Last month conservation campaign group Wild Justice published a detailed report on the impact of the mis-use and abuse of second generation rodenticides (SGARs) on red kites and buzzards in England and the failure of the Government’s Rodenticide Stewardship Scheme, which had been set up in 2016 to reduce the amount of rodenticides in wildlife (see here for press release and a copy of the Wild Justice report, ‘Collateral Damage‘).
On the back of the publication of Wild Justice’s report, Scottish Greens MSP Ariane Burgess lodged the following parliamentary question on 19th November 2024:
Question reference S6W-31459
To ask the Scottish Government, in light of the latest report, Collateral Damage, by the UK campaign group, Wild Justice, which states that the Rodenticide Stewardship Scheme in England “is a failed scheme”, and other reports that have indicated increased exposure to anticoagulant rodenticides in common buzzards in Scotland, whether it has assessed the effectiveness of the rodenticide scheme in Scotland.
The question was answered by Agricultural Minister Jim Fairlie on 3rd December 2024:
The Scottish Government continues to contribute to UK-wide monitoring of rodenticide use and exposure in wildlife. There is evidence that many users of rodenticides are complying with the Campaign for Responsible Rodenticide Use’s (CRRU) Rodenticide Stewardship Scheme (RSS), and that in Scotland rodenticide use in agriculture has substantially declined since the introduction of the scheme. But, despite this, recent environmental data for Scotland indicate that it has not yet achieved the aim of significantly reducing wildlife exposure.
Both the UK Government Oversight Group, which includes Scottish Government representation, and CRRU have acknowledged that rodenticide residues in UK wildlife have not declined as hoped. The RSS is being updated firstly to ban the use of second generation anticoagulant rodenticides (SGARs) bromadiolone and difenacoum for open area use from the end of this year. This means no SGARs will be available for open area use; this is also intended to reduce accidental or deliberate misuse of other products in open areas. Secondly, training requirements for the farming sector are also being brought in line with other sectors from end 2025 to ensure a consistent level of professional training across all sectors and reduce the risk of poor practice.
Whilst it’s true that legal authorisation is being rescinded for the use of the SGARs Bromadiolone and Difenacoum in open areas (see press release on this from June 2023, here), it is very clear from the Wild Justice report that the total increase of SGAR exposure in red kites and buzzards in England is being driven by a dramatic increase in the use/mis-use of Brodifacoum, not by Bromadiolone or Difenacoum.
Brodifacoum is the dominant SGAR being found in birds of prey and is more toxic than Bromadiolone and Difenacoum. It used to be restricted to internal use only, until the Government decided to relax that regulation and permit its use ‘in and around buildings’ – a regulation that is obviously being breached routinely given the high levels of exposure in birds of prey (e.g. here).
From January 2025, Bromadiolone and Difenacoum will also be permitted for use ‘in and around buildings’, but there are no proposed tighter rules on the use of Brodifacoum.
Minister Fairlie suggests that a restriction against any use in open areas of any SGAR is intended to reduce accidental or deliberate mis-use of other products in open areas and that new training requirements for all users (not just professional pest controllers) will ‘reduce the risk of poor practice’.
I suppose he’s thinking that this standardisation will remove any supposed ‘confusion’ between the use of different products. However, given that Brodifacoum is already supposedly restricted to use only ‘in and around buildings’, yet has been used with increasing frequency by gamekeepers for targeting birds of prey, Wild Justice argues that the new legal restrictions are unlikely to improve things significantly.
The Wild Justice report suggests that a better option is to return Brodifacoum to its pre-April 2016 approval status, so that it can be used in strict ‘internal areas’ within buildings, and to limit its use to professional pest control companies.
For those who might have missed it, Wild Justice’s Collateral Damage report can be read/downloaded here:
Raptor Persecution UK 
“The RSS is being updated firstly to ban the use of second generation anticoagulant rodenticides (SGARs) bromadiolone and difenacoum for open area use from the end of this year. This means no SGARs will be available for open area use; this is also intended to reduce accidental or deliberate misuse of other products in open areas.”
I wonder how Jim Fairlie thinks any banning of bromadiolone and difenacoum will lead to a reduction in the deliberate misuse of brodifacoum?
Weird.
I think Swinney is merely reiterating CRRUs own explanation.
I.e. that by banning the use of the currently approved products in open areas it makes it harder for people to use any product in that manner, either accidentally or deliberately.
CRRU appear to have concluded that this has been happening as they indicate in this announcement:
seems unlikely that illegal use is the primary source of such widespread and frequent contamination. Across species.
https://www.thinkwildlife.org/ending-use-of-second-generation-anticoagulant-rodenticides-bromadiolone-and-difenacoum-away-from-buildings
of course, whether it reduces brodifacoum residues enough is another matter….
At what distance does ‘in and around buildings’ become ‘open area’ and vice versa? It only needs a few scattered buildings to effectively facilitate the driving of the proverbial coach and horses through the supposed tightening up of the rules for bromadiolone and difenacoum – much as no doubt already occurs with brodifacoum. The Wild Justice suggestion in its penultimate paragraph above is surely the way forward for all three of the substances involved here – the key being containment within secure internal areas within buildings. This may present practical difficulties but, if the conditions cannot be met, the poisons should not be used. One thing is for sure – the use and availability of brodifacoum, in particular, needs to be seriously curtailed.
Schrodingers rodenticide.
Where are these poisons coming from? I was told by a gamekeeper Ireland. Ban the import or is it like drugs, illegal?
Rodenticides are readily available for purchase throughout the UK.
I think you’re getting confused with the banned pesticide Carbofuran, which is not available for sale but has been linked to sources in Ireland.