Health Canada consultation to include public comments
OTTAWA, Canada––Health Canada has extended until April 18, 2019 the public consultation period on a review of the “humaneness,” when used to kill wolves, coyotes, and bears, of the poisons strychnine, sodium cyanide, and sodium fluoroacetate, better known as Compound 1080.
The Canadian consultation on what it terms “Humane Vertebrate Pest Control,” while officially limited in scope to Canada, also amounts to a de facto third party review of the “humaneness” of the poison-based predator control practices of the U.S., Australia, and New Zealand.
“Growing concern among Canadians”
“The use of pesticides to control large predators and the unintended effects on non-target animals is a growing concern among Canadians,” opened the Health Canada Pest Management Regulatory Agency, both in announcing the consultation and in extending it on February 15, 2019.
Health Canada, accordingly, is asking Canadians “how the humaneness of pesticides to control predators could be considered during their approval and use.”
(Instructions for submitting comments are online at https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/consultations/humane-vertebrate-pest-control/document.html?fbclid=IwAR1bYIo6SzuMO5mIF-Nv37ug1CJ6sizA3LbeyOYxN-n1CHMc1qPLMFckdaY)
Invites comparison with U.S., Australia, EU
The consultation document specifically invites comparison of Canadian practices with those of the U.S., Australia, and European Union nations, but does not mention New Zealand.
The term “Humane Vertebrate Pest Control” is taken from the Australian Royal Society for the Prevention of Cruelty to Animals, the Health Canada consultation document explains.
Health Canada has also borrowed the Australian RSPCA definition of “Humane Vertebrate Pest Control” as referring to “the development and selection of feasible control programs and techniques that avoid or minimize pain, suffering and distress to target and non-target animals.”
The Health Canada Pest Management Regulatory Agency has regulatory authority over which pesticides may be sold and used in Canada.
The consultation document recognizes, however, that “Protecting animal welfare in Canada is a shared responsibility between federal, provincial and territorial jurisdictions.”
Health Canada has only an advisory role in enforcing the federal Health of Animals Act and Canada Wildlife Act. In addition, the consultation document explains, “Canadian provinces and territories have their own laws to protect animals.”
U.S. regs do not “consider animal welfare or humaneness”
The U.S. Federal Insecticide, Fungicide, and Rodenticide Act “does not consider animal welfare or humaneness as part of the assessment process for the registration of pest control products,” the Health Canada consultation document notes.
“Under the Australian Constitution, pest management is the responsibility of the state and territory governments,” the Health Canada consultation explains.
“The Commonwealth Government of Australia has developed the Australian Pest Animal Strategy, which sets out principles, goals and priorities to guide pest animal management, including animal welfare considerations,” the Health Canada consultation document continues, but “Humaneness is not considered as a factor in pest control product registration decisions.”
“Biocides might raise animal welfare concerns”
The European Union Biocides Regulation No. 528/2012 “acknowledges that certain biocidal products might give rise to animal welfare concerns,” the Health Canada consultation document adds. “Because of this, Member States are allowed to restrict the use of EU-approved products that may pose animal welfare concerns within their own jurisdictions,” but there are no European Union bans in effect in all EU nations against pesticides considered to be especially inhumane.
Strychnine, sodium cyanide, and sodium fluoroacetate, or Compound 1080, are the only pesticides currently in authorized use in Canada to kill wolves, coyotes, and bears.
All three poisons have relatively recently been reviewed for criteria other than humanness, including environmental risks and threats to non-target species: sodium cyanide in 2006, strychnine in 2007, sodium fluoroacetate in 2014. As a part of each review, labeling requirements were strengthened to “minimize risks to non-target species,” the Health Canada consultation document states.
“Swift fox extremely vulnerable”
In the case of sodium cyanide, “The swift fox (a non-target animal) is an endangered species that is extremely vulnerable to this pesticide and is specifically mentioned on the label to ensure the product is not used in its habitat areas,” notes the Health Canada consultation document.
Asks Health Canada, “Should the Pest Management Regulatory Agency 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 the Pest Management Regulatory Agency 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?”
Alberta poisons wolves
Commented Canadian Press writer Bob Weber, on February 20, 2019, “The most common of the three toxins under consideration is strychnine. One of Canada’s largest users is the government of Alberta, which has used strychnine to poison hundreds of wolves to help caribou herds survive in ranges heavily disrupted by industrial development.
“Alberta government biologists say the wolf cull, which also uses aerial gunning, has preserved caribou on a landscape heavily affected by energy development and forestry.”
However, acknowledging the effects of global warming continues to be politically difficult in Alberta, whose economy is from 25% to 50% dependent on fossil fuel extraction, depending on whose numbers one cites.
“One of the worst ways to die”
“Strychnine is one of the worst ways to die, in terms of pain and in terms of being conscious and aware,” University of Saskatchewan agriculture professor Ryan Brook told Weber.
“We have to do better,” Brook emphasized. “If you tried, I don’t think you could find a worse way to do it.”
Summarized Weber, “Within 20 minutes of being dosed by strychnine, muscles start to convulse. The convulsions increase in intensity and frequency until the backbone arches and the animal asphyxiates or dies of exhaustion.”
Fifty scientists and animal-welfare advocates from across Canada and three countries in fall 2018 co-signed a letter from the advocacy group Wolf Awareness to Health Canada declaring strychnine, sodium cyanide, and Compound 1080 all inhumane.
Wolf Awareness also released documents, Weber wrote, “showing that — along with 1,200 wolves killed by various means in Alberta since 2005 — at least 257 other animals have been poisoned, including 44 foxes and a grizzly bear.
“Many scientists doubt poisoning actually reduces wolves,” Weber noted.
“You kill a dominant wolf, the pack splits, sometimes up to three or four times,” renowned wildlife biologist Gilbert Proulx told Weber. “Then you’re faced with four litters the following year instead of one.”
Australia & New Zealand expand use of poisons
While Health Canada is at least considering the possibility that using strychnine, sodium cyanide, and Compound 1080 to kill predators might be inhumane, Australia and New Zealand are going full speed ahead in expanding use of all three pesticides to kill non-native species.
“A feral cat eradication trial that will use grooming traps that administer a toxic gel [made from Compound 1080] has begun on the Dudley Peninsula on Kangaroo Island,” reported Stock Journal on February 20, 2019.
The trial is part of an Australian federal scheme to kill two million feral cats by 2030, which the Australian government believes will eradicate feral cats nationwide, despite research indicating that the effort is likely to backfire.
Explained Stock Journal, “The Felixer grooming traps, which have been used extensively in northern South Australia and the Northern Territory, work by identifying cats from their size, shape and gait as they cross in front of the machines.
“When the traps identify a cat, the machine administers a single dose of the toxic gel (Compound 1080) to the animal’s coat, which is ingested when the cat grooms itself.”
The Stock Journal article appeared one day after five Australian scientists co-published in the peer-reviewed online periodical Conservation Letters a critique of the government scheme entitled “Conservation or politics? Australia’s target to kill 2 million cats.”
“Weak scientific basis”
Wrote co-authors Tim S. Doherty, Don A. Driscoll, Dale G. Nimmo, Euan G. Ritchie, and Ricky‐John Spencer, “The well‐publicized target to cull two million feral cats has a weak scientific basis because: (1) reliable estimates of Australia’s cat population size did not exist when the target was set; (2) it is extremely difficult to measure progress (numbers of cats killed) in an accurate, reliable way; and, most importantly, (3) the cull target is not explicitly linked to direct conservation outcomes (e.g., measured increases in threatened species populations).
“These limitations mean,” the five scientists explained, “that the cull target fails to meet what would be considered best practice for pest management. The focus on killing cats runs the risk of distracting attention away from other threats to biodiversity, most prominent of which is widespread, ongoing habitat loss.”
“Cats are now an integral part of Australia’s eco systems”
Further, the five scientists said, “The culling target is a highly visible symbol of a broader campaign around feral cat research and management in Australia, rather than a direct indicator of conservation action and success. We are concerned that progress toward the two million target could be misinterpreted as progress toward conserving threatened species, when the link between the two is not clear.”
Observed Arian D. Wallach, founder of the Centre for Compassionate Conservation at the University of Technology in Sydney, Australia, “Whether we like it or not, cats are now an integral part of Australia’s eco systems. We cannot get rid of them. We may as well learn to love them.”
“Australia made poisoning normal”
One day before the five scientists published their statement in Conservation Letters, University of New England Ph.D. in ecosystem management Justine M. Philip examined “How Australia made poisoning animals normal” in the online science periodical The Conversation.
Philip traced Australian reliance on poisoning for “wildlife management” to the scarcity of trustworthy shepherds in the days of convict settlement, in the early 19th century. “Among the convict labor available,” Philip wrote, “for every two experienced farm laborers, there were five convicted sheep, horse, cattle or poultry thieves.”
Poisoning dingos grew with sheep ranching
Documented efforts to poison dingos, the Australian native wild dogs, began in 1814. Arsenic was the preferred poison at first, but was soon superseded by the use of strychnine, developed in 1818 by the French scientist Pierre Joseph Pelletier (1788-1842), who earlier discovered the use of quinine to combat malaria symptoms.
Between 1822 and 1892 the Australian sheep population exploded from 120,000 to 106 million, Philip wrote. Efforts to kill dingoes grew apace, evolving into a government war on dingoes––and rabbits––in 1897.
“Mistaking poison for the cure”
“Natural biodiversity never recovered,” assessed Philip. “The legacy of Australia’s chemical-dependent farming over the past 200 years remains largely unacknowledged in conversations about the current biodiversity crisis. Australia has around 500 threatened animal species, and our rate of mammalian extinctions is unparalleled anywhere in the world. The main drivers of the crisis are attributed to introduced species, changed fire regimes, and land clearing,” yet “the removal of the dingo, the top order predator, led to the explosion of herbivore populations, more poisons, the establishment of introduced species, and destabilizing of the native ecosystem.
“Applying more vertebrate pesticides to the environment to try and solve the problem,” Philip said, “is arguably an extreme case of mistaking the poison for the cure.”
New Zealand SPCA calls for Compound 1080 ban
About 2,600 miles to the southeast, the New Zealand SPCA on January 5, 2019 called for “a ban on the use of poisons such as Compound 1080, because these substances cause such intense and prolonged suffering to animals that we believe their use can never be justified.”
Recommended the New Zealand SPCA, “There should be greater emphasis on looking for solutions that would enable species who cannot be completely removed to co-exist in the environment instead.
“SPCA also encourages the research and development of humane alternatives to species control,” the statement said, “including the replacement of lethal methods with humane non-lethal methods, such as limiting reproductive abilities.
“Welfare of all animals should be viewed equally”
“The welfare of all animals should be viewed equally, and people should recognize that they deserve protection from suffering pain or distress, regardless of the species or where they came from.
“Whether an animal is native or introduced,” the New Zealand SPCA finished, “any measures taken to manage their impact or numbers must recognize that these animals are sentient and have the capacity to experience pain, suffering, or distress, regardless of whether they are viewed or classed as a pest.”
“Cruelly eaten alive”
That predictably detonated New Zealand Forest & Bird chief executive Kevin Hague, a leading proponent of exterminating feral species by any means possible.
“While the idea of stoats and rats peacefully coexisting with native birds sounds great, the reality is that an estimated 25 million native birds, eggs and chicks are cruelly eaten alive by introduced predators every year in New Zealand,” Hague responded, not mentioning that the leading predators of New Zealand native birds, eggs, and chicks also include several million native gulls, terns, and skuas.
“The SPCA’s position on Compound 1080 is a blow to their credibility,” Hague charged. “It’s sad to see them promoting flawed logic whose outcome is the extinction through being eaten alive of treasured animals like our kiwi, kererū, and kōkako.”
Hague wholly disregarded what the New Zealand SPCA had said about developing “humane alternatives to species control.”
This could include the use of PZP-based contraceptives that are proven effective in some of the species the New Zealand government is most hellbent on killing; are quickly produced to order by the Science & Conservation Center at ZooMontana in Billings, Montana; and after decades of use, worldwide, are an off-the-shelf established technology.
Defending the use of Compound 1080, New Zealand conservation minister Eugenie Sage alleged in the national Parliament that “The best alternative at the moment is trapping, which is already used extensively.
“The Government is supporting a range of research into different compounds,” Sage continued, “including things like PAPP,” or para-aminopropiophenone, “which is very effective for stoats; things like sodium nitrite; microencapsulated zinc phosphate paste; and also into traps like self-resetting traps.”
Of the pesticide alternatives, only para-aminopropiophenone appears to have been reviewed by any agency for “humaneness.”
“Baits containing PAPP appear to be more humane than Compound 1080,” found the Royal SPCA of Australia in 2016, “as the toxin acts faster and appears to be less aversive, but PAPP still has the potential to cause some suffering.”
“Culture of selective killing”
Charged Bob Kerridge, 80, who for 32 years headed the Auckland SPCA, in a January 30, 2019 guest column for the New Zealand Herald, “Conservation in New Zealand has generated a culture of selective killing. If it is an introduced species to which we have taken a dislike, an animal we humans have declared to be a ‘pest,’ or a species who for its own survival preys on other animals, our only solution seems to be to destroy it and call it ‘humane’ conservation.
“When we consider the weapons used to undertake this dubious and destructive activity we have a moral reason for concern,” Kerridge said. “Trapping and shooting carry their own degree of animal pain and suffering, but heading the list of mass destruction has to be the use of toxins and poisons such as brodifacoum, PAPP and Compound 1080 for the sheer unadulterated cruelty they inflict, with animals taking hours and even days to die in agony.
“Dangers of their obsessions”
“The use of Compound 1080 has been correctly criticized by the New Zealand SPCA for the untargeted and indiscriminate destruction it leaves in its wake on so many life forms,” Kerridge judged.
“Perhaps it is time,” Kerridge concluded, “for those who are advocating this war-like behavior, including the New Zealand Department of Conservation, Predator Free-2050 and Forest & Bird, to name a few, to consider the potential dangers of their obsessions.”