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Fri, 9 Mar 2012 23:36:09 -0500 |
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>In June when the Medivet label was released Allen put it on The List
Here it is again:
http://www.medivetpharmaceuticals.ca/Guidelines/pmra%20final%20english%20label%20june%203.pdf
>Allen and all Canadians: this think is finish and unless your method is
>listed you better apply for your own acid label. And that includes
>anything which you soak first and then put in hive you cannot use your
> V50.
That is interesting. My understanding was that the intent was to write a label
sufficiently broad to encompass all the various methods. That is not easy to do,
and I guess the assumption was that PMRA would have little interest in enforcing
details about use of this widely used, largely benign, and flexible product.
Apparently that was wrong, unless Bill approached them and forced the question.
If they approached him, that is disappointing.
>After 8 months of working with PMRA I am happy to let you know that The
>MiteGone is legal to use in CANADA. And we filled the application for our
>own formic acid.
Actually, the above label covers any method I might consider using, unless I choose
to try Bill's method, but I wonder if PMRA may lack a sense of perspective on the
issue and be wasting everyone's time and money.
Writing labels a near impossible job to get right the first time because some twit
will take it with a grain of salt but some regulators will take it overly literally
and both either not comprehend the intent, or ignore it.
I thought this was all settled a long time ago in favour of free use within
reasonable bounds, but we are now seeing a succession of commercial products
becoming "legal" when IMO. they should have been covered in the basic approval
in the first place.
I'm afraid that the industry bowed to pressure from PMRA to be too restrictive
for no good reason, other than to make bureaucrats happy. As a result, people
like Bill are forced to seek approval for fear of being blindsided by PMRA.
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