Published onOctober 28 2019
In the sometimes confusing world of pesticides, chemical solutions expert Richard Strand shares his insight on the ever changing legislation in the industry.
In today’s environmentally aware world, chemical solutions to pest outbreaks in agriculture and public health are perceived to pose more problems than they solve. Even when chemical intervention is the only viable solution to stem an infestation, the smallest threat to the environment must be predicted, eliminated if possible, or at least minimised. Added to this are much higher expectations of health and safety both by the general public and pest managers, so that the question as to how pests are to be managed seems intractable. This is not a ‘fad’ and is unlikely to change any time soon.
Whilst public opinion may be the driving force, legislation is, and has been the engine of change. On the public health front, the transfer of product approvals from the Control of Pesticides Regulations to the newer Biocidal Products Regulations (BPR) has given Ministers an ideal opportunity to tighten standards. So far, only the transfer of vertebrate control agents has been completed; even here however, we have seen two examples of conditions of approval being tightened significantly.
Two new and mandatory certificates have been introduced, one to cover the application of metallic phosphides for rabbit, mole and rat control, the second regulating the use of rodenticides to control rats and mice. Both certificates have been supported by new and rigorous Codes of Practice. Both have spawned training standards tailored to meet tighter requirements.
Each Code of Practice evolved for a different reason. That covering metallic phosphides recognised the fact that the products being used were scheduled poisons. They are so toxic that unregulated use presented an immediate danger both to the user and to any non-targets (animals and people) that come into contact with them. The issue was black and white. Regulate the use of the product and the threat to non-targets is correspondingly reduced (secondary poisoning is not an issue when using metallic phosphides).
The Code covering rodenticides arose through a growing realisation of the threat to animals well beyond those coming into immediate contact with those rodenticides. This threat is far more insidious than that presented by metallic phosphides, as the threat extends beyond the target animals and the period of treatment.
It can be argued that anticoagulant rodenticides have become a victim of their own success. Both effective and easy to use, there was little pressure on users even to consider alternatives. The solution to your rat problem lay there in a bucket......and, to be frank, we haven’t been quite so canny as our forefathers used to be about how bait was applied. The products worked, you didn’t have to worry about pre-baiting, bait shyness and, if a pet ate the bait, there was time to get it to a veterinarian to administer the antidote.
Anticoagulant rodenticides became universal and so did the (non-target) animals carrying ever more significant residues of them. The aim of regulators – to reduce secondary poisoning – was one step removed from the pest control actions being taken. Who would have thought that slugs eating damp baits, yes, baits in locked and anchored boxes, would present a threat to hedgehogs?
Despite these differences, both Codes are ‘environmental’. They seek to minimise risks to non-target animals by encouraging a more responsible use of vertebrate control agents. Both Codes emphasise the concept that chemicals should be an option of last resort and not a first choice. Both Codes place demands on users to be more aware of the potential impact of the products that they are using and to apply them more responsibly. Both demand much higher levels of professionalism from operators.
These two Codes of Practice are now established, certification is in place and with most of those who need to be trained and assessed now approved, is this the end of the story? Probably not! Whilst all of the vertebrate control agents have gone through that process, the (non-agricultural) insecticides are just at the beginning of their journey.
So far, one popular product has been reviewed and the changes to the conditions of use for that product have been substantial. Substantial to the point that pest controllers are still not fully clear as to what they can or cannot do with the insecticide.
In the coming months, more products will be making that transfer….or, perhaps, losing their approvals altogether (a familiar story). Would it not seem prudent to assume that we will be faced with similar stories of change as other insecticides make their transfer to the BPR?
The last few years have been revolutionary for those undertaking vertebrate control. We need to be prepared for a similarly turbulent decade ahead of us, particularly for those of us involved in public health insect control.
This may sound exceedingly gloomy. It really shouldn’t. The need for change is undeniable. There is a wealth of evidence that tells us so. Change is nothing new and it has been shown many times that those who can embrace it, win the future.
Lantra already has a range of training products to enable its clients to look to the future. With a history of providing both training and qualifications in a changing world, Lantra also has the wherewithal to develop those products to meet the emerging needs.
Article by Lantra Approved Instructor and Technical Verifier Richard Strand