Do You Understand Poison Schedules?

In our industry, safety is our number one priority and when it comes to treatments, it all starts with the product and it’s toxicological profile. All products go through a safety assessment as part of the registration process, which includes classifying the product into a specific Poison Schedule and determining the required safety instructions on the label. So what is the Poison Scheduling process and what do you need to know?

Scheduling is a national classification system that controls how medicines and poisons are made available to the public. Medicines and poisons are classified into Schedules according to the level of regulatory control over the availability of the medicine or poison, required to protect public health and safety.

The Scheduling Policy Framework (SPF) is a key feature of the arrangements for scheduling of medicines and chemicals. It is developed and administered under a joint federal and state arrangement, the Australian Health Ministers’ Advisory Council (AHMAC), with input from advisory committees on medicines and other chemicals. The SPF sets out the scheduling process, guidance for amending the Poisons Standard, the classification system for medicines and chemicals, as well as guidelines for applications and public consultation, as these relate to scheduling applications.

The Poisons Standard consists of decisions regarding the classification of medicines and poisons into Schedules for inclusion in the relevant legislation of the States and Territories. The Poisons Standard also includes model provisions about containers and labels, a list of products recommended to be exempt from these provisions, and recommendations about other controls on drugs and poisons. The Poisons Standard is designed to promote uniform scheduling of substances and uniform labelling and packaging requirements throughout Australia.

But what does this all mean for the pest control industry? In short, pest control products generally fall within three of the 10 schedules (ie. Schedules, 5, 6 and 7). The remainder relate specifically to human and veterinary medicines and other prohibited substances. Pest control professionals will be aware that labels will often bear at the very top the words CAUTION, POISON or sometimes DANGEROUS POISON. These phrases are very specific to the schedules involved.

All products come with a range of controls on their use depending on the specific health effects that have been identified or inferred from animal toxicity studies. Using an extreme example, S7 products that may cause birth defects in laboratory animals are labelled with a warning for women of child-bearing age to avoid such products. Fortunately there are few if any S7 products used in the pest control industry these days.

On the other end of the spectrum there are products used in the pest control industry which are so benign that they do not warrant inclusion in any of these schedules and have little if any specific control over their use, for instance most biological products and some IGRs. These will often only carry the wording “Read safety directions before opening and using” as do all other labels.

It is important to remember that the poison scheduling relates to the product as sold – the formulation, the concentration of active, the format (liquid, gel, granules, etc) and the packaging it is in, and not to the product as applied, when the format and concentration can be very different. Typically the safety profile of the product as applied will be significantly more favourable. Although the safety of the product as applied will have been assessed in the registration process, the only reflection of the safety profile of the product as applied is in the application directions and requirements for PPE on the label – the product MSDS still refers to the product as sold not as applied.

So, read the label carefully – it does provide valuable information but of course is it a legal document and must be followed. It is also important to remember that when a customer asks, “Is it safe?”, the answer should always be, “Yes, as long as it is used according to the label.” After all, all registered products are “safe” or rather have an acceptable risk, if used in accordance with the label.