That's it in essence.
I should have mentioned that I also did not get my full written submissions in on time for translation. They are with the committee now, so presumably you'll get them. I have a more detailed discussion there of the PMRA's approach.
As I understand the PMRA's position, there is a specific requirement for them to:
consider available information on aggregate exposure
—that's the exposure of all the different ways someone comes into contact with a pesticide—
to the pest control product, namely dietary exposure and exposure from other non-occupational sources.
They interpret that section as meaning the aggregate exposure assessment is focused on non-occupational sources of exposure.
When we asked them about this, they said that at the time the act was drafted, in 2006, methodologies actually didn't exist to combine workplace exposure with aggregate non-workplace exposure. The methodologies are in the process of being developed now.
From our point of view, if you can determine—thanks to your label conditions—that the workplace exposure of a worker is just below what you consider to be a safe level for the pesticide to be approved, and you then ignore a small amount of non-workplace exposure the person comes in contact with as well, you've really missed the opportunity for a more precautionary approach.