Health Canada’s Pest Management Regulatory Agency (PMRA) is currently offering a public consultation to determine how the humaneness of pesticides used to kill predators (predacides) could be considered during their approval and use.
Wildlife Defence League (WDL) has made a submission and we’re encouraging our supporters to also participate in the consultation before the April 18th deadline. Please see the consultation questions below, as well as our feedback.
Should PMRA include humaneness considerations as part of the pesticide registration process for products intended to control large vertebrate predators? If so, what would be the best options and approaches for doing so?
Should PMRA develop public information, such as best practices / standards on humaneness considerations, that pesticide users could take into account when deciding whether to use a pesticide for controlling large vertebrate predators? If so, what kind of information would be most useful?
In either case, what should be the parameters to measure humaneness?
Visit the consultation page for more background information. Feedback can be submitted via email to firstname.lastname@example.org. Please be sure to personalize your response and do not just copy and paste.
It is the position of the Wildlife Defence League that humaneness must be a central part of all wildlife management strategies. The Canadian Veterinary Medical Association’s pest control position statement states that “the welfare implications, safety, and ecological impact of the chosen strategy should always be considered”. 1
Predacides such as sodium fluoroacetate (Compound 1080), sodium cyanide and strychnine are inhumane, as they result in severe and often prolonged suffering. Animals that ingest these poisons can experience seizures, cessation of breathing, hyperthermia, extreme suffering and death from exhaustion or asphyxiation. Death may occur within 1-2 hours but, depending on the dose ingested, it can take up to 24 hours or longer for the animal to die. 2,3
These predacides fail to meet the Canadian Council on Animal Care guidelines, which defines a killing method as humane if it causes rapid (immediate) unconsciousness and subsequent death without pain or distress. 4 They also fail to meet the Canadian Veterinary Medical Association guidelines for humane pest control. 5
Predacides are indiscriminate killers. The baited poisons used to attract the target species inevitably attract other animals (including pets), who suffer the same cruel fate. Secondary poisoning of animals that scavenge on the toxic carcasses is an additional concern. 6 The widespread impact of these poisons is likely not fully understood either, as they may not always be directly lethal to non-target animals, but may seriously compromise reproduction, immune function, overall fitness, and longevity. 7
Ultimately, these predacides cannot be used humanely, due to the very nature of the products themselves, as well as the risks they pose to biodiversity, entire ecosystems, and public safety. Existing animal welfare guidelines, as outlined in this submission, offer a baseline for humaneness considerations. As wildlife face increased human pressure, it’s crucial that root causes of conflict be addressed, rather than reliance on lethal strategies that often fail to address these root causes. WDL is calling on the Minister of Health and the Pest Management Regulatory Agency (PMRA) to include humaneness considerations in the pesticide registration process and to prohibit these predacides under the Pest Control Products Act.
Khan, S.A. (2010) Overview of strychnine poisoning. In: The Merck Veterinary Manual, Tenth Edition, ed. C.M. Kahn & S. Line, pp. 2744–2746. Whitehouse Station, NJ, USA: Merck & Co
Eason, C.T. & Wickstrom, M. (2001) Vertebrate Pesticide Toxicology Manual (Poisons). Department of Conservation Technical Series No. 23. Wellington, New Zealand: Department of Conservation