A Survey of the Extent of Compliance with the Requirements of the Code of Practice for the Humane Shooting of Kangaroos
Prepared for Environment Australia by RSPCA Australia
6 Comparison with the Recommendations in the 1985 Report
Within Chapter Seven (General Conclusions and Recommendations) of the 1985 Report, a number of recommendations were made concerning both the commercial and non-commercial killing of kangaroos. The recommendations were listed in the general context of the report's conclusions. Extracts from this chapter are presented here to indicate the main recommendations. The full text of the conclusions of the 1985 Report is provided in Appendix 6. A number of specific recommendations were also made regarding the first edition of the Code of Practice, which had been developed prior to the Report's publication. These are listed separately under Section 6.2 below, with the full text provided in Appendix 7.
'There was a greater chance of inhumane slaughter if a kangaroo was chest shot rather than head shot. Inaccuracy in both methods results in wounding of the kangaroo and, if not relocated and killed, will result in a slow death. There was a higher chance of wounding with a chest shot than a head shot. Head shooting from the front of an animal may require a different form of projectile than those used at present and a head shot from the side is the recommended technique.'
The present Code of Practice states that a head shot is the only consistent method of humanely killing kangaroos (see pages 1 and 2 of the Code, and Section 4 of this report). All States require compliance with the Code of Practice and therefore require that kangaroos be head-shot (although heart shots are permitted for dispatching wounded kangaroos where a further head shot is considered impractical). NSW has gone one step further and made a requirement that all kangaroos sold must only be head-shot (known as zero-tolerance).
There is still concern, however, over the precise definition of a head shot. A recommendation is made in Section 4 for an improved definition of a head shot versus a body shot in the Code of Practice that clarifies the issue of neck shooting.
'Some of the criteria used in the slaughter of domestic animals should be applied to the culling of kangaroos. These include the consecutive stunning and killing of one animal at a time, ie finding all wounded animals and the regular checking of all equipment by a licensed authority.'
The recommendation regarding killing one animal at a time relates to the wording of the Code of Practice and is addressed in Section 6.2 below. There is no requirement that applies to all shooters for the regular checking of equipment by a licensed authority.
'There are several ways in which the industry should reduce the amount of cruelty during kangaroo culling. The industry should be stronger in its demands for humanely killed kangaroos by only using full-time shooters and only accepting head shot carcasses and skins.'
The industry is certainly stronger in only accepting head-shot carcasses (and skins from head-shot carcasses). Discussion on how this can be further improved is presented in Section 4 . Although some full-time shooters argued against the use of part-timers (see Section 3.3), there is no hard evidence that part-time shooters are any less humane than full-time shooters.
'There should be a checking system of carcasses and skins by an appropriate authority and any shooter and/or processor should lose its license if found to have inhumanely killed kangaroos. There should be a check on all licensed shooters equipment and ability to shoot.'
A checking system is currently being undertaken by each State's wildlife management agency, together with AQIS inspectors checking the game meat hygiene aspects of the human consumption trade. In NSW, there are fines and licence loss for having sold a kangaroo that was shot in a place other than the head, and this system is currently being introduced to the other States. There is a compulsory check on a licensed shooter's ability to shoot in NSW and Queensland (condition of licence to successfully undertake a shooting accuracy test). A voluntary test is available in South Australia (compulsory from 1 July 2002), and one has been developed in Western Australia. A recommendation is made in Section 4.5 for the introduction of an auditing process for kangaroos shot for commercial purposes.
'There is a need for further research into the impact of projectiles upon kangaroos and into the humane disposal of pouch young.'
Unfortunately, such research is still pending. Concern over the impact of projectiles was expressed in the 1985 Report and reiterated in the present report during interviews (see Box 3.1). Since 1985, there are many more types of projectiles and firearms available and it is time that these were investigated to ensure that there is adequate knowledge about the most humane killing tool. The recommendation about the humane disposal of pouch young is perhaps even more relevant today (see Section 5.2). An appropriate recommendation on the humane destruction of pouch young is provided in Section 5.2 of this report.
RSPCA Australia recommendation - projectile types
6.1 It is recommended that a study be conducted into the relationship between projectile types, firearm size and the efficiency of killing kangaroos. The results should be incorporated into Schedule 1 of the Code of Practice.
'Reduction of cruelty during non-commercial culling could occur by education of the landholders, stricter gun licensing laws and the use of 'Wildlife Controllers' paid by the government via the royalty tag fee.'
'Suggestions for ways of reducing incidence of cruelty during illegal culling include imposing stricter controls on the marketing of carcasses and skins, a greater degree of self-regulation by the kangaroo industry, more law enforcement staff, use of 'Wildlife Controllers', stricter gun laws and conducting a moderate but professionally presented public awareness campaign.'
An increase in the use of kangaroo meat for human consumption over the past 15 years has led to the introduction of stricter regulation in the marketing of products and an increased requirement for the training of commercial kangaroo shooters. There also appears to be a greater degree of self-regulation by the kangaroo industry. However, these changes are unlikely to have had any impact on the non-commercial or illegal killing of kangaroos other than by making it harder for non-commercially shot kangaroo meat to enter the commercial market.
From the discussions carried out during this survey it appeared that law enforcement resources within State wildlife agencies has decreased since 1985, and several processors remarked about the lack of inspections and any follow up of reports. If States are to be able to adequately police the non-commercial sector, there needs to be more allocation of resources within the wildlife agencies for this purpose.
The 1985 Report made some specific suggestions regarding the improvement (and national consistency) of gun laws to assist in the reduction of cruelty to kangaroos. In particular, the report suggested that: 'all firearms should come under the same control, ie the ownership of light arms (.22 rifle and shotguns) should have the same restrictions placed upon them as high powered arms'. The Report also suggested that some form of test of the applicant's ability to shoot or maintain a firearm should be passed before a licence is issued. These issues are not addressed by changes in gun laws since the publication of the 1985 Report. However, the introduction of the Code of Practice included setting specific requirements for the type of gun and ammunition permitted to be used for shooting kangaroos (see Schedule 2 of the Code) which has removed the use of unsuitable firearms (with the exception of shotguns - see 6.2.1 below). Commercial shooters are now required to pass a firearms competency test in most States, however no such requirement exists for non-commercial shooters.
The 1985 Report provided some detail about how a Wildlife Controllers' program could be designed and implemented. The system was proposed to replace the damage mitigation licensing system and provide a means of ensuring that kangaroo killing was only carried out by professional shooters. The Report suggested that each State agency would appoint its own Wildlife Controller with policing powers who would keep a register of professional shooters. The officer would arrange for professional shooters to carry out damage mitigation killing on licensed properties following a request from the landholder. Further details are provided in points 20-23 in Appendix 6.
There has been some general education of landholders since the 1985 Report, but there is no evidence to indicate that the problems associated with non-commercial killing have changed in any significant way. A requirement for training, along the lines of the courses offered under the current commercial system, would ensure that all licence holders were familiar with the Code of Practice and were capable of meeting its requirements.
Recommendations addressing the issues outlined here are provided in Section 5.1 of this Report.
The first edition of the Code of Practice was endorsed on 30 May 1985, prior to the publication of the 1985 Report. The 1985 Report contained a number of specific recommendations for changes to this edition of the Code. All but one of these recommendations were taken up by the then Council of Nature Conservation Ministers (CONCOM).
A second edition of the Code was endorsed on 20 September 1990 which contained a number of amendments in line with the recommendations in the 1985 Report. The recommended change that was not addressed was 'to eliminate the use of shotguns from the Code, until a more thorough investigation of its impact upon kangaroos and wallabies has taken place'. Each recommendation made in the 1985 Report is presented below, followed by details of the relevant amendment.
'One recommended change is to eliminate the use of shotguns from the Code, until a more thorough investigation of its impact upon kangaroos and wallabies has taken place. As pointed out in section 3.4, existing data tends to show that a humane kill is not always possible using a shotgun at 30 metres.'
Subsequent to the publication of the 1985 Report, a further survey was carried out by RSPCA Australia into the incidence of cruelty to wallabies in commercial and non-commercial operations in Tasmania . As part of this report, a survey was carried out into the use of shotguns to hunt wallabies which showed that this can be an extremely cruel technique. Less than 50% of wallabies surveyed that were hunted with a shotgun were killed instantly - the remainder were wounded and subsequently escaped or were killed by other means. Despite the low rate of 'clean' kills, the chest region is often the preferred point of aim for shotgun use.
Studies of the use of shotguns for duck hunting can provide an indication of the level of wounding involved with this method of shooting (Box 6.1). It has been estimated from these studies that between 6.6 and 10 ducks are wounded for every 10 ducks that are bagged (ie shot and retrieved by the hunter). Although the spread of shot is different with a larger on-ground target such as a wallaby, the difficulty of ensuring a clean kill remains.
Box 6.1 Studies of the wounding rate of shotgun use - the example of duck hunting
Ducks are usually shot with a 12 gauge shotgun and need to be struck by three to eight pellets for a relatively quick kill, depending on the size of the pellets. The spread of pellets from a shotgun is irregular, so at normal hunting range it is impossible to ensure, even when the duck is within the target area, that it will be hit by enough pellets to kill it. A hunter will usually have to fire between four and ten shots for each duck they kill.
Studies of the incidence of shotgun pellets embedded in the bodies of live birds have found that the percentage of duck with embedded pellets ranged from 6% to 19%, depending on the size of the duck (Norman 1976). This does not include crippling and fatal shot wounds and does include ducks that have not been shot which dilutes the overall wounding rate.
A Canadian study which compared hunter estimates with reports from hidden observers who had watched the shooters and counted the number of ducks they crippled found that hunters reported a crippling rate of 6-18% of ducks bagged compared to the observed level of 20-45% (Nieman et al 1987). Overall, this study found a crippling rate of 40% of the total harvest.
Computer modelling has also been used to provide an estimate of wounding rates The study analysed hunters' hit rates to determine the level of wounding. The results found that a shooter who takes on average 6 shots to kill a bird (a conservative estimate compared to published studies) would wound between 60 and 120 ducks for every 100 bagged. Overall the study concluded that most competent shooters will wound at least one duck for every duck bagged (Russell 1994a, b).
Nieman DJ, Hochbaum GS, Caswell FD & Turner BC (1987) Monitoring hunter performance in prairie Canada. Trans 52nd NA Wild & Nat Res Conf 52:233-245.
The 1987 wallaby report recommended that the use of shotguns be banned and that the Code of Practice be changed accordingly. However, the Second edition of the Code of Practice continues to allow the use of shotguns and also permits the point of aim as the head, neck or chest when shotguns are used.
The controls now established over the commercial kangaroo industry in mainland Australia are in stark contrast to the continued acceptance of the use of shotguns to kill wallabies non-commercially in Tasmania.
RSPCA Australia recommendation - use of shotguns
6.2 Any reference to the use of shotguns on any macropod should be removed from the Code of Practice. It should be made clear in the Code that the only acceptable method of humanely shooting macropods is a shot to the head using a centrefire rifle with appropriate calibre ammunition (as specified in Schedule 1).
'a. Page 5. 'Paragraph 3'. Each animal shot should be checked to ensure it is dead before another is targeted. - Item (i) under 'Conditions' ought to reflect this too.'
In the Second edition, item (i) under 'Injured Kangaroos and Pouch Young - Conditions' states: 'The shooter must be certain that each animal is shot dead before another is targeted'.
'b. Page 6 'Conditions' (v). It may be necessary to shoot and this should be an option.'
In the Second edition, item (vi) under 'Injured Kangaroos and Pouch Young - Conditions' states: 'The pouch young of a killed female must also be killed immediately, by decapitation or a heavy blow to the skull to destroy the brain, or shooting.'
'c. Page 5. As a general comment, references to skilled shooters in paragraphs 1 and 3 and 'when a high standard of marksmanship prevails', should perhaps be deleted or rearranged so that there is no impression that unskilled shooters or any other standard of marksmanship other than very high could ever be acceptable.'
References to 'skilled' shooters or 'a high standard of marksmanship' have been removed in the Second edition.
'd. Page 6. 'shooting for Scientific Purpose' preamble, last sentence may provide an option and should be reworded to read 'Such variations must never detract from the primary etc'.'
Amended as recommended.
'e. Page 6 'Conditions' (ii) (a). Only if there is an Animal Care and Ethics Committee at the applicant's institution which has examined and approved the proposal.'
In the Second edition , item (ii) (a) under Shooting for Scientific Purposes - Conditions' states: 'the Animal Care and Ethics Committee (or equivalent) at the relevant institution has examined and approved the proposal.'
'f. Page 6 'Conditions' (iii). The waivering of any requirements of this code shall not relieve the shooter of the absolute requirement to provide a sudden and painless death for the kangaroos.'
Amended as recommended.
'g. Page 8 'Schedule 2' - diagram for a shot to the brain. Perhaps it should be noted that a side shot is preferred due to the size of target compared to that of a frontal shot.'
In the Second edition, Schedule 2 contains the note: 'A shot to the side of the head is preferred as it is a larger target area'.