Farmers and growers using anticoagulant rodenticide products in their operations will need to be trained and certified as competent in their use under new rules which start to be phased in from April this year.
Anyone wishing to purchase anticoagulant rodenticides in more than amateur pack sizes will soon require a certificate of competence to do so. Members of some approved farm assurance schemes have additional time to obtain certification, while those choosing not to complete training can always use a professional pest controller.
Rodent control is an unglamorous but essential part of everyday farming operations. Although, failure to get it right can have implications for the health of those living and working on the units and of the livestock under their management, as well as the safety and wholesomeness of food products leaving the farm. It is estimated some 50% of farm fires in the UK can be attributed to rats gnawing electrical cables, while a recent Bayer survey found rodent damage to seasonal machinery such as combine harvesters in store can be a costly problem.
However, there is growing concern about the toxicity of the anticoagulant rodenticides which account for most of the baits used in the UK, as well as rodent resistance to some of these active ingredients and their effect on the environment, particularly to raptor species at the top of the food chain.
The EU Biocides Regulation (BPR) of 2012 introduced new authorisation procedures for biocidal products including anticoagulant rodenticides. The toxicity of these products and their residues in wildlife could have led to these products being withdrawn from the market for outdoor use altogether. But the Health and Safety Executive (HSE), which is responsible for implementing the BPR in the UK, realised there were no effective alternatives to anticoagulant rodenticides in controlling rats and mice.
Now, HSE, in consultation with the industry, has introduced a UK Rodenticide Stewardship Regime, which aims to restrict the availability of these poisons to ensure they are used responsibly in order to protect their efficacy for as long as possible – while not adversely affecting non-target species such as owls, which may consume poisoned rodents.
Under the new regime, all anticoagulant products on the market will have to have their market authorisations renewed. From April 2016, authorised products will carry new ‘stewardship conditions’ labelling. As of April 2016, users, including farmers, gamekeepers and professional pest controllers, will only be able to buy the stewardship label products if they hold a certified proof of competence or are a member of an approved farm assurance scheme.
Old-label products (remaining stocks) which do not require proof of competence will be available for purchase until October 1, 2016, and can be used up until March 31, 2017. It will be illegal to use old-label products from March 31, 2017. However, rodenticide users should be aware there is no guarantee large amounts of ‘old-label’ remaining stocks will be available beyond April 2016, and they may require access to rodenticide with ‘stewardship conditions’ long before October 1, 2016.
Farmers and growers have four options:
Source: Campaign for responsible rodenticide use (CRRU)
The cross-industry Campaign for Responsible Rodenticide Use (CRRU) is in the forefront of work to ensure the new rules are communicated to all users, are effective, and reduce wildlife residues. Its objective, following discussions with farm assurance schemes, is to bring their standards into alignment with the CRRU Code of Best Practice (CoBP) before the end of December 2017. Beyond December 2017, such CoBP-aligned schemes will continue to provide proof of competence for purchase of professional rodenticide products.
Members of assurance schemes which have not come into alignment will not be able to use their membership for rodenticide purchases beyond the end of December 2017. Anyone who is neither trained nor in a farm assurance scheme will only be able to purchase up to 1.5kg of these rodenticides in more expensive ‘amateur’ packs from October this year. They may, of course, use the services of a professional pest control contractor employing technicians who possess the approved certificates.
Richard Moseley, technical manager at rodenticide manufacturer Bayer, describes the changes as a ‘last chance saloon’ for the pest control sector to demonstrate it can use these poisons responsibly.
If the stewardship measures are not shown to be effective, the products could be further restricted or even withdrawn, he says.
“This is a very serious issue, and needs the co-operation of all major users – professional pest controllers, farmers and gamekeepers.
“It is no longer good enough just to put down poison at the first sign of rodent activity, and persist in the belief full bait boxes means the problem is being dealt with – a holistic approach is needed. Measures must be taken to prevent non-target rodents from accessing the poison, and to stop the bodies of both target and non-target rodents getting into the environmental food chain so residues do not accumulate in predatory species.”
Emma Hamer, senior plant health adviser with the NFU, which is a CRRU stakeholder, believes most farmers are aware of the forthcoming changes in the availability of rodenticides. She concedes, however, a minority of farmers who are neither members of a farming union nor in an assurance scheme may be caught out by the changes.
But the phased withdrawal of non-stewardship label rodenticides from April will alert them to the new measures. At worst, they will still have access to the amateur-sized packs of the same active ingredients, although these will be more expensive.
There is a need for a change of mindset over rodent control, she says – it is no longer acceptable to use permanent bait boxes and assume the problem is solved. Mrs Hamer says: “Farmers must carefully assess the risk of rodent activity on their units, and take actions to prevent it, using rodenticides as a last resort.”
A small number of farmers may resent the changes and what they see as additional red tape, but the risk of losing the anticoagulant rodenticides far outweighs these objections, she adds. Anyone unwilling to undergo the training to obtain a certificate of competence can always outsource the work to a professional pest controller, she advises.
Charles Phillips is divisional director of Barrettine Environmental Health, which supplies pest control products and training to professional pest controllers. His business fully supports the CRRU approach and its best practice guidelines which stress rodenticides are just one method of pest control, and must be used in tandem with good housekeeping, rodent proofing and trapping, rather than just as the default option. Barrettine’s training underlines the need for holistic site risk assessments which consider all alternative methods of rodent control before reaching for the poisons.
“It is unacceptable to use second generation products where housekeeping is not up to standard,” Mr Phillips says. “Alternatives must be considered – and can be discarded if thought these will be ineffective – with these considerations being documented as part of a risk assessment. Rodent proofing measures, tidy sites which are less attractive to rodents and trapping are all methods which can reduce rodent populations.
“There is currently no alternative to the anticoagulant rodenticide products on the market. Therefore a balance is needed to protect both the efficacy of these products and the non-target species in the wider environment, while achieving the standards of control needed.”
Professional pest controller Matthew Benton says he is often surprised the care and attention to detail farmers put into protecting their growing crops in the field is not continued once the harvested crop is in store.
His business, MKB Environmental Services, based near Lincoln, has a large number of agricultural and rural business customers and is a signed-up supporter of the CRRU codes of practice. Mr Benton believes firmly rodenticides are just part of the answer to controlling these pests, together with actions to make stores and buildings rodent proof, restrict available food and water sources and keep working areas clean and tidy.
Stewardship measures are vital, he says: “Without tighter controls, occasional users may be tempted to use larger dose rates and leave rodenticide baits out for longer than is needed, posing a greater risk to non-target species and the wider environment.”
He adds the stewardship scheme could potentially see more tools and products available for rodent control. “As users of these tools and products, we have a responsibility to ensure they do not pose a greater risk to non-target species and the environment.
“Also rodenticides are expensive products – farmers can get better control for less money with a more holistic approach to their pest control.”
Mr Benton believes the new rules are likely to deter those who put out bait at the first sight of a rodent, rather than adopting an ongoing risk assessment approach.
He has also noticed that more farmers are outsourcing their pest control to businesses such as his in the same way they employ an agronomist for crop protection advice.
“Using an expert who has vast experience and is up-to-date with the necessary regulations ensures the control measures are successful, while the farm business is fully compliant with its assurance scheme requirements and the farmer is free to make more effective use of his time and expertise.”