Within 60 days of a new decision, anyone can file a Notice of Objection to Health Canada using an on-line form.

The objection must be based on science.  Some points below are worth speaking to.

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Scientific basis for the objection:​

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​RISKS TO BIODIVERSITY & BIODIVERSITY COMMITMENTS​

• Given Health Canada's statements in the review decision that i)"Reliable data for the number of target and non-target deaths as a result of the use of Compound 1080 are not available"; ii)Compound 1080 is classified as highly to very highly toxic to birds and mammals"; and iii)"There is a risk of death for animals who ingest poisoned baits"; Compound 1080 presents unacceptable risks to biodiversity through primary and secondary deaths. Several species-at-risk, as well as rare and sensitive species, occupy the areas where Compound 1080 is used in Alberta, including the American Badger, Wolverine, Grizzly Bear, and Golden Eagle to name a few.  The risk of death to these animals is too high when Compound 1080 is used. 

• Due to the delay in symptoms and death presented by victims who ingest Compound 1080, poisoned carcasses can be far from bait stations (km.'s away), leaving these deaths unrecorded and causing relay toxicity when fed on by scavengers. The Government of Alberta's own toxicant policy has stated “retrieval of carcasses is typically impossible and secondary poisoning of other wildlife species feeding on the carcass is a potential concern” (AESRD 2012).*

• The use-records all show high levels of non-compliance (ie. illegal use) of label directions, including poor record keeping. There is nothing to suggest this would change. Even with a new "steward program", instructions can go ignored and records can be 'fudged'.  Illegal use has led to dog deaths by secondary poisoning in British Columbia.

• Health Canada assumes the risk of secondary poisoning is low, however 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 (Butts 1973)*, swift fox  (Burnett 1989; Ginsberg and MacDonald 1990; COSEWIC 2009)*, California condor (Hegdal et al. 1986)*, and black-footed ferret (Defenders of Wildlife 1982)*.

• Health Canada claims that Compound 1080 is selective for wolves and coyotes, 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)*. Compound 1080 is recognized as a systemic pesticide (EPA 1985)*, and has been used around the world to kill rodents, rabbits, and non-canid carnivores such as mustelids (weasel family) and felids (cat family) (CCWHC 1999)*.

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*For full references see article: Indiscriminate, Inhumane and Irresponsible: Compound 1080 Is No Longer an Acceptable Form of Wildlife Management

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OTHER RISKS (ANIMAL WELFARE)

• Health Canada falsely claims to use a "comprehensive body of modern scientific methods and evidence...to determine the magnitude of potential risks posed by pesticides". HOWEVER, they also state that animal welfare/humaneness can be disregarded in evaluating pesticides due to claims that "there are no internationally recognized science-based parameters to evaluate the humaneness of pesticides".​ This is false! There are many expert bodies in North America that agree on minimal standards for humane euthanasia of animals, including:  the Canadian Veterinary Medical Association; the American Veterinary Medical Association; and the Canadian Council on Animal Care. The clinical symptoms caused by Compound 1080 do not meet these recognized standards.

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OTHER CONSIDERATIONS

• In that same way that it was possible to discontinue strychnine use for livestock purposes due to alternative methods, there are better options (ie. safer and more effective) for reducing conflict among wolves/coyotes and livestock.  There is no clear scientific evidence that killing predators is an effective way to reduce future livestock losses. 

• Wolves and coyotes are not pests. These sentient animals have intrinsic value, and as native species they also have existence value.  Their presence on the land also benefits the environment by helping to maintain biodiversity.  Wolves and other large carnivores also help limit the spread of disease in cervids (deer family). 

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