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Brazil - Final Regulatory Action
Trichlorfon CAS number:
52-68-6
Date circular:
12/12/2011

Chemical name: Phosphonic acid, (2,2,2-trichloro-1-hydroxyethyl)-, dimethyl ester

Final regulatory action has been taken for the category: Pesticide

Final regulatory action: The chemical is Banned

Use or uses prohibited by the final regulatory action:

All uses as pesticide for agricultural purposes.

Pesticide use or uses that remain allowed:

None.

The final regulatory action was based on a risk or hazard evaluation: Yes

Summary of the final regulatory action:

In August 2010, the Committee on Pesticide Reassessment, composed by the National Health Surveillance Agency (ANVISA), the Ministry of Agriculture, Livestock and Food Supply (MAPA), and the Brazilian Institute of Environment and Renewable Natural Resources (IBAMA) decided to cancel the registers of all technical products and formulated based on trichlorfon active ingredient, including its domestic usage. So, the production, trade and import of trichlorfon had been banned. The decision was based on the Technical Note of Toxicological Reassessment on Trichlorphon prepared by ANVISA.
Before that, in 2009, during the process of Environmental Reassessment, the agrochemical companies of products made of this active ingredient expressed no interest in supplying information or studies that could prove that there is no danger on the evidence of adverse effects of Trichlorfon to the environment, to non-target organisms, birds, bees and aquatic organisms. So, the reassessment process could not be completed and IBAMA has cancelled all assessment of Trichlorfon products.

The reasons for the final regulatory action were relevant to: Human health

Summary of known hazards and risks to human health:

Trichlorfon is an organophosphate insecticide that has high potential to cause neurotoxic effects (neurobehavioral and neurochemical features), anatomical and cell damage in humans. The main mechanism of neurotoxicity of trichlorfon is the acetylcholinesterase inhibition, an essential enzyme for the normal transmission of nerve impulses. It can overstimulate the nervous system causing nausea, dizziness, confusion, and at very high exposure, respiratory paralysis and death.
Trichlorfon is also genotoxic, immunotoxic, carcinogenic, teratogenic, causes adverse effects on reproduction and on the endocrine system. Experimental studies indicate that trichlorfon, as well as dichlorvos, its main metabolite, lead to depletion of the immune response.
These immunosuppressive effects may increase the susceptibility of individuals exposed to trichlorfon on infections by pathogens and increase the cases of neoplasms.
Many cases of intoxication of farm workers are reported and population living nearby the areas with extensive use.
Comparative studies between intoxicated humans and animals after acute exposure to trichlorfon, have shown that the neurotoxic effect is more aggressively in humans than in animals, thus conforming a situation susceptible to ban this active ingredient in Brazil.
The Brazilian Law no 7.802/89, in Article 3 establishes that a pesticide may be banned when : (...), (c) it is teratogenic, mutagenic or carcinogenic according to updated results experiences of the scientific community; (d) when it causes hormonal disorders, damages to the reproductive system, according to updated procedures and experiences in the scientific community; (...) , (f) when it causes damage to the environment.
Source: Technical Note of the Toxicological Reassessment on Trichlorphon - ANVISA (National Health Surveillance Agency)/Brazil -
Link: http://portal.anvisa.gov.br/wps/wcm/connect/c96ef900474594839c0adc3fbc4c6735/Nota+t%C3%A9cnica.pdf?MOD=AJPERES

Expected effect of the final regulatory action in relation to human health:

Do not use, trade nor import the product for agricultural purposes.
Prohibited: research in all stages, production, package, labelling, transport, transit, importation and exportation.

Date of entry into force of the final regulatory action: 18/08/2010