Human Health and Ecological Risk Assessment

for the Use of Wildlife Damage Management Methods

by USDA-APHIS-Wildlife Services

Chapter IV

THE USE OF FOOTHOLD TRAPS 

IN WILDLIFE DAMAGE MANAGEMENT

May 2017

Peer Reviewed Final 

February 2019
i

THE USE OF FOOTHOLD TRAPS IN WILDLIFE DAMAGE MANAGEMENT

EXECUTIVE SUMMARY

Foothold traps are used by USDA-APHIS-Wildlife Services (WS) Program for specific wildlife damage 

management (WDM) projects, mostly involving wildlife that are causing damage to property, agriculture, and 

natural resources or protecting human health and safety. Implementation of program-specific measures 

designed to reduce human interactions with traps reduces the risk of these types of management tools to the 

public and workers, and WS will continue to evaluate and implement, where appropriate, new protection 

measures. Advancements in trap use and design have resulted in more effective and humane trapping of 

target animals while reducing the potential for nontarget captures in foothold traps. In fact, nontarget capture 

has decreased in the last 25 years from a nontarget capture rate of 23.3% in FY88 (USDA 1997, Appendix P, 

pp. 23-27) to 5.9% annual average between FY11 and FY15 in the 6 states (AZ, CO, NM, OK, TX, and UT) 

analyzed. The use of pan tension devices, with most being implemented in the 1990s, likely accounted for the 

largest portion of the decrease. Additionally, target take has decreased five-fold from FY88 to FY11-FY15, 

from a total take of 21,992 to 4,244 (19.3%) in USDA (1997, Appendix P, pp. 23-27). This data indicates that 

foothold trap use has declined significantly and that their use is more selective for the target animal. WS will 

continue to support and conduct research and education that supports more humane and effective trapping 

methods and will implement these measures in programs, where appropriate, to further reduce risk to 

nontarget animals.

Overall, the risks to human health and safety and the environment from the use of foothold traps are minimal.

WS personnel are professional with their use of foothold traps and try to minimize the identified potential 

risks. Wildlife Services maximizes humane capture by using foothold traps recommended by the Association 

of Fish and Wildlife Agencies (2016) Best Management Practices program.

Table of Contents

1 INTRODUCTION...........................................................................................................................................................1

1.1 Use Pattern ........................................................................................................................................................4

2 HAZARDS ....................................................................................................................................................................6

2.1 Human Health and Safety ..................................................................................................................................6

2.2 Environmental ...................................................................................................................................................6

3 RISKS..........................................................................................................................................................................7

3.1 Human Health and Safety ..................................................................................................................................7

3.2 Environmental ...................................................................................................................................................9

4 UNCERTAINTIES AND CUMULATIVE EFFECTS..........................................................................................................10

5 SUMMARY ................................................................................................................................................................10

6 LITERATURE CITED...................................................................................................................................................11

7 PREPARERS..............................................................................................................................................................12

7.1 APHIS-WS Methods Risk Assessment Committee ..........................................................................................12

7.2 Internal Reviewers...........................................................................................................................................14

7.3 Peer Reviewers................................................................................................................................................15

7.3.1 Peer Reviewers Selected by the Association of Fish and Wildlife Agencies............................................15

7.3.2 Comments.............................................................................................................................................15

Appendix 1. “Other Species” Included in Tables ...........................................................................................................16
1

1 INTRODUCTION

The U.S. Department of Agriculture (USDA), Animal 

and Plant Health Inspection Service (APHIS), Wildlife 

Services (WS) Program uses foothold traps to conduct

wildlife damage management (WDM) to protect public 

and private landowners from losses to agricultural and 

natural resources, and to protect human health and 

safety and property. Foothold traps, often incorrectly 

called leghold traps, are mechanical devices designed 

to capture animals by gripping an animal’s foot. A 

foothold trap consists of a pair of metal jaws 

sometimes covered with rubber pads or laminated (this 

makes the jaws thicker to reduce injury), powered by

springs, a base to attach the springs and jaws, and a 

pan triggering mechanism to hold the trap in the set 

position until activated by an animal. In addition to 

these traps, a few new trap styles are available for 

raccoons1 (e.g., dog-proof raccoon trap, and footencapsulated trap) that exclude many nontarget 

species. Foothold traps are available in a variety of sizes (Figures 1, 2, and 3) depending on the type of animal 

to be captured and the manufacturer, including:

• No. 0 -- Small rodents

• No. 1 -- Muskrat, Weasel, Birds

• No. 11⁄2 - Muskrat, Mink, Skunk, Birds

• No. 2 -- Raccoon, Mink, Fox, Skunk

• No. 3 -- Coyote, Fox, Bobcat, Badger 

• No. 4 -- Coyote, Beaver, Bobcat 

• No. 41⁄2 - Wolf, Mountain Lion

Trap size is generally determined by the spread of the 

trap jaws, but may differ somewhat among 

manufacturers2

. Foothold traps designed to capture 

birds are placed on perches or are set on poles. The 

springs for bird traps are modified to reduce the force 

with which they close to avoid injuries. 

Foothold traps are a commonly used wildlife damage 

management (WDM) method by the Wildlife Services 

(WS) program and are used in both terrestrial and aquatic habitats nationwide, following state or local 

regulations. WS uses foothold traps on both public and private lands, and in rural or urban areas. Foothold 

traps are a versatile tool used by WS to capture a wide variety of mammalian species from muskrats to wolves 

and perching or large birds. It should be noted that some animals such as coyotes are difficult to trap with

other devices such as cage traps and foothold traps are considered the most efficient method to capture 

 1 See the Risk Assessment Introduction (Chapter 1) for scientific names of animals. These will only be given if they are not used in that Chapter.

2 WS may use trade names or show specific traps, but this does not constitute a recommendation for these traps.

Figure 2. Typical #2 coil spring trap. Coil spring traps with 

a spring removed, and often a smaller size trap, are typically 

used for trapping birds; the traps are set on poles and the pan 

replaced with a perch (pole trap).

Figure 1. Standard No. 3 trap used by APHIS-WS for 

trapping coyotes for many years (most have been replaced 

or laminated to meet BMP standards). This is a double longspring trap. This is an off-set, metal-jaw trap which is being 

replaced by padded-jaw- or laminated jaw- traps consistent 

with best management practices (BMP) standards. The jaw 

spread is just over 5”. 
2

them. WS may relocate or kill animals caught in foothold traps depending on the circumstances of capture.

In aquatic habitats, foothold traps may be used in submersion sets.

Depending on the target animal, a foothold 

trap, usually with an attractant, may be 

placed on or near the travel path of a target 

species, at typical perch sites for birds, in 

water near “slides” for beaver, at the 

entrance of burrows, or wherever a target 

animal is expected to travel, or has 

previously left sign. Trap placement varies 

according to the target species, habitat 

type, and the presence of nontarget 

animals. Most terrestrial sets for mammals

are placed underground with dirt or debris 

(e.g., leaf litter, rotting wood, pine needles, 

or ant pile granules) sifted on top. Bait, 

scent, lures, or carcass “draw stations”

may be used as attractants. Foothold traps 

in aquatic sets are typically placed in 

somewhat shallow water where animals 

come and go from land or near lodges or burrows; scent may be used for aquatic mammals, especially for 

beaver.

Birds are trapped on poles or the ground in places where they typically roost, near damage sites, or where 

safety concerns are occurring. Most birds are caught at airports or for the protection of threatened and 

endangered (T&E) species such as the California Least Tern (Sterna antillarum browni) and Western Snowy 

Plover (Charadrius nivosus nivosus) (Butchko 1990). Most bird traps or pole traps are made with a No. 1 or 

11⁄2 traps with spring tension reduced, according to WS policies, with the exception of those for eagles and 

larger birds of prey which require a greater jaw spread. 

Another type of foothold trap that can be used to live-capture raccoons and opossum are enclosed foothold 

traps, often called dog-proof traps. These traps can have metal jaws and power-activated snare cable to hold 

the foot (the cable restraint enclosed foothold are included here because so few are used). Enclosed foothold 

traps require a raccoon or opossum to reach inside the opening of an enclosed trap to get the bait. The bait 

is generally inserted onto or near the trigger, which is recessed approximately 2 to 3 inches inside the trap.

The trap generally requires the target animal to pull on the trigger to activate it, but some designs allow the 

trigger to be pushed as well. When the target animal trips the trigger inside the enclosed trap, the spring that 

was being held compressed by the trigger is released causing a metal arm or cable to close quickly over the 

animal’s foot. The foot of the animal is held inside the enclosed trap. The opening into the enclosed trap is 

narrow (normally 1.5 inches in diameter), which prevents animals much larger than a raccoon from accessing 

the trigger. The enclosed foothold trap can be placed above ground or buried underground with only the 

opening exposed to simulate a hole in the ground with a food cache. The enclosed foothold trap is anchored 

to the ground or nearby vegetation. 

Foothold traps are primarily used by WS specialists for coyotes, raccoons, beaver, foxes, bobcats, and other 

small predators, but more recently have been used more frequently for wolves. Live capture and relocation is 

Figure 3. Standard No. 3 padded coil spring trap used by WS mostly for 

coyotes. This trap is sprung, but in a standard set.
3

used most for Red-tailed Hawks, American Kestrels, other raptors, and raccoons and some wolves. Nearly all 

raptors are captured at airports as part of WS efforts to reduce wildlife-aircraft collisions. 

In 1996 the Association of Fish and Wildlife Agencies (AFWA), working cooperatively with federal and 

private partners, embarked on a goal to develop voluntary Best Management Practices (BMPs) for 

trapping furbearers in the United States (Batcheller et al. 2000). The stated purpose and intent of AFWA 

in developing the BMPs was to: “Scientifically evaluate traps and trapping systems used for capturing

furbearers in the United States.” AFWA determined the best methods by species3

, but was primarily 

targeting harvest by private fur trappers and not take in WDM activities. Evaluations of trap performance

were based on animal welfare, efficiency, capture rate, selectivity, practicality, safety, mechanical 

function, cost, quality, durability, weight, and maintenance requirements (Fall 2002). Science-based 

literature and research on the variety of traps and snares were used by AFWA to develop the BMPs. The 

evaluation of BMPs continues and BMPs are updated as research results warrant (AFWA 2016). BMPs 

were provided to state and federal wildlife agencies as well as trappers and the public in the form of a 

general overview for traps and trapping, and specifically the most efficient and humane methods for 

trapping 24 furbearer species in the United States (AFWA 2016). The goals were to promote regulated

trapping as a modern wildlife management tool, identify practical traps and trapping techniques while 

continuing to improve efficiency, selectivity, and the welfare of trapped animals through research, to

provide specifications for traps that meet BMP criteria for individual species in various regions of

the United States, to provide wildlife management and trap industry professionals with information to

evaluate trapping systems in the United States; and to instill public confidence in and maintain public

support for wildlife management and trapping through distribution of science-based information.

AFWA (2016) focused on private trappers and realized that trapping for depredation control was 

different. The BMP program utilizes international humane trapping standards consistent with the 

Agreement on International Humane Trapping Standards among Russia, Canada, and the European 

Union. WS has adopted these standards, where feasible, for trapping in the United States and conducts 

research on different trapping systems.

WS Policy (WS Directive 2.450, 09/24/2014) states that the use of the BMP trapping guidelines developed 

and promulgated by AFWA (2016) for private fur harvest and other trapping activities are valuable and should 

be followed as practical. WS uses the BMP guidelines as the basis for policy formulation, but recognizes that

some foothold traps used in WDM are not commercially available and that not all devices recommended in the

BMP guidelines for general public-use meet the more stringent performance requirements, particularly for

efficiency and durability, for use in federal wildlife management activities. The Directive also discusses the fact 

that foothold traps need to be set so that captured animals are not conspicuous to the public, particularly 

along public roads and trails; this reduces the possibility of a member of the public attempting to free an 

animal and getting injured and trap theft. Foothold traps are typically placed in areas where the public will not 

haphazardly stumble onto a trap or a trapped animal. The Directive also states that foothold traps are not to

be set closer than 30 feet from any exposed animal carcass, or part thereof, to reduce the potential of capturing 

raptors or other nontarget animals attracted to it4

. Foothold traps must also incorporate pan-tension devices

to prevent or reduce the capture of nontarget animals, unless such use would preclude capture of the intended

 3 Furbearers with AFWA (2016) trapping BMPs include Virginia opossum, beaver, muskrat, nutria, Canada lynx, bobcat, coyote in Eastern U.S., 

coyote in Western U.S. (both eastern and western United States populations have own BMPs since eastern coyotes are larger as a result of 

hybridizing with wolves), gray wolves, red fox, swift/kit fox, arctic fox, gray fox, river otter, fisher, American marten, weasel (least, long-tailed, 

and short-tailed), mink, American badger, ringtail, raccoon, and striped skunk. These are individual documents for each species and can be found 

at the AFWA website (2016). 4 If an animal carcass could be dragged or moved by scavengers to within 30 feet of set foothold traps, the carcass has to be secured to restrict 

movement (WS Directive 2.455, Scents, Baits, and Attractants). These restrictions do not apply to animal carcasses used to attract bear (foothold traps 

cannot be used to capture bear) or mountain lion for approved capture devices, including foothold traps.
4

target animals. It also states that foothold traps equivalent to size No. 3 or larger, when used in restraining

sets, are limited to types with smooth, rounded offset jaws that may or may not be laminated or padded jaws,

and that foothold traps with teeth or spiked jaws are prohibited (WS Directive 2.335, Wolf Damage

Management). The Directive also notes that agency foothold trap replacements are to be selected from the

various commercially available devices or equivalents listed in BMP regional guidelines for each species (AFWA 

2016), unless changes are authorized by the WS Regional Director.

The same Directive provides guidelines for pole traps. It allows foothold traps to be set on poles or roosting

structures to capture birds causing damage or considered a human health or safety risk under the 

appropriate federal, state, or local special purpose permit. WS personnel authorized to capture birds under 

a permit will have it in their possession. Foothold traps used as pole traps will not exceed No. l1⁄2 foothold traps, 

but this does not preclude the use of larger, modified traps to capture eagles. The Directive requires pole 

trap springs to be modified to produce the lightest jaw closure sufficient to catch and hold the target raptor

and sufficient padding to reduce the possibility of injuring a raptor's leg. To reduce unnecessary stress to

the captured birds, traps are checked at least twice daily, but not less than required by appropriate permit.

A slide wire, or similar device, is used to allow the raptor to slide to and rest on the ground after capture 

which minimizes injuries and stress.

1.1 Use Pattern

From FY11 to FY15, APHIS-WS captured an average annual total of 12,043 target animals (94%) of 84 species

and 779 nontarget (6%) of 98 species and 1 species group (maximum of 100 species) (Table 1) with foothold 

traps. Of the targeted animals, 792 were relocated or released after sampling (7% of targets). Of the nontarget

species, 258 were released (33%) following capture; those expected not to survive were humanely euthanized.

Traps were used in 48 states, 2 territories, and Guantanamo Bay, with 27 states having a take of more than 

100 animals. The most common target species taken annually with take exceeding 1,000 for each species

were coyotes, raccoons, and beavers. The most common nontarget species were raccoon, striped skunk, 

badger, Virginia opossum, coyote, and bobcat with take exceeding 40 for each species.

Animal capture trap night is a standard comparison measurement of effectiveness or selectivity for all types 

of mammal traps that remain in place for one or more nights. With foothold traps placed for mammals, trap 

nights can be determined from Management Information System (MIS5

) records. Pole traps for birds were 

not included since these are almost always set and taken down daily. In a few cases, foothold traps and not 

pole traps were used to capture birds and set on a daily basis, but these cannot be separated from the other 

take with foothold traps due to reporting procedures into the MIS and ability to query the data. Where traps

were set daily for several days in a row, trap nights would be calculated. However, these would equate to a 

minimal number of trap nights and would be included in the summaries for trap nights. The few target birds 

taken with foothold traps, which are usually placed on a platform rather than a pole, included an annual 

average of 24 killed and 38 relocated. From FY11 to FY15, WS used non-padded foothold traps, which 

includes BMP approved laminated traps, for a total of 1,039,387 trap nights, padded foothold traps 100,136

trap nights, and dog-proof traps 12,786 for a combined total 1,152,309 trap nights. An annual average of 

12,656 animals were captured in foothold traps for a total of 11.0 animals/1000 trap nights, with 94.0% target 

species and 6.0% nontarget species. Thus, for these figures, target animal take was 10.3/1000 trap nights 

and nontarget take was 0.7/1000 trap nights. Of the 11,899 target captures with foothold traps, 5.7% were 

 5

MIS - Computer-based Management Information System used for tracking WDM activities. Throughout the text, data for a year (i.e. FY11 to 

FY15) will be given and is from the MIS. MIS reports will not be referenced in the text or Literature Cited Section because MIS reports are not 

kept on file. A database is kept that allows queries to be made to retrieve the information needed.
5

relocated. Of the 757 nontarget captures, 33.0% were released at the capture site. These figures represent a 

high effectiveness rating for target mammal capture with a very low take of nontarget animals. In the hands 

of a skilled trapper, foothold traps are one of the most selective and efficient means available for removing 

problem animals.

Table 1. The annual average number of target and nontarget animals captured with foothold traps by APHIS-WS in WDM 

activities from FY11 to FY15 throughout the United States. Individual accounts of species are given only for those species 

that had an annual average of more than 10 taken, target and nontarget numbers combined. However, all federally listed 

threatened, endangered, or candidate species and eagles are included.

ANNUAL AVERAGE SPECIES TAKEN WITH FOOTHOLD TRAPS (INCL. POLE/DOG-PROOF TRAPS)

TARGET NONTARGET

Species Killed Released Killed Released

Virginia Opossum 177 2 25 22

Feral/Free-roaming Cat* 15 3 4 8

Bobcat 284 9 9 34

Mountain Lion 39 0.2 0.6 1

Coyote 5,316 11 30 13

Northwestern Gray Wolf (Canis lupus occidentalis) 48 21 0.2 0.6

- Great Plains WolfT&E (C. l. nubilus) 196 29 0 0.2

- Mexican Gray WolfT&E (C. l. baileyi) 0 1 0 0.8

- Feral/Free-Roaming Dog* (C. l. familiaris) 51 19 2 29

Red Fox 357 3 14 14

Arctic Fox 64 0 0 0

Common Gray Fox 444 1 18 16

Black Bear 2 0.4 4 16

Grizzly BearT&E 0 0.4 0 0.4

River Otter 2 0 18 0.6

Badger 169 3 35 14

Raccoon 2,003 41 178 34

Striped Skunk 183 0.2 85 4

Other Predator (6T, 6NT – 10 sp.)

1 4 0.2 10 2

Feral Swine* 38 0 1 0

Other Hoofed Mammal (2T, 8 NT – 8 sp.) 1 2 0.2 8 18

Beaver 1,550 0.4 0 0

Nutria* 38 0 2 0

Muskrat 66 0 10 0.6

Mountain Beaver 10 0 0 0

Yellow-bellied Marmot 35 0 0.6 0

Woodchuck 19 0 1 0.4

Porcupine 11 0 21 4

Other Rodents/Rabbits/Armadillo (165T, 16NT – 25 sp.) 1 17 0 17 2

Bald Eagle 0 0 0.8 0.4

Red-tailed Hawk 11 236 0 0.2

Golden Eagle 0 0.2 0.2 0

American Kestrel 55 220 0 0

Great-horned Owl 3 37 0 0.4

Common Barn Owl 2 11 0 0

Other Raptor (16T, 5NT – 17 sp.) 1 5 28 5 5

Double-crested Cormorant 0 114 0 0

Other Non-passerine Bird (4T, 19NT – 21 sp.) 1 1 0 16 5

Common Raven 21 1 1 1

Other Passerines (7T, 12NT - 13 sp.) 1 13 0.2 4 2

Reptiles (0T, 5NT+1 Group# - 7NT max) 1 0 0 1 9

AVE. ANNUAL NO. ANIMALS (84T, 100NT – 133 sp.) 11,251 792 521 258

% OF ALL TARGET AND NONTARGET SPECIES TAKEN 87.7% 6.2% 4.1% 2.0% 1

* See Appendix 1 for other species taken * Introduced Species # Unidentified Turtles 

T&E Federal threatened and endangered species T – Target NT - Nontarget
6

2 HAZARDS

2.1 Health and Human Safety

Human health and safety hazards associated with foothold traps include potential cuts, abrasions, bruises, or 

possibly bone fractures of the hands or fingers from the accidental discharge of a trap. Generally, most 

injuries occur while setting or placing traps which make the WS personnel using foothold traps most 

susceptible to such injuries. The setting and removing of foothold traps requires repeated bending, kneeling, 

and pounding and pulling stakes from the ground which may lead to back strains. The removal of animals 

from foothold traps may lead to bites or scratches.

Members of the public may come into contact with foothold traps. Because traps are set underground and 

“camouflaged” under sifted dirt or other debris, most contact would be to the foot from the trap being stepped 

on. Trap size would make a difference regarding the potential for the foothold trap to injure the public. The 

most common trap used is a No. 3 which has jaws about 4” x 5.5” which could potentially close around a 

small child’s foot or someone’s toes. It is possible that someone disturbing a trap site could have their hand 

on the ground and cause the trap to close on their fingers, but this is highly unlikely. To mitigate such 

possibilities, WS personnel post signs at entrances to properties, or on roads in the area, to alert the public 

that traps are present. Finally, it is possible for someone to find a captured animal and attempt to free it which 

could expose them to bites or scratches as well as the traps.

2.2 Environmental

The environmental hazards associated with foothold traps include the injury or death of target and nontarget 

animals. Animals may die from exposure to the elements such as heat or cold, other causes associated with 

capture, or euthanasia by the WS specialist. Foothold traps may accidentally capture nontarget animals 

including other wildlife species, domestic animals, or livestock (Table 1 lists nontarget species captured from 

FY11 to FY15). Injuries to animals include cuts, sprains, strains, broken bones and the disruption of 

circulation. Injuries may result from the closure of the trap, the animal attempting to escape, and length of 

time the animal remains in the trap. The BMPs (AFWA 2016) provide standards to minimize injuries from

trapping by incorporating findings from past and new research. Much research had been done on selectivity, 

injuries, humaneness, and other characteristics related to traps which provided AFWA (2016) a good starting 

point.

Olsen et al. (1986) reported that cutaneous lacerations were the most common injury for coyotes captured in 

unpadded (60% occurrence) or padded traps (48%). Phillips et al. (1992) reported similar results when 

comparing the incidence of injuries to coyotes between padded traps and two different types of unpadded 

long spring traps. Onderka et al. (1990) reported similar types of injuries to coyotes with unpadded traps 

which had the highest damage score followed by Novak snares and padded-jaw traps, with the least damaging 

trap being Fremont snares (snares are covered in another Risk Assessment, but it is a useful comparison).

The Fremont snare has also been shown to cause the least amount of injury in trapping lynx (Lynx canadensis) 

when compared to the padded foothold trap (Mowat et al. 1994). In addition to physical impacts to target and 

nontarget animals, physiological and behavioral changes can occur and will vary based on the type of foothold 

trap being used and how long animals are held. Kreeger et al. (1990) demonstrated that red foxes held by 

foothold traps had elevated levels of adrenocorticotropin, β-endorphin, and cortisol when compared to 

controls. These hormones or neurotransmitters are indicative of a physiological stress response in mammals.

Trapped foxes also had a higher incidence of adrenal gland, and heart and lung effects when compared to 

controls; however, the impacts were not considered to be life-threatening. Differences in padded versus non-
7

padded foothold traps were also noted showing that the padded traps reduced physiological impacts when 

compared to non-padded traps. Similar responses as well as additional physiological and behavioral impacts 

have also been noted in other animals held in traps such as European badgers (Meles meles), raccoons, and 

American black bear (Schutz et al. 2006, Proulx 1993, Powell 2005). Padded-jaw foothold traps consistently 

demonstrated a reduced risk of injury and stress to target wolves and nontarget animals (Turnbull et al. 2013).

However, their success rate was not as high as regular steel-jawed foothold traps. Padded-jaw foothold traps 

had fairly similar take for coyotes as steel-jawed foothold traps, though. Other than potential injury to animals, 

foothold traps are not expected to cause other damage to the environment.

The enclosed foothold trap, dog-proof trap, is designed to target animals that are capable of reaching inside 

the narrow entrance of the trap (normally 1.5 inches in diameter) to push or pull the trigger, which reduces 

the risk of nontarget animals from being captured, such as dogs or coyotes. The triggers are generally 

recessed 2 to 3 inches inside the trap, which excludes many potential nontarget animals from reaching inside 

the narrow entrance and pulling or pushing the trigger.

3 RISKS

3.1 Health and Human Safety

The risk of human injury is mainly to WS personnel placing foothold traps. Injuries related to traps closing 

on fingers are relatively minor. Most injuries are associated with larger traps, No. 4 and 41⁄2 wolf and beaver 

traps6

. WS employees engaged in trapping receive trapper education training to reduce risk of injury. WS 

personnel are encouraged to use gloves7 and job aids including stake pullers and trap setter devices to 

minimize injury risk.

WS field and office employees filed an annual average of 79 Office of Workmen’s Compensation (OWCP) 

claims for strained backs, lacerations, animal bites, burns, and other injuries that occurred on the job from 

FY13 to FY15. Of these, an annual average of 2.3 (1.3 compression/contusions, 0.7 lacerations, and 0.3 

accident) were related to setting foothold traps with contusions and lacerations the extent of injuries.

Additionally, WS employees had an average of 19 injuries from falls, slips, twists, and repetitive activities that 

resulted in lacerations, sprains, contusions, strains, compression bruises, and fractures that were associated 

with field activities, but the injury was not readily associated with any specific activity such as setting foothold 

traps. Considering the number of employees (~1,900), these claims are relatively few for the number of hours 

spent afield (the OWCP claims from FY13 to FY15 also includes office employees and injuries such as carpal 

tunnel syndrome). Thus, risks of setting foothold traps are relatively minor to employees.

The risk of injury from captured animals is also minimal. Typically, employees dispatch captured target 

animals with a gunshot to the brain8

. The highest risk is typically from animals that are trapped in foothold 

traps that are not staked, but are attached to drags; employees may accidentally come across a hidden animal 

that is trapped when approaching the location of the set. Few employees over many years have been injured 

by such captured animals. WS personnel enter trapping areas cautiously and know where traps with drags 

versus stakes are placed using extra caution in these situations. A more obvious risk is associated with the 

release of captured animals. WS employees usually carry a catch-pole (a pole with a cable loop that can hold 

 6 Small traps (#3 or less), especially those with long springs, are not likely to cause injuries to people.

7 Setting traps may sometimes require free hands and gloves may not be worn at all times.

8 WS personnel are trained and certified to use firearms which results rapid euthanasia and this is discussed in the Firearms Risk Assessment.
8

an animal prior to release). Catch-poles are very effective in handling wildlife, but an animal’s behavior 

following release, though mostly predictable, is a primary concern. If an animal is too large, is in an area 

where the use of firearms would cause a safety concern, or is being trapped for a research project, an animal 

may be immobilized or euthanized with drugs; though usually not a problem, drugged animals can also be a

risk9 which will be discussed separately under the Immobilization and Euthanasia Risk Assessment.

From FY13 to FY15, WS operational field personnel annually averaged 3 bites or injuries annually from 

animals and some of these were from trapped animals. One was a coyote captured in a foothold trap that bit 

the employee before it was euthanized. Another bite was from a feral cat that had been caught and released 

from a foothold trap; the cat bit the WS employee while it was in the process of being transferred to a local 

animal shelter. Another feral cat was captured in a cage trap and bit the WS employee while transferring 

custody. A black bear in a culvert trap bit a WS employee on the hand before being released after relocation.

Two WS employees were bit by feral or free-roaming dogs being hand gathered, but one escaped capture.

Finally, a bat that was caught by another agency, bit a WS employee while the bat was being sampled for a 

variety of diseases (primarily rabies). Two other dog bites occurred from dogs at private residences while WS 

personnel were making contact with people requesting WS assistance. For context, WS operations annually 

killed 43,576 and released 11,432 predators with methods conducive to being bitten from FY13 to FY5. Thus, 

an average of 2.3 bite incidents were related to capturing them alive while hand gathering (0.7), transferring 

custody to another agency after capture (0.7), relocating an animal (0.3), in the process of euthanizing a livecaptured animal (0.3), and while handling an animal for disease sampling (0.3). For bite incidents that 

occurred from released animals (2.0), WS had a ratio of one bite per 5,700 releases. For animals to be 

euthanized, the ratio was much less at 1 bite for 145,000 animals killed. Overall, the bite ratio was 1 bite for 

every 18,000 animals captured with methods where the animal would be captured alive. This is a minimal 

risk. 

It should be noted that 2 bites in three years occurred as dog attacks; this again is a minimal number as the 

Centers for Disease Control (2015) estimates 4.5 million dog bites alone occur annually throughout the United 

States. Thus again, we believe these risks are minimal and well within the norms.

In addition to field personnel, from FY13 to FY15, NWRC personnel received an annual average of 1.0 animal 

bites or injuries from research animals with bites from a skunk (0.3) and a rat (0.3), and a bone fracture from 

feral swine (0.3). Lab animal bites typically come from caged animals during routine maintenance or research.

It is not known whether these particular animals were from trapped animals from research that was being 

carried out in the field.

WS personnel could be exposed to animals carrying diseases such as rabies. All recorded bites from FY13 to 

FY15 and an annual average of two lacerations/splashes were from potentially diseased animals (rabies). Only 

one coyote bite (0.3) was from an animal in a known foothold trap and another, a cat bite, was from an animal 

caught in a foothold trap, but occurred when the animal was in the process of being transferred to another 

agency. The remaining bites had the potential for transmitting the rabies virus. None of the animals involved 

in the incidents was identified as subsequently rabid with the exception of fluids from tissue from a known 

rabid skunk that splashed into the eye of a researcher. Thus, a potential for 5 animals per year caused concern 

potentially for exposure to rabies from FY13 to FY15. Personnel that have the potential for exposure to rabid 

animals, have the option of obtaining the rabies prophylactic series with follow up boosters to reduce the 

potential for contracting the disease if exposed through a bite, laceration, or contact with animal fluids.

 9 WS personnel are trained and certified to use immobilization and euthanasia drugs and risks associated with their use are discussed in the 

Immobilization and Euthanasia Drug Risk Assessment.
9

General exposure to animals is common for many WS employees, but considering the number of animals 

captured or handled, the risk of contracting a wildlife-borne disease is minimal.

The placement of foothold traps in urban and rural areas may expose the public to trap sets; however, WS 

conducts WDM mostly on private lands where the risks are principally to WS employees and the landowners 

that receive WS assistance. Foothold traps are mostly placed in areas not visible or visited by the public. WS 

personnel consider the potential for the public to be in an area and generally do not use traps where people 

would frequent for three reasons: 1) the potential for the public to be exposed to a captured animal, 2) the 

potential for persons, particularly small children, accidentally stepping on a trap, or 3) the possibility of theft.

To minimize the risks to human health and safety, the WS policy requires warning signs be posted at the 

entrance to areas where foothold traps are in use. Additionally, foothold trap sets are frequently underground 

with dirt or other natural debris sifted over them, camouflaging the sets from both animals and humans.

Someone with knowledge of trap sets could, however, disturb the sites or steal the traps. Since traps are 

often set in remote areas, mostly on private lands, and camouflaged, the likelihood of incidental public contact

is minimized. Additionally, WS has received no reports of members of the public being injured by a set trap

from FY11 to FY15, and for that matter, over the last 25 years. Considering the number of trap nights in a 

given year (1.1 million), the risk of public exposure is negligible.

3.2 Environmental

WS recognizes that foothold traps may result in some risk of injury or death for nontarget wildlife and 

domestic animals (7.2% chance of catching a nontarget species – Table 1). WS supports efforts to make 

foothold trapping as humane as possible for the target species as well as minimizing impacts to nontarget 

vertebrates and is actively involved in research efforts to minimize impacts (Fagerstone and Keirn 2012). WS 

recognizes the BMPs for trapping as developed by AFWA (2016) emphasize animal welfare, efficiency, 

selectivity, practicality, and safety and will use these guidelines when conducting trapping programs. The risk 

of capturing nontarget animals is minimized by the selection of the suitable trap size, use of pan-tension 

devices, selection of the proper bait, lure or attractant, and appropriate trap placement. All of these issues are 

addressed in trapper education programs required of WS personnel and reinforced during annual meetings 

by discussion with experienced trappers. Additionally, supervisors monitor WS personnel and ensure that 

trapping is carried out humanely and efficiently.

Selecting the proper trap size can reduce the risk of catching animals larger than the target species because 

they can pull free if the trap is activated. Pan-tension devices reduce the risk of capturing animals which weigh 

less than target animals. Turkowski et al. (1984) reported nontarget exclusion efficiency rates of 92, 95 and 

100% for shear-pin, leaf spring, and steel tape tension devices, respectively compared to 6% for the standard 

trap set for coyotes. Kamler et al. (2000) used pan-tension devices to show a reduced rate of nontarget 

captures in foothold traps designed to trap coyotes and bobcats. Nontarget captures were greatest for 

raccoons which have body weights in the range for the target species and would not be feasible to exclude 

from trapping. Kamler et al. (2002) reported 100% exclusion for the swift fox and skunk in padded traps using 

a pan-tension device while trapping coyotes. Kamler et al (2008) reported an exclusion efficiency of 93% for 

nontarget animals using soft-catch foothold traps and pan-tension devices while still providing effective 

trapping efficiencies for the black backed jackal (Canis mesomelas). The use of baits, lures, and attractants 

that are preferred by the target species minimizes the chances of capture of nontarget species. Jojola et al. 

(2009) demonstrated an approximate two fold probability of capture for nutria using attractants. The attractant 

allows for more targeted management of vertebrates and will reduce the potential for trapping nontarget 

vertebrates. The home ranges, habitat preferences, travel corridors, population densities of both target and 

nontarget species are considered when selecting locations for the placement of foothold traps. WS policy 
10

requires that foothold trap placement be a minimum of 30 feet away from animal carcasses, often used as 

“draw stations,” to minimize the risk of capturing scavengers (WS Directive 2.455). Signs warning of the 

placement of foothold traps in the area alert people to the presence of traps. The signs advise people to 

restrain pets or their livestock from going to the area being trapped to minimize the risk of accidental capture.

From FY11 to FY15, WS personnel took an average of 779 nontarget animals. The most common species 

taken were raccoons (27%), striped skunks (11%), badgers (6%), opossums (6%), coyotes (5%), and 

bobcats (5%) which accounted for half of the nontarget species taken. The most common taken lethally were 

raccoons (34%), striped skunks (16%), badgers (7%), coyotes (6%), and North American porcupine (4%).

The number taken for any species, especially lethally, was minimal and all species were common except for 

grizzly bear and wolves. Of these, all were freed except for one northwestern gray wolf which is no longer a 

T&E species. Thus, take for the less common species was minimal. WS consults with the U.S. Fish and 

Wildlife Service under Section 7 of the Endangered Species Act and take was all within the levels authorized.

WS did not jeopardize any species population.

Of additional concern is the take of domestic animals. From FY11 to FY15, an annual average of 45 feral/free 

roaming nontarget animals were captured with 31 dogs, 12 cats, and 2 livestock; of these 2 dogs and 4 cats 

were euthanized and the remainder released. It is believed that the 6 animals euthanized were feral animals.

This is a minimal number and supports that nontarget domestic animal risk of capture from foothold traps is 

very low.

4 UNCERTAINTIES AND CUMULATIVE IMPACTS

Uncertainty in this risk assessment is negligible as WS has over 100 years using foothold traps for WDM 

activities and understands potential risks of using the variety of foothold traps available. The knowledge 

gained from this experience has helped reduce uncertainties.

Cumulative impacts could occur to target and nontarget animals. However, cumulative impacts are addressed 

in National Environmental Policy Act documents such as WS (2017)

10 and found not to be significant to any 

native population. Additional, the “Introduction to Risk Assessments for Methods Used in Wildlife Damage 

Management” looks at all take from all WDM activities by WS and none shows a significant level of take for 

any native species. From a human health perspective, the use of foothold traps in WDM will not have any 

known cumulative impacts.

5 SUMMARY

WS uses foothold traps as one tool in its damage management programs, typically as a component of an 

integrated approach to managing wildlife issues. WS works cooperatively with other natural resource 

agencies at the state, national and international level to develop effective and humane trapping measures 

while minimizing exposure to human health and nontarget animals. Implementation of program-specific 

measures designed to reduce human interactions with traps reduces the risk of these types of management 

tools to the public and workers, and WS will continue to evaluate and implement, where appropriate, new 

protection measures. In addition, advancements in trap use and design have resulted in more effective and 

humane trapping of target animals while reducing the potential for nontarget captures in foothold traps. In 

fact, nontarget capture has decreased in the last 25 years from a nontarget capture rate of 23.3% in FY88 

(USDA 1997, Appendix P, pp. 23-27) to 6.1% average from FY11 to FY15 with the number of nontarget

 10 WS NEPA documents are available @ https://www.aphis.usda.gov/aphis/ourfocus/wildlifedamage/programs/nepa.
11

species killed dropping from 13.9% to 4.1% in 6 states (AZ, CO, NM, OK, TX, and UT) as analyzed in USDA 

(1997, Appendix P, pp. 23-27). The nontarget percentages was less in those states from FY11 to FY15 at 

5.9%. The use of pan tension devices, with most being implemented in the 1990s, likely accounted for the 

largest portion of the decrease. Additionally, target take has decreased five-fold from FY88 to FY11-FY15, 

from a total take of 21,992 to 4,244 (19.3%) (USDA 1997, Appendix P, pp 23-27). This data indicates that 

foothold trap use has declined significantly and that their use is more selective for the target animal. WS will 

continue to support and conduct research and education that supports more humane and effective trapping 

methods and will implement these measures in programs, where appropriate, to further reduce risk to 

nontarget animals.

Overall, the evaluation of risks to human health and safety and the environment from the use of foothold traps 

are minimal. WS personnel are professional with their use of foothold traps and try to minimize the identified 

potential risks. The issue of humaneness is minimized by WS using the BMPs (AFWA 2016) as guidelines for 

foothold traps.

6 LITERATURE CITED

Association of Fish and Wildlife Agencies (AFWA). 2016. Furbearer Management: Best Management Practices for 

Trapping in the United States. @ http://fishwildlife.org/?section=best_management_practices. Last visited 

1/10/2017.

Batcheller, G. R., T. A. Decker, D. A. Hamilton, and J. F. Organ. 2000. A vision for the future of furbearer management in 

the United States. Wildl. Soc. Bull. 28(4):833-840.

Butchko, P. 1990. Predator control for the protection of endangered species in California. Proc. Vertebr. Pest Conf. 

14:237-240.

Centers for Disease Control (CDC). 2015. Preventing Dog Bites. CDC, National Center for Emerging and Zoonotic 

Infectious Diseases. May 18. @ https://www.cdc.gov/features/dog-bite-prevention/. Last visited 1/10/2017.

Fagerstone, K. A., and G. Keirn. 2012. Wildlife Services - A leader in developing tools and techniques for managing 

carnivores. Wildl. Damage Manage. Conf. Proc. 14:44-55.

Fall, M. W. 2002. The search for acceptable animal traps. Proc. Vertebr. Pest Conf. 20:31-377. 

Jojola, S., G. Witmer, and P. Burke. 2009. Evaluation of attractants to improve trapping success of nutria on Louisiana 

coastal marsh. USDA National Wildlife Research Center - Staff Publications. Paper 929. @ 

http://digitalcommons.unl.edu/icwdm_usdanwrc/929. Last visited 7/14/2014.

Kamler, J. F., N. F. Jacobsen, and D.W. Macdonald. 2008. Efficiency and safety of soft catch traps for capturing blackbacked jackals and excluding nontarget species. S. African J. Wildl. Res. 38(2): 113-116.

Kamler, J. F., W. B. Ballard, R. L. Gilliland, and K. Mote. 2002. Improved trapping methods for swift foxes and sympatric 

coyotes. Wildl. Soc. Bull. 30(4): 1262-1266.

Kamler, J. F., C. Richardson and P. S. Gipson. 2000. Comparison of standard and modified soft catch® traps for 

capturing coyotes, bobcats, and raccoons. Wildl. Damage Manage. Conf. Proc. 9:77-84.

Kreeger, T. J., P. J. White, U. S. Seal, and J. R. Tester. 1990. Pathological responses of red foxes to foothold traps. J.

Wild. Manag. 54(1):147-160.
12

Mowat, G., B. G. Slough, and R. Rivard. 1994. A comparison of three live capturing devices for lynx: Capture efficiency 

and injuries. Wildl. Soc. Bull. 22:644-650.

Olsen, G. H., S. B. Linhart, R. A. Holmes, G. J. Dasch, and C.B. Male. 1986. Injuries to coyotes caught in padded and 

unpadded steel foothold traps. Wildl. Soc. Bull. 14(3): 219-223.

Onderka, D. K., D. L. Skinner, and A. W. Todd. 1990. Injuries to coyotes and other species caused by four models of 

footholding devices. Wild. Soc. Bull. 18:175-182. 

Phillips, R. L., F. S. Blom, and G. J. Dasch, Jr. 1992. Field evaluation of three types of coyote traps. Proc. Vertebr. Pest 

Conf. 15:393-395.

Powell, R. A. 2005. Evaluating welfare of black bears (Ursus americanus) captured in foot snares and handled in winter 

dens. J. Mammol. 86:1171-1177.

Proulx, G. 1993. Injuries and behavior of raccoons (Procyon lotor) captured in the Soft Catch and the EGG traps in 

simulated natural environments. J. Wildl. Dis. 29(3):447-452.

Schutz, K. E., E. Agren, M. Amundin, B. Roken, R. Palme, and T. Morner. 2006. Behavioral and physiological responses 

of trap-induced stress in European badgers. J. Wildl. Manage. 70(3): 884-891

Turkowski, F. J., A. R. Armistead and S. B. Linhart. 1984. Selectivity and effectiveness of pan tension devices for coyote 

foothold traps. J. Wildl. Manage. 48:700-708.

Turnbull, T. T., J. W. Cain, and G. W. Roemer. 2013. Anthropogenic impacts to the recovery of the Mexican Gray Wolf 

with a focus on trapping-related incidents. Wildl. Soc. Bull. 37(2):311-318.

U.S. Department of Agriculture (USDA). 1997. Animal Damage Control Program Final Environmental Impact Statement: 

Appendix P-Risk Assessment of Wildlife Damage Control Methods Used by the USDA Animal Damage Program. Pp. 

23-27. Revision. USDA-APHIS-WS, Operational Support Staff, 6505 Belcrest Rd., Room 820 Federal Bldg., 

Hyattsville, MD 20782. 337 pp. 

Wildlife Services (WS). 2017. Predator damage management in Colorado. Environmental Assessment, Finding of No 

Significant Impact, and Record of Decision. 1/19/2017. USDA-APHIS-WS, 12345 West Alameda Pkwy., Suite 210, 

Lakewood, CO 80228. 334 pp.

7 PREPARERS

7.1 APHIS WS Methods Risk Assessment Committee

Writers for “Use of Foothold Traps in Wildlife Damage Management Risk Assessment”:

Primary Writer: Thomas C. Hall

Position: USDA-APHIS-WS, Operational Support Staff, Staff Wildlife Biologist, Fort Collins, CO

Education: BS Biology (Natural History) and BA Psychology – Fort Lewis College; MS Wildlife Ecology – Oklahoma State 

University

Experience: Special expertise in wildlife biology, identification, ecology, and damage management. Thirty-one years of 

service in APHIS Wildlife Services including operations and research in CO for research and OR, GU, CA, OK, and 

NV for operations conducting a wide variety of programs including bird damage research and management, 

livestock protection (predators and birds), invasive species management, wildlife hazard management at airports, 

property and natural resource protection including waterfowl, brown tree snake, feral swine, rodent, and beaver 

damage management. Expert in preparing environmental documents for WS programs to comply with the National 
13

Environmental Policy Act and the Endangered Species Act. For foothold traps specifically, have used and trained 

with all types of foothold traps in WDM and supervised employees that used them in their duties. Was a Certified 

Trapping Instructor in Oklahoma (Oklahoma Trappers Assoc.).

Primary Editor/Reviewer: Michael W. Fall (retired)

Positions: USDA-APHIS-WS, National Wildlife Research Center: Supervisory Research Wildlife Biologist; Chief 

Predation Management Research and Mammal Damage Control Research (retired 2001) and Senior Staff Biologist 

(rehired annuitant), Office of the Director (retired 2012), Fort Collins, CO

Education: BA, MS Biology/English/Psychology, Bowling Green State University; Ph.D. Entomology/Vertebrate Pest 

Management, Penn State University; Certificate in Management and Administration, University of Denver 

Experience: Special expertise in wildlife damage management including animal capture research; field work in US and 

more than 20 countries; 15 years development and coordination of US participation in the Agreement on 

International Humane Trapping Standards with Russia, Canada, and the European Union and Head of US Delegation.

Fifty-one years employment in wildlife biology operations and research, including 42 years with APHIS Wildlife 

Services (and predecessors) at the National Wildlife Research Center and field stations, conducting a variety of 

research, supervision, and policy development with special emphasis on mammals.

Editors/Contributors for “Use of Foothold Traps in Wildlife Damage Management Risk Assessment”:

Editor/Contributor: Andrea Lemay 

Position: USDA-APHIS-Policy and Program Development (PPD), Environmental and Risk Analysis Services (ERAS), 

Biological Scientist, Raleigh, NC

Education: BS Plant and Soil Science (Biotechnology) - University of Massachusetts; MS Plant Pathology -North Carolina 

State University 

Experience: Thirteen years of service in APHIS conducting risk analysis. Four years of experience in preparing 

environmental analyses in compliance with the National Environmental Policy Act.

Editor/Contributor: Fan Wang-Cahill 

Position: USDA-APHIS-Policy and Program Development (PPD), Environmental and Risk Analysis Services (ERAS), 

Environmental Health Specialist

Riverdale, MD

Education: B.S. Biology and M.S. Hydrobiology - Jinan University, Guangzhou, China; Ph.D. Botany (Ultrastructure/Cell 

Biology) – Miami University

Experience: Joined APHIS in 2012, preparing human health risk assessments and providing assistance on 

environmental compliance. Prior experience before joining APHIS includes 18 years environmental consulting 

experience specializing in human health risk assessments for environmental contaminants at Superfund, Resource 

Conservation and Recovery Act (RCRA), and state-regulated contaminated facilities.

Editor/Contributor: Jim Warren 

Position: USDA-APHIS-Policy and Program Development (PPD), Environmental and Risk Analysis Services (ERAS), 

Environmental Toxicologist, Little Rock, AR 

Education: B.S. Forest Ecology and M.S. Entomology – University of Missouri; Ph.D. Environmental Toxicology –

Clemson University

Experience: Eight years of experience working for APHIS preparing ecological risk assessments and providing 

assistance on environmental compliance. Prior experience before joining APHIS includes other government and 

private sector work regarding ecological risk assessments related to various environmental regulations.

Editor/Contributor: Ryan Wimberly 

Position: USDA-APHIS-WS, Operational Support Staff, Staff Wildlife Biologist, Madison, TN

Education: BS Wildlife Management and Ecology – Northwest Missouri State University

Experience: Special expertise in wildlife biology, ecology, and damage management. Seventeen years of service with 

APHIS Wildlife Services, including operations and research, conducting a wide variety of programs, including bird 
14

damage research and management, livestock protection, invasive species management, wildlife hazard 

management at airports, property, and natural resource protection. Expert in preparing environmental documents 

for WS programs to comply with the National Environmental Policy Act and the Endangered Species Act.

Data Contributor: Joey Millison

Position: USDA-APHIS-WS Information and Technology (IT), Junior Applications Developer

Education: Information and Technology coursework from various sources

Experience: Eleven years of experience in APHIS, WS Management Information System (MIS) Group. Retrieves WS field 

data from the MIS for writers, reviewers, and editors.

7.2 Internal Reviewers

USDA APHIS Wildlife Services

Reviewer: Michael Bodenchuk

Position: USDA-APHIS-WS, State Director/Supervisory Wildlife Biologist, San Antonio, TX

Education: BS Wildlife Sciences, New Mexico State University

Experience: Special expertise in wildlife damage management including predation management for livestock and wildlife 

protection and feral swine management. Four years wildlife and range management with NM Dept. of Agriculture, 6 

years wildlife and land management in the private sector and 25 years wildlife damage management with APHIS WS 

in MS, SD, NE, UT and TX. Experienced in a wide variety of programs including aquaculture and livestock protection, 

urban damage management, T&E wildlife management, human health and safety and crop protection from a 

diversity of species including beavers, predators, birds, feral swine and rodents. International experience in 

predation and feral swine management and wildlife capture methods.

Reviewer: Gary Littauer

Position: USDA-APHIS-WS, Assistant Regional Director/Supervisory Wildlife Biologist, Fort Collins, CO

Education: BS Wildlife Management Iowa State Univ., MS Biology, New Mexico State University

Experience: Special expertise in wildlife biology, ecology, and damage management including supervising an aerial 

operation program. Twenty eight years of service for APHIS-WS in TX, MS, and NM in a wide variety of programs 

(livestock, aquaculture, property, human health and safety, and natural resource protection) including predator, 

beaver, and rodent damage management activities.

Reviewer: Alan May

Position: USDA-APHIS-WS, State Director/Supervisory Wildlife Biologist, Albuquerque, NM

Education: BS Wildlife and Fisheries Sciences, Texas A&M University

Experience: Special expertise in wildlife biology, ecology, and damage management including supervising an aerial 

operation program. Twenty nine years of service in APHIS-WS in TX, NH, VT, MS, and NM with experience in a wide 

variety of programs (livestock , aquaculture, dairy, property, and natural resource protection) including predator, 

bird, beaver, feral swine, and rodent damage management activities.

Reviewer: John Steuber

Position: USDA-APHIS-WS, State Director/Supervisory Wildlife Biologist, Billings, MT

Education: BS Biology, BS Wildlife Management Texas A&M University

Experience: Special expertise in wildlife biology, wildlife damage management, and aviation program management. 

Twenty-seven years of service in APHIS-WS including a wide variety of programs such as endangered species 

protection (avian and mammalian predators), livestock protection (avian and mammalian predators), property and 

resource protection (aquatic rodent and feral hog damage management). Expert in managing statewide aviation 

programs (CA, OK, and MT). Sixteen years of experience as a State Director managing APHIS-WS Statewide 

Programs in OK and MT.
15

USDA APHIS Animal Care (AC)

APHIS Reviewer: Robert Gibbens

Position: USDA-APHIS-AC, Regional Director, Animal Welfare Operations, Fort Collins, CO

Education: BS Zoology and Doctor of Veterinary Medicine, Oklahoma State University

Experience: Special expertise in veterinary medicine and animal welfare, including animal welfare of free-ranging wild 

animals. Twenty four years of service in APHIS Animal Care as Veterinary Medical Officer, Field Supervisor, and 

Regional Director. 

USDA APHIS Veterinary Services (VS)

APHIS Reviewer: Donald Herriott, DVM

Position: USDA-APHIS-VS, District 5 Director, Ft. Collins CO

Education: BS General Science, Dr. Veterinary Medicine Oregon State University; MS Public Health: Epidemiology, 

University of Minnesota 1994.

Experience: Two years mixed animal veterinary practice in OR, 5 years VS Section Veterinary Medical Officer in WA and 

MN, 4 years VS Area Epidemiology Officer in OR, 15 years VS Area Veterinarian in Charge in OR, 3 years Associate 

Regional Director/District Director in Ft. Collins, CO.

7.3 Peer Reviewers

The Office of Management and Budget requires agencies to have peer review guidelines for scientific 

documents. The APHIS guidelines were followed to have “The Use of Foothold Traps in Wildlife Damage 

Management Risk Assessment” peer reviewed. WS worked with the Association of Fish and Wildlife Agencies 

to have experts review the documents. 

7.3.1 Peer Reviewer Agencies Selected by the Association of Fish and Wildlife Agencies

Reviewer: Association of Fish and Wildlife Agencies 

Reviewer: Michigan Department of Natural Resources

Reviewer: New Mexico Department of Game and Fish

Reviewer: North Dakota Game and Fish Department

Reviewer: Pennsylvania Game Commission Bureau of Wildlife Management

7.3.2 Comments

Comments regarding the quality of the risk assessment and concerns:

1. Assumptions and uncertainties were addressed adequately, and references were appropriate.

2. Data was sufficient in the risk assessment to assess effectiveness and safety in the risk assessment.

3. Overall, I felt the risk assessment was well-written and included all pertinent information. I have no concerns 

or suggestions for improvement.

4. Document is well written and comprehensive. Thumbs up.

5. Question: Why the 30-foot setback?: Response: WS Policy is to use the 30 foot setback when using draw 

stations or other visible “bait” to reduce the incidence of nontarget take. This does not apply to the capture of 

mountain lions or other large predators, since pan-tension devices eliminates capturing most nontarget 

species. This is discussed in Footnote #4.

Peer reviewers provided a few editorial comments on the manuscript. These were appreciated and 

incorporated into the final document. 
16

Appendix 1. “Other Species” Included in Tables.

Table 1

Other predator = small Asian mongoose, swift fox, kit fox, fisher, short-tailed weasel, mink, ringtail, hog-nosed skunk, 

hooded skunk, and western spotted skunks. 

Other hoofed mammal = collared peccary, moose, axis deer, mule deer, white-tailed deer, pronghorn, feral cattle*, and 

feral sheep*

Other rodent and rabbit, and other mammal = black-tailed prairie dog, California ground squirrel, rock squirrel

Richardson’s ground squirrel, Columbia ground squirrel, arctic ground squirrel, eastern chipmunk, Nearctic brown 

lemming, Ord’s kangaroo rat, eastern gray squirrel, fox squirrel, red squirrel, eastern woodrat, Mexican woodrat, 

bushy-tailed woodrat, cotton deermouse, marsh rice rat, brown rat*, black rat*, eastern cottontail, mountain 

cottontail, desert cottontail, European rabbit*, snowshoe hare, black-tailed jackrabbit, and nine-banded armadillo

Other raptor = turkey vulture, black vulture, osprey, white-tailed kite, Cooper’s hawk, northern harrier, red-shouldered 

hawk, Swainson’s hawk, rough-legged hawk, ferruginous hawk, snowy owl, barred owl, great gray owl, burrowing 

owl, short-eared owl, caracara, merlin and peregrine falcon

Other non-passerine = rock pigeon*, Eurasian collared-dove*, glaucous-winged gull, herring gull, Pomarine jaeger, 

greater white-fronted goose, Canada goose, mute swan*, wood duck, mallard, northern pintail, green-winged teal. 

Common eider, long-tailed duck, American bittern, great blue heron, snowy egret, sandhill crane, lesser yellowlegs, 

wild turkey and ring-necked pheasant

Other passerine = European starling*, red-winged blackbird, common grackle, black-billed magpie, American crow, 

Say’s phoebe, western kingbird, Lincoln’s sparrow, eastern meadowlark, western meadowlark, northern 

mockingbird, American robin and house finch

Reptile = American alligator, gopher tortoise, pond slider, southern painted turtle, common snapping turtle and 

unidentified turtle (0.4 released: SC – chicken turtle, pond slider, river cooter, and spiny softshell possible - 2 max)

* Introduced species