I’m inserting a section of the Product Re-evaluation Document specifically covering Demand CS . The PMRA is proposing elimination of all indoor residential uses of the product.
“The following postapplication scenarios were assessed: application for bedbugs, band and spot application, and crack and crevice application. Both cancer and non-cancer risks of concern were identified for all lifestages from dermal exposure for all scenarios except crack and crevice application. Both cancer and non-cancer risks of concern were identified for children from incidental oral exposure for all scenarios including crack and crevice application. Revised label directions are proposed to specify that crack and crevice applications are only permitted in non-residential areas.”
Their “cancer and non-cancer risks of concern” are not scientifically based, and in generally unfounded. They are stating a “concern” about children having an oral exposure to the product, even when applied in a crack and crevice application, under box springs or behind a refrigerator.
The Industry needs your help now…YOU ARE THE INDUSTRY!
There is a 90 day comment period on the proposed changes and YOU NEED TO COMMENT.
Read through the whole executive summary (linked below) and comment. Always refer to PRVD2017-03
Here’s where to comment: