About you
3. What is your name?
Name
Ian Andrew
Organisation details
1. Name of organisation
Name of organisation
(Required)
British Pest Control Association
2. Information about your organisation
Please add information about your organisation in the box below
BPCA is the professional association for the UK public health pest management industry. We’re a not-for-profit organisation representing over 700 companies in the UK and highlight the risks of inadequate pest control. Our mission is to drive excellence in pest management.
Question page 1
1. Did you take part in any consultation exercise preceding the Bill and, if so, did you comment on the financial assumptions made?
Please provide your response in the box provided.
Yes, although we focused on the public health and social implications more than the financial assumptions.
2. If applicable, do you believe your comments on the financial assumptions have been accurately reflected in the FM?
Please provide your response in the box provided.
NA
3. Did you have sufficient time to contribute to the consultation exercise?
Please provide your response in the box provided.
No.
The Financial Memorandum states:
“55. […] It is anticipated that the costs to individuals and businesses arising from the provisions relating to glue traps are minimal due to the wide availability of alternative methods of rodent control at comparable cost”.
We believe this to be grossly inaccurate, underestimating the implications for tens of thousands of businesses in Scotland.
The Financial Memorandum states:
“55. […] It is anticipated that the costs to individuals and businesses arising from the provisions relating to glue traps are minimal due to the wide availability of alternative methods of rodent control at comparable cost”.
We believe this to be grossly inaccurate, underestimating the implications for tens of thousands of businesses in Scotland.
4. If the Bill has any financial implications for you or your organisation, do you believe that they have been accurately reflected in the FM? If not, please provide details.
Please provide your response in the box provided.
No.
The Financial Memorandum states:
“55. […] It is anticipated that the costs to individuals and businesses arising from the provisions relating to glue traps are minimal due to the wide availability of alternative methods of rodent control at comparable cost”.
This is incorrect.
Rodent infestations pose a significant risk to businesses in Scotland, particularly those in the food industry. While the Financial Memorandum suggests that the costs associated with the use of glue traps are minimal, this claim is grossly inaccurate. In fact, the proposed ban on glue traps would have catastrophic consequences for businesses and organisations across the country, leading to substantial financial burdens and potential public health risks. It is essential to recognise the unique benefits of glue traps and the need for a sensible licensing scheme instead of an outright ban.
Inherent risks of rodent infestations:
Every business operating in Scotland is susceptible to rodent problems, and this is especially crucial for establishments in the food industry. Older buildings, those near water sources, in close proximity to other buildings, or multi-occupancy premises are more likely to attract rodent infestations.
Despite preventive measures, the risk of an infestation can never be eliminated entirely, as rodents can enter a property through gaps as small as the width of a pencil.
Glue traps act as a physical barrier, effectively catching rats and mice and preventing them from reaching food or water sources.
Swift and effective rodent control:
Glue boards offer a fast-acting solution in critical areas such as food and hospitality businesses, hospitals, care homes, food factories, and vital infrastructure like utilities.
These establishments often cannot operate with even a single rodent present.
Compared to other rodent management programs that typically take two weeks to be effective (traps and poisons), glue board treatments allow premises to reopen within 2-3 days.
The use of alternative methods would result in temporary closures lasting a minimum of two weeks, causing an enormous additional cost burden for businesses.
The alternatives to glue traps are:
Proofing - cannot be used after an infestation has occurred
Denial of food and water - cannot be used after an infestation has occurred
Removal of harbourage - cannot be used after an infestation has occurred
Trapping - rodents are naturally suspicious of new things and often avoid newly set traps for some time
Biocides (poisons) - typically take around two weeks to control an infestation
Clearly when speed is critical, in areas such as hospitals, food premises and around vulnerable people, sometimes glue boards are the only viable option.
Scale of businesses and organisations at Risk:
Scotland is home to a significant number of businesses and organisations that would be severely affected by a ban on glue traps.
Consider the following figures:
22,000 shops (British Retail Consortium figures)
17,495 registered enterprises in the food and drink sector (source: https://www.gov.scot/binaries/content/documents/govscot/publications/statistics/2019/07/growth-sector-statistics/documents/food-and-drink/food-and-drink/govscot%3Adocument/Food%2Band%2BDrink%2B-%2BGrowth%2BSector%2BBriefing.docx)
5,073 schools (source: https://www.gov.scot/publications/summary-statistics-schools-scotland-4-2013-edition/)
1,069 care homes (source: https://publichealthscotland.scot/publications/care-home-census-for-adults-in-scotland/care-home-census-for-adults-in-scotland-statistics-for-2011-to-2021-part-1/ ).
229 hospitals (source: https://www.interweavetextiles.com/how-many-hospitals-uk/)
Imposing a ban on glue boards would jeopardise the operations of these establishments in the event of a rodent infestation, leading to significant disruptions in services and potential health hazards.
Real-life scenarios:
To grasp the impact of a ban on glue traps, we must consider real-life situations that would unfold without this effective tool.
Imagine a child's school forced to close for two weeks because the school canteen has shut down, waiting for poisoned bait to take effect.
Picture a small, family-run takeaway anxiously waiting for two weeks for a single rat in their kitchen to be caught by a newly laid snap trap.
Envision an entire food factory shut down while professionals attempt to capture a single rodent in critical machinery.
These scenarios highlight the adverse consequences of a ban on glue traps, including grounded planes, elderly residents displaced from care homes, and immense economic losses.
Calculations of cost to Scottish organisations
To estimate the cost of closures for each sector, we need to consider the average daily revenue of each establishment and multiply it by the number of days they would be closed. This is a rough estimate, and the actual costs may vary depending on various factors, such as the size of the establishment, location, and specific industry.
Additionally, it's important to note that the estimation assumes 50% of establishments would close once every 30 years.
Shops:
The cost of closure for 22,000 shops can vary significantly based on the type of shop and its average daily revenue. Let's assume an average daily revenue of £1,000 per shop. With a two-week closure, the estimated cost per shop would be:
£1,000 (daily revenue) x 14 (days closed) = £14,000
Total cost for half of 22,000 shops: (£14,000 x 22,000) / 2 = £154,000,000 over 30 years or £5,133,300 a year.
Registered enterprises in the food and drink sector:
Similarly, estimating the cost for 17,495 registered enterprises in the food and drink sector depends on the average daily revenue. Assuming an average daily revenue of £2,000 per enterprise, the cost per enterprise for a two-week closure would be:
£2,000 (daily revenue) x 14 (days closed) = £28,000
Total cost for half of 17,495 registered enterprises: (£28,000 x 17,495) / 2 = £244,930,000 over 30 years or £8,164,000 a year.
Schools:
Estimating the cost of school closures requires considering the average daily cost of operating a school.
This includes expenses like staffing, utilities, maintenance, and other overhead costs. Assuming an average daily cost of £5,000 per school, the cost per school for a two-week closure would be:
£5,000 (daily cost) x 14 (days closed) = £70,000
Total cost for half of 5,073 schools: (£70,000 x 5,073) / 2 = £177,555,000 over 30 years or £5,918,500 per year.
Care homes:
Estimating the cost of care home closures can be challenging since it depends on the size, location, and specific services provided by each care home.
Assuming an average daily cost of £1,000 per care home, the cost per care home for a two-week closure would be:
£1,000 (daily cost) x 14 (days closed) = £14,000
Total cost for half of 1,069 care homes: (£14,000 x 1,069) / 2 = £7,483,000 over 30 years or £249,400 per year. This does not include the economic impact of school-age parents missing work to provide childcare.
Hospitals:
Estimating the cost of hospital closures is complex, as it involves a wide range of services and expenses. Assuming an average daily cost of £50,000 per hospital, the cost per hospital for a two-week closure would be:
£50,000 (daily cost) x 14 (days closed) = £700,000
Total cost for half of 229 hospitals:( £700,000 x 229) / 2 = £80,150,000 over 30 years or £2,671,000 per year.
Overall estimated cost: Total cost for all sectors: £154,000,000 (shops) + £244,930,000 (food and drink sector) + £177,555,000 (schools) + £7,483,000 (care homes) + £80,150,000 (hospitals) = £663,618,000.
Therefore, the estimated cost of closures for all sectors, considering the given numbers and assumptions, would be approximately £663,618,000 over 30 years which is £22,120,600 per year.
The need for a sensible licensing scheme:
Both UK Hospitality and the British Retail Consortium concur with the British Pest Control Association (BPCA) that an outright ban on glue boards in Scotland would be a costly mistake.
Instead, implementing a sensible licensing scheme would offer a more cost-effective solution for the Scottish Government. Such a scheme could ensure the responsible use, training, and monitoring of glue traps while minimising their potential negative impacts.
Conclusion:
Banning rodent glue traps in Scotland would have dire consequences for businesses, public health, and the economy. Recognising the indispensability of fast-acting tools like glue traps, it is crucial to implement a sensible licensing scheme to ensure their responsible use. By doing so, we can protect.
The Financial Memorandum states:
“55. […] It is anticipated that the costs to individuals and businesses arising from the provisions relating to glue traps are minimal due to the wide availability of alternative methods of rodent control at comparable cost”.
This is incorrect.
Rodent infestations pose a significant risk to businesses in Scotland, particularly those in the food industry. While the Financial Memorandum suggests that the costs associated with the use of glue traps are minimal, this claim is grossly inaccurate. In fact, the proposed ban on glue traps would have catastrophic consequences for businesses and organisations across the country, leading to substantial financial burdens and potential public health risks. It is essential to recognise the unique benefits of glue traps and the need for a sensible licensing scheme instead of an outright ban.
Inherent risks of rodent infestations:
Every business operating in Scotland is susceptible to rodent problems, and this is especially crucial for establishments in the food industry. Older buildings, those near water sources, in close proximity to other buildings, or multi-occupancy premises are more likely to attract rodent infestations.
Despite preventive measures, the risk of an infestation can never be eliminated entirely, as rodents can enter a property through gaps as small as the width of a pencil.
Glue traps act as a physical barrier, effectively catching rats and mice and preventing them from reaching food or water sources.
Swift and effective rodent control:
Glue boards offer a fast-acting solution in critical areas such as food and hospitality businesses, hospitals, care homes, food factories, and vital infrastructure like utilities.
These establishments often cannot operate with even a single rodent present.
Compared to other rodent management programs that typically take two weeks to be effective (traps and poisons), glue board treatments allow premises to reopen within 2-3 days.
The use of alternative methods would result in temporary closures lasting a minimum of two weeks, causing an enormous additional cost burden for businesses.
The alternatives to glue traps are:
Proofing - cannot be used after an infestation has occurred
Denial of food and water - cannot be used after an infestation has occurred
Removal of harbourage - cannot be used after an infestation has occurred
Trapping - rodents are naturally suspicious of new things and often avoid newly set traps for some time
Biocides (poisons) - typically take around two weeks to control an infestation
Clearly when speed is critical, in areas such as hospitals, food premises and around vulnerable people, sometimes glue boards are the only viable option.
Scale of businesses and organisations at Risk:
Scotland is home to a significant number of businesses and organisations that would be severely affected by a ban on glue traps.
Consider the following figures:
22,000 shops (British Retail Consortium figures)
17,495 registered enterprises in the food and drink sector (source: https://www.gov.scot/binaries/content/documents/govscot/publications/statistics/2019/07/growth-sector-statistics/documents/food-and-drink/food-and-drink/govscot%3Adocument/Food%2Band%2BDrink%2B-%2BGrowth%2BSector%2BBriefing.docx)
5,073 schools (source: https://www.gov.scot/publications/summary-statistics-schools-scotland-4-2013-edition/)
1,069 care homes (source: https://publichealthscotland.scot/publications/care-home-census-for-adults-in-scotland/care-home-census-for-adults-in-scotland-statistics-for-2011-to-2021-part-1/ ).
229 hospitals (source: https://www.interweavetextiles.com/how-many-hospitals-uk/)
Imposing a ban on glue boards would jeopardise the operations of these establishments in the event of a rodent infestation, leading to significant disruptions in services and potential health hazards.
Real-life scenarios:
To grasp the impact of a ban on glue traps, we must consider real-life situations that would unfold without this effective tool.
Imagine a child's school forced to close for two weeks because the school canteen has shut down, waiting for poisoned bait to take effect.
Picture a small, family-run takeaway anxiously waiting for two weeks for a single rat in their kitchen to be caught by a newly laid snap trap.
Envision an entire food factory shut down while professionals attempt to capture a single rodent in critical machinery.
These scenarios highlight the adverse consequences of a ban on glue traps, including grounded planes, elderly residents displaced from care homes, and immense economic losses.
Calculations of cost to Scottish organisations
To estimate the cost of closures for each sector, we need to consider the average daily revenue of each establishment and multiply it by the number of days they would be closed. This is a rough estimate, and the actual costs may vary depending on various factors, such as the size of the establishment, location, and specific industry.
Additionally, it's important to note that the estimation assumes 50% of establishments would close once every 30 years.
Shops:
The cost of closure for 22,000 shops can vary significantly based on the type of shop and its average daily revenue. Let's assume an average daily revenue of £1,000 per shop. With a two-week closure, the estimated cost per shop would be:
£1,000 (daily revenue) x 14 (days closed) = £14,000
Total cost for half of 22,000 shops: (£14,000 x 22,000) / 2 = £154,000,000 over 30 years or £5,133,300 a year.
Registered enterprises in the food and drink sector:
Similarly, estimating the cost for 17,495 registered enterprises in the food and drink sector depends on the average daily revenue. Assuming an average daily revenue of £2,000 per enterprise, the cost per enterprise for a two-week closure would be:
£2,000 (daily revenue) x 14 (days closed) = £28,000
Total cost for half of 17,495 registered enterprises: (£28,000 x 17,495) / 2 = £244,930,000 over 30 years or £8,164,000 a year.
Schools:
Estimating the cost of school closures requires considering the average daily cost of operating a school.
This includes expenses like staffing, utilities, maintenance, and other overhead costs. Assuming an average daily cost of £5,000 per school, the cost per school for a two-week closure would be:
£5,000 (daily cost) x 14 (days closed) = £70,000
Total cost for half of 5,073 schools: (£70,000 x 5,073) / 2 = £177,555,000 over 30 years or £5,918,500 per year.
Care homes:
Estimating the cost of care home closures can be challenging since it depends on the size, location, and specific services provided by each care home.
Assuming an average daily cost of £1,000 per care home, the cost per care home for a two-week closure would be:
£1,000 (daily cost) x 14 (days closed) = £14,000
Total cost for half of 1,069 care homes: (£14,000 x 1,069) / 2 = £7,483,000 over 30 years or £249,400 per year. This does not include the economic impact of school-age parents missing work to provide childcare.
Hospitals:
Estimating the cost of hospital closures is complex, as it involves a wide range of services and expenses. Assuming an average daily cost of £50,000 per hospital, the cost per hospital for a two-week closure would be:
£50,000 (daily cost) x 14 (days closed) = £700,000
Total cost for half of 229 hospitals:( £700,000 x 229) / 2 = £80,150,000 over 30 years or £2,671,000 per year.
Overall estimated cost: Total cost for all sectors: £154,000,000 (shops) + £244,930,000 (food and drink sector) + £177,555,000 (schools) + £7,483,000 (care homes) + £80,150,000 (hospitals) = £663,618,000.
Therefore, the estimated cost of closures for all sectors, considering the given numbers and assumptions, would be approximately £663,618,000 over 30 years which is £22,120,600 per year.
The need for a sensible licensing scheme:
Both UK Hospitality and the British Retail Consortium concur with the British Pest Control Association (BPCA) that an outright ban on glue boards in Scotland would be a costly mistake.
Instead, implementing a sensible licensing scheme would offer a more cost-effective solution for the Scottish Government. Such a scheme could ensure the responsible use, training, and monitoring of glue traps while minimising their potential negative impacts.
Conclusion:
Banning rodent glue traps in Scotland would have dire consequences for businesses, public health, and the economy. Recognising the indispensability of fast-acting tools like glue traps, it is crucial to implement a sensible licensing scheme to ensure their responsible use. By doing so, we can protect.
Question page 2
5. Do you consider that the estimated costs and savings set out in the FM are reasonable and accurate?
Please provide your response in the box provided.
NA
6. If applicable, are you content that your organisation can meet any financial costs that it might incur as a result of the Bill? If not, how do you think these costs should be met?
Please provide your response in the box provided.
NA
7. Does the FM accurately reflect the margins of uncertainty associated with the Bill’s estimated costs and with the timescales over which they would be expected to arise?
Please provide your response in the box provided.
NA