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Staff Report
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Report To: General Government Committee
Date of Meeting: December 4, 2023 Report Number: CSD-003-23
Submitted By:
Reviewed By:
File Number:
George Acorn, Director of Community Services
Mary -Anne Dempster, CAO Resolution#:GG-197-23
Report Subject: Rodenticide Use in Municipal Facilities
Recommendations:
By-law Number:
1. That Report CSD-003-23, and any related delegations or communication items, be
received.
2. That Council authorize staff to initiate a trial at Courtice Community Complex,
replacing rodenticides (interior and exterior) with rodent traps, catch tin traps, and
snap exterior traps;
3. That staff continue to investigate the feasibility of a future ban of rodenticides for all
municipal buildings;
4. That staff report back prior to 2024 summer recess with the results of the trial
program and to make further recommendations on the longer -term use of
rodenticides in municipal buildings; and
5. That all interested parties listed in Report CSD-003-23, and any delegations be
advised of Council's decision.
Municipality of Clarington
Report CSD-003-23
Report Overview
Page 2
This report, in response to direction by Council, provides the results of a preliminary
investigation by staff on the feasibility of implementing a ban on the use of rodenticides at all
municipal buildings. Following the preliminary work, staff are recommending a trial be
undertaken at one community centre, replacing bait traps with snap traps. Further, staff will
continue to research the matter, and report back to Council in June 2024 on the results of
the trial program and possible next steps for Council to consider.
1. Background
1.1 At the October 16, 2023, General Government Committee meeting, arising from the
delegations of Janice Freund and Allison Hansen, the following Resolution #GG-160-23
was referred to Staff to report back at the December 4, 2023 General Government
Committee meeting:
Whereas council acknowledges that rodenticide products are unreasonably
dangerous, inhumane, and ineffective.
And whereas rodenticides are highly toxic, persistent and bio accumulative
compounds used to eliminate rodent populations by causing death by preventing
normal blood clotting, causing internal hemorrhaging, or disturbing nervous system
functions.
And whereas rodenticides pose serious threats to Ontario's wildlife (including
raptors, songbirds, coyotes, snakes, and racoons) and the environment (including
aquatic ecosystems) through primary and secondary poisoning of non -target
species, and further threaten children and pets.
And whereas predators and scavengers are at a particularly high risk of secondary
poisoning because of their dependence on rodents as a food source, with countless
cases of poisoning across Ontario in the past decade.
And whereas rodenticides are an ineffective and counterproductive means of
controlling long-term rodent populations because they fail to address the root of
infestation problems (i.e., access to food, shelter, and other attractants), and kill
predators that serve as natural and chemical -free methods of pest control (e.g., a
single owl eats around 1,000 rats per year).
And whereas the existing risk mitigation measures implemented by the federal and
provincial government are incapable of adequately addressing the threats that
rodenticides pose to the environment, wildlife, and human health; and
And whereas preventative measures are the best method of vector control.
Municipality of Clarington
Report CSD-003-23
Page 3
And whereas eliminating non -essential use of rodenticides is consistent with the
precautionary principle.
And whereas Council wishes to enact a policy prohibiting the use of inhumane
vector control products to address public concern for the environmental wellbeing of
the community, and the health, safety, and well-being of its inhabitants.
And whereas: Council deems it desirable and in the public interest to enact an
Animal Poison Prevention Policy for protecting wildlife, pets, and people from
unreasonable adverse effects caused by rodenticide use for the purpose of:
• Eliminating inhumane methods of pest control.
• Regulating and controlling the use, purchase, and sale of rodenticides.
• Sustaining a healthy natural environment by protecting biodiversity.
• Protecting significant and sensitive natural areas.
• Protecting human health.
• Maintaining water quality; and
• Protecting fish habitat as defined in the Fisheries Act, Revised Statute of
Canada 1985.
Therefore, be it resolved that Council adopts a policy banning the use of
rodenticides on all municipally owned properties, with immediate effect.
That Council directs Staff to communicate this policy direction to residents and
businesses including information on the harmful impacts of rodenticides and the
availability of humane, ecologically sustainable alternatives; and
That Council incorporates humane practices regarding pest control on all municipal
properties.
1.2 Following the direction provided by Council, staff initiated an investigation into the
concern with the use of rodenticides and the potential secondary impact it may have on
domestic animals and other wildlife. This included reaching out to other communities as
well as discussions with our current pest control contractor. We have maintained
contact with Allison Hansen and have received valuable information from her on this
topic and we will continue to communicate as we do further investigation.
1.3 We have also been working with our Animal Shelter Supervisor, who has recent
experience coming from the City of Toronto. Her assistance will help inform our analysis
and any subsequent recommendations we may bring forward.
Municipality of Clarington Page 4
Report CSD-003-23
2. Rodenticide Use in the Municipality
2.1 Rodenticides are currently used in different applications throughout the interior and
exterior of municipal buildings in tamper -resistant bait stations for vector control. The
Municipality currently is under contract with Well Done pest control who are governed
under the Ministry of Environment, which uses 2nd generation rodenticide to control
rodent infestation(s) in/around municipal buildings. Although rodenticides can be
effective, they are felt to be dangerous, inhumane, and pose a threat to wildlife, pets,
and children through primary and secondary poisoning.
2.2 First -generation anticoagulant rodenticides (FGARs) like warfarin, chlorophacinone, and
diphacinone are still legal for use. These products are an older, slower -acting, and less
potent product compared to SGARs — but rodents still suffer the same effects. Rodents
can also develop resistance to the product.
2.3 Second -generation anticoagulant rodenticides (SGARs) are substantially more potent
than the first -generation compounds, and a lethal dose can be ingested in a single
feeding. Included in this class of rodenticides are the compounds difenacoum,
brodifacoum, bromadiolone and difethialone.
2.4 SGARs can also pose a serious risk to people, pets, and wildlife through direct and
secondary poisoning. The risk of secondary poisoning for wildlife by SGARs is higher
than first -generation products because the active ingredients stay in animal tissue for a
long time after feeding.
3. Rodenticide Use in Other Municipalities
3.1 Following direction provided in June 2023, City of Pickering staff are currently preparing
a report for their Executive Committee's December 4th agenda. Our discussions with
staff have indicated the City may be recommending a ban on rodenticide use for
municipal buildings.
3.2 City of Toronto staff are currently investigating this issue and indications are there will
be a report going forward for consideration early in 2024. Our staff will remain
connected as they work toward that report.
3.3 The Township of Minden Hills is also in the fact-finding stage of rodenticides and
alternative methods. Currently, staff are not aware of the timing on any future reports.
3.4 There are also examples in Western Canada, including the City of Port Moody, where
municipalities have approved the ban on the use of rodenticides for municipal buildings.
Staff are reviewing these policies to better inform us when making any future
recommendations.
Municipality of Clarington Page 5
Report CSD-003-23
4. Trial Program at Courtice Community Complex
4.1 Staff are proposing a rodenticide-free trial program from January to May at this location.
In conjunction with our pest control contractor, staff will arrange for the removal of all
rodenticide bait traps in and around the facility. They will be replaced with rodent traps,
catch tin traps, and snap exterior traps.
4.2 Data will be collected during this period, and the results of this trial will be reported back
to Council prior to the 2024 summer recess. The results of this trial will help inform any
future recommendations regarding a more widespread ban.
5. Financial Considerations
5.1 It is expected any costs related to the trial period at Courtice Community Complex can
be covered in the proposed 2024 operating budget. Pending the results of this trial and
any further recommendations being reported back to Council, staff will include any
financial impacts at that time.
6. Concurrence
6.1 This report has been reviewed by the Deputy CAO/Treasurer, who concurs with the
recommendations.
7. Conclusion
7.1 It is respectfully recommended that Council approve this report and direct staff to
complete the rodenticide-free trial program at Courtice Community Complex, and report
back on those findings, with additional recommendations for a long-term plan, prior to
the 2024 summer recess.
Staff Contact: Ken Ferguson, Manager of Facilities, 905-623-3379 ext. 2504 or
kferguson@clarington.net.
Attachments:
Not Applicable
Interested Parties:
Allison Hansen
Janice Freund
THE DEFEND THEM ALL FOUNDATION
December 1, 2023
Corporation of the Municipality of Clarington
40 Temperance Street
Bowmanville, ON L1 C 3A6
Re: Rodenticide use in Clarington
Dear Honourable Mayor and Council:
We are writing to express concern regarding the use and sale of rodenticides in Clarington, and
the recommendations proposed by Staff in Report Number CSD-003-23.
Defend Them All (DTA) is a nonprofit organization dedicated to securing a better future for
animals and their habitats through community advocacy, education, and legal guidance. In
furtherance of this aim, DTA supports and collaborates with advocates striving to make a
difference in their community. The organization is independent and non -partisan. It receives no
money, either directly or indirectly, from any government.
As an international organization focused on issues at the intersection of animal and
environmental law and policy, Defend Them All is part of the growing movement to reduce the
harm caused to animals and the environment as a result of rodenticides. As such, we are
excited to see a growing awareness of this issue and a clear shift towards better solutions.
We aim to offer constructive feedback on the plan proposed by Staff in its report as well as
provide background information to supplement documents and delegations by Allison Hansen
and Janice Freund. We are optimistic that with more information and support, Clarington will
take the opportunity to emerge as a leader on rodenticide policy in Ontario by taking more
aggressive action. Such leadership is consistent with this Council's commitment to the
environmental wellbeing of the Corporation, and the health, safety and well-being of its
inhabitants.
Risks posed by rodenticides are significant and undisputed.
Rodenticides are inhumane, pose serious threats to animals including family pets and wildlife
species, the environment, and to human health - these are well -documented facts based on
long accepted science, not theories as language in the Report seems to suggest'.
As correctly pointed out in the Report, chemicals classified as rodenticides vary in their active
ingredients, but generally aim to kill unwanted pests by preventing normal blood clotting,
'See Report section 1.2 - "potential,' section 2.1 - "felt," section 2.4 "can"
www.defendthemall.org
THE DEFEND THEM ALL FOUNDATION
causing internal hemorrhaging, or disturbing nervous system functions. Both first and second
generation rodenticides are inherently dangerous poisons designed to kill. Animals that ingest
these products and/or poisoned prey experience great pain and suffering over a period of days
or weeks, most often leading to death. This means that animals can continue to feed on the
baits, thus accumulating a significant level of rodenticides in their livers before they finally die.
High levels of these poisons can remain in the livers of carcasses for months.
Many of Ontario's native and at -risk species face high risks of rodenticide poisoning. In addition
to mice, small animals including songbirds, shrews, voles, and other non -target mammals and
invertebrates are known to access bait boxes containing these poisons. This direct feeding is
contaminating the food -chain and wider ecosystem: coyotes, bobcats, foxes, skunks and other
mammalian predators that feed on small animals have been found to have rodenticides in their
systems. Owls and other raptors are at a particularly high risk of secondary poisoning because
of their dependence on rodents as a food source.
In addition to ecosystemic impacts, rodenticides are known to bioaccumulate and persist in the
environment posing human health risks. Recently, researchers in the United States have even
measured traceable levels of ingestible rodenticides in the milk supply. The American
Association of Poison Control Centers receives approximately 10,000 reports of rodenticide
exposures in children annually in the U.S.
Rodenticides are not an effective method of controlling rodent populations over the long
term.
The use of poisons is counter -productive, evidenced by the fact that pest control companies
remain on contracts to supply poisons for indefinite durations of time. Consistent with these
facts, a majority of surveyed pest control professionals believe that while poisoning is the
easiest and cheapest method of controlling rats, this strategy fails to provide a long-term
solution because it fails to deal with the factors promoting and sustaining infestations.
Rodents are drawn to areas where they have access to food and shelter; therefore, structural
access points to these resources must be addressed to permanently remove rodents. By
eliminating resident rodents, rodenticides simply clear the way for a new population to move in.
Alternative approaches to poisons do exist, and a transition to chemical -free methods could be
done with relative ease and would prove cost-effective for Clarington in the long run. The
primary step that sustainability-oriented pest management companies recommend is
"rat -proofing" the premises of buildings by addressing the active and potential access -points in
the structures. In some cases, traps may be temporarily necessary if mice have made it indoors
and present an immediate threat. However, as rodents are known to not stay indoors,
companies that provide humane solutions use one-way doors to clear and permanently seal the
structure.
www.defendthemall.org
THE DEFEND THEM ALL FOUNDATION
Food and other resources that attract rodents must also be secured or eliminated. It is in the
economic interest of pest control companies that use poisons to ignore these steps, as
permitting such conditions to persist invites new populations of rats to invade, thus giving rise to
continued business.
Expecting to obtain information sufficient to inform future action on rodenticides by
trapping rodents in and around a building surrounded by natural areas is irresponsible
and illogical.
That being said, it is important to understand what proactive measures will be taken to exclude
rodents and eliminate attractants at Courtice Community Complex - or will this simply be an act
of ineffective and unsustainable trapping. What proactive and preventative measures has Well
Done Pest Control completed at the properties they service? If proactive measures will be
taken, the cost of these measures should have been included in the Staff Report.
Replacing rodenticides with snap traps will not effectively assess the need or effectiveness of
Clarington's current poison subscription plan with Well Done Pest Control.
Furthermore, continuing to allow the use of rodenticide in and around other municipal properties
in Clarington despite Council's October 16, 2023 acknowledgment of the unreasonable risks
these products pose is irresponsible and unjustifiable.
Recognizing the risks rodenticides pose to human health and the environment, in 2013 Health
Canada enacted risk mitigation measures for several commercial class rodenticides. However,
recent research in Ontario, and across Canada, demonstrates that these measures are
ineffective and merely symbolic. Restricting the most toxic rodenticides to indoor use and
requiring these products to be kept in tamper -proof bait boxes fails to consider the documented
fact that rodents do not die inside these boxes, but rather disperse into the surrounding natural
habitats.
Clarington must take the lead on pesticides by enacting legislation to prohibit
rodenticides.
The Pesticides Act (Section 7.1 (5)) renders inoperable municipal by-laws addressing the use,
sale, offer for sale or transfer of a pesticide that may be used for a cosmetic purpose. However,
it does not preclude municipalities from enacting policies deemed desirable and in the public
interest for protecting wildlife, pets, and people from unreasonable adverse effects caused by
rodenticides and other inhumane pest management methods. While it is now widely understood
that rodenticides are unnecessary and ineffective over the long-term, rodenticides were clearly
not contemplated as a part of sweeping reform related to lawn and garden products in the early
2000s.
www.defendthemall.org
THE DEFEND THEM ALL FOUNDATION
If rodenticides were an effective solution, businesses, farmers, and municipalities would not
have ongoing contracts with pest control companies for indefinite rodenticide application. The
extensive data before us evidences that mere restrictions are not enough. Rodenticides need to
be a thing of the past, and as stewards of the environment, local governments must protect
wildlife and future generations against the devastating harms they pose.
We appreciate your time and attention to this important issue and sincerely hope the materials
we have provided are helpful. Please feel free to reach out with questions that arise as you
review. We would be pleased to serve as a resource as you consider next steps forward.
Respectfully submitted,
Z/Ptt
Lindsey Zehel, Esq., LL.M.
Executive Director I Defend Them All Foundation
Phone: 567-203-7220
www.defendthemall.org