In November last year, conservation campaign group Wild Justice published a report (Collateral Damage) highlighting shockingly high levels of rodenticides (rat poisons) found in Buzzards and Red Kites and showed how the UK Government was ignoring the evidence (see press release here).
This led to a flurry of Parliamentary questions (see here) and promises for a review in 2025.
Since then, further reports show that the use of Second Generation Anticoagulant Rodenticides (SGARs), particularly Brodicfacoum, is causing widespread harm to wildlife including Foxes, Otters and Peregrines (see here).
The Health & Safety Executive (HSE) which controls the approval regime in the UK for rodenticides and decides what can and cannot be used, has announced a consultation on rodenticides. The consultation is looking at what alternatives to SGARs are available.
If the HSE is going to continue to approve SGARs for use, it needs to show that no other viable alternatives are available.
Apart from taking preventative measures, there ARE other viable alternatives, but the chemical companies aren’t keen for these to be promoted because SGARs are highly profitable financially, even though they’re disastrous for many species, especially raptors, from an ecological perspective.
The alternatives include:
- Non-SGAR alternative rodenticides such as Cholecalciferol, with which the targeted rodent stops feeding once a lethal intake has been consumed (reducing risk of secondary poisoning of predators and scavengers).
- Zinc Phosphide – a highly effective acute rodenticide.
- DR8 – a product developed with the support of the New Zealand Government which is specific to rats and poses no apparent secondary poisoning risk.
- Carbon Dioxide gas (also known as Rat Ice).
- Contraceptive products such as ContraPest, which controls rat populations by restricting rodent reproduction.
The HSE’s public consultation is not especially user-friendly, and nor does it seem to have been widely promoted (apart from amongst the chemical companies who will no doubt be pushing for the HSE to retain its approval for SGARs and to ignore the alternatives).
However, Wild Justice has prepared some helpful guidance on how to complete the consultation and is encouraging as many members of the public as possible to take part – you’ll find the guidance here.
The deadline for completing this consultation is this coming Tuesday (30 September 2025) so we don’t have long.
Please, if you have some time today, have a go at completing the consultation and help put pressure on the HSE to remove, or at least limit, the use of SGARs.
Thank you.
Raptor Persecution UK 
Hi, I guess your Carbon Dioxide is in the solid form, commonly known as ‘dry ice’, which sublimates to CO2 gas. Heavier than air, this could fill a burrow system and asphyxiate the inhabitants.
Or do they use CO2 fire extinguishers?
What a bizarre, so-called, ‘public consultation’ document – both in terms of complexity and format. Thanks to Wild Justice for attempting to plan a path through the mire.
I found this form unecessarily complicated. Moreover, for people who do not have the skills to access online forms, let alone a microsoft account, it is impossible.
May I suggest to the HSE that they comply with the Equality Act 2010, and publicise accessible non-digital alternatives for this Public Consultation.
To do this, they will have to extend the deadline.
Fully agree with this excellent comment. I have to admit that I gave up trying to complete the form. As far as I could see it did not provide an opportunity for individual comment on the current findings regarding the use of SGARs. I have first-hand knowledge of the devastating effects of these substances on Red Kites, whether as fatal doses or as background levels in cocktails of a variety of poisons – including several SGARs and other substances no doubt deployed as primary poisons on illegal baits. One kite tested positive for no fewer that 8 poisons! We know of 18 Yorkshire deaths directly attributable to rodenticide ingestion and there have, no doubt, been many more which have not been detected or reported.
I hope that the HSE heeds the suggestion in the comment above and produces something that is more user-friendly, not least in terms of what computer software it uses. Maybe RPUK and/or Wild Justice could ensure that this issue is brought to their attention.
Earlier today I did manage to complete the consultation as suggested by Wild Jusice. I could not manage on my phone. I highlighted the difficulty, as also suggested by Wild Justice. I hope that there are sufficient persons who subscribe and are able to respond to make a difference. I’m sure that the “opposition” has made available a copy of the suggested response to their users of the products. Wild Justice is perhaps more honest in providing a method of response rather than a doctors file with the suggested response. A pity, perhaps.
I don’t have MSword.
Therefore I don’t have any other alternative but to not participate in the ‘consultation’. A .docx isn’t the way to engage with everyone.
Carbon dioxide rodenticide and the “other SGAR consultation”
The HSE consultation is not the only one being conducted at the time being. There is another one being carried out in the Commonwealth of Massachusetts in the USA, which is very much encouraging public engagement and anyone can respond to by a variety of ways. For those interested, we have placed a copy of latest Massachusetts report (Phase 2) on the WPRUK website – in the reference section (address: wildlifepoisoningresearchuk.wordpress.com). This report has been independently produced by Eastern Research Group (ERG) on behalf of the Massachusetts Dept of Agricultural Resources and does provide a good description of some of the alternatives to Second Generation Anticoagulant Rodenticides (SGARs – or AR’s as they are called in the USA). Some alternatives have been missed out (DR8 and chloralose, which we have asked to be included).
ERG comments on Carbon Dioxide are as follows:
Carbon Dioxide
As of 2025, three rodenticide products registered for use in the Commonwealth have carbon dioxide as an active ingredient; and two of these three were used by licensed applicators in 2023 (Table 20). The uses in 2022 and 2023 were dominated by Rat Ice, which accounted for 99.5% of the statewide uses. The other and less widely used product, IGI CARBON DIOXIDE, involves using canisters of carbon dioxide to asphyxiate rodents in their burrows (Kelly Registration Systems, Inc, 2025; MDAR, 2025)
EPA first registered Rat Ice for use in June 2017. The product uses dry ice (i.e., solid carbon dioxide), which then releases carbon dioxide gas. Rat Ice is applied in pellets that are less than an inch in diameter. Applicators locate rodent burrows and place the pellets inside, then block off the burrows. As the dry ice sublimates, the released carbon dioxide displaces oxygen in the burrow. The resulting carbon dioxide buildup eventually leads to asphyxiation, killing rats within a few hours of application (DC Health, 2018). Dry ice products such as Rat Ice are intended for outdoor applications. Applicators should avoid using dry ice when people or animals are in nearby buildings. Applicators should wear appropriate personal protective equipment (e.g., heavy insulated gloves, eye protection) to prevent burns from contacting the pellets. Additionally, the resulting carbon dioxide can be hazardous in confined spaces.
Among the chemical rodenticide alternatives considered in this report, carbon dioxide was used in the greatest quantities by licensed applicators in Massachusetts in 2022 and 2023 (Figure 4). The carbon dioxide usage self-reported by licensed applicators decreased by 82% between 2022 and 2023. The reason for that decreased usage is not known.
The resources that ERG reviewed identify various advantages associated with using dry ice products (with carbon dioxide as the active ingredient) for rodent control. These advantages include:
• When applied according to label instructions and not in enclosed spaces, dry ice products are generally safe for use around humans and pets.
• Dry ice does not leave toxic residues, nor is it of concern for soil or water contamination.
• Exposed rodents typically die within minutes to hours, making this an efficient alternative to ARs, which typically take longer to kill rodents.
• Because it is a gas, carbon dioxide from the alternative products readily spread to hard-to-reach areas in burrows, which is more challenging for baits.
• Unlike ARs, carbon dioxide products do not result in secondary poisoning.
Disadvantages of carbon dioxide products include:
• These products are only viable when burrow locations are known.
• Rodent carcass removal from burrows can be challenging, though this concern also applies to various other burrow-based rodenticide applications.
………
Talking to others involved in wildlife management in the USA, it does appear that carbon dioxide is effective as a means of rat control, just so long as done by trained individuals. Whether or not the Massachusetts consultation and review will actually result in any change in how SGARs are used is yet to be seen. However, one has to admit that how this process is being done in the USA is far better than in the UK.
other alternatives should be used and the public made aware as I for one do not want other species to be killed because of poisoning. I did not know there are alternatives so I am disgusted to hear the public have not been informed
I tried to leave a comment on above
but it has not found its way to you
Can I try this way?
Like your other commenters , I am sickened by the lack of publicity given to this consultation
Thanks to you giving awareness, I tried very hard to respond to the consultation on both iPhone and iPad. I could get no further than filling in my name
This consultation is not at all useful friendly-whoever agreed it needs a spell on the shop floor . I would need to employ a compute expert to fill that in
Consequently, so annoyed snd frustrated I wrote to complain to thd HSE. Their automatic response tells me I can wait for 21 days for a reply. As the consultation finishes in 24 hours, I hae ma doots
Carol
Do you not think this is the whole purpose make things as difficult as possible so it’s difficult for us caring mortals to make a point then you give up and they don’t do anything.
Re: so-called ‘public consultation’ on SGARs
“Do you not think this is the whole purpose make things as difficult as possible so it’s difficult for us caring mortals to make a point then you give up and they don’t do anything.”
Exactly!
It happens over-and-over again, in all walks of policy. Governments have all sorts of weapons to achieve their ends when ‘consulting’ the public: going-through-the-motions-and-ignoring-the-results; posing leading questions to get the results they want; using proprietary, hardware-specific software; designing user-unfriendly forms; swamping users with multiple forms; swamping users with too much background information; using subject-specific jargon and technical terminology…
I missed the (short) deadline because I’ve been dealing with something else, but I sent them an email, instead, to let them know my feelings… which they might just bin:-(