Why Is HSE Consulting on Anticoagulant Rodenticides?

The Health and Safety Executive (HSE) has opened an early public consultation on six anticoagulant rodenticides (AVKs):

• Difethialone (CAS 104653-34-1)
• Difenacoum (CAS 56073-07-5)
• Bromadiolone (CAS 28772-56-9)
• Brodifacoum (CAS 56073-10-0)
• Flocoumafen (CAS 90035-08-8)
• Coumatetralyl (CAS 5836-29-3)

These substances are widely used under Product Type 14 (rodenticides) of the GB Biocidal Products Regulation (BPR). Because of their classification as toxic to reproduction, they meet exclusion criteria but remain approved on the basis of being essential for public health, animal health, and environmental protection. As part of their renewal process, HSE must now examine whether suitable alternatives exist.

Current Restrictions on AVK Use

AVKs are already subject to restrictions, including:

• Prohibition of use in open areas for some substances.
• Restrictions to trained professionals only.
• Requirements under stewardship schemes (e.g. CRRU) mandating tamper-resistant baits, routine checks, and record-keeping.

Despite these measures, risks remain. Non-target species, pets, and even children may still access bait boxes. Secondary poisoning is possible when predators or scavengers consume poisoned rodents. Technicians are expected to carry antidotes (vitamin K1) in case of accidental exposure. There are also welfare concerns, as AVKs cause death by internal bleeding, which can be prolonged and painful.

AVK Alternatives: Opportunities & Limitations

While AVKs are effective, alternatives are being explored:

• Other PT14 Chemicals
  Primarily gaseous or gas-releasing compounds (e.g. phosphine, hydrogen cyanide). These provide quicker, less painful deaths but are limited by safety risks and practical constraints (airtight chambers, reloading requirements, professional-only use).
• Non-Chemical Control Methods
  Mechanical traps offer safer options but struggle to demonstrate consistent effectiveness in controlling large infestations.

At present, AVKs remain the dominant tools in rodent control, making up six of only ten PT14 actives currently approved under the BPR.

What Would Removal of AVKs Mean?

If AVKs are not renewed, chemical control options in the UK would be drastically reduced, limiting availability for both professionals and the general public. Stakeholders need to weigh the trade-off between effectiveness, environmental protection, human safety, and animal welfare.

Consultation Timeline & How to Respond

The public consultation is open until 30 September 2025. HSE invites all stakeholders – manufacturers, pest control professionals, NGOs, and the public – to provide evidence and opinions on whether these substances should remain available, and under what conditions.

You can submit comments through HSE’s website.