PMRA re-evaluation – Roberts Rants

Mosquito Less(on) Learned

Posted on July 6, 2023July 6, 2023 by Robert Percy

This just seemed like this little screw up needed documented.

There have been several attempts at bringing 25b products or those Generally Regarded As Safe (GRAS) products into Canada. You remember the EPA decided products like thyme oil, spearmint oil and other plant based extracts did not require a full blow data package, or any package to be used as a pesticide in the US.

Extract from citrus, d-limonene another great example.

But in Canada?

No way. Show me the money!!

So how many GRAS products do we have registered?

So anyway, one company decided to pony up all the money involved, with a bit of a break as some date just could not be generated, and obtained a registration for Garlic Oil.

Yeppers, just the juice from a garlic clove.

Wait, you need to submit data and fees and a little bit more data and a lot more fees to get a registration for garlic oil? you bet

To repel mosquitos? damn straight

So if I squished the hell out of a billion garlic gloves and sprayed my bushes I would be making an illegal application? hahahaha…or a salad for an extinct oversized lizard.

So we have had a couple garlic oil products registered, domestic for the RTU’s and a commercial full strength concentrate that requires a mosquito license to purchase. Thats in case someone wants to kill themselves by drinking the concentrate and die by alienating friends and lovers.

SO END OF STORY

hahahahaha

Remember where we are, and this is Health Canada we’re ranting about.

THE REST OF THE STORY

So here we are in the midst of the season, when a customer called and told us he’d been inspected by Health Canada, and that he could not use the garlic oil product he purchased from us last year. About a third of a pail left, used once for a senior organic vegan hippie type. (Who were bitten the next day by Culex pipiens and died of West Nile Virus on Christmas Eve eating cauliflower blintzes. But thats my next rant.)

That was it, you just could not spray it. Nothing about was it a stop sale or recall or disposal as Hazardous waste.

Did they say why? Well, apparently the registration lapsed a while back – like 6 months ago – as the owner came down with a debilitating illness, a new company bought them, but never guessed a garlic oil sprayed for bugs outdoors would require the intervention of Health Canada.

The registration wasn’t renewed. No big deal.

Did someone forget to tell the rest of the world, like us or Varyairyus or Amazon Crime or Home Creepo or Canadian Tired or Home Hardly (sorry on a roll there) that all this product on their shelves and websites and in the hands of millions of consumers, that it was illegal to sell, use or spray?

No, just that the registration was up for fast tracking to mend this oversight. Probably the next few weeks. Which it should be, but here’s the question, what if the PCP# changes, what happens to product in the field? And homes. Does it need relabeled? Destroyed? Burned up as waste for a mere $250 a liter, or hauled off to residential household waste?

Why the delay? Vacation schedules maybe, or the act of just ticking the registered box seems way to simple.

If this had been Preparation HHH and had its DIN pulled, what happens? Does HC tell anybody, or do we just use it like we do the expired tube and stick it….well you get the rest.

It’s July, my garden needs weeding now that its fertilized.

So about this “Residential” definition

Posted on March 15, 2023 by Robert Percy

It makes you wonder how many people (including children) sat around in a committee, eating tax dollar donuts, did it take to come up with a definition for ”residential”?

This ones from Demand CS

11.2 Animal Housing (such as poultry and livestock housing)

For indoor applications to residential areas (where the general public, including children may be exposed), DO NOT apply as a broadcast, perimeter or spot treatment.

So a poultry barn is animal housing but is also human housing if your this general public person, including children? So animal residential until the poultryman’s wife drops off lunch then its residential, including children?

Dragnet EC: can anyone tell me what the *** the *** definition is for non-residential?

Indoor Broadcast (Permitted only in non-food/non-feed handling establishments* and non-residential** structures): DO NOT apply indoors in food/feed handling establishments* and in residential areas** as a broadcast application. Indoor broadcast application in non-food/non-feed handling establishments* and in non-residential** buildings is to broad expanses of indoor structural surfaces, such as walls, floors, ceilings and indoor foundation walls/crawlspaces.

**Residential areas are defined as any use site where the general public, including children, could be exposed during or after application. For structural uses, in residential sites, this includes homes, schools, restaurants, public buildings, modes of transport in areas where passengers are present, or any other areas where the general public including children may potentially be exposed.

How much time and effort was spent on coming up with something like this crap that comes out of these committees, meetings, zooms or my fav Teams? Ka-ching

It’s like the long story told and at the end they say ”You had to be there”

No duh.

A Call to Action! Part 2

Posted on May 22, 2012 by roberts

LiphaTech, the producers of Generation and FirstStrike, is petitioning to have DFN products re-instated for outdoor use.

What the Industry…let me re-phrase that…what you need to do is simple:

Read the attached letter from LiphaTech on the issues.

And if you agree, contact the persons outlined in their letter and add your voice of support.

This is an important task, simple to do, but one with major consequences for all of us in Pest Management.

So take the few minutes and write, it will certainly help the cause!

A Call to Action – Part One! (Canadian Rodenticide re-evaluation decision)

Posted on May 22, 2012 by roberts

The Industry needs your help as Professional Pest Managers.

You are all aware of the PMRA’s actions on the rodenticide re-evaluation decision, and the effects on domestic and commercial baits. But there is one part of the decision we as an Industry should try to have reversed, and that is the limiting use of difethialone (DFN) baits for indoor use only, completing eliminating the opportunity to use outdoors. The names more familiar to you would be Generation and FirstStrike.

The PMRA has lumped this bait into the same category as brodificoum, based on arbitrary levels set in one or two chemical properties.

What was ignored was the fact the bait is used at 50%, or half the rate, of brodificoum, and the properties of the products are much closer to bromodialone than brodificoum. But this and other factors must have taken into account by the EPA, as PMP’s are still allowed to use DFN products both indoors and out in the States.

So what else does the current decision mean and what impact can it have?

There is now only one second generation anticoagulant available for outdoors. And what, after 5 – 10 years of using one bait for outdoors, will we build up a resistant population of rodents???? Possible??? Who knows, but why take the risk. And do we want to chance ruining another great active by overuse, leaving Canada with no effective bait for outdoors, where you need to stop infestations from coming inside?

The second issue is bait shyness, which we all know develops after continual use and feeding. This will also impact choices…leaving us with products that aren’t any where near as effective.

So what do you need to do to help?

Read part 2!

Tis the season…

Posted on May 9, 2012 by roberts

No I’m not talking Holidays! Basically it’s that time of year when the degree days are adding up and insects are on the move.

Biggest issue I am encountering now is carpenter ants, with high activity levels indoors, more so than outdoors. No swarmers as of yet, or in very limited pockets, but should be expected in the next few weeks.

Hopefully we will be seeing some new active ingredients pass through the PMRA as we are in dire need for new ant baits to fit everyone’s IPM programs. Plus if we continue to rely on the same actives year in and year out, although we may not have a “true” resistance problem, overall effectiveness will start to diminish. I firmly believe we have developed resistance to some pyrethroids used on cockroaches.

There are at least 3 new actives waiting in the wings, with the capability for dusts, baits and dilutable formulations. Look for more posts on these in the coming weeks as I am trying to check on the status of each.

Next up…more on the Rodenticide re-evaluation decision and some major concerns and actions from Industry that is going to take place.

Plus an overview on resistance management, or lack thereof, in the Canadian market.

Cheers!

Rodenticide re-evaluation continued

Posted on April 4, 2012 by roberts

I have just completed the Gardex Positioning Paper on how we are working with the new regulations coming from PMRA on rodenticides, including the use of bait stations. This is available by sending an email to the Ontario office listed on our contact page. Customers will all receive a copy in the next few weeks.

Gardex is fully behind these regulations as we have always contended that some things in the Industry are better left to professionals. The availability of the Domestic registered products are the key focus of this initiative, but there is impact on the Commercial products as far as use sites and new requirements that have been added to the product labels approved by PMRA.

If you are a professional pest control operator, or agriculturalist (farmer) still the best thing is to read and follow the label!

When completing our review of the regulations, and subsequent strategy, I found it a bit more onerous than expected. But you can still boil down the facts, plus using some common sense, understand what the new requirements actually mean and what is required by users of rodenticide products.