Europe has seen a shift in attitudes – and legislation – when it comes to rodenticides. Steve Broadbent, regional director of Ensystex looks at the possible implications for us here in Australia.
Regulators in many jurisdictions have expressed concerns about anticoagulant rodenticides and are reviewing their use. This has led to professional pest management initiatives such as the UK Rodenticide Stewardship Regime and the Australian AEPMA Code of Best Practice for Rodent Management. In Australia, the APVMA have listed second generation anti-coagulant rodenticides as a priority 2 review group.
This group of products includes brodifacoum, bromadiolone, difenacoum, difethialone, and flocoumafen. The key concerns are these chemicals persist in organs of poisoned rodents and present a risk to non-target animals that feed on poisoned animals or carcasses. There is also a potential risk to humans, pets and wildlife through accidental poisoning, with around 1400 human exposure incidents to rodent baits reported to Poisons Information Centres annually.
These rodenticides are not intended for use in crops or the field, though some labels make it difficult to discern this; the use of liquid formulations is a concern because they are not designed for use in bait stations.
The threat to the continued use of all anti-coagulant rodenticides, first and second generation, is however far more grave and real in Europe. The European Biocides Committee has reclassified almost all of these products as toxic to reproduction. This requires product labels for all products containing 30ppm or more of these actives to display the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) exploding heart Health Hazard symbol and the words ‘May damage the unborn child’ (main picture above). It is clear warning that the professional pest control industry must make every effort to use these products responsibly, or risk losing them!
The consequence of this is that rodenticide manufacturers, for consumer markets, have had to reformulate all their products from the previously registered 50 ppm of active, to 25 ppm. This then avoids the above labelling requirement. The downside is these products, at these levels of active, are significantly less effective; take longer to kill the rodents; and present an increased risk of increasing resistance, which is already a serious concern in Europe. This legislation will also, most likely, spell the end of the first-generation anti-coagulants, since they are simply not effective at these lower rates.
Whilst professional products will still be available at the current 50 ppm, the same rate as used in Australia, as we will discuss later, their continued professional use is still threatened by these changes.
And it is not just anticoagulant rodenticides that are under re. The Biocidal Products Committee (BPC) established by the European Chemicals Agency (ECHA) recently released their opinion on cholecalciferol (Vitamin D3).
The committee advised “… the overall conclusion of the BPC is that cholecalciferol should normally not be approved unless one of the conditions for derogation is applicable”, citing environmental concerns, since, “… unacceptable risks for primary and secondary poisoning for mammals and birds have been identified.” Cholecalciferol was classified as an endocrine disruptor, since it alters the function of the endocrine system and causes an adverse e ect as a consequence of its endocrine mode of action in humans and non-target organisms. However, they acknowledged that “the intended use of the products leads to acceptable risks for human health as long as relevant risk mitigation measures are followed.”
With respect to anticoagulant rodenticides, the question of what the actual risk to technicians handling rodenticides must be considered. Naturally we can assume they use the recommended personal protective equipment (PPE), in which case, the straightforward answer is, as close to non-existent as one might imagine.
For our clients, the risk is even smaller than the risks to technicians. This is because this reclassification is all about the toxicity of the pure active ingredients, and little, if anything, to do with the risks involved when the products are used according to label instructions.
Intrinsic toxicity and risk are two very different concepts. It has been said that common sense is a rare gift of God, and this is the concern with this decision; and it is a concern that could arise in Australia, especially for professionals contracting services to European companies located here, or in the event of ‘smart’ lawyers becoming involved in a matter involving a rodenticide poisoning.
The challenge that we may face, and which the European industry does face, is that sadly, a small percentage of babies are born with birth defects and some parents will often look for someone, or something, to blame. Rodenticides and the pest professionals who placed the baits could find themselves in the firing line.
Whether anything could ever be proved is highly unlikely, but the hassle of going through a legal process is one every pest professional would want to avoid. Employers of the pregnant woman would also be in the ring line, and they will be as keen to avoid any legal action as pest professionals. In Europe this may mean, due to concerns of being sued, that some customers will take the view that products labelled in this way should not be used on their premises.
This reclassification may also raise concerns among female pest control technicians of child bearing age. If they fall pregnant they may likely request a change of duties.
These events are remote from us in Australia, but it is important that as professionals we are aware of these matters. More than ever before, we live in a global trading environment. Now is the time to consider a hierarchal approach to the control of rodents. This requires consideration of a holistic approach including: seeking out the source of the rodents, proofing, denial of food and water, removal of harbourages, and trapping. Rodenticides must be carefully managed, and glueboards only used as an absolute last resort.
The AEPMA Code of Best Practice for Rodent Management has been developed with due regards to this changing world in which we live and work, and it is strongly recommended that all pest management professionals join as a signatory to, and follow the requirements and processes of this Code.