The Pest Managements Regulatory Agency (PMRA) information note provides guidance to manufacturers, distributors and importers of pesticide treated articles that are sold and used in Canada. Its primary purpose is to clarify existing Canadian regulatory requirements for articles that have been treated with antimicrobial preservatives (in other words, pesticides). It also provides a link to a guidance document on acceptable label claims for treated articles. This guidance document will be useful to manufacturers and registrants when determining if current products meet Canadian regulatory requirements.
Until now, Health Canada’s Pest Management Regulatory Agency (PMRA) has been responding to questions regarding Canadian regulatory requirements for treated articles on a case-by-case basis. This information note serves as a means to educate and communicate Health Canada’s approach for treated articles to all relevant stakeholders.
Treated articles
In Canada, the Pest Control Products Act defines a pest control product as a product, an organism or a substance that is used directly or indirectly to control, destroy, attract or repel a pest, or for mitigating or preventing its injurious, noxious or troublesome effects. The term “pesticide”, while not defined in the Pest Control Products Act, is often used to describe a pest control product and covers a broad range of substances that are commonly known as “herbicides”, “insecticides”, “rodenticides”, “fungicides”, “antimicrobials”, etc. Many everyday items (for example, household products, clothing, and toys) that are currently available on the Canadian market have been treated with a pesticide during the manufacturing stage, in order to protect the product and to extend its shelf-life. Treatment with a preservative allows the manufacturer to produce a longer lasting product, which is a quality many consumers are looking for when making a purchase. Registered pesticides used to treat these products have undergone a rigorous scientific assessment by the PMRA to determine if the risks associated with the use of the pesticide are acceptable.
The term “treated article” is generally used to refer to any product that has been intentionally treated with a pesticide. Articles can be treated with pesticides such as antimicrobials (for example, textile treated with a preservative), insecticides (for example, insecticide-treated clothing), and herbicides (for example, herbicide-treated landscape fabric). A pesticide that has been intentionally incorporated into or applied to an article during manufacture for import, sale or use in Canada must be registered under the Pest Control Products Act.
Examples of products that may contain antimicrobial preservatives include: water-based paints; certain plastic products, such as shower curtains; and wood and construction/masonry materials. The range of products that could be treated with an antimicrobial preservative is quite broad. In most cases, there is no requirement for the label of an article treated with an antimicrobial preservative to include a statement indicating it has been treated. Therefore, knowing which articles have been treated is not always obvious.
Table 1 Some examples of articles treated with antimicrobial preservatives
Examples of products that may contain antimicrobial preservatives include: water-based paints; certain plastic products, such as shower curtains; and wood and construction/masonry materials.
The range of products that could be treated with an antimicrobial preservative is quite broad. In most cases, there is no requirement for the label of an article treated
with an antimicrobial preservative to include a statement indicating it has been treated. Therefore, knowing which articles have been treated is not always obvious.
Table 2 Some examples of treated articles regulated under the Pest Control Products Act
Table 2 provides some examples of treated articles that typically require or do not require registration under the Pest Control Products Act. In the table, all examples require the pesticide used to treat the articles to be registered.
In the first five treated articles examples, the antimicrobial preservative is used to extend the life of the product itself and therefore the article itself does not require registration. However, in the case of packaging materials (for example, sheets, stickers) the antimicrobial preservative is protecting an external product and the treated article is considered a delivery mechanism and therefore the article does require registration.
For more detailed information consult the Questions and Answers – Treated Articles
Health Canada continues to work closely with stakeholders to increase awareness of the regulatory requirements for treated articles in Canada. If you have any comments or questions, contact the PMRA’s Information Service at:
Toll-free 1-800-267-6315