TECHNICAL | PPC112 September 2023
PRESS RELEASE
A press release was posted by the UK Rodenticide Stewardship Regime (CRRU) on Monday, 12 June 2023.
ENDING USE OF SECOND-GENERATION ANTICOAGULANT RODENTICIDES BROMADIOLONE AND DIFENACOUM AWAY FROM BUILDINGS
Press Release: Mon 12 June 2023
Legal authorisation is being withdrawn for open area and waste dump use for the only two second generation anticoagulant rodenticides (SGARs) currently allowed to be used that way, bromadiolone and difenacoum. This will take effect in July next year.
The change was instigated voluntarily by the Campaign for Responsible Rodenticide Use UK, with support to make the necessary amendments from UK biocides regulator, the Health and Safety Executive (HSE). CRRU Chairman Dr Alan Buckle states that the change was a unanimous decision by all CRRU Directors to help meet rodenticide stewardship’s environmental targets.
“A primary factor leading to this is the stubbornly static incidence of rodenticide residues in around 80 per cent of barn owls, the HSE-nominated sentinel species for annual surveillance,” he explains. “This change will enable a single clear message about SGAR use: None of these products can be applied away from buildings.”
Sales of products containing bromadiolone and difenacoum for use in open areas and at waste dumps will cease on 4 July 2024. These products purchased on or before that date will be authorised for use in open areas and waste dumps until 31 December 2024. After that, it will be illegal to use any SGAR product to treat a rodent infestation not associated with a building.
Manufacturers will change product label instructions accordingly and will continue to promote the application of integrated pest management practices among all rodenticide users. The CRRU Code of Best Practice offers a range of effective methods for rodent management away from buildings, including elimination of harbourage, food and water; lethal non-anticoagulant baits; and trapping, shooting and dogs.
Policy statement: CRRU UK Board of Directors changes policy on use of anticoagulants in ‘open areas’ and at ‘waste dumps’
At the beginning of the UK Rodenticide Stewardship Regime the CRRU UK Board of Directors decided that manufacturers would not apply for authorisations for products containing the active substances brodifacoum, difethialone and flocoumafen to be used in ‘open areas’ and at ‘waste dumps’. This was because it considered that these high-potency anticoagulants were most likely to result in risk to wildlife when used in these scenarios. The CRRU board has now unanimously decided to extend this policy to products containing bromadiolone and difenacoum, thereby applying a consistent approach to all second-generation anticoagulant rodenticides (SGARs).
There are two reasons for this. The first is that the previously excluded SGARs bromadiolone and difenacoum contribute significantly to the total burden of SGAR residues found in UK wildlife, and at the initiation of the regime it was a critical requirement set upon CRRU UK by the regulatory agency, the Health and Safety Executive (HSE), to reduce all SGAR residues in wildlife. The second reason is that there has been a recent and sudden increase in exposure of wildlife to products containing brodifacoum. It is considered that such an apparently recent and widespread increase can only be explained by use of this substance, contrary to label instructions, in the open countryside.
The new CRRU policy will permit a clear message to be put out to all UK SGAR users: none of them can be used anywhere away from buildings and such use is illegal and may be subject to prosecution.
The CRRU Board took this decision after carefully considering the availability of alternatives and finding that options exist for those needing to control rodents in open areas and at waste dumps. These include chemical and non-chemical methods, as well as lethal and non-lethal techniques, so that unavailability of SGARs for use away from buildings need not be detrimental either to human and animal health or the rural economy.
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Ask CRRU UK
PPC Who runs CRRU UK?
CRRU CRRU decisions are made by a Board of Directors, one director coming from each of the fourteen CRRU funding member companies*.
The Board is guided by six CRRU stewardship Work Groups and by the CRRU Task Force of representatives from a wide range of stakeholder organisations.
PPC Who decided to change labels on bromadiolone and difenacoum to end their use away from buildings?
CRRU This decision was made voluntarily and unanimously by the CRRU Board.
PPC Doesn’t HSE normally tell you what should be on a rodenticide label? Would HSE have made the changes anyway?
CRRU Product label text is determined through dialogue between the applicant for an authorisation and the UK Competent Authority for Biocides, in this case, HSE. The text is specified on the product authorisation certificate.
CRRU does not know about, nor can it comment on, HSE’s intentions with respect to rodenticide authorisations.
PPC Why didn’t CRRU consult with professional rodenticide users about the change?
CRRU After seven years of rodenticide stewardship, environmental targets had not been met. It was decided by CRRU directors that change was urgently required.
PPC What classes as ‘in and around buildings’? Is there an official description? Are barns, silage pits, machine sheds and grain stores buildings for the purposes of the label?
CRRU This is a question to be discussed by the CRRU Best Practice Work Group. More information will be provided after those discussions.
“...it will be illegal to use any SGAR product to treat a rodent infestation not associated with a building.”
PPC These changes will affect farmers more than pest controllers. How are label restrictions enforced? Does anyone really get prosecuted for not following a label?
CRRU The label instructions, and failure to apply them, are enforced by HSE hse.gov.uk/biocides/enforcement.htm
Investigations may be carried out by Natural England and other agencies hse.gov.uk/pesticides/reducing-environmental-impact/wildlife/wildlife-incident-investigation-scheme.htm
Individuals are prosecuted when there is sufficient evidence to bring them to court.
PPC Why not just ban rodenticides from untrained users? That would stop wildlife from dying from rodenticides. People don’t read the label on their prescription medicine, so they won’t read it for rat poison.
CRRU It is the opinion of CRRU that removal of all authorisations for use of rodenticides by the general public would not “stop wildlife from dying from rodenticides”. HSE has not required such use to be included in the UK Rodenticide Stewardship Regime, coordinated by CRRU.
The regulatory foundation of all sales of rodenticides, and of chemicals more widely, is that labels are read and instructions on them are followed.
PPC From your research, how many barn owls have died from ingesting SGARs?
CRRU Very few barn owls are killed by SGARs, but that is not the point. UK wildlife, especially avian and mammalian predators and scavengers, is very widely contaminated by SGARs. This widespread exposure is a grave cause for concern and what the stewardship regime is required to reduce.
The barn owl is chosen as a ‘sentinel species’, whose levels of exposure are indicative of a number of species with similar ecology and behaviours.
PPC When label restrictions and non-chemical products are being scrutinised so much, is it really wise to be reducing our toolkit further?
CRRU The CRRU Directors took this decision after a great deal of careful consideration, including alternative options for control. It was felt that this change offered the best chance for CRRU to meet its environmental targets relating to wildlife contamination.
This in turn would help to protect the essential and most important use of SGARs, which is application ‘in and around buildings’.
PPC When is the next impact assessment for SGARs by HSE? Could they ban the use of SGARs altogether?
CRRU HSE has plainly said that, unless stewardship environmental targets are met, there will be a need to review who can use SGARs, how they are used and where they can be applied. The effectiveness of the UK Rodenticide Stewardship Regime has been under review by HSE since May 2021. A major review of all SGAR authorisations by HSE, the procedure known as ‘authorisation renewal’, is also ongoing.
CRRU cannot speculate on the future intentions of HSE. However, few regulatory jurisdictions have implemented an outright ban on SGARs, because it is widely accepted that safe and sufficiently effective alternatives do not currently exist. An outright ban would involve very substantial, and many would say unacceptable, risk of exposure of humans and animals to a wide range of serious diseases, carried either by the rodents themselves or by the parasites that live in or on them.
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