Stewardship Regime

CRRU UK Chairman Dr Alan Buckle says, “CRRU UK welcomes the opportunity to co-ordinate this important UK-wide stewardship initiative. We have to get smarter in the way we use rodenticides – and show we are doing so. It is now up to suppliers and users of these essential products to demonstrate that they can be applied without unacceptable effects on UK wildlife and other non-targets.”

Why do we need stewardship?

Anticoagulant rodenticides fail conventional regulatory risk assessments.  Residues are found in a wide variety of wildlife species and they are occasionally responsible for deaths of non-target animals.  The Health and Safety Executive (HSE), as the UK Competent Authority for biocides, requires reassurance that products containing these substances can be used without unacceptable risk to wildlife and other non-target species.

Development of the regime

In late 2012, HSE invited comments from stakeholders and other interested parties on a document setting out options for environmental risk mitigation measures for rodenticides in the UK. In April 2013, it held a meeting with stakeholders to discuss their responses. The conclusion of this consultation was that future use of rodenticide baits required a stewardship regime involving all main rodenticide user groups, including pest control professionals, local authorities, farm and land managers and gamekeepers.
HSE asked the Campaign for Responsible Rodenticide Use (CRRU) UK to co-ordinate the development and delivery of the stewardship regime, in collaboration with organisations from all user groups. The HSE document issued to describe the regime and the role of CRRU is available here.

The UK Rodenticide Stewardship Regime

The regime was launched in July 2015 and encompasses all rodenticide products sold to and used by professionals when applied outside buildings. It does not involve rodenticides restricted to use indoors, nor fumigant gases which are the responsibility of the Register of Accredited Metallic Phosphide Standards (RAMPS) (http://www.ramps-uk.org/). It also does not involve rodenticide products sold to and used by amateurs. HSE will issue new requirements for the authorisation of rodenticide products in alignment with the stewardship regime.

High Level Principles

A successful stewardship regime must meet ‘high level principles’ set out down by HSE (Please click HERE)

  1. Using Integrated Pest Management, including use of rodenticides, involving a hierarchy of risk controls for rodents;
  2. Using rodenticides responsibly, when demonstrated they are needed, because of their potential threat to human, animal health and the environment;
  3. Being applicable to all suppliers, handlers and professional users of rodenticides approved under stewardship to address these risks;
  4. Being robust, effective and workable, while remaining as simple as possible;
  5. Covering the whole life-cycle of the rodenticide products: manufacture, supply chain, end-use, disposal and environmental fate;
  6. Enabling good practice in the control of rodent populations as part of an integrated pest management system, while minimising resistance build-up and secondary poisoning in non-target species;
  7. Delivering key benefits such as:
    • governance of the supply chain, which gives governance over and provides the driver for later stages;

    • a competent workforce capable of delivering stewardship standards and of demonstrating an appropriate understanding and attitude toward case-specific control of rodents and use of rodenticides; and

    • monitoring compliance with the regime and its environmental impacts, and if possible of t he level of conflict reduction – i.e. an assessment of whether rodenticides and stewardship together are actually tackling the problems.

Implementation

To deliver the regime CRRU UK has set up a structure of six Work Groups which each comprise representatives from CRRU UK and user organisations, as well as technical experts. The composition of these groups and their remits can be seen here.

Code of Best Practice

The cornerstone of the regime is a Code of Best Practice for the use of rodenticides published by CRRU UK in early 2015. Application of rodenticides according to the code will prevent unnecessary exposure of wildlife and other non-target animals and help deliver the objectives of the regime. The code is available here.

Use patterns

Rodenticides will be authorised for professional use in three main areas (for definitions of these use patterns refer to the CRRU UK Code of Best Practice available here):

  • ‘Indoors’. Products authorised ONLY for use indoors will not be required to conform to ‘stewardship conditions’.
  • ‘In and around buildings’. This use includes an ‘outdoor’ element and therefore all professional products authorised for this use will be subjected to ‘stewardship conditions’.
  • ‘Open areas’. This use pattern involves only ‘outdoor’ use and all professional products authorised for this use will be subject to ‘stewardship conditions’. It is generally considered that this use pattern carries with it the greatest risk of accidental exposure to wildlife.

Monitoring

HSE has asked CRRU UK to fund and conduct a series of studies to monitor implementation and impacts of the regime:

  • Levels of anticoagulant residues in the livers of UK barn owls will be monitored annually. HSE will expect to see a significant decline in the proportion of barn owls carrying rodenticide residues and a reduction in the concentration of residues in the owls’ bodies as a result of stewardship implementation.
  • The breeding success of selected barn owl populations will be studied to determine impacts, if any, of rodenticide use.
    A periodic survey will be conducted on the knowledge, attitudes and
  • practices of all professional rodenticide users in order to observe changes over time in these important criteria. A baseline survey has already been conducted in advance of regime implementation.

What if it doesn’t work?

HSE has an option to introduce more stringent regulation if deemed necessary because the effects of stewardship on non-target organisms are found to be insufficient. These may involve further restrictions on who can use professional rodenticides and where they can be applied.

Downloads available:

Best Practice

Purpose:

  • Ensure that all users of professional-only rodenticide baits comply with the CRRU Code of Best Practice.
  • Work with assurance schemes to bring standards into alignment with the CRRU UK Code of Best Practice.

Work group members:
Dee Ward-Thompson (Lead) – BPCA
Nick Blasczkowicz – PelGar
Matthew Davies – Killgerm
Colm Moore – Rentokil Initial
Dave Oldbury – NPAP-CIEH
Colin Prescott – University of Reading
Iain Turner – NPTA

Downloads available:
CRRU Code of Best Practice

Training and Certification

Purpose:

  • Establish a framework for the review and approval of training courses and their certification. Click HERE
  • Define minimum standards for the achievement of certified proof of competence.
  • Commission a panel of qualification providers.
  • Review available training courses (existing and new) for compliance with framework requirements and publish updated lists of those approved. Please download Approved Certification HERE
    Approved Farm Assurance Schemes HERE
  • Set out compliance guidelines for schemes of continuing professional development (CPD)

Work group members:
Helen Ainsworth – Barrettine
Andrew Bauer – NFU Scotland
Nic Blasczkowicz – PelGar
Richard Burton – RSPH
Paul Charlson – NPAP (CIEH)
David Cross – Rentokil Initial
Matthew Davies (Lead) – Killgerm
Tony Davies – City & Guilds
Adam Hawley – NPTA
Andy Hughes – Antec DuPont
Oliver Madge – Pestwise / LANTRA
Mandy McCarthy-Ward – BPCA
Charles Nodder – NGO
Dave Oldbury – NPAP-CIEH
Lee Osborne- NFU
Stephen Jacob, Acting Chief Executive Officer of BASIS Registration Ltd
Katja Stoddart – AHDB
Gavin Wood – BASF
David Fisher – LANTRA

Downloads available:
Latest list of stewardship-approved certification. Download HERE.

Regulatory

Purpose:

  • Co-ordinate among rodenticide manufacturers to simplify and harmonise product labels.
  • Co-ordinate implementation of checks for proof of competence at point-of-sale with the time-table for product authorisation.
  • Ensure, where possible, that products with similar properties and patterns of use carry similar labels wording to reduce confusion and complexity, and promote the same core set of mitigation measures.
  • Provide stewardship monitoring data to HSE as a requirement of product authorisation (such data subject to agreed confidentiality and ownership structures).

Work group members:
Sarah Bull (Lead) – BASF
Gabrielle Cor – LiphaTech
Jayne Harris – Bayer
Brady Hudson – Bell Labs
Dawn Kirby – Rentokil Initial
James Pemberton – Syngenta
Charles Phillips – Barrettine
Mariateresa Rigato – ZAPI
Roger Sharples – BASF
Mike Swan – GWCT
Anne Withall – PelGar

Point of Sale

Purpose:

  • Implement the stewardship regime’s core requirement for proof of competence at the point-of-sale for rodenticide baits.
  • Work with all rodenticide distributors (including internet businesses) to ensure installation of mechanisms at point of sale to check that stewardship-approved qualifications are fulfilled by all purchasers and users of rodenticide baits.
  • Address with distributors the issue of centralised purchasing of rodenticide baits and their subsequent use by qualified field operatives.

Work group members:
Rupert Broome (Lead) – Killgerm
Steve Bailey – Barrettine
Nick Blasczkowicz – PelGar
Kevin Brown – Rentokil Initial
Gareth Capel-Williams – PelGar
Andy Deeks – Antec DuPont
Hazel Doonan – AIC
Ross Goodman – LODI UK
Tom Holmes – Pelsis
Andy Hughes – Antec DuPont
Ben Jordan – Mole Valley Farmers
Ian Scott – AHDA
Roger Simpson – LODI UK
Liz Webb – LODI UK
Gavin Wood – BASF

Proof of Competence Documentation

For information on proof competence documentation in Q&A format click HERE

Sample Declaration Forms

Declaration 1 Supply Chain Partners
Declaration 2: Certificated Users
Declaration 3: Farm Assurance Schemes

Monitoring

Purpose:

  • Liaise with appointed contractors and/or agencies for all monitoring mechanisms, including SGAR residues in barn owls; barn owl breeding and population investigations; and knowledge, attitudes and practice (KAP) surveys among rodenticide buyers and users.
  • Establish contracts between funding agencies and contractors.
  • Ensure scientific and statistical veracity of monitoring projects.
  • Co-ordinate provision of reports at required intervals and oversee publication of monitoring data.

Work group members:
Colin Prescott (Lead – University of Reading
Ton Abel – ZAPI
Alan Buckle – CRRU/University of Reading
Gareth Capel-Williams – PelGar
Alex Cornish – Syngenta
Matthew Davies – Killgerm
Alistair Leake – GWCT
Leah Morgan-Russell – Bayer
Dave Oldbury – NPAP-CIEH

Steering Group – The CRRU UK Task Force

Purpose:

  • Develop, co-ordinate and monitor the stewardship regime.
  • Seek consensus with all stakeholder organisations on the implementation of the stewardship regime.
  • Liaise with HSE-led Government Oversight Group.

CRRU UK Task Force representation:

  • CRRU’s sponsoring companies (x14 rodenticide manufacturers/distributors)
  • Specialist advisers
  • Rodenticide user group stakeholders (professional and local authority, gamekeeping, agriculture)

The organisations currently represented on the CRRU UK Task Force are:
The CRRU UK member companies:Antec-Dupont
Barrettine Environmental
BASF
Bell Laboratories
Bayer CropScience
Killgerm
LiphaTech
LODI UK
PelGar International
Pelsis
Rentokil Initial
Syngenta
Unichem
ZAPI

Stakeholder organisations:
The UK Competent Authority:
The Health and Safety Executive

Technical Advisors:
Centre for Ecology and Hydrology
The University of Reading
Royal Society for the Protection of Birds
Science and Advice for Scottish Agriculture

Representing users in agriculture:
Agriculture and Horticulture Development Board
National Farmers Union
National Farmers Union of Scotland

Representing users in gamekeeping:
National Gamekeepers Organisation

Representing users in professional pest control and local authorities:
Chartered Institute of Environmental Health