Technical | PPC107 June 2022
Pest management is highly skilled work. However, entry requirements to the sector are lower than other comparable trades.
We asked Senior Regulatory Manager Dawn Kirby from BPCA member company Rentokil to look at current regulation and speculate on what may change.
To work in pest management, you need to be thorough, have good attention to detail, and communicate well with the customer.
Patience is also essential, as is the ability to work well under pressure.
The working environment can be dirty, cramped and sometimes at height. There is a requirement to have good investigative skills and knowledge of pest identification and behaviour.
The ability to carry out minor repairs is also useful to prevent pests from entering the building, and collecting dead animals is often not for the faint-hearted.
Knowledge and skill are needed to choose the correct method of pest control, handle the often hazardous materials, and stay within the law that governs activities within the industry.
There are so many rules to follow, record keeping requirements, risk assessment and other paperwork to complete – but just how regulated is the pest management industry in the UK?
What is regulated?
Depending on where you fit into the pest control industry will probably influence the first thing you think of when posed with the question, “How regulated is the pest management industry in the UK?”
Products HIGH REGULATION
Manufacturers and distributors will probably immediately think of the authorisation of pesticide products under the UK’s national legislation.
Everyone will think of the extensive labelling requirements, products being withdrawn from the market or more restrictions being applied.
Chemical pesticides are regulated by the Health and Safety Executive (HSE) Chemicals Regulation Division (CRD).
Chemical manufacturers submit swaths of evidence of the safety and efficacy of products – CRD then approves (or rejects) the product and generates label conditions that are legally required to be followed. The process is robust, time-consuming and expensive.
Previously this was done at a European level; however post-Brexit, the UK now looks after its own chemical approval system. We are (for now at least) reasonably aligned with the EU regarding chemical regulation.
Product users MEDIUM-LOW REGULATION
The UK has no licenced pest technicians or mandatory professional bodies for companies like many other countries do.
Instead, we have many voluntary ‘self-regulating’ initiatives to help technicians conform to legislation, such as the Wildlife and Countryside Act 1981 and the legally-binding label conditions of biocides. Remember - the label is the law!
Qualifications like the RSPH Level 2 Award in Pest Management, various Codes of Best Practice and guidance documents are in place to ensure pest controllers understand how to control pests safely while remaining compliant.
Labels of professional products now regularly state they can only be applied by ‘trained professionals’. However, no official definition of a ‘trained professional’ exists, but note that CRRU UK keeps a list of approved training courses to purchase professional rodenticides.
CRRU UK is an interesting example of self-regulation that is almost second nature to us now. The CRRU Code and guidance documents regularly appear on rodenticide labels, meaning that they are effectively the law too.
There is also legislation in place to protect non-target species and wildlife, their breeding sites, and there are clear rules relating to the safe and humane use of live capture traps.
Service Users LOW REGULATION
While not the focus of this article, it’s worth pointing out that service users are not usually required to control pests, with a few exceptions.
Food premises must keep premises pest-free but are not required to hire a professional to conduct the work.
Local authorities and councils are required to keep their local areas rat and mouse free, as far as is reasonably practicable.
What is the Campaign for Responsible Rodenticide Usage (CRRU UK)?
Government agencies responsible for the regulation of rodenticides have raised concern that many species of wildlife, such as barn owls, kestrels and red kites, are being accidentally exposed to these products.
These agencies have called for better stewardship of rodenticides to prevent wildlife exposure.
CRRU UK is a response to that call. Under the banner ‘Think Wildlife’, CRRU promotes best practice and responsible rodent control, thereby protecting wildlife from rodenticide exposure.
thinkwildlife.org
Why all the regulations?
The tight regulation of pest management is there to mandate the requirement to safeguard the health of the public and prevent damage to property, and the rules ensure it is done safely and humanely, with a high level of protection for humans and the environment.
There will be plenty of opinions about whether the current level of regulation is sufficient.
Some of the UK’s close neighbours in the EU have comparable levels of regulation relating to pest management, while others approach regulation of the industry in a different way.
For example, certification of pest technicians, category of users, and restriction of chemical product use outdoors.
Without a doubt, the pest control industry continues to evolve as a result of new innovation, technology and skills, and the regulations that form a foundation for the industry will also adapt and change.
The future of regulation
The basics of good pest control will never change, but what does the future look like?
Despite exiting the EU, the UK regulator remains closely aligned to their regulatory decisions.
Without a doubt, the pest control industry continues to evolve as a result of new innovation, technology and skills, and the regulations that form a foundation for the industry will also adapt and change.
Dawn Kirby, Rentokil
We are seeing moves to ban glue traps in England (with similar moves in Scotland and Wales) under the Glue Traps (Offences) Bill. For England and Wales, glue traps will likely remain for use under licence, but we wait to see what licensing looks like.
Conversations continue under the EU NoCheRo (No Chemical Control of Rodents) Initiative about the need to test the quality and performance of break-back traps when users are aware that the power of these traps can vary widely.
The UK regulator has recently enforced a requirement that all tamper-resistant bait boxes used for rodent control must be fit for purpose.
The requirement is detailed on the product label, but they should be lockable/sealable and strong enough to prevent destruction by children or dogs, and weather conditions.
Monitoring of pests has always formed an important part of integrated pest management, but technology is changing the face of how this is done.
Digital and internet-connected traps continuously transmit data about rodent conditions and the number of animals caught. While inspections will remain important, there is the possibility of doing more remotely and sustainably.
There is a general trend to control pests sustainably with the minimum environmental impact, whether that is reducing energy outputs, reducing plastic, reducing pesticide use or choosing non-toxic alternatives such as traps.
Regulators are keen to reduce chemical control methods through the Chemical Strategy for Sustainability initiative, which has a zero pollution ambition, but the green agenda is also driven by the customers who are looking for pest controllers to deliver pest management more sustainably.
Final thoughts: what does this mean for the pest controller?
Pest management has always been a highly skilled industry, operating within a regulatory framework.
Currently, a large percentage of the regulation is self-governed and this is largely done at the product level with some success. As product users, engaging and volunteering with your trade association is a great way of having a say in what self-regulation looks like in the UK.
Either way, pest controllers will need to prepare for further regulation in the future, otherwise, business operations cannot continue.
There will be more training to access products, and prove competence to buy products which can be picked up easily today. It could be completed via CPD points or a licensing scheme.
Pest management has always been a highly skilled industry, operating within a regulatory framework.
Dawn Kirby, Rentokil
Simply having worked in the industry for many years will not be enough. We don’t know what form this increased regulation will take, but these regulations will continue to evolve in order to meet the growing needs of the population that lives alongside pests of all shapes and sizes.
There will always be a balance between controlling the pests and the risk of disease and damage. Still, the legal framework allows standards and quality to be maintained while ensuring pests are controlled with minimum risk to operators, bystanders and the environment.
Environmental considerations will drive a lot of the future regulatory decisions, as will the fast pace of new technology and innovation, which will likely reduce some of the need for chemicals.
GOT QUESTIONS?
If this article has sparked some questions for you, let us know and we'll try to answer them for you.
technical@bpca.org.uk
Source: PPC107