URGENT: Tell BC to Adopt More Aggressive Rodenticide Policies
It is essential for the citizens of BC to call upon the Ministry to uphold its duty to protect, manage, and conserve BC’s water, land, air, and living resources by prohibiting ALL rodenticide products known to present unreasonable risks to BC’s wildlife. We encourage the public to submit comments regarding the proposed rodenticide policy changes before June 19, 2022, 11:59 pm PDT. Below are talking points you are welcome to draw from.
On May 4th, 2022, B.C.’s Ministry of Environment and Climate Change Strategy (“the Ministry”) announced it’s intent to make permanent changes to the Integrated Pest Management Regulation. Unfortunately, these changes fail to satisfactorily mitigate the risks posed by rodenticide use. Limited in scope to include only three rodenticide products while allowing broad exemptions and posing challenging enforcement logistics, the proposal does little to prevent primary, secondary, and tertiary poisoning of BC’s wildlife. As such, the proposed changes fall short of the Ministry’s obligations pursuant to the Integrated Pest Management Act to protect the environment from unreasonable adverse effects caused by rodenticide products.
Despite public demand to ban all rodenticide products, the Ministry intends to only restrict Second Generation Anticoagulant Rodenticides (“SGAR’s”), that is, only products containing the active ingredients brodifacoum, bromadiolone, and/or difethialone: just 3 of 27 active [toxic] ingredients found in rodenticides currently registered in Canada.
While products classified as rodenticides vary in the way they aim to kill unwanted pests (e.g., preventing normal blood clotting, causing internal hemorrhaging, or disturbing nervous system functions) ALL of these active ingredients pose serious threats to animals, including family pets and wildlife species, the environment, and human health, while at the same time failing to control rodent populations over the long-term.
Restricting only three rodenticides ignores serious risks posed by other products commonly used in BC, and leaves opportunity for the pest management industry to develop new products that fall outside of the proposed restrictions.
The exemptions to the proposed ban are unnecessary and overly broad.
Allowing rodenticide use across broad categories will negate the Ministry’s purported “aim to minimize the unnecessary use of SGARs to reduce accidental exposure to wildlife” (Rodenticides Intentions Paper, pg.1). Risks of rodents impacting infrastructure across these applications can and should be addressed in all cases using preventative measures and rodenticide-free alternatives ultimately leading to more permanent, cost-effective solutions in the long-term.
Clearing a resident rodent population simply makes space for new groups to move in as poisoned rats reproduce faster to compensate for thinning numbers. Rodenticide also eliminates natural rodent control by poisoning raptors and other predators. For example, a single barn owl consumes an average of 1,000 rodents per year.
Complexities of the proposed ban further frustrate compliance issues and enforcement impossibilities.
Expecting a “high level of due diligence” by IPM practitioners (persons licensed by the ministry) “when considering SGARs use” is ambitious at best. In addition to demonstrating prevention efforts, and collaborating with ministry inspectors to verify IPM adoption, i.e., “a science-based decision-making system that focuses on strategies to minimize unnecessary pesticide use” (Rodenticides Intentions Paper, pg.3) users will be expected to document prevention measures, keep daily records, and develop and follow an IPM plan for each location they are using SGARs [to be provided to ministry inspectors upon request].
Rodenticides (both “first'' and “second generation”) cause death over a period of days or weeks during which the poisoned rodent can disperse into the surrounding environment or die trapped within walls or other structures, where they are not conveniently collected. Additionally, rodents are known to have hoarding tendencies and will commonly collect food to store back at their nests, including rodenticide baits (Science Review, pg. 9). Moreover, the behavior of rodents suffering from rodenticide poisoning is known to make them more available for consumption by predators.
Asserting that “timely clean up of waste bait and dead rodents” is possible calls to question the ministry’s understanding of its own science review, and the [lack of] seriousness with which it is approaching an issue known to be affecting so many of BC’s treasured species.
The Ministry’s proposed changes are rooted in a flawed assumption that rodenticides are necessary and/or preferable in certain circumstances despite widely recognized science demonstrating that they are ineffective, dangerous, and inhumane.
The Ministry has a duty of care to protect, manage, and conserve BC’s water, land, air, and living resources. Continuing to allow any use of rodenticides is contrary to this obligation. The only sure way to mitigate risk to humans, animals, and the environment from the toxic effect of rodenticides is to discontinue their use. This could easily be achieved by establishing a new class of prohibited pesticides to the Integrated Pest Management Regulation prohibiting all of the rodenticide products known to present unreasonable risks to BC’s wildlife.