UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
 
October 20, 2005
 
In Reply Refer To:
4730/4700 (WO-260) P
 
EMS TRANSMISSION 11/03/2005
Instruction Memorandum No. 2006-023
Expires:  09/30/2007
 
To:              All Field Officials (except Alaska)
 
From:          Assistant Director, Renewable Resources and Planning
 
Subject:      Euthanasia of Wild Horses and Burros
 
Program Area: Wild Horses and Burros
 
Purpose: This policy identifies requirements for euthanasia of wild horses and burros.
 
Policy/Action: A Bureau of Land Management (BLM) authorized officer may authorize the euthanasia of a wild horse or burro in field situations (includes free-roaming horses and burros encountered during gather operations) as well as short- and long-term wild horse and burro holding facilities with any of the following conditions:
 
(1)     Displays a hopeless prognosis for life;
(2)     suffers from a chronic or incurable disease, injury or serious physical defect; (includes severe tooth loss or wear, severe club feet, and other severe acquired or congenital abnormalities)
(3)     would require continuous treatment for the relief of pain and suffering in a domestic setting;
(4)     is incapable of maintaining a Henneke body condition score greater than two, in its present environment;
(5)     has an acute or chronic injury, physical defect or lameness that would not allow the animal to live and interact with other horses, keep up with its peers or exhibit behaviors which may be considered essential for an acceptable quality of life constantly or for the foreseeable future;
(6)     suffers from an acute or chronic infectious disease where State or Federal animal health officials order the humane destruction of the animal as a disease control measure.
 
Euthanasia in field situations (includes on-the-range and during gathers):
 
There are three circumstances where the authority for euthanasia would be applied in a field situation:
 
(A) If an animal suffers from a condition as described in 1-6 above that causes acute pain or suffering and immediate euthanasia would be an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize the animal.   If the animal is euthanized during a gather operation, the authorized officer will describe the animal’s condition and report the action using the gather report in the comment section that summarizes gather operations (See attachment 1). If the euthanasia is performed during routine monitoring, the Field Manager will be notified of the incident as soon as practical after returning from the field.  
 
(B) Older wild horses and burros encountered during gather operations should be released if, in the opinion of the authorized officer, the criteria described in 1-6 above for euthanasia do not apply, but the animals would not tolerate the stress of transportation, adoption preparation, or holding and may survive if returned to the range. This may include older animals with significant tooth wear or tooth loss that have a Henneke body condition score greater than two. However, if the authorized officer has inspected the animal’s teeth and feels the animal’s quality of life will suffer and include health problems due to dental abnormalities, significant tooth wear or tooth loss; the animal should be euthanized as an act of mercy.
 
 (C) If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner. The authorized officer will prepare a written statement documenting the action taken and notify the Field Manager and State Office Wild Horse and Burro (WH&B) Program Lead. If available, consultation and advice from a veterinarian is recommended, especially where significant numbers of wild horses or burros are involved.
 
If, for humane or other reasons, the need for euthanasia of an unusually large number of animals during a gather operation is anticipated, the euthanasia procedures should be identified in the pre-gather planning process. When pre-gather planning identifies an increased likelihood that animals may need to be euthanized, plans should be made for an APHIS veterinarian to visit the gather site and consult with the authorized officer on euthanasia decisions.
 
In all cases, the final responsibility and decision regarding euthanasia of a wild horse or burro rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4730 manual. 
 
Euthanasia at short-term holding facilities:

Under ideal circumstances horses would not arrive at preparation or other facilities that hold horses for any length of time with conditions that require euthanasia. However, problems can develop during or be exacerbated by handling, transportation or captivity. In these situations the authority for euthanasia would be applied:
 
(A) If an animal suffers from a traumatic injury or other condition as described in 1-6 above that causes acute pain or suffering and immediate euthanasia would be an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize the animal. A veterinarian should be consulted if possible.
 
(B) If in the opinion of the authorized officer and a veterinarian, older wild horses and burros in short-term holding facilities cannot tolerate the stress of transportation, adoption preparation, or long-term holding they should be euthanized. However, if the authorized officer has inspected the animal and feels the animal’s quality of life will not suffer, and the animal could live a healthy life in long-term holding, the animal should be shipped to a long-term holding facility.   
 
(C) It is recommended that consultation with a veterinarian is obtained prior to euthanasia. If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner. Situations where acute suffering of the animal is not involved could include a physical defect or deformity that would adversely impact the quality of life of the animal if placed in the adoption program or on long-term holding. The authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was euthanized. These records will be maintained by the holding facility.
 
If, for humane reasons, the need for the euthanasia of a large number of animals is anticipated, the euthanasia procedures should be identified to the WH&B State Lead or the National Program Office (NPO) when appropriate.  A report that summarizes the condition, circumstances and number of animals involved must be obtained from a veterinarian who has examined the animals and sent to the WH&B State Lead and the NPO.
 
In all cases, final decisions regarding euthanasia of a wild horse or burro rest solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4750-1 Handbook.
 
Euthanasia at long-term holding facilities:
 
This portion of the policy covers additional euthanasia conditions that are related to long-term holding facilities and includes existing facilities and any that may be added in the future. 

At long-term holding facilities the authority for euthanasia would be applied:
 
(A)  If an animal suffers from a traumatic injury or other condition as described in 1-6 above that causes acute pain or suffering and
 immediate euthanasia would be an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize
 the animal.
 
(B) If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the
      authority and obligation to euthanize the animal in a humane and timely manner. In situations where acute suffering of the
      animal is not involved, it is recommended that a consultation with a veterinarian is obtained prior to euthanasia. The
      authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was
      euthanized. These records will be maintained by the authorized officer.
                                                                     
The following action plan will be followed for animals at long-term holding facilities:
 
The WH&B Specialist who is the Project Inspector and the contractor will evaluate all horses and their body condition throughout the year. Once a year a formal evaluation as well as a formal count of all horses at long-term holding facilities will be conducted. The action plan for the formal evaluation is as follows:
 
1. All animals will be inspected by field observation to evaluate body condition and identify animals that may need to be euthanized to prevent a slow death due to deterioration of condition as a result of aging. This evaluation will be based on the Henneke body condition scoring system. The evaluation team will consist of a BLM WH&B Specialist and a veterinarian not involved with regular clinical work or contract work at the long-term holding facilities. The evaluations will be conducted in the fall (September through November) to identify horses with body condition scores of 3 or less. Each member of the team will complete an individual rating sheet for animals that rate a category 3 or less. In the event that there is not agreement between the ratings, an average of the 2 scores will be used and final decisions will be up to the BLM authorized officer. 
 
2. Animals that are rated less than a body condition score of 3 will be euthanized in the field soon after the evaluation by the authorized officer or their designated representative. The horses that rate a score 3 will remain in the field and should be re-evaluated by the contractor and WH&B Specialist that is the Project Inspector, for that contract, in 60 days to see if their condition is improving, staying the same or declining. Those that are declining in condition should be euthanized soon after the second evaluation.
 
3. The euthanasia process that will be used is a firearm. The authorized officer or their designated representative will carry out the process. Field euthanasia does not require the gathering of the animals which would result in increased stress and may cause unnecessary injury to other horses on the facility.
 
4. Documentation for each animal euthanized will include sex, color, and freeze/hip brand (if readable). Copies of all documentation will be given to the contractor and retained by BLM.
 
5. Arrangements for carcass disposal for euthanized animal(s) will be in accordance with applicable state and county regulations.
 
In all cases, the final decisions regarding euthanasia of a wild horse or burro for humane reasons rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4750-1 Handbook.
 
Timeframe: This action is effective from the date of approval through September 30, 2007.
 
Budget Impact: Implementation of these actions would not result in additional expenditures over present policies.
 
Manual/Handbook Sections Affected: No manual or handbook sections are affected.
 
Background: The authority for euthanasia of wild horses or burros is provided by the Wild Free-Roaming Horse and Burro Act of 1971, Section3(b)(2)(A) 43 CFR4730.l and BLM Manual 4730-Destruction of Wild Horses and Burros and Disposal of their Remains.
 
Decisions to euthanize require an evaluation of individual horses that suffer due to injury, physical defect, chronic or incurable disease, severe tooth loss or old age. The animal’s ability to survive the stress of removal and/or their probability of surviving on the range if released, transportation to a BLM facility and to adoption or long-term holding should be determined. The long term care of these animals requires periodic evaluation of their condition to prevent long term suffering. These evaluations will, at times, result in decisions that will require the euthanasia of horses or burros if this is the most humane course of action.
 
Coordination: This document was coordinated with the Wild Horse and Burro Specialists in each affected state, the National Program Office and Wild Horse and Burro Advisory Board.
 
Contact:  Questions regarding this memorandum should be directed to Lili Thomas, Wild Horse and Burro Specialist, Wild Horse and Burro National Program Office, at (775) 861-6457.
 
Signed by:                                                   
Authenticated by:
Thomas H. Dyer                                          
Robert M. Williams
Deputy Assistant Director                             
Policy and Records Group,WO-560
Renewable Resources and Planning
 
 
1 Attachment