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Jonathan Peck
Senior Member
United Kingdom
167 Posts |
 Posted - 15 Feb 2008 : 23:49:19
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Dear all
We have been asked by several customers about the legal requirements for distributors taking back rodent bodies.
The legal position is as follows:
a) If a distributor is taking back rodent bodies to their own premises, or allowing customers to deliver them to their premises, this would be considered as a bulking up activity hence the premises would need to be licensed as a waste transfer station and the relevant criteria met by the licence holder.
b) If the distributor disposed of the carcasses at their own premises, again a WML (or environmental permit depending on the method of disposal - incineration/burial etc) would need to be obtained.
c) A distributor can have a contract with a third party licensed waste transfer site providing that the waste is not stored at the distributor's premises between collection from the customer and disposal at a licensed site. The site must be licensed to accept that waste and the distributor must be registered as a waste carrier if they are going to be transporting the waste from the customers premises. The distributor's premises cannot act as a drop off point for customers without being licensed - even if another licensed site is then used for disposal - see a)
The Killgerm premises at Ossett are a licensed waste transfer station and so any rodent bodies disposed of there will meet legal requirements.
Hope this helps.
Best wishes
Jonathan Peck
Killgerm Group |
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notcorporate
Starting Member
7 Posts |
Posted - 17 Feb 2008 : 11:05:04
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| Yes - clear as mud |
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Fenn Man
Senior Member
Ireland
485 Posts |
Posted - 17 Feb 2008 : 22:37:14
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 God Damn! You Actually Said It!!!
That nearly cost me Guinness and a Key Board, that one!
I read it myself, the other night. Read it again. Gave up and went away! Couldn't make head or tail of it either 
Nice try though, Jonathan. I'm sure some here will have worked it out .....
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Jonathan Peck
Senior Member
United Kingdom
167 Posts |
Posted - 17 Feb 2008 : 23:47:50
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Steve
What it means is that a distributor may only collect or dispose of rodent bodies on behalf of a pest control company in the UK if they have a licence to do so from the Environment Agency. Licences are only granted if the distributor has a staff member who is suitably qualified as a waste disposal manager.
Distributors may have a contract with a waste management company but the rodent bodies must be handed in direct to the waste management company's premises and not be disposed of via the distributor's premises. The distributor would then pick up the bill from the waste disposal company.
Killgerm does have a waste transfer licence and so it can accept rodent bodies legally if required from companies registered under its waste disposal scheme.
Does this explanation help?
Best wishes
Jonathan Peck
Killgerm Group |
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Fenn Man
Senior Member
Ireland
485 Posts |
Posted - 18 Feb 2008 : 23:43:26
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Does that help?
Well, I think I'm getting there, Jonathan. Thankfully it doesn't overly concern me as I'm ex uk and 'Farmer' orientated these days. In fact, I'd have to be up pretty early to beat most of my clients to the bodies!
Quite honestly though ~ now ye've re explained it in more human terms ~ I think it's the " Distributor " that throws one. I gather Killgerm is " The Distributor " ? Only I always look of you and any such outfits as " Suppliers ".
Damn silly and illogical difference, I know but, I couldn't get my head round the person Distributing dead rats. Oddly, if ye'd said Supplier, it wouldn't have crossed my mind that that meant anyone but KG. And I wouldn't have thus found myself stumbling around trying to fit the other bits into place.
All a bit what we, here in the Bog Land, might refer to as " Dublin Irish ", that first Post 
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Jonathan Peck
Senior Member
United Kingdom
167 Posts |
Posted - 19 Feb 2008 : 00:21:55
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OK Steve
I used the word distributor because that is the word that the UK Environment Agency used. Supplier is the same thing in this context.
Best wishes
Jonathan
PS Did you know that it is illegal to use either Storm or Klerat in crop protection in the EU now? That will no doubt come as a shock to many Irish farmers!!
Both products can now only be used as biocides, ie in public health.
Best wishes
Jonathan Peck
Killgerm Group |
Edited by - Jonathan Peck on 19 Feb 2008 01:11:36 |
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The Spotlight Kid
Hyperactive Member
610 Posts |
Posted - 19 Feb 2008 : 08:39:29
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| Jonathan, what is the industry definition of "crop protection" when using rodenticides? |
Edited by - The Spotlight Kid on 19 Feb 2008 09:00:51 |
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Fenn Man
Senior Member
Ireland
485 Posts |
Posted - 19 Feb 2008 : 14:22:13
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Jonathan; Much of what these Irish Farmers do with rodenticides comes as a shock to me, mate! I don't think I've ever met one who's shown any sign of having ever read the label 
Crop Protection? Outside my remit. In the area I operate the only thing approaching a 'crop' is beef, silage and hay. I guess one could say then that my own approach to health protection is two pronged: I protect health by destroying the rats that threaten it. And, in so doing, I take the baits out of the (bare!) hands of those who would otherwise endanger their own health with the practices they picked up from their fathers before them and would now pass onto their sons.
Ever been to Co. Leitrim, Jonathan? Ye can get here overland from Dublin. Or in the Tardis! Know what I'm saying?
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Jonathan Peck
Senior Member
United Kingdom
167 Posts |
Posted - 19 Feb 2008 : 23:06:16
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Spotlight
The following is the official distinction between rodenticides as a biocide and a plant protection (crop protection) product.
"Biocidal Product 14 (Rodenticides): Products used for the control of mice, rats or other rodents outside plant growing areas (agricultural field, greenhouse, forest), for example in farms, cities, industrial premises etc, and inside plant growing areas not to protect plant or plant products 2 . Products for the control of squirrels (Sciurus spp.), when within the scope of Directive 98/8/EC, are excluded from this product type since they are included in PT 23 (Control of other vertebrate).
Plant Protection Products: Rodenticides applied in plant growing areas (agricultural field, greenhouse, forest) to protect plants or plant products temporarily stored in the plant growing areas in the open without using storage facilities."
Of course, greenhouses would cover not only horticulture but also garden centres and parks departments. Products containing brodifacoum, coumatetryl and flocoumafen are illegal in plant protection because they were not supported under the Plant Protection Products Directive. All three are being supported under the Biocidal Products Directive which is why they can still be used for biocidal purposes.
Best wishes
Jonathan Peck
Killgerm Group |
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The Spotlight Kid
Hyperactive Member
610 Posts |
Posted - 20 Feb 2008 : 08:22:58
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Thanks Jonathan. I assumed that is what was meant by plant protection but I just wanted to make sure it excluded grain stored in grain stores which it obviously does from that definition.
Thanks again. |
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Disposal of rodent bodies
