Advising the British Columbia Ministry of Environment on
the risk of Zoonotic Disease Transfer as it relates to the
Controlled Alien Species Regulations
598 Policy Report
Candidate: Dr. Jane Vermeulen
Supervisor: Dr. Rebecca Warburton
Second Reader: Dr. Richard Marcy
Chair: Dr. Lindsay Tedds
Client: Jen Smith, British Columbia Ministry of Environment
Defence Date: April 13, 2010
EXECUTIVE SUMMARY
Objective
In the past decade, we have seen diseases such as Avian Influenza, Severe Acute Respiratory Syndrome (SARS) and “Swine Influenza” significantly impact public health and cause global panic. These diseases are classified as zoonoses and represent the newest trends in emerging diseases. Zoonotic diseases are bacterial, viral or parasitic pathogens that can be transmitted from animals to humans. Government agencies have recognized the influence of zoonotic diseases and have responded through updated regulations on the importation of animals. The purpose of this report is to address the regulatory status of the BC Wildlife Act as it pertains to animal species artificially introduced into British Columbia (“alien species”). In May 2008, new legislation was added to the Wildlife Act enabling the BC Minister of Environment to manage alien species according to the amount of risk they pose to human safety, wildlife and wildlife habitat. These species are called Controlled Alien Species (CAS) and owners must apply for a permit to possess these species in British Columbia. The majority of mammalian species on the list were included in recognition of the physical trauma they can inflict on humans. The CAS list was developed through assistance with several stakeholders within the animal welfare community, the veterinary field and pet industry. The goal of the Ministry is to further develop regulations that consider the risk of disease transmission between mammals and humans. The Ministry is interested in classifying zoonoses according to their potential to cause significant morbidity or mortality to humans. The goal is to minimize zoonotic disease transmission to individual pet owners/handlers and the general population. Alien species that carry the potential to transmit a significant zoonotic disease may be placed on the Controlled Alien Species list.Summary of Methods
The current policies regulating non‐native species in British Columbia will be reviewed with a brief history of the Wildlife Act. The presence of non‐native species in North America will be assessed with a focus on their impact on public health and other industries. As zoonoses are not unique to British Columbia or Canada; the international and federal policies that regulate the import of non‐native species into British Columbia will be examined. International agreements and federal agencies regulating animal trade and importation into Canada will also be reviewed.The key stakeholders who have participated in the current regulations of Controlled Alien Species will be examined. Groups such as the Pet Industry Joint Advisory Council of Canada and the BC Society for the Prevention of Cruelty to Animals have partnered with the Ministry of Environment and their recommendations formed the foundation for the current CAS regulations. The impact of amending the CAS list to include species with potential zoonotic risks will also be considered. The report will include a comparison and overview of animal import and trade regulations present in other jurisdictions, including our “neighbors” such as Washington State and Alberta. The regulations are varied and can range from completely prohibiting a non‐native animal from entering to absolutely no regulation. A focus on regulations that recognize zoonoses will also be incorporated. A classification system will be developed to assist the Ministry of Environment to determine which animals should be placed on the Controlled Alien Species list. The report will conclude with recommendations for the BC Ministry of Environment as they update their regulation of Controlled Alien Species. The report will conclude with areas of further research for the Ministry of Environment to consider.
Recommendations
Based on the review of zoonotic diseases that may significantly impact public health and existing regulations, the report makes several recommendations to the BC Ministry of Environment. Recommendation 1: Prohibit the importation, trade and possession of species that are considered at risk for transmitting zoonotic diseases listed as “high risk” to humans. Recommendation 2: Use the Controlled Alien Species regulation to support existing federal regulations restricting the importation of non‐human primates. Recommendation 3: Enforce Controlled Alien Species Regulations as outlined in the Wildlife Act Review. Recommendation 4: Consult with key stakeholders such as veterinary epidemiologists to develop guidelines and recommendations for applicants seeking permits for species that are listed on Controlled Alien Species regulation based on the risk of zoonotic disease.Table of Contents
EXECUTIVE SUMMARY ...2 Objective...2 Summary of Methods...2 Recommendations ...3 TABLE OF CONTENTS...4 LIST OF FIGURES...6 INTRODUCTION ...7 THE CURRENT STATUS OF THE CONTROLLED ALIEN SPECIES REGULATION...9 Fines and penalties ... 10 Response to the Controlled Alien Species regulation... 11 INTERNATIONAL AND FEDERAL REGULATIONS AND POLICY ...12 The Convention of International Trade in Endangered Species of Wild Fauna and Flora (CITES) ... 12 Canadian Food Inspection Agency ... 12 THE SIGNIFICANCE OF NON‐NATIVE SPECIES...14 The Presence of NonNative Species ... 14 Significance of zoonotic disease ... 15 The Cost of zoonotic Disease... 16 KEY STAKEHOLDERS ...17 Pet Industry... 17 British Columbia Society for the Prevention of Cruelty of Animals ... 19 Veterinary Profession... 20 Canadian Association of Zoos and Aquariums... 22Impact of Updated Regulation on Key Stakeholders ... 23 EXAMPLES OF REGULATIONS IN OTHER REGIONS ...24 United States of America... 24 Washington State... 25 Alberta ... 26 Municipalities... 26 CLASSIFYING MAMMALIAN SPECIES BASED ON ZOONOTIC RISK...28 RECOMMENDATIONS ...31 CONCLUSIONS AND FURTHER RESEARCH...33 REFERENCES...34 APPENDICES...39 Appendix A: Wildlife Act, Section 6.46.6... 39 Appendix B: List of prohibited species as recommended by Pet Industry Joint Advisory Council of Canada... 48 Appendix C: Classification system for zoonotic diseases ... 49 Table 1: Significant zoonoses and resultant clinical syndromes in humans...50 Appendix D: Detailed description of selected zoonotic diseases... 51 Appendix E: Proposed Regulation to Include Specific Species ... 54 Non‐Human Primates...54 Bats (Pteropodidae) ...55 Civets and selected members of genus Viverridae...56 Prairie Dogs...56 Non‐native raccoons, raccoon dogs, skunks and foxes...56 Appendix F: Photos of specific mammalian species... 58 Appendix G: Proposed Permit Application Process ... 59
List of Figures
Figure 1: Classification system to assess zoonotic disease risk potential of non‐
INTRODUCTION
The purpose of this report is to address the regulatory status of the BC Wildlife Act as it pertains to animal species artificially introduced into British Columbia (“alien species”). In May 2008, new legislation was added to the Wildlife Act enabling the BC Minister of Environment to manage alien species according to the amount of risk they pose to human safety, wildlife and wildlife habitat. Essentially, three categories were envisioned: prohibited, restricted and monitored. My role in the project will be to assist in the development of the “prohibited” list of alien animal species. My project will build on Sections 6.4‐ 6.6 and 97.71‐ 97.73 of the Wildlife Act as included in Appendix A. The term “prohibited” refers to animals that “pose a serious risk to the health or safety of people”. A species that is classified as “prohibited” may still be allowed to enter or live in British Columbia, but the owner must apply for a permit through the Ministry of Environment. The Ministry of Environment recognizes that several industries such as research and entertainment depend on “alien species” such as monkeys to operate. The permit process is extensive with specific requirements on the husbandry and handling of the animal. The permit lasts for the lifespan of the animal if the conditions established in the approved permit continue to be met. The Ministry of Environment partners with exotic‐animal specialists such as the British Columbia Society for the Protection of Animals (BC SPCA) in the application process. The Ministry of Environment is not able to estimate the number of Controlled Alien Species (CAS) present in British Columbia. Since the introduction of the CAS regulations in March 2009, a total of 52 applications have been received and more are expected as we pass the April 1, 2010 deadline (J. Smith, personal communication, February 2, 2009). Although the current CAS list has facilitated public safety and health, it has not recognized the underlying risk of zoonotic disease. Zoonoses or zoonotic diseases are defined as diseases transmitted from animals to humans. These may include bacterial, viral, prion or parasitic agents. The goal of the Ministry is to develop regulation that considers the risk of disease transmission between mammals and humans and protect both the individual pet owner/handlers and the general population. The list focuses primarily on mammals due to their close contact with humans and also the severity of mammalian‐related zoonotic diseases. Although zoonoses associated with animal products, such as hides, have been reported, this report will focus strictly on live animals. The report will begin with a review of the current regulations and offer comparisons to other jurisdictions, both internationally and locally. The key stakeholders involved in the implementation of the current Controlled Alien Species regulation will be examined. The impact of the proposedrecommendations on the stakeholders will also be reviewed. A flow chart has been developed to assist the Ministry of Environment with classifying non‐ native mammalian species based on their risk of transmitting a zoonotic disease. Finally, the report will conclude with recommendations to expand the Controlled Alien Species regulations. Areas of further research will be examined as the report acknowledges the unpredictable and changing nature of zoonoses.
THE CURRENT STATUS OF THE CONTROLLED ALIEN SPECIES
REGULATION
In March 2009, the British Columbia Ministry of Environment released the Controlled Alien Species regulation that limits the possession of exotic and non‐native species that are considered to pose a lethal or serious threat to the public. These species are termed “alien” as they refer specifically to animals that are not native to British Columbia. These species can be differentiated from “wildlife species” that are defined by the BC Wildlife Act as “all native and some non‐native amphibians, reptiles, birds, and mammals that live in B.C” (Wildife in BC, Ministry of Environment, nd). In the past, there were many “loopholes” that allowed potential owners to introduce non‐native species into British Columbia. For example, non‐native species that were “captive bred” in Canada did not fall under international or federal agreements and were free to cross provincial borders. The regulation was developed following several incidents involving human injury or death that highlighted the lack of legislation regarding exotic pets. Internationally, the mauling of a Connecticut woman by a “pet chimpanzee” in February 2009 demonstrated the dangers associated with owning an alien species (Lisi, 2009). In the Highlands, near Victoria, there has been a concern regarding “Suzy”, a two‐year‐old tiger living in a fenced enclosure on a private property. The municipality quickly passed a bylaw in an attempt to ban her arrival, however; the issue eventually ended up in the courts with no clear resolution (Pearson, 2009). As one of the oldest pieces of legislation in BC, the Wildlife Act was written in 1859 and the authors could not have imagined how global the pet and wildlife trade could become. The original document focused on “birds and beasts of game” and regulation was restricted to animals and fish that roam wild in British Columbia. The original document excluded species that were non‐ native or “alien” so there was no regulation of animals such as tigers, alligators or even many companion animals (Preserve and Protect, 2008). The need for provincial regulation prompted the Ministry of Environment to create the Controlled Alien Species regulation. The regulations contain a list of prohibited non‐native species that pose a potential risk to humans based on physical trauma (Appendix A). The Wildlife Act review process began in November 2004 and concluded in 2008. The mandate of the Ministry of Environment when modifying the Wildlife Act stated (Wildlife Act Review – Ministry of Environment, nd): The provincial government has the responsibility of ensuring public safety and the listed animals pose a serious risk to that safety. The regulation protects the public while also ensuring that recognized institutions cancontinue to possess these animals. The BC SPCA, the Union of BC Municipalities and the Office of the Chief Coroner all requested the control of alien species. The goal was not to regulate all alien species, just those that were considered a risk. The list encompassed roughly 1, 250 species ranging from anacondas to foxes. The regulations were not just centered on possession but also included breeding, release, selling and transport (Preserve and Protect, 2008). The wording of the legislation is key to understanding the purpose of the Controlled Alien Species regulations. As stated in the legislation (Wildlife Act Review – Ministry of Environment, nd): If the minister considers that a non‐native species described in paragraph (a) or (b) of the definition of "species" poses a risk to the health or safety of any person or poses a risk to property, wildlife or wildlife habitat, the minister may make regulations designating the species as a controlled alien species. It is important to note that the regulation was only if the Minister considered a non‐native species to pose a risk to the health or safety of any person, or poses a risk to property, wildlife or wildlife habitat. The provisions in the Wildlife Act included granting emergency powers to wildlife officers to enter properties to investigate cases of diseased exotic species, authorizing the Minister to manage species that “pose an immediate disease threat” and to “control possession and use of live alien or exotic species” (Wildlife Act Review, nd).
Fines and penalties
The Controlled Alien Species regulation enables Conservation Officers and constables to seize and possibly destroy a species described as “prohibited” if the permit requirements are not met (“To Preserve and Protect”, 2008). The current penalties established through the Controlled Alien Species regulation include fines and imprisonment (Wildlife Act Review – Ministry of Environment, nd). The penalties associated with breeding and releasing for a first time offender are: • fines ranging from $2500 to a maximum of $250,000 or • a term of imprisonment not exceeding two years; or • both a fine and a sentence. The penalties for possession without a permit for a first time offender are: • fines up to a maximum of $100,000; or • a term of imprisonment of one year; or• both a fine and a sentence.
Response to the Controlled Alien Species regulation
The response to the recent Controlled Alien Species list has been mixed with some applauding the move to protect public health and others feeling that the list was an over ‐reaction to a few isolated incidents. The BC Society for the Protection of Animals (SPCA), Pet Industry Joint Advisory Council (PIJAC) of Canada and the Canadian Association of Zoos and Aquariums (CAZA) are key stakeholders that support the CAS Regulation. Animal welfare groups such as the SPCA are pleased that the CAS permits required applicants to describe their species enclosure and animal welfare plans (“BC SPCA applauds”, 2009). However, a web‐site review indicated that many owners of exotic pets are angered at the legislation and cite “drug gangs, booze and guns” as posing more danger than a fennec fox (a small fox weighing less than a cat). Particularly vocal are the reptile owners. For example, the BC Reptile Club (BCRC) has stated that they do not support the regulation and feel that it will negatively and unfairly impact reptile owners (Letts, 2009). Opponents of the Controlled Alien Species regulation state several reasons for disagreeing with the animals included in the list. Although most agree that species such as tigers and bears should not be allowed as companion pets, other animals such as Fennec foxes pose minimal threat to human safety if appropriately housed. Several readers stated that the list appeared “poached” from Alberta and was not thoroughly researched. Some groups, including the BCRC state that they had been promised involvement in the development of the list and are now displeased that their input was not sought. There was also concern that the legislation would “frighten” owners into abandoning their prohibited species. Finally, many readers objected to the exclusion of other species such as scorpions, zebras and octopi (Letts, 2009). Although the new regulation represents advancement in the management of alien species, it also introduces new challenges such as enforcement. For example, Tony Vecchio, a former board member with the Association of Zoos and Aquariums stated at the BC SPCA Exotics Symposium in 2008 that “legislation is not the answer but still critical”, as enforcing regulations can be difficult and costly (p.5). There is also concern that priorities may change as governments change. Creating and enforcing regulation may be a priority now, but governments set their own agendas and the CAS list may not carry the same weight for future governments (To preserve and protect, 2008).INTERNATIONAL AND FEDERAL REGULATIONS AND POLICY
The importation of a non‐native species from outside Canada into British Columbia is an extensive process with permits and restrictions ranging from the international level to municipality restrictions. The following section will highlight the restrictions and guidelines that a potential exotic –animal owner would have to acknowledge as they import an animal into a specific municipality in British Columbia.The Convention of International Trade in Endangered Species of Wild
Fauna and Flora (CITES)
The Convention of International Trade in Endangered Species of Wild Fauna and Flora (CITES) refers to an international agreement between governments, including Canada, to assure that the international trade of wild animals and plants does not negatively impact their survival. The agreement was developed to recognize and address concerns for the multi‐billion dollar industry of wildlife (live species and their by‐products) and to minimize risk of endangerment. Formalized in 1975, CITES now has 175 member countries who have voluntarily committed to ensure that their national and domestic laws comply with the CITES agreement. The list is extensive with over 5000 animal species recognized, including recommendations dependant on specific countries and also the global population of an animal (CITES, nd). Canada is a signatory of CITES with the purpose of restricting the trade of endangered species. Environment Canada is the lead agency responsible for implementing the regulations established in CITES. However, much of the selling and trade of exotic pets occur illegally or through the black market so it can be difficult to enforce such regulations. As the purpose of CITES is to protect endangered species, there is little focus on the risks of zoonotic disease or banning trade based on this criteria, however; it is another tool that can be used to restrict ownership of certain species. CITES does not impact non‐native animals that have been captive‐bred within Canada and able to move provincially, unless that animal is to be exported out of Canada (CITES, nd).Canadian Food Inspection Agency
The Canadian Food Inspection Agency (CFIA) is the federal agency responsible for ensuring that the Government of Canada’s goals of reducing public health risks from zoonoses are met. As their mission statement cites, they are “dedicated to safeguarding food, animals and plants, which enhances the health and well‐ being of Canada’s people, environment and economy” (Vision, Mission and Values, nd). One of their mandates is to protect and strengthen our borders to minimize the transport of illegal species into Canada. They are considered the “lead agency” in the development of procedures and protocols to manage zoonoses at a national level (Lang, 2009). Their regulations include restrictions on transport/ importation of primates and investigation into reportable diseases.The 2009‐2010 Corporate Business Plan highlights the commitment the CFIA has stated towards preventing zoonoses and mitigating the impact on public health. Their current budget has allocated 75 million dollars per year until 2012 with a stated target of ensuring “no Canadians become infected with federally controlled zoonotic disease by direct contact with animals or their products”. The CFIA partners with other international and national agencies such as the Canadian Animal Health Surveillance Network and the World Organization for Animal Health (OIE) to improve surveillance and knowledge of zoonotic disease (Corporate business plan, nd.). At a provincial and federal level, the overlap in regulation generally benefits the public in terms of increased surveillance and regulation, but there are instances where conflict arises between the two levels. The Canadian Food Inspection Agency acknowledges that provincial requirements for importing pets may differ between provinces and potential owners should consult with provinces and municipalities before importation of specific species (Foxes, Skunks, Raccoons, nd).
THE SIGNIFICANCE OF NON‐NATIVE SPECIES
We have seen an increase in non‐native species in research, commercial usage and private ownership. Smaller mammals such as capuchin monkeys, Fennec foxes and hedgehogs that were once considered strictly “wild animals” are now becoming domesticated and promoted as family pets. However, these species have now introduced diseases to native animal populations and humans (Locke and Wines, 2004). The impact of zoonoses can be felt through multiple sectors ranging from agriculture to public health.The Presence of Non‐Native Species
The results of 2001 survey of the American Veterinary Medical Association indicated that 13.1% of households in the United States included an exotic pet. The most prevalent species included fish, rabbits, guinea pigs and turtles (Locke, 2004). Other reports focused specifically on “wild” animals have demonstrated the growing prevalence in the United States. It is difficult to predict the trends of non‐native or alien species. Although shocking, reports of monkeys escaping or running rampant in grocery stores have occurred in the past (“Monkeys as pets”, nd). The Captive Wild Animal Protection Coalition estimated more than 5,000 tigers in the United States and at least 3,000 Great Apes were kept in captivity. Globally, more than 300 million live animals are traded, often illegally, in an industry worth up to 20 billion dollars (Freedom Fauna, 2009). In terms of importation, the reasons for bringing non‐native species into British Columbia vary. There is a thriving entertainment industry in British Columbia and the application for permit even has a separate section for the film industry (Wildife in BC, nd). Exotic animals are not used exclusively as pets but are also used as guard animals of grow‐ops and roadside attractions. In the United States, the most common purpose for importation was commercial use such as pet trade or traditional medicine and this accounted for 66% of the total percentage of animals imported. Following second at 28% of total imports were animals imported for biomedical research. The remaining imports were for animals introduced for breeding, zoos and personal uses. The five most common species imported into the United States included long‐tailed macaques (greater than 50% of all imported individuals), small desert hamsters, rhesus macaques, raccoons and chinchillas (Pavlin, Schloegel and Daszak, 2009). The survival rate for exotic pets is significantly lower than their domesticated counterparts and one report cited that 60% of all wild animals kept as “pets” die within their first months of ownership with only 10% alive after their second year (Freedom Fauna, 2009). The most common countries of origin included the People’s Republic of China, Guyana, United Kingdom, Vietnam and Indonesia. However, it must be noted that animals can be imported and then re‐exported with their “true origin” becoming blurred. From a zoonoses control and surveillance standpoint, it isimportant to note whether the species was “wild caught” or “captive ‐bred”. It is assumed that animals that are captive‐ bred carry less risk of harbouring a zoonotic disease than their wild‐caught counterparts (Pavlin et al., 2009) as their environment is more controlled with less interaction. Regardless of the origin of the alien species, the emergence of zoonotic disease within all populations has prompted further investigation into means of reducing the risk of transmission to humans.
Significance of zoonotic disease
Although we are familiar with the more “dramatic” zoonotic diseases such as rabies and ebola, diseases such as salmonellosis and Herpes‐B virus can cause significant public health and economic impacts (Chomel, Belotto and Meslin, 2007). One of the greatest challenges facing federal and provincial legislators is determining how significant the risk of zoonotic disease can be. Complicating the issue is that there is often confusion regarding the mode of transmission between humans and animals. For example, is the transmission through direct contact, aerosolisation (spread via “fine mist”) or ingestion of contaminated meat? The inability to understand the transmission of disease remains a hindrance for predicting the impact of a zoonotic disease (Murphy, 1998). The scientific community has long recognized the use of zoonotic diseases as markers of public health, however; the level of education and training has not caught up with this need. Interestingly, epidemiologists have been predicting the impact of zoonoses in Canada as stated in 2004 (Stephen, Artsob, Bowie, Drebot, Fraser, Leighton, Morshed, Ong and Patrick): As we saw with SARS and HIV, and can expect to see with pandemic influenza, new diseases are most likely to arise outside of Canada, but reach Canada rapidly. This statement is over five years old, however; it reflects the emerging importance placed on the prevention and identification of zoonotic disease. The goal for the federal government is to transition Canada from a “reactive” mode of merely responding to the devastating impact of zoonotic disease to a more “proactive” approach of recognizing and preparing for a pandemic (Stephen et al, 2004). Funding and legislation has been difficult to secure as zoonotic diseases often crosses multiple sectors such as veterinary medicine, public health and academia. Furthermore, in the past, the media reports often focused on the more “gruesome” aspects of animal –human interactions such as bites and mauling. Public health and zoonotic disease were often treated secondary to the physical interactions between humans and animals. However, as the prevalence of zoonotic disease increases, the public demand for government intervention will also increase (Murphy, 2008).The Cost of zoonotic Disease
The statistics outlining the cost of zoonotic disease vary greatly and it is difficult to differentiate between zoonotic diseases of native species compared to alien species. For example, the beef industry in the United States suffered a loss of 11 billion in over 3 years due to the detection and Bovine Spongiform Encephalopathy (Sustaining Global Surveillance, 2009). In Canada, the impact of zoonotic disease has greatly affected the swine, chicken and cattle industry, with one estimate predicting costs over 1 billion dollars annually. In 2003, the impact of zoonotic diseases reduced the federal spending and economic surplus. The impact of zoonotic disease can be felt across many sectors including tourism, research and food production (Stephen et al, 2004). The recent outbreak of H1N1 has demonstrated how one disease can influence the global economy. The difficulties for estimating the impact of zoonotic disease arise for several reasons. Only a select group of zoonotic diseases are “reportable”, such as plague, rabies and brucellosis. There is also the challenge of “shared symptoms” as some zoonotic diseases may share clinical syndromes with other diseases. For example, parasitic diseases causing digestive upset may be shared with other common water‐borne disease. Zoonotic diseases may also be difficult to diagnosis and require expensive laboratory testing that may not be readily available (“The Control of Neglected”, 2005). Although we cannot always determine an exact dollar value when calculating the cost of zoonoses, the events of the past decade have shown how crippling a zoonotic disease can be to a country’s economy.KEY STAKEHOLDERS
As the development of the Controlled Alien Species list demonstrated, the trade and possession of non‐native species does not simply impact owners. As stated by Clarke (2009), the failure to include stakeholders in the development of zoonotic and wildlife disease management can “potentially trigger backlash, in terms of opposition to specific policies” (p. 316). The goal is to build consensus within the stakeholder groups and create an approach that allows impacted groups and agencies to participate and support the development of an expanded Controlled Alien Species list. The key stakeholders impacted include the pet industry, the veterinary community, the BCSPCA and members of the Canadian Association of Zoos and Aquariums. The stakeholders not only collaborated with the implementation of the current Controlled Alien Species regulation, but are also active partners in the application process. The permit process involves several steps including review by an adjudication committee to ensure that minimum standards of animal care and safety are being met. For example, the permit has requirements for housing and care that may be assessed by the SPCA. The committee members operate on a strictly volunteer basis at this time. The recommendations to expand the CAS regulations to regulate species based on zoonotic potential will also impact the key stakeholders, both negatively and positively.Pet Industry
The pet industry is a key stakeholder in the possession and breeding of exotic animals. Determining the participants of the exotic pet trade is difficult as much of the selling, trading and transporting is done “underground” through the Internet. An Internet search by the Washington State Board of Health in 2004 found the following species listed for sale/trade: sugargliders, degus, Brazillian short‐tailed opossums, chinchillas, hedgehogs and even a wallaby. Several of these species are illegal to trade and possess in Washington State, but their availability for trade and possession demonstrates the significance of the underground market (Locke, 2004). It is unlikely that the underground trade will voluntarily participate in the exotic pet regulation, however; the entire pet industry will be impacted, regardless of whether they operate legally or illegally. As stated in a 1997 report from the Public Health Agency of Canada, the pet industry plays a large role in the “trends” of exotic pet species. The report cited the prevalence of African pygmy hedgehogs in Canada and the emergence of Salmonella tilene as an example of the role that the pet industry plays in the introduction of exotic pets. Pygmy hedgehogs were first imported into Alberta in 1992 and were sold for over $1000. Several years later, as the trends moved away from hedgehogs, a breeding pair could be purchased for under $20. However, during that time, Salmonella serotype Tilene was introducedinto Canada and lead to clinical signs in several families. (“Africa pygmy hedgehog”, 1997). The opinions of the exotic pet industry often differ greatly from public health and veterinary agencies. Many members of the exotic pet trade feel that they are valuable partners in the welfare and conservation of the exotic species. They contend that the growth of their industry provides “in demand” species that might otherwise be sought in the wild. They are opposed to regulation prohibiting ownership of exotic pets, however; they do agree with regulatory programs directed towards “point of sale” education to inform potential owners of zoonotic disease (Locke, 2004). Nationally, the Pet Industry Joint Advisory Council (PIJAC) is a voluntary, non‐ profit organization representing the pet industry in Canada. PIJAC was developed in 1988 in response to the growing trend of exotic pets in Toronto. Formed by members of the pet industry, they developed the first prohibitive species list in Canada (Appendix B). In personal communication with Louis McCann, Executive Director (February, 2009), it is evident that PIJAC and the pet industry in general wishes to ensure the welfare of exotic pets and also minimize public health risks. He stated that exotic animals have a niche in the pet community. For example, individuals with allergies to animal fur have been able to experience the joys of pet ownership through ownership of birds and reptiles. In larger cities such as Vancouver and Toronto where condo developments dominate, exotic pets allow condo dwellers to “bypass” the pet restriction. He states that it is not the goal of the pet industry to introduce new “non‐native” or hybrid species. PIJAC supports the sale of captive bred animals versus animals captured from the wild. They state that captive‐bred animals are friendlier and easier to handle for retailers and pet owners (“Common arguments”, nd). The Pet Industry Joint Advisory Council of Canada has been cooperating and participating with multiple levels of government to create a partnership to protect both business and government interests. In the past, PIJAC has developed bylaw templates to assist lawmakers at the municipal level. This collaboration resulted in the first “prohibitive species list” in Canada. The pet industry routinely advocates for pet ‐store owners, breeders and exotic pet owners. As part of their argument, they state that exotic pets carry less risk of transmitting zoonotic diseases compared to their more “traditional” counterparts (Pets can Stay, 2008). Although PIJAC has been active in promoting the appropriate care of exotic pets, they also carry a vested interest in protecting the pet‐store industry. As stated in their 2008 mission statement (Pets can Stay): First, PIJAC Canada advocates on behalf of pet industry businesses when municipal, provincial or federal governments are poised to make decisions that can affect their way of life or the very survival of their business.
According to PIJAC, many of the arguments used to prohibit exotic animals, such as lack of adequate owner‐knowledge and poor medical care are no longer valid (McCann, personal communication, 2009) They cite the amount of dogs and cats in shelters as evidence that it is not the species of pet, rather; the commitment and education of the owner that determines how well an animal will be cared for. Furthermore, PIJAC actively promotes the use of captive breeding programs to ensure that animals are not captured from the wild. They state that many hobbyists can provide viable partnerships to help maintain species that may be endangered or at‐risk in the wild. Finally, they state that the incidence of zoonotic disease transmission does not merit the restriction or prohibition of particular species (“Common arguments”, nd). The Pet Industry Joint Advisory Council debated forming a “permitted species” list, however; they felt that the ongoing introduction of new species would become a “logistical nightmare” requiring constant upgrading. PIJAC has supported the development of the Controlled Alien Species list and their list of “suggested prohibited” species has formed the cornerstone for the Ministry of Environment as they develop the Controlled Alien Species regulation. The list is focused primarily on species that can cause extensive physical trauma such as tigers and bears. As the Controlled Alien Species list continues to be updated, PIJAC will be consulted to assist in adjudicating the permit application and also provide insight into future recommendations.
British Columbia Society for the Prevention of Cruelty of Animals
The BC SPCA has been actively engaged in the implementation of regulations to restrict the ownership of exotic animals. Their website lists that 8% of cruelty cases in the past year involved exotic pets ranging from parrots to monkeys. They are opposed to the breeding and keeping of “exotic or wild” animals (including hybrids) as well as commercial trade and importation. The BC SPCA is responsible for ensuring the welfare of all animals in captivity; however, their scope does not include protecting public health (Exotic Animal Legislation, nd). The lack of legislation was evident in the tiger –mauling incident in 100 Mile House. A “captive tiger” killed a 32‐year old woman in the presence of her children. The owner of the tiger had been under the “microscope” of the SPCA for several years, as he had several tigers and lions on his property. The lack of legislation limited the SPCA abilities to remove or regulate the animals (“Woman mauled to death by tiger”, 2007) As proponents of animal welfare, they felt that the lack of provincial regulation allowed inexperienced and unqualified individuals to own exotic pets that may be a risk to public health. They are also critical of provincial municipal laws that focus primarily on the human health aspect without regard to animal welfare. Their recommendations included developing a definition of “wildlife” and “domestic animals” to better differentiate ownership status. They strongly support programs focused on education and increasing awareness of the risks of owning exotic pets. As stated in “Preserve and Protect” (2008)The BC SPCA firmly believes in seeking science‐based and public education alternatives to reduce the negative impact of non‐native species rather than lethal means. The BC SPCA supported the development of the Controlled Alien Species list. A press release dated March 17, 2009 (“BC SPCA applauds”) from the BC SPCA states that they “applaud the provincial government’s announcement of new regulations that will monitor the keeping and breeding of exotic wild animals”. In the release, they highlighted that their special constables were often called to investigate situations involving exotic pets that were improperly managed; however, the constables did not have legislative authority to support their recommendations. The BC SPCA did express concern that several species such as kangaroos and zebras were not included but may need monitoring. There was also concern that the regulation may cause some pet owners to “panic” and release or abandon their pets that fall under the CAS regulation (“BC SPCA applauds”, 2009). Although the CAS regulations specify that current pet owners do not need to surrender their pets, other non‐profit organizations cite this concern when opposing the regulation.
Veterinary Profession
Members of the veterinary community have become actively involved in the prevention and management of zoonotic diseases. Veterinarians carry a unique skill set and are trained in comparative medicine. As stated by King (2006), veterinarians are trained in a different manner than their “counterparts in human medicine” with a focus on multiple species. Dr. Amy Worrell echoed this sentiment in 1999: Veterinarians treating exotic animals should be aware that physicians may be uninformed as to the zoonotic conditions affecting commonly kept exotics and that the animal’s owner themselves often are poorly informed as to the zoonotic disease potentially housed in their pets. The concept of “one medicine” or the collaboration between the medical and veterinary medical field was first proposed in the 19th century but had fallen out of favour in the latter part of the 20th century. However, with outbreaks of SARS, avian influenza and West Nile virus, there has been resurgence in the demand for veterinarians in public health sectors. As the incidence of zoonotic diseases rise, the need for veterinarians to interact and communicate within the infectious ‐disease community will continue to increase. Kahn (2006) has condemned the American Veterinary Medical Association (AVMA) for being “lackadaisical regarding strong efforts to engage in active dialogue” with the human medical field but expressed hope following the 2006 AVMA annual conference as the AVMA president endorsed the concept of “one health”.Multiple research groups have stated the need to form an advisory group to address the expanding and global nature of zoonotic diseases (Chomel et al, 2007). King (2006) highlighted the increasing role of veterinarians at the Center for Disease Control as a natural progression given the increased surveillance and focus on zoonotic disease. Veterinarians act as “epidemiologists, laboratory scientists, policy makers, researchers and surveillance experts” (King, 2006). At a municipal and provincial level, veterinarians are needed to assist in the recognition and management of zoonotic diseases in pets, such as rabies, salmonella and campylobacter. Often, a veterinarian will be the first to recognize the early signs of a zoonotic disease and will be in a position to diagnosis and report a zoonotic disease before it spreads to humans. As a veterinarian myself, I am exposed to exotic pets and have been proactive in educating myself on the risks of zoonotic disease. Unfortunately, I have also discovered that the medical profession is often lacking in such training and pet owners may turn to the Internet and other pet owners for advice. As veterinary students are overwhelmed with the amount of material required to pass their exams, there is often little time or resources to focus on one species or group. Exotic species such as birds and reptiles are often referred to larger cities where veterinarians can become more species‐specific but this is often a luxury not available in rural and smaller cities. However, as Dr. Johnson – Delaney stated at the BC SPCA Exotics Symposium (Preserve and Protect, 2008), there are very few veterinarians that are trained appropriately and adequately with a clinic setting established for exotic species. From an ethical aspect, veterinarians may be asked to treat species that are prohibited but in need of medical attention. Owners may also be reluctant to pursue diagnostics or treatment if their pet is prohibited and they do not have the appropriate permit. This may represent a public health risk if the animal suffers from a zoonotic disease and the owners do not seek expert knowledge (Preserve and Protect, 2008). The veterinary profession has acknowledged the demand for exotic and alien species as pets. In July 2004, the Canadian Veterinary Medical Association affirmed their stance against the capture of wild animals and stated (“Capture of wild animals”, 2004): Those animals that survive capture and transport are often unable to acclimatize fully to captivity, and will not adapt and become good pets. Information on the optimum care and feeding of many wild animal species is not readily available; therefore, the keeping of these animals as pets often results in unnecessary suffering and premature death. For these reasons, along with potential danger and public health concerns with some exotic pets, the CVMA cannot condone the trade in captured wild animals as pets.
In general, the veterinary community is united in their recommendations of ownership of exotic pets, particularly wild animals. For example, the American Veterinary Medical Association, The National Association of State Public Health Veterinarians, The Humane Society of the United States and the Association of Wildlife Veterinarians are united in their stance against ownership of exotic wild animals. They feel that the level of education and resources required to safely and effectively manage wild animal greatly exceeds the capabilities of most private pet owners (Locke, 2004). The Canadian Veterinary Medical Association has not made a formal statement about the Controlled Alien Species list or other regulation specific to government involvement or intervention of non‐native species. The Ministry of Environment Provincial Veterinarian has served as the veterinary consultant in the development of the Controlled Alien Species list and has also informed members of the British Columbia Veterinary Medical Association of the updated regulations.
Canadian Association of Zoos and Aquariums
The Canadian Association of Zoos and Aquariums (CAZA) is a non‐profit, voluntary organization representing zoos and aquariums across Canada. Formed in 1975, their goal is to promote animal welfare through “conservation, science and education”. With a focus on education, they estimate that over 11 million annual visitors benefit from visits to accredited zoos and aquariums within Canada. The association also supports standardized professional conduct and accreditation programs. They do not support possessing wildlife or exotic species for commercial usage and feel any net profits should be directed towards education and conservation (Canadian Association of Zoos and Aquariums, nd). The organization recognizes the value of human and animal contact and states that such interactions can “provide a valuable educational experience for visitors and participants” (“Canadian Association of Zoos and Aquariums, 2008). However, they also acknowledge the risk of disease transmission but feel this risk can be minimized through appropriate quarantine programs and sanitation techniques. Presently, their policy specifications state nine mandatory steps that must be incorporated for a facility to provide human – animal contact. These include routine health checks of animals and adequate sanitation stations (CAZA Position, 2008). Zoos and educational institutes are impacted by regulations created through the Controlled Alien Species list and will be required to obtain permits to breed and transport alien species. Permits will be required after March 31, 2009 and permit applicants claiming to be “zoos” will also be required to seek accreditation through CAZA (Wildife Act Review, nd).Impact of Updated Regulation on Key Stakeholders
The Controlled Alien Species regulation have been supported and endorsed by PIJAC, CAZA and animal welfare groups. The literature from PIJAC indicates that the pet industry supports the safe and healthy handling of exotic pets and is not interested in introducing new or hybrid species that may harm pet owners (L. McCann, personal communication, February 2009). However, PIJAC is a voluntary association representing pet retail stores and recognized sellers. Individuals or groups that are actively breeding, trading or selling species that may be prohibited based on the proposed guidelines will be negatively impacted due to a loss of income and livelihood. It is difficult to assess how expanded regulations will impact the veterinary community. As “experts” of animal disease, veterinarians will also be expected to participate in diagnosing, reporting and providing assistance in cases where high‐ risk zoonoses have been detected (Preserve and Protect, 2008). Such responsibilities would likely fall under the umbrella of the Canadian Food Inspection Agency and their veterinarians (Vision, Mission and Values, nd). Concern has been expressed in the past that new regulations may place a veterinarian in a “conflicting” situation if an owner brings in a “prohibited species” without the appropriate permit (Preserve and Protect, 2008). Individuals or groups that are actively seeking to keep or import a Controlled Alien Species into British Columbia will feel the greatest impact. The regulations will affect research, film and pet industries that rely on particular species. The permit application represents another step of bringing or keeping the animal in British Columbia and the time required for the permit to be approved will have to be incorporated into planning timelines. As discussed in the previous section, facilities that wish to display Controlled Alien Species to the public will have to seek accreditation with the Canadian Association of Zoos and Aquarium to fulfill permit requirements.
EXAMPLES OF REGULATIONS IN OTHER REGIONS
As the impact of zoonoses have become more recognized nationally and internationally, other provinces and countries have begun to develop regulations to prevent and mitigate zoonotic disease. It is interesting to note how other jurisdictions manage the challenges of alien species and the means of regulation. As we make amendments to the Controlled Alien Species list, we must also acknowledge and examine the regulations of our “neighbors” as they will likely be sources of non‐native species. For example, Washington State has been very pro‐active in their recommendations to manage non‐native species, whereas other states have been more relaxed. The literature review indicated that very few jurisdictions have developed regulations to proactively prohibit a species based solely on the risk of zoonotic disease transmission.United States of America
There is wide variation in the regulation of exotic pets, as highlighted during the monkeypox outbreak of 2003. Monkeypox was introduced to the United States through importation of infected rodents from Africa. The infected rats transmitted the viral disease to prairie dogs that were intended for exotic animal trade. The prairie dogs then transmitted the disease to humans with resulting flu‐like syndromes. In total, the Centers for Disease Control and Prevention reported 72 suspected cases in six states (Leibman, 2004). The monkeypox outbreak provided the stimulus needed to acknowledge the risks of owning an exotic pet and the need for regulation to control the importation of exotic animals. Nationally, the government is limited in their scope and their influence is primarily restricted to interstate commerce. Law‐making pertaining to the ownership of exotic animals is delegated to state and local laws. In 2003, several bills were enacted to address exotic pet ownership but at the time of the monkeypox outbreak, none had been signed into law (Madigan, 2003). For many states, the monkeypox outbreak provided a means of demonstrating the importance of legislation to regulate exotic pets. For example, Minnesota senator Don Betzold had attempted to introduce regulation to ban exotic animals but was repeatedly denied due to budgetary constraints (Madigan, 2003). In general, state and local governments have police power that “allows them to legislate for the general welfare” of animals (Leibman, 2004). Regulations extending towards pet ownership also differ greatly across the United States ranging from complete prohibition of exotic wild animals to some regulation. For example, Massachusetts outlines strict guidelines for the possession of wild animals, such that the animal must not require any care “greater than the average domestic animal” and the animal must not pose any risks to theowner, other animals or their environment (Leibman, 2004). Essentially, it is not possible for a private individual to own an exotic animal. Other states such as Illinois and Indiana actively regulated the movement and sale of prairie dogs before the Centers for Disease Control (CDC) and the Food and Drug Administration (FDA) listed their recommendations restricting rodents as pets. This differs from other states that waited until recommendations were listed from the FDA (Locke, 2004). Although only 12 states completely prohibit wild animals based on the “claws and jaws” principle, the remaining states have some regulation on the private possession of wild animals. This may include licensing the wild animal or seeking a health certificate upon entrance into the state (Locke, 2004). Following the monkeypox outbreak, several states began arguing for a federal regulation to control exotic pet ownership. Lawmakers cited the relative ease of importing exotic animals as cause for a national legislation to limit exotic pets (Madigan, 2003). The incident in February 2009 involving the Connecticut woman who was viciously attacked by a “pet chimpanzee” also prompted Congress to act swiftly to halt interstate trade of apes and monkeys (Lisi, 2009). This was the congress’ second attempt to pass such legislation but previous tries were stalled in Senate. Congress cited the 40 incidents involving humans injured by primates as reasons to legislate the movement across states (Madigan, 2003). As the monkeypox outbreak and the chimpanzee‐mauling incident demonstrate, the majority of regulations and policy were generally enacted in response to a disease outbreak or physical attack. Very few states have been “pro‐active” in developing regulations restricting exotic‐pet ownership.
Washington State
Washington State has been pro‐active in their regulation of exotic pets and “alien species” with particular focus on public health and zoonoses. A working group comprised of the Department of Health, local public health jurisdictions and the State Board of Health was created to address the exotic pet trade in Washington. In Washington State, the zoonotic diseases that have been noted in the past include tularemia, hanta virus pulmonary syndrome, plague, psittacosis and rabies (Locke, 2004). In October 2004, The Washington State Board of Health prepared a document outlining the emerging public health risks associated with exotic species. An outbreak of monkeypox prompted the public health agencies of Washington State to examine their level of authority and what steps could be taken to reduce the risks of transmission of zoonotic disease. A review of local, state and federal laws demonstrated a significant variation of laws pertaining to pet ownership with minimal recognition of the risks of zoonotic disease except rabies and psittacosis. The report also indicated that animal control officersand exotic pet veterinarians provided more information on the incidence of zoonotic disease transmission than public health authorities (Locke, 2004). The goal for the Washington State joint working group was to develop recommendations to minimize the risk of zoonotic disease transmission between pet owners and exotic pets. The recommendations from the joint advisory group included increased surveillance and data collection with the goal of creating a “working definition of exotic pet” (Locke, 2004, p.2). Since July 2007, Washington State has placed strict legislation on the private ownership of potentially dangerous animals such as bears or wolves (“Summary of state laws”, nd). There does not appear to be a particular focus on physical trauma versus zoonotic disease transmission; however, the working groups would like to further pursue regulations focused on minimizing zoonoses (Locke, 2004).
Alberta
As discussed earlier, the recent Controlled Alien Species regulation in BC referred to the pre‐existing Alberta Controlled Animal Regulation as a point of reference to guide the types of animals listed in Schedule 1 of the CAS regulations. The presence of roadside zoos and inadequate facilities prompted several provinces, including Alberta to examine their current regulation of “zoo facilities” and non‐native species. In 2006, Alberta introduced a set of standards to ensure that “zoo facilities” provide the same standard of care to protect both animals and the public. Requirements were established for transportation, conservation education and “visitor and zoo staff safety”. Other departments that have partnered to regulate zoos include Alberta’s Sustainable Resource Development, the Alberta SPCA and municipal governments that provide development permits to individuals interested in establishing zoos (“Zoo Standards”, nd). When Alberta introduced their regulations, about 1200 permits were issued. Alberta has not developed specific regulation based solely on the risk of transmitting a zoonotic disease.Municipalities
The Union of BC Municipalities supported the development of the prohibited species list and the amendments to the Wildlife Act. In September 2007, the Union of BC Municipalities gathered in Vancouver and expressed concern that the current Wildlife Act did not recognize exotic animals as “wildlife” and this limited their regulatory ability. They stated (Annual Convention of BC Municipalities, 2007, p.45): when making amendments to the Wildlife Act, (we ask) the Ministry of Environment specifically regulate the keep and sale of exotic animals in BC by including a list of exotic animals that are prohibited for keeping or sale in BC.Historically, cities in British Columbia have been pioneers of regulations restricting the sale and ownership of exotic pets. In 1994, Langley became the first community to place restrictions on the selling and keeping of certain exotic pets. Locally, Saanich was at the forefront of exotic pet regulations when they became the first jurisdiction in Canada to pass a bylaw to prevent “circus animals” from performing on city property (Freedom Fauna, nd). The new Controlled Alien Species regulation provides a harmonized province‐wide approach for controlling dangerous exotic animals while enabling municipalities within BC to have more restrictive by‐laws if the choose.
CLASSIFYING MAMMALIAN SPECIES BASED ON ZOONOTIC RISK
The Ministry of Environment has requested that a flow chart be developed to assist in the classification of risk assessment of zoonotic disease transfer from non‐native mammalian species. This assessment tool will be used to develop the guideline to determine which species will be regulated as part of the Controlled Alien Species list. The background material to develop the classification section is described in Appendix C. The recommendations to classify mammalian species are based on the following: 1) The likelihood of the mammalian species carrying the disease. Several factors contribute to the likelihood of an animal carrying a zoonotic disease, primarily if the species was captive‐bred versus wild caught. Species that are captive‐bred are less likely to carry disease as they are raised in a controlled environment, unlike their “wild‐caught” counterparts (Pavlin et al, 2009). Other factors contributing to zoonoses risk include stress during handling and transport, origin country and exposure to other species that may carry zoonotic disease (Locke, 2004). 2) The risk of transmission between an infected animal and humans. Several factors contribute to the transmission of a zoonotic disease from an infected animal to a human. An animal can be infected with a zoonotic disease and carry little risk to a human. The primary factor is the means of pathogen transmission from the animal to human. A pathogen such as Francisella tularensis can be transmitted by multiple routes such as inhalation, skin contact with infected animals or consumption of infected animals (Dennis, 2001). A species potentially carrying this bacterium may be considered “higher risk” as there is a greater chance of them transmitting the disease to humans and causing a pandemic. This can be contrasted with a disease such as rabies that requires close contact, primarily through bite wounds, for transmission (Locke, 2004). Although unmanaged rabies is fatal, the likelihood of the general population becoming infected is minimal. A detailed description of specific zoonoses of interest is included in Appendix D. 3) The likelihood of the disease causing significant illness or death. There are hundreds of zoonotic diseases with clinical syndromes ranging from a simple skin rash to potential death. For example, ringworm is readily transmitted between infected animals but does not cause significant or chronic illness in humans. This can be contrasted with a disease such as Marburg virus that can lead to life‐threatening illness in humans.The purpose of the flow chart is to develop a systematic approach to determining the risk of animal carrying a significant zoonoses and subsequently transmitting it to a human. Quantifying “risk” is difficult, particularly when studying potential zoonotic diseases as new risk factors are continuously emerging. However, based on existing knowledge of known significant zoonoses and the likelihood of transmission to humans, we can develop a means of classifying non‐native species. The flow chart forms the basis of the recommendations for prohibiting specific species from being possessed in private collections within British Columbia. Determining “significance” of illness is subjective and the report acknowledges that classifying clinical syndromes in humans can be difficult. I would advise the following classification system when assessing the risk of animal transferring a zoonotic disease. 1) Death or severe morbidity ‐ zoonotic disease may cause death or illness requiring life‐long therapy and reduced quality of life. 2) Significant illness – zoonotic disease will cause clinical illness but individual will resume normal quality of life once recovered. 3) No significant illness – zoonotic disease will cause non‐clinical or mild illness without significant consequence to quality of life.
