Conclusions and recommendations
1. Reasons for using glue traps
There are public health concerns in certain high-risk situations that clearly require effective and rapid pest control in order to reduce the spread of disease. However, the Commission is not convinced that evidence exists supporting the view that glue traps are genuinely the only method of last resort.
2. Animal welfare issues
The Commission noted unanimous recognition that glue traps cause animal suffering, with the majority of respondents indicating the likelihood that their use causes significant and potentially prolonged animal suffering to the target species. Importantly, concerns are not isolated to a particular aspect of the use of glue traps and even with optimal use (frequent checking and effective dispatch) there remains a significant animal welfare concern. It is the view of the Commission that there is no way that glue traps can be used without causing animal suffering.
3. Non-target captures
There is an undeniable risk of capture of non-target species. However, without knowing how frequently glue traps are used it is not possible to quantify that risk. Information on how 'indiscriminate' other forms of control are in comparison to glue traps would also be useful – in relation to rodenticides in particular.
4. Alternative methods
There are a range of alternative pest control methods available and glue traps are often cited as only being used as a last resort in high risk (to public health) settings. The Commission concludes that it is difficult to justify the use of glue traps, except possibly in the most significantly high-risk (to public health) settings, such as hospitals. However, even in those settings the Commission cannot support the continued use of glue traps, given the very high likelihood of animal suffering. We note no evidence is provided to back up the statement that glue traps are only used as a last resort and there is a likelihood that this is not always the case with some operators. Independent expert advice should be harnessed to identify a ranking of likely suffering caused by all current methods of pest control to justify a hierarchy or cascade of future use.
5. Ethical considerations
The labelling of target species as 'pests' in this context should be discouraged in the future. It is important to recognise that 'pest' animals have the potential to suffer to the same extent as other sentient 'non-pest' species. In considering all 'pest' control methods, the Commission would like to see these ethical considerations higher up the agenda and explicitly addressed in all future discussions.
6. Legislation in other countries
In those countries that have introduced legislation the general direction is toward licensing the use of glue traps in specific and limited circumstances and the use of glue traps by the general public has been banned. Where a strict licensing approach has been adopted the number of applications for such licences has reduced significantly or has not occurred at all. The Commission concludes that the outright ban for sale of glue traps to the general public is appropriate and that, to further reduce (and ultimately end) their use a very strict licensing approach should be adopted.
The Commission believes that the animal welfare issues connected with the use of glue traps would justify an immediate outright ban on their sale and use. This is our preferred recommendation. However, given that some agencies have suggested that in some cases there is no alternative to the use of glue traps as a last resort, if the Scottish Ministers are not minded to introduce such a ban at this stage, the Commission recommends implementation of Option 5 (until such time as an investigation into alternatives has been completed), with the following specific recommendations:
1. There should be an immediate outright ban on the sale of glue traps to the general public.
2. An interim licensing regime should be introduced as soon as is practicable.
3. The parameters of that licensing regime should form part of future discussions and consultations. However, the Commission would favour the following requirements:
a. Licences must be applied for by individual operators (not companies – see note below).
b. Licences must only apply to a single location where there is a significant risk to public health.
c. Licences must only be situation-specific (referring to a particular incursion).
d. Licences must be time-limited and not open-ended.
e. Licences must only be granted where clear evidence of a 'cascade' of use of alternative methods can be demonstrated. Documentation of such a cascade of use should be a prerequisite of a licence application
f. Licences must require operators to implement mechanisms to reduce the time between capture and humane destruction to the minimum, ideally by use of remote monitoring methods to ensure immediate attendance at the trap site.
4. The licensing regime should be time-limited and subject to review within three years of its introduction, with a view to ending the use of glue traps altogether following investigation of alternative approaches.
5. Professional pest control companies should be encouraged to invest in research and development aimed at the identification of additional humane methods that would replace the apparent need for glue traps.
6. Once the legal status of any proposed Code of Practice has been determined, the Commission recommends the creation of an independent group of experts in animal welfare and behaviour, ethicists and pest control practitioners, with support and oversight from the Commission, to develop a Scottish code.
Note: The Commission considered the option of a general licence but preferred individual licensing because other general licences only permit methods that are assessed to be relatively humane, including non-lethal methods. This contrasts with the clear evidence that glue traps cause animal suffering as soon as the animal becomes trapped. It is unlikely that a general licence system would be able to mitigate this to any significant degree. Individual licences would ensure greater protection and accountability, particularly if they include conditions pertaining to record-keeping and reporting. The application process could be designed to include training and accreditation from an approved body.