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AgVetLink February 2005

TNP status under HSNO Act

Processing registration applications for trade name products

The ACVM Registration Product Data Sheet requests the applicant to supply the TNP’s status under the HSNO Act. Instead, some applicants have been referencing similar TNPs approved under the HSNO Act. This is not acceptable. The HSNO approval is based on the entire formulation and uses, not just the active ingredient (AI). Consequently, even if the proposed TNP has the same formulation type, AI and AI concentration for a TNP approved under the HSNO Act, it cannot be assumed that they have the same hazardous profile.

In addition, if the proposed TNP (even if the formulation is the same) has different uses that may not have been considered before (e.g. aerial application as opposed to ground application), then this may also mean a new approval is required under the HSNO Act.

Under such circumstances, the applicant must obtain advice from ERMA on the product’s status. Once this has been determined, the ACVM Group can consider issuing the certificate of registration. This may also apply to variations to registrations such as changes in formulation.

Where the proposed TNP has the same formulation and uses as that in the TNP approved under the HSNO Act, the ACVM Group normally considers the proposed TNP to have the same hazard profile and no determination is required by ERMA.