Rodenticides are now considered "reprotoxic"- What does this mean?
Tuesday 13th August 2019
Rodenticides can damage the unborn child. No news there? There's so much to consider around the reprotox ruling that I had to put it down on paper.
Read on for a little educational rant about pesticides, stewardship and professionalism.
So, the changes have been much mooted, chatted about in corridors of power with only the barest whispers escaping and then they rolled out quietly.
The concept of reprotoxicity was a bit of a surprise when it was mentioned to me back in 2015. I didn't think much of it at the time. I even made a joke "I suppose death is the ultimate contraceptive," not very funny at the time, not quite as funny as that now.
Rodenticides have been looked at by EHCA- that's the European Chemicals Agency. They are pretty important people that do amazing work across a mind boggling array of specialities. When they talk, we should listen. The data gathered on the effects of toxicity against developing foetuses has pushed the Committee for Risk Assessment to change the hazard status of rodenticides.
All rodenticides
Brodifacoum, Bromodiolone, Chlorophacinone, Coumateralyl, Difenacoum, Difethialone, Flocoumafen and Warfarin
Have been reclassified as "Toxic to Reproduction" if stronger than 30ppm (.003%) and some are "dangerous to organs (blood) through repeated exposure"
By the by, this change came into effect in March 2018. And as usual we have the six month transition period. Old labelled products without the reprotox warning should be used up by the end of the month. Keeping out of date products can lead to disastrous consequences- see here- Ipswich Crown Court Ruling- 2017. Be warned
This doesn't sound like a fundamental change but it has had its effects on the way that rodenticides are distributed.
All amateur-use rodenticides have been removed from distribution if stronger than 30ppm.
The cool thing is, the risk to human health from exposure to rodenticides is pretty minimal. I mean, how many pregnant women are munching on Bitrex-infused Octablox? BUT the unintended consequence of this change is that danger to wildlife has been markedly reduced. Where pest controllers' days and nights are largely preoccupied by not causing collateral damage to wildlife, the average homeowner with a rat might not be aware of the consequences of non-target species rodenticide exposure to the upward food chain.
Professional use can continue at professional levels. Amateurs have had their access to rodenticides restricted. This is something that a lot of pest control professionals have been calling for for a long time and largely we can view it as a good thing.
One active ingredient has been retained for the amateur-use market; Brodifacoum. This has led many a canny pest controller to avoid all Brod' products like the plague (excuse the pun) because if they actively avoid those products then they can be provably exonerated from non-target species fatalities that have been caused by amateur use.
All of this sounds like brilliant news but I have two caveats to add....
One little problem we have in this whole picture is the definition of a professional.
What makes a professional?
Well, apparently, in the eyes of the law, it means taking a one-day course "Safe use of Rodenticides." That makes you a professional. That proves competence. One day of THEORY. With no proof of practical application. With no auditing process to prove continuity of competence or application of learning. With no requirement for CPD or training refreshers. Really?!
To make things worse, there are no prerequisite learnings for someone to go on this course, the test is multiple choice and the passmark is 17 out of 25!
Yes, the bar has been moved, but not far enough.
If that hasn't annoyed you please bear this in mind. Even the low bar of passing a single day course brought enough howls of protest from the 'occasional rodenticide user' that our HSE-backed stewardship body (CRRU) arranged a derogation for anyone who is a member of a "stewardship-approved" farm assurance scheme (eg Red Tractor). So anyone who has been able to prove minimal responsible levels of animal husbandry is now also allowed to use professional-only pest control products. List of Schemes here
Now, Red Tractor is a great auditing body. Their audits are noticeably improving all the time. But, how have they been invited into the professional pest control tent? Raising animals and doing pest control are not the same area of expertise. Being an audited farmer doesn't make you a pest control professional. And yet professional-use products are still available to farmers with a Red Tractor stamp but with no formal pest control training. Am I the only person that thinks this situation is a bit strange?
To put this in perspective.
- There are 13,000 individuals in the UK who have attained that minimum level of 'professionalism'- Passing the (ONE DAY, multiple choice, cpd immune, theory based) Safe Use of Rodenticides course.
- Members of 'approved' farm assurance schemes? 97,000.
That's 97,000 people who don't have to inconvenience themselves with the rigor of a one day course who can use professional-only rodenticides.
It's high time we made the distinction between someone who is a professional, safe with rodenticides, and someone who may or may not have had a try at a bit of learning once.
Why is this so important and why am I having a go at you about it? Let me tell you-
The levels of rodenticide in the natural food chain are being monitored all the time by the Centre of Hydrology and Ecology (CEH). It has been well reported and well recorded since 1998 that a wide range of avian and mammalian predators and scavengers in rural Britain are known to be exposed to Second Generation Anticoagulant Rodenticides (SGARs).
Defra’s Wildlife Incident Monitoring Scheme (WIIS) and the Predatory Bird Monitoring Scheme (PBMS) have shown that some mortalities are the result. Exposure is generally thought to be secondary in most predators and scavengers but, as many species rarely feed on commensal rodents, exposure is likely due to feeding on non-target small mammal species.
So the theory is this- stop exposure to non-target animals, stop poisoning the upward food chain. Simples.
In 2015 there were the first reported incidences of Brodifacoum in barn owl livers. This coincided spookily with Brodifacoum being made available to amateur users for external baiting. So the changes from the reprotox ruling I mentioned above will definitely help there.
The last CEH report actually showed a tiny decrease in residues in tested barn owl livers in 2016 compared to 'baseline' years. This shows that, at the very least, incidence of non-target poisoning has stopped going up. Good news.
So CRRU's efforts appear to be making an impact and these should be massively applauded. And the reprotox ruling will stop a lot of non-target species by people who just don't know any better. All good things.
Want to really move the needle though? Let's delve a little deeper into the methods Stewardship-Approved-Assurance-Scheme sector of rodenticide users.
In a recent survey of farmers (here) by CRRU 40% of respondents said they still consider permanent baiting an essential practice for rodent control. That's having rodenticide present in the environment whether rodents have been detected or not.
On top of that, in addition to poison baits, used by 79%, other control measures were used by some but not all farmers: Denying access to food (58%), traps (40%), rat-proofed buildings (31%), terriers and shooting (31% each).
That's only 31% of respondents who proof their buildings. That's the same amount who set their dogs on rats... This is probably why they consider permanent baiting an essential option! Clearly these folk who are granted access to professional-use-only products through their stewardship schemes are not following the CRRU code of conduct (here), otherwise proofing would be much nearer 100%.
So, again I ask, Want to really move the needle? Reconsider the derogation to stewardship-approved-assurance-schemes and get this sector educated. It might just be enough to protect our wildlife from this constant accidental poisoning and the pernicious effects of reprotoxicity.
