Ask Health Canada to ban carnivore poison/predacides

https://pest-control.canada.ca/public-engagement-portal/en/forms/consultation-comment

Please ban both predacides and rodenticides (they both kill all sorts of animals, even when locked in boxes, and they kill slowly). Killing animals only leaves room for more to move in.  And earlier this year, a child got sick and several companion animals died from predacides, along with death to non target animals.

While banned in some provinces, there are places in Canada in which predacides (Sodium MonoFluoroacetate, Strychnine, etc) are legal. These poisons kill all sorts of animals, are cruel, and do not solve the original reason for conflict. Please follow Ontario's and Quebec's lead, and ban predacides across Canada. 

https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/consultations/proposed-re-evaluation-decisions/2022/predacide-uses-strychnine-sodium-monofluoroacetate.html

Killing wolves and bears does not protect woodland caribou.  Woodland caribou are endangered due to habitat loss and climate change.  Banning logging and development in sensitive areas is a better investment.

Predacides do nothing to prevent or control rabies.  The Province of Ontario successfully controls rabies through oral vaccines.  No lethal management is used by Ontario to control rabies.  Tests are done on animals found deceased from natural causes or car accidents.

If resources are to be used surrounding educational materials, the most useful information to be provide is in regards to preventing conflict situations which lead people to seek lethal options (such as poisons).

These poisons are often used where conflicts among livestock and carnivores occur. However, only a small percentage of livestock deaths are caused by wild predators. Ample scientific evidence shows that lethal reduction of wolf and coyote populations (whether through poisoning, traps or shooting) can result in higher wolf and coyote numbers and greater livestock depredation. Alternative techniques exist that are both humane and effective at reducing livestock depredation and this information required greater dissemination.

There are numerous veterinary and medical experts, associations, and societies that have already established that these toxicants are not humane, as reflected in guidelines, standards, policies, testimonials, recommendations. We ask that PMRA adhere to the recommendations of these experts and do not condone the use of inhumane practices.

Animals poisoned with predacides die traumatically following painful convulsions. It is widely acknowledged that these highly toxic poisons cause animals extreme and often prolonged suffering. Symptoms can include but are not limited to severe and prolonged convulsions, vomiting, unusual vocalizations, excessive salivation, muscular weakness and respiratory distress. Poisoned animals can become injured or suffer tissue trauma if they come in contact with rigid objects during their uncontrollable muscle spasms.

The use of poisons to kill wildlife is in violation of the Canadian Council on Animal Care (CCAC) Guidelines and the International Union for the Conservation of Nature (IUCN) Wolf Manifesto. The Canadian Veterinary Medical Association denounced the use of Compound 1080 and strychnine in a position paper published in 2014 due to the severe pain and convulsions these poisons cause. Strychnine has long been judged by the Canadian Council on Animal Care (CCAC) as an inhumane way to kill animals.

Considering that a humane death implies one without signs of panic, pain or distress, minimum time to loss of consciousness, and minimal undesirable physiological and psychological effects on the animal, death through poisoning by strychnine, Compound 1080 or other predacides is inhumane and must be abandoned on ethical grounds. Proulx et al.'s scientific publication Poisoning wolves with strychnine is unacceptable in experimental studies and conservation programmes outlines the following: "According to the Canadian Council on Animal Care (CCAC 2003), a killing method is humane if it causes rapid (immediate) unconsciousness and subsequent death without pain or distress. Death by strychnine ingestion is inhumane, as it causes frequent periods of tetanic seizures, occasional cessation of breathing, hyperthermia, extreme suffering, and death from exhaustion or asphyxiation, which typically occurs within 1–2 hours of the onset of clinical signs (Khan 2010). However, death can take up to 24 hours or longer if the dose is low (Eason & Wickstrom 2001). The use of strychnine to kill wolves is in contravention of CCAC guidelines (CCAC 2003), the American Veterinary Medical Association (AVMA 2013), the Canadian Veterinary Medical Association (2014), and the American Society of Mammalogists (Sikes et al. 2011)". Although the above quotes reference strychnine, all predacides fit into this rationale. Finally, we want to take this opportunity to remind each of you about Alberta's Animal Protection Act, which states No person shall cause and animal to be in distress. See page 3 of http://www.qp.alberta.ca/documents/Acts/A41.pdf