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Help Ban Cruel Rodenticides in BC

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Guide to Submitting Public Comments on the Proposed Changes to the Integrated Pest Management Regulation RE: Use of second-generation anticoagulant rodenticides (SGARs)

Animal advocates currently have an opportunity to help mice, rats, and other wild animals in British Columbia. The provincial government is considering restricting or ending the use of some cruel poisons used to kill rodents and other wildlife.

Rodenticides, such as second-generation anticoagulant rodenticides (SGARs), are the most common poison used to kill off rats and mice. They work by causing severe internal bleeding, which is slow and painful. These poisons are typically placed as bait in an enclosed area that’s easy for rodents to get into. But rodents aren’t the only victims—other animals, including cats and dogs, can also be poisoned if they can access and ingest the bait themselves, or by consuming rodents killed by poison. 

The proposed changes in British Columbia aim to address risks that SGARs pose to wildlife by minimizing unnecessary use and reducing accidental exposure. However, this proposal ignores the impact on rodents themselves. Rats and mice are smart, sensitive creatures who are highly altruistic towards others of their species, and do not deserve the pain and horrifying deaths they endure when poisoned. Animal Justice is concerned that the proposed changes overlook this, and provide too many exceptions so that these poisons can still be used. Help us put these concerns on the agenda and remind the government that the Canadian public cares about all animals, including rodents and wildlife.

To share your feedback, comment on the proposed changes by June 19, 2022. Below you will find a summary of important issues to raise. Please note this list is not exhaustive. Simply visit the survey link above, and you will be taken through a series of questions that match up with the information we have provided below. 

If you can, please submit your comments in your own words. This has a much greater impact than copying and pasting the text below. Identical responses are easier for the government to ignore and dismiss. 

If you would like to learn more about the issues, you can read the current Integrated Pest Management Regulation, and an “Intentions Paper” that was released by the government explaining a review of the Regulation. This includes a scientific review, regulatory gap analysis, and a survey of how SGARs are regulated in other jurisdictions. 

General Comments on the Proposed Changes to the Regulation

  • The proposed changes completely ignore the pain and suffering SGARs cause to rodents. They are smart and sensitive living, feeling beings. 
  • There are alternative, effective means of rodent control that do not cause such immense suffering. 
  • The list of exemptions is far too broad, encompassing almost everything. 
  • Without preventing future access to important structures SGAR use alone will not solve a rodent infestation. It’s important to prevent rodents from getting into a building in the first place.

Q1: Exemptions for Essential Services (Sections 5.1, 5.2 and Appendix 1)

Demand that the proposed exemption list be refined. 

  • SGARs cause animals, including rodents and wildlife, to slowly bleed to death after ingesting the poison. 
  • The proposed changes currently allow certified users to continue to use SGARs for “essential services”, found in Appendix A, which defines essential services as: Health and Health Services, Public Safety, Critical Infrastructure, Food Supply and Agricultural Production, Transportation, Sanitation, Communications, Coroners and those Performing Mortuary Services, Government-Approved Environmental Protection Activities. This list is very broad, covering almost everything other than residential homes. See page 12 of the Intentions Paper for a complete list.
  • Many of these exemptions are unnecessary and may be misused.

Q2: Integrated Pest Management (IPM) focused on prevention and alternative control methods required (Section 5.3)

Call for specific IPM requirements prior to allowing SGAR use.

  • Rodents are creatures of habit. They typically use the same areas for food and shelter. Without preventing future access to structures and removing shelter/food, rodents will return after SGARs have been used. 
  • The proposed changes would prohibit preventative baiting, meaning there won’t be traps laying around when they aren’t needed.
  • The proposed changes don’t set clear requirements regarding how long alternative rodent control methods must be attempted before an IPM practioner could resort to using SGARs, nor do they define what level of activity constitutes an “infestation”. This could lead to increases in pre-emptive use, and misuse. 
  • Requirements should be as defined as possible to ensure that they are easily understood.

Q3: Site specific IPM Plans required where SGARs are used (Section 5.3)

Call for stricter oversight. 

  • The proposed changes require that IPM practitioners keep detailed records of their prevention efforts prior to SGAR use. 
  • The proposed changes don’t set clear requirements surrounding how long alternative control methods need to be attempted.
  • The proposed changes don’t set clear guidelines surrounding ministerial oversight. Just that the information should be “available upon request”. 
  • Requirements should be as defined as possible to ensure that they are easily understood.

Q4: Section 5.6 – Prohibit long-term SGAR use/baiting 

Call for shorter timeframes of allowable SGAR baiting.  

  • The proposed changes define short-term baiting as less than 35 consecutive days and not exceeding 120 days within a 12-month period and suggest that the focus should shift to alternative control measures after the first 35 days. SGARs could be used by an essential service for up to 4 months per year. 
  • SGAR baiting under this threshold can be effective. 
  • The proposed change does not provide guidelines for how much time must elapse between baiting attempts.
  • Failing to define these requirements may lead to prolonged and unnecessary uses. 

Q5: Critical Wildlife Habitats (Section 5.7) 

Demand a more expansive definition of critical wildlife habitats.

  • The proposed changes define a critical wildlife habitat as “a wildlife sanctuary, an ecological reserve, a bird sanctuary, or other established wildlife protection areas”.
  • The Regulation defines a critical wildlife area as those designated under section 5 of the Wildlife Act; specifically, land the minister requires “for habitat of a species of wildlife designated as an endangered species or threatened species, the minister may, by regulation, designate land in a wildlife management area as a critical wildlife area” or land which the minister has designated as a wildlife sanctuary. 
  • These definitions should be as expansive as possible and include all facilitates that may be of relevance. For example, zoos, Provincial and National Parks, conservation areas, wildlife rehabilitation centres, etc. 
  • There should not be an exemption for authorized government-approved conservation projects. Any risk of unintended exposure to SGARs in these areas is unacceptable. 

Q6: How could the proposed requirements affect critical operations for Essential Services defined in the Intentions Paper?

Call for strict oversight of IPM requirements, including where critical operations are concerned.

  • A critical operation is one that is “negatively affected by restricting the use of SGARs”. Drafters considered human health, environmental protection, and ensuring the stable supply of necessary items in creating the essential service list contained in Appendix A.
  • The proposed changes require that essential services develop and implement an integrated pest management (IPM) program which emphasizes the need for prevention methods prior to allowing SGAR use. Alternative methods of pest control must be used preceding and following SGAR use (Section 5.3). 
  • Preventative baiting would not be permitted under any circumstances (Section 5.3). 
  • All users must document and demonstrate rodent activity, including the species, its behaviours, population levels, and make attempts to remove sources of food, shelter, and access points prior to SGAR use. The documentation must include prevention methods that have been tried and their relative success. All records must be available to the minister upon request (Section 5.3). 
  • All IPM practitioners must hold the appropriate pesticide applicator certificate to be able to purchase and/or use SGARs for essential services (Section 5.4)
  • For an essential service to use or hire someone to use SGARs on their property, they must hold a valid authorization licence issued under the Act at a cost of $250 per year for application up to 50 hectares (Section 5.5). They are still required to develop an IPM plan, keep records and submit an annual usage report to the ministry. 
  • Long-term use (more than 35 consecutive days, or more than 120 days per year) is not permitted (Section 5.6). 
  • SGAR use is not permitted in critical wildlife habitats, unless for an authorized government-approved conservation project (Section 5.7). 
  • All SGARs must be properly labelled when in use and cleaned up/disposed of in a timely manner, at approved facilities. This includes the dead rodents (Section 5.8). 

Q7: Proposed SGAR Regulation for agricultural operators

  • The proposed regulations consider agricultural operators to be an essential service thereby exempting them from the total ban if they meet all other requirements of the regulation (i.e., have an IPM plan, and meet all requirements).
  • In addition to the requirements imposed on essential services, agricultural operators will have to ensure that pesticide drift and/or runoff doesn’t enter the watershed or cross property boundaries and keep detailed pesticide application records. 
  • This may be difficult to control in practice. There should be detailed parameters of how close poisons can be to watersheds, and measures to prevent SGAR use in fields to avoid accidental ingestion.

Q8: Proposed sales restrictions and vendor requirements for the access and purchase of SGARs (Section 5.9) 

Demand greater government oversight rather than enhanced vendor requirements.

  • The proposed changes would restrict access to SGARs by requiring that they be displayed in a way that customers couldn’t access them without assistance from a certified dispenser. Displays must be accompanied by ministry signage indicating risks to wildlife.
  • Pesticide vendors selling SGARs must be certified as a pesticide dispenser and will be responsible for verifying that purchasers hold a valid pesticide applicator certificate, licence, and are an essential service or licensed service provider prior to completing the purchase.
  • SGAR dispensers would be responsible for informing customers of the risks associated with wildlife and non-target animals, communicating that there are new IPM principles that must be followed before use, and new disposal and record keeping requirements that now apply. 
  • Proper regulation must involve retailers/vendors, government oversight and public pressure to ensure IPM plans are being properly implemented prior to use. Relying more heavily on one could lead to reduced efficiency.  
  • Without adequate oversight these requirements may not be implemented in practice.

Q9: Designated groups or sensitive populations 

Demand that designated groups and First Nations be adequately consulted on potential SGAR use in their areas. 

  • Species protection is essential to sustaining First Nations lifestyles and culture.
  • SGARs are known to have unintentional impacts on wildlife and other animals who accidentally ingest them and can have devastating effects if they get into the watershed. This could have profound impacts on various groups, including First Nations who rely on these animals for food as well as cultural and spiritual practices. They should be consulted on any prospect of use in or near their respective areas, including reserves and traditional hunting/fishing grounds. 

Q11: Consequential Amendments

  • Previously, all licences expired on March 31 in the calendar year following purchase regardless of the date of purchase. All licence holders had to file for renewal on or before March 31 of the following year to avoid it lapsing causing backlog in processing new licences. The proposed change would allow licences to instead expire 1 year from the date of purchase. E.g., a license purchased on August 1, 2021, would now need to be renewed by July 31, 2022. 
  • The proposed change would require that all agricultural operators ensure that pesticides do not enter waterways or cross property boundaries, and that operators keep detailed records of pesticide use. This requirement already exists under the Environmental Management Act, so would only change the Act an offender would be charged under for breaking said laws. 
  • Adjuvants are substances that can be added to pesticides to improve their performance. They are not considered pesticides on their own. The proposed change would clarify this distinction. 
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