IFAW Comment on MMR Dec 2008

Barry Rashotte Director General, Resource Management, Department of Fisheries and Oceans 16 December 2008 Submitted via email to: mmrivwg@dfo-mpo.gc.ca Dear Mr. Rashotte: Re: Your letter of 14 November 2008 The International Fund for Animal Welfare (IFAW) would like to thank you for the opportunity to comment on the proposed Amendments to Sections 2, 28 and 29 of the Marine Mammal Regulations. IFAW remains opposed to Canada’s commercial seal hunt, and our comments should not be interpreted as indicating otherwise. As an animal welfare organization with almost 40 years of experience with Canada’s commercial seal hunt, IFAW considers this hunt to be inherently inhumane and we remain unconvinced that any changes to the Regulations will adequately address our concerns about humane killing practices. That being said, as long as seals continue to be killed in Canada’s commercial seal hunt, it is our opinion that the current Marine Mammal Regulations (MMR) are inadequate to ensure humane killing and require improvement. Our comments on the proposed amendments are as follows: Proposed Amendments to Section 28: • remove the requirement for checking via the blinking reflex test, • clarify that the purpose of checking by palpation is to ensure that the seal is irreversibly unconscious or dead, We recognize that different groups of veterinarians have arrived at different conclusions on the use of the blink reflex test, and ...