02 September 2020

Open letter to the Scottish Animal Welfare Commission: glue traps for professional use

BPCA has written to Andrew McKinlay, policy advisor for the Scottish Animal Welfare Commission (SAWC), in response to a call for evidence on the use of glue traps for pest management. This response will be shared with the SAWC's Glue Traps Working Group. 

The letter expresses our concern that an outright ban on glue traps would remove a vital piece of equipment from a pest professional's toolkit, preventing the use of them as an important last resort control method. 

You can read the letter in full here:

Mr Andrew McKinlay
Policy Advisor
The Scottish Animal Welfare Commission Secretariat
Animal Health and Welfare Team
P-Spur, Saughton House
Broomhouse Drive
EH11 3XD

RE: Invitation to submit a statement on glue traps

Dear Andrew McKinlay,

Thank you so much for sending us an invitation to submit our views on the use of glue traps for the purpose of pest management and protecting public health.

As I’m sure you’re aware, the British Pest Control Association (BPCA) is already working as part of the Pest Management Alliance (PMA) to provide a view on glue traps as part of a public petition in the Scottish parliament.

To be clear, this letter is a direct response from BPCA on behalf of our members (700 companies across the UK) and does not include the views of the other PMA stakeholders.

Let me begin by acknowledging that glue traps do have the potential to impact animal welfare significantly. This particular control method in the wrong hands can be very nasty, and we certainly understand why many would see their use as distasteful.

As with all pest management, we have to balance public health with animal welfare concerns. No pest professional wants to cause suffering. Our training teaches us that our first thought should be to restrict the possibility of ingress.

In short, prevention is always better than cure. Given a choice, all professionals would rather be part of stopping an infestation before it occurs, rather than to kill an animal - even a rat or mouse.

As with all pest management, we have to balance public health with animal welfare concerns.

However, this ethos comes with a healthy dose of realism. Once an infestation has occurred, our profession has little choice but to use lethal control for the sake of riddance, thereby protecting public health.

Our sector has a toolkit. In it are tools such as traditional traps, rodenticides and glue traps. Once an infestation has occurred, it’s a professional’s responsibility to choose the right tool, balancing:

  • Animal welfare and suffering
  • The risk to public health
  • The risk to non-target species
  • The practical limitations of the environment.

Our members follow a risk hierarchy (ranked lowest impact to highest): 

  1. Proofing
  2. Denial of food and water
  3. Removal of harbourage
  4. Trapping
  5. Biocides ie rodenticides (ranked least harmful to the environment to most harmful)
  6. Glue (sticky) boards (last resort).

With so many items in our toolkit with a lower risk than glue boards, it seems only right that legislators and welfare organisations would ask us if we truly need glue boards to protect public health?

We believe that we do.

As we’ve already stated, prevention is better than cure. However, once an infestation has occurred, proofing, denial of food & water and the removal of harbourage is out of the question.

Next, we look at traps. Traps are a fantastic tool that, when used correctly, can provide an excellent form of riddance. When used by professionals (in tunnels or secured boxes), they pose little risk to non-target species. Professional rodent traps kill quickly when properly set, meaning there is little opportunity for suffering.

However, a trap is not suitable in all situations. Rats and mice are naturally scared of new things by nature (neophobia). It can take a long time for rodents to become used to a trap in any given environment. While in many situations this isn’t an issue, when it comes to hospital wards, operating theatres or school kitchens or where vulnerable people will undoubtedly be present, it can be very dangerous as we often cannot wait a number of days for the traps to work.

These situations pose imminent threats to public health.

Rodents carry and transmit pathogenic microorganisms (and therefore disease). Failure to act quickly in a high-risk environment can result in sickness, distress and death.

Like traps, rodenticides are another invaluable tool for professionals. However, these chemicals have similar limits. Rodents are naturally suspicious of new things, particularly when it comes to their food. Rodents that have fed from rodenticides don’t die instantly, sometimes meaning that carcasses are challenging to recover.

Some environmental risk assessments will not allow for the use of rodenticides as they are bioaccumulative and can pose a risk to non-target species. It can be difficult to get rodents to feed on baits when an alternative and plentiful food source is still available to them (not all available food will be removed in every situation).

Rodents carry and transmit pathogenic microorganisms (and therefore disease). Failure to act quickly in a high-risk environment can result in sickness, distress and death.

As we reach towards the bottom of our toolkit, I hope you can begin to see the vital role glue board can play.

These are not tools professionals reach for lightly, or indeed regularly. However, in niche circumstances where there is an imminent risk to people’s lives, we’re thankful we have a last resort to hand.

Our sector has long recognised that these tools are dangerous in the wrong hands (as are almost all the tools listed in this letter). For the last 12 years, BPCA has been active in producing Codes of Best Practice on glue boards (first on our own, and then through the PMA).

The current document (available here) makes clear our current thoughts on glue boards.
To summarise, our key thoughts are outlined in this document:

  • Glue boards should be used as a last resort when all other tools we have at our disposal have proved to be ineffective or inappropriate
  • Glue boards should only be used by trained and competent professionals (see below; BPCA membership criteria)
  • Glue boards should be checked at least every 12 hours, and their continued use should be assessed every 24 hours
  • Anyone who has placed a glue board must be able to competently and humanely dispatch any caught rodent (making glue boards unsuitable for amateur use)
  • The technician responsible for the glue board must have a contingency plan where a second technician can inspect the glue traps in an emergency, and an emollient is made available if a non-target species was to be caught
  • Detailed reports regarding the use of glue boards should be maintained at all times
  • Glue boards should be removed at the end of treatment and disposed of appropriately.

The Code of Pest Practice was produced in consultation with the Department for Environment, Food & Rural Affairs and the Animal and Plant Health Agency. It has full cross-sector support from BPCA, The Chartered Institute of Environmental Health and the National Pest Technicians Association.

BPCA has the highest membership standards of any pest management organisation in the UK. Our members may only employ technicians that:

  • Meet or exceed the industry standard qualifications
  • Are compliant on a Continuing Professional Development (CPD) scheme.

All of our members are audited to the BS EN 16636 Standard for Pest Management. They must pass this audit to remain in membership. You can see the full requirements to be a BPCA member on our website here.

Our members take pest management seriously, and if it were up to us, only companies who have proven they meet the standards of BPCA membership would have access to the more dangerous tools in our kit - including glue boards.

Pest management is mostly unregulated, as at least on paper we’re a tiny sector.

That doesn’t mean that some companies aren’t striving for the highest professional and technical standards. Many are. They’re our members.

Nor does that mean we’re not a vital part of society. Governments across the UK declared the importance of public health pest management by designating pest professionals essential workers during the Covid-19 pandemic.

In conclusion:

We support any proposed partial ban to glue boards that takes them away from public use or anyone else who wouldn’t ordinarily meet BPCA’s membership criteria.
We support any mandatory labelling or documentation that highlights the risks of improper use (the PMA Code of Best Practice could be used for this).
We do not support an outright ban of rodent glue boards for professionals (our definition for which makes up our membership criteria).

A ban on glue boards would remove a tool that helps protect some of the most vulnerable people and high-risk environments. This would have a detrimental effect on public health in Scotland.

Our team at BPCA will support your consultation in whatever way possible. If you have any follow up questions or if we can provide any guidance during your deliberation, please ask.

We appreciate you taking the time to ask for our input and consider our point of view.

Yours sincerely,

Ian Andrew

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