Stevens has a valid concern, and the lack of a firearms training program for wildlife researchers at Great Eastern University does not shield the IACUC from its duty to promote safety and require technical proficiency in all areas of mammal care and use. The AVMA euthanasia guidelines1 recognize that gunshot may be a practical method of euthanasia when “performed by highly skilled personnel trained in the use of firearms,” and the guidelines of the American Society of Mammalogists2 state that “investigators using this method must be experienced in safe handling of firearms.” We agree that gunshot can be an effective method of euthanasia, and there are situations, particularly with unrestrained mammals in a field situation, where gunshot is the preferred technique.
There are four criteria that should be met before IACUC approval, however. The first is that the researcher should consider alternatives to gunshot and justify why gunshot is the best method possible under the circumstances. The second criterion is that the researcher should clarify what the protocol means by 'gunshot'. Not all firearms and ammunition are the same, and shooting a trapped animal from 3 meters away is different from shooting a running animal from a distance of 60 meters. A generic use of the term 'gunshot' should be a red flag for the IACUC. Third, firearm use is inherently dangerous. All state-approved hunter education programs in the United States emphasize safe techniques for handling firearms. However, under the General Duty Clause of the Occupational Safety and Health Act of 1970, employers are required to provide their employees with a place of employment that “is free from recognizable hazards that are causing or likely to cause death or serious harm to... employees”3. We accept that firearms are recognizable hazards, but the hazard is abated with safety training. The problem with accepting hunter education certification as a sufficient training is that, first, this is a lifetime certification that can be taken when the prospective hunter is as young as 10 years old (in some states there is no minimum age). In such cases, this training might not be used until decades later. Second, safety training with one type of firearm (for example, a .22-caliber rifle) might not be appropriate or sufficient for other types of firearms (such as shotguns, center-fire rifles or semi-automatic pistols). Investigators should be required to demonstrate that they have abated the hazards of firearm use.
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