UNITED STA TES ENV IRONMENTA L PR O T ECTfON AGEN C Y



### MEMORANDUM DATE: Decem b er 10,2014 WA S HINGTON , DC 104 60
O FFI CE OF CH E MICAL SA FETY AND POLLUT I ON PREVENTION



### SUBJECT: Oxa l ic Acid. New Use in Bee Hives to contro l Varroa mites. D424360



### PC Code: 00960 I 

### Decis ion No.: 4973 9 8 

### P etition No.: NA 

### Ris k 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: Mic haelS. Metzge r , Chief

# ~'**/)~7** () R i sk Assessme n t B ranch VII 

# M"j 

# % H ea l th Effec ts Division (7509 P ) 

### TO: Me re d i th Laws, C hi ef 

### f nvertebrate- Verteb r ate B ranch 3 Registration Div i s ion (750 5P)
The U.S. Department of Agriculture ha s requested a new use of oxalic ac id dihydrate (91266-R, oxalic acid di hydrate 100 % w/w a . i .) to control Varroa mite s in honey bee h ives. A Rereg is tra tion E li g ibili ty Dec i s io n (RE D ) doc u me nt for Oxa li c ac id was .i ssued in 1 992. As part of a work s hare with the U.S. EPA, Canada 's Pest Management Regulatory Agen cy (PMRA) co m pleted an updated review of the tox icity da t a for oxalic acid , a dietary assessment, a n d an occ upat io n al assess me n t for the proposed use (B r ian Be lliv eau , Ph .D
. , Hea d , M icro b ial an d Biochemical**Eva~uation** Section, 10/26/ 2009). RED concur s with the conclusions drawn by PMRA and re iterates the m , in part , below. O xalic acid is u biq u ito u s in the e n vi ron me nt bei ng foun d n atura ll y in m any pl an ts and vegetable s, as well as in hone y . D ietary exposu re from the proposed use will be insi g nificant and indisti n guishable from backgrou nd levels of oxal ic acid ; the use s ho ul d be con s idered a food use without the requ i rement of a tolerance. Labe l ed pe rsonal protective eq u ipment (PPE) is s u ffic ient to re d uce worke r ex pos ures to in s ig n ifican t leve ls pres e nt ing no ri sk concern. Therefo re, RED has no · objecti o n to granting this regi stration. 

### Page 1 of20Toxicity: 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 di sso lve 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 b ox. 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), thi s application metho ds may cause some bee mortality or overwintering bee lo ss . VAPORIZER METHOD: Apply only t o 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 manu facturer's directions for use. Insert t he vaporizer apparatus through the bottom entrance. A p ply heat until all Oxalic Acid has sublimated. Dietary an d A22re2ate Exposure: The following summary i s 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 vary in g 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 th at 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 natu rally occurring in h oney) on ingestion, re s ulting in a compound which is poorly absorbed by t he 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 abso rbed through the Gl tract. Di s tin guish ing between e ndog e n ou s and anthropogenic sou rces of oxalic acid and e nfo rcing an MRL 

### [pesticide tolerance in th e case of the US. registration] is not pos s ible. As such, promulgation of an MRL 

### [p esticide tolerance in the case of the US. registration] will not be nec e ss ary ." HED con cu rs with thi s assess men t. Since low level residu es in honey are po ss ibl e as a resul t o f this use but are indis tinguis h able from endogenous sources, the u se shou ld be considered a food use , but a tolerance should not be required
. Si nce oxalic acid is ubiquitous in the environment and exposures from use in hon ey 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 Ex posure: The following label restrictions are included in the oxal ic acid labe l (EPA Reg. No. 9 I 266-R)

" Hazard avoidance: Do not breathe dust or fumes. D o not get in eyes, on sk in, or on clothing. Wear protective clothing, eyewear, and respiratory protection as listed under " Persona l Protective Equipment.." Wash thoroug hl y with soap and water after handling and before eating, drinking , chewing gum , using tobacco or using the toilet. Remove and wash contami nated clothing before reuse . PERSONAL PROTECTIVE EQUIPMENT: Handlers and Applicators who apply product by the Solution Method mu st wear: Long-sleeved sh irt 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 Meth od mu st wear: L o ng-sleeved sh irt 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 s uch instru ctions are provided for washables , use detergent and hot water. Keep and wash PPE separately from other laundry. Wash hands before eating, drinking, chewi ng gum, using tobacco, or u s i ng the toilet. 

### Page 3 of20

### Remove clothing immediately ifpesticide gets inside. Then wash thor o ughl y and put on clean clothing. Remove PPE immediat e ly after handling this product. As soon as possible, wash thoroughl y and change into clean clothing." HED recommends that the label additionally specify that the r es pirator used when applying this product be used with an acid gas cartridge and a particula te filter. HED has not se lected endpoints related to us e 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 restricti o ns will reduc e worker exposures to oxalic ac id to an insignificant level, unlikely to result i n risks of concern.

Page 4 of20

### Attachment: Toxicity Review from Canada ' s Pest Management Re gu latory Agency

Page 

### 5 of20

# • • Health Canada Pest Man agement Regulatory Agen cy Sante Canad a Agence de reg l eme ntation d e lalutte a ntiparas itaire 2720 promenade Rivers ide Dri ve Ottaw a , On tario KIAOK9 Te lephone/Telephone: (613)736-3518 Fax!Telecopieur: (6 13)73 6-3505
October 2 6 , 2009



### M emorandum To/N ote adressee 

# a: Bri an Belliveau , Ph
.D. H ead , Microbial and Biochemical Eva l uation Section Health Eva luation Directorate , PMRA 

### F rom/De : Kevin Arnold Senior Eval uati o n Officer, M icrob ial a nd Bioc hemical Evaluat ion Sectio n Hea l th Evalu a tion Direc to rat e , PMRA 

### S ubject/Ob j et: Sub. No(s): Product Name :
Active I ngredient: Applicant: I) 2008-4596 2) 200 8 -4584 I) Oxalic Ac id Dih y drate 2) Oxalic Acid Varroa Mite Contro l Product Oxa li c acid (OXL) 

### I acaricide Canadian Ho ney Counci l ( HCA) 

### ACTION REQUES TE D : Level D, Category A.l. l Submission Rev iew (HED3) Toxicology



### Page 6 o f20Submission Information: The Canadian H oney Co uncil ha s 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 -u s e product 

### (EP), Oxalic Acid 

### Varroa Mite Contro l Product (oxali c acid , 

### 99.6% w/w a.i.). Th e EP, a miticide , is proposed for use in the control ofvarroa mites on h oney bees. According to the U .S. EPA , oxalic acid i s commonly used as an analytical reagent, in textile finishing , in metal, wood, or equipment c lean ing, in bleaching s traw and leather, in rem ov ing pain t , varn ish, ru st, or ink stain s, in dye manufacturing, in chemical synthes is, in the pap er, ceramics, photographic, and rubber industrie s, in vitro as a blood specimen anticoagulant in veterinary medicine, etc. Oxalic Acid Dihydrate and Oxalic Acid Varroa Mite Control Product (oxa lic acid , 

### 99.88% w/w a.i.) were originally su bmitted for registration in 

### 2005 as submiss ions 

### 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 Canad ian H oney Council (Aucoin to C lay , October 

### 5, 2005) that permission to use oxa li c acid as an unregistered m iticide in bee colonies would be granted if conditions and pre cautions dete rmined by the PMRA were observed and foll o wed. According to the Canadian Honey Council, concerns were raised by their members regarding the l ega lity of using an unregi stered pest control product in the colonies. The Canadian Honey Cou ncil has since reappr oac hed the PMRA for full regi stration of the TGAI and associated EP. Oxalic acid is not reg istered with the PMRA as a tech nical grade active ingredient but is present in a number of registered EPs as a formulant (list 

### 3) s in ce 

### 2002. There are currently no active registrants usin g oxalic acid as active pesticide ingre dient reg istered with the U.S. EPA. T he 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 Ac tive Ingredient Acute T oxicity Oxalic Acid Dihydrate ha s an oral LDso of 

### 375 m g/kg bw in female rats, and a dennal LD so > 

### 20,000 mg/kg bw in female rabbits. The inhalation LCso was not included in the available literature , but the chemical nature of oxal ic acid is such that one would expect irritation and mucosal bums to result from oxalic acid dust and/or fum es. The TGAI i s classified as hi g hly acutely toxic via th e oral route and a low acute toxicity clas sific ation via the dennal route. According to available literature, oxa lic acid dihydrate is moderately irritating when applied to the s kin and severely irritating to the eyes. The pH of oxalic acid dihydrate is 1.3, which suggests a corrosive compound. In light of th e fact that detailed studies were not s ubmitted by the applicant, c lass ificati on of oxalic acid dihydrate with the skin or the eye will default to corrosive. Although there was a lack of in formation with respect to oxalic acid 's potential as a dermal se nsiti ze r , the long history of use in a variety of processe s and products , coup l ed with a general lack of medical reports regarding sens itization potential of ox alic acid, suggests that the TGA I is not a dennal sensitizer. Pag e 

### 7 of20T able 1. Acute t oxicity information for oxalic aci d dihydrate (99.6% w/w a.i.). 

## I ACUTE STUDIES 

## I O ral ( gavage) Rat

- S pragu e- Dawl ey LD so**)** 375 m g/kg bw A NOAEL 

### co u l d not (5/sex) LDs o 

### (0' ) 475 mg/kg bw be determ ined from the ava ilable inf orm ation. Highly acutely tox ic. The principal disp lay pan e l should inc lude (Based on th e LDso**)** the sta t e m ent 375 mg/kg bw) DANGER POISO N . Fata l or Poisono us if swallowed sho u l d be incl ud ed o n the
_ secondary d isplay panel. D ermal Rabbit- New Zealand LD s o**)** > 20,000 mglkg A N OAEL co u ld not white bw be de t erm ined from (3 females) the avai lable inf ormatio n. D ose administered as a 5 Low acute toxicity. % aq u eous so l ution. Inha lation Information rega rdin g acute inh alation was not avail ab l e for evaluation
. It is expected, however, that , due to the caust ic nature o f oxalic acid, in halin g d u sts or fumes should be avoi de d
. T here a r e N IOS H a nd ACGIH adopted TLVs of I mg/m 3 (TWA) and 2 mg/m 3 (STEL).a The s ta te ments Av oid inhaling/breathing d ust or fumes and N I OSH app roved m ask should be worn should be includ e d on the secondary di splay panel. Eye Irritation Rabbit Extr e m e Irritatio n when 

### In another study, u nrins ed after 24 h o ur s. corneal in ju r y was D ose: 250 flg of oxa li c reso l ved wi th in 6 days (30 second ex pos ure acid for 24 h ours. S e ve rly irritating. to a 5 %solution). Since the p H of oxal ic aci d dihyd rate i s 

### 1.3, eye .irri tati on will be catego rize d as Page 8 

### o f 20corros ive. The principal display pan e l s hould include the statement

### DANGERCORROSIVE TO EYES. The secondary display panel should inclu de 

### CORROSIVE to the eye and 

### DO NOT get in eyes. Dermal Rabbit 

### Moderately Irritating
. The pr incipal display Irritatio n pan e l s ho uld include Dose: 500 mg of oxalic the statement 

### DANGER- SKIN acid for 24 hours. 

### IRRITANT. The secondary display panel should includ e 

### Corrosive to skin and 

### DO NOT get on skin. Dermal Although there appears to be n o available information regarding d ermal Se n s itization se nsitizatio n , the long history of us e sugges ts that oxalic acid is not a potential sensitizer.
a- TLY

- Threshold L tmtt Value; TWA

- Ttme Weighted Average; STEL- Short-Term Exposure Limit; N JOSH

- Nationa l In stitute for Occupational Safety and Health; ACGIH

- America n Conference ofGovernment Indu s tr ial Hy gie ni sts. 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 s tati stically 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< I0 %. There were no clinical effects apparent in the 2.5% dose group , but pronounced effects were noted in the 5.0% dose gro up , 

### i.e. , emaciated , stun ted, gaunt with arched backs. Gross patholog y res ults demon s trated a lack of body fat and a minimal amount of adip ose tissue adherent to visceral and endocrine tissue , as well as kidneys which were discoloured, brownish with roughen ed crinulated surface s, abnormal notching on the edges and sma ll s tones . All pathology findings were observed in male and fema le rat s at 5.0% oxa li c acid. The majority of th ese findings are consistent with emancipate d animals, resultin g fro m a significant loss of bod y weight in th e test animal s and not nece ssa rily due to the direct effects of oxalic acid. The kidney pathology may have been due to expos ure 

### Page 9 of20from oxalic acid, but insufficient data was avai lab l e in the literature to verify these findings
. Additiona l 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 toxico logical effects
. Prenatal Developmental Toxic ity 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 oxal ic acid is unlikely to resu l t in prenatal developmental toxicological effects. Mutagenicity and Genotoxicity Anhydrous oxalic acid (99 

### %), in water as a solvent, was tes ted for bacterial mutag en icity using the AMES assay, i.e., Salmonella typhimurium strains TA 1535, TA153 7, TA98 , and TA 

### I OQ. The doses tested were 0 .0- 6666.7 <t>g/p late, with and without metabolic activation, 

### i.e ., rat and hamster liver S-9, Aroclor 1254 induced. Posi tive contro l s were also tested concurrently. The positive control chemical 2- aminoanthracene was tested on all strains in the presence of rat a nd hamster S-9. 4-Nitro-ophenylenediamine was tested on TA98 without S-9, 9-am i noacridine was tested on TA1537 without S-9, and sodiu m azide was te sted on T A 

### I00 and 

### TA !53 5 without S-9
. The number of revertants was used as the endpoint and a posit ive result was determined to be a result of at least 2x the background count. All other genotoxicity results were negative, with or without metabol ic activation. Additional informat ion with respect to mutagenicity and genotoxicity was not available. It is expected that, due to the lo n g history of use in a number of manufacturing processes and goods, exposure to oxalic acid is unlikely to re sult in mutagenic and/or genotoxic effects. End Use Product Acute Toxicity The end use product is the same as the techn ical grade active ingredient, therefore, the acute toxici ty of the EP will be identical to the TGAI. The reader is referr e d to the acute toxicity section of the technical grade active ingredient of this evaluation report . 

### Labe l Recommendations: Techni cal Grade Active Ingredient Principal Display panel Remove the following s tatements and pictographs: 

### OXAL IC ACID Page 

### 10 of20

### Varroa Mite Control Product**Agr icultura~**  

### KEEP OUT OF REACH OF CIDLDREN 

# ®

P OISO N CORROSIVE
Add the follow ing sta t ements and pictograph : 

### OXALIC ACID DIHYDRATE FOR MANUFACTURING, FORMULATING OR REPACKAGING

DANGER

- POISON DANGER- CORROSIVE TO EYES DANGER

- SKIN IRRITANT Secondary Display Panel Rem ove the following s t atem ents an d pictog r aphs fr om the beg inning of the secondary di sp la y pane l :



### Page 11 of20OXALI C ACID ,t.N':'I.'· /,<RRO!. M i TE F'RO;:•UC I

.**.\GR CUL** **TU~L** O :

•A!. I:: ,:., ;: li) CHY :R .:.. TE**~~** Q;b RS:31STRAT I · ::rl'·,:) PES T CO'IiRO L F'RC · ::UCTS ACT KEEP OUT OF REACH OF CHILDREN 

# @@

POISON CORROSIVE**~/IGffi. to.t:~UTfL** **I** 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 gogg les) fitted with organic acid filter and chemical resistant gloves when applying oxalic acid. Keep away from food, drink and b ee feeds. Add the following statements to t he PRECAUTIONS section: PREVENT ACCESS BY UNAUTHORIZED PERSONNEL. Fatal or Poisonous if swallowed
. Avoid inhaling/breathing dust or fumes. CORROSIVE to the eyes . DO NO T 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 o r mild detergent and large amounts of water. If 

### chemical burn develops, cover area with a sterile, dry dressing and bandage secure ly
. 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 immedia tely
. 

### Page 12 of20

### INHALED. Re mo ve victim to a safe, uncontaminated area. Res t. Keep warm . If 

### breathing is shallow, gjve oxygen . Get immediate medical attention. Add th e following statements to the 

### FIRST AID section: If 

### swallowed Call a poison control centre or doctor immediately for treatment adv ice. Have person s ip a glass of water if able to swa llow. Do not in duce vom iti ng unless told to do so by a poison control centre or doctor. D o not give anything by mouth to an unconscious person. If on skin or clothing Take off contaminated clothing. Rinse skin immediately wit h plen ty of water for 15-20 minutes. Call a po ison control centre or doctor for treatment adv ice. If 

### inhaled Move person to fresh air. If 

### person is not breathing, call 911 or an ambu lance, then g ive artificial respiration, preferab ly by mouth-to-mouth , if possibl e . Call a poison control centre or doctor for further treatment a dvice
. If 

### in eyes Hold eye open and r i nse slowly and gently with water for 15-20 minutes. Remove con tact lenses, if present, after the first 5 

### minutes, then continue rinsing eye. Call a poison control centre or docto r for treatment adv ice. Take container, label or product name and Pest Contro l Product Registration Nu mber w ith you when seeking medical attention. Add th e foll ow i ng section and associate d sta teme nt to the secondary display panel: 

### TOXICOLOGICAL INFORMATION. Treat symptomatically. End Use Product Principal Display Panel 

### Rem ove the following statements a nd pic tographs: 

### OXALIC ACID

POISON CORROSIV E 

### Page 13 of20Add the following statements and pictograph: 

### OXALIC ACID DIHYDRATE

# ~**~** DANGER- POISON DANGER- CORROSIVE TO EYES DANGER- SKIN IRRITANT Secondary Display Panel Remove the follow ing statements and pictographs from the beginning of the secondary display panel:

OXA.LIC ACID ANi'I-'·: .:.RROA M J TE PR ODUC'i

. !>GR i CUL TUR.o<L GI.-

. .=.RANTE: P.:31STRATI:JN 1 ·.0**O> :..~** **::** ;. . ::1 0 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 Po isonous if swallowed. Avoid inh aling/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 Oxa lic Acid Dihydrate occurs . SKI N: Remove contaminated clothing immediately. Wash affected area with soa p 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 steri l e bandages. Con tact 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. Co ntact a phys ician or Poison Control Center immediately. INHALED. Remove victim to a safe, uncontaminated area. Re st. Keep warm. If 

### breathing is shallow, give oxyge n. Get i mmediate medical attention. Add th e foll ow ing statements to the FIRST AID section: If 

### swallowed Call a poison contro l 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 an ything by mouth to an unconscious pers on. If 

### on skin or clothing T ake off contaminated clothing. Rinse skin immediately with plenty of water for 

### 15-20 minutes. Call a po i son control centre or doctor for treatment advice. If 

### inhaled Move person to fresh air. If 

### person is not breathi n g, 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 H old eye open and rinse slow l y and gently with water for 

### 15-20 minutes. Remove cont act lenses, if present, after th e first 

### 5 minutes, then con t inue rinsing eye . Call a poison control cent re or doctor for treatment advice. Take container, label or product name and Pe st Control Produ ct Registration Number with you when seeking medical attention. Add the fo llowing sec tion and associated stateme nt to the seco ndary display panel: TOXICOLOGICAL INF ORMATIO N : T reat symptomatically.
F ormulant Tox icology: Th ere were no formulants of toxicological co ncern. 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 Sen io r Evalu ation Officer, Microbial and Biochemi ca l Evaluation Section Health Eva luati o n Di recto rate, PMRA


### Peer Reviewed by:



### ___________________________ Date: _____________ _ Sathish Ac huthan Evaluat io n Officer, Microbial and Biochemi ca l Evaluati o n Section Health Evaluation Di recto rate, PMRA 

### Approved by:



### ________________________ . Date:

_____________ _ B rian Belliveau , Ph .D. Head, Microbial and Bioc he mical Eva luation Section Hea l th Eval uation Directorate , PMRA



### Page 17 of 20REFERENCES 966154 CHEMINFO : Oxalic Acid. www .in tox .o r<J./d atabank/docum ents/c hemical /oxa li cac/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 CB I 966159 Reregistration Eligibility Document. http://www.epa.gov/oppsrrd 1/REDs/old

_reds/oxalic _ac id
.pdf Retrieved June 28, 2004
. Environmental Protection Agency, Un ited 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 Mater ial Safety Data Sheet. Univar Canada Tech Data, Dept. Richmo nd BC , Canada
. 6pp., DACO: 0.9 966165 Oxalic acid residues in honey. Melliferae.V,lmkerei Fi sc hermiihle, 72348 Rosenfeld , Germany. 2pp. Published, DACO: 4.1,7.4 966166 Determ in ation of residues in honey after t reatments with formic and oxalic acid under fi e ld cond itions
. Apido logie 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 Netherland s, 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 Se lected Vegetables. 

### In Agricultural Handbook No 8-11: Vegetables and Ve get able Products
. USDA, United States of America. 2 pp. Published , DACO: 4.4.2,4.4 .3 1669578 2008, Draft Label, DACO: 1.1.1 1810554 2004 TLVs and BE Is -Thr es hold Limit Values for Chemical Substances an d Physical Agents 

### & Biological Exposure Indices , DACO: 4.8 1810556 2003 , Committee for Veterinary Medicinal Product s - Oxalic Acid Summary Report , DACO: 4.8 1810564 M. Grant, 1962, Toxicology ofthe Eye, DACO: 4.8 1810573 G. Hath away 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 Reproducti on in Male and Fema l e Long-Evans Rats , DACO : 4 .3
. 1 181 05 81 E.H. Vernot et. at., 1977, Acute Tox icity and Skin Corrosion Data for Some Organic and In or ganic Compounds and Aqueous So lutions, DACO: 4.8 1810584 G. Clayto n, 1982, Patty's Industrial Hygiene and Toxicology, DACO: 4.8 

### Page 1 8 of20

### REFERENCES

- CBI 1767370 DACO: 0.1
. 6003



### Page 19 of20A
. ppendix 1 : Pro uct >pect tcattOns d 

# s 'fi Purpose Acaricide Formulation Oxal ic Acid Dihydrate Varroa Mite Control Product Name Technical Acti ve Oxalic Acid Dihydrate (99
.6 %) (%) PCP I Appl
. N o. 2008-4584 U se Pattern USC# 8

- Livestock For Food F o r mu la nt Evaluation Formulant In gredien t CAS#

No ne . N/A PMRA List: Purpose in Formulation N/A Percent 

### by Weight

N/A 

# I ! 

## I

PMRA Formulant List N/A

L ist 1 : Contains formu lants identified as being of s ign ificant concern wi th respect to their potential adverse effects on health and the environment, meeting defined criteria for carcinogenicity, neurotoxicity, chronic effects , adver se reproductive effects, ecological effects, Track I s ubstances as defined und er the Toxic Substance s Management Policy (TSMP) and substances designated under the Montreal Protocol. List 2: Contains f ormulants that are considered potentially toxic, based on either structural similarity to List l formulants or data suggest ive of toxic ity. · List 3: Contains formu lants that do not meet the criteria of any of the other lists
. List 4A : Contain s fo rmulant s that appear on the USEPA Min imum Risk lnerts List , which are generally regarded to be of minimal toxic ological concern, as well as substances commonly consumed as foods. Li st 4B: Include s form u lan ts, 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 o n specific u s e pattern liste d in the United States Code of Fed eral Regu lations, 40 CPR Protection of Enviro nment, Subpart D 180
. 000(c)(d)(e)] will no t adversely affect pu blic health and the environment.



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