The implementation of EU legislation over the next 12 months will have a significant impact on the Anti-Vitamin K (AVK) rodenticides in the EU Member States, including Ireland. The implementation of this EU legislation will result in the introduction of new classification and labelling criteria for the AVKs, and additional Risk Mitigation Measures (RMMs) not previously in place.
As a result of the above processes, there are practical consequences for the use of AVK rodenticides in Ireland.
There will be a clear designation of product user groups.
There are now three categories of user groups: the General Public, Professional Users, and Trained Professional Users. Professional Users are all those who use rodenticides in the course of their work. Trained Professional Users are a subset of professional users, who have received approved training and certification in the use of rodenticides.
From 01 March 2018, all products on the Irish market for General Public Use will have a maximum active substance content of 30mg/kg. However, products containing > 30mg/kg will still be allowed to be marketed for professional and trained professional use after this date.
There will be no legal AVK product on the Irish market for General Public use, containing active substance content > 30 mg/kg, after 01/03/18. However, products containing > 30 mg/kg will still be allowed to be marketed for professionals and trained professionals use after this date.
Rodenticides should only be used as part of an integrated pest management (IPM) system, including, amongst other measures, hygiene measures and, where possible, physical methods of control.
All users remain legally obliged to use rodenticides in accordance with the instructions on the product label. Up-to-date labels of rodenticides in Ireland will shortly contain a phrase “use according to an accepted code of best practice such as the CRRU Ireland Best Practice Requirements for Rodent Control and Safe Use of Rodenticides”. So, compliance with such a code of practice will effectively be a legal requirement.
It should be noted that permanent baiting is restricted to Trained Professional Users only. Permanent baiting is only permitted for products containing difenacoum and bromadiolone and then only at sites with a high potential for reinvasion when other methods of control have proven insufficient. Justification for use of such techniques must be documented and reflect best practice requirements, including wildlife awareness, rodent monitoring, assessments of the treatment and the collection of dead rodents and unused bait.
In practical terms, the new legal requirements detailed above will come into force as products are authorised for the first time or are re-authorised with new product labels. New product labels will come into force during the next twelve months.