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26 February 2021

CRRU and stewardship: crunch time

TECHNICAL | PPC102 MARCH 2021

As we pass the five-year mark of rodenticide stewardship, BPCA’s Communications Officer Kat Shaw takes a look at where the regime is at and where it’s going.

crru-and-stewardship

SPEED VIEW:

  • Rodenticides were targeted by the EC, putting our toolkits at risk
  • CRRU implemented a stewardship scheme to guide future use of rodenticides in the UK
  • Proof of competence at point of sale is now mandatory for professional use products
  • Among groups of rodenticide users, pest technicians lead the way in knowledge of products and actives
  • Findings for the last five years will be given to HSE for review.

In 2015, the Health and Safety Executive (HSE) presented the pest management industry with a clear choice: adopt stewardship over rodenticide products or lose them.

When the stewardship regime began, the government set a five-year target for improvement and indicated that it would review the regime at that point.

With the five years now up, it’s a good time to look at the regime, how it began, what it has accomplished and what the future might hold for rodenticide use in the UK.

Background

In 2011, the European Commission (EC) reviewed all biocides including rodenticides, which had failed environmental risk assessments, and there was particular concern about the primary and secondary poisoning of non-target species such as barn owls.

As a result, they were put up as candidates for substitution, which was a polite way of saying that they wanted to ban these products as soon as possible.

However, with no alternatives on the market, it wasn’t feasible to ban them outright and protect public health and safety at the same time.

In 2012, HSE began asking stakeholders for opinions on options for mitigating the environmental risk of rodenticides.

Upon consultation, they found that it was necessary for the groups using these pesticide products to demonstrate that they could be used safely if continued use was to be an option.

It was decided that any future use of rodenticides specifically outside buildings would need stewardship involving all main rodenticide user groups, including pest control professionals.

As a result, the Campaign for Responsible Rodenticide Use (CRRU) was tasked with implementing the delivery of a stewardship regime.

They were asked to ensure the safe and responsible use of primarily second-generation anticoagulant rodenticides (SGARs). However, the principles were also applied to first-generation (FGARs).

If this could not be achieved, HSE would have the option to introduce more stringent regulation, such as further restrictions on who can use professional rodenticides and where they can be applied.

After much negotiation, HSE published its high-level principles that laid out what the regime needed to accomplish and the targets for reducing wildlife exposure.

Not just any old ‘rat catcher’

The first hurdle that CRRU came across was the definition of a ‘professional’ pesticide user – many rodenticide products were labelled as ‘professional use only’, however there has never been a license requirement to carry out pest control.

In CRRU Chairman Dr Alan Buckle’s words, “Anyone could walk in off the street with a piece of headed paper saying ‘A N Other Pest Control’ and they were considered to be professionals.”

CRRU approached HSE with the idea of a licensing or certification scheme for pest management professionals in the UK, however that was not something HSE wanted to implement at that time. CRRU would have to develop a more voluntary scheme and use stakeholder support in the industry to deliver it.

It appeared that the key to this would be to implement some proof of competence at the point of sale.

“Anyone could walk in off the street with a piece of headed paper saying ‘A N Other Pest Control’ and they were considered to be professionals.”

Dr Alan Buckle, CRRU


A Code of Best Practice for Rodenticide Use was developed and published. This was a stepping stone for CRRU to set approved training courses, which anyone wanting to buy professional use rodenticides would need to take to gain certification - the proof of competency that was so key.

From 1 October 2016, all sellers of professional use rodenticides were prohibited from selling those products to anyone unable to provide this documentation or proof of competence under the stewardship regime’s conditions.

Remaining stocks of pre-stewardship rodenticides were used up and replaced by stewardship-authorised rodenticides. We’re all now familiar with the new labels that carry the legally-binding requirements from HSE specifying user certification and compliance with product label conditions of use.

The next review

In 2016, the EC did another review of rodenticides, which resulted in changes to how people could bait for prolonged periods.

CRRU published the first set of guidance on permanent baiting in 2017, which at the time was subject to some debate.

The old ‘just in case’ approach to setting permanent baits that many pest controllers had been used to was no longer allowed under the CRRU Code of Best Practice.

Permanent baiting was now strictly limited to sites with a high potential for reinvasion when other control methods have proven insufficient.

The following year, for the first time, all suppliers of professional-use rodenticides to pest controllers, farmers and gamekeepers were required to register with Basis as part of the new Point-of-Sale audit process.

Put simply, the audits were a check on whether or not any outlets selling professional use products were asking for proof of competence.

Disruption due to Covid-19 in 2020 meant that a remote audit process had to be devised so that stewardship could continue uninterrupted.

Owl liver residue tests

The barn owl is the chosen sentinel species for the environment in the UK and levels of anticoagulant residues in the livers of UK barn owls are monitored annually.

HSE wants to see a significant decline in the proportion of barn owls carrying rodenticide residues and a reduction in the concentration of residues in owls’ bodies due to stewardship implementation.

So far, results show that the residue levels in barn owls are stable, and this is both good news and bad news. The good being that the levels haven’t increased, but neither have they decreased, which we would hope to see.

Although at first, this appears as though permanent baiting reduction hasn’t had an effect on these levels, CRRU believes that any changes in these levels would take place slowly.
Stewardship wasn’t fully implemented until 2018/2019, so biological delays may mean that residue levels have not yet been positively affected by a reduction in permanent baiting.

CRRU also studies the breeding success of selected barn owl populations to determine impacts of rodenticide use.

CRRU says that year on year, although there is a significant fluctuation in how barn owls breed (driven by prey availability and the weather) patterns have in no way been driven by rodenticide residues.

The current state of play

With five years’ worth of monitoring programmes completed, CRRU will be delivering its findings to a government oversight group.

A second five-year review should have begun at the start of this year, but due to Covid-19 this has currently been delayed until spring 2021.

There are six areas in which the government asks CRRU to provide monitoring information:

  • Environmental impact
  • Whether rodenticides are effective
  • Resistance monitoring
  • Awareness using the Knowledge, Attitude and Practice (KAP) survey
  • Point-of-sale information
  • Training.

In all areas of the KAP survey, CRRU found that pest controllers have led the way among groups of rodenticide users.

When it came to the knowledge of brands, active substances and other important information related to rodenticide users, pest professionals could answer questions more thoroughly than gamekeepers or farmers.

Pest technicians were also more likely to be involved in a Continuing Professional Development Scheme (CPD).

In all areas of the KAP survey, CRRU found that pest controllers have led the way among groups of rodenticide users.

However, the survey has shown that knowledge among all three groups has improved during the stewardship regime, which is a very positive trend.

CRRU is currently in discussions with HSE regarding how the review will take place, but the outcome is certainly going to depend on the information gathered about those six points above.

Potential outcomes from the review might include improvements to training and awareness, changes to who approved users are, further regulation on how they’re used or where they can be applied or revoking the use of certain products.

Would you like to know more?

You can watch Dr Alan Buckle talk stewardship at PestExtra in March. You’ll even have the opportunity to ask him any of your stewardship-based questions.

pestex.org/agenda

Source: PPC102

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