Robert's Rants
Robert's Rants
A personal blog on the Canadian pesticide industry and other pet peeves and interests

Let’s Get Real – and I won’t name names

In reviewing the data of a pesticide within the cyclical guidelines of the PCP Act, I decided to look at the maximum rates, and maximum allowable applications to determine the potential exposure levels possible.

And to be on the safe side I take the evidence (rat and mouse studies) and apply a 300 fold safety factor.   That’s what I’m putting in my report.

So that’s 10 fold for intra-species differences (one rat might be different than another) and another 10 fold for inter-species differences (humans ain’t like rats) then another 10 fold for the little kiddies (cuz their parents let them lick the floor).

So 300 fold the safety level….

But wait… 10 x 10 x 10….doesn’t that equal 1000 fold safety level?  Oh, I can say 300 fold, then change the math to fit my desired outcome.

So instead of meeting the criteria of less than 1 per million incidences of a potential carcinogenic effect, I’ve changed the hurdle rate to one per billion chances of contracting (that’s not the right word) cancer from this product.

1,000 x 1,000,000.  Do the math.

So in the entire human population of 7 billion, there may be a chance that 7 people develop  cancer due to direct exposure to this product.

Perfect, I ban those products or uses to save those people.  I am good.

What’s that?  What about other benefits?

Lyme disease, West Nile, asthma, Zika, malaria.  Bed bugs and the effect on the psyche of people living with them.  Cockroaches sharing your food, which many people can’t afford. Stored product pests completely ruining grains and flour, food and feed.

And all the other benefits that product brings…

I still ban it to save those 7 people.  I am good.

Zero use means zero risk correct?

Hey buddy, can ya’ spare a smoke?  Gotta ponder this.


Demand CS. You need to take action!

If you’ve read through my last rant (okay I deleted the last one) PMRA is planning on eliminating one of the best tools we’ve had in this industry for quite some time…Demand CS.

“Potential of risks of concern”

What kind of political mumbo jumbo BS is that?  ANYTHING has a potential of risk of concern!!!

“Don’t run with scissors”!

NO – just eliminate scissors!

“Stick a needle in your eye”

NO – ban sewing for gosh sakes!   Gosh?  I’m getting too nice.

This is based on bad data or misuse of data.

The PMRA believes you do 4 treatments per year in every house in Canada and for every year in existence!

We would love that!!!!

And besides the 4 treatments per year, they are using application methods that are not on the label.


Nearly all of the data cited comes from the USEPA or the USDA.

Out of 72 some studies, only 28 have been conducted AFTER they registered the product in 2004.  And of all the new data the only ones dealing with toxicity were done for a tox package for registration.  Dermal and oral, and one on a lymph node.

But none of these showed any results that would call for elimination of the product.

The USEPA has Demand (lambda-cyhalothrin) listed as a Group D carcinogen.  There is no data to support the classification as a carcinogen, nor enough to classify it as not being a carcinogen.

But with the removal of the product we are back to using a Group C carcinogen…permethrin.  This group is classified as “likely to cause cancer in humans”

So we lose a great product in favor of two that have a worse tox profile and a greater risk of being carcinogenic???

What the hell is the problem here?

YOU NEED TO COMMENT – email, write, call

They’ve lost complete control of their senses.