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Indiscriminate, Inhumane and Irresponsible: Compound 1080 Is No Longer an Acceptable Form of Wildlife Management

May 2021

Authors:

Sadie Parr

Wolf to Willow Wildlife Services

Hannah R. Barron

Wolf Awareness

Canada’s mammalian and avian predators and scavengers are at risk of exposure to the inhumane and deadly Compound 1080 (sodium monofluoroacetate), a poison authorized by Health Canada’s Pest Management Regulatory Agency to kill wolves (Canis lupus) and coyotes (Canis latrans) under the following circumstances: i) following instances of livestock predation; ii) where predation has been identified as the primary factor affecting survival of a specific wildlife population, or iii) where a serious threat to human safety exists. Misrepresentation of Compound 1080 as being a canid-selective or even canid-specific toxicant, in addition to victim dispersal due to delayed presentation of clinical signs, has led to an under-evaluation of the risk this poison poses in the environment and to the welfare of wild and domestic species. Compound 1080 causes evidence of pain and distress for prolonged periods before death. The severe suffering it induces upon its victims should be sufficient grounds for removing Compound 1080 from the Canadian landscape. Compound 1080 presents unacceptable risks to the health and safety of non-target individuals, including species at risk and domestic animals. The relatively slow toxic action of Compound 1080 allows poisoned individuals to disperse widely across the landscape, preventing accurate monitoring of primary and secondary poisoning. Data provided through a Freedom of Information request provide evidence that at least 36 of Alberta’s Compound 1080 occurrence use records failed to indicate carcass/bait recoveries from poisoning sites between 2011 - 2016, and thus failed to demonstrate the legally required carcass/bait recovery. Records provided through a Freedom of Information request to the Government of Saskatchewan shows Ministry of Environment staff explaining that the lengthy time it takes an animal to succumb to Compound 1080 results in poisoned carcasses almost never being found. Where the intended outcome is preventing future conflict between wild canids and livestock, compared with poisons, safer and more effective alternatives exist. In response to multiple requests made by nongovernmental organizations, toxicologists, veterinarians and members of the public, Health Canada initiated a reevaluation of the cluster of predacides registered in the country in January 2021, including strychnine and sodium cyanide in addition to Compound 1080. Recent poll results indicate that most Canadians believe the risks of Compound 1080 and other predacidal poisons registered in Canada are unacceptable. It is imperative that the broader scientific community takes a participatory role in Health Canada’s consultation periods around Compound1080 to support the ban of this non-discriminating and inhumane poison from all future use in Canada.

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Indiscriminate, Inhumane and Irresponsible:

Compound 1080 Is No Longer an Acceptable

Form of Wildlife Management

Sadie PARR1 and Hannah BARRON2

121-514 Anderson Rd. Golden, British Columbia, V0A 1H1, Canada. Email: sadieparrwolfpact@gmail.com

2Wolf Awareness. Email : hannah@wolfawareness.org

Abstract

Canada’s mammalian and avian predators and scavengers are at risk of exposure to the inhumane and deadly

Compound 1080 (sodium monofluoroacetate), a poison authorized by Health Canada’s Pest Management Regulatory

Agency to kill wolves (Canis lupus) and coyotes (Canis latrans) under the following circumstances: i) following

instances of livestock predation; ii) where predation has been identified as the primary factor affecting survival of a

specific wildlife population, or iii) where a serious threat to human safety exists. Misrepresentation of Compound

1080 as being a canid-selective or even canid-specific toxicant, in addition to victim dispersal due to delayed

presentation of clinical signs, has led to an under-evaluation of the risk this poison poses in the environment and to

the welfare of wild and domestic species. Compound 1080 causes evidence of pain and distress for prolonged periods

before death. The severe suffering it induces upon its victims should be sufficient grounds for removing Compound

1080 from the Canadian landscape. Compound 1080 presents unacceptable risks to the health and safety of non-target

individuals, including species at risk and domestic animals. The relatively slow toxic action of Compound 1080 allows

poisoned individuals to disperse widely across the landscape, preventing accurate monitoring of primary and

secondary poisoning. Data provided through a Freedom of Information request provide evidence that at least 36 of

Alberta’s Compound 1080 occurrence use records failed to indicate carcass/bait recoveries from poisoning sites

between 2011 ̶ 2016, and thus failed to demonstrate the legally required carcass/bait recovery. Records provided

through a Freedom of Information request to the Government of Saskatchewan shows Ministry of Environment staff

explaining that the lengthy time it takes an animal to succumb to Compound 1080 results in poisoned carcasses almost

Correspondence: Sadie Parr, 21-514 Anderson Rd. Golden, British Columbia, V0A 1H1, Canada. Email:

sadieparrwolfpact@gmail.com

CWBM 2021: Volume 10, Number 1

Point to Ponder

ISSN: 1929–3100

PARR and BARRON 34

never being found. Where the intended outcome is preventing future conflict between wild canids and livestock,

compared with poisons, safer and more effective alternatives exist. In response to multiple requests made by non-

governmental organizations, toxicologists, veterinarians and members of the public, Health Canada initiated a re-

evaluation of the cluster of predacides registered in the country in January 2021, including strychnine and sodium

cyanide in addition to Compound 1080. Recent poll results indicate that most Canadians believe the risks of Compound

1080 and other predacidal poisons registered in Canada are unacceptable. It is imperative that the broader scientific

community takes a participatory role in Health Canada’s consultation periods around Compound1080 to support the

ban of this non-discriminating and inhumane poison from all future use in Canada.

Key Words: Animal Welfare, Canid, Canis, Compound 1080, Humaneness, Lethal Control, Livestock, Non-selective,

Non-target Animals, Poison, Predacide, Secondary Poisoning, Species at Risk, Wildlife Management.

Introduction

Poison baits are often the subject of vigorous debate over

the impact they have on non-target animals, including

endangered species, domestic animals and companion

animals (Defenders of Wildlife 1982; Hjertass et al. 1995;

Sherley 2007; Canadian Veterinary Medical Association ̶

CVMA 2014; Pest Management Regulatory Agency ̶

PMRA 2014). Despite controversy regarding their use,

deadly poisons continue to be registered and used in Canada

to kill native carnivores when they come into conflict with

farmed animals, including sodium monofluoroacetate, also

called sodium fluoroacetate or more commonly referred to as

Compound 1080.

Compound 1080 is currently classified as a restricted

product in Canada and regulated under the Pest Control

Products Act (PMRA 2015). It is used in Alberta and

Saskatchewan under permits nos. 18300, 24512, 25857 and

28865 for the purpose of killing wolves (Canis lupus) and

coyotes (Canis latrans) under the following circumstances:

i) following instances of livestock predation; ii) where

predation has been identified as the primary factor affecting

survival of a specific wildlife population, or iii) where a

serious threat to human safety exists. Compound 1080 is

available in 2 forms: 1) 5 mg tablets which are placed in meat

baits, and 2) 60 ml livestock protection collar (LPC) devices

(10 mg/ml of Compound 1080). LPCs are placed around the

neck of sheep (Ovis aries) or goats (Capra aegagrus hircus),

and are designed to rupture when bitten by a predator.

However, they can also be punctured by a conspecific animal

chewing on them, or by a sharp object such as barbed wire,

bramble or branch (Randall 1981).

In this Point to Ponder, we address scientific and ethical

implications of using Compound 1080 as a predacide in

wildlife management programmes.

Unacceptable Environmental Risk

Impact on Biodiversity

Compound 1080 is labeled as a “super poison” by the US

Environmental Protection Agency (EPA 1995) and listed a

Category 1A ̶ the most toxic category ̶ by the World Health

Organization (2009). This broad-spectrum pesticide kills via

metabolically blocking the Krebs cycle (Kun 1982; Atzert

1971), inhibiting an important pathway to cell energy

production, which results in loss of cell function and

eventually cellular death, causing gross organ failures and

organ system failures (Atzert 1971). Compound 1080 is toxic

to most mammals and poses a serious risk to non-target

species, including wild and domestic species (Burns and

Connolly 1995; Canadian Cooperative Wildlife Health

Center ̶ CCWHC 1999; PMRA 2014).

Because canids are up to 10 times more susceptible to the

poison compared to most other mammals (Atzert 1971;

Eisler 1995; CCWHC 1999), it was previously believed that

Compound 1080 could be used selectively to poison species

in the Canidae family (Robinson 1953; Atzert 1971; Randall

1981). This misconception remains widely perpetuated, as

indicated by PMRA’s use-permits for Compound 1080

tablets (nos. 18300, 25857) which state the “predacide [is for]

coyote control and wolf control”. However, differences in

susceptibility to toxicity of poisons does not guarantee

selectivity (Cain et al. 1972). Indeed, Alberta’s use-permit

for tablets (no. 18300) states that “Sodium

monofluoroacetate is toxic to all warm-blooded animals”

(Alberta Agriculture and Forestry 2015). Recognized as a

systemic pesticide (EPA 1985), Compound 1080 has also

been used around the world to kill rodents, rabbits, and non-

canid carnivores such as mustelids and felids (CCWHC

1999).

PARR and BARRON 35

Compound 1080 is historically believed to be at least partly

responsible for the decline of several species at risk in North

America, including the burrowing owl (Athene cunicularia)

(Butts 1973), swift fox (Vulpes velox) (Burnett 1989;

Ginsberg and MacDonald 1990; COSEWIC 2009),

California condor (Gymnogyps californianus) (Hegdal et al.

1986), and black-footed ferret (Mustela nigripes) (Defenders

of Wildlife 1982).

Prior to the 1972 ban on predator toxicant use on federal

lands in the United States, a government program was

initiated in 1969 in response to repeated claims against the

state that people’s pets were being poisoned on public lands

(Randall 1981). Randall (1981) reported non-target

carcasses of coyote, dog (Canis familiaris), black bear

(Ursus americanus), badger (Taxidea taxus), bobcat (Lynx

rufus), American marten (Martes americana), mink

(Neovison vison), weasel (Mustela spp.), golden eagle

(Aquila chrysaetos), red-tailed hawk (Buteo jamaicensis),

magpie (Pica hudsonia), prairie falcon (Falco mexicanus),

sharp-shinned hawk (Accipiter striatus), Canada jay

(Perisoreus canadensis), and rough-legged hawk (Buteo

lagopus) (Defenders of Wildlife 1982).

Unquantifiable primary and secondary poisoning

Compound 1080 is tasteless, colourless and odourless.

Residual poison in the carcasses of Compound 1080 victims

can poison other animals feeding on the contaminated

carrion, a process termed “secondary poisoning” (Cain et al.

1972). Secondary poisoning occurs when an animal

consumes unmetabolized Compound 1080 from the vomitus

or gut of a victim, or during scavenging after Compound

1080 is absorbed into the bloodstream and distributed

through skeletal muscle, soft tissues, and organs (CCWHC

1999; Eason et al. 2010). Although Compound 1080 does

not bioaccumulate in animal tissue (Eason et al. 1994;

PMRA 2014), it can persist in carcasses at hazardous

concentrations that remain lethal to various scavengers, both

mammalian and avian, for several months (Defenders of

Wildlife 1982; Meenken and Booth 1997; Eason et al. 2010).

Compound 1080 poisoning has a long latent period, with

initial clinical signs in canids being delayed for at least 2 h,

although this period is often much longer (Atzert 1971).

During this time, poisoned animals can travel several

kilometers prior to dying (Randall 1981), precluding carcass

detection and retrieval (ENV 2019), thus further distributing

Compound 1080 to unknown areas and increasing the

likelihood of secondary poisoning. The Government of

Alberta’s policy entitled “Use of Toxicants for Wildlife

Management” acknowledged that it “is very difficult to

monitor its [Compound 1080’s] effectiveness as it is slow

acting; animals can travel long distances before succumbing

to the toxicity” (AESRD 2012). In fact, this observation

explains why some people mistakenly believe that

Compound 1080 results in fewer non-target victims when

compared to faster-acting poisons. The Government of

Alberta toxicant policy further states that “retrieval of

carcasses is typically impossible and secondary poisoning of

other wildlife species feeding on the carcass is a potential

concern” (AESRD 2012). Given these acknowledgements of

risk, it is highly disconcerting that Alberta has continued to

use Compound 1080 since their first permit was given by

Health Canada in 1984, and without addressing the concern

of secondary poisoning. Alberta government records indicate

that between 2012 and 2018, a minimum of 9,450 tablets of

Compound 1080 were deployed on the landscape, with the

vast majority (92%) being placed by landowners (AF 2017;

AF 2019; Animal Justice and Wolf Awareness 2020).

It is impossible to estimate the diversity and number of

non-target animals killed by secondary poisoning from a

single poisoned carcass that is not recovered. Data obtained

via Freedom of Information requests indicate that poison

baits and carcasses are not being recovered in an adequate or

timely manner, posing significant risks of primary and

secondary poisoning to non-target organisms. Between

2011 ̶ 2016, there were at least 13 Compound 1080

occurrence reports from Alberta’s Ministry of Environment

and Parks showing that Compound 1080 baits were

consumed but no carcasses were recovered (AEP 2018,

Animal Justice and Wolf Awareness 2020). In addition, 23

occurrence reports from this period provided no further

information following placement of 1080 baits, suggesting

that neither baits nor poisoned carcasses were retrieved from

the landscape. Similarly, correspondence obtained through a

Freedom of Information request to Saskatchewan’s Ministry

of Environment showed Problem Wildlife Specialist staff

explaining that “you are never certain of your success for a

carcass is almost never found” (ENV 2019). The use of

Compound 1080 in Alberta and Saskatchewan is of

especially great concern for species at risk, including birds

and mammals with At Risk status under the federal Species

at Risk Act, which inhabit rural areas where this poison has

been used in recent years to lethally control wild canids

(Table 1).

Reducing conflict between carnivores

and livestock

Where conflicts arise between predators and livestock,

humane and ecologically sustainable alternatives to poisons

can be employed. Knowledge continues to grow surrounding

non-lethal alternatives aimed at preventing or reducing the

chances of future conflicts between carnivores and livestock

(Musiani et al. 2003; Shivik 2004; 2006; Shivik et al. 2003;

PARR and BARRON 36

Treves and Naughton-Treves 2005; Barnes 2015; Miller et

al. 2016; Treves et al. 2016; 2019; Eklund et al. 2017; Stone

et al. 2017; Moreira-Arce et al. 2018; van Eeden et al. 2018a).

Additionally, contemporary science suggests that lethal

removal of carnivores can lead to no decrease in predation

levels, or can backfire and lead to increased levels of conflict

(Connor et al. 1998; Musiani et al. 2005; Wallach et al. 2009;

Allen 2014; Peebles et al. 2013; Wielgus and Peebles 2014;

Treves et al. 2016; van Eeden et al. 2018a; Santiago-Avila

2018; Nattrass et al. 2019; Treves et al. 2019), which calls

into question Health Canada’s assumption that predacides

have value because they adequately address livestock losses.

Indeed, researchers should be concerned that Health Canada

has never evaluated this purported value, despite claiming

that the Pest Management Regulatory Agency is a science-

based agency (S. Kirby– Director General, Environmental

Assessment, Pest Management Regulatory Agency, Health

Canada, personal communication 2018), which implies that

their decisions are guided by scientific evidence.

Removing canids may provide a temporary reduction in

conflicts with livestock, but it is by no means a solution that

will prevent future negative interactions (Musiani et al. 2005;

Lennox et al. 2018; Wielgus and Peebles 2014; Treves et al.

2019). The cycle of repeatedly killing canids can and must

be replaced by a combination of responsible husbandry

practices and prevention-based techniques that are evidence-

based (Treves et al. 2016; van Eeden et al. 2018a, b). The

use of Compound 1080 under the guise of reducing conflicts

among livestock is a distraction from taking necessary

measures to prevent predation events and promote

coexistence.

Ethical Considerations

Humaneness

It is ethically essential that the welfare of both target and

non-target animals be considered when assessing the

humaneness of Compound 1080 (Sherley 2007; CVMA

2014). An increasing sector of global society no longer

tolerates human-caused suffering of animals (Dubois et al.

2017). An estimated 69% of Canadians say that the risks

posed by using Compound 1080, strychnine, or sodium

cyanide in wildlife management programs are unacceptable,

with more than twice as many Canadians supportive of a ban

of all 3 predacidal poisons than are unsupportive (Environics

2020).

The CVMA has denounced the use of Compound 1080 in a

position statement on pest control due to the severe pain and

Table 1. Native species occurring in Alberta and Saskatchewan with At Risk status under the federal Species at Risk Act

that have ranges overlapping areas where Compound 1080 was used as a predacide in the past decade. Species ranges were

compared with Compound 1080 general use locations (municipal district) determined through records obtained through

the Freedom of Information process (AF 2017, AF 2019, ENV 2017, and ENV 2019).

Species

Canadian Species at Risk Act, Schedule 1

Mammals

American badger (Taxidea taxus)

Special Concern, Endangered

Black-footed ferret (Mustela

nigripes)

Extirpated with recovery strategy involving reintroduction

Saskatchewan

Brown (grizzly) bear (Ursus arctos)

Special Concern

Swift fox (Vulpes velox)

Threatened. Captive breeding programs, reintroduction efforts in

AB and SK; previously extirpated from Canada (1978).

Wolverine (Gulo gulo)

Special Concern

Birds

Burrowing owl (Athene cunicularia)

Endangered

Ferruginous hawk (Buteo regalis)

Threatened

Peregrine falcon (Falco peregrinus

anatum)

Special Concern

Short-eared owl (Asio flammeus)

Special Concern

PARR and BARRON 37

convulsions it causes, also noting that risks to non-target

organisms should be considered when evaluating the impacts

of lethal management (CVMA 2014). Scientists,

veterinarians, and wildlife managers familiar with

Compound 1080 consider it “inhumane” (Randall 1981;

CCWHC 1999; Sherley 2007; J. Smits ̶ Professor

Ecotoxicology & Wildlife Health, Faculty of Veterinary

Medicine, University of Calgary, personal communication

2017). Compound 1080 creates organ disorders, which can

be extremely painful as essential cellular processes break

down. Over a period of a few to several hours, victims who

ingest Compound 1080 experience both physical and

psychological terror caused by the recurrence and repetition

of violent convulsions and seizures (Randall 1981; Sherley

2007). In a review of the literature, Sherley (2007) cites that

clinical signs of severe pain and distress are evident in

animals poisoned with Compound 1080; these include

retching and vomiting, trembling, fecal and urinary

incontinence, severe and prolonged convulsions, unusual

vocalizations/screaming, hyperactivity, muscular weakness,

incoordination, hypersensitivity to sensory stimuli, and

respiratory distress. Eventually death results from cardiac

failure, central nervous system failure, or respiratory arrest.

In comparison to strychnine, which is largely recognized

as an unethical and unacceptable wildlife poison (CVMA

2014; Proulx et al. 2016), Compound 1080 produces a longer

duration of pain, distress and suffering; prolonging the agony

and anxiety each victim experiences (Randall 1981; Sherley

2007). During this time, poisoned animals are vulnerable to

injury from other factors as well (Randall 1981). Animals

that ingest non-lethal doses of the poison have reduced

survival after being weakened, as individuals depend

upon alertness, agility, and coordination to survive

(J. Smits, personal communication, 2017). If they recover,

these animals may experience long-term effects of

toxicity (Robinson 1953; Randall 1981; J. Smits, personal

communication, 2017).

By hosting a public consultation on “Humane Vertebrate

Pest Control” in 2019, the PMRA formally recognized that

animal welfare is an important societal concern and

responsibility. However, in 2021, PMRA concluded their

consultation and announced that they had decided to ignore

humane considerations during pesticide evaluation and re-

evaluation processes (PMRA 2021a), despite stating that:

“affected animals may endure a period of pain and suffering

before death…” (PMRA 2021b). The statement goes on to

say, “These products may also pose risks to other animals

through accidental exposure, either to uneaten baits or

through eating a poisoned carcass”. The use of the word

“may” in the above statements provides a false sense of

security given the nature of Compound 1080.

Risk to pets

Dogs are particularly susceptible to Compound 1080 (Goh

et al. 2005). In New Zealand, possum (Trichosurus

vulpecula) carcasses retrieved as follow-up to a poisoning

program were shown to have enough residual Compound

1080 to pose a serious hazard to dogs for up to 75 d

(Meenken and Booth 1997). Toxicology tests are expensive

and time consuming, so under-reporting incidents of related

dog-deaths is likely. Between 2019 and 2020, pathology

reports confirmed Compound 1080 toxicity of dogs in the

area of Cranbrook, British Columbia (B.C.) in 3 separate

occasions (A. Skaien ̶ Director of Administration, Steeples

Veterinary Clinic, personal communication, 2020). Note that

B.C. has not had legal ‘use-permits’ for Compound 1080 for

over 2 decades, which reinforces concerns surrounding

misuse of this highly dangerous poison if it is available

anywhere in this country.

Poisoning carnivores to temporarily increase prey

populations

As noted previously, Alberta’s use permit for Compound

1080 (no. 18300) also includes instances where predation has

been identified as the primary factor affecting survival of a

specific wildlife population. However, we apply the same

rationale to any use of this pesticide regardless of the

intended outcome and maintain that allowing the use of a

non-selective and inhumane pesticide to ostensibly benefit

another wild species, whether At Risk or not, is unacceptable

on both environmental and ethical grounds.

Conclusion

Compound 1080 poses a serious threat to wildlife, pets, and

even people. It causes prolonged and extreme suffering and

can no longer be accepted as an ethical wildlife management

practice. Like strychnine (Proulx et al. 2016), we argue that

Compound 1080 is unacceptable in light of its inherent

inhumaneness and adverse effects on non-target organisms,

both wild and domestic. We question the perceived value of

the toxicant as a tool to prevent and mitigate livestock losses.

Furthermore, we are concerned that Health Canada

continues to fail to address non-compliance with conditions

set out in the use permits it provides to registrants, as

evidenced in records obtained from the registrants, all of

which are themselves government bodies. Health Canada has

responded to recent concerns raised by public and non-

government organization over the use of predacides by

speeding up the regular 15-year re-evaluation of all 3

registered predacides, and began evaluating them as a

“cluster” in January 2021.

Throughout the ongoing re-evaluations, we will continue

to recommend that Health Canada immediately withdraws

PARR and BARRON 38

and cancels active permits for Compound 1080, and bans

future use. In addition, we encourage and promote the

adoption of non-lethal prevention-based management

techniques to eliminate reliance on poisons where livestock

overlaps with native carnivores. Indeed, in the past, Health

Canada has participated in Integrated Pest Management

research to find effective alternatives to rodenticidal

strychnine (PMRA 2020). It should be noted that there are

numerous cases where livestock producers have initiated a

combination of effective range management practices and

non-lethal techniques which have resulted in reduced

negative interactions between predators and livestock. One

example includes the Waterton Biosphere Reserve's

Carnivores and Communities Program in southwestern

Alberta where vast areas with livestock share borders with

wild/public lands of the eastern slopes of the Rockies. This

program has achieved impressive success at reducing

predation on cattle by community members changing their

livestock management practices while working together with

local conservation officers (Morehouse et al. 2020).

We suggest that the scientific community, conservation

groups, livestock producers and wildlife managers have a

responsibility to work with the public and policy makers to

ensure that Compound 1080 and all of its derivatives are

banned from use across Canada. Ending Canada’s misguided

reliance on inhumane and ineffective wildlife poison

programs can be both simple and revolutionary. We

encourage concerned scientists to subscribe to receive

notifications of Health Canada’s upcoming consultation

opportunities during the re-evaluation period, and to report

poisoning deaths discovered through their research efforts to

Health Canada’s Public Incident Database and the Canadian

Wildlife Health Cooperative, which have so far failed to

compile wildlife poisoning death data collaboratively.

Acknowledgements

The authors would like to offer thanks and acknowledge

important contributions from the following individuals and

organizations: Kaitlyn Mitchell, Paul Paquet, Gilbert Proulx,

Judit Smits, Kirsten Weagle, Liz White, Animal Alliance of

Canada, Animal Justice, and Wolf Awareness. In addition,

we thank 2 anonymous referees who helped improve this

manuscript.

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