Carbon disulfide review history and regulatory outcomes

Nomination for review

In July 2003, the APVMA (formerly the NRA) began a review of carbon disulfide. Carbon disulfide was nominated for review because of concerns over toxicology, occupational health and safety, residues in food and the explosive nature of carbon disulfide under certain circumstances, and a concern that existing label instructions may be inadequate.

In 2003 there were only two carbon disulfide products registered in Australia, Ajax Carbon Disulphide Grain Fumigant Ready-To-Use Liquid (a grain fumigant) and C.S.S.P. Phosphorus Pig Poison (a pig poison). The review focused on the registration and associated labels of these two products.

In December 2002 the registration of the grain fumigant had been suspended because of concerns over the potential for the product to explode and pose a risk to workers. Before beginning the review the APVMA issued modified use instructions to allow the continued supply and use of the product; these instructions remained in force while the review was being conducted.

Draft review report

In August 2004 the APVMA released the Carbon Disulfide Draft Review Report. A key concern was the risk to workers from the grain fumigant’s potential to explode. The APVMA concluded that the existing label instructions for both the pig poison and grain fumigant were inadequate to protect workers.

The APVMA proposed a number of changes to the labels of carbon disulfide products to reduce risks to workers, the environment, and to reduce residues in commodities. These changes included varying product labels to include warnings of the potential for explosion, strengthening safety instructions and improving personal protection requirements. These changes were in addition to the modified use instructions that were put in place in December 2002.

In the draft review report the APVMA also proposed revoking the December 2002 suspension of the registration and label approvals for Ajax Carbon Disulphide Grain Fumigant Ready-to-Use Liquid.

Preliminary review

In April 2005 the APVMA released the Carbon Disulfide Preliminary Findings Review Report for public comment. The APVMA concluded that the two carbon disulfide products did not contain adequate label instructions. The APVMA proposed varying the approved product labels to include new use instructions.

In December 2004 the registrant of the grain fumigant voluntarily requested that the APVMA cancel the registration of its product, Ajax Carbon Disulphide Grain Fumigant Ready-to-Use Liquid.

The review of carbon disulfide originally included two registered products, a grain fumigant and a feral pig poison. Following the cancellation of the grain fumigant, the review continued but only dealt with the use of carbon disulfide as a pig poison in the product, C.S.S.P. Phosphorus Pig Poison.

Final review and outcomes

In October 2005 the APVMA released the Carbon Disulfide Review Final Report. The APVMA found that it was not satisfied that existing labels contained adequate instructions to ensure the safety of workers and public health.

However, the APVMA was satisfied that the approved labels for the product C.S.S.P Phosphorus Pig Poison could be varied to allow the continued registration of the product.

In final report the APVMA recommended:

• varying the current approved product label to include the following new use instructions:
  - increasing minimum distances for laying pig poison near homes, water supplies, public roads and property boundaries
  - indicating areas where pig poison may not be laid, including not laying baits in areas where the minimum distance restrictions cannot be met.
  - a requirement to notify the public before laying poison. Landholders must put up notices warning that pig poison has been laid on the property and give at least three days notice to anyone whose property boundaries fall within four kilometres of the outermost baiting line.
  - advice on the placement, timing and use of bait material, and the recovery of poison/bait and carcasses
  - a requirement to report any suspected incidents of non-target animal poisoning to state or territory authorities
  - additional safety directions, precautionary statements and first aid instructions.

For more information please contact the Chemical Review Program on (02) 6210 4749 or by email to chemrev@apvma.gov.au