Rodenticide Legislation in Ireland
– Use of Rat & Mice poison new rules in the Republic (2019) –
Since 2018 the EU Biocide Directive is compelling local governments to implement changes in the use of rodenticides.
Due to the variety of rodenticide (rat & mice poison) formulations, actives and use, it is not possible to produce a specific piece of legislation that can apply to all products and all users. The DAFM-PRCD approach is to approve each individual rodenticide with a specific set of instructions/conditions on the product label. The label will then contain this notice: “It is illegal to use this product for uses or in a manner other than prescribed on this label“. In other words, the rodenticide label is the legislation.
From March 2018, the main rodenticide changes are:
Rat & Mice poisons for amateur-use
- Pack size to reduce to 300g. max. across Europe (it used to be up to 10 Kg. before that)
- Concentration of active ingredient for amateur-use rodenticide to be reduced to 25ppm across EU (standard concentration was twice as much prior to that)
- All bait must now be placed in temper resistant bait boxes
- Loose grain sachets should be placed as they are sold and should not be opened
Rat & Mice poisons for “Trained Professional” users
- Loose Grain rodenticide pack size to reduce from 20Kg to 10Kg in UK and Ireland (this is mainly for operator safety by reducing decanting)
- Rodenticides cannot be left permanently in situ. Without a justifying written Risk Assessment they should be removed after 35 days
- Rat & Mice poisons must be used only after a rodent infestation has been established, and must be removed immediately after the infestation is cleared.
- “Professional Users” (i.e. people who use the rodenticides commercially) must now obtain a licence (“PMU” number) in order to purchase or use professional rodenticides. They must also enrol in a Continuous Professional Development (CPD) scheme. For more information check: The Licencing of Irish Pest Controllers From 01/01/2018.
- There is currently an exception for Irish farmers who can still purchase and use professional rodent poisons (but not in sewers or away from buildings / open areas), providing they have a herd number and use the rodenticide on their own farm.
- Professional rodenticides should only be used in accordance with a code of best practice such as the CRRU Ireland Code of Best Practice
DAFM-PRCD “Permanent Baiting” Rules
The DAFM-PRCD (Pesticide Registration and Control Division) recently published a letter instructing all necessary conditions for using rat and mice poison “permanently”, i.e. to leave it deployed on site for a long-term period.
Official communication (dated 11/04/2019):
“The rules on permanent toxic baiting using anticoagulant rodenticides have changed based on the EU product authorisations. As a result of the rule changes, permanent toxic baiting is no longer the go-to treatment for the pest control industry.
The renewal of the product authorisations has moved away from the use of permanent baiting due to the risks associated with these products such as-
- the primary poisoning of non-targets, i.e., field mice and shrews etc.
- the secondary poisoning of birds of prey and mammals as a result of feeding on the poisoned non-targets.
Toxic baiting periods should only be for a maximum of 35 days, after this time period, a new/revised risk assessment is required to continue treatment with toxic bait. The product authorisation renewals have resulted in more prescriptive product labels specifying restrictions to the allowed uses by trained professionals only (PMUs). If these new rules are not implemented, there is a risk we may lose these products at the next renewal in 2023.
Permanent toxic baiting is no longer permitted as a routine practice in rodent pest management, long-term baiting is ONLY permitted using specific products in situations where all other alternatives have been considered by registered PMUs.
Permanent baiting is strictly limited to sites (indoors, around buildings, open areas and in sewers) with a high potential for re-invasion when other methods of control have proven insufficient.
When permanent toxic baiting is required and whilst it continues to be justified, the baiting strategy should be periodically reviewed in the context of Integrated Pest management (IPM) and the assessment of the risk for re-infestation. The period between baiting should be determined by the PMU in line with the product label directions and sites should be revisited every 4 weeks at a minimum during treatment with toxic bait.
Those who adopt external permanent baiting must first examine and document the risks to non-targets and make a conscious decision that those risks are managed and permanent baiting must be justified by an examination of the risks to non-targets and an assessment of the continuing threat to human or animal health and hygiene. The use of internal permanent baiting must also be justified and documented by a continuing threat to human or animal health and hygiene. Records must be kept of site assessments and product usage which should be in line with the authorised label, and a date assigned to carry out a re-
review of the site assessment to determine if there is a continued need to use toxic baiting.
Clients should agree a programme with PMUs for when non-toxic monitoring baiting is used. When permanent toxic baiting is used, the PMU will determine the frequency of site visits based on activity. This may be as frequent as daily checks, depending on the site survey and/or risk assessment and/or customer SLA and in line with the product label.”
Professional Rodenticide Legislation: Label Instructions Example (Vertox)
“Not for sale to the general public or any person other than trained professionals. Trained professional users must register with DAFM as a ‘Trained Professional-Pest Management Professional’ (PMU) and must present their PMU No. at point of sale to purchase this product for use only as specified on the label. Use Biocides Safely and Sustainably. It is illegal to use this product for uses or in a manner other than that prescribed on this label. This product should only be used in accordance with a code of best practice such as the CRRU Ireland Best Practice. Requirements for Rodent Control and Safe Use of Rodenticides. Follow any additional instructions in that code of best practice.“
Note: The CRRU Ireland Code of Best Practice recommends:
- ALWAYS HAVE A PLANNED APPROACH
- ALWAYS RECORD QUANTITY OF BAIT USED & WHERE IT IS PLACED
- ALWAYS USE ENOUGH BAITING POINTS
- ALWAYS COLLECT AND DISPOSE OF RODENT BODIES
- NEVER LEAVE BAIT EXPOSED TO NON-TARGET ANIMALS AND BIRDS
- NEVER FAIL TO INSPECT BAIT REGULARLY
- NEVER LEAVE BAIT DOWN AT THE END OF THE TREATMENT
“Directions for use: (…) Consider preventative control measures (e. g. plug holes, remove potential food and drink as far as possible) to improve product intake and reduce the likelihood of reinvasion. Carry out a pre-baiting survey of the infested area and an on-site assessment in order to identify the rodent species, their places of activity and determine the likely cause and the extent of the infestation. Remove food which is readily attainable tor rodents (e.g. spilled grain or food waste). (…)”
Written Pest Management / Environmental Risk Assessment is now mandatory prior to use professional rodenticides.
Only use open poison bait trays in “protected” areas
Professional Pest Control operator decides of frequency of re-visits
(…) “Where possible, bait stations must be fixed to the ground or other structures. Bait should be secured so that it cannot be dragged away from the bait station.” (…) “Collect any spilled bait and dead rodents.“ (…) “Cover or block the entrances of baited burrows to reduce the risks of bait being rejected and spilled.“ (…)
Search for carcasses of dead rodents to prevent risks of secondary poisoning of predators. Customers may need to assist by checking for dead rodents between scheduled visits.
“Storage and disposal:(…) At the end of the treatment, dispose of uneaten bait and the packaging in accordance with EPA requirements for the disposal of hazardous waste. Use of gloves is recommended.(…)”
Professional-use rodenticide that cannot be re-used must be treated as “hazardous waste”. the PMU should have a hazardous waste collection system in place at their office and keep written records.
“Long-term use: Do not use the product as pemanent baits for the prevention of rodent infestation or monitoring of rodent activities. Products shall not be used beyond 35 days without an evaluation of the state of the infestation and of the efficacy of the treatment. Do not rotate the use of different anticoagulants with comparable or weaker potency for resistance management purposes. (…)”
No permanent baiting under any circumstances (e.g. for monitoring activity) indoors or outdoors.
If “long term” baiting is necessary, this must be determined in the initial Risk Assessment and this assessment must be reviewed (in writing) every 35 days max.
Disclaimer: This label interpretation is for general information and general understanding of the label, and does not provide specific legal advice. It should not be used as a substitute for competent legal advice on rodenticide use. The ideas and views expressed in this document are solely those of its author, and do not represent the views of Owl Pest Control Ltd. or any other entity.