Please respond to this consultation on rodenticides
The Health and Safety Executive has announced a consultation on Second Generation Anticoagulant Rodenticides (SGARs).
Although this is meant to be a ‘public’ consultation, there appears to have been very little actual publicity informing anyone or the conservation organisations that this exercise is taking place. The consultation itself – click here to see it – is rather inaccessible to the average member of the public (whom, we argue, can both take part in rodent control and has an interest in the methods of control that are available).
The consultation is particularly fiddly, involving the downloading of forms as Word documents, which consultees must fill out and then reattach to the consultation in order to submit their views.
But – despite all of this – this is an opportunity for you to add to the conversation around rodenticides. We would be grateful if you could.
Anyone can legally go out and buy poisons, and no one checks how they are being used. The chemical companies will want people to believe that SGARs are essential and must be used without any further restrictions being imposed. It is likely that they will always downplay the level of harm SGAR exposure causes to wildlife.
There is a real concern that the HSE’s approach with this consultation favours maintaining the status quo, potentially due to pressure from chemical companies who benefit financially from the continued use of SGARs.
So, please take the time to respond if you can. What you say is entirely up to you, but we’ve written some guidance that may help you form some answers – see below.
COMPLETING THE CONSULTATION:
Firstly, open the consultation in another browser window, click the button below:
Overview:
You’ll see some background preamble – not written for the layperson! Scroll to the bottom and click on ‘Submit your comments – Share your views’
The first page is simple – you’re probably an individual, and you might want to say you learned about the consultation from Wild Justice (unless you didn’t). Click Continue.
The second page is easy too – this is about you! Fill in and Click Continue.
The third page has one question:
Q. Please indicate whether you are aware of suitable alternatives to anticoagulant rodenticides that are available in GB for any of the below use categories:
We hope our guidance has made you aware of alternatives – if so, please click ‘Yes’, then click Continue.
The fourth page is where it gets fiddly. Now you need to use one of two attachments provided – the non-confidential one (which means your responses can be published), and the confidential one (which means they won’t be published).
We suggest using the non-confidential attachment – but it’s up to you.
Click on the link for whichever attachment you use. This will download a Word document onto your computer or device.
Filling out the form:
Below you’ll find guidance on filling out the form you’ve just downloaded. Please put this into your own words, and share your own experiences – copy and paste answers might not count as individual answers in a consultation.
Okay, let’s get started.
Name of substance:
We suggest changing the words to ‘Integrated rodent control’
Relevant use category for this alternative:
(We suggest ticking all of the boxes)
☒ House mice and rats – professional users with demonstrated competence – indoor
☒ House mice and/or rats – professional users with demonstrated competence – outdoor around buildings
☒ Rats – professional users with demonstrated competence – sewers
☒ House mice – general public – indoor
☒ Rats – general public – indoor
☒ Rats – general public – outdoor around buildings
☒ House mice and rats – professional users with demonstrated competence – permanent baiting
Type of alternative: (Tick all but ‘A micro-organism’)
☒ A chemical substance
☐ A micro-organism
☒ A technical alternative (i.e., an adaptation or a change in the technology, process, procedure, device, modification of end product or other solutions)
Type of treatment:
(Tick both – we’ll be talking about both preventing and treating a rodent problem)
☒ Preventative
☒ Curative
Generic name of alternative (non-confidential):
Here you might want to explain that a suitable alternative is using integrated rodent control, first using prevention (habitat management, food source control, access control and predator encouragement) is needed, followed by the use of lethal options including non-SGAR rodenticides if only absolutely necessary.
Legal name of submitter(s):
Enter your name here.
Next, there are seven questions to fill out.
1. ALTERNATIVE IDENTITY AND PROPERTIES.
Provide a description of the chemical substance / micro-organism / technical alternative.
Here you might want to say that you are aware that rodent control (both rats and mice) can be achieved by preventative methods. These are things that, if you have a garden, allotment or other land, you’re probably already doing. Things like preventing rodents from accessing food sources and the use of habitat management (encouraging natural predators, removal of rodent harbourage and preventing access of rodents to potential food sources).
You could also say that if these techniques were to fail, and you found yourself with a rodent problem, you might explore other alternatives of lethal control, including trapping and using non-SGAR rodenticides (as a last resort).
2. TECHNICAL FEASIBILITY
Please provide information on the technical feasibility of the use of this alternative as a replacement for anticoagulant rodenticides. This includes showing whether the alternative can fulfil the function of anticoagulant rodenticides and describing the precise functions or tasks performed by the alternative.
Information should also be provided on the effectiveness under field conditions of the use of the alternative as a replacement for anticoagulant rodenticides. Particular attention should be paid to any behaviour affecting the effectiveness of the alternative (e.g. aversion to traps in neophobic rodents), and the conditions under which death occurs (e.g. unnecessary suffering, etc.).
You might want to point out here that the approach of using habitat management can prove to be successful without ever having to use lethal control. You could also point out that SGARs are now already limited to use only ‘in and around buildings’. This means that even if you used these products as a member of the public, you would still need other techniques for locations where you can’t legally use SGARs.
You might also want to point out, that as a member of the public you can see that there is a lack of enforcement or monitoring of SGAR use, and you’re concerned about the effect this has on the UK’s wildlife.
3. ECONOMIC FEASIBILITY
Please provide information on the economic feasibility of the alternative as a replacement for anticoagulant rodenticides. If possible, provide a cost comparison between the continued use of anticoagulant rodenticides and switching to and use of the alternative.
Please distinguish between one-off transitional costs and ongoing costs. It helps with our understanding to see the thinking that go into your cost calculations – for example, “200 clients will have to reapply the substitute product an additional two times a year at £500 per application, giving a cost of £200,000 a year” is much more useful than just saying, “It will cost £200,000”.
You could point out there that integrated control to manage rodents – i.e. preventing the problem in the first place – would be far more cost effective rather than having to buy lots of bait boxes and lots of SGARs to put in them.
4. HAZARDS AND RISKS OF THE ALTERNATIVE
Please provide information on the potential hazard or risks to human health, animal health and the environment associated with the use of the alternative. In any assessment, consider relevant risks and effects associated with the alternative, including user safety and environmental impacts such as on non-target species.
Here you could explain that there aren’t any significant hazards and risks involved in habitat management nor in taking preventative methods.
Compare this to SGAR bait – where much poisoned bait will be removed by rats and hoarded elsewhere. This significantly increases the risk to non-target species from both primary and secondary poisoning – which is what you’re particularly concerned with. You might also want to share a link to Wild Justice’s report on this: https://wildjustice.org.uk/wp-content/uploads/2024/11/Collateral_Damage_Wild_Justice_website.pdf
5. AVAILABILITY
Please provide information on the availability of the alternative, including any possible delays to acquiring the required quantity, and the long-term sustainability.
Here you can say that taking preventative measures to reduce rodent infestations is easily doable, and the ability to manage habitats and other preventative measures are freely available from a range of organisations.
6. CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE.
Please provide a conclusion on the overall suitability and availability of the alternative in this specific use category.
You can summarise your response by explaining that integrated control programme (prevention, habitat management, predator encouragement) backed up by non-SGAR rodenticide use is both suitable, effective and fully available for all categories mentioned above. It is both cheaper than control using SGARs and has no restrictions on where it can be carried out by you (a member of the public) – unlike SGARs.
7. OTHER COMMENTS.
Please include any other information you may have on the alternative.
Here we would encourage you to make some comments in relation to alternatives to SGARs in the UK, and also the manner in which this consultation is being conducted.
Here you could point out that the regulations in relation to the approval of biocides state:
Article 5(2) of Regulation (EU) No 528/2012 (the GB Biocidal Products Regulation). The section in bold requires that when deciding whether an active substance may be approved under Article 19(5), “the availability of suitable and sufficient alternative substances or technologies shall be a key consideration”.
Knowing this, you can point out that the scope of the HSE consultation is limited. You could also point out that there are now a number of products, either once approved for use in the UK, in use in other countries or soon to be coming onto the market in other countries which should have been included in this consultation.
You might also make the point that whilst the Great Britain market is dominated by the virtually uncontrolled use of SGARs, chemical companies are very unlikely to introduce any alternatives onto the market. You could say you believe there is a role for the regulator (the HSE) to control the market by limiting SGARs to encourage chemical companies to introduce these less environmentally damaging alternatives.
The justification for the approval of SGARs is that they are ‘essential to prevent a serious danger to human health, animal health or the environment.’ You might accept that rodents can pose a serious danger to human health, but that does not mean SGAR approval currently in operation in the UK is appropriate.
Here you could link to further evidence that demonstrates the environmental risks of SGARs, including these WPRUK reports on SGAR exposure in wildlife: https://wildlifepoisoningresearchuk.wordpress.com/reports/
You could also mention emerging evidence showing that sub-lethal SGAR exposure can actually increase the level of disease, such as Leptospira, in rat populations (Murray and Sanchez, 2021). Thus, SGAR use could be contributing to the public health danger posed by rats rather than resolving it.
You might want to share your opinion on the quality of this consultation; perhaps pointing out it appears to be designed for a specialist, or those in the chemical industry, not (as its titled) a ‘public consultation’.
Phew – that’s it!
Once completed, you can save your form, and return to the consultation in your browser.
Upload it into the consultation:
Select Choose File and select your form document, before clicking on Continue.
Additional Information:
If you have any additional comments or thoughts you can add them here.
Click Continue
Enter your email if you would like a link to a receipt and a PDF of your response.
Click Submit Response.
And you are done! Thank you for taking the time to respond to this fiddly and rather inaccessible consultation – this is an important subject and you have now contributed to the conversation on a subject that affects our wildlife. Thank you!