by Camilla H. Fox
Greenwash: The dissemination of misleading information by an organization to conceal its abuse of the environment in order to present a positive public image.1
Replace “The environment” with “wildlife” in the above definition, and this could easily describe the United States Best Management Practices (BMP) trap-testing program that was started in response to pressure to end the use of leghold traps. As stated in BMP trapping literature, one of the primary aims of the federal program is “to instill public confidence in and maintain public support for wildlife management and trapping through distribution of science-based information.” Funded by American tax dollars and passed through the US Department of Agriculture (USDA) to the Association of Fish and Wildlife Agencies (AFWA)2, the BMP trap-testing program has cost millions since its inception in 1996, while the cost to wildlife has been immeasurable. Despite the fact that the program has been criticized by independent scientists, wildlife professionals, and animal advocacy organizations as unscientific, self-serving, non-transparent, and rife with political agendas, thousands of coyotes, bobcat, beaver, raccoons and other furbearing species have been forced to suffer in leghold traps, as well as a variety of neck and body snares over the past 13 years.
A History of the Program
In 1991, the European Union (EU) passed a historic measure that banned leghold traps within member countries and sought to pressure other nations to prohibit their use or risk losing the ability to export furs to the EU from 13 furbearing species.3 The measure was the first ever international agreement that comprehensively addressed animal welfare issues specific to wildlife. Animal advocates hoped Regulation 3254/91 would provide the necessary impetus to finally end use of leghold traps within the US, Canada and Russia—the three largest wild-caught fur exporting nations. At the time the regulation had passed, Europe imported more than 70 percent of wild-caught furs from the US and Canada. Instead of following Europe’s lead, the US responded to the regulation with threats of trade reprisals if enacted. Fearing the loss of the European fur market, US trapping and fur interest groups led by the AFWA and the National Trappers Association sought to avoid the EU fur-import ban and maintain public acceptance of trapping in the US These pro-trapping organizations secured the support of the US government to help them fight the ban.
Buckling under pressure and fearful of a challenge before the World Trade Organization, the EU weakened its regulation to allow countries outside the EU to avoid the fur ban if they agreed to work toward adoption of humane trapping standards. However, no internationally recognized humane trap standards existed at that time, or even today. A process to establish international trap standards under the International Organization for Standardization (ISO) was underway, but came to a stand-still in 1997, when countries were unable to agree on base criteria for "humane" trapping standards. The ISO process was criticized internationally as lacking in transparency and being biased in its representation. Members of the US delegation included representatives from the AFWA and the National Trappers Association—entities that had a vested interest in maintaining the use of leghold traps and a limitless fur trade with the EU. The United Kingdom’s House of Lords investigated the matter and concluded,
We are concerned at the Group’s apparently unrepresentative composition and the secretive nature of its proceedings. The exclusion of campaigning organizations is perhaps understandable but the under representation of professional experts in animal welfare and behaviour is less easily defended. It is not clear what status its eventual recommendation should have when around three quarters of its members are closely associated with the fur trapping trade in the major fur exporting countries. (Harrop 2000)4
Despite these formal condemnations, the work of the committee was allowed to proceed and formed the foundation of a non-binding bi-lateral trapping agreement between the EU and the US, known as the “agreed minute,” and a tri-lateral agreement between the EU, Canada and Russia called the Agreement on International Humane Trapping Standards (AIHTS). These agreements enabled all parties to side-step the original intent of Regulation 3254/91, thereby allowing continued use of leghold traps and free-trade in wild-caught fur with Europe. Outside this process, the BMP trap-testing program took shape, garnering the full backing of the US government.
Legitimizing the Status Quo
Through the BMP trap-testing program, the US government was able to demonstrate sufficient progress in exploring trap standards and establishing a trap certification process. However, it has focused on legitimizing standard leghold traps (as well as other controversial trapping devices, such as neck snares and kill traps) and ensuring that the US wild-caught fur trade with Europe is not disrupted. Former National Trappers Association President Craig Spoores assured trappers that "the scientific BMP process will discover that some leghold traps will continue to be necessary and prove best for some American species." Indeed, the first official BMPs recommend unmodified steel-jaw leghold traps and neck snares for several species.
At least 23 furbearing species have been or will be subject to testing under the BMP program across the country. Recreational fur trappers are paid to participate in the program and are given a set of standard procedures to follow as they trap coyotes, bobcats, marten, raccoons, badgers, muskrats, otters and other furbearing animals on their traplines. These trappers and their “technicians” (who can, by protocol, be the trapper's spouse, relative or a trapping buddy) are asked to set certain types of traps and aid in the evaluation of criteria that describe trap performance. Protective of their industry and far from objective or unbiased when it comes to their hobby, the idea that fur trappers are conducting this field work brings into question the veracity and accuracy of the data and the scientific rigor of the process. Trappers would be loath to admit having trapped an endangered species or family pet, or that a trapped coyote had struggled so hard in the trap that she mutilated her foot while trying to escape. In one BMP progress report, the AFWA boasts that, of 80 trapping incidents,
Forty-six coyotes (57.5%) had only mild injuries, including edema and minor skin cuts. Thirty-two (40%) had moderate injuries including broken teeth, major lacerations on foot pads, joint luxation below the carpus or tarsus, or minor periosteal abrasions. These results are among the lowest injury rates reported for coyotes captured in padded traps ...
As this 2001 entry from one AFWA trap tester’s log reveals, the BMP trap-testing program has meant indescribable pain and suffering for individual animals:
... caught 16 beaver in the SNR02 [a particular type of body snare]. One beaver was eaten by a coyote. One beaver was drown[ed], caused by entanglement. One beaver caught by the neck suffocated. One small beaver caught by the neck and one front leg was dead, probably by suffocation. The other 12 were alive. ... Being a forgiving snare causes the beaver to be quite stressful as it thrashes about considerably bothering other beaver in the area, enough so they avoid the area for some time.
After killing the unfortunate beavers who are still alive in the snares, the carcasses are then sent to be necropsied and rated on a trap injury trauma scale. Hemorrhages and lacerations, regardless of severity, are always considered minor. Eye lacerations and tooth fractures with pulp exposure—which are recognized as extremely painful injuries—are given low values in regard to severity. No consideration is given to the size of the animal, even though a two-centimeter laceration on a two-pound marten may be more critical than on a 40-pound coyote. The trapper submits an invoice to the AFWA and receives a check for his time and expenses for participating in the program.
To date, BMP trap recommendations have been issued for 12 species in the US. Unmodified steel-jaw leghold traps—the very device the EU originally intended to prohibit—are included in the list of traps meeting the BMP criteria for several species, including coyote, bobcat, beaver and river otter. With legholds permitted for select species, who is monitoring to see which species are actually caught in them? A variety of standard neck snares and body-gripping kill traps have also been approved, several of which have been shown in earlier trap research studies to cause severe injuries, pain and trauma.
The BMP trap testing is ostensibly conducted using a 24-hour trap check protocol; however, once the traps are approved, they may be used in states that permit animals to suffer for even longer periods of time, while some states have no mandated trap check time whatsoever. It is during this extended period in a trap that many victims sustain additional injuries as they struggle for freedom.
Although the BMP trap-testing program is in large part federally funded, the government has not allowed public review of the research projects or monitoring of the BMP trap-testing process to this day. Program design and implementation has occurred with no public accountability, transparency or oversight. Moreover, the final BMPs issued are mere recommendations; neither state nor federal wildlife management agencies are required to adopt them as mandatory requirements.
Will Europe Uphold the Ban?
In 2005, the European Parliament, representing the 27 member-nations of the EU, rejected a proposed “Trapping Directive” that would have codified into EU law the AIHTS-based standards for testing animal traps. In rejecting this directive, the European Parliament made a clear statement that the trapping standards annexed to the AIHTS agreement were unacceptably low. Meanwhile, thousands of animals continue to suffer in body-gripping traps and snares throughout North America as part of quasigovernmental trap-testing programs that use standards that have no international recognition or legitimacy.
The jury is out as to how this international trapping debate will unfold. Animal advocacy organizations and independent scientists continue to pressure European legislators to adhere to the original intent of Regulation 3254/91, which was to prohibit the import of wild-caught fur into Europe from countries that continue to use leghold traps. While more than 85 countries have banned or severely restricted use of these traps, the US appears to have no intention of reducing its reliance on them. In a recent trap inventory conducted by the US Department of Agriculture’s Wildlife Services program, the federal agency determined that it has more than 62,000 leghold traps in its possession, which are largely used for predator control, and acknowledges that only 59 percent of them are consistent with BMP trap recommendations. In 2007, the agency trapped and killed close to 12,000 native carnivores in leghold traps, including coyotes, wolves, bobcats and badgers. This figure does not include the many aquatic animals it trapped and killed, such as beaver and muskrat.
It will likely take heightened international exposure of the US BMP trap-testing program for the world to see it for the sham it is. Global pressure will be needed to compel the EU to re-think its weak trapping agreement with the US and ultimately push for an end to the trap that Charles Darwin once described in an 1863 Gardeners’ Chronicle and Agricultural Gazette article as one of the cruelest devices ever invented by man.
Camilla Fox is a wildlife consultant with AWI and a co-editor and lead author of Cull of the Wild: A Contemporary Analysis of Trapping in the United States, available from AWI. She is also a co-producer of the companion film Cull of the Wild: The Truth behind Trapping.
2In 2006 the International Association of Fish and Wildlife Agencies changed its name to the Association of Fish and Wildlife Agencies.
3In EU Regulation 3254/91, 12 North American and one Russian furbearer species were listed. Under the AIHTS, six European species were added for a total of 19 species. Original 13: badger, beaver, bobcat, coyote, ermine, fisher, lynx, marten, muskrat, otter, raccoon, wolf; Russian: sable; European species added: badger, beaver, lynx, otter, pine marten, raccoon dog.
4Harrop, S.R. 2000. The trapping of wild mammals and attempts to legislate for animal suffering in international standards. Journal of Environmental Law, 12:333-360.