BPCA has been consulted on the thorny issue of public area use of rodenticide, and the contentious requirement to signpost the area to bystanders.

As the UK body with responsibility for rodenticide authorisation, Chemicals Regulation Directorate (CRD), is working through the renewal authorisations for anticoagulant rodenticides and is finalising the renewal certificates for these products.

Although most of the conditions of authorisation were agreed at the Biocidal Products Committee in July 2016, for certain issues there is flexibility at a national level on what should appear on the SPC (Summary of Product Characteristics) and product label.

The EU guidance document gives the following instructions on completing the General Directions for Use section of the professional use rodenticide SPC:

[If national policy or legislation require it] When the product is being used in public areas, the areas treated should be marked during the treatment period and a notice explaining the risk of primary or secondary poisoning by the anticoagulant as well as indicating the first measures to be taken in case of poisoning must be made available alongside the baits.

EU guidance document

Until now all rodenticide products (both professional and non-professional) authorised under the EU Biocides Regulations have needed to carry the following phrases on the SPC and product label:

“For products to be used in public areas the following safety precaution shall be carried on the label, packaging or accompanying leaflet:

• when the product is being used in public areas, the areas treated must be marked during the treatment period and a notice explaining the risk of primary or secondary poisoning by the anticoagulant as well as indicating the first measures to be taken in case of poisoning must be made available alongside the baits.
• when tamper-resistant bait stations are used, they should be clearly marked to show that they contain rodenticides and that they should not be disturbed.”

The phrases in italics have caused confusion and have been criticised by BPCA, rodenticide users and suppliers alike.

With some national flexibility available, HSE asked BPCA to respond with comments on the suitability of the label requirement.

The Association’s view is that the phrase in the grey box above should not be used.

Our reasoning is as follows:

1. We believe that by signposting the location of ‘live’ baits, it will encourage passers-by to disturb, interfere with, damage or even steal the bait. This will have knock-on effects on treatment efficacy, potential harm to non-target animals, possible secondary poisoning, and obviates the stewardship chain of custody. The notice will have the effect of drawing attention to the bait locations, encouraging vandalism, theft and disturbance of the environment
2. Live bait use outdoors should be limited to trained professional users only. Trained Professional Users (TPUs) read and follow the label, carry out appropriate risk assessments, and have access to MSDS, poisoning and other important information. Amateurs annexing bait via theft from signposted locations have no access to product labels, no training in its use, and are very likely to misuse it. In an urban setting, we believe the likelihood of misuse and risk to the environment is significantly higher from amateur use
3. We would further propose that HSE increases scrutiny of non-professional use products which are often mis-used outdoors, causing many orders of magnitude more harm than any potential issues from trained professional users utilising products in an urban environment (ie professional pest managers).

We await further guidance from HSE, but in the meantime always follow the label instructions and consult your supplier if unsure.

Simon Forrester
Chief Executive

8 November 2017  |  BPCA Online