Information Note - Regulation of Pesticides to Control Large Vertebrate Predators

Pest Management Regulatory Agency
29 January 2021

Purpose

The purpose of this information note is to provide an overview and update on the regulation of pesticides used to control large vertebrate predators (predacides) in Canada.

Federal and Provincial/Territorial roles and responsibilities

Health Canada’s Pest Management Regulatory Agency (PMRA) is responsible for the regulation of pesticides in Canada. Health Canada applies current, evidence-based scientific approaches to assess whether the health and environmental risks of pesticides proposed for registration are acceptable, and if the products have value. While Health Canada has the authority to register pesticides, municipalities and provinces have the authority to impose further restrictions on the use of these products.

Provinces and territories also have authority, on provincial lands, for natural resource management and animal welfare issues, including humaneness standards. In addition, Canadian provinces and territories have their own animal protection laws. In most provinces and territories, the local Society for the Prevention of Cruelty to Animals enforces animal protection legislation. Provinces are responsible for wildlife management, including decisions about whether to use predacides registered by Health Canada.

The need for predator control

Large predators such as wolves, coyotes and bears can pose threats to livestock, vulnerable wildlife species and people in remote communities through disease exposure or attacks. In Canada, various methods may be used to protect livestock and people from predators, such as fencing, guard dogs, and relocation of problem animals. However, these approaches do not always successfully deter predators from killing or causing harm.

Current pesticides registered for use on predators

In Canada, the three active ingredients registered to control large vertebrate predators are:

• strychnine
• sodium monofluoroacetate (Compound 1080)
• sodium cyanide

Labels for registered pesticides, including those containing these three active ingredients, can be searched and viewed through Health Canada’s online Pesticide Label Search, and through the Pesticide Labels apps, available for download through the following links:

• Pesticide Labels on the App Store: Apple
• Pesticide Labels in Apps on Google Play
• Amazon.com: Pesticide Labels: App Store for Android

In Alberta and Saskatchewan only, and as a last resort in a limited number of situations, provincially authorized personnel can use these predacides on a restricted basis to control predators.

While these predacides are effective at controlling targeted predators once baits have been consumed, the affected animals may endure a period of pain and suffering before death. These products may also pose risks to other animals through accidental exposure, either to uneaten baits or through eating a poisoned carcass.

For these reasons, and to minimize non-target exposure, the use of these products is restricted and, in the limited cases where predacides may be used, the strict use conditions on the label must be followed.

These use conditions^{Footnote 1} include:

• Not for sale and use by the general public; may only be used by authorized and trained personnel
• The predator is a threat to the safety of people or other animals (that is, species at risk or livestock)
• All other methods of managing the predator have failed
• Placement of visible signs at bait sites and entrances to areas where baits are used, to prevent accidental human or pet exposure
• Frequent inspection of bait sites during the control program
• Maintaining accurate records of use amounts, locations and dates
• Not to be used in areas where species at risk may accidentally ingest the baits
• Requirements related to placement, monitoring and disposal of carcasses and baits

Compliance with the Pest Control Product Act

Compliance and adherence with the Pest Control Products Act and Regulations, and conditions of use on the label, are required by law. Failure to do so:

• is a violation of the Pest Control Products Act
• is subject to compliance and enforcement action under the Pest Control Products Act and the Agriculture and Agri-Food Administrative Monetary Penalties Act
• is subject to compliance and enforcement action by regional compliance and enforcement officers during inspections
• may be reported by Canadians to Health Canada through the PMRA Public Engagement Portal

Incident reporting

Under the Pest Control Products Incident Reporting Regulations, registrants are required by law to report suspected incidents to Health Canada related to negative effects (adverse reactions) to humans, non-target animals or the environment that may be associated with the use of predacides. Incidents involving predacides may also be reported by Canadians to Health Canada through the PMRA Public Engagement Portal Voluntary Incident Reporting Form.

Incident reports may be used to:

• identify new health and environmental risks
• develop additional safety measures to protect health and the environment
• improve label instructions
• inform compliance and enforcement action

Re-evaluation of predacides

Health Canada is also required by law to initiate re-evaluation of all registered pest control products every 15 years. In 2021, Health Canada will be initiating a re-evaluation of predacidal uses of strychnine, sodium monofluoroacetate, and sodium cyanide. The re-evaluation process will include:

• an assessment of the available scientific information pertaining to value and the health and environmental risks of these products
• consideration of incident reports and compliance reports
• consideration of non-target death data provided to PMRA

The outcome of this re-evaluation could include continued registration with label changes, and/or further use restrictions, or cancellation of some or all uses.

For further information

• Pesticides in Canada
• Pest Management Information Service
• Alberta Wolf Response Guide
• Coyote Predation Control (Alberta)
• Predation Management Fact Sheet at the Saskatchewan Sheep Development Board