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Regulatory Proposal PRO2001-02
Harmonization of environmental chemistry and fate data requirements under NAFTA

Her Majesty the Queen in Right of Canada, 
represented by the 
Minister of Public Works and Government Services Canada 5oct01

source: http://dsp-psd.pwgsc.gc.ca/Collection/H113-8-2001-2E.pdf 11dec01
Government of Canada Main Website (French and English) 

Comment on Canada's Regulatory Proposal PRO2001-02
"Harmonization of environmental chemistry and fate data requirements under NAFTA." by Paul Goettlich 9dec01

The purpose of this document is to provide information on proposed changes to the Pest Management Regulatory Agency’s environmental chemistry and fate data requirements for conventional chemical pesticides on terrestrial food crops (PMRA Use–Site Category 14). These proposed changes implement the agreements reached with the United States Environmental Protection Agency under the North American Free Trade Agreement Technical Working Group on Pesticides. It is proposed that these changes will come into effect on January 1, 2003.

Please provide any comments on this publication within 45 days of the date of release of this document to the Publications Coordinator at the address listed below.

(publié aussi en français)     October 5, 2001

This document is published by the Submission Coordination and Documentation Division, Pest Management Regulatory Agency. For further information, please contact:

Publications Coordinator                  Internet: pmra_publications@hc-sc.gc.ca 
Pest Management Regulatory Agency                   www.hc-sc.gc.ca/pmra-arla/ 
Health Canada                             Information Service:
2720 Riverside Drive                      1-800-267-6315 or (613) 736-3799
A.L. 6605C                                Facsimile: (613) 736-3798
Ottawa, Ontario
K1A 0K9

ISBN: 0-662-31114-0
Catalogue number: H113-8/2001-2E-IN

© Her Majesty the Queen in Right of Canada, represented by the Minister of Public Works and Government Services Canada 2001

All rights reserved. No part of this information (publication or product) may be reproduced or transmitted in any form or by any means, electronic, mechanical photocopying, recording or otherwise, or stored in a retrieval system, without prior written permission of the Minister of Public Works and Government Services Canada, Ottawa, Ontario K1A 0S5.

The harmonization of pesticide regulatory requirements being carried out under the auspices of the North American Free Trade Agreement (NAFTA) Technical Working Group (TWG) on Pesticides is important for achieving the goal of one North American market for pesticides. This goal is articulated in the document known as the North American Initiative (NAI). The NAI commits Canada’s Pest Management Regulatory Agency (PMRA) and the U.S. Environmental Protection Agency (EPA) to harmonize pesticide regulatory tools so that work sharing and joint review activities become routine.

Changes to the PMRA environmental chemistry and fate data requirements for conventional chemical pesticides used in Use–Site Category (USC) 14 (Terrestrial Food Crops) are being proposed to implement the agreements1 reached with the U.S. EPA under the NAFTA. These changes are reflected in the attached USC 14 data code (DACO) table for the combined technical grade active ingredient (TGAI) and end-use product (EP) (Appendix 1). Identical changes will be made for corresponding data codes in the USC 14 TGAI and EP DACO Tables. The proposed changes do not jeopardize the stringency of the environmental data requirements nor the interpretation of the data with respect to environmental protection. It is proposed that these changes will come into effect on January 1, 2003. Applicants, however, are encouraged to accommodate these changes as soon as possible. Combinations of old and revised data requirements will not be acceptable. The EPA will be implementing these agreements on the same schedule through its normal processes until Code of Federal Regulations 40 Part 158 is revised. Highlights of the changes to the environmental chemistry and fate data requirements appear in the following summary tables.

Proposed revisions to USC 14 environmental chemistry data requirements for the TGAI

Data code

Title

Existing

Proposed

Data required

Conditions

Data required

Conditions

8.2

Laboratory Studies

 

 

 

 

8.2.3.4

Biotransformation in Soil (TGAI)

 

8.2.3.4.4

Anaerobic Soil 20-30• C

CR

Can be satisfied by
8.2.3.5.6

R

Can be satisfied by
8.2.3.5.6

8.2.3.5

Biotransformation in Aquatic Systems

(TGAI)

 

8.2.3.5.2

Aerobic Water 20-30• C

R

Preferred over part
18.2.3.5.4

R

 

8.2.3.5.4

Aerobic Water-Sediment
20-30• C

CR

III partitioning into I
sediment is expected

R

 


1 See Status of Harmonization of Data Requirements and Test Protocols for Pesticide Registration, Environmental Fate, NAFTA Technical Working Group on Pesticides, June 5, 2000.


Data code

Title

Existing

Proposed

Data required

Conditions

Data required

Conditions

8.2.3.5.6

Anaerobic Sediment Water

R

CR

If partitioning into 20-30• C sediment is expected; likely to be upgraded to required (R) in the future for the purposes of model input

8.2.4

Laboratory Studies of Mobility (TGAI)

8.2.4.2

 Adsorption or Desorption

CR

One of 8.2.4.2, R
8.2.4.3.1, 8.2.4.3.2 or
8.2.4.4 is required (R)

8.2.4.3 Soil

Column Leaching

R

8.2.4.3.1

Unaged Soil

CR

See 8.2.4.2

8.2.4.3.2 Aged Soil

CR

See 8.2.4.2

8.2.4.4

Soil Thin Layer Chromatography (TLC) Leaching

CR

See 8.2.4.2

R = required; CR = conditionally required; blank = not required.

With respect to the data requirements for laboratory studies of mobility, adsorption or desorption (8.2.4.2) and soil column leaching data (8.2.4.3) will now be required. The differentiation between unaged soil and aged soil column leaching (8.2.4.3.1 and 8.2.4.3.2, respectively) has been removed, as well as the requirement for soil TLC (8.2.4.4).

Proposed revisions to USC 14 environmental chemistry data requirements for the EP

Data code

Title

Existing

Proposed

Data required

Conditions

Data required

Conditions

8.3.3

Aquatic

 

 

CR

Based on potential for
aquatic exposure and if
pesticide residues have the
potential for persistence,
mobility, non-target aquatic
toxicity or bioaccumulation;
U.S. field studies are
acceptable, if conducted at
appropriate sites in relevant
ecoregions

8.3.3.1

Canada

CR

Based on potential for
aquatic exposure and if
pesticide residues have the
potential for persistence,
mobility, nontarget aquatic
toxicity or
bioaccumulation

 

8.3.3.2

Northern U.S.

CR

Can augment Canadian
studies

 

 

R = required; CR = conditionally required; blank = not required.

The changes to the environmental field study data requirements reflect the removal of the differentiation between Canadian and northern U.S. study sites. For the terrestrial field studies, the subsections 8.3.2.1 and 8.3.2.2 have been collapsed into 8.3.2. This does not affect the overall data requirements, as terrestrial field studies (Canadian or northern U.S.) remain required. Previously, available northern U.S. terrestrial field studies could substitute for some Canadian studies and consequently were denoted as "CR." Similarly, 8.3.3.1 and 8.3.3.2 have been combined into 8.3.3 for the aquatic field studies, which remain conditionally required.

Similar changes to several other outdoor USCs (4,7,13,16, 25, 27 and 30) will be addressed in a separate regulatory proposal.

List of abbreviations

CR      conditionally required
DACO    data code
EP      end-use product
EPA     Environmental Protection Agency
NAFTA   North American Free Trade Agreement
NAI     North American Initiative
PMRA    Pest Management Regulatory Agency
R       required
TGAI    technical grade active ingredient
TLC     thin layer chromatography
TWG     Technical Working Group
U.S.    United States
USC     Use–Site Category

Appendix I Proposed USC 14 DACO requirements for the combined TGAI and EP

Data code

 Title

Data required

Conditions

Volume no.
and pages

8

Environmental Chemistry and Fate

8.1

Summaries

R

8.2

Laboratory Studies

8.2.1

Summary of Physicochemical
Properties to include Solubility in
Water, Vapour Pressure,
Octanol-Water Partition Coefficient,
Dissociation Constant and LTV Visible
,Absorption (See Part 2) (TGAI)

R

Data submitted under 2.14.7, 2.14.9,
2.14.10, 2.14.11 and 2.14.12

8.2.2

Analytical Methodology (parent
compound and transformation
products)

8.2.2.1

Soil

R

8.2.2.2

Sediment

R

8.2.2.3

Water

R

8.2.2.4

iota

R

8.2.3

Laboratory Studies of Transformation
(TGAI)

8.2.3.1

Summary

R

8.2.3.2

Hydrolysis

R

8.2.3.3

Phototransformation

8.2.3.3.1

Soil

R

8.2.3.3.2

Water

R

8.2.3.3.3

it

CR

If volatilization is indicated by vapour
pressure or Henry's Law Constant

8.2.3.4

Biotransformation in Soil (TGAI)

8.2.3.4.2

Aerobic Soil 20-30• C

R

8.2.3.4.4

aerobic Soil (Flooded) 20-30• C

R

Can be satisfied by 8.2.3.5.6

8.2.3.5

Biotransformation in Aquatic Systems
(TGAI)

8.2.3.5.2

Aerobic Water 20-30• C

R

8.2.3.5.4

Aerobic Water Sediment 20-30• C

R

1

Data code

 Title

Data required

Conditions

Volume no.
and pages

8.2.3.5.6

Aerobic Sediment Water 20-30• C

CR

If partitioning into sediment is expected;
likely to be upgraded to required (R) for
the purposes of model input

8.2.3.6

Special Studies Related to Use Pattern
or Formulation (EP)

CR

8.2.4

Laboratory Studies of Mobility (TGAI)

8.2.4.1

Summary

R

8.2.4.2 Adsorption or Desorption R
8.2.4.3 Soil Column Leaching R
8.2.4.5 Volatilization CR If volatilization is indicated by  vapour
pressure or Henry's Law Constant
8.2.4.6 Special Studies Related to Use Pattern
or Formulation (EP)
CR
8.3 Field Studies of Dissipation and
ccumulation [may be small or large
scale] (EP)
8.3.1 Summary R
8.3.2 Terrestrial R . US field studies are acceptable, if
conducted at appropriate sites in relevant
ecoregions
8.3.3 Aquatic CR Based on potential for aquatic exposure
and if pesticide residues have the
otential for persistence, mobility, non-
target aquatic toxicity or
bioaccumulation; U.S. field studies are
acceptable, if conducted at appropriate
sites in relevant ecoregions
8.3.4 Special Studies Related to Intended
Use Pattern
CR Based on concerns arising from results
of other studies
8.4 Storage, Disposal and Decontamination
(TGAI and EP)
8.4.1 Summary R
8.5 Other Environmental Fate Studies
(TG AI and EP)
8.5.1 Summary CR Based on concerns arising from
results of other studies
8.6 Other Studies, Data and Reports CR If available

 

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