Official Report: Minutes of Evidence

The Chairperson (Ms D Armstrong): Good morning. I welcome Rosina Robson, chief executive of the British Pest Control Association, to the meeting. We have received your briefing paper and members will have read that, Rosina. We have heard a lot about pest control this morning, and you have been in the room to hear the evidence, so I invite you to brief the Committee. Thank you.

Ms Rosina Robson (British Pest Control Association): Thank you very much for the invitation today. We appreciate it, and I am pleased to be here to represent the professional pest management sector. It is very toasty in here, is it not?

To begin with and for a bit of context before I outline our issues with the Bill as it stands, as you said, Chair, we are the British Pest Control Association, and we are the UK's trade association for professional pest management. We were set up in the 1940s, during the Second World War, specifically to protect the food supply chain and public health. That still goes to the heart of the services that our members provide today. We have over 750 members, who primarily service companies UK-wide. We have 20 members in Northern Ireland, and they are out supporting businesses, schools, hospitals, care homes, farms and food production, so, although we are a small sector by number of businesses, we have quite a broad reach.

As an organisation, we are serious about professionalism, excellence and driving improvement. We are a member-led association and have a vigorous application and assessment process that members go through. We can talk a little bit more about that if you are interested. I have travelled across the UK and met various members, and I have been struck by the passion that they have for the job that they do and the role that they carry out, and by the fact that they really care about animal welfare and the environment.

Integrated pest management is a well-established approach within the sector. That means that businesses think about prevention first before they get anywhere near aspects of control. They think about proofing and preventing animals from getting into certain spaces or removing food and water etc, so that is a well-established principle and practice in the sector.

Specifically, as far as the Bill is concerned, we are broadly supportive of what you are trying to do. Obviously, legislation exists in England, Wales and Scotland, so we appreciate your efforts to introduce legislation here in Northern Ireland, and we appreciate the intention around animal welfare. As we have outlined in our written briefing, we have three particular issues. I will not go into too much detail, as you have that in the paper. We are keen to work constructively with you if you are looking at tabling amendments, for example, but we do not want unintended consequences that impact on the valuable work that our members are doing to protect public health and the food supply chain.

First, on the offence of trail hunting applying to naturally laid scents, our reading of that is that it would make it unlawful to use working dogs as a tool for surveying sites: that is, the detection element of pest activity. We have a small number of businesses that are specialists, but there are more businesses, both in Northern Ireland and further afield, that use dogs in some way. Dogs are particularly useful for large areas and large buildings. They can detect where rats and mice enter and exit a building and where they move around, which informs pest controllers on where they can think about traps and other control methods, essentially. So, we would not want to lose that option.

The wider context is that, over time, there has been a slow erosion of the toolkit — that array of physical tools, such as traps or chemical tools, that are used in a variety of circumstances and scenarios to do particular jobs — that pest controllers have at their disposal. We would not want this to be another way of removing tools at their disposal. We think that you could use, if you wanted to, the same definition as that in the Hunting with Dogs (Scotland) Act 2023. We can talk a bit more about the detail of the trail hunting aspect.

The other area that we outlined in the briefing is the offence of terrier work, which we see as problematic for two reasons. We think that the offence of terrier work is duplicating that of hunting, in that you have already prohibited the use of dogs below ground through the hunting offence. We wonder whether it is a bit unnecessary and is actually adding complexity and confusion when it comes to businesses trying to comply with the law. We also thought that "enclosed space", was not clearly defined. We wondered whether, if you interpret "enclosed space" to be a warehouse or similar, it might make it illegal to flush out rats and mice from buildings. Those are our issues with the terrier offence.

There is a third thing that we would like to see. In the exempt hunting provision, you have rats and mice, but rabbits are not included. We would really like to see rabbits included as exempt hunting alongside rats and mice, as is the case in England and Wales. We can talk a little bit more about that. We are at a time when food security is of increasing concern. That has already been talked about this morning. There are cost-of-living challenges, and it is well documented that rabbits are voracious eaters and cause damage to crops etc. We do not want a reduction in supply or an increase in costs. Nobody wants that when it comes to food supply. Rabbits can carry disease, and members also report that rabbits cause all sorts of damage to infrastructure and flood defences, create holes in airstrips and even damage infrastructure such as solar farms. We can talk a little bit more about that as well. Essentially, we want to make sure that, through the Bill, there is no erosion of the skills and tools that pest controllers have to do their job.

Finally, we see value in having an element of continuity across the UK. Yes, we have those 20 members in Northern Ireland, but we have a wider body of membership that works across the different nations and areas of the UK. Therefore, an element of continuity would be good: it creates confidence and boosts compliance. Thank you very much for inviting me to be here.

The Chairperson (Ms D Armstrong): Thank you very much, Rosina, for that opening statement. You mentioned the definition of "enclosed space". We looked at that, particularly in regard to pest control in hospital settings and more industrial settings. How should the Bill define "enclosed space" to avoid unintended consequences while still meeting its animal welfare objectives? You talked about detection dogs locating rats, for example, in enclosed spaces, and then pest control moves in.

Ms Robson: We are open to working with you to look at specific wording. I understand that "enclosed space" really means holes and very small spaces, so we are very happy to suggest a particular wording, if that is useful, because we want to avoid it being more difficult to do surveys of sites in warehouses, food production centres and hospitals, where there is a lot of ground to cover. However, they were not really intended to be part of the Bill as drafted.

The Chairperson (Ms D Armstrong): That is all from me. Thank you.

Mr McAleer: In your operations, do you ever use artificially laid scents for training purposes?

Ms Robson: I am not aware that we do, no. Our concern at the moment relates to the fact that dogs are specifically trained to follow around a building a scent that will have been naturally laid by the rats or mice etc. I would have to look in more detail at exactly how the dogs are trained, but I know that they can be specialists in detecting rats and mice, and other dogs are specially trained in the detection of bedbugs in hotels, for example, which is an issue separate from the Bill. It is about maintaining the ability to do that detection work, because, in Northern Ireland and other parts of the UK, a lot of our members are small and medium-sized businesses, and a lot of those are microbusinesses and sole traders, so the value of having the dog is in saving time. You can cover a lot of ground quickly and efficiently, which you could not do if you were laying lots of traps and needing to check them daily. As was mentioned earlier, we do not want to encourage increased use of rodenticides and chemicals where that is not necessary. In essence, it is about keeping detection ability.

Mr Blair: Thank you, Rosina, for your presentation and your constructive — I will call it that on this occasion — criticism. My question is just to get your thoughts on this, because we are still going through scrutiny processes and further conversations can be had. The Chair mentioned hospitals, workplaces, warehouses and other such establishments. The Bill provides exemptions for the protection of livestock and foodstuffs, which would apply in many workplaces, and the preservation of human health, which would apply in hospitals and other workplaces.

Ms Robson: OK.

Mr Blair: Does the inclusion of those exemptions not suggest that the provision is already there?

Ms Robson: That is part of the picture, but it leaves a little confusion and doubt —

Mr Blair: I tried to make provision for it, but OK.

Ms Robson: — about the spaces that do not fit exactly within those parameters.

Mr Blair: I will give you my thoughts. The exemptions reflect the legal advice that I was given that, for example, defining "enclosed space" means automatically excluding a plethora of enclosed spaces. Specifying a building, a room, a cave or undergrowth would be a minefield, because the law would then not apply to the many other areas, buildings and structures that were not clearly defined on a specified list. We have to be mindful of the legal advice along those lines.

Ms Robson: Did you say that such spaces would be automatically excluded?

Mr Blair: If you produce a defined list of establishments, spaces or whatever, everything that you do not put on that list will be excluded.

The Chairperson (Ms D Armstrong): Rosina, if you have a suggested amendment to deal with enclosed spaces, you are welcome to submit that to the Committee.

Ms Robson: Good. Thank you.

Mr Wilson: As you will be aware — I have seen this from planes landing in Great Britain and here — rabbits love the internal strips of grass at airport runways, and quite a few of them reside there. You mentioned in your paper that there is no exemption for rabbits. How are rabbits controlled by members of your organisation, and would the Bill in its current form create issues for the control of rabbits in the type of scenario that I described?

Ms Robson: We have talked about the use of dogs for detection, but they are also used as a pest control method. The Terrier Association suggested that the dogs are very well trained and targeted in certain circumstances. They can kill very effectively and handle larger pest populations. As I mentioned, it is about retaining elements of the toolkit, because firearms are not always appropriate.

From a trapping point of view, small businesses have to be able to run a viable business. To do so, they charge the client a reasonable fee for the work that is done. If, however, they have to ask members of staff to be at the site more often because they are dealing with multiple traps etc, commercial viability becomes more problematic and more difficult.

Absolutely, the dog element of pest control is about public health. We want aeroplanes to land properly, do we not? We do not want issues there.

The Chairperson (Ms D Armstrong): Thank you very much. That is a new element. We had not considered airports and their surrounding areas. Rosina, thank you very much for coming in this morning. It has been very helpful to hear your evidence. We appreciate that.