18 Jan Implications for rodenticide users of new label text specifying bait-station standards
Changes required by Health and Safety Executive to legally binding instructions on rodenticide product labels have significant implications for users in pest control, farming and gamekeeping. Updated text will appear on labels January onwards, according to chairman of the Campaign for Responsible Rodenticide Use Dr Alan Buckle.
“In practice, the changes are about users being responsible for bait stations being sufficiently robust rather than how, where or when they are used,” he explains. “As co-ordinator of UK rodenticide stewardship, CRRU supports any and all measures designed for the protection of non- target wild species, pets and people.”
HSE requires that tamper-resistant bait stations must now be:
- “Strong enough to prevent entry or destruction by dogs.
- “Strong enough to prevent entry or destruction by children under six years of age using hands, feet or objects reasonably expected to be available in the use area (e.g. household objects, toys etc).
- “Lockable or sealable so that children and dogs cannot gain access through the opening or mechanisms used to fill the bait compartments.”
- And for use ‘outdoors around buildings’: “Resistant to destruction or weakening from exposure to typical non-catastrophic weather (e.g. direct sunlight, extremes of temperature and humidity, rain, snow etc).
Dr Buckle points out how these are clearly open to interpretation. “CRRU notes that neither HSE, nor the European Commission before or after Brexit, has published guidance for testing that would allow manufacturers of tamper-resistant bait stations to demonstrate their compliance with these requirements,” he explains. “Moreover, there is currently no regulatory requirement to do so.”
The HSE conditions apply equally to reusable bait stations sold separately from rodenticides and those supplied pre-filled as ready-to-use integrated products. For bait stations sold empty, neither CRRU nor manufacturers of rodenticide products can exert any influence on bait stations chosen by users. Neither can they vouch for the robustness of these stations.
Accordingly, CRRU’s position is that this is a matter for purchasers, manufacturers and distributors of empty bait stations to ensure, as far as practicable, that new label conditions are met.
If in doubt, CRRU advises users to consult either their supplier or bait station manufacturer for assurances that, whether prefilled or refillable, sold together with an authorised product or separately, a bait station meets the product label’s requirements.
CRRU Information Note: New GB and NI Label Bait Station Text
Background
Following Brexit, Great Britain (England, Scotland and Wales) implemented its own regulatory framework operating independently from the EU. Northern Ireland continues to follow EU Regulation (under the NI Protocol).
Authorisation holders must be established in the UK for GB product authorisations, Authorisation holders must be established in NI or EU for NI authorisations.
The HSE is in the process of issuing new, separate, GB and NI authorisations.
New GB and NI authorisation documents include the following new text: “Bait formulations: Ready-to-use bait to be used in tamper-resistant bait stations
Tamper-resistant bait stations must be:
– Strong enough to prevent entry or destruction by dogs.
– Strong enough to prevent entry or destruction by children under six years of age using hands, feet or objects reasonably expected to be available in the use area (e.g. household objects, toys etc)
– Lockable or sealable so that children and dogs cannot gain access through the opening or mechanisms used to fill the bait compartments.”
“Field of use: outdoors around building”
Resistant to destruction or weakening from exposure to typical non-catastrophic weather (e.g. direct sunlight, extremes of temperature and humidity, rain, snow etc)
Previous UK authorisations did not specify in detail the requirements of bait stations and instead cited ‘CA-Nov16-Doc.4.x-Final on the concept of tamper resistant bait stations’. The change in the authorisation documents is due to the Government’s accessibility regulations, whereby footnotes have been removed and relevant information included into the body of the text.
The new text will appear on rodenticide product labels from the beginning of 2022.
CRRU Position
CRRU fully supports the promotion of stewardship and the protection of all non-targets.
Users should consult either the supplier/distributor or the manufacturer to seek assurance that whether prefilled or refillable, sold together with an authorised product or sold separately, a bait station will meet the requirements stated on the authorised product label.
It is the responsibility of the end user to ensure the bait station employed complies with the new label requirements.