Authorized Use of Firearms by Non-Law Enforcement Personnel to Euthanize Wild Horses and Burros

CA IM-2022-002
Instruction Memorandum

                                                                         October 20, 2021

In Reply Refer To: 
4730 (CA-932) P 

Instruction Memorandum No. CA-2022-002
Expires:  09/30/2024

To:           District Managers and Field Managers

From:       State Director 

Subject:   Authorized Use of Firearms by Non-Law Enforcement Personnel to Euthanize
                Wild Horses and Burros 

Program Areas: Safety, Occupational Health and WH&B 

Policy/Action:  Non-law enforcement personnel with firearms qualifications may be authorized to transport, possess, or use a firearm while on official duty to euthanize wild horses and burros that meet criteria outlined in Attachment 1.  Personnel authorized to perform this duty will be required to follow the training, safety and operational requirements outlined in Attachment 2.

Purpose:  This Instruction Memorandum (IM) establishes the Bureau of Land Management (BLM) California requirements for on-the-job transport, possession and use of firearms by non-law enforcement personnel to euthanize wild horses and burros.  This policy does not apply to law enforcement personnel.. 

In accordance with Federal Regulations, 18 U.S. Code § 930, firearms are prohibited inside Federal facilities. Exceptions are made for law and non-law enforcement personnel with firearms qualifications.

Timeframe: This Instruction Memorandum (IM) is effective upon issuance. 

Budget Impact:  Costs associated with implementing this IM will include purchase of firearms, ammunition, and all associated equipment meeting established safety and storage requirements for each field office that manages a WH&B program. Annual costs include ammunition and shooting range fees to recertify firearms training and qualifications. 

Background:  The BLM California manages 21 Herd Management Areas, 18 Herd Areas, two short-term holding facilities (Ridgecrest and Litchfield), a contracted adoption facility in Redlands CA, and a training facility at the Rio Cosumnes Correctional Center in Elk Grove, CA.  Occasionally, wild horses and burros are injured from natural or human-related encounters and need to be euthanized in a humane manner to reduce undue suffering. The BLM can use either lethal injection or firearms to humanely euthanize wild horses and burros. Lethal injection is not an option for animals on the range due to drug residues that may poison wildlife or enter the environment. Currently, BLM California relies on law enforcement to euthanize wild horses and burros with firearms, or a veterinarian to administer a lethal injection. Many times, law enforcement officers or veterinarians are unavailable to euthanize an animal in a timely manner, causing undue suffering.  Allowing non-law enforcement employees to carry firearms in the field will allow timely responses to humanely euthanize wild horses and burros to prevent undue suffering. 

Directives Affected:  This IM complies with the BLM Permanent Instruction Memorandum No. 2021-002 (Comprehensive Animal Welfare Policy); BLM WO IM-2016-118 (Security and Storage of Non-Law-Enforcement Firearms); Department of the Interior Departmental Manual, Part 446; BLM Manual 4730; and BLM Handbook 1112-1, Chapter 37, pertaining to the authorization, use, storage, issuance and qualification with the Bureau-issued firearms by wild horse and burro personnel.  

Coordination:  This policy has been prepared by the BLM California Advisory Safety and Health Committee in coordination with the Branch of Natural Resources with coordination between BLM California District and Field Office Wild Horse and Burro Specialists, the State Chief Law Enforcement Ranger, and the BLM California Safety and Occupational Health Manager.   

Contact:  For additional information, contact Amy Dumas, Wild Horse and Burro Program Lead (916) 978-4678 or Jim E Beason, State Safety and Occupational Health Manager (916) 978-5344.

Signed by:                                  Authenticated by:
Karen E. Mouritsen                    Larry Weitzel
State Director                             GIS/Application Mgmt. Branch, CA-946. 


2 Attachments:
1-Animal Evaluation and Response (8 pp) 
2 – BLM California Requirement Governing the Management and Use of Firearms by Non-Law Enforcement Personnel (3 pp)

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