Consultation Summary - Humane Vertebrate Pest Control
Pest Management Regulatory Agency
29 January 2021
Table of Contents
- About predacides
- Public consultation: Humane vertebrate pest control
- Overview of comments received
- Comments from the general public and letter-writing campaigns
- Comments from non-governmental organizations
- Provincial/territorial and municipal governments
- Other considerations
- Next steps
- About Health Canada’s Pest Management Regulatory Agency
There are three registered pesticidal active ingredients in Canada that may be used to control large predators (wolves, coyotes and bears):
- sodium monofluoroacetate (Compound 1080)
- sodium cyanide
The use of these products, known as predacides, is highly restricted in Canada. They can only be used by authorized personnel in Alberta and Saskatchewan, in cases where there are no other practical alternative control measures, to protect:
- livestock herds
- vulnerable wildlife species
- the health and safety of inhabitants in remote areas
Public consultation: Humane vertebrate pest control
In recent years, many Canadians have expressed concern to Health Canada about the humaneness of these pesticides. In the interest of seeking Canadians’ views and input, Health Canada published a consultation document Humane Vertebrate Pest Control on 20 December 2018 for a 120-day consultation period ending 18 April 2019.
Canadians were asked the following questions:
- 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?
Over the course of the consultation, 4012 responses were received:
- 3685 responses from the Canadian public were form letters that were part of letter writing campaigns attributed to several organizations
- 306 responses were from individual Canadians
- 15 responses were from non-governmental organizations (NGOs)
- 5 responses were from provincial and municipal governments
- 1 response was from academia
Following the close of the consultation period, correspondence regarding humaneness of vertebrate pest control continued to be submitted to Health Canada through various letter-writing campaigns. Although these are not included in the comment count, the information provided in these letters is consistent with those received during the comment period, and therefore is included in this document.
The review and consideration of more than 4000 responses was completed in early 2020. A published consultation summary and response was planned for autumn 2020; however, logistical, resource and priority issues related to the COVID-19 pandemic resulted in delays.
Overview of comments received
In general, Canadian public respondents are concerned about the humaneness of the three predacides currently registered for use in Canada. Many of these same respondents feel the predacides should be banned in favour of alternative predator control measures, and that Health Canada should consider humaneness in the risk assessment process for pesticides.
Many of the comments received revealed a lack of awareness of the high degree of restriction associated with using these products.
NGOs were divided in opinion. Industry NGOs (for example, livestock associations) commented that current conditions of use are already very restrictive, to be used only when existing alternatives have failed, and that a ban could result in unacceptable and inhumane loss of livestock. Environmental and veterinary groups called for the establishment and use of humaneness parameters in the assessment of pesticides.
Provincial governments noted that humaneness standards are provincial/territorial jurisdiction, and provinces/territories that rely on predacides also emphasized that the use of these products is already highly restricted.
Respondents from all groups supported developing information for the public and predacide users, including humaneness considerations for users (for example, on the effect of predacides on animals, and alternative approaches) and clarity about the high degree of restrictions placed on their use.
Comments from the general public and letter-writing campaigns
Respondents from among the general public, and those who submitted letters through non-governmental organization letter-writing campaigns, largely called for a ban on the use of the three predacides. Some recommended only registering products that can be proven to be used humanely. While label conditions specify that reasonable alternative approaches must be exhausted prior to using predacides, Canadians suggested a variety of non-lethal predator control strategies such as:
- managing populations with birth control
- altering human behaviour to prevent conflict
- wildlife relocation
- improving education and public awareness of the effects of predacides and successful non-lethal measures
- use of guardian dogs or donkeys
- physical deterrents such as fencing, fladry (strips of fabric on a rope that flap in the breeze), penning, and increased human presence
While some noted that the consultation process was not sufficient to develop standards and parameters for humaneness, others offered suggestions for factors that should be considered when evaluating whether a predacide is humane:
- minimal time to loss of consciousness and death
- minimal undesirable psychological and physiological effects on the target animal
- target animals should not suffer
In addition, many Canadians stated that non-target animals should not be affected.
Comments from non-governmental organizations
Non-governmental organizations were divided in terms of whether the current federal approach to the regulation of predacides is appropriate.
Animal Welfare and Environmental NGOs
Non-governmental organizations concerned with the environment and animal welfare advocated for legislative changes that would afford higher protection to wildlife from the effects of predacides, and from lethal forms of control. Some organizations reported that the registered predacides do not meet their own animal care guidelines, specifically, that humane death should cause rapid unconsciousness and subsequent death without causing pain and distress/suffering.
Some organizations recognized the need for predator control measures to reduce damage or conflict between animals, promote sustainable agricultural production, control diseases such as rabies, and to ensure the conservation of biodiversity; however, it was reported that these measures should be humane, scientifically based, have minimal environmental or human health impacts, and abide by local legislative and municipal requirements.
These organizations made many of the same recommendations as the general public as described above. Further recommendations included:
- developing an effective mechanism to ensure compliance with label requirements
- evaluating and taking into account the effectiveness of lethal wildlife removal in the various use scenarios
- developing and distributing information on alternative approaches to using predacides
Livestock Producer NGOs
Non-governmental organizations representing livestock producers expressed that humaneness considerations should remain the jurisdiction of animal welfare experts at the federal (for example, Canadian Food Inspection Agency) and provincial/territorial levels (and not become part of the PMRA registration process). They also reiterated that the use of registered predacides is highly restricted, and that all other options must already be exhausted prior to being permitted to use them.
Concerns expressed about any humaneness-based decision to cancel these products included:
- significant herd and financial losses to livestock producers
- increased pain and suffering of livestock animals subject to attack
- the lack of last-resort alternatives
- producers resorting to home remedies that may result in worse outcomes
Both groups of NGOs provided PMRA with incident information on the deaths of animals that were exposed to predacides. This information will be considered during the accelerated 2021 re-evaluation of predacides as a cluster, as found in REV2020-01, PMRA Re-evaluation and Special Review Work Plan 2020-2025 (see “Next Steps” at the end of this document).
Provincial/territorial and municipal governments
The provincial/territorial, regional and municipal government organizations that provided comments on the consultation supported the continued use of predacides, noting that provincial/territorial government departments are responsible for resource and wildlife management, animal welfare, and pesticide use permits for these restricted products.
As with the other groups, the input from provincial/territorial and municipal governments included recommendations related to education and public messaging including:
- educating users on the effects of the registered predacides, in a humaneness context
- educating the public on the restrictions and controlled use of these products
- providing information about the financial and herd-related losses due to predation
The issue of the deaths of non-target animals through the use of predacides was raised by respondents from all groups. This information falls within Health Canada’s existing responsibilities with respect to pesticides and environmental protection. Therefore, it will be taken into consideration during the upcoming re-evaluation of these predacides, and in the planning of compliance and enforcement activities.
At this time, Health Canada will not be taking steps towards incorporating humaneness considerations into the pesticide risk assessment framework. There are currently no internationally recognized science-based parameters to evaluate the humaneness of pesticides, and no new information on this topic was brought forward through the consultation process. Moreover, it is important to note that provincial/territorial governments are responsible for and have measures in place to address both wildlife management and animal welfare.
To address concerns raised by Canadians through this consultation, Health Canada will develop information materials to:
- improve awareness of federal and provincial/territorial roles and responsibilities with respect to wildlife management and animal welfare
- improve awareness of predacide use restrictions and scenarios
- improve awareness of the risks associated with predacide use
In 2021, Health Canada will initiate a re-evaluation of strychnine, Compound 1080 (sodium monofluoroacetate), and sodium cyanide as a cluster, based on the similarity of the use pattern and toxicity profile. Information submitted during the humaneness consultation period relevant to the re-evaluation will be included for consideration at that time.
This re-evaluation will take into consideration information related to non-target animal incident reports.
Health Canada would like to thank all respondents for taking the time to share their thoughts on this important issue, as the department works to continually improve health and environmental protection for Canadians.
About Health Canada’s Pest Management Regulatory Agency
The Pest Management Regulatory Agency (PMRA) is the branch of Health Canada responsible for regulating pesticides under the authority of the Pest Control Products Act. PMRA's primary mandate is to prevent unacceptable risks to Canadians and the environment from the use of these products.
PMRA applies current, evidence-based scientific approaches to assess whether the health and environmental risks of pesticides proposed for registration are acceptable, and if the products have value.
This same approach is used to regularly and systematically review whether pesticides already on the Canadian market continue to meet modern scientific standards.
Health Canada's Regulatory Operations and Enforcement Branch (ROEB), in collaboration with PMRA, promotes, monitors and enforces compliance with the Pest Control Products Act across Canada. Health Canada is committed to doing this in an open and transparent manner.
This work is carried out by a highly skilled workforce, the majority of whom are scientists, with additional expertise in areas such as regulatory and policy development, stakeholder engagement, international collaboration, and information management.
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