HSE's SGAR product authorisation plans and timetable

On 12 January, the Health & Safety Executive (HSE) circulated an information document that laid out its plans and timescales for the authorisation of second generation anticoagulant rodenticides (SGARs) in light of the development by suppliers and users of the stewardship scheme, which has been co-ordinated by the Campaign for Responsible Rodenticide Use (CRRU).

In the information document HSE says that it is proceeding to authorise some rodenticide products on the basis set out in the paper.

HSE also says that it remains open to constructive input and suggestions for improvement to its plans. It also points out that the principles will more than likely also apply to first generation anticoagulant rodenticides (FGARs) since the issues being addressed are fundamentally the same.

So what are the key activities and deadlines detailed in the HSE authorisation plan?

For those who need to understand all the detail, then we recommend careful reading of the full 12-page document. However, for those who just need a summary, the key points and deadlines are as follows:

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1 June 2016 is the most important deadline for users. From this date no anticoagulant rodenticide products for professional outdoor use can be used unless approval under stewardship has been granted. Adherence to the stewardship scheme will be set as a condition of authorisation and the product label will have to contain the phrase:

‘For supply to and use only by professional users holding certification demonstrating that they have been trained according to the UK second generation anticoagulant rodenticide (SGAR) stewardship programme requirements.’

But what is outdoor use? The company submitting the product for authorisation will have to specify the intended use area so ‘in and around buildings’, ‘waste dumps’, ‘open areas’ or any combination of these.

And, how will this work in practice? Essentially professional users will have to provide evidence of their competence e.g. by holding the RSPH/BPCA Level 2 Award to suppliers before they can purchase these products.

1 June 2015 and 1 November 2015 are key dates for approval holders. If they wish to continue to supply rodenticide products for use outdoors after 1 November 2015, then they need to submit their application for ‘outdoor use under stewardship’ before 1 June 2015.

Log Jam of authorisations
As readers may know there has been something of a log jam in product authorisation applications within HSE. This came about because, until such time as the industry could demonstrate to HSE that it had an active stewardship programme to ensure safe and responsible professional use to control the environmental risks associated with SGARs, HSE could not legally authorise any SGAR products for outdoor use.

HSE will now process these applications with the aim of completing them all by the end of January. These pending authorisations for bromadialone, brodifacoum and flocumofen products will be approved without linking to stewardship, unless the applicants request otherwise.

This means that all SGAR products (except those based on difethialone – see below) about to be authorised without reference to stewardship will be restricted to use ‘in and around buildings’

Difethialone was authorised for ‘indoor only’ before the results of risk assessment showed that the science did not support different restrictions for different ‘types’ of SGARs. For consistency, approval holders will be able to apply, if they so wish and before the end of January deadline, to extend use to ‘in and around buildings’.

This will be a stop-gap measure as authorisations will need to be amended and the stewardship link added to allow continued sale for outdoor use (after 1 November 2015) and continued use by professionals in outdoor areas (after 1 June 2016).

Within the stewardship document it is important to note that manufacturers have undertaken not to apply for the use of the so-called single feed products, i.e. those containing brodifacoum, difethialone and flocumofen, in ‘open areas’.

They have also agreed that they will only contract to supply product to distributors who have agreed to fully implement stewardship measures. The following chart taken from the stewardship document summarises what has been agreed:

Comments sought
HSE say that comments on their approach or the proposed stewardship scheme will be considered at any time, but are in particular invited before the end of January 2015. Comments can be sent to [email protected]