Directive 98/8/EC concerning the placing biocidal products on the market Inclusion of active substances in Annex I or IA to Directive 98/8/EC Assessment Reporti Powdered Corn Cob Product-type PT 14 (Rodenticides) September 2012 Annex I / IA – RMS Hellas Powdered Corn Cob Product-type PT 14 September 2012 Powdered Corn cob (PT 14) Assessment report Finalised in the Standing Committee on Biocidal Products at its meeting in view of its inclusion in Annex I or IA to Directive 98/8/EC CONTENTS 1. 2. STATEMENT OF SUBJECT MATTER AND PURPOSE .................................................... 3 1.1. Procedure followed ....................................................................................................... 3 1.2. Purpose of the assessment report .................................................................................. 4 1.3. Overall conclusion in the context of Directive 98/8/EC .............................................. 4 OVERALL SUMMARY AND CONCLUSIONS .................................................................. 6 2.1. 2.2. 3. Presentation of the Active Substance ........................................................................... 6 2.1.1. Identity, Physico-Chemical Properties & Methods of Analysis ................... 6 2.1.2. Intended Uses and Efficacy ........................................................................... 8 2.1.3. Classification and Labelling .......................................................................... 9 Summary of the Risk Assessment ................................................................................ 9 2.2.1. Human Health Risk Assessment.................................................................... 9 2.2.2. . Environmental Risk Assessment ............................................................... 12 DECISION............................................................................................................................. 15 3.1. Background to the Decision........................................................................................ 15 3.2. Elements to be taken into account by Member States when authorising products 17 APPENDIX I: LIST OF ENDPOINTS .......................................................................................... 18 Chapter 1: Identity, Physical and Chemical Properties, Classification and Labelling ............................................................................ 18 Chapter 2: Methods of Analysis .................................................................. 20 Chapter 3: Impact on Human Health ........................................................... 21 Chapter 4: Fate and Behaviour in the Environment .................................... 22 Chapter 5: Effects on Non-target Species .................................................... 24 Chapter 6: Other End Points ........................................................................ 25 APPENDIX II: LIST OF INTENDED USES ................................................................................ 26 TABLE: LIST OF INTENDED USES SUPPORTED BY THE SUBMITTED DATA ............... 26 APPENDIX III: LIST OF STUDIES ............................................................................................. 27 2 Powdered Corn Cob Product-type PT 14 September 2012 1. STATEMENT OF SUBJECT MATTER AND PURPOSE 1.1. Procedure followed This assessment report has been established as a result of the evaluation of corn cob as product-type PT 14 ([Rodenticides]), carried out in the context of the work programme for the review of existing active substances provided for in Article 16(2) of Directive 98/8/EC concerning the placing of biocidal products on the market1, with a view to the possible inclusion of this substance into Annex I or IA to the Directive. Powdered corn cob (CAS no. [none]) was initially notified as an existing active substance, by Natrocell Technologies Limited in product-type PT14. Ιn 2009, Zea Sciences Limited, hereafter referred to as the applicant, confirmed to the European Commission, ownership of the dossier. Commission Regulation (EC) No 2032/2003 of 4 November 20032 lays down the detailed rules for the evaluation of dossiers and for the decision-making process in order to include or not an existing active substance into Annex I or IA to the Directive. In accordance with the provisions of Article 5(2) of that Regulation, Greece was designated as Rapporteur Member State to carry out the assessment on the basis of the dossier submitted by the applicant. The deadline for submission of a complete dossier for Powdered corn cob as an active substance in Product Type PT14 was 28/3/2004, in accordance with Annex V of Regulation (EC) No 2032/2003. On 28/3/2004, RMS competent authorities received a dossier from the applicant. The Rapporteur Member State accepted the dossier as complete for the purpose of the evaluation on 6/12/2004. On 22/10/2009, the Rapporteur Member State submitted, in accordance with the provisions of Article 10(5) and (7) of Regulation (EC) No 2032/2003, to the Commission and the applicant a copy of the evaluation report, hereafter referred to as the competent authority report. The Commission made the report available to all Member States by electronic means on 21 September 2012. The competent authority report included a recommendation for the inclusion of Powdered corn cob in Annex I and I / IA to the Directive for PT 14. In accordance with Article 12 of Regulation (EC) No 2032/2003, the Commission made the competent authority report publicly available by electronic means on 21 September 2012. This report did not include such information that was to be treated as confidential in accordance with Article 19 of Directive 98/8/EC. In order to review the competent authority report and the comments received on it, consultations of technical experts from all Member States (peer review) were organised by 1 Directive 98/8/EC of the European Parliament and of the Council of 16 February 1998 concerning the placing biocidal products on the market. OJ L 123, 24.4.98, p.1 2 Commission Regulation (EC) No 2032/2003 of 4 November 2003 on the second phase of the 10-year work programme referred to in Article 16(2) of Directive 98/8/EC of the European Parliament and of the Council concerning the placing of biocidal products on the market and amending Regulation (EC) No 1896/2000. OJ L 307, 24.11.2003, p. 1 3 Powdered Corn Cob Product-type PT 14 September 2012 the Commission. Revisions agreed upon were presented at technical and competent authority meetings and the competent authority report was amended accordingly. On the basis of the final competent authority report, the Commission proposed the inclusion of Powdered corn cob in Annex I / IA to Directive 98/8/EC and consulted the Standing Committee on Biocidal Product on In accordance with Article 11(4) of Regulation (EC) No 2032/2003, the present assessment report contains the conclusions of the Standing Committee on Biocidal Products, as finalised during its meeting held on. 1.2. Purpose of the assessment report This assessment report has been developed and finalised in support of the decision to include Powdered corn cob in Annex I and I / IA to Directive 98/8/EC for product-type PT14. The aim of the assessment report is to facilitate the authorisation [/registration] in Member States of individual biocidal products in product-type PT14 that contain powdered corn cob In their evaluation, Member States shall apply the provisions of Directive 98/8/EC, in particular the provisions of Article 5 as well as the common principles laid down in Annex VI. For the implementation of the common principles of Annex VI, the content and conclusions of this assessment report, which is available at the Commission website3, shall be taken into account. However, where conclusions of this assessment report are based on data protected under the provisions of Directive 98/8/EC, such conclusions may not be used to the benefit of another applicant, unless access to these data has been granted. 1.3. Overall conclusion in the context of Directive 98/8/EC The overall conclusion from the evaluation is that it may be expected that there are products containing powdered corn cob for the product-type PT14, which will fulfil the requirements laid down in Article 10(1) and (2) of Directive 98/8/EC. This conclusion is however subject to: i. compliance with the particular requirements in the following sections of this assessment report, ii. the implementation of the provisions of Article 5(1) of Directive 98/8/EC, and iii. the common principles laid down in Annex VI to Directive 98/8/EC. Furthermore, these conclusions were reached within the framework of the uses that were proposed and supported by the applicant (see Appendix II). Extension of the use pattern beyond those described will require an evaluation at product authorisation level in order to 3 http://ec.europa.eu/comm/environment/biocides/index.htm 4 Powdered Corn Cob Product-type PT 14 September 2012 establish whether the proposed extensions of use will satisfy the requirements of Article 5(1) and of the common principles laid down in Annex VI to Directive 98/8/EC. 5 Powdered Corn Cob Product-type PT 14 September 2012 2. OVERALL SUMMARY AND CONCLUSIONS 2.1. Presentation of the Active Substance 2.1.1. Identity, Physico-Chemical Properties & Methods of Analysis 2.1.1.1 Name, address of applicant of active substance Applicant: Name: Zea Sciences Limited Address: The Barn Audley End Business Centre, Wendens Ambo, Saffron Walden, Essex CB11 4JL UK Telephone: +44 (0) 1673 885138 Fax number: +44 (0) 1673 885163 E-mail address: [email protected] 2.1.1.2 Identity of the active substance Common name, synonym: Powdered Corn cob. CAS-No.: None EINECS-No.: None CIPAC: None IUPAC Name: None CA Name: None 6 Powdered Corn Cob Product-type PT 14 September 2012 Purity: 100% (Due to the nature of the active substance as Powdered Corn Cob we can consider the central core of a maize). Molecular weight (g/mol): Powdered corn cob is a naturally occurring composite material and thus does not have specific molecular weight. Molecular formula: Powdered corn cob is a naturally occurring composite material and thus does not have a specific molecular formula. Structural formula: Powdered corn cob is a naturally occurring composite material and thus does not have a specific structural formula 2.1.1.3 Physico-chemical properties of the active substance Stripped corn cobs are ground into powder to produce the active substance corn cob. It is a solid tan coloured powder with negligible odour. A melting point of 1204-1325°C has been reported for 100% natural corn cob fractions. Powdered Corn cobs do not have a boiling point. Powdered Corn cob is a carbohydrate material, poorly soluble in water and all solvents. Powdered Corn cobs are very stable and are non-flammable at normal temperatures. If ignited, combustion products may include components typical of wood smoke. 2.1.1.4 Methods of analysis Analysis of the active substance as manufactured An analytical method is not identifiable. Formulation analysis An analytical method is not identifiable. 7 Powdered Corn Cob Product-type PT 14 September 2012 Residue analysis Powdered corn cobs decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. Thus there are no residues which pose a threat to human or animal health or the environment. 2.1.2. Intended Uses and Efficacy Powdered corn cob is the main ingredient in Eradirat and Eradimouse, which are used as rodenticides for the eradication of unwanted rats (Rattus norvegicus) and mice (Mus musculus), respectively. Based on the available data, Eradirat and Eradimouse, when consumed by rats and mice, rapidly cause a state of dehydration. This leads to significant perturbation of normal physiological feedback pathways because dehydration is accompanied not by an increase in water intake but rather by a reduction in it. Several mechanisms are postulated for the proximate cause of the dehydration, the most likely of which is passage of fluid across the intestinal epithelium caused by the extremely absorptive nature of Powdered Corn Cob bait. Based on combined experimental measurements and clinical observations, it appears that the consumption of the active substance Powdered Corn Cob causes acute dehydration, with consequent hypovolemia (i.e. reduced blood volume), reduced blood pressure, tissue ischemia (oxygen deprivation), and circulatory shock leading to death.As it is stated in the Manual of Decisions (See 2.3.11. Cellulose product as a rodenticide), “this mode of action is covered by the Biocidal Products Directive, and these active substances have to be notified and evaluated. For these particular products, the possibilities for justifying waiving of data as provided for in Article 8(5) of the Directive should also be examined”. As far as the Humaneness of powdered corn cob products is concerned, it is reported that animals feeding on Powdered Corn Cob baits remain apparently normal for several days until they become ‘huddled and lethargic’ in the last few hours before dying. The main external symptoms observed were lethargy, piloerection and, occasionally, tremors. None of the symptoms appeared to be noticeably severe, although this is not necessarily indicative of an humane end-point. As far as the efficacy is concerned, the Applicant has provided 18 efficacy studies, comprised of 10 field trials and 8 laboratory studies. Of the field trials, 8 have been conducted against small populations of rodents, however one was conducted against populations of 12 rats and 40 mice, and the last was against an estimated population of 60-70 rats. In all of these studies, there was no take of the census bait after treatment, indicating 100 % control of the rodent population (efficacy in a rodenticide field study is assessed by comparing how much of a census bait is eaten before and after treatment - the less that is eaten after treatment, the better the control) The Applicant has also provided 8 no-choice laboratory studies, 6 against rats and 2 against mice, where the test animals were provided with excess bait as their only food source. In all 8 studies 100 % mortality was recorded at the end of the test. 8 Powdered Corn Cob Product-type PT 14 September 2012 While there are issues with this data package (such as the low target numbers in the field studies, and because there are only no-choice tests available in the laboratory studies), the overall data package still demonstrates that the active substance is capable of having an effect on the target organisms. While the data package is definitely not suitable to support a product authorisation (as further data, including laboratory palatability and confirmatory field data against larger rodent populations will be required), the current data package is suitable to demonstrate the innate activity of the active substance, as required to recommend inclusion of the active substance onto Annex I for this Product Type in terms of efficacy. In addition, in order to facilitate the work of Member States in granting or reviewing authorisations, and to apply adequately the provisions of Article 5(1) of Directive 98/8/EC and the common principles laid down in Annex VI of that Directive, the intended uses of the substance, as identified during the evaluation process, are listed in Appendix II. 2.1.3. Classification and Labelling Classification and labelling of the active substance Based on the available data, no classification is currently used or proposed for powdered corn cob concerning its physico-chemical, toxicological, environmental and ecotoxicological properties in accordance with Annex I of Council Directive 67/548/EEC and the CLP Regulation 1272/2008. Classification of the products No classification is proposed for the products EradiRat and EradiMouse concerning their physico-chemical, toxicological, environmental and ecotoxicological properties in accordance with Directive 1999/45/EC and the CLP Regulation 1272/2008. 2.2. Summary of the Risk Assessment 2.2.1. Human Health Risk Assessment 2.2.1.1. Hazard identification Several published reports have been submitted concerning mammalian toxicology of the active substance. Most of them concern Cellulon fibres (a cellulose produced by bacterial fermentation process) or microcrystalline cellulose. There are, also, feeding studies using powdered corn cob as part of the diet of different species (e.g. rats, pigs, sheeps, cockerels, lamps, cows etc.). Additionally, an evaluation report of the Joint FAO/WHO Expert Committee on Food Additives has been submitted concerning cellulose. Cellulose is the predominant substance in powdered corn cob, contained at levels of 4045%. The applicant has argued that cellulose is commonly used in many products intended 9 Powdered Corn Cob Product-type PT 14 September 2012 for human and animal consumption and has been more widely studied than powdered corn cob. Besides, cellulose has been characterized as G.R.A.S. (generally recognized as safe) by the US FDA. The cellulose studies have been accepted by the Competent Authority, only as indicative of the toxicity of corn cob. The subchronic studies in rats indicate that at level of about 50% cellulose in the diet (about the same percentage as in powdered corn cob), It is noted that the results of the submitted studies indicate that powdered corn cob do not cause adverse effects when administered in a variety of animals including rats. On the contrary, powdered corn cob administration may even be beneficial to the animals, even the rodents. This fact seems not in accordance with the rodenticidal action of corn cob but it is easily to be explained since the doses administered in the toxicity studies are much lower that the amount of corn cob consumed in the efficacy studies. Based on the efficacy data, the lethal dose is estimated to be 200-300 g/kg b.w., whereas based on the results of the acute toxicity study of the product Eradirat (94% corn cob w/w) the LD50 is estimated to be >15.1 g/kg b.w. 2.2.1.2. Effects assessment No conventional metabolism study was submitted. The waiving was accepted as powdered corn cob is a natural product of low toxicity. Nine published reports investigating the effects of powdered corn cob when fed to either rats, cockerels, ruffed grouse, chukar partridge, bobwhite quail, sheep, lambs, pigs and ruminants have been submitted by the applicant in order to address the ADME data. The submitted studies are considered indicative of both the safe use of powdered corn cob as a feeding stuff and the low digestibility of corn cob when fed to mammals. As far as the acute oral toxicity of powdered corn cob is concerned, apart from the FAO/WHO Report on microcrystalline cellulose, two published reports describing studies conducted with either Cellulon fibres (a cellulose produced by bacterial fermentation process) or microcrystalline cellulose have been submitted. Both substances were of low acute toxicity when administered to rats or rabbits. The skin and eye irritation of powdered corn cob was addressed by the submission of skin and eye irritation studies conducted with Cellulon fiber, a cellulose produced by a bacterial fermentation process and which most closely resembles powdered and microcrystalline cellulose. The material tested caused no irritation effect when applied to rabbits. Skin sensitization data were included in the Joint FAO/WHO Expert Committee on Food Additives (1998) review of microcrystalline cellulose. The material tested exhibited no sesnsitization potential. The subchronic toxicity data included apart from the FAO/WHO Report on microcrystalline cellulose, two published reports conducted with powdered corn cob: a 4week feeding study in hens and a 40-day feeding study in cattle. Besides, a subchronic toxicity study conducted with Cellulon fibres was submitted from which it can be concluded that administration of Cellulon fibre at dosages of 5 and 10% in the diet of rats for 13 weeks did not induce any toxic effects. The submitted studies are considered indicative of both the safe use of powdered corn cob as a feeding stuff and the very low toxicity of powdered corn cob when fed to mammals. 10 Powdered Corn Cob Product-type PT 14 September 2012 Based on the submitted short term toxicity data on powdered corn cob it is not possible to establish a NOAEL/NOEL value, due to the absence of any toxic effects. Nevertheless, since the test substance is a natural product of low toxicity the RMS considers that this is not a significant deviation concerning the inclusion of the substance in the Annex I of Dir. 98/8/EC. Apart from the genotoxicity data FAO/WHO Report on microcrystalline cellulose, several published reports concerning in vitro tests conducted with either Cellulon fibres (a cellulose produced by bacterial fermentation process), microcrystalline cellulose or powdered corn cob have been submitted (Table 4.6). According to the results of these reports, the tested substances demonstrate no genotoxic potential. Carcinogenicity data were included in the Joint FAO/WHO Expert Committee on Food Additives (1998) review of microcrystalline cellulose. The material tested exhibited no carcinogenic potential. The submitted reproductive toxicity data included the FAO/WHO Report on microcrystalline cellulose and several published reports with dietary administration of powdered corn cob in many species (female sheep, pigs, cows). Among the parameters examined were weight at puberty and at first oestrus cycle, interval of puberty to first normal oestrus cycle, weaning-to-oestrus intervals and individual and total litter birth weight. No significant effect was noted on any of the reproductive parameters examined. These studies are considered indicative of both the safe use of powdered corn cob as a feeding stuff and the very low reproductive toxicity of powdered corn cob when fed to mammals. Based on the submitted data on powdered corn cob it is not possible to establish a reproductive NOAEL/NOEL value, due to the absence of any toxic effect. Nevertheless, since the test substance is a natural product of low toxicity the RMS considers that this is not a significant deviation concerning the inclusion of the substance in the Annex I of Dir. 98/8/EC. In addition, in the FAO/WHO Report on microcrystalline cellulose, results of two volunteer studies were reported. In both studies, no adverse effect to human was observed after microcrystalline cellulose administration. 2.2.1.3. Exposure assessment Test sites could be either inside buildings or outside depending on the location of the rat or mouse infestation. Loose pellets of Eradirat or Eradimouse should be placed in bait stations within the infested areas. The finished product is made of food-grade ingredients and is totally safe to handle for both professional users and the general public. Special protective equipment is not required, but users are advised to wear gloves when dispensing material to protect them from rodent-borne diseases within the infested area. Therefore the dermal exposure will be negligible. As the biocidal product is provided as a pelleted dust free product, there will be no inhalation exposure to the active substance in the finished product when handling it. Secondary exposure is possible in case of accidental ingestion of the pelleted product. According to the reverse reference scenario and if the minimum efficacious amount of 200 g/kg bw/d is considered, a 10 kg infant would have to ingest 2 kg of product, equivalent to the contents of >13 bait stations loaded at 150 g/station according to the ‘Eradirat’ product label. It is also noted that the HUMAN EXPOSURE TO BIOCIDAL PRODUCT (TNsG, June 2007) indicates that it should be assumed that an 11 Powdered Corn Cob Product-type PT 14 September 2012 infant ingests a maximum of 5 g of bait, which is 400 times less than the 2 kg total dose considered in the reverse reference scenario. 2.2.1.4. Risk characterisation Based on the submitted data on powdered corn cob, it is not possible to establish a NOAEL/NOEL value, due to the absence of any toxic effect. The submitted studies of cellulose have been accepted by the Competent Authority, only as indicative of the toxicity of corn cob. Based on the submitted data on cellulose, the subchronic studies in rats indicate that at level of about 50% cellulose in the diet (about the same percentage as in powdered corn cob) there are no toxicological effects. Therefore, it seems that the concentration of powdered corn cob and its composition as a whole natural product is the source of the rodenticidal effect. Since the rodenticidal action of powdered corn cob cannot be attributed solely to cellulose, the cellulose studies cannot be used for the establishment of an Acceptable Exposure Level (AEL). Conclusively, the setting of and AEL is not possible. This fact is not considered a significant deviation for the inclusion of the substance in the Annex I of BPD, since powdered corn cob is a natural product of low toxicity. The same policy of the non establishment of Reference Values has been followed also for many natural products of low toxicity (e.g. sheep fat, hydrolyzed proteins, paraffin oils, fish oil, tall oils, etc) evaluated in the frames of the Plant Protection Products Directive 91/414/EEC. 2.2.2. . Environmental Risk Assessment 2.2.2.1 Fate and distribution in the environment Powdered corn cobs are composed of plant carbohydrate material, and are poorly soluble in water and other solvents. They are very stable and do not become partitioned between aqueous phases and organic surfaces of soils, sediments and sludge. The most labile parameter of the quality of powdered corn cobs during storage is the monosaccharide content. Monosaccharides start to break down much earlier than the appearance of putrefaction. The appearance of moulds and change in the colour of the cobs is seen once the process of putrefaction is already considerably underway. Powdered corn cobs stored outdoors rapidly deteriorate, whereas there are no significant changes in the quality of cobs stored indoors for up to 5 months. 2.2.2.2. Effects assessment Eradirat and Eradimouse are intended to be used by professional pest control officers and the general public to eradicate unwanted rats and mice. Eradirat and Eradimouse can be used both inside buildings and outdoors. When used outside, it is recommended that the product is protected from moisture and where possible placed in the nesting burrows of the rats and mice or in their feeding stations. A total of up to 150g of product should be used per rat baiting point (plus loss and spillage) and around 50g of product per mouse baiting point. Feeding 12 Powdered Corn Cob Product-type PT 14 September 2012 stations should be replenished daily. It is estimated that rodents die from consuming more than 200-300g/kg bodyweight over a period of several days. Powdered corn cobs are composed of plant carbohydrate material, and are poorly soluble in water and other solvents. They are very stable and do not become partitioned between aqueous phases and organic surfaces of soils, sediments and sludge. The most labile parameter of the quality of powdered corn cobs during storage is the monosaccharide content. Monosaccharides start to break down much earlier than the appearance of putrefaction. The appearance of moulds and change in the colour of the cobs is seen once the process of putrefaction is already considerably underway. Powdered corn cobs stored outdoors rapidly deteriorate, whereas there are no significant changes in the quality of cobs stored indoors for up to 5 months. Cellulose was shown to have no hazardous effects on environmental organisms, indeed it, and its breakdown products, can provide an important food source for various organisms. Likewise, powdered corn cob is a natural plant material which decomposes mainly to sugars, which are readily incorporated into intermediary metabolism in the environment and thus present no hazard to environmental organisms. 2.2.2.2.1 Aquatic environment (fresh water & sediment) See above. 2.2.2.2.2 Atmosphere No data were submitted by the applicant. However, as powdered corn cob is a natural plant material which decomposes to products which are readily incorporated into metabolism, this route of exposure is not considered to pose any risks. 2.2.2.2.3 Terrestrial compartment See above. 2.2.2.3. PBT assessment Powdered corn cob cannot be regarded as fulfilling the PBT-criteria. Powdered corn cobs are composed of plant material. They do not act as a chemical and become partitioned between aqueous phases and organic surfaces of soils, sediments and sludge. If left outside cobs decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. The most labile parameter of the quality of powdered com cobs during storage is the monosaccharide content. Monosaccharides start to break down much earlier than the appearance of putrefaction. The appearance of moulds and change in the colour of the cobs is seen once the process of putrefaction is already considerably underway. Powdered corn cobs stored outdoors rapidly deteriorate, whereas there are no significant changes in the quality of cobs stored indoors for up to 5 months. Cellulose was shown to have no hazardous effects on environmental organisms, indeed it, and its breakdown products, can provide an important food source for various organisms. Likewise, powdered com cob is a natural plant material which decomposes mainly to sugars, which are readily incorporated into intermediary metabolism in the environment and thus present no hazard to environmental organisms. The fate in water of dead plant material (containing cellulose) imported from the surrounding drainage basin, where it is attacked by fungi and bacteria (some aquatic and some 13 Powdered Corn Cob Product-type PT 14 September 2012 which were originally present in the plant material) it will be decomposed, mainly to sugars which are readily incorporated into intermediary metabolism in the environment. Where various essential nutritional elements such as nitrogen, phosphorus, calcium, magnesium and potassium are in a high enough concentration not to limit growth, the fungi flourish, increasing the amount of protein in the detritus, which provides a suitable food source for invertebrates and, in turn, predatory fish. The ability of cellulose in the aquatic environment to degrade is indicative of a low risk to aquatic systems as it effects more as a feed rather than a toxicant. It does not biaccumulate as it is one of the waste by-products of corn, a food crop grown worldwide for both human and animal. The other ingredients in Eradirat and Eradimouse are molasses and wheat flour (Eradirat only). They are both food stuffs and are also classified by the US EPA as Minimal Risk Inerts. 2.2.2.4. Exposure assessment Eradirat and Eradimouse are intended to be used by professional pest control officers and the general public to eradicate unwanted rats and mice. Eradirat and Eradimouse can be used both inside buildings and outdoors. When used outside, it is recommended that the product is protected from moisture and where possible placed in the nesting burrows of the rats and mice or in their feeding stations. A total of up to 150g of product should be used per rat baiting point (plus loss and spillage) and around 50g of product per mouse baiting point. Feeding stations should be replenished daily. It is estimated that rodents die from consuming more than 200300g/kg bodyweight over a period of several days. Powdered corn cobs are composed of plant carbohydrate material, and are poorly soluble in water and other solvents. They are very stable and do not become partitioned between aqueous phases and organic surfaces of soils, sediments and sludge. The most labile parameter of the quality of powdered corn cobs during storage is the monosaccharide content. Monosaccharides start to break down much earlier than the appearance of putrefaction. The appearance of moulds and change in the colour of the cobs is seen once the process of putrefaction is already considerably underway. Powdered corn cobs stored outdoors rapidly deteriorate, whereas there are no significant changes in the quality of cobs stored indoors for up to 5 months. Cellulose was shown to have no hazardous effects on environmental organisms, indeed it, and its breakdown products, can provide an important food source for various organisms. Likewise, powdered corn cob is a natural plant material which decomposes mainly to sugars, which are readily incorporated into intermediary metabolism in the environment and thus present no hazard to environmental organisms. Aquatic environment (fresh water & sediment) See above. Air No data were submitted by the applicant. However, as powdered corn cob is a natural plant material which decomposes to products which are readily incorporated into metabolism, this route of exposure is not considered to pose any risks. Terrestrial compartment 14 Powdered Corn Cob Product-type PT 14 September 2012 See above. 2.2.2.5. Risk characterisation Corn-on-the-cob is a food crop grown world-wide for both human and animal consumption. One of the waste by-products, the stripped powdered corn cobs, is used for a variety of purposes including animal bedding, fuel and animal feed. Powdered corn cobs decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. Thus the active substance, powdered corn cob, clearly does not pose any threat to the environment. In addition, the other ingredients are also human food substances derived from plant products; molasses and wheat flour. They too do not pose any risk or hazard to the environment. Powdered corn cobs are composed of plant carbohydrate material, and are poorly soluble in water and other solvents. They are very stable and do not become partitioned between aqueous phases and organic surfaces of soils, sediments and sludge. The most labile parameter of the quality of powdered corn cobs during storage is the monosaccharide content. Monosaccharides start to break down much earlier than the appearance of putrefaction. The appearance of moulds and change in the colour of the cobs is seen once the process of putrefaction is already considerably underway. Powdered corn cobs stored outdoors rapidly deteriorate, whereas there are no significant changes in the quality of cobs stored indoors for up to 5 months. Cellulose was shown to have no hazardous effects on environmental organisms, indeed it, and its breakdown products, can provide an important food source for various organisms. Likewise, powdered corn cob is a natural plant material which decomposes mainly to sugars, which are readily incorporated into intermediary metabolism in the environment and thus present no hazard to environmental organisms. Tests on terrestrial animals(included in the dossiers)such as dogs, cats, rabbits, ducks and chickens all indicated that when ingested, no adverse effects are observed. The material is not palatable to non-rodents. Non-rodent species have consistently been found to not consume the same quantities of the product as compared to commensal rodents on a g/Kg body weight basis. Indeed the product is generally not palatable to non-rodents. The extensive non-target species testing, extensive rodent control field trials as well as the inherent safety of the cellulose active ingredient is justification for not specifically conducting field trials aimed at non species effects. Field trials to date have not indicated any adverse effect on non-rodent species. In addition, powdered corn cob products have been used extensively in industry for many years without reported impact on animals(Physical properties. Chemical properties and the uses of the Andersons' corn cob products, 2 nd edition, 1978, pages 215). Further tests on non-rodent animals in field trials are unjustified from an efficacy as well as a humaneness perspective (see efficacy and toxicology section). 3. DECISION 3.1. Background to the Decision 15 Powdered Corn Cob Product-type PT 14 September 2012 The overall conclusion from the evaluation of powdered corn cob for use as a rodenticide (PT14) for professional and non-professional users is that the substance fulfils the safety requirements laid down in Article 10(1) of Directive 98/8/EC. It is expected that it will be possible for MS to issue authorisations for products containing powdered corn cob in accordance with the conditions laid down in article 5 (1) (b-d) of Directive 98/8/EC. Powdered corn cob is therefore proposed for inclusion into Annex I and IA of that Directive. The efficacy of powdered corn cob as a rodenticide against rat (Rattus norvegicus) and mouse (Mus musculus) has been sufficiently demonstrated and the formulated products satisfy efficacy evaluation requirements for Annex I listing of the active substance. As stated by the applicant, further efficacy studies will be required, and will be presented at the stage of Product Authorisation. Powdered corn cob as a natural by-product of corn is of low toxicity to human health, based on the results conducted either with corn cob or with cellulose which is the predominant ingredient of corn cob (40-45%). Primary human exposure of corn cob is negligible since the products are dust free pellets and no dermal exposure will occur since the use of gloves is recommended. Secondary exposure may occur in case of accidental ingestion of the pellets but will cause no adverse effects, since an infant should ingest an amount 2kg of bait which is 400 times higher than the standard amount of 5gr bait assumed by the TNsG for human Exposure (June 2007) to experience adverse effects. In any case it is recommended to keep the products away from children. The active substance is powdered corn cob. The data provided shows that neither the biocidal products nor the active substance pose any risk to the environment. Loose pellets of Eradirat or Eradimouse are placed in bait stations (or directly into burrows) within the infested areas which can be either inside buildings or outside. Powdered corn cobs, are poorly soluble (<10%) and naturally decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. The Biocides Directive defines a low-risk biocidal product as: “A biocidal product which contains as active substance(s) only one or more of those listed in Annex IA and which does not contain any substance(s) of concern. Under the conditions of use, the biocidal product shall pose only a low risk to humans, animals and the environment” (Article 2 (1) b)). Eradirat and Eradimouse (active substance powdered corn cob) do not contain any substances of concern. Furthermore, under the conditions of use, the biocidal active substance corn cob pose no risk to humans, animals and the environment and thus should be included in Annex IA. Powdered corn cobs, the by-product of the food crop corn-on-the-cob, have been used for many years in a variety of products including animal feed and bedding, and fuel. The other ingredients, molasses and wheat flour (Eradirat only), are human foodstuffs and thus are also not hazardous materials. 3.2. Decision regarding Inclusion in Annex I 16 Powdered Corn Cob Product-type PT 14 September 2012 On the basis of the proposed and supported use, it is concluded that the proposed use of powdered corn cob as a rodenticide fulfils the safety requirements laid down in Article 5(1) of Directive 98/8/EC. It is therefore proposed that powdered corn cob to be included into Annex I and IA of the Directive 98/8/EC as an active substance in rodenticide products (product type 14), with the following provisions : * In Annex I : When assessing the application for authorisation of a product in accordance with Article 5 and Annex VI, Member States shall assess, where relevant for the particular product, those uses or exposure scenarios and those risks to human populations and to environmental compartments that have not been representatively addressed in the Union level risk assessment.’ * In Annex IA : Member States shall ensure that registrations are subject to the following condition: — Only for use in the form of pellets in dry locations. 3.3. Elements to be taken into account by Member States when authorising products Further efficacy studies regarding the biocidal products containing corn cob powdered should be submitted. 17 Powdered Corn Cob Product-type PT 14 September 2012 Appendix I: List of endpoints Chapter 1: Identity, Physical and Chemical Properties, Classification and Labelling Active substance (ISO Common Name) Powdered Corn cob, Product-type 14 Identity Chemical name (IUPAC) None Chemical name (CA) None CAS No None EC No None Other substance No. None Minimum purity of the active substance as manufactured (g/kg or g/l) 1000g/kg (Due to the nature of the active substance as Corn Cob we can consider the core of a maize.) Identity of relevant impurities and additives (substances of concern) in the active substance as manufactured (g/kg) No substances of concern Molecular formula Powdered corn cob is a naturally occurring composite material and thus does not have a molecular formula Molecular mass Powdered corn cob is a naturally occurring composite material and thus does not have molecular mass. Structural formula Powdered corn cob is a naturally occurring composite material and thus does not have a structural formula. 18 Powdered Corn Cob Product-type PT 14 September 2012 Physical and chemical properties Melting point (state purity) 100% natural corn cob fractions have a melting point of 1204-1325°C. Boiling point (state purity) n.a. Temperature of decomposition Due to the nature of the active substance it is expected to be stable Appearance (state purity) Solid tan powder Relative density (state purity) 0.288 – 0.416g/cm3 (woody portion of the corn cob) (Bulk density) Surface tension n.a. Vapour pressure (in Pa, state temperature) 3 n.a. -1 Henry’s law constant (Pa m mol ) n.a. Solubility in water (g/l or mg/l, state temperature) Due to the nature of the active substance it is expected to have poor solubility in water Solubility in organic solvents (in g/l or mg/l, state temperature) Due to the nature of the active substance it is expected to have poor solubility in all solvents. Stability in organic solvents used in biocidal products including relevant breakdown products Due to the nature of the active substance it is expected to have poor solubility in all solvents Partition coefficient (log POW) (state temperature) n.a. Hydrolytic stability temperature) n.a. (DT50) (state pH and Dissociation constant n.a. UV/VIS absorption (max.) (if absorption > 290 nm state at wavelength) n.a. Photostability (DT50) (aqueous, sunlight, state pH) n.a. Quantum yield of direct phototransformation in water at > 290 nm n.a. Flammability Non highly flammable. Explosive properties No explosive properties based on the structure of the compound and the percentage oxygen balance. 19 Powdered Corn Cob Product-type PT 14 September 2012 Classification and proposed labelling with regard to physical/chemical data None with regard to toxicological data None with regard to fate and behaviour data None with regard to ecotoxicological data None Chapter 2: Methods of Analysis Analytical methods for the active substance Technical active substance (principle of method) An analytical method for identification is not identifiable. Impurities in technical active substance (principle of method) - Analytical methods for residues Corn cobs decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. Thus there are no residues which pose a treat to human or animal health or the environment. . Furthermore an analytical method is not identifiable. Soil (principle of method and LOQ) Air (principle of method and LOQ) Water (principle of method and LOQ) Body fluids and tissues (principle of method and LOQ) Food/feed of plant origin (principle of method and LOQ for methods for monitoring purposes) Food/feed of animal origin (principle of method and LOQ for methods for monitoring purposes) 20 Powdered Corn Cob Chapter 3: Product-type PT 14 Impact on Human Health Absorption, distribution, metabolism and excretion in mammals Rate and extent of oral absorption: No data, not required Rate and extent of dermal absorption: No data, not required Distribution: No data, not required Potential for accumulation: No data, not required Rate and extent of excretion: No data, not required Toxicologically significant metabolite(s) None Acute toxicity Rat LD50 oral >15g/kg b.w. Rat LD50 dermal No data, not required Rat LC50 inhalation No data, not required Skin irritation Not irritating Eye irritation Not irritating Skin sensitization (test method used and result) Not sensitising Repeated dose toxicity Species/ target / critical effect None Lowest relevant oral NOAEL / LOAEL Not established, not required Lowest relevant dermal NOAEL / LOAEL No data, not required Lowest relevant inhalation NOAEL / LOAEL No data, not required Genotoxicity No genotoxic potential Carcinogenicity Species/type of tumour No carcinogenic potential lowest dose with tumours Not relevant Reproductive toxicity Species/ Reproduction target / critical effect None Lowest relevant reproductive NOAEL / LOAEL Not established, not required Species/Developmental target / critical effect None Developmental toxicity Lowest relevant developmental NOAEL / LOAEL Not established, not required Neurotoxicity / Delayed neurotoxicity 21 September 2012 Powdered Corn Cob September 2012 Product-type PT 14 Species/ target/critical effect No data, not required Lowest relevant developmental NOAEL / LOAEL. No data, not required Other toxicological studies ............................................................................... No data, not required Medical data ............................................................................... No data, not required Reference values Value Study Assessment factor ADI (acceptable daily intake, external long-term reference dose) - - - DWL (Drinking water limit - - - - - - AEL short term - - - AEL medium-term - - - AEL long-term - - - ARfD (acute reference dose) - - - Reference value for inhalation (proposed OEL) - - - Reference value for dermal absorption - - - Non-professional user AELs (Acceptable reference dose): Exposure Limits. Internal Acceptable exposure scenarios (including method of calculation) Production of active substance: Not under the scope of the BPD Professional and non professional users No unacceptable exposure is foreseen Chapter 4: Fate and Behaviour in the Environment Corn cobs decompose mainly to sugars which are readily incorporated into intermediary metabolism in the environment. No further data were submitted by the applicant and thus no arithmetic end-points could be derived. Route and rate of degradation in water Hydrolysis of active substance and relevant metabolites (DT50) (state pH and temperature) pH______: No data available pH______: No data available pH______: No data available Photolytic / photo-oxidative degradation of active substance and resulting relevant metabolites No data available 22 Powdered Corn Cob Product-type PT 14 Readily biodegradable (yes/no) No data available Biodegradation in seawater No data available Non-extractable residues No data available Distribution in water / sediment systems (active substance) No data available Distribution in (metabolites) No data available water / sediment systems September 2012 Route and rate of degradation in soil Mineralization (aerobic) Laboratory studies (range or median, with number of measurements, with regression coefficient) DT50lab (20C, aerobic): No data available DT90lab (20C, aerobic): No data available DT50lab (10C, aerobic): No data available DT50lab (20C, anaerobic): No data available degradation in the saturated zone: No data available Field studies (state location, range or median with number of measurements) DT50f: No data available DT90f: No data available Anaerobic degradation No data available Soil photolysis No data available Non-extractable residues No data available Relevant metabolites - name and/or code, % of applied a.i. (range and maximum) No data available Soil accumulation and plateau concentration No data available Adsorption/desorption Ka , Kd No data available Kaoc , Kdoc pH dependence (yes / no) (if yes type of dependence) Fate and behaviour in air Direct photolysis in air No data available Quantum yield of direct photolysis No data available Photo-oxidative degradation in air Latitude: . No data available ................. DT50 .............. Volatilization No data available Monitoring data, if available 23 Season: Powdered Corn Cob Soil (indicate location and type of study) No data available Surface water (indicate location and type of study) No data available Ground water (indicate location and type of study) No data available Air (indicate location and type of study) No data available Chapter 5: September 2012 Product-type PT 14 Effects on Non-target Species Toxicity data for aquatic species (most sensitive species of each group) Species Time-scale Endpoint Fish No data available Invertebrates No data available Algae No data available Microorganisms No data available Effects on earthworms or other soil non-target organisms Not applicable Acute toxicity to ………………………………….. Not applicable Reproductive toxicity to ………………………… 24 Toxicity Powdered Corn Cob Product-type PT 14 Effects on soil micro-organisms Nitrogen mineralization Not applicable Carbon mineralization Not applicable Effects on terrestrial vertebrates Acute toxicity to mammals Acute Dietary toxicity toxicity Reproductive toxicity No data available to birds No data available to birds No data available birds No data available to Effects on honeybees Acute oral toxicity Not applicable Acute contact toxicity Not applicable Effects on other beneficial arthropods Acute oral toxicity Not applicable Acute contact toxicity Not applicable Not applicable Acute toxicity to ………………………………….. Bioconcentration Bioconcentration factor (BCF) No data available Depration time (DT50) No data available (DT90) Level of metabolites (%) in organisms accounting for > 10 % of residues Chapter 6: No data available Other End Points 25 September 2012 Powdered Corn Cob September 2012 Product-type PT 14 Appendix II: List of Intended Uses Table: List of Intended Uses supported by the submitted data MG/PT Field of use envisaged Likely concentration at which active substance will be used MG03/Product type Eradirat and Eradimouse are intended for use by 14: Rodenticides for professional pest control officers and the general public to eradicate unwanted rats (Rattus rats and mice. norvegicus) and mice (Mus musculus). Eradirat and Eradimouse can be used both inside buildings and outdoors. When used outside it is recommended that the product is protected from moisture, and where possible, placed down the nesting burrows of the rats and mice or in their feeding stations. Eradirat and Eradimouse were first marketed in the EU (in the UK) in 2000. In 2000 approximately 40 tonnes of the product were imported into the EU, in 2001 approximately 64 tonnes were imported and in both 2002 and 2003 approximately 120 tonnes of product were imported. The products can now be sold in the UK, Norway, Ireland, Italy and Germany. 26 A total of up to 150g of product should be used per rat baiting point (plus loss and spillage) and around 50g of product per mouse baiting point. Feeding stations should be replenished daily. It is estimated that rodents die from consuming more than 200-300g/kg bodyweight over a period of several days. Powdered Corn Cob September 2012 Product-type PT 14 Appendix III: List of studies Data protection is claimed by the applicant in accordance with Article 12.1(c) (i) and (ii) of Council Directive 98/8/EC for all study reports marked “Y” in the “Data Protection Claimed” column of the table below. These claims are based on information from the applicant. It is assumed that the relevant studies are not already protected in any other Member State of the European Union under existing national rules relating to biocidal products. It was however not possible to confirm the accuracy of this information. Section No/ Reference No Author (s) Year A3/5 A3/12 A3/15 Α3/12 Andersons, The Cob 1978 Division Processing Group, Ohio, USA (editor Foley, K) White, G.A 2011 Β3/8 White, G.A 2011 B5/01 Delmar Products Ltd 1995, Trial No 1 1995 B5/02 Delmar Products Ltd 1995, Trial No 2 1995 B5/03 Delmar Products Ltd 1995, Trial No 3 1996 Title Source (where different from company) Company, Report No GLP (where relevant)/(Un) Published Physical properties, Chemical properties and uses of The Andersons’ corn cob products, unpublished Examination of Powdered Corn Cob GC Laboratories Ltd Report No J18496 GLP Determination of particle size of Powdered Corn Cob and Eradirat pellets, and determination of attrition and friability characteristics of Eradirat pellets. GC Laboratories Ltd Report No J18895 GLP The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 1 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 2 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 3 Not GLP, Unpublished 27 Data protection Claimed Yes/No Owner Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Powdered Corn Cob September 2012 Product-type PT 14 B5/04 Delmar Products Ltd 1995, Trial No 4 1996 B5/05 Delmar Products Ltd 1995, Trial No 5 1996 B5/06 Delmar Products Ltd 1995, Trial No 6 1996 B5/07 Delmar Products Ltd 1995, Trial No 7 1996 B5/08 Delmar Products Ltd 1995, Trial No 8 1996 B5/09 Delmar Products Ltd 1995, Trial No 9 1996 B5/10 Delmar Products Ltd 1995, Trial No 10 1996 B5/11 Morgan DR, Eason 2002 CT 2002, LC0203/053 The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 4 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 5 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 6 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 7 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 8 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 9 Not GLP, Unpublished The Orbis Molasses Pellet an all natural and organic rodenticide to control rats and mice. Field test results and appraisals Trial No 10 Not GLP, Unpublished Efficacy of Eradirat against Sprague-Dawley rats Landcare Research Contract Report LC0203/053, Study number GLP 02/10/01 GLP, Unpublished 28 Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Powdered Corn Cob September 2012 Product-type PT 14 B5/12 Kable JR 2002, GLP31745 2002 B5/13 Hoyer K 2002, GLP31755 2002 B5/14 Morgan DR, Eason 2002 CT 2003, LC0203/061 B5/16 Prescott, Dr C.V & Buckle, Dr A 2006 Prescott, Dr C.V & Buckle, Dr A 2006 B5/17 Morgan DR 2002, 2002 LC0203/055 B5/18 Hoyer K 2002, GLP31754 2002 Effects of Eradirat on rats when fed ad libitum Celsius Laboratory Group, Study ID number GLP31745 GLP, Unpublished Confirming effects of Eradirat on rats when fed ad libitum Celsius Laboratory Group, Study ID number GLP31755 GLP, Unpublished Efficacy of Eradirat against Sprague-Dawley Laboratory Rats and Assessment of Mode of Action and Effects. Landcare Research Contract Report LC0203/061 Not GLP, Unpublished Pilot field study investigating the behaviour of Norway Rats, Rattus norvegicus (Berkenhout, 1769) on a mixed farm in Wales when “Natrocell Pro” rodenticide bait, containing the active substance powdered corn cob, was applied. Vertebrate Pests Unit, School of Biological Sciences, The University of Reading Field efficacy evaluation of “Natrocell Pro” rodenticide bait, containing the active substance powdered corn cob, for the control of Norway Rats, Rattus norvegicus (Berkenhout, 1769) infesting an agricultural holding on the Anglo-Welsh border. Vertebrate Pests Unit, School of Biological Sciences, The University of Reading Efficacy of Eradimouse against Wild House Mice Landcare Research Contract Report LC0203/055 Not GLP, Unpublished Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Yes Zea Sciences Ltd Effects of Eradimouse on mice when fed ad libitum Celsius Laboratory Group, Study ID number GLP31754 GLP, Unpublished Yes Zea Sciences Ltd 29 Powdered Corn Cob September 2012 Product-type PT 14 B5/19 Morgan DR 2003, 2003 LC0203/121 Susceptibility of the chicken (Gallus gallus) to Eradimouse. Landcare Research Contract Report LC0203/121 Study Number GLP03/01/03 GLP, Unpublished Yes Zea Sciences Ltd B5/20 Morgan DR 2003, 2003 LC0203/122 Yes Zea Sciences Ltd B5/21 Morgan DR 2003, 2003 LC0203/117 Yes Zea Sciences Ltd B5/22 Morgan DR 2003, 2003 LC0203/116 Yes Zea Sciences Ltd B5/23 Morgan DR 2003, 2003 LC0203/115 Yes Zea Sciences Ltd B5/24 Morgan DR 2003, 2003 LC0203/120 Yes Zea Sciences Ltd B5/25 Morgan DR 2003, 2003 LC0203/118 Yes Zea Sciences Ltd B5/26 Morgan DR 2003, 2003 LC0203/119 Susceptibility of the duck (Anas Platyrhynchos) to Eradimouse. Landcare Research Contract Report LC0203/122 Study Number GLP03/01/05 GLP, Unpublished Susceptibility of the guinea pig (Cavia porcellus) to Eradimouse. Landcare Research Contract Report LC0203/117 Study Number GLP03/01/06 GLP, Unpublished Susceptibility of the European rabbit (Oryctolagus cuniculus cuniculus) to Eradirat. Landcare Research Contract Report LC0203/116 Study Number GLP03/01/07 GLP, Unpublished Susceptibility of the brushtail possum (Trichosurus vulpecula) to Eradirat. Landcare Research Contract Report LC0203/115 Study Number GLP03/01/01 GLP, Unpublished Susceptibility of the ferret (Mustela furo) to Eradirat. Landcare Research Contract Report LC0203/120 Study Number GLP03/01/08 GLP, Unpublished Susceptibility of the cat (Felis catus) to Eradirat. Landcare Research Contract Report LC0203/118 Study Number GLP03/01/02 GLP, Unpublished Susceptibility of the dog (Canis familiaris) to Eradirat. Landcare Research Contract Report LC0203/119 Study Number GLP03/01/04 GLP, Unpublished Yes Zea Sciences Ltd 30 Powdered Corn Cob B6/1 Rothstein EC 1994, #9412329 September 2012 Product-type PT 14 1994 Acute oral toxicity study LD50 Leberco Testing Inc, Assay #9412329 GLP, Unpublished Yes Zea Sciences Ltd i Section Number/Reference Number should refer to the section number in Doc III-A or III-B. If the study is non-key, and hence not summarised in Doc III but mentioned in Doc II, it should be included in the reference list alongside related references and its location in Doc II indicated in brackets. (If there is a need to include a cross-reference to PPP references then an additional column can be inserted). i Author’s Name should include the author’s surname before initial (s) to enable the column to be sorted alphabetically. If the Human Rights Charter prevents author’s surnames on unpublished references being included in non-confidential documents, then it will be necessary to consider including ‘Unpublished [number/year & letter] ’ in Doc II, and both ‘ Unpublished [number/year & letter]’ and the ‘Authors Name’ in the reference list’. This may necessitate the need for an additional column to state whether a reference is unpublished which can then be sorted. i Title, Source (where different from company), Company, Report No., GLP (where relevant), (Un)Published should contain information relevant to each item (ideally on separate lines within the table cell for clarity). If useful, the name of the electronic file containing the specific study/reference could be added in brackets. 31
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