1-800-267-6315 (in Canada)
613-736-3799 (outside Canada)
613-736 3798 (fax)
E-mail
pmra-arla_pre-subs@hc-sc.gc.ca
pmra_infoserv@hc-sc.gc.ca
Mail
Stéphane Lavigne or Richard Kenny
Screening and Pre-submission Consultation Section
Submission Coordination Division
Pest Management Regulatory Agency
2720 Riverside Drive
Ottawa, Ontario K1A 0K9