PPC117 | Technical

The CRRU code of best practice has seen its latest revision, with various changes and updates. Some of the changes aren’t relevant to pest control but other items are important for us to review and understand.

3.8 

Availability of First Generation Anticoagulant Rodenticides (FGAR) baits in the UK (Coumateteryl, warfarin, etc).

The only remaining product with an FGAR active ingredient is a contact foam. With this in mind, the document recognises this and so has redacted the previous guidance on its use.

Availability of Second Generation Anticoagulant Rodenticides (SGAR) baits for use away from buildings. New statement says “From the 1 January 2025, no products containing a second generation anticoagulant as an active ingredient may be used away from a building.”

Clarification on use pattern of cholecalciferol baits

This has been updated – “Some baits containing cholecalciferol are permitted for use against wood mice (Apodemus sylvaticus). However, they are not authorised for use against the closely related yellow-necked mouse (A. flavicollis) and care should be exercised to ensure that this species is not inadvertently exposed to cholecalciferol baits.”

This is basically saying that we must identify the species of “field mouse” in a targeted effort and to not make assumptions.

In any situation, it is important to identify the rodent species we are trying to control, especially with mice, and not just make assumptions between house mouse, and the varied field mouse species. Wildlife cameras and live sightings will be useful for this process.

“Some products containing cholecalciferol are authorised for use in ‘open areas’ and at ‘waste dumps’.”

If treatments are needed in areas where SGARs are not allowed, this product, label requirements dependent, may be a suitable alternative.

Proper caution still needs to be applied when considering any primary poisoning risks, as always. It is vital not to use the product with a false sense of security. The prevention of primary access to the bait, from non-targets, is still of the utmost importance.

Cholecalciferol is a fantastic option when considering reducing the possibility of secondary poisoning. However, there is no “antidote” and the LD50 is lower (lower being bad!) in terms of grams per kilo needed to affect a non-target species, such as a dog.

5.3

This section gives some clarification on what certain definitions mean, specifically, “in and around buildings”, what a building actually is and waste dumps.

In brief, the term in and around buildings is quite straightforward when we understand the definition of a building. The updated code describes a building as a FIXED structure that forms an enclosure and protects from the elements.

For an example of something that is not a building, we would be looking at structures such as movable sheds and pens (not fixed) and open barns storing hay (not enclosed).

Make sure you take a look at all the definition updates so that you understand what your restrictions are.

Q&A

Can I still burrow bait?

In short, yes and no. As we always reiterate, when using pesticides, the label is key and a piece of guidance you have to follow legally. So if a label says you can burrow bait, you can. If it doesn’t, then you can’t!

However, if a label states that you can apply the product to burrows but the area to be treated is an “open area” then no, you cannot use an SGAR. You would need to source a product that allows burrow baiting AND use in open areas.

As mentioned above, there is a cholecalciferol product available that allows burrow baiting and can be used in open areas.

As always, if you have a product that allows burrow baiting, make sure you follow all safety advice and make sure that the product is not at risk of non-target animals gaining access.

Who makes these changes and are they law?

Law surrounding chemicals in the UK is regulated by the Health and Safety Executive (HSE). All manufacturers of chemicals have to go through a rigorous application process to authorise their products for use in the UK – this consists of field testing, lab testing and the payment of fees for assessment by the HSE.

Part of this process is the approval of the labels associated with the pesticide. This authorisation is governed by the Biocidal Product Regulation (BPR) and the Control of Pesticides Regulations (COPR) – the latter being superseded, eventually, by the BPR.

And so, this is the regulation that makes the label a legal requirement to follow.

In terms of the CRRU code, rodenticide labels state that the user must comply with the CRRU code of best practice. This makes it a legal requirement to adhere to the CRRU code!

Changes to the code are implemented by the working groups associated with the efforts to reduce residues of rodenticide in non-target animals, most notably the barn owl. This is all done with the oversight of government workgroups reporting back to the HSE.

GOT QUESTIONS?

If you’re a BPCA member and you’ve got questions around the CRRU code and what it means, get in touch.

technical@bpca.org.uk