UNITED STATES ENVIRONMENTAL PROTECTfON AGENCY 

MEMORANDUM 

DATE: December 10,2014 

WASHINGTON, DC 10460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: Oxalic Acid. New Use in Bee Hives to control Varroa mites. D424360 

PC Code: 00960 I 

Decision No.: 497398 

Petition No.: NA 

Risk Assessment Type: NA 

TXRNo.: NA 

MRIDNo.: NA 

DP Barcode: 424360 

Registration No.: 91266-R 

Regulatory Action: New Use 

Case No.: NA 

CAS No.: NA 

40 CFR: NA 

FROM: MichaelS. Metzger, Chief ~' /)~7 () 

Risk Assessment Branch VII M"j % 

Health Effects Division (7509P) 

TO: Meredith Laws, Chief 

f nvertebrate-Vertebrate Branch 3 

Registration Division (7505P) 

The U.S. Department of Agriculture has requested a new use of oxalic acid dihydrate (91266-R, 

oxalic acid dihydrate 100 % w/w a.i.) to control Varroa mites in honey bee hives. 

A Reregistration Eligibility Decision (RED) document for Oxalic acid was .issued in 1992. 

As part of a work share with the U.S. EPA, Canada's Pest Management Regulatory Agency (PMRA) 

completed an updated review of the toxicity data for oxalic acid, a dietary assessment, and an 

occupational assessment for the proposed use (Brian Belliveau, Ph.D., Head, Microbial and 

Biochemical Eva~uation Section, 10/26/2009). RED concurs with the conclusions drawn by PMRA 

and reiterates them, in part, below. 

Oxalic acid is ubiquitous in the environment being found naturally in many plants and vegetables, as 

well as in honey. Dietary exposure from the proposed use will be insignificant and indistinguishable 

from background levels of oxalic acid; the use should be considered a food use without the 

requirement of a tolerance. Labeled personal protective equipment (PPE) is sufficient to reduce 

worker exposures to insignificant levels presenting no risk concern. Therefore, RED has no · 

objection to granting this registration. 

Page 1 of20 
Toxicity: 

Toxicity data for oxalic acid are summarized in the attached review from PMRA (Toxicology 

Review, Brian Belliveau, Ph.D., Head, Microbial and Biochemical Evaluation Section, I 0/26/2009). 

Proposed Use 

Oxalic acid may be applied using two different methods as described below. 

SOLUTION METHOD: 

NOTE: To completely dissolve Oxalic Acid Dihydrate, use warm syrup. 

Dissolve 35 g of Oxalic Acid Dihydrate in l liter of l: l sugar: water (weight:volume). Smoke 

bees down from the top bars. With a syringe or an applicator, trickle 5 ml of this solution 

directly onto the bees in each occupied bee space in each brood box. The maximum dose is 50 

ml per colony whether bees are in nucs, single, or multiple brood chambers. Under certain 

unfavorable conditions (e.g., weak colonies, unfavorable overwintering conditions), this 

application methods may cause some bee mortality or overwintering bee loss. 

VAPORIZER METHOD: 

Apply only to outdoor colonies with a restricted lower hive entrance. Seal all upper hive 

entrances and cracks with tape to avoid escape of Oxalic Acid vapor. Smoke bees up from the 

bottom board, Place 2.0 g Oxalic Acid Dihydrate powder into vaporize;r. Follow the vaporizer 

manufacturer's directions for use. Insert the vaporizer apparatus through the bottom entrance. 

Apply heat until all Oxalic Acid has sublimated. 

Dietary and A22re2ate Exposure: 

The following summary is taken from the PMRA dietary exposure review (Dietary Exposure 

Review, Brian Belliveau, Ph.D., Head, Microbial and Biochemical Evaluation Section, I 0/26/2009). 

HED concurs with these conclusions [information in brackets added by HED]: 

"Oxalic acid occurs naturally in honey with amounts varying with the type of flower pollen 

is collected from. The applicant is unable to provide a range of values of oxalic acid in 

Canadian Honey, but submitted information which suggests that European honey contains 1-

800 mglkg, depending on the botanical source of the pollen. 

It is anticipated that the amount of oxalic acid present as a food residue after application of 

the end use product will not likely exceed the naturally occurring background concentration 

currently found in honey or vegetables (300-17,000 mg!kg for vegetables). It is also 

expected that a majority of available oxalate anion will bind with calcium (also naturally 

occurring in honey) on ingestion, resulting in a compound which is poorly absorbed by the 

gastro-intestinal tract (GI tract). Excretion of calcium oxalate in the faecal matter and urine 

of rodents was evidenced upon ingestion of oxalic acid in non-fasted animals. Less than 10 

Page 2 of20 
%of the administered dose was absorbed through the Gl tract. 

Distinguishing between endogenous and anthropogenic sources of oxalic acid and enforcing 

an MRL [pesticide tolerance in the case of the US. registration] is not possible. As such, 

promulgation of an MRL [pesticide tolerance in the case of the US. registration] will not be 

necessary." 

HED concurs with this assessment. Since low level residues in honey are possible as a result of this 

use but are indistinguishable from endogenous sources, the use should be considered a food use, but 

a tolerance should not be required. 

Since oxalic acid is ubiquitous in the environment and exposures from use in honey bee hives will be 

minimal, the contribution to aggregate risk from this use will be insignificant relative to the total 

exposure from other sources. 

Worker Exposure: 

The following label restrictions are included in the oxalic acid label (EPA Reg. No. 9 I 266-R) 

"Hazard avoidance: Do not breathe dust or fumes. Do not get in eyes, on skin, or on clothing. 

Wear protective clothing, eyewear, and respiratory protection as listed under "Personal 

Protective Equipment.." Wash thoroughly with soap and water after handling and before 

eating, drinking, chewing gum, using tobacco or using the toilet. Remove and wash 

contaminated clothing before reuse. 

PERSONAL PROTECTIVE EQUIPMENT: 

Handlers and Applicators who apply product by the Solution Method must wear: 

Long-sleeved shirt and long pants 

Socks and shoes 

Waterproof gloves 

Protective eyewear (goggles or face shield) 

Half-face respirator with cartridge and/or particulate filter 

Handlers and Applicators who apply product by the Vaporizer Method must wear: 

Long-sleeved shirt and long pants 

Socks and shoes 

Waterproof gloves 

Protective eyewear (goggles or face shield) 

Half-face respirator with cartridge and/or particulate filter 

User Safety Requirements: 

Follow manufacturer's instructions for cleaning/ maintaining PPE. If no such instructions are 

provided for washables, use detergent and hot water. Keep and wash PPE separately from 

other laundry. 

Wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. 

Page 3 of20 
Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean 

clothing. 

Remove PPE immediately after handling this product. As soon as possible, wash thoroughly 

and change into clean clothing." 

HED recommends that the label additionally specify that the respirator used when applying this 

product be used with an acid gas cartridge and a particulate filter. 

HED has not selected endpoints related to use of oxalic acid in bee hives, or completed a quantitative 

risk assessment. However, based on the high level of personal protective equipment (PPE) required 

by the pesticide label, HED concludes that the label use restrictions will reduce worker exposures to 

oxalic acid to an insignificant level, unlikely to result in risks of concern. 

Page 4 of20 
Attachment: Toxicity Review from Canada's Pest Management Regulatory Agency 

Page 5 of20 
• • 

Health 

Canada 

Pest 

Management 

Regulatory 

Agency 

Sante 

Canada 

Agence de 

reglementation 

de lalutte 

antiparasitaire 

2720 promenade Riverside Drive 

Ottawa, Ontario 

KIAOK9 

Telephone/Telephone: (613)736-3518 

Fax!Telecopieur: (6 13)736-3505 

October 26, 2009 

Memorandum To/Note adressee a: Brian Belliveau, Ph.D. 

Head, Microbial and Biochemical Evaluation Section 

Health Evaluation Directorate, PMRA 

From/De: Kevin Arnold 

Senior Evaluation Officer, Microbial and Biochemical 

Evaluation Section 

Health Evaluation Directorate, PMRA 

Subject/Objet: Sub. No(s): 

Product Name: 

Active Ingredient: 

Applicant: 

I) 2008-4596 

2) 2008-4584 

I) Oxalic Acid Dihydrate 

2) Oxalic Acid Varroa Mite Control 

Product 

Oxalic acid (OXL) I acaricide 

Canadian Honey Council (HCA) 

ACTION REQUESTED: Level D, Category A.l.l Submission Review 

(HED3) Toxicology 

Page 6 of20 
Submission Information: The Canadian Honey Council has applied for the registration of a new source 

of the technical grade active ingredient (TGAI), Oxalic Acid Dihydrate (2008-4596), as well as the 

commercial registration of a new end-use product (EP), Oxalic Acid Varroa Mite Control Product (oxalic 

acid, 99.6% w/w a.i.). The EP, a miticide, is proposed for use in the control ofvarroa mites on honey 

bees. 

According to the U.S. EPA, oxalic acid is commonly used as an analytical reagent, in textile finishing, in 

metal, wood, or equipment cleaning, in bleaching straw and leather, in removing paint, varnish, rust, or 

ink stains, in dye manufacturing, in chemical synthesis, in the paper, ceramics, photographic, and rubber 

industries, in vitro as a blood specimen anticoagulant in veterinary medicine, etc. 

Oxalic Acid Dihydrate and Oxalic Acid Varroa Mite Control Product (oxalic acid, 99.88% w/w a.i.) were 

originally submitted for registration in 2005 as submissions 2005-0026 & 2005-0027 but were withdrawn 

by the applicant in 2006. An interim decision was made by the SMC and a letter notifying the Canadian 

Honey Council (Aucoin to Clay, October 5, 2005) that permission to use oxalic acid as an unregistered 

miticide in bee colonies would be granted if conditions and precautions determined by the PMRA were 

observed and followed. According to the Canadian Honey Council, concerns were raised by their 

members regarding the legality of using an unregistered pest control product in the colonies. The 

Canadian Honey Council has since reapproached the PMRA for full registration of the TGAI and 

associated EP. 

Oxalic acid is not registered with the PMRA as a technical grade active ingredient but is present in a 

number of registered EPs as a formulant (list 3) since 2002. There are currently no active registrants using 

oxalic acid as active pesticide ingredient registered with the U.S. EPA. The only active submissions 

within the PMRA, involving oxalic acid as the TGAI, are those submitted by the Canadian Honey 

Council (2008-4596 & 2008-4584). 

Review: 

Technical Grade Active Ingredient 

Acute Toxicity 

Oxalic Acid Dihydrate has an oral LDso of 375 mg/kg bw in female rats, and a dennal LDso > 20,000 

mg/kg bw in female rabbits. The inhalation LCso was not included in the available literature, but the 

chemical nature of oxalic acid is such that one would expect irritation and mucosal bums to result from 

oxalic acid dust and/or fumes. The TGAI is classified as highly acutely toxic via the oral route and a low 

acute toxicity classification via the dennal route. 

According to available literature, oxalic acid dihydrate is moderately irritating when applied to the skin 

and severely irritating to the eyes. The pH of oxalic acid dihydrate is 1.3, which suggests a corrosive 

compound. In light of the fact that detailed studies were not submitted by the applicant, classification of 

oxalic acid dihydrate with the skin or the eye will default to corrosive. 

Although there was a lack of information with respect to oxalic acid's potential as a dermal sensitizer, the 

long history of use in a variety of processes and products, coupled with a general lack of medical reports 

regarding sensitization potential of oxalic acid, suggests that the TGAI is not a dennal sensitizer. 

Page 7 of20 
T able 1. Acute toxicity information for oxalic acid dihydrate (99.6% w/w a.i.). I 

ACUTE STUDIES I 

Oral (gavage) Rat - Sprague-Dawley LDso ) 375 mg/kg bw A NOAEL could not 

(5/sex) LDso (0') 475 mg/kg bw be determined from 

the available 

information. 

Highly acutely toxic. 

The principal display 

panel should include 

(Based on the LDso ) the statement 

375 mg/kg bw) DANGER POISON. 

Fatal or Poisonous if 

swallowed should be 

included on the _ 

secondary display 

panel. 

Dermal Rabbit- New Zealand LDso ) > 20,000 mglkg A NOAEL could not 

white bw be determined from 

(3 females) the available 

information. 

Dose administered as a 5 Low acute toxicity. 

% aqueous solution. 

Inhalation Information regarding acute inhalation was not available for evaluation. It is 

expected, however, that, due to the caustic nature of oxalic acid, inhaling dusts 

or fumes should be avoided. 

There are NIOSH and ACGIH adopted TLVs of I mg/m3 (TWA) and 2 mg/m3 

(STEL).a 

The statements Avoid inhaling/breathing dust or fumes and NIOSH 

approved mask should be worn should be included on the secondary display 

panel. 

Eye Irritation Rabbit Extreme Irritation when In another study, 

unrinsed after 24 hours. corneal injury was 

Dose: 250 flg of oxalic 

resolved within 6 days 

(30 second exposure acid for 24 hours. Severly irritating. to a 5 %solution). 

Since the pH of oxalic 

acid dihydrate is 1.3, 

eye .irritation will be 

categorized as 

Page 8 of 20 
corrosive. 

The principal display 

panel should include 

the statement 

DANGERCORROSIVE TO 

EYES. The secondary 

display panel should 

include 

CORROSIVE to the 

eye and DO NOT get 

in eyes. 

Dermal Rabbit Moderately Irritating. The principal display Irritation 

panel should include 

Dose: 500 mg of oxalic 

the statement 

DANGER- SKIN acid for 24 hours. IRRITANT. The 

secondary display 

panel should include 

Corrosive to skin and 

DO NOT get on skin. 

Dermal Although there appears to be no available information regarding dermal 

Sensitization sensitization, the long history of use suggests that oxalic acid is not a potential 

sensitizer. 

a- TLY - Threshold Ltmtt Value; TWA - Ttme Weighted Average; STEL- Short-Term Exposure 

Limit; NJOSH - National Institute for Occupational Safety and Health; ACGIH - American Conference 

ofGovernment Industrial Hygienists. 

Short-term Toxicity 

Young adult Long-Evans rats were administered oxalic acid in the diet at 0, 2.5, and 5.0% (estimated to 

be 0, I .98, and 5.3 g/kg bw/day in females; 0, 1.78, and 5.3 g/kg bw/day in males) for 70 days. 

There was an statistically significant decrease in term body weight in both the 2.5 and 5.0% dose groups 

(p<O.OO I in males and females. The mortality rate for the 5.0% dose group was 25 %, whereas the 

mortality rate for the 2.5 %group was< I 0 %. There were no clinical effects apparent in the 2.5% dose 

group, but pronounced effects were noted in the 5.0% dose group, i.e. , emaciated, stunted, gaunt with 

arched backs. 

Gross pathology results demonstrated a lack of body fat and a minimal amount of adipose tissue adherent 

to visceral and endocrine tissue, as well as kidneys which were discoloured, brownish with roughened 

crinulated surfaces, abnormal notching on the edges and small stones. All pathology findings were 

observed in male and female rats at 5.0% oxalic acid. The majority of these findings are consistent with 

emancipated animals, resulting from a significant loss of body weight in the test animals and not 

necessarily due to the direct effects of oxalic acid. The kidney pathology may have been due to exposure 

Page 9 of20 
from oxalic acid, but insufficient data was available in the literature to verify these findings. 

Additional short-term toxicity information was not available. It is expected that, due to the long history of 

use in a number of manufacturing processes and goods, exposure to oxalic acid is unlikely to resu lt in 

short-term toxicological effects. 

Prenatal Developmental Toxicity 

Information with respect to prenatal developmental toxicity was not available. It is expected that, due to 

the long history of use in a number of manufacturing processes and goods, exposure to oxalic acid is 

unlikely to result in prenatal developmental toxicological effects. 

Mutagenicity and Genotoxicity 

Anhydrous oxalic acid (99 % ), in water as a solvent, was tested for bacterial mutagenicity using the 

AMES assay, i.e., Salmonella typhimurium strains TA1535, TA1537, TA98, and TA I OQ. The doses tested 

were 0.0- 6666.7 <t>g/plate, with and without metabolic activation, i.e., rat and hamster liver S-9, Aroclor 

1254 induced. Positive controls were also tested concurrently. The positive control chemical 2-

aminoanthracene was tested on all strains in the presence of rat and hamster S-9. 4-Nitro-ophenylenediamine was tested on TA98 without S-9, 9-aminoacridine was tested on TA1537 without S-9, 

and sodium azide was tested on T A I 00 and T A !53 5 without S-9. The number of revertants was used as 

the endpoint and a positive result was determined to be a result of at least 2x the background count. 

All other genotoxicity results were negative, with or without metabolic activation. 

Additional information with respect to mutagenicity and genotoxicity was not available. It is expected 

that, due to the long history of use in a number of manufacturing processes and goods, exposure to oxalic 

acid is unlikely to result in mutagenic and/or genotoxic effects. 

End Use Product 

Acute Toxicity 

The end use product is the same as the technical grade active ingredient, therefore, the acute toxicity of 

the EP will be identical to the TGAI. 

The reader is referred to the acute toxicity section of the technical grade active ingredient of this 

evaluation report. 

Label Recommendations: 

Technical Grade Active Ingredient 

Principal Display panel 

Remove the following statements and pictographs: 

OXALIC ACID 

Page 10 of20 
Varroa Mite Control Product 

Agricultura~ 

KEEP OUT OF REACH OF CIDLDREN 

® 

POISON CORROSIVE 

Add the following statements and pictograph: 

OXALIC ACID DIHYDRATE 

FOR MANUFACTURING, FORMULATING OR REPACKAGING 

DANGER - POISON 

DANGER- CORROSIVE TO EYES 

DANGER - SKIN IRRITANT 

Secondary Display Panel 

Remove the following statements and pictographs from the beginning of the secondary display panel: 

Page 11 of20 
OXALIC ACID 

,t.N':'I.'·/,<RRO!. MiTE F'RO;:•UCI 

. .\GR CUL TU~L 

O:•A!.I:: ,:.,;:li) CHY:R.:.. TE ~~ Q;b 

RS:31STRATI·::rl'·,:) PEST CO'IiROL F'RC·::UCTS ACT 

KEEP OUT OF REACH OF CHILDREN 

@@ 

POISON CORROSIVE ~/IGffi. 

to.t:~UTfLI Cf ra-".1 r r9Hif0 :J r.llit': 

•::r:tk!- to -!yts ar·::J ;, r ~· lt't-:t ·XtY.Xl 

Remove the following statements from the PRECAUTIONS section: 

Wear a full mask (or a half mask and goggles) fitted with organic acid filter and chemical 

resistant gloves when applying oxalic acid. 

Keep away from food, drink and bee feeds. 

Add the following statements to the PRECAUTIONS section: 

PREVENT ACCESS BY UNAUTHORIZED PERSONNEL. 

Fatal or Poisonous if swallowed. 

Avoid inhaling/breathing dust or fumes. 

CORROSIVE to the eyes. 

DO NOT get in eyes. 

Corrosive to skin. 

DO NOT get on skin or clothing. 

Remove the following statements from the FIRST AID section: 

Always carry large amount of clean water to wash skin and eyes immediately if contact with 

Oxalic Acid Dihydrate occurs. 

SKIN: Remove contaminated clothing immediately. Wash affected area with soap or mild 

detergent and large amounts of water. If chemical burn develops, cover area with a sterile, 

dry dressing and bandage securely. Contact a physician immediately. 

EYES: Wash eyes immediately with large amounts of water. Cover with sterile bandages. 

Contact a physician immediately. 

INGESTED. Do not induce vomiting. Drink large quantities of water or milk. If vomiting 

occurs, administer fluids repeatedly. Never give anything by mouth to an unconscious 

person. Contact a physician or Poison Control Center immediately. 

Page 12 of20 
INHALED. Remove victim to a safe, uncontaminated area. Rest. Keep warm. If breathing 

is shallow, gjve oxygen. Get immediate medical attention. 

Add the following statements to the FIRST AID section: 

If swallowed Call a poison control centre or doctor immediately for 

treatment advice. Have person sip a glass of water if able 

to swallow. Do not induce vomiting unless told to do so 

by a poison control centre or doctor. Do not give 

anything by mouth to an unconscious person. 

If on skin or clothing Take off contaminated clothing. Rinse skin immediately 

with plenty of water for 15-20 minutes. Call a poison 

control centre or doctor for treatment advice. 

If inhaled Move person to fresh air. If person is not breathing, call 

911 or an ambulance, then give artificial respiration, 

preferably by mouth-to-mouth, if possible. Call a poison 

control centre or doctor for further treatment advice. 

If in eyes Hold eye open and rinse slowly and gently with water for 

15-20 minutes. Remove contact lenses, if present, after 

the first 5 minutes, then continue rinsing eye. Call a 

poison control centre or doctor for treatment advice. 

Take container, label or product name and Pest Control Product Registration 

Number with you when seeking medical attention. 

Add the following section and associated statement to the secondary display panel: 

TOXICOLOGICAL INFORMATION. 

Treat symptomatically. 

End Use Product 

Principal Display Panel 

Remove the following statements and pictographs: 

OXALIC ACID 

POISON CORROSIVE 

Page 13 of20 
Add the following statements and pictograph: 

OXALIC ACID DIHYDRATE 

~ 

DANGER-

~ POISON 

DANGER- CORROSIVE TO EYES 

DANGER- SKIN IRRITANT 

Secondary Display Panel 

Remove the following statements and pictographs from the beginning of the secondary display panel: 

OXA.LIC ACID 

ANi'I-'·:.:.RROA MJTE PRODUC'i 

.!>GRiCUL TUR.o<L 

GI.-. .=.RANTE: 

P.:31STRATI:JN 1·.0 

O> :..~ :: ;..::10 Cl-fY!:R:O.TE ~G ce;;, 

PES- C•)'·ITP.OL ?RC::UCTS ACT 

KEEP OUT OF REACH OF CHILDREN 

@@ 

POISON CORROSIVE O~IIGER. 

2~~~~·~c.~a;~!~ ~7a ~~ i~;~~, x• 

Add the following statements to the PRECAUTIONS section: 

Fatal or Poisonous if swallowed. 

Avoid inhaling/breathing dust or fumes. 

CORROSIVE to the eyes. 

DO NOT get in eyes. 

Corrosive to skin. 

DO NOT get on skin or clothing. 

Remove the following statements from the FIRST AID section: 

Page 14 of20 
Always carry large amount of clean water to wash skin and eyes immediately if contact with 

Oxalic Acid Dihydrate occurs. 

SKIN: Remove contaminated clothing immediately. Wash affected area with soap or m·ild 

detergent and large amounts of water. If chemical burn develops, cover area with a sterile, 

dry dressing and bandage securely. Contact a physician immediately. 

EYES: Wash eyes immediately with large amounts of water. Cover with sterile bandages. 

Contact a physician immediately. 

INGESTED. Do not induce vomiting. Drink large quantities of water or milk. If vomiting 

occurs, administer fluids repeatedly. Never give anything by mouth to an unconscious 

person. Contact a physician or Poison Control Center immediately. 

INHALED. Remove victim to a safe, uncontaminated area. Rest. Keep warm. If breathing 

is shallow, give oxygen. Get immediate medical attention. 

Add the following statements to the FIRST AID section: 

If swallowed Call a poison control centre or doctor immediately for 

treatment advice. Have person sip a glass of water if able 

to swallow. Do not induce vomiting unless told to do so 

by a poison control centre or doctor. Do not give 

anything by mouth to an unconscious person. 

If on skin or clothing Take off contaminated clothing. Rinse skin immediately 

with plenty of water for 15-20 minutes. Call a poison 

control centre or doctor for treatment advice. 

If inhaled Move person to fresh air. If person is not breathing, call 

911 or an ambulance, then give artificial respiration, 

preferably by mouth-to-mouth, if possible. Call a poison 

control centre or doctor for further treatment advice. 

If in eyes Hold eye open and rinse slowly and gently with water for 

15-20 minutes. Remove contact lenses, if present, after 

the first 5 minutes, then continue rinsing eye. Call a 

poison control centre or doctor for treatment advice. 

Take container, label or product name and Pest Control Product Registration 

Number with you when seeking medical attention. 

Add the fo llowing section and associated statement to the secondary display panel: 

TOXICOLOGICAL INFORMATION: 

Treat symptomatically. 

Formulant Toxicology: There were no formulants of toxicological concern. See Appendix l . 

Page 15 of 20 
TGAI: (HED3) Toxicology Level D Passed. 

EP: (HED3) Toxicology Level D Passed. 

Page 16 of20 
Reviewed by: 

Date: --~----------~----------- -------------- Kevin Arnold 

Senior Evaluation Officer, Microbial and Biochemical Evaluation Section 

Health Evaluation Directorate, PMRA 

Peer Reviewed by: 

___________________________ Date: _____________ _ 

Sathish Achuthan 

Evaluation Officer, Microbial and Biochemical Evaluation Section 

Health Evaluation Directorate, PMRA 

Approved by: 

________________________ .Date: _____________ _ 

Brian Belliveau, Ph.D. 

Head, Microbial and Biochemical Evaluation Section 

Hea lth Evaluation Directorate, PMRA 

Page 17 of20 
REFERENCES 

966154 CHEMINFO : Oxalic Acid. 

www.intox.or<J./databank/documents/chemical/oxalicac/cie358.htm 

Retrieved: August 27, 2004. 13pp. Published, DACO: 2.14.1,2.14.2,2.14.3,2.14.4, 

2.14.5,2.14.6,2.14.7,2.14.8,2.14.9,2.3.1 ,2.4,2.5,2.6,2.7,2.8,4.1 ,4.2.1 ,4.2.4,4.2.6,4.4.2, 

966156 Hazardous Substances Databank: Oxalic Acid. www.ccohs.ca. Retrieved June 28,2004. 

23pp. Published, DACO: 2.14.10,2.14.11,2.14.13,2.14.14,2.3.1,4.4.1 CBI 

966159 Reregistration Eligibility Document. 

http://www.epa.gov/oppsrrd 1/REDs/old _reds/oxalic _acid. pdf Retrieved June 28, 2004. 

Environmental Protection Agency, United States of America. 58pp Published., DACO: 

12.5.4,4.2.1,4.2.3,4.3 .2,4.3.5,4.4.1,4.5.1,4.5.2,4.5. 

966163 Material Safety Data Sheet. Univar Canada Tech Data, Dept. Richmond BC, Canada. 6pp., 

DACO: 0.9,4.1 

966164 Material Safety Data Sheet. Univar Canada Tech Data, Dept. Richmond BC, Canada. 6pp., 

DACO: 0.9 

966165 Oxalic acid residues in honey. Melliferae.V,lmkerei Fischermiihle, 72348 Rosenfeld, 

Germany. 2pp. Published, DACO: 4.1,7.4 

966166 Determination of residues in honey after treatments with formic and oxalic acid under field 

conditions. Apidologie 33:399-409. Published, DACO: 4.1,7.4 

966167 Health-based Reassessment of Administrative Occupational Exposure Limits: Oxalic Acid. 

The Hague, Health Council of the Netherlands, Netherlands. 18pp. Published, DACO: 

4.1,4.2.1,4.2.3,4.2.5,4.3.1,4.3.5,4.4.1,4.5.1,4.5.6 

966168 Oxalic Acid Content of Selected Vegetables. In Agricultural Handbook No 8-11: Vegetables 

and Vegetable Products. USDA, United States of America. 2pp. Published, DACO: 

4.4.2,4.4.3 

1669578 2008, Draft Label, DACO: 1.1.1 

1810554 2004 TLV s and BE Is -Threshold Limit Values for Chemical Substances and Physical Agents 

& Biological Exposure Indices, DACO: 4.8 

1810556 2003, Committee for Veterinary Medicinal Products - Oxalic Acid Summary Report, DACO: 

4.8 

1810564 M. Grant, 1962, Toxicology ofthe Eye, DACO: 4.8 

1810573 G. Hathaway et. al., 1966, Chemical Hazards ofthe Workplace, DACO: 4.8 

1810577 M. Goldman et. at., 1977, Effect of Dietary Ingestion of Oxalic Acid on Growth and 

Reproduction in Male and Female Long-Evans Rats, DACO: 4.3 .1 

181 05 81 E.H. Vernot et. at., 1977, Acute Toxicity and Skin Corrosion Data for Some Organic and 

Inorganic Compounds and Aqueous Solutions, DACO: 4.8 

1810584 G. Clayton, 1982, Patty's Industrial Hygiene and Toxicology, DACO: 4.8 

Page 18 of20 
REFERENCES - CBI 

1767370 DACO: 0.1 .6003 

Page 19 of20 
A .ppendix 1: Pro d uct s >pect 'fi tcattOns 

Purpose Acaricide 

Formulation Oxalic Acid Dihydrate Varroa Mite Control Product 

Name 

Technical Active Oxalic Acid Dihydrate (99.6 %) 

(%) 

PCP I Appl. No. 2008-4584 

Use Pattern USC# 8 - Livestock For Food 

Formulant Evaluation 

Formulant Ingredient CAS# 

None. N/A 

PMRA List: 

Purpose in 

Formulation 

N/A 

Percent 

by 

Weight 

N/A 

I 

! 

I 

PMRA 

Formulant 

List 

N/A 

List 1: Contains formulants identified as being of significant concern with respect to their potential 

adverse effects on health and the environment, meeting defined criteria for carcinogenicity, neurotoxicity, 

chronic effects, adverse reproductive effects, ecological effects, Track I substances as defined under the 

Toxic Substances Management Policy (TSMP) and substances designated under 

the Montreal Protocol. 

List 2: Contains formulants that are considered potentially toxic, based on either structural similarity to 

List l formulants or data suggestive of toxicity. · 

List 3: Contains formulants that do not meet the criteria of any of the other lists. 

List 4A: Contains formulants that appear on the USEPA Minimum Risk lnerts List, which are generally 

regarded to be of minimal toxicological concern, as well as substances commonly consumed as foods. 

List 4B: Includes formulants, some of which may be toxic, but for which there are sufficient data to 

reasonably conclude that the specific use pattern of the pest control product [as on specific use pattern 

listed in the United States Code of Federal Regulations, 40 CPR Protection of Environment, Subpart D 

180.000(c)(d)(e)] will not adversely affect public health and the environment. 

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