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B.C. government asking for feedback on rodent poisons

The B.C. government is seeking public feedback on proposed changes to the province’s rodenticide regulations. Similar to the current temporary, partial ban on second-generation anticoagulant rodenticides (SGARs), the permanent changes being proposed fail to address a number of glaring gaps that will leave wildlife and pets at risk of rodenticide poisoning.

Birds of prey and scavengers that eat poisoned rodents continue to turn up dead; domestic cats and dogs are still being brought to veterinary clinics with serious symptoms of rodenticide poisoning, even losing their lives.

From now until June 19, 2022, animal lovers have a unique opportunity to speak up for wildlife and pets before B.C. moves forward with inadequate legislation.

Speak up for B.C. wildlife

Tell the provincial government that wildlife need stronger protections against inhumane and indiscriminate poisons. Click the link below to go to the B.C. government’s online consultation page.

Key points to consider during the public consultation period:

  • Many dangerous poisons would still be allowed under the new regulations, including first-generation anticoagulant rodenticides and neurotoxins.
  • Exemptions to the ban are too broad; second-generation anticoagulant rodenticides would still be used in many locations, including those with frequent wildlife activity.
  • Compliance with and enforcement of the partial ban have been inconsistent; there is inadequate evidence that the government has capacity to enforce proposed restrictions or Integrated Pest Management requirements.
  • Rodenticides are not a long-term solution, as they can harm and kill natural predators of rodents and cause ecosystem imbalance. Many more effective alternatives and prevention strategies exist.

Key recommendations

  • A comprehensive ban of all rodenticides is needed.
  • At the very least, the list of exempt locations should be reduced and the proposed changes should apply to all rodenticides.

Tips for filling out the public consultation survey

British Columbia residents can complete the online consultation by going to the B.C. government’s consultation page and clicking the button to “Submit comments online”.

If you are unable to complete the online consultation, you can email your feedback to IPMProgram@gov.bc.ca.

Continue scrolling for more in-depth points broken down by section. Please be sure to submit constructive comments in your own words.

Section 1: Demographics

Complete the section with your information.

Section 2: Discussion Questions (Optional – tap to expand)

Note: If you are unable to complete this section, you may still enter your key concerns under Section 3: General Comments. Please use the suggested points below as a guide rather than copy and pasting, as unique submissions are important.

QuestionSuggested points (in your own words)
1. The ministry is proposing to restrict the use of second-generation anticoagulant rodenticides (SGARs) to Essential Services … What is your feedback on the proposed Essential Services list?The list is too broad and will result in continued widespread use of SGARs.
It should be further reduced and essential services should be assessed to evaluate and prioritize prevention and alternatives to rodenticides.
For example, both rodent conflict and other wildlife activity may be present because of attractants, such as at garbage dumps or recycling facilities. This increases the probability of poisoning of non-target wildlife.
2. What is your feedback on implementing an Integrated Pest Management (IPM) program, focused on prevention and alternative control tools to rodenticides, when managing rodents?IPM has always been required, but has not been consistently followed or enforced.
Express your concerns about how prevention and alternatives will be enforced.
3. What is your feedback on the proposed requirement for a site-specific IPM plan where SGARs are used?Enforcement appears reactionary (site-specific plans would be provided to ministry inspectors upon request) rather than proactive (require all plans be submitted and reviewed).
4. The ministry is proposing to only allow short-term baiting if using SGARs within an IPM program. … How might the use of SGARs only for short-term baiting within an IPM program affect Essential Service operations?It appears that compliance would be based on good faith by service owners and operators.
Express your concerns about how compliance with 35-day limit and 120 total days per year time limit will be tracked and enforced.
Questions 5-11Respond as desired or proceed to Section 3.

Section 3: General Comments

12. Do you have any other feedback on the proposed changes outlined in the Intentions Paper?

Respond with your main concerns and key points. Below are some additional details to consider. Please feel free to use the points below as a guide, but be sure to submit comments in your own words rather than copying and pasting.

  • There are many negative impacts of rodenticides, such as secondary poisoning of non-target species—which poses a danger to domestic pets and wildlife, including birds of prey.
  • The proposed changes don’t impact the use of other dangerous and inhumane rodenticides, such as first-generation anticoagulants (FGARs) and non-anticoagulants. For instance, veterinarians have raised concerns about bromethalin, a neurotoxin with no specific antidote, yet its use as a rodenticide is still permitted.
  • Exemptions for essential services are too broad and would mean SGARs will continue to be used in many circumstances and contribute to significant wildlife poisoning and deaths.
  • There are concerns about the government’s ability to enforce a permanent partial ban on SGARs. Evidence of suspected SGAR use in prohibited locations was routinely found during the temporary ban and follow-up on reported complaints was inconsistent and slow, suggesting that there aren’t enough resources allocated to effectively enforce a partial ban.
  • The same concerns exist with regard to capacity to enforce enhanced Integrated Pest Management (IPM) requirements—how will the government ensure compliance in terms of no preventative SGAR baiting; ensuring prevention and alternative measures are first exhausted; and limits on baiting time periods? IPM is already required in the current regulations and has not been effectively enforced, leading to regular overuse and misuse of all rodenticide products.
  • There are many prevention methods and alternatives.
  • Prevention is the only long-term solution to rodent conflict. For instance, removing attractants (garbage, compost, food sources like bird seed and fallen fruit, leaky plumbing); rodent-proofing buildings and fixing structural flaws and access points; habitat modification (cutting back bushes and grasses from around building, storing items away from buildings and off the ground).
  • Alternatives exist for lethal control, if needed, including high-quality snap traps; captive bolt traps and other mechanical systems (e.g. Goodnature device); rodent contraceptives (e.g. Contrapest); supporting presence of natural rodent predators, such as owls, through building owl boxes. A family of owls can eat more than 1,000 rodents per year!
  • Recommendation: For all of the above listed reasons, a complete ban on all rodenticides is strongly recommended, including FGARs and non-anticoagulants. As currently proposed, the regulations would result in a complicated patchwork of rules for different audiences and different rodenticide products, which is practically impossible to enforce.
  • At the very least, the proposed essential services list should be further reduced and, crucially, all of the proposed changes being proposed should be applicable to all rodenticides, rather than just SGARs. This would streamline the regulations across audiences and rodenticide products, creating more consistency in the regulations and enforcement.

Note: clicking the button below will open the link in a new tab. You can still return to this tab to review the key points.

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B.C. wildlife photographers call for full ban on dangerous rodent poisons

Calls continue to grow for a comprehensive ban on rodent poisons across British Columbia. The province’s current temporary ban on second-generation anticoagulant rodenticides (SGARs) still allows for these products to be used in many circumstances. Meanwhile, the ban fails to prohibit other dangerous rodenticides that pose a similar threat to wildlife from being used. These loopholes prompted VHS, advocates and concerned B.C. residents to call for further action by the B.C. government to protect wildlife from these dangerous and cruel poisons.

Most recently, the Canadian Conservation Photographers Collective shared their support for a comprehensive rodenticide ban and their members took to social media to help raise awareness.

“The Canadian Conservation Photographers Collective (CCPC) fully supports a province-wide ban of all rodenticides in British Columbia as proposed by the Vancouver Humane Society.

The indiscriminate use of rodenticides in the province leads to the deaths each year of many non-target species, such as raptors and household pets. Many owl species, which are extraordinarily adept at catching and killing rodents, are the unfortunate victims of rodenticide use. As advocates for conservation, our members would welcome the discontinuation of all rodenticides in B.C. and the rest of Canada.”

CCPC members shared stunning images of different species who often fall victim to rodenticide poisoning, reiterating the widespread impact of these indiscriminate poisons. Scroll down the page to see some of the CCPC photographers’ powerful images and words.

If you haven’t already, you can also add your name to our petition, calling for a comprehensive rodenticide ban.

Yuri Choufour

“They’ve played an important role in ecosystems for millions of years and captured the human imagination through recorded history. I think you’d be hard pressed to find someone who doesn’t like owls. When scanning their surroundings with large piercing eyes, these elusive and charismatic birds often perch hidden in plain sight. Varying adaptations such as nearly silent flight, strong vision & exceptional hearing have made them one of nature’s ultimate rodent hunters.

Some owl species are already imperilled by habitat loss, so we need to act to diminish further threats! Thanks to efforts by the Vancouver Humane Society, you can take part in an online petition to help put an end to the controversial use of rodenticides in BC. These poisons are counter-productive, as they often kill the predators of the targeted rodents in the process. We would love you to lend your voice, helping put a stop to this outdated practice. There are better solutions out there, and we need to continue to improve when it comes to coexisting with wildlife.”

Follow: yurichoufour

Mark Williams

“Rodenticides:

You may have heard this this term, you may have even considered using them, trusting a large company that they are safe, well they are absolutely not. Not for you, for your pets and certainly not for a number of wild animals.

They are extremely toxic poisons that cause a slow and painful death for the rodents. Then what do you think happened to the dead rodents? They are consumed by a number of scavengers or the sick rodents are piled off by predators like owls having deviating effects. I also ready one study that over 60% of mountain lion necropsies found large numbers of rodenticides in them. They are also very harmful for pets and can easily getting into human agricultures for us to consume.”

Follow: marineconservationphotography

Isabelle Groc

“A few years ago, I wrote and co-directed with @mikemckinlayproductions a short film in collaboration with @wildernews about the work of biologist Sofi Hindmarch to understand and conserve the threatened barn owl in British Columbia. ‘Silent Flight’ highlights the many struggles this species is facing: habitat loss, road mortality and rodenticide poisoning. The film can be viewed in the film section of my website.

Today there is an opportunity for all of us to take action and make a difference for the survival of the barn owl, and all wildlife species that suffer a slow and painful death after consuming poisoned rodents.

On July 21, 2021, the B.C. government enacted an 18-month partial ban on second-generation anticoagulant rodenticides (SGARs), citing the serious risk they pose to the public, pets and wildlife. This means SGARs cannot be used in or around most residential buildings, offices, parks, schools, or non-food retail shops. Unfortunately, gaps in the ban and an apparent lack of enforcement continue to leave wildlife at risk.

Please join me and the members of @theccpc.ca in supporting the @vancouverhumane who are asking the government of British Columbia to ban all rodenticides in the province.”

Follow: isabellegroc

Ryan Miller

“Vancouver Humane Society is taking action to ban rodenticides. They are 1000 signatures shy of their goal.

Rodenticides are highly toxic poisons that cause a slow and painful death for the rodents that consume them and can severely injure or kill any scavengers, predators or pets who encounter the poisoned rodents. In fact, B.C.-based Orphaned Wildlife Rehabilitation Society (OWL) noted that a few years ago a blood test study found that more than half of the animals in their care had poison residue in their system.”

Follow: ryanmillerphoto

Trailz

“Important BC Wildlife post … Please go to @vancouverhumane click in their profile to sign the petition to permanently ban poisons against all wildlife. Lets be a voice for those without and help protect these beautiful lives.”

Follow: happytrailzjk

Ray Maichin

“Rodenticides have long caused problems for BC wildlife. On top of being extremely inhumane, rodenticides have far reaching consequences not just to the target ‘pests’ but the wildlife that feeds on them.

Last year, the BC government put a temporary ban on rodenticide use which may be lifted soon. @vancouverhumane and others are calling for a full PERMANENT ban on these deadly poisons that also pose threats to children and pets.”

Follow: raymaichinphoto

Michael, Vancouver Island Wildlife

“At the time I’m writing this The Vancouver Humane Society is a little over a thousand signatures short of there goal of 5000 to help ban the use of rodenticides.

Rodenticides for anyone that doesn’t know are an incredibly toxic poison that once consumed cause a very cruel and painful death to the rodents that consume.

The effects of rodenticides doesn’t stop there as it can cause severe injuries and death to scavenging animals especially birds of prey that feed on these rodents!

On July 21st 2021 the BC government put in place a 18 month PARTIAL ban on rodenticides where they can not be used near schools, residential buildings, parks, offices, or non-food retail shops. Holes in this law and lack of enforcement are still leaving wildlife at risk!”

Follow: islandwildlife

Josh DeLeenheer

“Please join me and the members of @theccpc.ca in supporting the @vancouverhumane, who are asking the government of British Columbia to ban all rodenticides in the province. This is an opportunity for you to have a direct impact on a conservation issue.”

Follow: josh.deleenheer.photography

You can help!

Your voice can make a difference in the call to protect wildlife from cruel and dangerous rodent poisons. Take the quick action to support a full ban on rodenticides in B.C.

Looking to protect animals in your community? Next time you are running errands or spending time outside, keep an eye out for bait boxes that may contain banned poisons around non-exempt locations like apartment buildings, offices, and parks. Learn how to identify and report banned rodenticides here.

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Open letter: B.C.’s wild and exotic animal captivity rules due for update

VHS and residents from across B.C. and Canada call for better protections for wild and exotic animals

Last month, VHS launched a campaign seeking changes to B.C.’s rules around wild and exotic animal captivity. To date, the petition demanding immediate action to protect animals from suffering in zoos and aquariums has received more than 4,700 signatures.

VHS has now shared that petition with provincial decision-makers, along with a request for a meeting and an open letter outlining our recommendations for updating B.C.’s outdated regulations around wild and exotic animal captivity.

The open letter calls on the B.C. government to:

  • Incorporate animal welfare criteria into considerations around species suitability for captivity
  • Prevent bringing in new exotic animals into permanent captivity and prohibit captive breeding of existing captive exotic animals
  • Close loopholes in current provincial regulations that leave out many species
  • Acknowledge and act on growing body of science that indicates wild and exotic animals suffer psychologically in captivity

You can read the full letter below as a PDF, or scroll down to add your name to the growing call for change and view the open letter on this page. We will keep ministry decision-makers updated on the total number of public signatures in support of the campaign, and will keep you updated on the campaign’s progress.

April-2022-VHS-Captivity-Briefing-Note

By signing the petition, you call on the B.C. government to:

  • Expand the Controlled Alien Species regulation criteria to include animal welfare considerations and update the CAS list to include and prohibit the keeping, breeding and transporting of all exotic species for permanent captivity.
  • Adopt a positive list approach, which allows only those species that meet certain evidence-based suitability criteria to be kept, bred and transported.
  • No longer allow permits to be issued for the keeping, breeding and transporting of exotic animal species, including for zoos and aquariums, film and tv industry, and research and education institutions;
  • Relocate to more appropriate facilities, animals whose physical, psychological and/or social needs are not being adequately met in captivity and/or those who are not appropriate for B.C.’s climate.
  • If no suitable alternatives exist, allow exotic species currently kept in captivity to remain, but prohibit captive breeding of exotic species.
  • Restrict captive breeding of native wildlife, unless it is part of a reintroduction program into the wild.
  • Maintain records for all individual wild and exotic captive animals in facilities, including information related to origin, import/export, breeding, births, deaths, and transport history.
  • Require emergency management plans for all wild and/or exotic animals in captivity.

Call for changes to wild & exotic animal captivity rules in B.C.

Discussion & recommendations for updating B.C.’s wild and exotic animal regulations 

Summary of recommendations 

  • Expand the Controlled Alien Species regulation criteria to include animal welfare considerations and update the CAS list to include and prohibit the keeping, breeding and transporting of all exotic species for permanent captivity. If no suitable alternatives exist, allow exotic species currently kept in captivity to remain; 
  • Adopt a positive list approach, which allows only those species that meet certain evidence-based suitability criteria to be kept, bred and transported; 
  • No longer allow permits to be issued for the keeping, breeding and transporting of exotic animal species, including for zoos and aquariums, film and tv industry, and research and education institutions; 
  • Relocate to more appropriate facilities, animals whose physical, psychological and/or social needs are not being adequately met in captivity and/or those who are not appropriate for B.C.’s climate. 
  • Prohibit captive breeding of exotic species. 
  • Restrict captive breeding of native wildlife, unless it is part of a reintroduction program into the wild. 
  • Maintain records for all individual wild and exotic captive animals in facilities, including information related to origin, import/export, breeding, births, deaths, and transport history.  
  • Require emergency management plans for all wild and/or exotic animals in captivity. 

Introduction 

The Vancouver Humane Society (VHS) is a registered charity dedicated to the humane treatment of animals. The VHS has identified that the keeping, breeding and transport of wild and exotic animals (wild animals not native to B.C.) for the purposes of permanent captivity is not in the public interest. 

Background 

Psychological impact of captivity 

Society’s understanding of how wild and exotic animals can suffer in captivity has expanded greatly over the years. Consider that around the time Canada’s first SPCA was founded in 1869, much of the focus was on the treatment of work horses, used routinely as transportation in cities at the time. Efforts were focused on preventing physical mistreatment of animals, but much less was known then about the psychological suffering of animals. Nearly 150 years later, in 2017, the Vancouver Park Board prohibited new cetacean (whales, dolphins and porpoises) captivity and performances in city parks, citing that the display of these intelligent and social mammals was no longer ethical. This decision, along with ground-breaking federal legislation in 2019 that similarly banned cetacean captivity, acknowledged the scientific evidence that reflects how confinement in captivity causes not only physical, but also psychological suffering.  

Today, a vast body of scientific literature outlines that good welfare is about more than just an animal’s basic health and functioning, such as freedom from pain, injury or disease. Good welfare goes beyond this to consider an animal’s ability to live naturally, including engaging in important instinctual behaviours, as well as an animal’s emotional state and their ability to engage in positive experiences, such as play and social contact.  

Wild and exotic animals, whether wild-caught or captive-bred, retain their complex social, physiological and behavioural needs that they would have in the wild. Attempting to replicate their natural environment in a captive setting is incredibly challenging and failure to meet their needs can significantly compromise their welfare. 

Scientific research, including studies published since B.C. implemented the Controlled Alien Species regulation in 2009, outlines how wild and exotic animals suffer in captivity when deprived of the ability to live naturally and experience positive affective states. Captive conditions are known to elicit abnormal behaviour across a range of different species, due to an animal’s inability to cope with stressors, behavioural frustration or psychopathology.  

Stressors in captivity can include exposure to aversive sounds and smells; uncomfortable temperatures or substrates; artificial lighting; restricted movement; inability to escape from public view and from other animals; artificial social groupings; and inability to engage in instinctive behaviours. Captive animals are often kept in climates and exposed to temperatures that their species is not adapted to, which can cause distress and impact their behaviour. Studies suggest that thermal ranges are complex and can differ based on the species, developmental age, weight and number of animals being housed. This makes temperature control especially challenging for captive facilities.  

Chronic stress in captive animals can lead to health problems including weight loss, immune system changes, disease susceptibility, reproductive suppression, premature death and high infant mortality rates. For example, studies indicate that giraffes have shorter lifespans in captivity than in the wild. Cheetahs in Western captive facilities have been found to experience reproductive issues, including high infant mortality rates. They also exhibit elevated cortisol levels and are more susceptible than their wild counterparts to bacteria that causes severe gastritis. Captive penguin species are also more likely than wild penguins to experience Aspergillosis, a stress-related fungal infection.

Responses to chronic stress can also present as stereotypical behaviour, which is repetitive, purposeless and an indicator of poor psychological well-being and poor general welfare. This can include stereotypic ritualistic behaviour like pacing or head-tossing; self-directed behaviours, like feather-plucking or over-grooming; or externally directed behaviors, like aggression toward other animals. Stereotypy is a major issue for zoos and aquariums. In fact, approximately 75% of the captive giraffe population in North America exhibits oral stereotypic behaviours, including wall licking. Stereotypy is also estimated to occur in the vast majority, approximately 82%, of captive carnivores.

These behaviours, which are common in captivity but almost never take place in the wild, are often referred to as zoochosis. This chronic inability to cope with stressors and/or behavioural frustration can also lead to significant cognitive issues in captive animals. Research explains that “…these states may result in physiological stress and the release of cortisol into the circulatory system…Specifically, circulating cortisol may act upon the hippocampus in the brain, resulting in temporary amnesia and inhibition of learning or response to new experiences (e.g., enrichment or behavioral modification)…In addition, chronic exposure of the hippocampus to circulating cortisol may accelerate hippocampal degeneration, a normal ageing change associated with senile cognitive dysfunction or dementia-like syndromes which have been described in apes, canids and felids.” In the wild, the stress-response allows an animal to make decisions and escape dangerous situations, but in captivity there is little to no ability for an animal to make such choices when stressed. This chronic stress can lead to “learned helplessness”, a psychological condition whereby individuals learn that they have no control over their environment. This can result in negative behavioural and physiological consequences, including impacting brain health by compromising the functioning of the hippocampus, amygdala, neurons and serotonin, which regulate memory, emotions, movement, behaviour, and mood. 

Addressing the psychological suffering of captive wild and exotic animals is incredibly challenging, particularly when we consider that for some species the evidence of suffering can be very subtle or undetectable by humans (e.g. outside of our audible range). In addition to this, new research suggests that abnormal behaviour repertoires and the behavioural expression of stress can also vary between individuals of the same species, adding further complexity to the issue.

Government responsibility 

Public sentiment around wild and exotic animal captivity has also been shifting in recent years, with growing concern about the welfare of animals in captive environments. This is reflected in research that indicates good welfare in zoos and aquariums is valued by the general public. The same research found a high rate of willingness among zoo visitors to pay for animal welfare improvements. Another study found “dissatisfaction of zoo staff with executive management and government officials’ knowledge and leadership in promoting good animal welfare.” The study suggests that leadership in prioritizing animal welfare is also needed at the level of government ministries responsible for overseeing captive facilities. These studies highlight the government’s responsibility to address animal well-being, as instances of abnormal behaviour have been minimized by facilities holding captive animals. For example, when asked why a Steller sea lion at the Vancouver Aquarium was repetitively sucking on the substrate of their enclosure, an aquarium representative explained it as a “comforting behaviour the animals like to do after eating”, comparing it to a baby sucking their thumb.  

Locally, recent public polling data reveals that 89% of British Columbians oppose the international trade of exotic, wild animals to be kept on display in permanent captivity in zoos and aquariums. This reinforces that protecting the welfare of captive animals is indeed in the public interest and there is an expectation that the provincial government, as the regulator of wild and exotic animals in captivity in B.C., has a responsibility to prioritize this. The protection of animal welfare is a widely shared value in our society, as evidenced by its inclusion in our laws, but it’s not being consistently applied. Given the obligation under our existing laws to not knowingly harm animals; the leadership of other levels of government to respond to changing public sentiment and animal welfare considerations; and the scientific evidence outlining the harm that non-domesticated animals face as a direct result of captivity, it follows that the provincial government has the moral responsibility to better protect wild and exotic animals in captivity.    

Zoonosis concerns 

The Covid-19 pandemic also put a spotlight on the wildlife trade and its connection to infectious disease risk. In fact, research indicates that 75% of emerging infectious diseases are zoonotic (transmitted from non-human animals to humans). The international trade of animals, including for captive facilities, increases the risk of disease spread. Factors that increase the risk of disease spread include more animal species; higher risk species; more animal numbers; more human contact; greater geographic ranges; movement from less encountered areas; species we know less about; mixing of species (in transit, upon arrival); less structure/scrutiny. These factors directly relate to captive facilities like the Greater Vancouver Zoo and Vancouver Aquarium, where large numbers of animals, from a variety of species and geographic ranges that would otherwise not occur in such proximity to each other are kept.  

Covid-19 cases or evidence of exposure has been confirmed in a number of captive species, including tigers, lions, puma, snow leopards, Canada lynx, jaguars, Asian small-clawed otters, gorillas, mink, white-tailed deer, ferrets, binturongs, fishing cats, coatimundi, spotted hyenas, and hippopotamus.

Local context 

The VHS has monitored the issue of wild and exotic animal captivity in B.C. for many years, dating back to 1997, with the first report about the Greater Vancouver Zoo published by VHS and Zoocheck. Subsequent reports were published in 2003, 2008, and most recently in 2019. Common recurring issues throughout the reports include observed abnormal behaviour by animals; inappropriate housing of social species; enclosure conditions; water-logging and dampness of outdoor exhibits; lack of enrichment; and breeding practices. Recurring recommendations have included ending the keeping of exotic species; providing more enclosure space and complexity; improved enrichment; housing according to social needs; and ending captive breeding.  

The VHS has also advocated over the years for changes at the Vancouver Aquarium, including supporting a move away from cetacean (whale, dolphin and porpoise) captivity. Through a report, “A Crumbling Case for Cetacean Captivity”, claims that cetacean captivity resulted in substantive conservation research and education benefits was critically assessed. The report concluded that the output of captive cetacean research papers was relatively low and a citation analysis largely suggested that impacts were not substantive. The educational benefit of captive cetaceans was also not substantiated. The report went on to note that stated goals of conservation and education made by zoos, marine parks and aquariums can be achieved, and in many instances are being achieved, in other ways that do not require the keeping of live cetaceans in captivity. It’s also worth noting that in terms of research on captive animals, they can respond quite differently to a range of experiments than a wild, free-living counterpart would. This reinforces the importance of prioritizing field research and the conservation benefits of studying species in the wild. 

The VHS has encouraged both facilities to transition toward a sanctuary model, focused on rescue, rehabilitation and release programs for injured and orphaned native wildlife and to assist and support conservation efforts of native, wild populations. 

Provincial definitions and regulation of wild and exotic species 

The keeping, breeding and transport of wild and exotic animals is governed under British Columbia’s Wildlife Act and its regulations.  

Under the Wildlife Act, the definition of “wildlife” includes raptors, threatened species, endangered species, game and other species of vertebrates prescribed by regulation, and for the purposes of a number of specific sections, also includes fish. The definition of “game” includes big game, small game, game birds and fur bearing animals, and other species prescribed as game. The Designation and Exemption Regulation lists several schedules of species, noting that Schedule A are prescribed as wildlife for the purposes of the definition of “wildlife” in section 1 of the Wildlife Act. Schedule B lists animals that may be captured or killed only for the specific purpose of protecting property unless an open season is designated by regulation. Schedule C lists animals that can be captured or killed anywhere and at any time in B.C. A hunting licence is not needed to hunt or kill Schedule C animals, unless a person is hunting the following species on their property or they are damaging the person’s property: crows, black-billed magpie, and brown-headed cowbird. Schedule D lists threatened species, with sea otters as the only species currently listed. Schedule E lists endangered species, including the Vancouver Island marmot, burrowing owl and American white pelican. Under the Wildlife Act Permit Regulation, a permit can be issued to possess and transport live wildlife.

Under this framework, the definition of “wildlife” excludes exotic animals, a number of species of which are designated as “controlled alien species” under a separate regulation by the Wildlife Act. Section 6.4 of the Wildlife Act states that the minister can designate a non-native species that poses a risk to the health or safety of any person or poses a risk to property, wildlife or wildlife habitat as a controlled alien species. The minister may by regulation prohibit and impose requirements in relation to the possession, breeding, release, selling and transporting of a controlled alien species. B.C.’s Controlled Alien Species Regulation currently designates more than 1,000 exotic species as controlled alien species, prohibiting that they be kept, bred or transported without a CAS permit. Permits are allowed for accredited or equivalent zoos and aquariums; certified research and educational institutions; film and tv production companies; rescue facilities; and prohibited animals passing through the province in transit. Private individuals still have sunset permits and if they want to transfer ownership to another person, can apply for permit. 

Bill S-241 

Recently proposed federal legislation, Bill S-241 (Jane Goodall Act), aims to improve protections for captive animals across Canada. The bill prohibits owning, breeding, importing/exporting and interprovincial transport, and possessing reproductive materials for a wide range of species, including big cats, bears, wolves, seals, sea lions, walruses, certain monkeys, and dangerous reptiles, such as crocodiles and giant pythons. It provides exceptions for existing individual animals currently in captivity; for those in need of rehabilitation; for the purpose of conducting non-harmful scientific research or in the best interest of the animal, with regard to individual welfare and conservation of the species.   

Bill S-241 also prohibits the captivity of the listed species for entertainment purposes; phases out captivity of elephants; and restricts captivity of great apes to specific organizations for the purpose of conservation and research only. It also identifies seven organizations that have been deemed in the bill to be eligible animal care organizations, including the Vancouver Aquarium but no other facilities in B.C.  

It outlines a number of factors to be considered when adding or removing a species from the list of designated animals subject to the prohibitions and references consultation with representatives of groups whose objective includes the promotion of animal welfare. Considerations listed include whether the biological and ecological needs of individual animals to live a good life can be met in captivity, specifically their ability to engage in natural behaviour; their intelligence, emotions, social requirements, physical size, lifestyle and potential use in performances of species; the public safety risk they pose; and the evidence of harm to animals of the species in captivity, including stereotypies, health problems in captivity, shorter lifespans and increased infant mortality rates. 

The bill allows the Minister to issue permits authorizing eligible animal care organizations to keep designated animals; conduct non-harmful scientific research; breed; import; transport between eligible animal care organizations; transport/export for relocation to natural habitat; export to an animal care organization outside of Canada that is a member of the Association of Zoos and Aquariums or the Global Federation of Animal Sanctuaries or that would be considered an eligible animal care organization if located in Canada. The bill requires organizations to apply for designation as an eligible animal care organization. Organizations are expected to administer the highest professionally recognized standards and best practices of animal care; have procedures that protect whistleblowers; refrain from activities that misrepresent or degrade captive animals, including through performance for entertainment purposes; and acquire animals in a manner that doesn’t threaten species populations. The Minister may prescribe standards and best practices of animal care, if professionals in animal science, veterinary medicine and animal care, and groups whose objective includes promotion of animal welfare have been consulted and if the standards account for the best available science and information. 

Issues 

Gaps in provincial regulations 

B.C.’s existing regulations related to the keeping, breeding, display and transport of exotic species are not comprehensive, leaving out many exotic species that are not subject to permits under regulations, because they are not considered “wildlife” as per the Act’s definition, or are not on the CAS list. For example, exotic species including, but not limited to, zebras, kangaroos, serval cats, ball pythons, and wallabies can still legally be kept by anyone in B.C. where there are no municipal restrictions. 

The CAS regulation currently prohibits only species that pose the greatest threat to public health and safety and does not consider animal welfare or a species’ suitability for captivity. The CAS regulation has not been significantly updated since it was created in 2009. Meanwhile, a growing body of evidence, as outlined in this document, pointing to how exotic animals suffer in captivity, along with shifting public sentiment, reflects the need for B.C.’s regulations to be updated. 

Controlled alien species permits and reliance on Canada’s Accredited Zoos & Aquariums accreditation  

Currently, the B.C. government issues permits to zoos and aquariums for possessing, breeding and transporting prohibited controlled alien species, requiring that they be either accredited by Canada’s Accredited Zoos & Aquariums (CAZA), or able to provide proof to the satisfaction of the director of meeting or exceeding the accreditation standards set by CAZA in order to receive a permit. In reviewing the B.C. government’s permit application, the only supporting documentation required is certification of insurance. Any other information pertaining to species welfare and care, enclosure details, safety standards and collection/breeding plan is available upon request and shared by CAZA on the facility’s behalf.

This heavy reliance on and downloading of responsibility to ensure high standards to a private, industry association is problematic for ensuring oversight and transparency around captive facility operations.  

A review of CAZA’s organizational structure, as outlined in the 2021 Accreditation Process Guide, illustrates how the organization is a private zoo and aquarium industry association that represents the interests of its members and that CAZA accreditation is not, on its own, an indicator of best practices and high animal care standards. CAZA’s organizational structure, including the Board of Directors, Accreditation Commission, Visiting Committee, Accreditation Appeal Panel, and Ethics and Compliance Committee, are comprised of CAZA members, with the exception of a veterinarian, permitted to be on the Visiting Committee and Accreditation Commission (as a non-voting member). The criteria for serving as an Accreditation Inspector requires that individuals are CAZA members (veterinarians may be an exception) and that individuals are currently employed at an accredited institution, with no exception noted for veterinarians.

Another overarching concern regarding CAZA is that the accreditation standards are vague, not species-specific, and largely outcome-based, leaving the process in terms of how to achieve them open to interpretation. Instead, prescriptive requirements can help prevent animal welfare issues from occurring in the first place, because they outline a specific process or action to follow, making them more objective and easier to enforce. For example, the Global Federation of Animal Sanctuaries (GFAS) accreditation program includes more taxa-specific, in-depth animal care standards. Standards around space allocations illustrate this difference between outcome-based and prescriptive approaches. CAZA standards around space allocations, which are not taxa-specific, state that “Habitats in which animals are on public display must be of a size which enables the animal to demonstrate natural behaviours and to achieve a full range of body motion and physical movements.” While outcome-based measures can be useful, when used, they must be based on both psychological and physical metrics. Being able to physically move is not enough of a benchmark to establish the well-being of an animal in captivity. 

CAZA standards also state that member institutions must develop a clear and transparent process for identifying, communicating, and addressing animal welfare concerns, including from members of the public. It’s required that feedback to the person submitting the observation be timely. Prior to publishing of VHS’s most recent Greater Vancouver Zoo report in 2019, the author of the report made a number of attempts to engage with zoo management but received no response. VHS also shared the report with the zoo’s owner and received no response.  

Also of concern is that CAZA facility inspections occur only once every five years, with facilities notified in advance when they will be subject to an inspection. The results of these inspections are also kept confidential, preventing transparency and oversight of the accreditation process.  

Ultimately, CAZA accreditation simply indicates that minimum standards have been met that qualify an institution for CAZA membership, rather than any assurance of adequate standards for animal care and welfare.  

Recent captive facility incidents and site visits 

A series of high-profile incidents that have occurred in recent years at CAZA-accredited facilities in B.C., along with the multiple reports, photos and video evidence collected of concerning behaviours and circumstances, reinforce the issues around relying on CAZA accreditation for CAS permits. A lack of adequate facilities is also evidenced by the history of incidents and concerns outlined in various VHS reports, dating back to 1997, and discussed in the background section of this document. Since VHS’s last report was commissioned, several more high-profile incidents have occurred at the Greater Vancouver Zoo, including an incident in August 2019 in which a toddler was able to access an unauthorized area and was bitten by a black bear, resulting in the child being airlifted to hospital in serious condition. Then in the summer of 2020, photos of an emaciated-looking moose shared by a zoo visitor prompted public concern and resulted in the animal being euthanized the following day. Most recently, a WorkSafeBC report obtained by CBC News discovered that in December 2021 a zoo employee was bitten while feeding one of the zoo’s jaguars through a metal feeding chute. 

VHS visits to the Greater Vancouver Zoo in January and the Vancouver Aquarium in February of this year resulted in further documentation of ongoing animal welfare concerns. Photo and video evidence collected during these facility visits and from previous visits in recent years establishes a history of concerning situations and behaviour. This includes abnormal, purposeless, and repetitive behaviour by a number of animals, including a Steller sea lion seen repeatedly sucking on the ground of their enclosure; sea otters repeatedly pulling on the edge of their tank; a lone male lion repetitively pacing the fence that separates him from other captive lions; and giraffes licking and biting the bars of their enclosure. VHS also documented a number of inadequate enclosures, including for the two hippos at the Greater Vancouver Zoo, whose indoor enclosure is small and barren. It also appears there is only one, small indoor pool. Signage on their enclosure indicates they have been kept separated from each other since at least the summer of 2020. The African Penguin enclosure at the Vancouver Aquarium is also small and fails to provide any opportunity for the animals to escape public view. The penguins were observed spending the vast majority of the day during public viewing hours huddled together around a door in their enclosure. This evidence led VHS to submit a report to the BC SPCA and an investigation has since been opened and is underway.  

Bill S-241 gaps 

While Bill S-241 proposes a number of significant changes to the wild and exotic animal captivity industry across Canada, particularly in areas of the country where current regulations are largely non-existent, there are gaps in the bill which B.C. can address through action at the provincial level. The bill’s exceptions around owning, breeding, importing/exporting and transporting of designated animals for non-harmful scientific research or in the best interest of the animal, with regard to individual welfare and conservation of species leaves room for interpretation. Clarity is needed around what criteria will constitute legitimate non-harmful scientific research, an animal’s best interest and species conservation.  

The preamble to Bill S-241 acknowledges the shared federal and provincial jurisdiction around the subject of non-domesticated captive animals. This reality of shared jurisdiction means that, should Bill S-241 pass, the B.C. government would need to update provincial permitting for wild and exotic animals to meet or exceed the regulations outlined in Bill S-241, as the federal regulations would prevail over any weaker provincial regulations in this case. In its second reading in the Senate, the bill’s sponsor, Senator Martin Klyne, stated that the Association of Zoos and Aquariums (AZA) has one of the highest standards of accreditation, with only seven facilities in Canada achieving AZA accreditation. These seven facilities, which includes the Vancouver Aquarium but not the Greater Vancouver Zoo, are listed as the first eligible “animal care organizations” under bill S-241. Senator Klyne acknowledged that other organizations, including CAZA-accredited facilities, would need to improve or evolve in order to be approved as an animal care organization under the bill. This reinforces the need for improvements to B.C.’s regulations around wild and exotic animal captivity.  

While Bill S-241 extends protections to more than 800 wild animal species, thousands of other species remain unprotected under the proposed regulations, as well as under existing provincial CAS or Wildlife Act regulations. This includes species such as zebras, kangaroos, serval cats, ball pythons and wallabies. 

Recommendations 

With B.C.’s Controlled Alien Species regulations currently under review, now is the ideal time for updated regulations that are informed by society’s expanded awareness of the issues facing wild and exotic animals in captivity.  

The VHS is recommending a number of actions be taken to address the issues and gaps outlined in this briefing note: 

First, the VHS recommends that B.C.’s Controlled Alien Species Regulation be expanded to include criteria related to animal welfare considerations and, ultimately, that the possession, breeding, and transporting of all exotic species for the purpose of permanent captivity be prohibited. Crucially, this prohibition must also apply to circumstances under which the B.C. government currently issues CAS permits, including accredited zoos and aquariums, TV and film industry, and research and education institutions. 

Exemptions should be considered for existing exotic animals in B.C. In regards to possession, this includes maintaining the exemption that allows for a Rescue Centre Possession Permit for seized, abandoned or surrendered CAS animals. An exemption should also be included for the possession and transport, for the purposes of rehabilitation, of established, wild, non-native Wildlife Act species, including but not limited to grey squirrels. This exemption is not intended to include invasive species that pose serious impacts on native species and the environment. In addition, abandoned domestic European rabbits should be removed from Schedule C of the Wildlife Act, to allow for rehabilitation and rehoming without the requirement of a permit. 

In regards to transport of exotic species, an exemption should be included that allows existing exotic animals in B.C. to be relocated to more appropriate facilities if their physical, psychological and/or social needs are not being adequately met in captivity and/or those species who are particularly inappropriate for B.C.’s climate. Criteria for what constitutes a more appropriate facility should be based on the Global Federation of Sanctuaries accreditation standards or equivalent. A transport exemption should also apply for seized, abandoned or surrendered CAS animals under a Rescue Centre Possession permit. The VHS asks that the B.C. government adopt a positive list approach to the CAS regulation, which is a framework that allows only those species that meet certain evidence-based suitability criteria to be kept, bred and transported. This serves as an alternative to B.C.’s current negative listing approach, which involves restricting or banning problematic species. As outlined in a previous VHS submission regarding positive lists, the advantages include that they are short and easily understood by the public; they use an evidence-based approach, including animal welfare considerations; they are preventative and utilize the precautionary principle; and the onus is on those who wish to trade or keep exotic animals to identify animals suitable as pets. 

The VHS also asks that breeding of existing captive exotic species in B.C. be prohibited, effective immediately, so that efforts can be focused on providing the best possible care for those individual animals while ensuring no additional exotic animals are born into permanent captivity in B.C. facilities. Native wildlife must not be bred for the purpose of permanent captivity. As such, breeding of captive native wildlife should be restricted and only permitted as part of a reintroduction program into the wild, with video streaming permitted, but no physical display of the animals to the public allowed.  

The VHS’s final recommendation relates to record-keeping and emergency planning for facilities that have captive wild and exotic animals. As part of the B.C. government’s permitting process, the province should require and maintain records for all individual wild and exotic captive animals in B.C. facilities, including information related to every individual animal’s origin, import and export history, breeding history, births, deaths, and transport history. This should also include all animals owned by a facility but on loan. Similarly, emergency management plans for all wild and exotic captive animals must be required. Last year’s catastrophic flooding, heat dome and wildfires and the deaths of more than one million farmed animals as a result reiterates the growing importance of protections for animals under human care during disasters and emergencies. The area impacted in last year’s flooding of the Fraser Valley was not far from the location of the Greater Vancouver Zoo. It’s crucial that emergency planning include a feasible strategy for urgent animal evacuations to prevent the kind of mass suffering we have seen. 

While this document is focused on the context of zoos and aquariums, B.C.’s regulations also encompass the use of wild and exotic animals in other industries, such as TV and film, exotic pets, and educational and research institutions. The discussion and considerations outlined in this document should apply to all industries and use of wild and exotic animals that are subject to B.C.’s regulations.  

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Protect wild, exotic animals in captivity: Petition

Wild, exotic animals suffer in captivity

Zoos and aquariums cannot replicate the size and complexity of a wild animal’s natural habitat. Captive wildlife are also unable to engage in many natural behaviours that are crucial to their physical, social and psychological well-being. Captive exotic animals are often kept in climates that are not suitable for their species.  

According to a recent poll,89% of British Columbians oppose the international trade of exotic animals (wild animals not native to B.C.) to be kept on display in permanent captivity in zoos and aquariums.

By signing the petition, you call on the B.C. government to:

  • Expand the Controlled Alien Species regulation criteria to include animal welfare considerations and update the CAS list to include and prohibit the keeping, breeding and transporting of all exotic species for permanent captivity;
  • Adopt a positive list approach, which allows only those species that meet certain evidence-based suitability criteria to be kept, bred and transported.
  • No longer allow permits to be issued for the keeping, breeding and transporting of exotic animal species, including for zoos and aquariums, film and tv industry, and research and education institutions;
  • Relocate to more appropriate facilities, animals whose physical, psychological and/or social needs are not being adequately met in captivity and/or those who are not appropriate for B.C.’s climate.
  • If no suitable alternatives exist, allow exotic species currently kept in captivity to remain, but prohibit captive breeding of exotic species.
  • Restrict captive breeding of native wildlife, unless it is part of a reintroduction program into the wild.
  • Maintain records for all individual wild and exotic captive animals in facilities, including information related to origin, import/export, breeding, births, deaths, and transport history.
  • Require emergency management plans for all wild and/or exotic animals in captivity.

Call for changes to wild & exotic animal captivity rules in B.C.

VHS has delivered a letter outlining our recommendations and has requested a meeting with the Minister. We will keep Ministry decision-makers updated on the total number of public signatures in support of the campaign.

*The petition form will only accept Canadian postal codes. If you reside outside of Canada, you can send a message directly to B.C. Minister Katrine Conroy at FLNR.Minister@gov.bc.ca

Update

VHS has been closely observing the status of animals at the Greater Vancouver Zoo and the Vancouver Aquarium. Investigation of both facilities revealed animals in small, barren enclosures and animals exhibiting abnormal behaviours. We have reported this footage to the BC SPCA and a cruelty investigation has been opened.

View the full footage reported to the BC SPCA.

Learn more about exotic, wild animal captivity and help raise awareness

Scroll through the infographics below to learn more about the issues facing captive wild animals. Click the images to save and share them on social media, or scroll down the page for key messages to share on Twitter.

Wild, exotic animals have no place in B.C. zoos. I support @vanhumane’s suggested restrictions to animal captivity.
I signed the petition to protect wild, exotic animals from suffering in captivity! Will you join me?
B.C.’s Controlled Alien Species regulation has not been updated since 2009 and is overdue for an update. Sign the petition to call for changes!

B.C.’s outdated regulations

There are loopholes in the law when it comes to keeping exotic animals. While B.C. has regulations related to the possession, transportation and breeding of exotic animals (wild animals not native to B.C.), the “Controlled Alien Species” (CAS) regulation prohibits only species that pose the greatest threat to public health and safety and does not consider animal welfare or a species’ suitability for captivity. This leaves out many exotic species, such as kangaroos and zebras, who are not subject to the CAS regulation.

The international trade of animals also increases the risk of disease spread. One in four emerging diseases is zoonotic; many of the most serious illnesses of our lifetimes have originated in animals, including COVID-19.

In B.C., zoos and aquariums, industries using animals for research, and the TV and film industry can get permits to keep dangerous exotic animals through provincial laws regulating the trade of exotic animals. These Controlled Alien Species permits lead to frequent trade of exotic animals and end up resulting in at best, boredom and repetitive behaviours, and at worst, physical suffering and early death.

The province has not significantly updated the CAS regulation since its passing in 2009 and it is overdue for an update.

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Have your say on proposed hunting & trapping regulations in B.C.

The B.C. government is seeking public feedback on a long list of suggested changes to hunting and trapping regulations. Now is your chance to see proposed changes in your area and across B.C. and speak up for wildlife. Their website is open for comments until January 23, 2022 at midnight.

Potential changes include:

  • A ban on the use of trail cameras for hunting
  • A ban on feeding or baiting ungulates such as deer near human dwellings to prevent human-wildlife conflict
  • Expansions and additions of no hunting and no shooting areas

How to register & comment

To participate through the government’s engagement website, you’ll need a Basic BCeID account.

  1. If you don’t have a BCeID account, register for a “Basic BCeID” account online. If you have a BCeID account and have not logged in for a while, you may need to reset your password.
  2. Go to the “Hunting” page and click “Login”.
  3. If you are prompted to complete your registration, fill out the required fields and submit the form.
  4. Once you’ve logged in, it will return you to the main “Hunting” page.
  5. You can now scroll through the proposed regulations and click or tap each regulation title to comment.

Note: You must be logged in and select one of the three cells (“Support”, “Neutral”, “Oppose”) under “Level of Support” to comment.

Some regulation changes to consider commenting on:

TitleProposed “Level of Support”
Wireless Trail CamerasSupport
Black Bear No Hunting Area Within the Primary Range of Kermode BearsSupport
Squamish River Valley No Shooting AreaSupport
Prohibit Feeding of Ungulates Within 200m of a Dwelling HouseSupport
No Hunting Zone – Highway 3 – Loop Bridge to Alexander BridgeSupport
Compulsory Inspection for Black BearSupport
Woodhus Slough No Hunting AreaSupport
Close Pink Mountain Caribou General Open Season (Bow Only) and Limited Entry Hunting OpportunitiesSupport
Minimum Distance Between Exposed Bait and TrapsSupport
Compulsory Inspection for Bobcat and Lynx in the OkanaganSupport
Mayne Island – HuntingNeutral
*3 options are suggested. Be sure to comment and indicate your preferred solution.
Rescind Downie Creek Motor Vehicle for Hunting Closed Area RegulationOppose

Trouble logging in?

If you have difficulty obtaining a BCeID, please make your concerns known to the Honourable Katrine Conroy directly at FLNR.Minister@gov.bc.ca.

A community-led initiative is available to support residents in participating in this feedback process. For further information, please email friendsofpublicsafety@gmail.com.

Thank you for taking the time to share your feedback on policies that impact wildlife.

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News/Blog

BC: end unnecessary owl deaths

VHS and BC residents call for comprehensive rodenticide ban

Following a public campaign gathering B.C. resident signatures in support of a comprehensive rodenticide ban, the Vancouver Humane Society has submitted a letter to provincial decision-makers and reported on public support for the campaign. This document contains scientific evidence for improving regulations of rodenticides. At the time of submission, 2582 B.C. residents signed on in support of the campaign and its recommendations for a full ban. This letter is a direct response to B.C.’s update to its Rodenticide Action Plan.

You can read the briefing note by clicking the button below or scrolling down this page.

January 5, 2022

Integrated Pest Management & Bonding Team
PO Box 9341 Stn Prov Govt
Victoria BC
V8W 9M1
ENV.mail@gov.bc.ca

Discussion & Recommendations for Rodenticide Action Plan (RAP)

Summary of recommendations

  • Scientific evidence demonstrates significant negative impacts on wildlife, particularly raptors and owls, due to all rodenticides.
  • Effective and sustainable alternative solutions exist to address human-rodent conflicts, including high quality snap traps, captive bolt traps, rodent contraceptives, and exclusion and preventative measures.
  • The current temporary, partial ban is unenforceable and it’s impossible for the public to identify non-compliance. The exemptions will continue to result in significant animal suffering and wildlife losses.
  • Following the current 18-month ban, 2582 B.C. residents support a comprehensive ban on all rodenticides and a significant decrease in exemptions, which have been shown to threaten wildlife.

Introduction

The Vancouver Humane Society (VHS) is a registered charity dedicated to the humane treatment of animals. The VHS advocates for humane wildlife management practices and, as such, supports an end to the use of inhumane and indiscriminate rodenticides, in favour of humane alternatives and preventative measures that address the root cause of human-rodent conflict. 

Background

Rodenticide use

The use of rodent poisons has become a primary approach for managing unwanted rodent populations. In British Columbia, the quantity of rodenticide products sold increased from 62,233 kg in 2010 to 81,340 kg sold in 2015.[i] Despite suggestions that rodenticides are intended to be a temporary, last resort, it appears that in practice these products are used much more routinely, at times even proactively and permanently.[ii]

There is no evidence that indicates the permanent use of rodenticides is the most effective method for reducing rodent populations. In fact, the regular use of rodenticides has resulted in resistance among rodent populations to some poisons.[iii]

Negative impacts of rodenticides

The impact of rodenticides not only on target species, but also on non-target wildlife, pets, and the environment is a growing public concern. By design, rodenticide baits aim to attract animals, creating a risk for primary poisoning of wildlife and pets, should they access the bait directly. Secondary poisoning of non-target species that may consume poisoned rodents, such as coyotes, raccoons, hawks, eagles and owls, is also a major concern. Data has shown that residues of anticoagulant rodenticides have been found in all tested species of raptors that inhabit agricultural landscapes in southwestern British Columbia, reflecting the widespread impacts of secondary poisoning among predators and scavengers.[iv] In addition to this, B.C.-based Orphaned Wildlife Rehabilitation Society (OWL) noted that a few years ago a blood test study found that more than half of the animals in their care had poison residue in their system.[v]

There are also concerns surrounding the bioaccumulation of rodenticides across a variety of species and the impact of these poisons on the larger environment. Evidence of contamination among insects, slugs, and songbirds reflect how these poisons may move through the food chain.[vi] Meanwhile, the prevalence of these toxins in the environment, along with the decomposing remains of poisoned animals, may also contribute to contamination of soil and water.[vii]

Rodenticides contribute to significant and prolonged suffering for target and non-target species, taking days and sometimes even weeks for poisoned animals to die.[viii] For animals that don’t die, the effects of sub-lethal rodenticide poisoning, including lethargy and internal bleeding, may put them at increased risk of injury or death due to other causes, such as window and vehicle strikes. For example, a sub-lethal dose of anticoagulant rodenticides, which prevents blood clotting, in an owl could mean an injury causing an otherwise survivable cut could lead to the animal bleeding to death.[ix] Research also suggests that rats that experience external bleeding or bloody diarrhea, as a result of consuming anticoagulants, present a public health risk as contact with their blood can increase the chance of pathogen transmission to humans.[x]

Current situation

Municipal & provincial bans

While recent action by a growing number of B.C. municipalities to restrict or ban rodenticides on city property, along with the provincial government’s temporary, partial ban on second generation anticoagulant rodenticides are important first steps, further action is needed to effectively address the widespread use and impacts of rodenticide products.

Other rodenticides

B.C.’s temporary 18-month ban prohibits only second-generation anticoagulant rodenticides (SGARs), leaving first-generation anticoagulants (FGARs) and other rodenticides permitted for use. Many of these products not included in the ban, such as bromethalin, zinc phosphide, chlorophacinone, diphacinone, and warfarin, are also inhumane and pose the above mentioned threats to wildlife, pets and the environment. Diphacinone and chlorophacinone, for example, are high risk for secondary poisoning for wild mammals, dogs and cats.[xi] Concerns have also been raised by veterinarians in regards to secondary poisoning by bromethalin, a neurotoxin that targets the central nervous system and causes paralysis and convulsions, as there is no specific antidote.[xii] Another non-anticoagulant, zinc phosphide, produces a toxic gas in the animal’s body, leading to respiratory distress. Warfarin has been so widely used that rodents are becoming increasingly resistant to it, yet its use continues to harm non-target wildlife.[xiii] In practice, pest control companies can simply replace the now-banned SGAR products with these other types of rodenticides.

Exemptions

The current temporary ban also permits the continued use of SGARs by a long list of exempt users, including agricultural operators, hospitals, gas stations, food processing and storage facilities, restaurants, grocery stores, convenience stores, transportation facilities, sanitation facilities, coroners and facilities performing mortuary services.[xiv] Given the lengthy list of exemptions, it’s inevitable that the use of these products will continue to result in direct and indirect poisoning of wildlife, pets, as well as negative impacts on our food systems that would benefit from more research. The current list of exemptions is based on the Covid-19 essential services list, raising questions about the list’s applicability to a very different issue of rodenticides and the government’s justifications for allowing the continued use of SGARs in each of these situations. For example, allowing the continued use of SGARs in locations where wildlife activity is common, such as at garbage dumps or recycling facilities, is especially problematic in terms of the strong likelihood of poisoning of non-target wildlife.

Issues of non-compliance & lack of transparency

Non-compliance with the current SGAR ban is an area of concern, as evidence of suspected SGAR use in prohibited locations continues to be found and reported by members of the public. In a number of these situations, upon the public reporting bait boxes labeled as containing SGARs in prohibited locations, the Ministry has responded that the bait boxes were mislabeled and did not contain SGARs. This was the case in a recent report of a SGAR bait box at the Ministry of Environment’s office in Victoria.[xv] The mislabeling of these bait boxes fails to align with the Integrated Pest Management regulations, which require labeling indicating the pesticide’s active ingredient or its registration number under the federal Act.[xvi] This raises questions about overall compliance with and enforcement of the regulations and the recent ban. It also creates issues around transparency, as the public cannot be certain as to whether or not poisons (and prohibited poisons specifically) are in use in their community. 

Enforcement of ban and Integrated Pest Management (IPM)

The provincial government also requires that rodenticides only be used after following the principles of “Integrated Pest Management” (IPM). Specifically, IPM requires that preventative measures to address rodent attractants and structural flaws are implemented and that rodenticides are a last resort and temporary treatment, with other sustainable long-term strategies prioritized.[xvii] It is unclear how IPM is tracked and enforced to ensure the use of alternative approaches are exhausted before resorting to rodenticides, but the outcome of a series of inspections by provincial IPM officers in 2019 raises cause for concern. A total of 311 inspections were conducted, which found that only 39% were in compliance.[xviii]

In public education webinars hosted by Ministry staff outlining the temporary ban, it was noted that SGAR users must keep records about rodenticide use and IPM measures implemented, but these records are not required to be submitted to government.[xix] Without strong government oversight and proactive enforcement of the ban and IPM requirements related to preventative measures and rodenticide use, industry compliance will largely be based on the honour system and there will be a heavy reliance on the public to identify suspected violations. As previously noted, with the allowances given by government regarding labelling (e.g. mislabeled or label inside box) it’s not possible for the public to identify where prohibited poisons are in use.

Alternative approaches & products

The expansion of humane alternative products and approaches in recent years presents an opportunity for government to shift from rodenticide use and to prioritize further research and trials around innovative and sustainable alternatives. Alternative products for rodent control or lethal management, when necessary, range from high-quality snap traps; captive bolt traps and other mechanical systems (e.g. Goodnature device); rodent contraceptives (e.g. Contrapest); remote monitoring technology; and measures to support the presence of natural rodent predators, such as owls, through building owl boxes. Natural predators can help keep rodent populations in check, with evidence suggesting that a family of owls can consume more than 1,000 rodents per year.[xx] It’s worth reiterating that the use of rodenticides reduces natural rodent control through secondary poisoning of owls and other predators.

Some initial research surrounding the Goodnature A24 rat and mouse trap has been conducted, including recently in North Vancouver and at the University of British Columbia. The evidence suggests the Goodnature trap is more cost-effective than rodenticides and it eliminates the risk of poisoning of other animals and the environment. [xxi] [xxii]

Humane Solutions, a B.C.-based wildlife management and pest control company, reports strong success with their poison-free approach to dealing with rodent conflict, including in high-attractant scenarios, such as in agricultural, industrial and commercial settings. Their approach focusses on resolving attractants, structural flaws and access points. Structural removal includes the use of one-way doors that allow rodents to leave the structure and prevents them from re-entering. Rodent-proofing can include addressing gaps in foundations, venting, and utility lines. In high-attractant locations, further rodent-proofing steps can be taken inside of buildings to reduce human-rodent conflict. For example, in a feed store this may involve keeping feed in rodent-proof containers. If lethal management is justified, it is conducted through the use of high quality snap traps enclosed in containers to exclude non-target species. The company says that their poison-free approach is scale-able and adaptable to a variety of settings, ranging from households to large institutions. For example, Humane Solutions reports successfully working with Langara College to become rodenticide-free in their operations.[xxiii]

Ultimately, the best long-term approach for addressing human-rodent conflicts is exclusion and preventative measures. This includes removing attractants, such as open garbage, compost bins, fallen fruit or bird seed, and leaking plumbing. It also involves fixing and rodent-proofing structural flaws and access points in buildings, as these provide sources of shelter for rodents. Habitat modification and sanitation, such as cutting back dense vegetation and tall grass from along the perimeter of buildings and storing firewood and other materials away from buildings and off the ground, can also reduce the presence of rodents by making the immediate environment around a location less desirable to them. [xxiv] [xxv]

Conclusion & Recommendations

The humane treatment of animals is a central value of Canadian society and it’s crucial that this value be reflected in the many ways we as a society interact with animals, ranging from those we label as “pets” and others we label as “pests”. Regardless of the labels assigned to them, commensal rodents share the same capacity to suffer as other vertebrates and therefore the same humaneness considerations should apply in how they are managed.[xxvi] Likewise, the continued use of poisons threatens the balance of our ecosystem with raptors and owls suffering significant losses in B.C. each year.

The VHS suggests that the continued use of rodenticides presents significant animal welfare, conservation and environmental concerns. The growing body of data and public awareness around the issues associated with rodenticides, along with the expansion of humane alternative approaches and products requires that more be done to urgently move away from these indiscriminate and inhumane poisons.

Specifically, the VHS recommends a comprehensive and permanent rodenticide ban, including first and second generation anticoagulants and non-anticoagulant rodenticides. It’s also recommended that the lengthy list of current exemptions under the temporary ban, which is based on the Covid-19 essential services list, be re-evaluated for appropriateness and applicability to the issue of rodenticides. It’s also crucial that government prioritize enforcement of the current temporary ban. Ultimately, the VHS believes that the issues surrounding compliance with IPM practices and the current ban reflect the difficulty in enforcing a partial rodenticide ban. The VHS recommends that the remainder of the temporary ban timeframe be spent prioritizing research around innovating and sustainable alternatives and planning a transition away from rodenticides, in favour of approaches that address the underlying causes of human-rodent conflict.

The recommendations outlined in this submission are supported by 2582 B.C. residents that have signed on to a statement which asks the provincial government to implement these recommendations.[xxvii]

References


[i] https://www2.gov.bc.ca/gov/content/environment/pesticides-pest-management/publications-guides/pesticide-use-surveys

[ii]http://www.barnowlsbc.ca/uploads/3/0/2/7/30276721/rats_what_triggers_us_to_control_for_rodents_rodenticide_user_survey_in_british_columbia_canada_hindmarch_et_al._2018.pdf

[iii]http://www.barnowlsbc.ca/uploads/3/0/2/7/30276721/rats_what_triggers_us_to_control_for_rodents_rodenticide_user_survey_in_british_columbia_canada_hindmarch_et_al._2018.pdf

[iv]http://www.barnowlsbc.ca/uploads/3/0/2/7/30276721/rats_what_triggers_us_to_control_for_rodents_rodenticide_user_survey_in_british_columbia_canada_hindmarch_et_al._2018.pdf

[v] https://www.surreynowleader.com/news/south-surrey-resident-sounds-alarm-after-neighbourhood-owl-dies-from-eating-rat-poison/

[vi]http://www.barnowlsbc.ca/uploads/3/0/2/7/30276721/rats_what_triggers_us_to_control_for_rodents_rodenticide_user_survey_in_british_columbia_canada_hindmarch_et_al._2018.pdf

[vii] https://pubmed.ncbi.nlm.nih.gov/25965004/

[viii] https://www.epa.gov/rodenticides/restrictions-rodenticide-products

[ix] https://thetyee.ca/News/2010/12/13/BarnOwls/

[x] https://www.tandfonline.com/doi/full/10.1080/23311932.2018.1525147

[xi] http://npic.orst.edu/factsheets/rodenticides.html

[xii] https://www.aspcapro.org/resource/treating-bromethalin-toxicosis

[xiii] https://animalkind.ca/wp-content/uploads/AnimalKind-Wildlife-Control-Standards.pdf

[xiv] https://www2.gov.bc.ca/gov/content/environment/pesticides-pest-management/legislation-consultation/rodenticide-ban#essential_services

[xv] https://www.saanichnews.com/news/saanich-owl-advocate-calls-for-permanent-rodenticide-ban-after-collecting-another-dead-bird/

[xvi] https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/604_2004#section81

[xvii] https://www2.gov.bc.ca/gov/content/environment/pesticides-pest-management/legislation-consultation/rodenticide-ban#user_resources

[xviii] https://spca.bc.ca/ways-to-help/take-action/safe-from-poison/

[xix] https://www.youtube.com/watch?v=yAKUdiaeJ4s&t=1435s

[xx] https://canadianraptorconservancy.com/barn-owls/

[xxi] https://open.library.ubc.ca/soa/cIRcle/collections/ubctheses/24/items/1.0401883

[xxii] https://drive.google.com/file/d/15ZnK6b9INxAiZAXyKdEk-53BSu7oDQSH/view

[xxiii] Personal communication with Humane Solutions, 2021.

[xxiv] https://drive.google.com/file/d/15ZnK6b9INxAiZAXyKdEk-53BSu7oDQSH/view

[xxv] https://www2.gov.bc.ca/gov/content/environment/pesticides-pest-management/managing-pests/animals/rodents#prevent

[xxvi] https://animalkind.ca/wp-content/uploads/AnimalKind-Wildlife-Control-Standards.pdf

[xxvii] https://vancouverhumanesociety.bc.ca/posts/rodenticide-ban/

Categories
News/Blog

Take action: Identify & report the use of banned rodenticides

Effective July 2021, the B.C. government enacted a temporary, partial ban on second-generation anticoagulant rodenticides (SGARs). These poisons have been used widely in rodent control and they cause significant suffering for wildlife and pets.

You can help protect animals from these banned poisons by being on the look out for them in your community and reporting them to provincial authorities and to VHS, so we can keep track of the presence of banned poisons throughout communities.

Learn more below about how to identify and report banned rodenticides. Visit this page to call for further action from the provincial government.

How to report banned rodent poisons in B.C.

Effective July 2021, the B.C. government enacted a temporary, partial ban on second-generation anticoagulant rodenticides (SGARs). These poisons have been us…

Which rodenticides are banned?

The ban applies to the following second-generation anticoagulant rodenticides (SGARs):

  • Brodifacoum
  • Bromadiolone
  • Difethialone

Under the ban, these poisons are now prohibited in or around most residential buildings, offices, parks, schools, and non-food retail shops.

There are exemptions that allow for SGARs to continue being used in certain locations that are deemed to be “essential services”. For a complete list of exemptions, visit the B.C. government’s website.

Tips for documenting banned rodenticides

Be on the lookout for bait boxes, often found around the outside perimeter of buildings, as well as inside of buildings. If the bait box contains a rodenticide, a label identifying the active ingredient or its registration number, along with the contact information for the pest control company, should be on the outside of the container lid.

Note: The presence of a bait box does not necessarily mean SGAR poisons are being used, as bait boxes may contain snap traps or other products.

If the active ingredient noted on the label is brodifacoum, bromadiolone, or difethialone and the bait box is not in a location that is exempt from the ban, please document the following in order to file a report: (Note – Do not tamper with bait boxes.)

  • Photos of the outside of the bait box;
  • Photos of the label on the bait box;
  • Photos of the surrounding location;
  • Note the date, time and address.

How you can report banned rodenticides

STEP 1: Report the suspected banned poison to the B.C. government via the “Report All Poachers and Polluters” (RAPP) hotline at 1-877-952-7277 (RAPP) or #7277, or through the online reporting form.

STEP 2: Submit a report, using the form below, for VHS’s prohibited rodent poison tracking project.

STEP 3: Upload photos (see section below form) to go with your report for VHS’s tracking project.

Click or drag files to this area to upload. You can upload up to 5 files.
Categories
Opinion Editorial

Discovery of dead wildlife demands further action on rodent poisons

Article originally published on Daily Hive.

Take action

Support a full ban on rodenticides in B.C.!

Earlier this year, wildlife protection advocates in BC cautiously celebrated news of a partial ban on second-generation anticoagulant rodenticides. Anticoagulant rodenticides cause a slow and painful death through internal bleeding for the animals that ingest them. The BC government cited the serious risks these highly toxic poisons pose to the public, pets and wildlife, and specifically banned – with many exemptions – types of poisons that are more potent to rats and wildlife alike.

As reports of dead and dying wildlife from suspected rodenticide poisoning have circulated in news headlines in recent years, the issue has gained much-needed attention and calls for a rodenticide ban have grown.

While the government’s announcement was a welcome first step, it has become increasingly evident that much more needs to be done to effectively address the widespread use of all inhumane and indiscriminate poisons, both first- and second-generation. The ban itself is incomplete, leaving a wide range of exemptions wherein second-generation poisons can continue to be used. It also leaves out other cruel and dangerous rodenticides, such as first-generation and non-anticoagulants.

Gaps in government ban leave wildlife at risk

First-generation rodenticides are called this because they have been used for many years and have begun to lose their effectiveness on rodents, while still having a negative impact if another animal eats a poisoned rat or mouse. This is called secondary poisoning. For example, two common first-generation anticoagulants, diphacinone and chlorophacinone, pose a high risk for secondary poisoning of wild mammals, cats and dogs. Veterinarians have also raised concerns about bromethalin, a neurotoxin with no specific antidote, yet its use as a rodenticide is still permitted.

At the time the partial ban was enacted, the province indicated that pest control operators would be informed about the new rules to ensure compliance. Yet, months later, the public continues to find bait boxes labeled as containing second-generation rodenticides in locations where they are prohibited, such as along the outside of residential buildings and offices.

Dead owl found outside Ministry of Environment building

Concern about the apparent lack of enforcement and compliance surrounding the ban turned to frustration when a dead great horned owl was found earlier this month near the Ministry of Environment building in Victoria. A closer look around the exterior of the building by a local wildlife protection advocate led to the discovery of rodent bait boxes with labelling that indicated they contained the poison bromadiolone – a second-generation poison in a location that would appear to be in violation of the ban. While the ministry has since responded, saying that an investigation determined that the labels on the bait boxes were incorrect and that they did not contain bromadiolone, the incident illustrates the issues surrounding the partial ban. How can the public be sure that bait boxes they encounter in their community are accurately labeled and in compliance with the partial ban?

Take action

Support a full ban on rodenticides in B.C.!

Number of dead owls remains unchanged despite partial rodenticide ban, says local wildlife rehabilitation organization

Meanwhile, owls and other birds of prey that commonly fall victim to rodenticides continue to show up at rehabilitation centres, raising concern that the partial ban may not be leading to intended changes for animals. BC-based OWL (Orphaned Wildlife) Rehabilitation Society has said that the number of owls that have died since the ban remains unchanged. A few years ago, a blood test study found that more than half of the animals in OWL’s care had poison residue in their system.

To effectively address and curtail rodenticide use, the provincial government must proactively enforce its current, partial ban on second-generation rodenticides. Additionally, as the government currently considers next steps regarding this issue, it is crucial that the lengthy list of exemptions be revisited and that the government ultimately phase out all types of rodenticides, in favour of humane alternatives and preventative measures that address the root causes of human-rodent conflict.

Poison-free alternatives offer a long-term solution

Addressing attractants, such as open garbage, compost bins, fallen fruit or bird seed, and fixing structural flaws and access points in buildings that provide sources of food and shelter for rodents is central to solving human-rodent conflicts. Meanwhile, a variety of poison-free alternatives for lethal management are available and new and innovative technologies are being tested and piloted in communities. Alternatives range from snap traps, to captive bolt traps, rodent contraceptives, and owl boxes that support the presence of natural predators – a family of owls can consume more than 1,000 rodents per year!

As awareness has grown surrounding the threats rodenticides pose and the suffering they cause, we can and must do better.

Take action

Support a full ban on rodenticides in B.C.!

Categories
News/Blog

Fireworks create more stress than joy

A brief moment of joy for some

Unintended consquences for others

Most kids have a story about the first time they got their hands on fireworks, including VHS’ recently retired Peter Fricker, who accessed some pretty dangerous fireworks when he was growing up!

While fireworks may be tempting for a moment of joy, they have some intense and devastating consequences. You may remember the 2016 case of Maggie, a 10-year-old pup who was off-leash at the unfenced Trout Lake dog park during the afternoon when someone set off fireworks. Suddenly, Maggie was running, not sure where to go for safety. Tragically, she was killed by a skytrain.

Her story is not unique. Walking down the street one Vancouver Halloween, I witnessed a coyote running full speed, terrified of the sounds. Wildlife centres receive many calls on days with fireworks about animals that are anxious and disoriented and they report that wildlife often show signs of distress for days afterward.

There is an answer: Banff was the first Canadian city to recognize these impacts and produce a sound-free fireworks display, and Canmore has followed suit.

In Maple Ridge, B.C., it is illegal to set off fireworks without a permit.

The City of Vancouver, B.C., also has a consumer fireworks ban in place and so does the City of North Vancouver.

There are three ways to prevent the suffering of animals from fireworks:

1. Write to your municipal council.

Write to your local municipal council and ask them to put a ban in place for the sale and use of fireworks by private citizens. The District of North Vancouver is currently considering such a ban. Residents can contact City Council in support of a consumer fireworks ban.

2. Sign the federal petition.

Sign the federal e-petition, which calls on the Canadian goverment to explore legislative changes around the use of fireworks. The petition is open until February 25, 2022, at 10:45 a.m. PST.

3. Share this infographic!

Without public education, people will continue to seek illegal means to access fireworks even in areas with bans in place. The infographic demonstrates how one small change can help create a community that cares for everyone who belongs in it, be they feathered, furry or human.

Categories
News/Blog

B.C. government asking for approval to kill wolves

The B.C. government is seeking a five-year approval for a continued wolf cull program, which if granted would total 12 years of killing wolves in a bid to recover caribou herds decimated by habitat destruction. Since the B.C. government started killing wolves in 2015, 1,429 wolf lives were taken by aerial weapon use.

Scientists confirm there is no statistical support for this measure and that the study used to support this policy is flawed.

The government survey is running until November 15. You can take the short survey here: https://engage.gov.bc.ca/caribou/feedback-form/

Credit: We Animals

Tips on filling out the survey

For tips on filling out the survey, consider the following suggested responses to support humane conservation efforts:

PageQuestionSuggested response
1N/AReview as desired, scroll to bottom, click “Take the survey
2N/AReview as desired, scroll to bottom, click “Next”
31. Since the 1990s, B.C.’s caribou population has declined from 40,000 to approximately 15,000. What do you consider to be the three greatest causes of this population decline?Responses related to habitat destruction and urbanization
2. How important is the recovery of caribou in B.C. to you?“Very important”
3. Why is caribou recovery important to you?Respond as relevant
41. Do you spend time in areas where predator reduction for caribou recovery is being considered?Respond as relevant
2. Are you aware of the reasons the Province of B.C. states for the need to reduce predators to recover caribou?“Yes”
3. Do you agree predator reduction is a necessary action for caribou recovery?“Strongly disagree”
3a. If you disagree with predator reduction for caribou recovery, please tell us why?“It is inhumane”; “Other” responses can indicate there is no statistical support for this measure
4. Are there any herds that you feel should be added to or removed from predator reduction for caribou recovery?Respond as relevant
5. What other caribou recovery actions do you feel are important to implement?Responses indicating habitat related actions first, and conservation breeding/maternal penning/predator reduction last
All remaining questionsRespond as relevant & complete the survey

Thank you for taking the time to speak up for wolves!