FAQ - Pest Management Trained Professional Users - February 2018
Q. I completed a training course but it is not on the list on the registration website, what do I do?
A. Select ‘Other’ and enter details of the training course. DAFM may contact you to provide information on the course content.
Q. Where can I find details of the CRRU Wildlife Aware Courses?
A. Details of the CRRU Wildlife Aware Courses are on their website.
Q. I am thinking of moving to another company or setting up my own business, how does this affect my registration?
A. You register as an individual rather than an employee of a company, if you move companies your registration will remain valid. However, if you supplied company specific contact details (email, address, and mobile) these will need to be updated to ensure you receive communication.
Q. I am new to the industry and need a PMU No to purchase product. I am undergoing training but it is not complete, can I register?
A. You can register and receive a Conditional Approval as soon as you complete a recognised training course, you will be required to complete the CRRU Wildlife Aware Course within 4 months of receiving Conditional Approval. However, you cannot purchase product until you receive your full approval, you must be supervised at all times during your training by an approved Pest Management Trained Professional User.
Q. Why do I have to participate in CPE?
A. CPE is essential for the application of Best Practice. Training programmes are in place in many EU Member States for those who offer a commercial service of pest control to third parties. It provides Pest Management Trained Professional User the opportunity to keep abreast of upcoming changes that will affect the industry and allows them the opportunity to change practice and react in a planned structured manner. DAFM will recognise CPE schemes that meet the requirements for continued registration as a PMU in Ireland.
Q. I am a farmer and use rodenticides during the course of my work; do I have to register as a trained professional user?
A. No, farmers can purchase professional use products for use indoors and outdoors around buildings. You will be required to supply your herd number when purchasing the products and follow the instructions for use on the product. If you wish to provide a service to others, you must complete the required training courses and register as a Pest Management Trained Professional User.
Q. I am a gamekeeper and use rodenticides during the course of my work; do I have to register as a trained professional user?
A. Gamekeepers can purchase professional use products for use indoors and outdoors around buildings. If rodenticide is required in open areas, you will have to contract in a Pest Management Trained Professional User to control rodents in open areas, or complete the required training and register as a Pest Management Trained Professional User to carry out this task yourself. A PMU number will be required to purchase trained professional use products.
Q. Is there any standard that Professional Pest Control Operators should adhere to?
A. EN 16636:2015 (Pest management services – requirements and competences) was published in 2015. Annex A of this standard identifies the required competences for professional pest management services; these are detailed in Table A.1. This standard specifies the requirements, recommendations and basic competences under which pest management servicing companies must operate to meet the needs of their customers, be they private companies, public authorities or the general public.
This Standard will contribute to controlling unprofessional use of biocidal products, facilitate the availability of a labour force working at an agreed industry standard across the EU and ensure the implementation of Best Practice in all aspects of pest management, including the application of rodenticides.
The CRRU Ireland Best Practice Requirements for Rodent Control and Safe Use of Rodenticides, available at http://www.crru.ie/best-practice/ and published in 2016, highlights best practice to be followed by individual professional and trained professional users of rodenticides. Compliance with the prescribed best practices facilities the identification of situations in which the use of rodenticides is warranted, facilitates the effective use of rodenticides and minimises potential impacts on non-target species, including birds or prey and mammals. Labels of rodenticide products for both professional use and for trained professional use, require that rodenticide users abide by the CRRU Ireland Best Practice Requirements for Rodent Control and Safe Use of Rodenticides.
Q. Why should we comply with this standard?
A. Compliance with this Standard and with the Best Practice Requirements will contribute to controlling unprofessional use of biocidal products, facilitate the availability of a labour force working at an agreed industry standard across the EU and ensure the implementation of Best Practice in all aspects of pest management, including the application of rodenticides.
Q. Is there a minimum pack size for AVK anticoagulant rodenticide products supplied to professional or trained professional users?
A. Yes. A minimum pack size of 2.5kg will apply in general, with derogations for specialist formulations.
Q: I understand the need to relabel amateur use products from 1st March 2018. Do 50 ppm products need to be relabelled from 1st March 2018?
A: Yes. All rodenticide products on the market at 01 March 2018 must be labelled according to current Classification, Labelling & Packaging regulations and Biocidal Product regulations. All amateur products containing >30 ppm must be removed from the market on the 28th February 2018.
Q. Most Irish rodenticide labels are dual labels which cover the UK as well. Will the upcoming changes to labels add further confusion?
A. All product labels are based on the text in the Summary of Product Characteristics (SPC) and the instructions on the labels are clear for the user. If the instructions on the label are followed, there won’t be any confusion for the user.
Product labels should be read before use and follow the instructions set out on the label as labels can be subject to change at any time.
Q. Due to the delay in product authorisation renewals, will PCD extend the 180d + 180d phase-out for products already labelled to CLP standards?
A. Under Article 52 of the BPR, the competent authority (CA) can issue a period of grace, “the period of grace shall not exceed 180 days for the making available on the market and an additional maximum period of 180 days for the use of existing stocks of the biocidal products concerned.” The 180 day period is applied from the date of renewal of the product. The renewed products will receive a new authorisation number (IE/BPA) and the old number/CLP product label will receive 180 day phase out and a further 180 day use up. This will only apply to the professional product as the amateur products cannot be sold post 28th February 2018.
Q. Do PRCD intend making the record keeping requirements (for distributors) a legal requirement? There are data protection and commercial confidentiality issues.
A. Record keeping is a legal requirement under our national statutory instrument SI 427 of 2013. The new GDPR sets out requirements for all companies in relation to data, each company needs to ensure they are complying with data protection requirements.
Q. What records should distributors keep and how should they keep them?
A. The requirements are set out in the following link, records on all goods in and goods out need to be kept and there is a minimum amount of details required specified. Click here for further details.
Q. How can a merchant verify a PMU number?
A. All registered Trained Professional Users (PMU) are listed on the register published on the Department of Agriculture Food and the Marine’s website. It is the responsibility of the Merchant to ensure that PMU’s are registered. Trained Professional Users require CPE to remain on the register so periodic checking is advised. http://www.pcs.agriculture.gov.ie/registers/
Q. What number should arable farmers present at point of sale to prove they are professional users?
A. Arable farmers should present their Herd number (also referred to as Basic Payment Scheme number or Area Aid number).
Q. How can a distributor check at point of sale if a herd number or address is genuine?
A. The distributor can contact DAFM if there are any concerns in relation to validity of the herd number been presented to them.
Q. Is an online reporting system (record keeping) a digital logbook instead of a physical folder acceptable?
A. Yes, it is the responsibility of the authorisation holder, marketing company, distributor, wholesaler, retailer, professional user and trained professional user to keep the minimum set of records required of them by DAFM. These records can be in paper or electronic copies once they are in a format that can be sent to DAFM on request.
Q. Please clarify which rodenticide active substances can be used for: 1. Pulse baiting & 2 Permanent baiting, by trained professionals.
A. Pulse Baiting: Brodifacoum, Difethialone & Flocoumafen only.
Permanent Baiting: Bromadiolone & Difenacoum only
Q. How should dead rodents be disposed of?
A. Dispose of dead rodents in accordance with local requirements, using one of the following methods of disposal (in order of preference):
· via an on-site or on-farm small carcass incinerator,
· with the site’s or farm’s domestic waste,
· in the site’s or farm’s normal non-hazardous waste, or
· by burial on-site, but away from sensitive areas.
Q. How should old rodenticide be disposed of?
A. At the end of the treatment, dispose of uneaten bait and the packaging in accordance with EPA requirements for the disposal of hazardous waste. Use of gloves is recommended. Unused rodenticides are classified as hazardous waste and are accepted at civic amenity centres, and also at the Farm Hazardous Waste Collections that are held periodically at different centres around the country. The services of a licenced hazardous waste contractor may be engaged.