Proposed Registration Decision PRD2025-12, 3-Chloro-4-methylaniline hydrochloride and DRC-1339

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• Pest Management Regulatory Agency
• 17 October 2025
• ISSN: 1925-0886 (PDF version)
• Catalogue number: H113-9/2025-12E-PDF (PDF version)

Summary

Table of contents

• Proposed registration decision for 3-chloro-4-methylaniline hydrochloride
• What does Health Canada consider when making a registration decision?
• What is 3-chloro-4-methylaniline hydrochloride?
• Health considerations
• Environmental considerations
• Value considerations
• Measures to minimize risk
• Next steps
• Other information

Proposed registration decision for 3-chloro-4-methylaniline hydrochloride

Health Canada's Pest Management Regulatory Agency (PMRA), pursuant to subsection 28(1) of the Pest Control Products Act, is proposing registration for the sale and use of DRC-1339 Technical and DRC-1339, containing the active ingredient 3-chloro-4-methylaniline hydrochloride, for control of corvids in relation to greater sage-grouse recovery.

3-Chloro-4-methylaniline hydrochloride is currently registered for the control of corvids to protect greater sage-grouse populations in Alberta on an emergency basis.

An evaluation of available scientific information found that, under the approved conditions of use, the health and environmental risks and the value of the pest control products are acceptable.

This summary describes the key points of the evaluation, while the Science Evaluation in the full version of Proposed Registration Decision PRD2025-12, 3-Chloro-4-methylaniline hydrochloride and DRC-1339 provides detailed technical information on the human health, environmental and value assessments of 3-chloro-4-methylaniline hydrochloride and DRC-1339.

What does Health Canada consider when making a registration decision?

The key objective of the Pest Control Products Act is to prevent unacceptable risks to individuals and the environment from the use of pest control products. Health or environmental risk is considered acceptable^{Footnote 1} if there is reasonable certainty that no harm to human health, future generations or the environment will result from use or exposure to the product under its proposed conditions of registration. The Act also requires that products have value^{Footnote 2} when used according to the label directions. Conditions of registration may include precautionary measures on the product label to further reduce risk.

To reach their decisions, Health Canada's PMRA applies modern, rigorous risk-assessment methods and policies. These methods consider the unique characteristics of sensitive subpopulations in humans (for example, children). They also consider the unique characteristics of organisms in the environment. These methods and policies also consider the nature of the effects observed and the uncertainties when predicting the impact of pesticides. For more information on how Health Canada's PMRA regulates pesticides, the assessment process and risk-reduction programs, please visit the Pesticides and pest management portion of Canada.ca.

Before making a final registration decision on 3-chloro-4-methylaniline hydrochloride and DRC-1339, Health Canada's PMRA will consider any written comments received from the public directly related to the proposed decision in consultation document PRD2025-12.^{Footnote 3} Health Canada will then publish a Registration Decision^{Footnote 4} on 3-chloro-4-methylaniline hydrochloride and DRC-1339, which will include the decision, the reasons for it, a summary of comments received on the proposed registration decision and Health Canada's response to these comments.

For more details on the information presented in this summary, please refer to the Science Evaluation of PRD2025-12.

What is 3-chloro-4-methylaniline hydrochloride?

3-Chloro-4-methylaniline hydrochloride is an avian nephrotoxin. It is the active ingredient in DRC-1339, a product used to manage corvid populations in greater sage-grouse habitat in order to protect greater sage-grouse nests from predation by corvids (for example, ravens, crows, and magpies).

Health considerations

Can approved uses of 3-chloro-4-methylaniline hydrochloride affect human health?

DRC-1339, containing 3-chloro-4-methylaniline hydrochloride, is unlikely to affect your health when used according to proposed label directions.

Potential exposure to 3-chloro-4-methylaniline hydrochloride may occur when handling and applying the end-use product and handling baited eggs. When assessing health risks, two key factors are considered: the levels at which no health effects occur and the levels to which people may be exposed. The levels used to assess risks are selected to protect the most sensitive human population (for example, children and nursing mothers). As such, sex and gender are taken into account in the risk assessment. Only uses for which the exposure is well below levels that cause no effects in animal testing are considered acceptable for registration.

Toxicology studies in laboratory animals describe potential health effects from varying levels of exposure to a chemical and identify the dose level at which no effects are observed.

In laboratory animals, the technical grade active ingredient, DRC-1339 Technical, was of low acute toxicity via the dermal route of exposure, of high acute toxicity via the oral route of exposure, and expected to be of high acute toxicity via the inhalation route of exposure. It was corrosive to the eyes and skin, and caused an allergic skin reaction. The acute toxicity profile of the end-use product DRC-1339, containing 3-chloro-4-methylaniline hydrochloride, is equivalent to that of the technical grade active ingredient. Consequently, the signal word "DANGER" and hazard statements "POISON", "CORROSIVE TO EYES AND SKIN" and "POTENTIAL SKIN SENSITIZER" are required on the labels for both the technical grade active ingredient and the end-use product.

In addition to acute toxicity studies, registrant-supplied long-term (lifetime) oral toxicity tests and genotoxicity testing, as well as information from the published scientific literature, were assessed. Following repeated oral dosing in mice and rats, administration of surrogate test material 3-chloro-4-methylaniline resulted in decreased body weight in mice and rats and effects in the spleen and liver of rats. Results from testing indicate that 3-chloro-4-methylaniline hydrochloride is not mutagenic.

The toxicology database for 3-chloro-4-methylaniline hydrochloride did not contain the full array of studies normally required for pesticide registration. Rationales to waive additional toxicity testing were accepted based on the restricted-class designation, limited use and stringent use conditions of the associated end-use product, as well as the elaborate and significant risk mitigation measures for handlers and applicators included on the end-use product label. Although there were limited toxicity data available, the supporting toxicological database was considered to be adequate for the current assessment.

Occupational risks from handling DRC-1339

Occupational risks are not of health concern when DRC-1339 is used according to the proposed label directions, which include protective measures.

Workers mixing, loading and injecting DRC-1339 into chicken, turkey or duck eggs, and workers handling baited eggs can be exposed to residues of 3-chloro-4-methylaniline hydrochloride through direct skin contact or through inhalation. Therefore, the label specifies that anyone mixing, loading and injecting DRC-1339 into the eggs must wear coveralls over long-sleeved shirt, long pants, chemical-resistant gloves, socks, chemical-resistant footwear, protective eyewear (goggles or face shield) and respirator. Workers handling the baited eggs must wear a long-sleeved shirt, long pants, chemical-resistant gloves, socks and shoes. Taking into consideration the restricted marketing-class designation of the end-use product, the required personal protective equipment, restrictions on the location where DRC-1339 can be handled, and the product being confined inside an egg, the risks to these individuals from exposure to 3-chloro-4-methylaniline hydrochloride are not of health concern when the end-use product is used according to the proposed label directions.

Health risks in residential and other non-occupational environments

Risks in residential and other non-occupational environments are not of health concern when DRC-1339 is used according to the proposed label directions.

DRC-1339 is a restricted-class end-use product, for use only in areas where corvid populations are to be controlled in relation to greater sage-grouse recovery. Furthermore, the general public is not permitted to enter baited sites. As such, residential exposure is not expected.

Health risks to bystanders

Bystander risks are not of health concern when DRC-1339 is used according to the proposed label directions.

DRC-1339 is injected into hard-boiled eggs. Bystander exposure when workers are injecting or handling the eggs is not expected due to restrictions on the location where DRC-1339 can be handled.

Environmental considerations

What happens when 3-chloro-4-methylaniline hydrochloride is introduced into the environment?

When used according to label directions, the environmental risks associated with the use of 3-chloro-4-methylaniline hydrochloride and its associated end-use product, DRC-1339, to control corvids in greater sage-grouse habitat are acceptable.

3-Chloro-4-methylaniline hydrochloride will enter the environment when DRC-1339 is used in egg baits to control corvids (for example, ravens, crows, and magpies) preying on greater sage-grouse (Centrocercus urophasianus) nests in Alberta. The greater sage-grouse is an endangered species in Canada, with fewer than 100 individuals left in Alberta. Corvids have been identified as a significant predator of greater sage-grouse eggs and chicks.

In order to control corvids, 3-chloro-4-methylaniline hydrochloride is injected into hard-boiled eggs which are then placed in dummy nests for a short period of time in the spring during the greater sage-grouse nesting season. A maximum of 18 eggs per site is permitted. Limited environmental exposure is expected from the proposed use.

3-Chloro-4-methylaniline hydrochloride is toxic to aquatic organisms; however, exposure to the aquatic environment is not expected from the proposed use. 3-Chloro-4-methylaniline hydrochloride is also toxic to non-target birds and mammals if they consume high enough quantities. Since corvids have been identified as a significant source of predation on greater sage-grouse eggs, they are expected to be the main species exposed to 3-chloro-4-methylaniline hydrochloride. Population-level effects in non-target species are not expected due to limited use of 3-chloro-4-methylaniline hydrochloride in terms of area, duration and amount used.

After a scientific review of the available information, Health Canada has concluded that the environmental risks from the proposed use of 3-chloro-4-methylaniline hydrochloride are acceptable when used according to the label directions.

Value considerations

What is the value of DRC-1339?

DRC-1339 has value as a management tool to reduce corvid predation on critically endangered greater sage-grouse (Centrocercus urophasianus) and protect this species from extirpation in Canada.

Greater sage-grouse was listed as endangered in Alberta in June 2000, and an Emergency Protection Order for greater sage-grouse has been in effect since 2014. Corvid predation of nests is a key risk factor in greater sage-grouse survival, with over 63% of monitored greater sage-grouse nests depredated by corvids in 2010-2013. DRC-1339 provides an essential tool as there are no alternative corvid control products registered in Canada. Without avian predator control, it is expected that greater sage-grouse would be extirpated from Alberta within 3 to 5 years.

Measures to minimize risk

Labels of registered pesticide products include specific instructions for use. Directions include risk-reduction measures to protect human and environmental health. These directions must be followed by law.

The key risk-reduction measures being proposed on the label of DRC-1339 Technical and DRC-1339 to address the potential risks identified in this assessment are as follows.

Key risk-reduction measures - Human health

To reduce the potential exposure of workers to 3-chloro-4-methylaniline hydrochloride through direct skin contact or inhalation, workers mixing, loading and injecting DRC-1339 into poultry eggs must wear coveralls over long-sleeved shirt, long pants, chemical-resistant gloves, socks, chemical-resistant footwear, protective eyewear (goggles or face shield) and respirator. Workers handling the baited eggs must wear a long-sleeved shirt, long pants, chemical-resistant gloves, socks and shoes. The label also restricts the general public from entering baited sites.

Key risk-reduction measures - Environment

• A "toxic to aquatic organisms" label statement based on the inherent toxicity of 3-chloro-4-methylaniline hydrochloride.
• A "toxic to birds and small wild mammals" label statement.

Next steps

Before making a final registration decision on 3-chloro-4-methylaniline hydrochloride and DRC-1339, Health Canada's PMRA will consider any written comments received from the public that are directly related to proposed decision PRD2025-12, such as comments directed to the science evaluation, in response to this consultation document up to 30 days from the date of publication (by 16 November 2025) of PRD2025-12. If more time is required to provide comments, a request for an extension of up to 15 days can be made before the end of the original 30-day consultation period. Please forward all comments to PMRA Publications, through the Public Engagement Portal (Public Engagement Forms – Consultation Comment). Health Canada will then publish a Registration Decision, which will include its decision, the reasons for it, a summary of comments received on the proposed decision and Health Canada's response to these comments.

Other information

When Health Canada's PMRA makes its registration decision, a Registration Decision on 3-chloro-4-methylaniline hydrochloride and DRC-1339 (based on the Science Evaluation Section of PRD2025-12) will be published. In addition, the test data referenced in PRD2025-12 will be available for public inspection, upon application, in the PMRA's Reading Room. For more information or if you have questions, please contact the PMRA's Pest Management Information Service.