Health and Safety
Executive / Commission
Biocides &
pesticides
As part of our continuing commitment to reviewing our documented procedures, HSE's Pesticides Registration Section (PRS) decided to draw up a COPR Registration Handbook specific to non-agricultural pesticides.
Therefore, in early April 2000, PRS will be sending out an amended version of The Registration Handbook specific to non-agricultural pesticides. This new version will be slimmer than the existing version as all reference to the Pesticides Safety Directorate's (PSD) operating procedures for agrochemicals has been removed - as a result, it will now fit into one ring binder.
When receiving the new version of the Handbook, you should discard your current copy and use one of the ring binders to store the new version in.
As MAFF's PSD will still be responsible for agrochemicals, any issues relating to such registrations under COPR should be directed to their offices in York.
If you have any further questions on this issue please contact PRS on 0151 951 3535, fax 0151 951 3317 or info.prs@hse.gsi.gov.uk
In issues 44 and 45 of our Newsletter we informed you that HSE would be collecting its own fees for applications of non-agricultural pesticides from 1 April 2000. In order to do this the Health and Safety Commission (HSC) needs to have agency agreements with Ministers and devolved administrations.
There has been a delay in arranging these agency agreements and the HSC will not be empowered to collect fees by 1 April. Instead, MAFF WILL CONTINUE to collect fees in the interim on our behalf.
We will keep Approval Holders informed of progress and contact you as soon as the agency agreements are finalised.
If you have any further questions on this issue please contact the Information Group on 0151 951 3535, fax 0151 951 3317 or e:mail info.prs@hse.gsi.gov.uk
In our drive to meet current guidelines for labelling of non-agricultural pesticides generated by general chemical legislation, the Pesticides Registration Section instigated a review of registered products with regards to potential aspiration hazards - the "R65 Review". During this review PRS used the opportunity not only to assess the products for their aspiration hazard potential but to update the product details to current guidelines, which resulted in the issuing of amended Notices and Schedules to many Approval Holders. It was also noted that older products not involved in this exercise might not meet current guidelines.
In order to bring all products in line with current guidelines PRS has decided to upgrade all current products that were not previously upgraded in the R65 Review. This means that PRS requires Approval Holder co-operation in supplying requests for information on their products. The requested information will generally focus in greater detail on application rates, requests for Safety Data Sheets and where necessary a detailed breakdown of the products formulation. These requests for information will occur throughout the year and a specific deadline for completion by you the Approval Holder will be set.
Once PRS are in receipt of the information and it has been assessed, an amended Notice and Schedule will be issued. Any changes that affect the product label should be incorporated into your next label print run.
Failure to respond to the information request within the deadline may result in further regulatory action being taken against your product(s) on the grounds of insufficient information being available for an accurate assessment on the safe use of this product.
If you have any further questions on this issue please contact the Approvals Group on 0151 951 3535, fax 0151 951 3317 or e:mail info.prs@hse.gsi.gov.uk
PRS has had several enquiries with regard to the definitions of dipping and immersion. Therefore it was decided to remind all Approval Holders of the agreed definitions, which were last published in 1994.
Guidelines to describe the application methods of immersion and dipping were agreed with the British Wood Preserving and Damp-Proofing Association, the Building Research Establishment, the Timber Research and Development Association and the Nationwide Association of Preserving Specialists some years ago, and are as follows:
Partial submersion of timber (likely to take place in a small vessel) e.g. fence post ends to be buried in the ground or cut ends of treated timber before assembly into structures. This method is used by amateur, professional and industrial operators.
Complete submersion of timber in open tanks (likely to be large volume), e.g. immersion of window frames and fence panels in joinery workshops. This method is used by professionals and industrial operators.
Complete submersion of timber in an enclosed tank, in an industrial treatment plant. Enclosed immersion may be a timed and closely controlled process. This method is rarely used by professional operators and is used mostly by industrial operators. This method is not for use by amateurs.
These definitions will be used for risk assessment purposes and on schedules. In order to ensure the most appropriate risk assessment is undertaken, it will be necessary for the applicant to specify if treatment is to take place indoors or outdoors. If any particular concerns are raised when a risk assessment is undertaken, then there may be specific conditions of approval which have to be set, e.g. limit dipping to indoors or limit immersion to closed immersion only.
If you have any further questions on this issue please contact the Approval Group on 0151 951 3535, fax 0151 951 3317 or e:mail info.prs@hse.gsi.gov.uk
Like any industry, new developments are being made in the pesticide industry, for example in the area of pesticide application technology. Whilst it is understood that approval holders may want to take advantage of these developments, you should remember that this may affect your conditions of approval - especially if your product is approved for application by a particular type of equipment.
If approval holders are considering changing any application equipment you may recommend on your label/product literature, and have any doubts on how it may affect your approval, please contact the Information Group at PRS on 0151 951 3535, fax 0151 951 3317 or e:mail info.prs@hse.gsi.gov.uk
Following the initiation of the review of all products containing organophosphate or carbamate active ingredients in July 1998, the Pesticides Registration Scheme (PRS) issued data call-in notices on 30 September 1998.
The deadline for the submission of data packages was 30 September 1999 and non-agricultural products containing the following active ingredients, which were not supported by a data package, have been issued with notices of revocation:
Chlorpyrifos-methyl Diazinon Iodofenphos Propoxur TrichlorfonAny application for products containing these active ingredients will be treated as an application for a new active ingredient and will attract the associated fee.
The following active ingredients were supported by data packages:
Azamethiphos Chlorpyrifos Dichlorvos Fenitrothion Pirimiphos-methyl Bendiocarb 3-iodo-2-propynyl-n-butyl carbamate (IPBC)Approval holders will recall that HSE requested the submission of information regarding the packaging of products containing anticholinesterase compounds. This information has been collated and will be discussed by the Advisory Committee on Pesticides (ACP) in the near future.
Initial sifts of the data indicate that the submissions meet the requirements of the data call-in and will be taken forward to the ACP. HSE intend to evaluate dichlorvos and fenitrothion first, followed by the remaining organophosphates and finally the carbamates.
The data call-in letters which were sent to approval holders emphasised that the ACP regarded usage date (i.e. information on the amount of material used and the manner of its use) as an important component of the risk assessment process for both humans and the environment. The ACP considered that this information should be provided as voluntary submissions by approval holders at the request of PRS. To date PRS have received little usage information from approval holders.
Approvals holders will receive a letter within the next month reminding them of the request for this information and inviting them to submit data. In the absence of this data PRS will utilise the best or most appropriate alternative information available from other sources. As emphasised in the data call-in letter these estimates will inevitably be less accurate and will certainly tend towards more precautionary assessments.
The letter to Approval Holders will give further information on the nature of the data PRS will require to refine the risk assessments.
Anyone wishing to discuss the HSE review of organophosphates and carbamates should contact Mr Paul Willgoss on 0151 951 3639, fax 0151 951 3317 or e:mail paul.willgoss@hse.gsi.gov.uk
There have been no new issues or developments over the past months.
Please note there is no factsheet on the Biocidal Products Directive with this issue of the Pesticides Newsletter.
If you require any further advice or information about any of the articles in this issue of the newsletter, please contact the Pesticides Registration Section by telephone on 0151 951 3535, by fax on 0151 951 3317 or by letter to Pesticides Registration Section, Health and Safety Executive, Magdalen House, Stanley Precinct, Bootle, Merseyside L20 3QZ. Alternatively we can be contacted via e:mail at info.prs@hse.gsi.gov.uk