Regulatory changes mean that large 20kg packs of loose grain, pellets or granular rodenticide baits are being withdrawn from the market. The change will affect all such rodenticides currently available in 20kg sacks but the timing of the withdrawals will vary depending on when the product authorisations were renewed.
Our attention was first drawn to this in a tweet from Barrettine about its Romax range. Whilst the 280 characters allowed is sufficient to flag up the withdrawal of 20kg packs, the reasons for the move were unclear. The link to the company web page listed the Barrettine products affected and, helpfully, both the ‘sell by’ and ‘use by’ deadlines for each, but, simply blamed the recent EU Biocidal reauthorisation process.
Just some of the 20kg products which will be dropping down to 10kg size as the STOP principle bites
We turned to PelGar’s regulatory manager, Anne Withall, for an explanation.
She told us: “New pack limits for professionals – max size 10kg (for loose grains and pellets) – are being introduced to comply with the STOP principle. This is a hierarchy of controls applied to dangerous substances.
“STOP stands for Substitution, Technical measures, Organizational and Personal protective equipment (PPE). It means that, if possible, you must avoid exposure using engineering means, rather than the relying on PPE.
“For rodenticides STOP is picked up in the amendment to HEEG Opinion 12, dated September 2016. HEEG is the European Chemical Agency’s Human Exposure Expert Group. The amendment states that packs of up to 10kg must not be decanted. If a product fails the risk assessment for OPEX (OPerator EXposure) when decanting (as all SGAR pellet, granule and grain baits will) then packs are limited to 10kg so that no decanting takes place.
“The pack size restriction only applies to formulations where the risk assessment shows greater than acceptable exposure (usually by inhalation) when decanting. So, the products affected are those where, up to now, the label has said that you must wear a mask if decanting the product. This means the pack size restriction applies to LOOSE pellets and grains but it DOES NOT APPLY to grains/pellets in sachets or to loose wax blocks or pasta sachets.
“Basically, there is an assumption that packs greater than 10kg will be decanted. Decanting leads to inhalation exposure from loose pellets and grains, which results in the need for PPE. This must be avoided if possible. Therefore, loose grains or pellets in packs over 10kg may not be sold,” she concluded.
No restrictions on 10kg pack sales
The good news is that there is no limit to how many 10kg packs a user may purchase. So, for pest professionals the change doesn’t present many, if any challenges. Indeed when it comes to safe lifting 10kg sacks will be easier to handle than larger 20kg ones.
But, what about pricing, will two 10kg packs be the same price as one 20kg pack? Any pest professional who does the weekly supermarket shop will have noticed that pack sizes for branded items ranging from tomato ketchup to furniture polish have also been shrinking but that prices remained the same. Let’s hope the shift from 20kg to 10g packs doesn’t mask any unnecessary price increases!