The Globally Harmonized System for the Classification and Labelling
(The GHS) - Implementation of the GHS in Canada
Pest Control Products
Introduction
Pesticide labelling encompasses both a hazard-based and risk-based approach.
Symbols are required to represent some physical hazards (i.e. flammability,
explosivity, corrosivity) and acute health hazards. Other physical, health
and environmental hazards are not shown on the labels of pest control
products but are considered in the registration decisions as described
below.
The hazards associated with pressurized containers and flammable, corrosive,
irritating or acutely toxic products are consistently communicated by
means of symbols and signal words which convey both the nature and level
of the hazard. The symbols and signal words are provided in Schedule III
of the PCPR. The Registration Handbook contains general guidance on label
requirements for petitioners of pest control products. It includes criteria
for identifying a product as flammable, corrosive, acutely toxic, or irritant.
It also includes three levels of hazard in a progression of increasing
severity to be reflected in the signal words CAUTION, WARNING, and DANGER
and corresponding symbols. If more than one symbol is required, the most
severe signal word is required with all of the hazard identifying words.
If more than one signal word is required, there are operational criteria
in place for use by the pesticide regulatory authority when verifying
labels. Verification of the appropriateness of the symbols and signal
words is performed following evaluation of the information submitted to
support registration.
An application to register a pest control product must include information
on several physical and chemical properties: explodability, flammability,
oxidizing or reducing action, corrosion characteristics and the container.
These properties are used to determine the appropriate hazard symbols.
Methods used to determine the physical and chemical properties must be
described or referenced. For technical active ingredients, the melting
point, boiling point, vapour pressure and stability (metals, temperature)
must be provided as well as the test method or reference to an established
international protocol. This information is used in the risk assessment
of the product.
Health (other than acute and irritation) and environmental hazards are
not labelled but are evaluated through a risk assessment approach. This
process includes the identification of hazards and the level of anticipated
exposure when the product is used as intended. The exposure levels are
combined with the hazard assessment to determine whether there are risks
associated with the use of the product. If risk mitigation measures such
as personal protective equipment, buffer zones to sensitive ecosytems,
or other exposure reducing measures are necessary and reasonable to achieve
an acceptable level of risk, they are added to the label as a condition
of use or else the registration of the product is not supported.
The Pest Control Products Regulations (PCPR) stipulate the types of information
to be provided on labels. These labelling requirements will be included
in regulations under PCPA 2002 when it comes into force. However, a few
changes will be incorporated.
The current PCPR requires that the active ingredient(s) and its concentration
be identified on the label. There is no regulatory requirement for disclosure
of any other hazardous ingredients. Under PCPA 2002, the active ingredient
and any components (formulants and contaminants) of health or environmental
concern that are identified on a Health Canada list are excluded from
the definition of confidential business information. The regulations could
therefore require that these components be listed on the Material Safety
Data Sheet (MSDS) and on the label of a pest control product. Other components
of a pest control product will be included in the definition of confidential
business information and therefore will not be disclosed.
Material Safety Data Sheets are not currently required under the PCPA.
The PCPA 2002 requires that an MSDS be provided to workplaces where a
pest control product is used or manufactured. The content of the MSDS
will be prescribed in the regulations.
The label of each pest control product must show the market class to
which it has been designated. The purpose of these classes is to provide
a framework for provincial regulation of the sale and use of registered
pesticides. Classification has an important role in mitigating potential
risks associated with pesticide use, because there is an ascending degree
of hazard associated with the DOMESTIC, COMMERCIAL and RESTRICTED classes.
The DOMESTIC class is for products marketed to consumers for use in and
around a dwelling. The COMMERCIAL class is for products marketed for general
use in the commercial activities specified on the label. Products within
the RESTRICTED class are subject to specific limitations respecting their
display, distribution, use, or operator qualifications, due to high inherent
toxicity or intended use in environmentally sensitive areas. The market
class to which a product is assigned depends on the intended uses, the
package size, potential risks, and inherent hazards of the product. Acute
toxicity is one criterion used to ensure that more hazardous products
are not available in the DOMESTIC class and that highly hazardous products
are limited to the RESTRICTED class.
The FPT Committee on Pest Management and Pesticides has proposed for
public comment (November 2002) some modifications to the federal market
class system to enable harmonization of provincial and federal classification
systems. The proposed system would include 5 market classes: Lower Risk
Domestic, Higher Risk Domestic, Lower Risk Commercial, Higher Risk Commercial,
and Restricted. The intended uses, package size, potential risks and inherent
hazards of a pest control product would continue to be important considerations
in designating its appropriate market class. Acute toxicity remains an
important criterion. The proposed LD50 (oral, dermal) and LC50
(inhalation) cut-values for the FPT market classes are generally consistent
with cut-off values for Acute Toxicity categories of the GHS. The proposal
states that other hazards within the GHS may be incorporated in the FPT
market classification system at a future date.
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