Dear Ladies and Gentlemen,
First of all, we would like to thank the BPC for sharing the draft opinion with the CEPA stakeholders.
The discussion, what this is all about focusses on preventing humans, non-target species and the environment from ARs, which makes sense and already is covered by the strict risk mitigation measures for anticoagulant rodenticides in Germany. Kept out of focus seems to be the fact of the benefit of ARs in terms of protection of food, feed, materials, buildings (which means also to save energy) and most importantly the protection from spreading infectious diseases and public health in general.
The implementation of IPM is a crucial part of each rodent extermination job and is already state of the art for years in Germany by the combination of AR’s, snap traps, proofing and cleaning in all parts of the pest control business, especially in the food and retail industries. According to experience it is impossible to cope with rodent infestations by the lack of even one of the already mentioned tools, especially in very sensitive areas of rural and urban hygiene and the whole food industry and retail.
Therefore, it is essential for PCPs to have a vast variety of chemical and non-chemical alternatives. Preventive treatments are left out of sight at this point, since they do not erase infestations and are part of the IPM program anyways.
One should keep in mind that the targets of our every day’s jobs are intelligent beings, able to learn fast and avoid what harms them. A) Bait shyness to acute toxins was overcome by the introduction of ARs, which may reincarnate an old problem by the use of Alphachloralose. If so, there would be realistically only one active ingredient left for a huge portion of German PCPs, which is Cholecalciferol. And there are only two products available on the market. B) trap shyness of rodents by learning from accidentally triggering of the trap when investigating it. The use of glue boards as a non-chemical alternative is more than questionable due to the German animal welfare law.
In conclusion the definition of „risk“ should be specified and not generalized. For example: In our opinion the risk for humans, non-targets and the environment by the correct indoor-use of ARs by trained professionals (mandatory in Germany) is close to zero, since the application of ARs in tampered resistant baiting systems or in a protected manner is mandatory.
To erase rodent infestations especially in environments where rodents find great conditions for themselves (food and feed industry, retail, etc.) it is essential to have a large „tool box“ of chemical and non-chemical products/alternatives in addition to the preventive treatments. Only this way it is possible to match the taste and behavior of the targets to get the job done in an economical and practical way to protect human health, food and feed. In order to mitigate risks for humans, non-targets and the environment, it is necessary to apply treatable rodenticides in case of an accidental primary or secondary poisoning. So, it is unlikely for bait shyness to arise and to mitigate the risk of resistance formation.
To ensure food safety and public health an effective combination of chemical and non-chemical methods and preventive treatments is essential.
With Kind Regards
On behalf of German Pest Control Board
Alexander Kassel
APC-AG
CEO