Human Health and Ecological Risk Assessment

for the Use of Wildlife Damage Management Methods

by USDA-APHIS-Wildlife Services

Chapter XXIII

Carcass Disposal in

Wildlife Damage Management

August 2022

Peer Reviewed Final

May 2023
i

CARCASS DISPOSAL IN WILDLIFE DAMAGE MANAGEMENT

EXECUTIVE SUMMARY

USDA APHIS Wildlife Services (WS) uses various carcass disposal methods as part of its wildlife 

damage management activities, including disposing of carcasses during disease outbreaks.

Federal and state regulations and internal USDA APHIS WS policies provide the requirements 

for proper carcass disposal to reduce environmental and human health impacts.

WS uses various carcass disposal methods, including leaving carcasses in the field, burial, openair burning, composting, rendering, landfill, incineration, and tissue digestion. Some carcasses

may also be donated for human consumption where appropriate and in compliance with federal 

and state regulations. APHIS WS disposes of carcasses more commonly as a result of wildlife 

damage management activities compared to disease outbreaks. WS leaves most carcasses in 

the field since most animals taken using lethal methods are individually taken or taken in small 

numbers and do not pose a threat to wildlife or humans. This method ensures disease is not 

moved off-site if a local outbreak is occurring. If an animal is diseased, it is turned over to the 

Health Department or disposed of appropriately to eliminate disease transmission to other wildlife.

As carcasses degrade, bodily fluids consisting of natural and anthropogenic chemical and 

biological leachate, and hazardous gases may be released into the environment. As a result, 

carcasses must be effectively managed to minimize the risk to human health and the environment. 

In addition, specific processes used to manage carcasses may also result in air emissions, liquid 

effluent, or solid byproducts that pose a risk to human health, animal health, and the environment.

The risk of carcass disposal to human health varies based on the number of animals being 

disposed of and whether a disease is a concern. The risk to human health from carcass disposal 

is generally low for all methods when following applicable federal and state regulations and APHIS 

WS policies. WS personnel are at the greatest risk from handling carcasses either from onsite 

disposal or from transporting carcasses to other sites for disposal. WS has two directives related 

to carcass disposal. WS policies and compliance with applicable federal and state regulations 

reduce the risk to WS employees and the public. 

Risk to ecological resources also varies based on the number of animals being disposed of and 

the method being employed for disposal. Decomposition products produced during carcass 

disposal can also pose a risk to ecological resources through air, soil, and water exposure. 

Leaving carcasses on-site in the field results in a greater potential for exposure to scavengers 

compared to the other disposal options, such as burial, rendering, incineration, and tissue 

digestion, where no exposure to scavengers would be expected. Animals that WS euthanizes

with drugs can pose secondary hazards to scavengers. Disposal of animals euthanized with drugs 

is dictated by applicable federal and state regulations, drug label instructions, or lacking such 

guidelines, by deep burial, incineration, or at a landfill approved for such disposal. These would 

also apply in cases of carcass disposal where zoonotic disease or chemical contaminants are a 

concern. WS uses disposal options to reduce the risks to scavengers and other ecological 

resources through compliance with federal and state regulations and WS policies.
ii

Table of Contents

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

1.1 Carcass Disposal Methods............................................................................................. 1

1.1.1 Carcasses Left in Field............................................................................................... 2

1.1.2 Human Consumption ................................................................................................. 3

1.1.3 Unlined and Lined Burial ............................................................................................ 3

1.1.4 Open-Air Burning ....................................................................................................... 4

1.1.5 Composting and Above Ground Burial ....................................................................... 5

1.1.6 Rendering .................................................................................................................. 6

1.1.7 Landfill ....................................................................................................................... 7

1.1.8 Incinerator.................................................................................................................. 8

1.1.9 Alkaline Hydrolysis Tissue Digester............................................................................ 9

1.1.10 Anaerobic Biodigester .............................................................................................. 9

1.2 Use Pattern ...................................................................................................................10

2 HAZARDS..............................................................................................................................13

2.1 Human Health and Safety Hazards ...............................................................................13

2.2 Environmental Hazards .................................................................................................16

3 EXPOSURE AND RISKS.......................................................................................................17

3.1 Human Health and Safety Exposure and Risks .............................................................17

3.1.1 Disease.....................................................................................................................17

3.1.2 Cleaning and Disinfectants........................................................................................18

3.1.3 Contaminants............................................................................................................19

3.1.4 Injuries ......................................................................................................................22

3.2 Environmental Risks......................................................................................................22

3.2.1 Soils and Vegetation .................................................................................................23

3.2.2 Air Quality .................................................................................................................23

3.2.3 Water Quality ............................................................................................................24

3.2.4 Wildlife ......................................................................................................................25

4 UNCERTAINTIES AND CUMULATIVE EFFECTS.................................................................26

5 SUMMARY ............................................................................................................................26

6 LITERATURE CITED.............................................................................................................27

7 PREPARERS.........................................................................................................................36

7.1 APHIS WS Methods Risk Assessment Committee........................................................36

7.2 Internal Reviewers.........................................................................................................37

7.3 Peer Review..................................................................................................................38

7.3.1 Peer Reviewers Selected by the Association of Fish and Wildlife Agencies ..............38

7.3.2 Comments.................................................................................................................38

Appendix A. Average weights of animals lethally taken by WS in wildlife damage management 

and for comparison weights of animals from sportsmen harvest and vehicular accidents. ........40
1

1 INTRODUCTION

The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), 

Wildlife Services (WS) Program conducts wildlife damage management (WDM) and other related 

wildlife management activities that result in carcasses of animals. WS uses a variety of WDM 

methods that lethally take wildlife that may be left in the field (carrion), used for human 

consumption, rendered, taken to landfills, buried, incinerated, put into a waste digester, 

composted, or used as bait. Carcasses, especially in large numbers, can present potential risks 

to humans, domestic animals, wildlife, and the environment. As carcasses degrade, bodily fluids 

consisting of natural and anthropogenic chemical and biological leachate and hazardous gases 

may be released into the environment. As a result, carcasses must be effectively managed to 

minimize this potential. In addition, specific processes used to manage the carcasses may result 

in air emissions, liquid effluent, or solid byproducts that pose a risk to human health, animal health, 

and the environment and must be considered. This human health and ecological risk assessment 

provides a qualitative evaluation of potential risks and hazards to human health and the 

environment from exposure to carcasses taken by WS.

WS complies with all applicable regulations and policies for carcass disposal activities. WS 

policies regarding the disposition of wildlife carcasses are outlined in WS Directive 2.515 Disposal 

of Wildlife and WS Directive 2.5101

: Fur, Other Animal Parts, and Edible Meat Carcasses and 

USDA-APHIS Standard Operating Procedures for disposal (APHIS 2014, 2016, 2021). 

Management of carcasses taken in WDM mostly depends on the method used to take the animal 

(e.g., toxicant, euthanasia drugs, traps, and firearms) and the number of animals taken and 

carried out according to the WDM operational plan. Carcass retrieval is often necessary for 

zoonotic disease management, ecological, environmental, scientific, or public sensitivity 

purposes. In these instances, WS personnel make reasonable efforts to retrieve and dispose of 

wildlife carcasses that result from WS WDM activities. WS personnel comply with procedures 

outlined in the WS Field Operations Manual for the Use of Immobilization and Euthanizing Drugs 

and WS Directive 2.430 Controlled Chemical Immobilization and Euthanizing Agents. Animals 

euthanized with drugs that may pose secondary hazards to scavengers must be disposed of 

according to federal, state, county, and local regulations, drug label instructions, or lacking such 

guidelines by deep burial, incineration, or at a landfill approved for such disposal. WS is also 

guided by carcass management as conducted by APHIS Veterinary Services (VS) for livestock 

and poultry disease outbreaks and discussed in APHIS (2016).

1.1 Carcass Disposal Methods

Several carcass disposal options are considered for different WDM operations based on the type 

of project. If no known problem exists, such as a disease, carcasses may be left in the field to 

decompose or be removed for disposal. If an animal is taken with toxicants or drugs with potential 

secondary hazards or succumbs to a disease or environmental contaminant that could affect 

humans or wildlife, they are generally removed from the project site and managed with any 

number of disposal methods (APHIS 2016, 2021). Depending on the circumstances, the carcass 

may need to be decontaminated prior to removal, including being bagged, especially if an external 

contaminant or disease is present that can affect people, wildlife, or the environment. 

Depopulation in an area for disease suppression, such as a herd of captive white-tailed deer2 with 

chronic wasting disease or brucellosis, may require an increased level of carcass management

1 All WS Policy Directives referenced in this document can be found under Wildlife Damage – WS Program Directives @ 

http://www.aphis.usda.gov/wps/portal/aphis/ourfocus/wildlifedamage.

2 See the Introduction to Risk Assessments – Chapter I for scientific names. These are only given if not used in that Section
2

procedures to ensure that disease does not spread or odor does not become an issue (Mukhtar 

et al. 2012). WS conducts many WDM projects that result in carcasses but conducts few projects 

specifically for animal disease annually.

On-site disposal options include leaving carcasses in the field, unlined and lined burial, open-air 

burning, mobile incineration, and composting (APHIS 2016). Off-site disposal includes taking to 

unlined and lined burial sites, centralized composting, rendering, landfills, and fixed-facility 

incineration. Still, it can create additional concerns due to the potential for the transport vehicle to 

accidentally leach infection or be involved in an accident on the way to the disposal facility (Center 

for Food Security and Public Health 2014, APHIS 2016).

After removing contaminated carcasses from an animal health disease site, decontaminating

equipment, materials, and premises may be required to prevent or mitigate the spread of 

contaminants (APHIS 2018). Decontamination is the inactivation or reduction of contaminants by 

physical, chemical, or other methods to meet a cleanup goal. Cleaning and disinfecting are part 

of the decontamination process. USEPA (2022a, b) has the authority to regulate pesticides, 

specifically disinfectants. USEPA defines disinfectants as pesticides that are used to kill or 

inactivate disease-producing micro-organisms on inanimate objects.

All disposals will be made in a manner consistent with federal, state, county, and local regulations. 

All methods listed below are approved for the disposal of wildlife carcasses or parts thereof unless 

otherwise prohibited (APHIS 2021). 

1.1.1 Carcasses Left in Field

WS personnel often leave carcasses in the field, which 

become carrion (Figure 1). Carrion provides food or nutrient 

resources for various scavengers, including invertebrates,

vertebrates, and plants (Barton et al. 2012, Barton and 

Bump 2019). Carrion represents only a minimal portion of 

detritus in most ecosystems because plant litter is usually in 

much greater quantity (e.g., Parmenter and MacMahon 

2009), but its role in nutrient cycling and community 

dynamics is disproportionate as carrion is nutrient-rich and 

decomposes much faster (Swift et al. 1979, Moore et al. 

2004, Parmenter and MacMahon 2009, Barton and Bump 

2019). Carrion forms a ‘‘cadaver decomposition island” with 

distinct biological and chemical activity hotspots (Carter et 

al. 2007, Barton et al. 2012). As a result of being a draw to 

scavengers, especially birds, cadaver decomposition 

islands can also influence seed dispersal from birds flying to 

and from them (Steyaert et al. 2018). 

WS leaves most carcasses in the field since most animals 

killed in WDM are taken individually or in small numbers and 

do not pose a threat to wildlife, humans, or the environment.

For animals trapped in larger groups in cage or corral traps (e.g., feral swine), WS scatters the 

carcasses in the area surrounding the trap site to minimize any potential environmental risks 

associated with a concentration of carcasses in one spot. This method aims to limit pathogen 

dissemination off-site if a local outbreak is occurring. If a known diseased animal is encountered,

Figure 1. Carcasses left in field provide 

feed for diurnal and nocturnal 

scavengers, and invertebrates.
3

it is turned over to the Health Department or disposed of appropriately so it will not transmit the 

disease to other wildlife.

1.1.2 Human Consumption

WS may donate meat for human and non-human consumption,

which can provide a source of nutrition for people and animals. 

Typically, WS takes animal carcasses to a meat processor as 

soon as possible after a WDM operation to minimize spoilage; 

some animals may be transported and euthanized with carbon 

dioxide at the processor. Meat processors are contacted 

beforehand, and arrangements are made for the drop-off. 

Processors prepare the meat (Figure 2) and give it to designated 

recipients. WS has stopped donating meat of some species, 

particularly feral swine, due to the number and high prevalence 

of diseases found in their populations.

With changes in the global economy, people throughout North America and elsewhere are taking 

advantage of locally available food sources such as wildlife. Many of these communities have 

limited access to sufficient food due to limited resources. When examining the environmental 

contaminant concentration risks to humans, the greatest at-risk groups rely on “traditional food 

systems” for most of their diet. Traditional food systems refer to food species available to a 

particular culture from natural resources and their accepted usage patterns (Kuhnlein and Chan 

2000). These groups are typically indigenous peoples in ecological settings of Alaska and other 

areas of the United States, Canada, Greenland, and northern Europe, and less frequently, people 

that primarily practice subsistence lifestyles (Kuhnlein and Chan 2000). To a lesser extent, 

sportsmen who harvest wildlife supplement their diets from wildlife sources. 

If the consumption of a food resource such as wildlife does not pose a life-threatening risk, it is 

not governed by food industry regulations. Ultimately, the decision to harvest and consume these 

items is the responsibility of the harvester and consumer. Often, consumption advisories are 

issued based on the contaminate residue limits, and consumers should remain vigilant in ensuring

these recommendations are not exceeded. 

1.1.3 Unlined and Lined Burial 

Unlined burial involves excavating a pit in the earth (Figure 

3), placing the carcasses in the pit, and backfilling with the 

excavated material. This action is referred to as trench 

burial when a long narrow pit (trench) is dug versus a large 

circular hole. Burial pits are typically dug at a single, central 

location on the premises but typically involve a single large 

animal or several animals where a cull occurred. However, 

trench burials may also be constructed with multiple 

trenches at the affected premises when the numbers of 

animals are high. Carcasses from multiple premises may 

also be gathered and buried at a single centralized location.

The landowner or land manager typically conducts carcass 

burial. Larger, existing burial trenches are sometimes 

excavated by livestock managers for routine livestock 

carcass disposal programs. Carcasses exude leachate that 

Figure 3. Unlined burial pit for 

livestock carcasses (Unknown 

source).

Figure 2. Preparing venison cuts 

for packaging.
4

can contaminate soil and groundwater, predominantly permeable soils such as sandy loam in 

unlined burial pits.

Lined burial pits are used to control leachate from carcasses. Lining materials such as compacted 

clay liner systems or synthetic liners in pits are a barrier for vertical movement of leachate and 

control flow to reduce soil and groundwater contamination (Kim and Pramanik 2015). In lined 

systems, leachate can be pumped for treatment to control potential contaminants in soil and 

groundwater effectively (Albano et al. 2011).

State and local laws and regulations may apply to unlined and lined burial sites, and permits may 

be necessary to conduct such activities. For example, states require varying depths, which may 

be 3 to 10 feet deep depending on the state and cover material such as soil or carbon source.

Generally, burial pits are not allowed on a slope greater than 5%. The primary resources required 

for burial sites include the appropriate area to store accumulated carcasses awaiting burial

temporarily, the appropriate area to bury carcasses, moving and excavation equipment, and 

equipment fuel. Land use at these sites may be impacted or lost for several years. Uncontrolled 

gases, leachate from carcasses, and exhaust from excavation equipment are byproducts of 

unlined burial. Gases and leachate are more controlled in lined burial systems. Assessing how 

much leachate will affect groundwater quality by volume and concentration in the watershed is 

important. It is most likely to occur from leachate produced in unlined burial sites. It should be 

noted that livestock producers prefer to use licensed collector services for carcasses rather than 

burial because of the ease and potential for site contamination (Freedman and Fleming 2003).

Currently, WS buries feral swine carcasses in relatively few states, including Alabama, Arkansas, 

Florida, New York, and the territory of Puerto Rico. In most states with large feral swine 

populations, including Texas, California, Hawaii, and Oklahoma, WS does not bury carcasses on 

site.

1.1.4 Open-Air Burning 

For open-air burning in fields, carcasses are placed on 

combustible heaps, known as pyres, and burned to ash

(Figure 4). Open-air burning typically occurs where mass 

animal health emergencies have occurred (e.g., on the 

affected premises). As with unlined burial, state, and local 

laws and regulations may apply and require permits, such 

as one from a local Fire Marshall. In some areas burning

may be restricted or banned. Resources required for 

open-air burning include the appropriate area to store 

accumulated carcasses awaiting to be burned 

temporarily, the appropriate area to burn the carcasses, 

the necessary equipment and equipment fuel, and fuel 

and combustibles to set and maintain the fire. Machinery 

is necessary to dig a shallow trench to build the pyre and

move the carcasses onto the pyre. A mixture of fuels, 

such as straw or hay, untreated timbers, kindling wood, 

and coal or diesel fuel, are required to ignite the pyres 

and raise the temperatures to the degree necessary for 

carcass incineration. Fully burned carcasses produce 

solid waste byproducts, bone, and ash, typically free of 

pathogens except for prions (Ellis 2001) and decaying 

Figure 4. A pyre and smoke rising from a 

pyre during open-air burning of livestock 

(picture source Ledingham, S., n.d.) 
5

material that could attract disease vectors (APHIS 2014, 2018). However, other outputs include 

potentially high levels of air pollution, large amounts of potentially contaminated ash (dioxins, 

heavy metals), leachate, and unwanted heat. WS generally avoids the use of open burning due 

to potential fire hazards except when regulations require this method, and it can be conducted 

safely (WS Directive 2.515).

1.1.5 Composting and Above Ground Burial

Composting is a decomposition process that takes place in 

the presence of oxygen from the air and relies on naturally 

occurring microbes, including bacteria and fungi, that aid in 

the process (Kalbasi-Ashtari et al. 2005, Auvermann et al. 

2006, Rahman et al. 2009). Carcasses are combined with 

organic matter either directly on the ground or on a protective 

barrier such as plastic or cement that lies on the ground. 

Above ground burial has been shown to be very effective,

with minimal potential to contaminate groundwater (Figure 5).

Windrow composting is when the carbon-rich organic matter 

and carcasses are piled in long rows. Carcass composting 

can occur on the affected premises or at a centralized 

location away from the affected premises.

Resources required for composting include the appropriate 

area to store accumulated carcasses waiting to be composted temporarily, the proper area to 

compost, composting equipment and amendments, and generally, a carbon source such as wood 

chips and water (Brinton 2000). Composting equipment includes machinery to lift, mix, move, or 

grind and churn composting piles and instruments for monitoring the composting piles' physical 

(temperature) and chemical (pH) properties. A front-end loader can be used to move carcasses 

and turn the pile every 3 to 6 months (Auvermann et al. 2006) and load the final compost into a 

spreader truck. Effective carcass composting requires layers of carbon sources and bulking 

agents, adequate aeration, and water (Dougherty 1999, Kalbasi-Ashtari et al. 2005). Carbon 

source bulking agents (also referred to as amendments) provide the necessary nutrients for 

decay. These include spent horse bedding (horse manure and pinewood shavings), wood chips, 

refuse pellets, rotting hay bales, peanut shells, or tree trimmings. 

Compost piles are sometimes placed directly on bare ground, but a barrier may be placed 

between the ground and the piles to help contain leachate. Impermeable barriers can be made of 

polyvinyl chloride (PVC), plastic, concrete, or asphalt (Rahman et al. 2009). A layer of 

biodegradable carbon sources (e.g., straw, sawdust, corn stalks, and yard waste) may also be 

placed beneath carcasses to act as a sorbent and biofilter layer to capture and assist in degrading 

pollutants). Composting has the potential to produce a valuable stabilized organic residue that is 

a dark brown to black soil called humus. Humus, which contains primarily nonpathogenic bacteria 

and plant nutrients, may be spread over the land as a soil additive (Mukhtar et al. 2004) if harmful 

pathogens are absent. Incompletely degraded humus (which still contains pathogens) or compost 

made from contaminated animals should not be sold as a commodity and should be disposed of 

as solid waste. In addition to humus, composting produces water vapor, carbon dioxide, heat, and 

leachate. The compost area is temporarily lost to production or other activities during composting.

Composting should always be performed in a controlled manner and accomplished by trained 

and experienced personnel where possible. While composting is effective at degrading many 

disease agents, the process may not be as good as other methods because harmful byproducts 

Figure 5. Carcass compost piles 

(picture source Severidt, J.A. et al. 

2002).
6 

could potentially move into the environment where they could be a risk to people unless 

containment measures are employed.

WS does not typically establish new compost sites for its projects but may take advantage of 

compost piles established by producers to dispose of carcasses from their livestock operations. 

Composting would only be conducted in coordination with land management agencies and 

landowners and in compliance with federal, state, territorial, tribal, county, and local regulations 

and in accordance with APHIS-WS Directive 2.515 and where facilities already exist.

1.1.6 Rendering 

Rendering is a physical and chemical 

transformation of animal products using a 

variety of equipment and processes (Meeker 

2009). Rendering factories (Figure 6) convert 

meat-packing plant waste, kitchen grease, and 

livestock and wildlife carcasses into industrial 

fats and oils for products such as tallow for 

soap and various other products such as 

fertilizer. All rendering processes require the 

application of heat, the extraction of moisture, 

and the separation of fat (Meeker 2009). If a 

carcass is in an advanced decomposition 

stage, removing the hides and cleaning 

carcasses becomes more difficult, and decay 

results in poor-quality end products 

(Auvermann et al. 2004). Thus, carcasses 

should be rendered in the early stages of

decomposition if the byproducts are to be 

marketed. Livestock and wildlife carcasses 

(raw materials) are ground into consistent 

particle sizes and put into a cooking vessel.

Depending on the system and materials, it is 

heated with steam to temperatures of 240 to 

290 °F for 40 to 90 minutes. The melted fat is 

then separated from the protein and bone 

solids with a press, removing a large portion of 

the moisture. Lastly, the protein, minerals, and 

some residual fats are further processed with 

continued grinding removing additional moisture, and the products are transferred for storage or 

shipment (Meeker 2009). Rendering facilities are typically equipped with scrubbers to control 

emissions of odors and air toxins and wastewater treatment systems to meet discharge permit 

requirements for the generated wastewater. Compared to digestion and composting, rendering

produces 25% as much carbon dioxide, a greenhouse gas, and is considered to have better 

environmental sustainability (Gooding and Meeker 2016).

Resources required for rendering include transportation equipment, fuel to move the carcasses 

offsite, and a rendering facility that will accept the carcasses. An appropriate area to store 

accumulated carcasses temporarily may also be needed. The final byproducts of carcass 

rendering are free of most pathogens and unpleasant odors, provided the proper processing 

conditions are used (Sindt 2006). Rendering byproducts from processing carcasses generated 

Figure 6. Fishmeal rendering plant (picture source 

asthaiworks.com, ASTW 2020).
7

by diseased animals are generally not sold for human or animal use. The three primary byproducts 

from the rendering of carcasses are carcass meal (solid proteins), melted fat or tallow, and water 

(Auvermann et al. 2004, Sindt 2006). Wastewater created during the process must be disposed 

of properly, typically under a wastewater discharge permit (USEPA 2022e). The capacity of each 

rendering plant varies (Auvermann et al. 2004), but industry reports show that typical rendering 

operations can process 1 million pounds of raw materials in a 24-hour period (Sindt 2006). 

Rendering cannot be used for animals killed with lead ammunition, and the availability of 

independent rendering plants may be limited. Due to the remote operational locations of WS WDM 

activities, rendering may be precluded as a method of carcass disposal. WS used rendering 

frequently in the past when they were more commonplace and accessible, but they do not use 

them as regularly today. 

1.1.7 Landfill

In the United States, landfills (Figure 7) are highly 

regulated engineered structures containing solid waste. 

The Resource Conservation and Recovery Act (RCRA), 

which amended the Solid Waste Disposal Act, created 

standards for waste generation, treatment, storage, and 

disposal. It essentially banned open dumps (40 CFR §§ 

258.1(g), 258.1(h)). USEPA (2022f) is responsible for 

compliance monitoring and enforcement activities 

under RCRA. Disposal of animal carcasses is allowed 

in landfills if the facilities have been approved to accept 

this type of waste. Poultry carcasses taken by WS and 

other APHIS personnel were placed in landfills during 

the 2002, 2016, and 2022 avian influenza outbreaks in 

several states, the 2002 exotic Newcastle disease 

outbreak in California, and, more recently, the 2022 

avian influenza outbreak. The primary resources required for a landfill include the appropriate 

area to store accumulated carcasses awaiting burial, a landfill that accepts the carcasses, and 

equipment and fuel for transportation (Chang et al. 2008). While leachate and gases are produced 

in landfills, they must be collected and contained in accordance with USEPA (2022f) regulatory 

requirements to protect the surrounding environment. USEPA requires facilities to follow design 

and operating standards, groundwater monitoring programs, and corrective action measures. The 

primary features are composite liners, leachate containment, and gas collection systems. The 

requirement for at least daily cover with earthen materials (or an approved alternative) is 

specifically designed to control disease vectors, odors, blowing litter, and scavenging (40 CFR § 

258.21(a) and (b)). In addition to USEPA (2022f) regulations, landfill operators must also meet 

State and local landfill regulations. 

Potential risks to public health from decomposing animal carcasses in landfills can influence an 

operator’s decision regarding whether to accept carcass material, even if the landfill is permitted 

to receive carcasses. Some landfill owners refused to accept carcasses for burial from the 2001 

foot-and-mouth disease outbreak in the United Kingdom (Nutsch and Spire 2004) and deer and 

elk in Wisconsin from a chronic wasting disease (CWD) outbreak. 

Figure 7. Typical landfill, which must be 

certified to accept animal carcasses. 
8 

Landfills treat byproducts of decomposition, such as leachate, prior to release into the 

environment. Landfills may recover byproducts of decomposition, such as methane and carbon 

dioxide (biogas), for use as an energy source (USEPA 2022c) or release gases into the 

environment in a controlled manner. Federal or State regulations require most large landfills to 

capture landfill gas and combust it by flaring or treating it so it can be used in a landfill gas energy 

system (USEPA 2022c). Flaring will burn the gas with no energy recovered, while harnessing the 

power of landfill gas will reduce greenhouse gas emissions, offset the use of nonrenewable 

energy resources, improve local air quality, and provide revenue for landfills (USEPA 2022c). 

Recovered methane can be sold directly to an end user as natural gas fuel (USEPA 2022c). The 

availability of preexisting landfills is an advantage when other options fail, particularly if the landfill 

can receive a relatively large quantity of carcasses. Previously approved Subtitle D landfills allow 

a rapid response to situations where large numbers of animals are culled if the site already has 

the needed environmental protection features. Animal carcasses would typically be categorized 

as nonhazardous waste. RCRA Subtitle D regulates the management of nonhazardous solid 

wastes (USEPA 2022f). Under Subtitle D, permitting and monitoring municipal and nonhazardous 

waste landfills are the responsibility of States. Carcass disposal at landfills would occur in Type 1 

facilities. Type 1 facilities are required to meet RCRA Subtitle D 

requirements, as well as other applicable federal and state

regulations. These types of facilities can accept most types of 

carcasses and are designed to manage leachate and gases that 

are a result of the degradation of organic material, such as those 

associated with carcass disposal. It must be noted that many 

landfills have contractual obligations to accept waste from other 

sources, and these landfills may not have the available additional 

capacity to accept large quantities of animal carcasses.

1.1.8 Incinerator

Incineration is a waste treatment process that ignites waste 

materials, combusts the organic portion of the materials, and 

captures the inorganic portion of the materials either as fly ash or 

flue-ash, which is a fine particle residue that rises with gases 

generated during and after combustion, or bottom ash, which is 

the larger, noncombustible residue that falls to the bottom of a 

furnace. Fixed-facility incineration (Figure 8, top) occurs at 

facilities that are dedicated to this purpose, as opposed to semimovable incinerators on skids (Figure 8, middle) and mobile 

incinerators on trailers (Figure 8, bottom), which are transported 

to various sites. Fixed-facility incinerators include small on-farm 

incinerators, small and large municipal and hazardous waste 

incineration facilities, crematories, and power plant incinerators. 

Several smaller incinerators are made to fit on trailers that can be 

moved to the location of a carcass and incinerate on-site. 

Unlike open-air burning, fixed-facility incinerator processes and 

locations are highly controlled (Kastner and Phebus 2004). New 

incinerators are particularly efficient at burning carcasses under 

USEPA (2022e) established emission standards of the Clean Air 

Act, which have limits on pollutants released into the 

environment. Many fixed-facility incinerators are equipped with 

flue gas-cleaning equipment that captures fly ash and air toxins 

from the incineration process, such as acid gases. The United 

Figure 8. A fixed-facility 

incinerator, a semi-mobile 

incinerator on a skid, and a 

mobile incinerator (picture 

source matthewsenvironmental

solutions.com 2020). 
9 

Kingdom disposed of many infected animals during bovine spongiform encephalitis (BSE), “mad 

cow” disease, outbreak by using fixed-facility incinerators (Kastner and Phebus 2004) and any 

could be used for CWD in deer. BSE and CWD are prion-based diseases; prions are abnormal 

folding proteins that affect mammals. Resources required for incineration include the appropriate 

area to temporarily store accumulated carcasses awaiting incineration, an incinerator that can 

accept the carcasses, and equipment and fuel for transportation. Typically, diesel, natural gas, or 

propane fuel is needed to ignite the high-water content carcasses. Incineration produces ash, air 

emissions, and heat. Burning waste materials to ash requires sustained high temperatures, 

generally over 1562.0 oF (850 C). Facilities accepting solid wastes do not necessarily accept 

animal carcasses (USEPA 2021a, 2022e). The capacity or productivity of incineration plants 

(volume of incinerated wastes produced per time unit) varies with the available type, size, and 

number of equipment and other resource factors. Some plants can treat more than 100,000 tons 

of waste per year. WS does not anticipate using this method very often, but it may be used in 

some states. Backyard poultry flock producers in the 2022 avian influenza outbreak used this 

method for a small number of premises.

1.1.9 Alkaline Hydrolysis Tissue Digester

With the appearance of a massive pressure cooker on wheels, alkaline hydrolysis tissue digesters 

convert carcasses to a sterile slurry and crushable bone and teeth 

with no pathogens that can be safely disposed of in a sanitary 

sewer. Digesters degrade tissues and proteins quickly, including 

prions. The carcass is placed in a pressure vessel that is filled 

with a mixture of water and sodium or potassium hydroxide and 

heated to a temperature around 320°F for four to six hours under 

an elevated pressure, which prevents boiling and effectively 

breaks a carcass down into its chemical components. A lower 

temperature of 208°F and pressure may be used but for 14 to 16 

hours. The mixture starts at a strongly basic pH level of 

approximately 14 that drops to 11 by the end; the final pH level 

depends on the total operation time and the amount of fat in the 

body. Alkaline hydrolysis tissue digesters that have an 8-foot 

diameter are large enough to accept cattle carcasses. Digesters 

are the best method to dispose of carcasses with pathogens such 

as CWD, whereas other disposal methods may not ensure 100% 

devitalization of the pathogen. Digester availability limits their use, 

but these are becoming more available for use.

1.1.10 Anaerobic Biodigester

Another digester is an anaerobic biodigester, which uses anaerobic microbes to break down 

organic matter in the absence of oxygen. The output is principally methane gas along with carbon 

dioxide. Methane can be captured and used for heating and electricity. The process is similar to 

composting except that the gases are captured and can be used for power. The byproducts can 

be used as fertilizer. Temperatures range from 86o to 100o for mesophilic digesters (intermediate 

temperature environment) and 122o to 140o for thermophilic digesters (high-temperature 

environment), and generally have particular microorganisms that thrive in these temperature 

ranges (USEPA 2021c). Thermophilic digesters are generally used to destroy most pathogens.

Carcasses are ground, then placed in a digester, and decomposed by various fermentative 

anaerobic bacteria (USEPA 2021b). For example, in lactic acid fermentation, ground carcasses 

are mixed in tanks with lactic acid bacteria and fermentable carbohydrates such as whey or corn. 

Figure 9. Tissue digesters. 
10

Biogas is generated, mostly methane and carbon dioxide, with small amounts of water vapor and 

other gases. Carbon dioxide and other gases can be removed, leaving only methane. In addition, 

digestate, a wet mixture that is usually separated into a solid and a liquid, is left. Recovering 

methane from biogas can be a cost-effective source of renewable energy. Digestate is nutrientrich and can be used as fertilizers for crops if temperatures are consistently high enough to 

deactivate pathogens. Otherwise, digestate can be stored in vented vats and transported to a 

rendering facility (USEPA 2021b). Anaerobic digestion can sometimes be slow, approximately 7 

to 10 days to complete, and the capacity is limited to the digester size. Thus, the method is 

appropriate for the disposal of a set tonnage of carcasses. These are becoming more popular as 

a disposal method, but still are not used very frequently.

1.2 Use Pattern 

WS conducts WDM with a variety of methods to protect agriculture, property, natural resources, 

and human and animal health and safety throughout the United States. WS lethal take is recorded 

in the computer-based Management Information System (MIS3

). The methods used by WS have 

been discussed in other risk assessments, and the disposition of carcasses was minimally 

discussed in “The Use of DRC-1339 in Wildlife Damage Management” risk assessment. WS 

NEPA documents often include some discussion on carcass management, and for feral swine 

specifically, carcass management was discussed in APHIS (2015). From FY114 to FY15 and 

FY16 to FY20, WS killed an estimated average of 3,966,168 and 2,585,469 target and nontarget 

vertebrates annually, respectively, for species with at least an average annual take (rounded) of

one or more, or more than two in five years. WS WDM involved 465 species, 5 subspecies, and 

3 “unknown” groups (bats, turtles, and fish)5 (Table 1 and Appendix A). The total take would have 

resulted in an estimated annual average of 5,873 and 9,288 tons of carcasses, respectively. The 

primary difference was a significant increase in the annual average feral swine taken, rising from 

33,000 in FY11-FY15 to 79,000 in FY16-FY20, respectively, which would make an estimated 

increase of 3,400 tons of carcasses per year. The National Feral Swine Program is expected to 

continue to increase take until feral swine are eradicated in many states; this will increase take 

for some time. It should be noted that about 46% of the take was from invasive species from FY11 

to FY20. 

From FY11-FY20, the highest annual average lethal take involved European starlings (37%), 

brown-headed cowbirds (16%), red-winged blackbirds (14%), black-tailed prairie dogs (6%), 

coyotes (2%), and feral swine (2%) (Appendix A). The highest tonnage of carcasses from FY11 

to FY20, though, was estimated to be from feral swine (55%), coyotes (13%), white-tailed deer 

(8%), beaver (7%), black-tailed prairie dogs (3%), and raccoons (2%). By group, hoofed mammals

accounted for 4,874 tons (64%), predators 1,302 tons (17%), and rodents and rabbits 880 tons 

(12%) (Table 1 and Appendix A). WS take represents only a small portion of wildlife taken in the 

United States. To give context, white-tailed deer harvested by hunters annually averaged 6.1

million deer and 1.3 million struck by cars (Quality Deer Management Association (QDMA) 2019),

resulting in 648,000 tons of carcasses. Waterfowl harvest averaged 17 million birds annually from 

FY11-FY20, resulting in 21,000 tons of carcasses (USFWS 2012, 2014, 2016, 2018, 2020). The 

meat, fur, or other parts are often consumed or used. Thus, not all of this represents carcasses 

3 The MIS is used for tracking WDM activities. Throughout the text, data for a year (e.g., FY11 to FY15) will be given and is from the 

MIS. MIS reports are not 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.

4 FY11 equals the federal Fiscal Year 2011, which is October 1, 2010-September 30, 2011 (the year is denoted by FY11, FY12, and 

so on).

5 The Management information System (MIS) has several groups of species such as bats (all) or turtles (other) that are used and it 

could not be determined what the species was.
11

left in the field, but it estimates the amount taken for context. For example, a deer carcass 

averages about 47% meat by weight, 13% bones, 9% hide, 5% blood, and 26% other

(Pennsylvania Game Commission 2020), depending on what is kept (typically meat, hide, and 

bones) an annual average of about a third was likely left in the field from FY11-FY20 (Table 1) or

214,000 tons from white-tailed deer harvest alone, which is 28 times higher than the total weight 

of all animals that WS takes. Scavengers consume those portions of the carcasses left in the field. 

Table 1. The estimated annual average lethal take of target and nontarget animals in WDM by WS and 

tonnage of their carcasses from FY11 to FY15 and FY16 to FY20. For comparison, white-tailed deer 

harvested by hunters and killed in collisions with vehicles from insurance claims (QDMA 2019) and 

waterfowl harvested by hunters (USFWS 2012, 2014, 2016, 2018, 2020). Species taken by WS and 

harvested by hunters are given in Appendix A and discussed in Chapter 1: An Introduction to WS Methods 

Risk Assessments6. 

Sp. = species; Ssp. = subspecies

The majority of mammals taken by WS are taken individually and left as carrion to decompose in 

the field or scavenged7. Many birds are collected and disposed of at local landfills. Culls to 

minimize disease spread when a herd has become infected with a disease such as CWD or 

brucellosis in a captive herd of white-tailed deer are disposed of by the most appropriate method, 

including incinerators and digesters. WS donates approximately 2% of wildlife meat taken in WDM 

for human and animal consumption(Table 2). 

Table 2. The estimated annual average tonnage of meat donated by WS to qualifying organizations and 

individuals from FY18-FY21. 

Annual Average Meat Donated by WS for FY18-FY21

Consumption

Type

Meat (lbs.) Total Venison Swine Bear Goose Other

Human 253,342 N/A 12,175 10,956 900 277,373

Animal 11,802 5,175 44 11,007 5,079 33,107

Total 265,144 5,175 12,219 21,963 5,979 310,480

Tons 132.6 2.6 6.1 11.0 3.0 155

FY18 was the first year that WS recorded the amount of meat donated nationally (most states 

collected this information earlier but it was incomplete nationally). For FY18-FY21, WS donated 

6 The Introduction is found at https://www.aphis.usda.gov/aphis/ourfocus/wildlifedamage/programs/nepa/ct-ws-risk_assessments

7 WS and the MIS does not track carcass disposition, so WS does not have disposition numbers.

Whole Carcass Weight (Tonnage) of Wildlife Taken by WS for FY11-FY15 and FY16-FY20 

and Sportsmen Harvest/Vehicle Kills for Context and Comparison

WS Lethal Take From Appendix 1 FY11-FY15 FY16-FY20

Group Species Included # Killed Carcass 

(T )

# Killed Carcass (Ton)

Predators 27 Sp., 3 Ssp. 106,793 1,383 93,681 1,222

Hoofed Mammals 18 Species. 39,179 3,011 87,436 6,736

Rodents and Rabbits 82 Species 387,366 893 368,971 867

Other Mammals 17 Sp., 1 Group 884 6 670 4

Landbirds 148 Sp., 1 Ssp. 3,274,616 305 1,882,214 200

Waterbirds 131 Sp., 1 Ssp. 84,658 208 70,177 178

Reptile/Amphibian/Fish 42 Sp., 2 Group 72,672 67 82,320 81

Total 465 sp., 5 ssp., 3 3,966,168 5,873 2,585,469 9,288

Private Harvest and Vehicle Killed Weight FY11-FY15 FY16-FY20

How Taken Species # Killed Carcass (Ton) Take Carcass (Ton)

Sport Harvest/Vehicle White-tailed Deer 7,200,000 630,000 7,600,000 665,000

Sport Harvest Waterfowl (35 sp.) 17,846,014 22,515 15,841,817 20,156

Total 36 species 25,046,014 652,571 23,041,817 685,156
12

an average of 155 tons (310,480 pounds) of meat annually (Table 2). Feral swine were regularly 

donated prior to 2010, but WS ceased feral swine donations for human consumption due to the 

number and severity of pathogens that could be transmitted to people, as determined by testing. 

It should be noted that sportsmen donated 1,400 tons (2.8 million pounds) of cervid, antelope, 

waterfowl, and pheasant meat in 2010 and that some states give income tax credits for donating 

meat (Congressional Sportsmen’s Foundation 2022).

Table 3. The average annual disease tests submitted by WS operational personnel from FY17-FY19 as 

reported in the MIS and seropositive rate (have had the virus but may not be shedding) from any source.

Rabies surveillance collections included an average of 8,466 brainstems collected in the eastern U.S. (for 

raccoon rabies variant), with 221 of these positive for the rabies virus. Some collections were from years 

other than FY17-FY19, where data were not available yet from testing, but the year is noted below. One 

highly pathogenic avian influenza was found in FY17 in a mallard8. 

DISEASE Predator Hoofed 

Mammal

Rodent 

& 

Rabbit

Bats Bird Turtle TOTAL % Sero 

Pos 

VIRUS

Rabies 18,840 12 143 174 - - 19,169 2%

Avian Flu 2 - 19 - 10,652 - 10,673 ~13%

Pseudorabies 5 1,861 - - - - 1,866 20%*

Hog Cholera 1 1,829 - - - - 1,830 0%

West Nile Virus 2 311 - - 84 592 989 na

Epizootic Hemorrhagic 227 - - - - 227 ^

Avian Paramyxovirus - - - - 162 - 162 16%+

Exotic Newcastle - - - - 152 - 152 na

Other Viral1 1 42 - - 78 - 121 N/A

BACTERIA

Plague 2,004 97 127 - - - 2,228 27%

Swine Brucellosis 1 2,132 - - - - 2,133 6.3%*

Tularemia 1,499 117 204 - - - 1,820 0.7%

Leptospirosis 622 118 - - - - 740 3.6%**

Salmonella - - - - 206 - 206 8%#

Tuberculosis3 2 95 - - 40 - 137 na

Other Bacterial4 1 10 - - 40 - 51 N/A

OTHER

Unspecified Disease 223 1,452 19 - 302 - 1,996 N/A

Prion - 564 - - - - 564 na

Roundworms 302 - 64 - 25 - 391 na

Toxoplasmosis 5 53 - - 79 - 137 13%

Other Parasite/Insect 

Vector5

78 72 4 - - - 154 N/A

Environmental (Lead) - - - - 51 - 51 na

TOTAL 23,588 8,992 580 174 11,871 592 45,797 N/A

1 Other virus = Adenovirus, African swine fever (0%), avian bornavirus, canine parvovirus, equine encephalitis, hepatitis E, porcine 

epidemic diarrhea, swine influenza (7%), swine vesicular disease, viral encephalitis, and Wellfleet Bay virus; 2 Swine and bovine 

brucellosis; 3 Avian and bovine tuberculosis; 4 Other bacteria = Anthrax, avian cholera, bluetongue, botulism, bovine brucellosis, 

chlamydiosis, ehrlichiosis, Escherichia coli, and typhus; 5 Other Parasite/Invertebrate = Canine heartworm, echinococcosis, 

giardiasis, mites, neosporosis, Rocky Mountain spotted fever, trichinellosis (14% FY14-FY16), tapeworms, and ticks; ^ vector-borne

and not presented on the carcass; + FY13 - 3,826 samples 

NWRC surveillance ann. avg. FY17-FY19 - * 3,190 feral swine, ** 308 feral swine between, # – 388 gamebird intestinal samples, 

tularemia 168/23,426 in FY12

A primary concern of carcass disposal is the presence of disease pathogens. Zoonotic agents 

may be bacterial, viral, parasitic, or fungal or involve unconventional agents, such as prions 

8 In FY22, an HPAI outbreak occurred and hundreds of wild birds (e.g., waterbirds, raptors, and passerines) and a few mammals (e.g., 

fox, coyote, raccoons, and seals) were collected that tested positive for HPAI
13

(World Health Organization 2013). WS operations collect samples for disease testing, which is 

recorded in the MIS. In addition, the WS National Wildlife Research Center (NWRC) also collects 

samples in coordination with other programs in APHIS and other organizations, but this is not 

recorded in the MIS. From FY17 to FY19, WS collected an annual average of 45,797 samples to 

test for the presence of viral and bacterial diseases, parasite vectors of disease, and 

environmental contaminants (Table 3). The WS National Feral Swine Damage Management 

Program tested about 3,000 feral swine annually for several diseases, but these are not included 

in Table 3. The percentage of positive animals for disease varied greatly by region. It should be 

noted that some pathogens are alive only while the host is alive or are transmitted by vectors and 

not a problem in the carcass, but depending on the pathogen can persist for days or months in 

the carcass.

2 HAZARDS

2.1 Human Health and Safety Hazards

Hazards to human health and safety associated with carcass disposal primarily involve zoonotic 

disease, secondary hazards from drugs and toxicants (if these were used in the WDM project to 

kill or euthanize the animals), natural and artificial chemical and biological leachate from bodily 

fluids exuded during decomposition, and hazardous or odoriferous gases released during 

decomposition. The potential for people to consume contaminated or diseased animal meat is 

also a concern. Additionally, the movement or lifting of carcasses for disposal, especially heavier 

animals, could cause low back strains or other injuries to WS personnel. 

Disease exposure is a primary concern for people that handle carcasses, including WS personnel. 

Carcasses from culls involving many animals for disease containment from WDM operations, 

though relatively infrequent, are collected and managed with one or more disposal methods 

discussed in Section 1.1. Most times, the animal owner may be responsible for the disposal of 

animals where their animals, such as captive cervids, are being culled for a disease. If carcasses 

are collected and transported to a disposal site and potentially have a contagious pathogenic 

disease, APHIS (2014, 2020) decontamination standard operating procedures (SOPs) for 

equipment and clothing are used to minimize the spread of the disease-causing agents during 

carcass management activities and allow personnel to work safely. The use of disinfectants and 

decontamination of personal protective equipment (PPE) is designed to reduce the risk of human 

infections by zoonotic pathogens and minimize the risk of transporting the disease agent to other 

locations (USEPA 2022g). For these reasons, cleaning and disinfecting actions of environmental 

surfaces and PPE during a response are considered a critical part of carcass handling, transport, 

and disposal policies. Decontamination procedures depend on the pathogen and follow guidelines 

presented in the Codes of Federal Regulations Title 9. Typical decontamination requires a

disinfectant such as 2% chlorine solution applied to dry surfaces at room temperature. For more 

hardy pathogens such as prions that cause transmissible spongiform encephalopathies (e.g., 

CWD or scrapie), a 1-molar solution of sodium hydroxide at room temperature for at least 1 hour

is applied to disinfect surfaces. Some disinfecting activities on the premises of a disease outbreak 

require that a State or APHIS employee supervise it.

According to the Centers for Disease Control (CDC 2022b), approximately 75 percent of new 

emerging human infectious diseases are of animal origin, and approximately 60 percent of all 

human pathogens are zoonotic. Fortunately, the primary diseases that cause mass animal 

emergencies, which can be foreign or endemic to the United States, are diseases such as footand-mouth disease and classical and African swine fever, which are not public health concerns

because humans, for the most part, are not susceptible to these infections (Center for Food 
14

Security and Public Health 2020). However, humans are susceptible to some zoonoses that can 

be transmitted from animal carcasses, such as avian influenza, this virus causes conjunctivitis or 

mild respiratory disease, but some viral strains, such as Asian lineage H5N1 (HPAI), cause severe 

disease and death. Brucellosis (Brucella spp.) bacteria causes an acute febrile illness in humans 

from cattle, bison, elk, and swine with nonspecific flu-like symptoms such as fever, headache, 

malaise, back pain, drenching sweats, myalgia, and generalized aches. Anthrax (spore-forming 

bacteria Bacillus anthracis) causes severe illness in humans affecting the gastrointestinal and 

respiratory tracts from direct contact with infected animals or animal parts such as blood, wool, or 

hide via a break, through an abrasion in the skin or from biting flies. Bovine spongiform

encephalopathy (prion-based disease from consumption of contaminated meat) causes a spongy 

degeneration of the brain (WHO 2013, Center for Food Security and Public Health 2020). 

As carcasses degrade, leachate is released into the environment and can directly affect the health 

of humans in the area. Leachate samples collected from a closed, covered, 5- to 15-year-old 

landfill had normal microbial flora of Aeronomas hydrophila, A. sobria (can cause gastroenteritis), 

Bacillus thuringiensis, Brevundimonas diminuta, Chryseobacterium indologenes, 

Corynebacterium lucuronolyticum, Nocardia otitidiscaviarum, and Pseudomonas aeruginosa and 

P. putida (Davis-Hoover et al. 2006). The leachate supported the survival of inoculated Bacillus 

anthracis (anthrax) cultures for 24 weeks, Clostridium botulinum (responsible for foodborne 

botulism) for 22 weeks, and non-spore-forming Yersinia pestis (plague) and Francisella tularensis

(tularemia) for less than 7 weeks (Davis-Hoover et al. 2006). The ability of pathogen populations 

to survive in leachate demonstrates the need for leachate movement to be controlled but suggests 

minimal durations for severe pathogen risk from disposal that generates leachate. Concentrations 

of Escherichia coli (strains can cause gastroenteritis, urinary tract infections, and other animal 

and human diseases) and Cryptosporidium spp. (microscopic parasite causes diarrhea) in ground 

and surface waters were affected to a greater extent by excretion from live animals than from the 

burial of a small number of carcasses (Gwyther et al. 2011). 

Improper carcass management can contaminate water supplies with biological or chemical 

agents, representing a health risk to human populations using the contaminated water for 

drinking, bathing, and cleaning. Existing laws and practices are designed to minimize impacts on

water resources and decrease the likelihood of human exposure to contaminated water. Transient 

wildlife may disseminate contaminants from carcass piles or contaminated water to nearby 

people. Biological agents may become wind- or water-borne and place human populations at risk 

from nearby carcasses, making it prudent to require some level of carcass management activities 

for these areas. The risks rise with the number and size of carcasses being disposed of. The 

human health and safety risks of each disposal method arise from exposure to pathogens, 

workplace hazards associated with the equipment, and hazardous materials used or produced 

during processing. Each disposal method is associated with the production of some level of noise, 

either through the equipment as it operates or during the loading and offloading of carcasses. 

During normal operations for routine mortalities, these noise levels are expected to be within 

existing standards for occupational exposure. 

Human health risks also include the potential for psychological distress arising from the sight of 

animal remains or coping with extremely unpleasant odors. Odors permeate most carcass 

management operations, primarily the smell of decaying animals that is revulsive to most people. 

To a certain extent, the human nose becomes desensitized during extended exposure to any 

smell, and, therefore, acute distress is likely to be felt by workers only from time to time. Passersby 

are likely to avoid the smells by leaving the area and closing vehicle windows. People residing 

downwind from a carcass management operation are those most likely to avoid periodic wafting 

odors. 
15

Site safety is a key factor in preventing disease and contamination. If carcasses are contaminated 

with a contagious pathogen, the carcass management site may need biosecurity practices as part 

of the security system. If carcasses are contaminated with a non-infectious agent, the site may 

not need strict security and biosecurity measures. It should be noted that anthrax is rare in the 

U.S. because of the yearly vaccination of livestock in areas where it has been previously detected 

(CDC 2022b). Therefore, it is typically not a threat. Cleaning and disinfection at a site after carcass 

disposal include using physical or chemical processes to reduce, remove, inactivate, or destroy 

pathogenic microorganisms (APHIS 2020). Cleaning and disinfection procedures are crucial in 

controlling the spread or transfer of microorganisms between animals, locations, or people. The 

potential for the spread or transfer of microorganisms can occur from the direct or indirect 

contamination of equipment, facilities, vehicles, people, and the movement of animals or animal 

products. Cleaning and disinfection processes vary: many factors affect the efficacy of the 

process, including the method or product selected, the organism involved, and several other 

environmental factors, such as temperature, organic load, or water hardness. Procedures vary 

depending on the situation. No single method is adequate for all situations.

People can be exposed to pathogens or environmental contaminants from consuming wildlife 

meat. While most wildlife are healthy, pathogens and contaminants can be in the meat of some 

animals. Thus, preparation is critical to reducing most pathogens, but contaminants, such as 

mercury, remain. Proper preparation includes using clean surfaces and utensils, washing hands 

before and after cutting and handling meats, and cooking meats thoroughly. A few pollutants that 

do not break down in the environment can be consumed or absorbed by fish and wildlife and 

accumulate in the food chain, which in turn may be eaten by people. Many researchers have 

attempted to study the effects of chronic low-dose exposure to meat contaminants among human 

populations, but results remain controversial due to inconsistent findings because of confounding 

variables such as malnutrition, smoking, substance abuse, genetics, supplement use, 

medications, and pre-existing health conditions. Risk determinations for human populations from 

wildlife meat consumption are not static due to changing environmental contaminant levels, 

consequences of their use, and health effects. Health departments and other agencies often 

publish advisories or guidelines regarding high contaminant levels and are typically based on 

maximum residue limits or tolerable intakes and estimated consumption levels (Kuhnlein and 

Chan 2000). 

Secondary hazards could occur in humans that consume found carcasses killed in WDM by

toxicants and drugs. Secondary hazards of chemicals used in WDM are addressed in other risk 

assessments 9 for the use of toxicants, drugs, and environmental contaminants such as 

bromethalin, sodium pentobarbital, and lead. This scenario is not likely because carcasses found 

dead will not likely be consumed by people who chance upon them.

Injuries moving carcasses occur, especially for large animals such as deer and bears. WS 

personnel sustain injuries from moving carcasses, such as muscle pulls, slip-and-falls, abrasions, 

and cuts. Cuts that occur while dressing carcasses are especially concerning when the animal 

has a disease that can be transferred to humans. Blood-to-blood contact (septicemic 

transmission) is especially concerning for bacterial infections and toxins.

9 WS methods risk assessments are at https://www.aphis.usda.gov/aphis/ourfocus/wildlifedamage/programs/nepa/ct-wsrisk_assessments for toxicants, immobilization and euthanasia drugs, and lead.
16

2.2 Environmental Hazards

Similar to human hazards, environmental hazards associated with carcass management primarily 

involve wildlife disease, secondary hazards to wildlife from drugs and toxicants if these were the 

WDM methods used to take the animals, naturally and unnaturally occurring biological (e.g., 

Aeronomas hydrophila and Francisella tularensis) and chemical (e.g., rodenticides and 

euthanasia drugs) leachate components from bodily fluids, and hazardous gases (e.g., methane

and carbon dioxide) released during decomposition. 

APHIS responds to new animal disease outbreaks and is concerned about disease transmission 

from carcasses to healthy animals. For example, should an outbreak of African swine fever occur 

in the United States, APHIS would work closely with other federal and state agencies and the 

swine industry to take actions to protect the nation’s pigs. African swine fever is a highly 

contagious and deadly viral disease affecting domestic and wild pigs of all ages. There is no 

evidence the virus is transmissible from pigs to humans. No treatment or vaccine is available for 

this disease. The only way to stop this disease is to depopulate all affected or exposed domestic 

and feral swine. APHIS is actively preparing to respond if African swine fever is detected in the 

U.S. In FY22, an outbreak occurred on the Island of Hispaniola, and APHIS is actively removing 

feral swine and sampling them on the neighboring island of Puerto Rico. Minimizing risks from 

feral swine carcasses on the landscape is necessary for response planning and preparedness.

During outbreaks that potentially involve livestock, APHIS Veterinary Services becomes involved 

and works with the appropriate state agency to determine the disposal method and where this will 

occur according to state laws. APHIS provides technical information, but the states and the

landowner, if it involves captive wildlife for slaughter, would conduct the disposal. 

Bowden et al. (2023) determined that

applying hydrated lime, a disinfectant, to feral 

swine carcasses, in a control operation where 

carcasses must be left in the field, even 

temporarily, could reduce carcass disruption 

via scavenging (Figure 10). The addition of 

hydrated lime to a carcass creates a sterile 

crust on feral swine but does not disinfect the 

entire carcass. Scavengers, including turkey 

vultures, corvids, and coyotes, visited

hydrated lime-treated carcasses. Preliminary 

research suggests that applying hydrated

lime to carcasses may be a partial solution to 

leaving carcasses in the field. However, 

further study is needed to determine if 

scavengers could transfer the disease. 

Hydrated lime could also be used for other 

contagious disease outbreaks.

Secondary hazards could occur for wildlife that consumes carcasses killed with the use of some 

toxicants and drugs; these risks are addressed in separate risk assessments for the individual 

take methods, as given in footnote number 9. Depending on the method used to take wildlife, 

some risks of secondary poisoning could be higher. Although many chemical methods WS uses 

can potentially be a secondary hazard, the risk of exposure to toxic levels is minimal.

Figure 10. Turkey vultures attempting to scavenge a feral 

swine carcass covered with hydrated lime.
17

3 EXPOSURE AND RISKS

3.1 Human Health and Safety Exposure and Risks

Human exposure and risk to carcasses are greatest for those who handle and dispose of the 

carcasses. Where carcasses are left in the field, the public can be exposed. However, the majority 

of carcasses are on private lands where the public has little access. The various carcass disposal

methods can potentially pose risks to human health and safety at various levels and for a broader

range of people. Proper carcass disposal management with mitigation as necessary can minimize 

or nullify human health and safety risks. 

3.1.1 Disease

Wildlife can potentially carry several zoonotic diseases that are a risk to people, and WS surveils

the prevalence of many of these diseases (Table 3). WS conducts disease surveillance by 

collecting samples from an animal population which may require taking the animal (e.g., testing 

for rabies in raccoons) or collecting samples from an animal taken for another purpose (e.g., 

removing birds from an airport). In these situations, WS personnel are the population at risk of 

exposure to the disease when they collect the sample. However, WS personnel wear personal 

protective equipment such as gloves and face masks and use appropriate restraining devices to 

prevent zoonotic pathogens from entering their skin through wounds or bites from the restrained 

animal. WS personnel are trained in using sharp tools such as scalpels and needles used during 

sample collection and follow proper disposal protocols for sharp implements, as discussed in WS 

(2018). 

During a mass animal health emergency involving a disease outbreak, WS personnel, along with

veterinarians or livestock owners, may be exposed to the pathogen. APHIS (2021) carcass 

management protocols and safeguards may provide some protection to non-APHIS staff assisting 

in a mass outbreak, but WS does not have the authority to impose its safeguards on others. 

Virulent diseases can spread to people from contaminated people, their clothing, PPE, or other 

equipment used to handle carcasses. Before leaving an infected site, WS mitigates these risks 

by cleaning and disinfecting clothing, PPE, and equipment, including trailer beds, trucks, 

backhoes, cutting implements, and hoists. APHIS (2020) and USEPA (2022a, b) provide 

information for various disinfectants that are appropriate to use against animal disease causative 

agents. Label directions are followed for disposal of items that cannot be adequately disinfected, 

such as some masks. The additional pathogen dissemination risk associated with transportation 

may be minimized by proper decontamination procedures and practices, including at vehicle 

accident sites along the transport route. For example, particles contaminated with pathogens may 

become airborne and then deposited on surfaces and equipment during infected carcasses' 

loading, transport, and off-loading (Center for Food Security and Public Health 2020). Thorough 

cleaning and disinfection with approved disinfectants of the transport vehicles after loading and 

unloading reduce these risks. Carcasses may need to be bagged for transport to avoid dispersal 

of pathogens. Insecticides may need to be used around carcasses to prevent the spread of 

disease from vectors such as biting flies and midges (Baird and Savell 2004). 

Wildlife meat in the U.S. could be a potential source of pathogens. WS donates meat for human 

consumption (Table 2). WS personnel appropriately dispose of individuals that appear sick 

(lethargic, poor condition, abnormal growths, or other maladies). Meat processors can further cull 

animals with abnormal organs (spots on the liver, foul-smelling meat, or growths on internal 
18

organs). Many pathogens are minimized through proper handling and killed by cooking meats 

thoroughly, to 160 oF for ground meat and 145 oF for steaks. WS cannot guarantee any meat is 

disease-free, but if cooked appropriately, risks are minimal.

 

Carcass management can be a direct exposure risk to humans through pathogens such as 

tuberculosis, plague, and brucellosis. Carcasses turned over to processors for human 

consumption have the potential to spread disease or contaminants to people who process and 

consume the meat. Another example is that risks can be related to the process itself, such as 

working around heavy equipment used for handling carcasses, heat-related injuries related to 

burning, incineration, and rendering, or risks of chemical exposure from disinfection. Failure to 

properly manage carcasses when in large numbers also creates the potential for indirect exposure 

to risks. Disease and contaminants can be transferred from flies landing on carcasses or leachate 

and then directly landing on humans. If left unabated, vectors such as fleas and rats can spread 

pathogens or contaminants to humans from decomposing carcasses. Leachate runoff without 

mitigation can also spread disease and contaminants.

The risk of contracting a zoonotic disease, being exposed to harmful chemicals, or suffering an 

injury varies with carcass management methods and the number of carcasses at a site. The least 

potential risk posed by carcass management methods is leaving carcasses in the field when few 

are taken, taking carcasses to a landfill, rendering facility, incinerator, or digester, and using lined 

burial or composting with leachate and gas mitigation. Disposal methods that have more potential 

to be harmful to people but still minimally are open-air burning, unlined burial, and lined burial or 

composting without leachate and gas mitigation. Impacts on people are expected to be least when 

carcasses are left in the field or disposed of at regulated facilities, including rendering facilities, 

fixed-facility incinerators, landfills, and digesters, but transportation of the carcasses to these 

places could be a concern. This is especially true when the number of carcasses weighs many 

tons and when a known live contagious pathogen is potentially in the carcass. Byproducts of 

degrading carcasses, such as leachate that can potentially contain biological and chemical 

agents, are better contained within these controlled facilities than other methods. Regulated 

facilities with higher control in their processing are better able to destroy disease agents and 

destroy or capture potentially toxic residues and byproducts. Newer designs of disposal methods 

with enhanced containment of byproducts and better processing procedures have reduced the 

risks to humans. Overall, risks are minimal from decomposing carcasses, but WS personnel are 

mindful of this potential.

3.1.2 Cleaning and Disinfectants

Cleaning involves the removal of visible organic and inorganic matter (e.g., soil, dirt, debris, salts, 

oils, blood) from objects or surfaces where carcasses or animal parts have been. When done 

appropriately, cleaning alone can remove a large percentage of microorganisms (APHIS 2018, 

USEPA). This step also helps improve disinfection efficacy since many chemical disinfectants 

have reduced effectiveness in the presence of organic material. The cleaning process should be 

conducted before applying all EPA-registered disinfectants. Cleaning is broken down into steps 

dry clean, wash, rinse, and dry (APHIS 2018, USEPA 2022a, g). 

Disinfectants are chemical agents that inactivate or destroy microorganisms on surfaces (APHIS 

2020). Disinfection may not kill all microorganisms, such as bacterial spores resistant to these 

chemicals. Disinfectants include soaps and detergents, oxidizing agents, alkalis, acids, 

aldehydes, phenols, bleaches, and possibly insecticides10 (Baird and Savell 2004). The use of 

10 Baird and Savell (2004) consider insecticides as a disinfectant by minimizing vectors that spread disease from contaminated carcasses. 
19

any specific disinfectant depends on the type of disease outbreak that resulted in the need for 

carcass management (Mukhtar et al. 2012). When specific data is unavailable, USEPA (2022a, 

b) sometimes uses an organism hierarchy to identify effective products for use on emerging 

pathogens. Chemical disinfectants can inactivate most vegetative bacteria and enveloped 

viruses. Fungal spores and non-enveloped viruses generally are less susceptible to chemical 

disinfectants. Mycobacteria, bacterial endospores, and protozoal oocysts are highly resistant to 

most disinfectants (Favero and Bond 2000). Prions, the cause of transmissible spongiform 

encephalopathy, are exceptionally resistant to chemical inactivation. Newer model incinerators 

and digesters are best for destroying these proteins rather than disinfectants; APHIS SOPs 

discuss cleaning and disinfection in APHIS (2018). Some diseases, such as vesicular stomatitis,

can be minimized using insecticides, stopping insect vectors that spread the disease from 

contaminated carcasses. Most diseases can be minimized by appropriate disinfection, vector 

management, or using the most appropriate carcass management method.

Disinfectant manufacturers typically must register their pathogen pesticide products with USEPA 

(2022a, b) and are required to provide data showing that the product performs as claimed. Labels

appearing on the product containers, as well as any associated labeling, are approved by USEPA

(2022a, b) under the Federal Insecticide, Fungicide, Rodenticide Act of 1947 (FIFRA), as 

amended (7 U.S.C. §§ 136-136y). It is unlawful to use a registered pesticide product in a manner 

inconsistent with its labeling (FIFRA section 12(a)(2)(G)). If a microorganism claim appears on 

the label, applicators may use the product according to label directions. If a claim for a particular 

microorganism does not appear on the label, which could be anticipated with new animal diseases 

arising, but all other use directions are followed and, among other things, the use site is the same 

as it is on the label, a disinfectant may still be used under a FIFRA section 2(ee) exemption. 

However, applicators are advised to check with USEPA to confirm this. Applicators may also apply 

to USEPA (2022a) for use exemptions that are not approved on the label through a FIFRA section 

18 emergency exemption request. 

3.1.3 Contaminants

Contaminants could affect human health from being consumed in wildlife meat, the primary 

concern of their presence. They can also be found in ash or leachate when carcasses are

disposed of. Several toxic heavy metals such as arsenic, cadmium, mercury, and lead, and 

organochlorines enter the food chain from local mineralogy, military sites, mining and smelting 

sites, agriculture, and industrial areas such as glass, metal and paint manufacturers, lumber and 

crude oil processors, landfills, and quarries (Tsipoura et al. 2011, Rather et al. 2017). Plants are

the base of the food chain, and they can easily absorb toxic substances from the soil and may

contaminate leaves, fruits, and vegetables (Peralta-Videa et al. 2009); these, in turn, are eaten 

by fish and wildlife and go up the food chain. In the case of pesticides, the maximum residue level 

(MRL) is an important determinant of the risk it poses to human health and determines their use 

restrictions and allowable levels put on resources. The pesticide residue levels in food are 

regulated by legislation to minimize its exposure to the consumer (Nasreddine and Parent-Massin

2002). Chemical contaminants are primarily those transported short- and long-range from sites 

due to geology, including rain runoff and rivers, wind, wildlife, or industrial activities such as the 

movement of all types of vehicles. Contaminants can accumulate in wildlife and plants depending 

on multiple factors (pH, temperature, soil type, molecular structure of chemicals, concentration, 

organic-carbon content, and physiology) and their bioavailability in the soil, sediments, water, and 

plants. Once an organism ingests a contaminant, it can be subject to bioaccumulation or facilitate 

the transfer of the compound to other organisms. The degree of bioaccumulation in food webs 

depends on the number of species it passes through, biomagnification, solubility in lipids or water, 

and chemical inertness. Biomagnification, the continuous increase in chemical concentrations in 
20

a food chain, is highest in fish and marine mammals or seabirds (Kuhnlein and Chan 2000) but 

occurs in terrestrial birds as well.

Studies examining the effects of chronic low-dose exposure to contaminants among human 

populations have had inconsistent findings. These results may have been confounded by factors 

such as malnutrition, smoking, substance abuse, genetics, medications or supplement use, and 

pre-existing health conditions. Risk determinations for populations are not static due to evolving 

data on contaminants, the consequences of their use, and their health effects. Published 

advisories or guidelines are typically based on maximum residue limits or tolerable intakes and 

estimated consumption levels (Kuhnlein and Chan 2000). Subsequently, consuming food 

resources more often than the daily allotment or not consuming them in off-seasons when they 

are not available have not been studied. 

Contaminant levels in wildlife meat vary regionally depending on proximity to local conditions, as 

discussed in Tsipoura et al. (2011). The age, sex, and diet of animals can similarly impact 

exposure. Like dietary assessments for nutrient intake, human contaminant exposure through 

food consumption is measured by assessing the level of food intake and the potential contaminant 

level within the food. Frequently consuming a large quantity of a food source with a low 

contaminant level could expose the consumer to the same relative risk as consuming a small 

amount of food with high contaminant levels, especially if it is primarily stored in the fats or lipids 

of animals. The extent of risk derived from dietary data and dietary standards for contaminants

related to contaminate exposure must be carefully considered, especially in situations where 

meats pose a low risk to the consumer and contribute to the sustainable health of a community. 

Wildlife are a food resource for many people, including subsistence hunters and sportsmen that 

harvest meat and impoverished people with food insecurities given donated meat from WS (Table 

2). This meat may potentially contain contaminants. Cultures such as indigenous peoples that 

rely on wildlife resources and regularly consume meat may refer to dietary intake guidelines 

published by health organizations such as the Agency for Toxic Substances and Disease 

Registry, Joint Food and Agricultural Organization, World Health Organization Expert Committee 

on Food Additives, and USEPA. These dietary standards, including contaminant-intake 

guidelines, express tolerable intake levels for everyday consumption for a given timeframe (grams 

or micrograms of contaminant per kilogram of body weight per day) and incorporate safety 

precautions based on orders of magnitude for contaminant standards. 

Table 4 provides the Agency for Toxic Substances and Disease Registry (2022) minimal risk level 

(MRL) for a few toxic heavy metal contaminants and organochlorines and average levels in meats

from studies. It should be noted that contaminant levels in organs such as liver and kidney tissues 

have been studied, as well as muscle tissues because they are consumed; organs can have 

higher levels of several contaminants. Some levels found in meat, including organs, could be 

toxic. Studies used in Table 4 found no toxic levels of contaminants except for lead, but high levels 

were from a few outliers of the animals collected for the studies (Bruckwicki et al. 2006, Danieli et 

al. 2012, Hassan et al. 2012, Horak et al. 2014). However, considering the meat from wildlife 

consumed, exposure risks are minimal. An example of toxicity from Table 4 is if a 110 lb (50 kg) 

person ate 0.25 pounds (0.11 kg) of goose breast meat a day for 100 days of a year, then they 

would get 0.1 ng of arsenic, .03 ng cadmium, a day or 0.01 mg/kg in that time. That would be a 

tenth of the MRL for arsenic.

Sportsmen and indigenous people throughout the United States harvest wildlife, including 

mammals (deer, elk, moose, antelope, rabbits, bear, and others), birds (waterfowl, gallinaceous 

birds such as pheasant and grouse, pigeons, and doves), reptiles, amphibians, and fish. The total 
21

weight exceeds half a million tons for deer alone in the United States (Appendix A Table A2). Few 

records of problems have arisen from eating this meat, but it does occur. On the other hand, 

impoverished people with few food sources could benefit from a nutritious meal, which would 

benefit their health. Thus, we believe the risks are minimal, especially if the meat is prepared 

appropriately. 

WS donates wildlife meat for consumption to qualifying organizations (Table 2). A concern that 

has arisen is the potential for meat to be contaminated. Contaminated meat is a risk to people but 

is considered minimal (Kuhnlein and Chan 2000, QDMA 2019). When the consumption of wildlife 

does not generally pose a life-threatening risk, it is not governed by food industry regulations. 

Ultimately, the decision to harvest and consume these items is the responsibility of the harvester 

or consumer. Often, consumption advisories are issued based on the contaminate residue limits. 

Consumers should remain vigilant to ensure these recommendations are not exceeded and 

regularly occur, especially for contaminants such as mercury and lead, for animals from a given 

area.

Table 4. Examples of dietary intake guidelines for contaminants from the Agency for Toxic Substances and 

Disease Registry (2022) in meat and the average amount of contaminants present in turkey and urban 

goose breast meat (Horak et al. 2014), wild boar meat (Danieli et al. 2012), semi-domestic reindeer venison 

(Hassan et al. 2012), and deer (Bruckwicki et al. 2006). The contaminants given are some that are of 

greatest concern. 

CONTAMINANTS IN MEAT FROM DIFFERENT SOURCES

Contaminant ATSDR MRL Turkey 

Breast

Goose 

Breast

Swine 

Meat

Reindeer 

Meat

WT Deer 

Meat

WT Deer 

Liver

mg/kg Amount (ppm)

As (Arsenic) 0.1 Int. (15-

364 days)

0.04 0.05 na 0.020 <0.2 <0.2

Cd (Cadmium) 0.025 /month 0.005 0.016 0.078 0.002 <0.1 2.6

Pb (Lead)* 0.035** 0.018 0.191 0.124 0.008 0.38 (5.2) <0.2 (1.9)

Hg (Mercury) 0.3 na 0.154 na na <0.1 <0.1

Organochlorines 0.5-1 na 0.0103 na na x x

* Both white-tailed deer and Canada goose studies had individual animals that tested very high, but most were within the safe zone.

** No safe level of lead has been determined for children but has been set at 3.5 μg/dL blood level (0.035 ppm) is with potential effects 

at ≤ 5μg/dL (CDC 2022a) so this cannot be converted to mg/kg. Background levels in the first 5 cm soil throughout the United States 

averaged 26 mg/kg (Smith et al. 2013)

Contaminants in Canada goose breast meat from several states were analyzed from urban WS 

WDM projects where geese were euthanized with carbon dioxide (Horak et al. 2014). “Resident” 

geese tend to stay within the confines of urban areas for most of the year, where high levels of 

contaminants may exist. Horak et al. (2014) found higher levels of cadmium and lead than in 

regular turkey breast meat and somewhat high mercury levels, but this was not available for turkey 

or was not found (Table 4). Levels of cadmium and mercury were not considered a risk to people 

(Horak et al. 2014). In the Horak et al. (2014) study, three geese, in particular, had high levels of 

lead, with one from Virginia having three times the level of any others, which skewed results; it 

was not determined exactly where these three geese were feeding, but possibly in nearby 

industrial areas. Geese with high levels of one contaminant usually had high levels of others. Lead 

concentration studies in urban versus rural areas have typically found that lead levels in urban 

human populations are generally higher (Cohen et al. 1973, Aelion and Davis 2019). These have 

been associated with lead paint, leaded gasoline, and continued environmental background to 

this day. Lead has no biological function and is considered toxic to people and wildlife at certain 

levels of chronic exposure, mostly from exposure to environmental contamination. When 

absorbed, lead disrupts various biochemical reactions and cellular structures (Thompson 2012). 
22

It is believed that, in general, goose or other meats donated by WS to the food insecure will have 

minimal potential to cause long-term effects because the number of geese or other meats donated 

to an individual person is limited, and the duration of the donations is seasonal. Meat from animals 

suspected of carrying a zoonotic disease, appearing sick, or having abnormal-looking meat and 

organs are discarded appropriately. WS does not donate any meat from animals taken with any 

chemicals and minimally for animals shot with lead. Even with meat cut away from the entrance 

and exit wounds, bullet or shot fragments can often still be found in the meat as far as 6 inches 

away (Tsuji et al. 1999, Bellinger et al. 2013). WS attempts to recover animals from operations 

that have a potential for contaminants that could harm people. Thus, it is believed that the 

consumption of meat donated by WS will not have more than a minimal effect on people.

3.1.4 Injuries

Injuries to WS personnel from carcass management in the field are mostly associated with moving 

carcasses. Between FY13 and FY15, WS employees reported an annual average of 2 injuries 

related to the movement of carcasses (a strained back and sprained wrist), an annual average of 

3 tick bites (it is unknown whether these came from carcasses or just from being in the field) and 

0.7 average annual injuries from using scalpels to take rabies samples, potentially exposing 

themselves to the disease. Between FY16 and FY21, WS employees reported an annual average 

of 2 injuries related to the movement of carcasses resulting in strains and sprains, and an annual 

average of 16 tick bites (it is unknown whether these came from carcasses or just from being in 

the field) and 6 average annual injuries from using scalpels or needles to take tissue and blood 

samples, potentially exposing themselves to zoonotic disease. Additionally, WS employees had 

an annual average of 31 field injuries from FY13-15 and 5 field injuries from FY16-20 from falls, 

slips, twists, and repetitive activities that resulted in lacerations, sprains, contusions, strains, 

compression bruises, and fractures, but the injury report did not associate them with any specific 

activity such as moving a carcass. Considering the number of employees (~1,900), the claims 

were relatively few for the number of hours spent afield. Thus, risks are relatively minor to 

employees.

3.2 Environmental Risks

Carcass management and the various disposal methods have the potential to pose risks to wildlife 

and the environment (APHIS 2018, USEPA 2022b, d). Carcass management can spread 

unwanted pathogens to wildlife and livestock. Vehicles loaded with carcasses may pass through 

other land-use areas, but these areas are only briefly affected unless consequences arise from 

an accident. The risk of contracting a disease or being exposed to harmful chemicals varies with 

carcass management methods and is similar to risks discussed in Section 3.1, except pathogens 

typically spread to the same or similar species in the area. Thus, it is much more important for 

proper disposal methods to be used. Newer designs of incinerators and digesters are better for 

some diseases, such as those resulting from prions. Landfill and carcass burial liners that allow 

the collection of leachate reduce the potential for a large number of buried carcasses to impact 

water quality in an area.

Environmental components consider a broad range of abiotic and biotic resources. Abiotic 

resources include soil, air, and water; biotic resources include vegetation and wildlife. Areas 

potentially affected during the implementation of a carcass management program include 

agricultural and nonagricultural lands in all States of the United States and its territories. 

Impacts on soil, air, and water are expected to be minimized by handling carcasses at regulated 

facilities, including rendering facilities, fixed-facility incinerators, and landfills. Animals left in the 
23

field cause minimal problems if there are few but can be more of a concern when it becomes tons 

of biomass.

3.2.1 Soils and Vegetation

WS WDM projects that result in carcasses occur at a range of sites on rangelands, grasslands, 

forests, urban areas, and farms, which often dictate the carcass management choice and location. 

Most are at remote sites where the public has no or little access. Overall, carcass management 

locations and facilities where carcasses are disposed of, such as landfills or off-site incinerators, 

have minimal access by the public. However, roads that lead to offsite disposal facilities could be 

accessed so carcasses are secured and covered as necessary to prevent the spreading of 

pathogens or contaminants of concern. During carcass management, land use on a premise may 

shift from livestock production to a disposal location if onsite burning, burial, or composting occurs.

Plant cover reduces erosion and protects the soil against degradation; consequently, the removal 

of plant cover impacts ecosystem function and future land use (Castillo et al. 1997, Zhao et al. 

2011).

Soils are affected by decomposing carcasses. The degree depends on local topography,

geography, soil type, and plant cover. Variations in the chemical and physical properties of the 

soil will impact bioavailability, chemical degradation, and transport of leachate, including chemical

contaminants and pathogens from carcasses. Physical impacts on soil during carcass 

management can occur from digging trenches, removing topsoil, and physically compacting soil 

using heavy equipment; these activities may increase erosion and decrease soil quality (Engel et 

al. 2004). Decaying carcasses impact soil quality by releasing chemical contaminants or leachate. 

Nitrogen and phosphorus from carcass leachate may add minerals and nutrients to the soil that 

become available for plant growth; however, excessive amounts of these nutrients can negatively 

affect soil microorganisms and alter normal carbon, nitrogen, and phosphorus cycling. Antibiotics 

from farmed animals and other chemical contaminants may leach into soil and affect naturally 

occurring soil microorganisms or become available for plant and animal uptake, which may 

contaminate the food chain. The impacts on soil and vegetation from leachate are minimal when 

isolated or a few individuals are left in the field. The impacts on soil and vegetation from leachate 

increase with a large number of carcasses requiring other disposal methods that collect leachate

and protect soil quality.

3.2.2 Air Quality

The release of atmospheric pollutants from carcass management methods varies and may be 

regulated by federal and state regulations. Many air pollutants associated with large animal 

operations are also associated with various carcass management practices. Carbon dioxide, 

ammonia, methane, and other volatile organic carbons are associated with onsite burial, 

composting, and landfills (Engel et al. 2004, Xu et al. 2007, Hao et al. 2009, Akdeniz et al. 2011, 

Yuan et al. 2012). Air quality conditions vary across the United States, with urban areas typically 

experiencing degraded air quality during certain times of the year. Both Federal and State 

agencies monitor air quality. USEPA (2014) monitors air quality throughout the country at 

monitoring stations that measure various pollutants (USEPA 2014). USEPA monitoring generates 

an air quality index (AQI) for a given area that can be used by the public to determine air quality 

conditions (USEPA 2014). The AQI ranges from 0 to 500, with values below 50 suggesting good 

air quality with no health impacts. In contrast, values above 300 suggest poor air quality and 

potential human health impacts on the entire population. A value of 100 is related to the air quality 

standard for a given pollutant; values between 100 and 150 may result in potential health impacts 

on the most sensitive populations. An AQI above 150 represents unhealthy conditions for a larger 

part of the population, with more impacts as the value increases. Values above 200 are 
24

considered rare in the United States. Typical AQI values are below 100 throughout the United 

States but may exceed 100 during various times of the year (USEPA 2014). The AQI is based on 

four priority pollutants: sulfur dioxide, carbon monoxide, particulate matter, and ozone. Particulate 

matter is further divided into particles less than 2.5 micrometers (μm) and those less than 10 μm. 

Other air quality standards are not considered in the estimate of the AQI. 

USEPA and some state agencies also monitor other pollutants; these may be used to determine 

if some regions of the United States are within attainment for priority pollutants as defined by the 

National Ambient Air Quality Standards (NAAQS) in the CAA. Areas in the United States where 

large numbers of livestock occur are typically rural, where the AQI is below 50, and are considered 

compliant with air quality standards. However, these areas may contain large, confined animal 

operations with the potential for localized impacts on air quality. The extent of the impact on air 

quality from these operations depends on the size and management of the facilities. Releases of 

pollutants or volatile organic compounds (VOC) from these types of facilities may impact air 

quality and include odorous compounds, microorganisms, particulate matter, ammonia, nitric 

oxides, nitrogen oxides, carbon dioxide, methane, and hydrogen sulfide, which are commonly 

grouped as VOCs (Aneja et al. 2009, Ni et al. 2009, Guerra et al. 2017). Some pollutants are 

regulated under federal or state law and may be managed through compliance agreements 

between the source and the applicable regulatory entity. Strategies to abate VOC emissions are 

ongoing but getting more robust (Guerra et al. 2017). WS may be required to obtain burn permits 

from the appropriate agencies for disposal operations involving burn piles and incinerator use.

3.2.3 Water Quality

Ground and surface water quality varies across the United States due to various natural and manmade factors. Natural physical and chemical features (e.g., soil type, topography, vegetation type, 

cover, and mineral levels) can all influence background water quality characteristics for a water 

body. However, features and activities such as dams, urban development, industrial mining, and 

agricultural activities can also provide point and non-point sources of contamination that can 

impact a wide variety of water quality parameters such as pH, temperature, and biological oxygen 

demand. These and similar features and activities can also introduce natural and anthropogenic 

stressors into ground and surface water, impacting water quality. Excessive nutrients, pathogens, 

sediments, and other chemicals can degrade water quality, impacting human and ecological 

health and the designated use of a specific water body. 

Carcasses of animals that die in water due to a WDM action may not be retrieved, which can 

happen with several species, such as double-crested cormorants, red-winged blackbirds, 

beavers, nutria, and waterfowl. The Rivers and Harbors Act of 1899, known as the Refuse Act of 

1899, as amended (codified at 33 U.S.C. §§ 401–426), makes it unlawful to obstruct navigation 

or discharge or deposit refuse into navigable waters. Carcasses that die in or fall into the water 

are not discharged into the water. However, carcasses taken on the ground are not disposed of 

in U.S. waters by WS. Reasons for water quality impairment vary and generally fall into a category 

of contamination, but CWA section 303(d) listings for all States show that the primary reasons for 

impairment (in decreasing order) are pathogens, nutrients, metals, organic enrichment, and 

sediments. This group represents approximately 38 percent of the total causes for impairment of 

assessed water bodies in the United States (USEPA 2022h). Within the pathogen group, fecal 

coliforms and E. coli are the primary causal agents for impairment due to pathogens. Nutrient 

impairment is primarily due to excessive phosphorus and total nitrogen in water. The minimal 

number of carcasses taken by WS and left in water would not foul the waters of the United States.

WS attempts to retrieve diseased animals that have died in water if it is safe and possible to 

reduce further disease transmission.
25

Agriculture is the primary cause of impairment to rivers and streams, is the third leading cause of 

impairment for lakes, and is the second leading cause of impairment for wetlands (Kim and Kim 

2012, U.S. Geological Survey 2019, USEPA 2022h). Agriculture includes multiple aspects of the 

industry, including crop and livestock production. Livestock sources may include grazing, confined 

animal feeding operations, animal manure, and other activities (U.S. Geological Survey 2019, 

USEPA 2022h). Several pollutants are identified as threats to ground and surface water as a 

result of carcass management, including antibiotics, ash, chloride, dioxins, polycyclic aromatic 

hydrocarbons, and other combustion byproducts, hormones, metals, microorganisms such as

pathogens, nitrogen-containing compounds (ammonia and nitrate), oils and grease,

pharmaceutical drugs (various veterinary uses such as euthanasia), phosphorous, sulfates, total 

dissolved solids, and total organic carbon (Ritter and Chirnside 1995. Myers et al. 1999, Engel et 

al. 2004, Glanville et al. 2006, Pratt and Fonstad 2009, Joung et al. 2013, Yuan et al. 2013). Some 

of these contaminants are detected in leachate from swine, cattle, and poultry disposal, while the 

presence of others, such as antibiotics, pathogenic microorganisms, and veterinarian 

pharmaceuticals, reflect the specific source or industry. Many of these pollutants are also listed 

as causal agents for impairment under section 303(d) for various water bodies in the United 

States. Aerial deposition and leaching or runoff may be pathways for pollutants to enter surface 

and groundwater sources from burning activities (Pollard et al. 2008). 

3.2.4 Wildlife

Wildlife may feed on carcasses left in the field. In general, scavenging of carcasses left in the field 

will have no deleterious effects on wildlife and may benefit wildlife, especially during food-limited 

times. On the other hand, if pathogens, euthanasia drugs, or chemicals, including lead, are a 

concern, scavengers may be at risk, and, thus, collecting and conducting the appropriate level of 

carcass disposal for the particular pathogen, drug, or chemical would be required. Managing 

carcasses as quickly as allowable decreases the time that scavengers (e.g., raptors, corvids such 

as ravens, canids, bears, mustelids such as fishers, skunks, and to a lesser extent, cats) can feed 

on carcasses helping to minimize the transmission of pathogens. Scavengers, such as eagles, 

quickly locate fresh carcasses, making them susceptible to secondary poisoning when animals 

are killed with toxins and left uncovered. Animals euthanized with drugs are generally in hand or 

controlled so they can be immediately gathered. In contrast, those taken with toxicants may die 

in varied locations depending on the chemical used.

WS has prepared or is preparing chemical risk assessments, including immobilization and 

euthanasia drugs, for the individual chemical control methods used in WDM. In those risk 

assessments, WS evaluated the risk of secondary poisoning to nontarget plants and wildlife that 

feed on treated animals or carcasses in each applicable chemical risk assessment. The risk 

assessments, for the most part, did not address the disposal of carcasses taken with chemical 

method, as required by labeling or policy. WS minimizes secondary risks as necessary by 

collecting target and nontarget animals that are taken using chemical control methods. The labels 

for chemical control use limit the amount of pesticide that can be used or where it may be used. 

In many cases, the label requires the collection of any target or nontarget species that succumb 

to chemical control when secondary hazards are a risk or for other reasons. For example, USFWS 

and National Euthanasia Registry recommend that animals treated with pentobarbital are either 

buried or burned shortly after death since this drug, in particular, can have an effect on scavengers 

(Krueger and Krueger 2002, Lazaroff 2002). Mammals, birds, and other wildlife, such as foxes, 

bears, coyotes, lynxes, bobcats, and mountain lions, could be affected by the ingestion of 

pentobarbital (Krueger and Krueger 2002). WS does not anticipate this to be a problem, though,

since all animals euthanized are disposed of according to label instructions, mostly taking them 
26

to a facility that accepts them and has the animal on hand (e.g., in a cage or foothold trap, a catchpole, or immobilized).

Lead ammunition is a concern for wildlife. The United States mostly banned the use of leaded 

paint, gas, and lead pellets for hunting waterfowl in 1991 (Anderson et al. 2000), and these helped

reduce environmental lead levels, but lead poisoning remains a hazard to wildlife. Lead use from 

all sources has been banned in the range of the California condor (Gymnogyps californianus). 

The WS Use of Lead in Wildlife Damage Management risk assessment discussed lead risks. It

determined that the amount of lead used in WS WDM operations poses minimal risk to humans 

and the environment.

The final issue related to carcass disposal is the potential for leachate to harm wildlife and 

ecosystems. Leachate is managed to the greatest extent by the selection of the disposal method,

as several methods do not result in leachate 

4 UNCERTAINTIES AND CUMULATIVE EFFECTS

A few uncertainties are associated with carcass management and disposal. WS is unable to 

predict when and where a mass disease outbreak will occur, which could result in the handling 

and disposal of a large number of carcasses. The disposal methods available to WS are 

appropriate for the range of animal diseases currently identified in the United States. Current 

disposal methods and their use may need to be modified if a disease outbreak that can be spread 

by carcass-based transmission (e.g., African Swine Fever) occurs.

Cumulative impacts are not expected to occur by disposing of wildlife carcasses in WDM. 

Although the open burning of animal carcasses from a mass disease outbreak could occur in an 

area where there are other burn activities taking place (controlled burning of a field or forest, 

wildfire, etc.), the burning of carcasses is controlled, localized and occurs for a short period of 

time. The “Introduction to Risk Assessments for Methods Used in Wildlife Damage 

Management”12 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 carcass disposal 

methods in WDM will not have any known cumulative impacts.

5 SUMMARY

WS uses carcass disposal as a component of an integrated approach in WDM. WS works 

cooperatively with other federal and state natural resource agencies, including other programs in 

APHIS, to develop standards for disposing of animal carcasses following WDM projects, including 

mass animal incidences involving pathogens. Federal and state regulations and internal USDA 

APHIS WS policies provide the requirements for proper carcass disposal to reduce environmental 

and human health impacts.

The various carcass disposal methods WS uses include leaving carcasses in the field, burial, 

open-air burning, composting, rendering, landfill, incineration, and tissue digestion. Some 

carcasses may also be donated for human consumption where appropriate and in compliance 

with federal and state regulations. Carcass disposal due to wildlife management activities typically 

results in fewer animals than carcass disposal due to disease outbreaks. However, APHIS WS 

disposes of carcasses more commonly due to WDM activities than disease outbreaks. WS leaves 

most carcasses in the field since most animals taken using lethal methods are individually taken 

or taken in small numbers and do not pose a threat to wildlife or humans. If a local outbreak 

occurs, this method ensures disease is not moved off-site. If an animal is diseased, it is turned 
27

over to the Health Department or disposed of appropriately to eliminate disease transmission to 

other wildlife. 

As carcasses degrade, bodily fluids consisting of natural and anthropogenic chemical and 

biological leachate, and hazardous gases may be released into the environment. The risk of 

carcass disposal to human health and the environment varies based on the number of animals 

being disposed of and whether a disease is of concern. The risk to human health from carcass 

disposal is generally low for all methods when following applicable federal and state regulations 

and WS policies. WS personnel are at the greatest risk from handling carcasses, but risks are 

minimal or nullified if standard operating procedures are followed. Risks to ecological resources 

are also generally low. Decomposition products from carcass disposal can also pose a risk to 

ecological resources through air, soil, and water exposure. Leaving carcasses on-site in the field 

results in a greater potential for exposure to scavengers compared to the other disposal options,

such as burial, rendering, incineration, and tissue digestion, where no exposure to scavengers 

would be expected. Animals euthanized with drugs can pose secondary hazards to scavengers. 

Disposal is dictated by applicable federal and state regulations, drug label instructions, or lacking 

such guidelines by deep burial, incineration, or at a landfill approved for such disposal. In cases 

of carcass disposal where zoonotic disease or chemical contaminants are a concern, WS uses

disposal options intended to reduce the risks to scavengers and other ecological resources 

through compliance with federal and state regulations and WS policies. 

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https://www.epa.gov/anaerobic-digestion/types-anaerobic-digesters#WRRFdigesters

_____ USEPA. 2022a. Antimicrobial pesticide registration. USEPA website. Accessed 7/18/2022

@ https://www.epa.gov/pesticide-registration/antimicrobial-pesticide-registration

_____ USEPA. 2022b. Emerging viral pathogen guidance and status for antimicrobial pesticides. 

USEPA website. Accessed 7/18/2022 @ https://www.epa.gov/pesticideregistration/emerging-viral-pathogen-guidance-and-status-antimicrobial-pesticides

_____ USEPA. 2022c. Landfill methane outreach program (LMOP). USEPA website. Accessed 

7/18/2022 @ https://www.epa.gov/lmop

_____ USEPA. 2022d. Managing materials and wastes for homeland security incidents. USEPA 

website. Accessed 7/18/2022 @ https://www.epa.gov/homeland-security-waste

_____ USEPA. 2022e. National pollutant discharge elimination system (NPDES). USEPA 

website. Accessed 7/18/2022 @ https://www.epa.gov/npdes

_____ USEPA. 2022f. Resource Conservation and Recovery Act (RCRA) laws and regulations. 

USEPA website. Accessed 7/18/2022 @ https://www.epa.gov/rcra

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7/18/2022 @ https://www.epa.gov/pesticide-registration/selected-epa-registereddisinfectants

_____USEPA. 2022h. Water topics. USEPA website. Accessed 7/18/2022 @ 

https://www.epa.gov/environmental-topics/water-topics
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36

7 PREPARERS

7.1 APHIS WS Methods Risk Assessment Committee

Writers for “Carcass Disposal 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-seven 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. Applied and 

supervised the disposal of carcasses in WDM.

Editors/Contributors for “Carcass Disposal in Wildlife Damage Management Risk 

Assessment”:

Editor/Contributor: Shelagh DeLiberto 

Position: USDA-APHIS-Wildlife Services (WS), National Wildlife Research Center (NWRC), 

Wildlife Biologist, Fort Collins, CO

Education: BA Biology and Environmental Science – Ithaca College; MS Wildlife Biology –

Colorado State University 

Experience: Sixteen years of service in APHIS conducting wildlife research. Two years of 

experience in preparing categorical exclusions and environmental analyses in compliance 

with the National Environmental Policy Act.

Editor: Michael Green 

Position: USDA-APHIS-Wildlife Services (WS), Environmental Coordinator, Fredrick, MD

Education: BS Wildlife and Fisheries Sciences, University of Tennessee

Experience: Special expertise in wildlife biology, ecology, and damage management. Eleven 

years of work experience with WS in MD and VA. Experienced in a wide range of program 

activities including nutria eradication, airport wildlife management, and wildlife damage 

management to protect livestock, aquaculture, public safety, and natural resources. Served 

as staff biologist in WS Headquarters for two years.

Editor: 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: Sixteen years of service in APHIS conducting risk analysis. Six years of 

experience in preparing environmental analyses in compliance with the National 

Environmental Policy Act.

Editor/Contributor: Jim Warren
37

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: Sixteen 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 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.

7.2 Internal Reviewers

USDA APHIS Wildlife Services

Reviewer: Michael Bodenchuk

Position: USDA APHIS WS, State Director, San Antonio, TX

Education: BS Wildlife Management, New Mexico State University

Experience: Ten years state and private sectors in wildlife management . Thirty-two years USDA 

APHIS WS in wildlife damage management including conducting and supervising carcass 

management.

Reviewer: Vienna Brown

Position: USDA APHIS WS National Feral Swine Program, Disease Biologist, Fort Collins, CO

Education: BS Animal Sciences, Colorado State University; MPH Animals, People, and the 

Environment; University of Colorado, Denver; PhD Microbiology, Colorado State University

Experience: Two years as a post-doc with Department of Homeland Security working on risk 

assessments at the wildlife-livestock interface. Four years as a staff biologist with the National 

Feral Swine Damage Management Program as the Disease and Research Components lead.

Reviewer: Brett Dunlap

Position: USDA APHIS WS, State Director, Madison, TN

Education: BS Wildlife & Fisheries Sciences, Texas A&M University; MA Biology, Sam Houston 

State University

Experience: Thirty-three years with Texas Animal Damage Control and USDA APHIS WS in 

wildlife damage management including conducting and supervising carcass management.

Reviewer: Shannon Hebert

Position: USDA APHIS WS, Assistant Deputy Director, Environmental Management

Education: BS Animal Science, Virginia Tech; MS Agriculture, Cal Poly, San Luis Obispo

Experience: Thirty-three years in Federal environmental compliance focused on natural resource 

management, including 27 years with APHIS WS.
38

Reviewer: Michael Marlow

Position: USDA APHIS WS, National Feral Swine Damage Management Program, Assistant 

Program Manager

Education: BS Wildlife Ecology, MAg International Agriculture, Oklahoma State University

Experience: Twenty-six years USDA APHIS WS including field operations, disease surveillance, 

and carcass management.

7.3 Peer Review

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

scientific documents. The APHIS guidelines were followed to have "Use of Carcass Disposal in 

Wildlife Damage Management" peer reviewed. WS worked with the Association of Fish and 

Wildlife Agencies to have experts review the documents.

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

Missouri Department of Conservation

Oklahoma Department of Wildlife Conservation

Idaho Department of Fish and Game

7.3.2 Comments

1. The only hazard/risk I did not see, and I could have missed it, was the risk of attack from 

large carnivores that are looking to feed on disposed carcasses, especially in areas 

where animals are regularly left in open areas. I know from my time in the mountain west 

that some grizzly and black bears were frequent areas that animal carcasses were 

disposed of and in some cases these animals expressed aggressive behaviors towards 

people that either were dropping off carcasses or with people that were driving or hiking 

in the area. So that might be something to look into, but again this was not a frequently 

occurring thing but I think is valid to think to acknowledge given all the other factors that 

are considered in this document.

Response: We agree that bears and other large carnivores may be attracted to 

carcasses left on the landscape. If carcasses are routinely disposed of in the same pit, 

over time, the area can be an attractant to scavengers. However, WS personnel do not 

do this. Sander et al. (2002; Selected methods of animal carcass disposal JAVMA 220: 

1003-1006) acknowledge that cattle carcasses can attract predators to an area causing 

increased predation of calves at calving time. WS is not generally involved in cattle 

removals. Wildlife removed by WS through WDM are taken individually or in small 

numbers and do not pose a threat to wildlife, humans, or the environment when left on 

the landscape. Most animals are scavenged relatively quickly by birds (e.g., turkey 

vultures, eagles). Other wildlife, such as deer, are often donated and not left on the 

landscape (see Table 2). Feral swine, when trapped in large numbers, are often spread 

across the landscape, but the location of these carcasses would not put humans or the 
39

public in danger. In locations where WS conducts wildlife damage management 

activities, people would not usually drive or hike, and WS does not generally utilize

carcass pits at centralized locations. 

Comments received not requiring a response.

1. This document provided an exhaustive review on the subject of carcass disposal in wildlife 

management. I did not find any sections that warranted changes.

2. Document was reviewed. No edits or comments to be added.

3. The Carcass Disposal in Wildlife Damage Management document to me seem well written 

and covers a lot of information in a concise manor for just about anyone to be able to read 

and understand. In Missouri, we do a mix of sending carcasses to dumps, incinerate, or 

leave in the field when possible. Most of the animals that are disposed of do not pose a 

threat to human safety and this document does a good job providing context about the 

potential hazards that could come from utilizing any of these methods.
40

Appendix A. Average weights of animals lethally taken by WS in wildlife damage 

management and for comparison weights of animals from sportsmen harvest and 

vehicular accidents.

WS conducts wildlife damage management (WDM) for many species each year in different 

projects. Numbers are recorded in the MIS. The use of toxicants needs estimates of the 

numbers taken but are included and assumptions are given in the risk assessments for those 

methods. Appendix A - Table A1 (mammalian predators), Table A2 (hoofed mammals), Table 

A3 (rodents and rabbits), Table A4 (other mammals), Table A5 (landbirds), Table A6 

(waterbirds), and Table A7 (reptiles, amphibians, and fish) give the numbers of animals killed by 

WS and their carcass weights. For comparison to WS take, sportsmen harvest of deer and 

waterfowl and road killed deer numbers and weight are include in Table A8. Numbers from 

these tables are summarized in the risk assessment.

Table A1. The annual average number of predators killed by WS in WDM between FY11 and 

FY15 and FY16 and FY20 throughout the United States and its territories (only animals with an 

annual average take of 0.5 or more included) and the weight of their carcasses.

* Introduced Species ^ Translocated from former range within North America to areas where invasive

# Numbers killed were estimated for dens taken (2 for each badger den, 3 for striped skunk, and 4 for coyote, red fox, and opossum) 

T&E –Threatened and endangered species (Federal only)

PREDATORS

Species Scientific Name Weight 

(oz)

Annual Avg FY11- Annual Avg FY16-

# Killed Total Wt # Killed Total Wt 

Virginia Opossum^ Didelphis virginiana 96 2,287 13,722 2,457 14,742

Feral/Free-roaming Cat* Felis catus 240 907 13,605 473 7,905

Bobcat Lynx rufus 288 944 16,992 903 16,254

Mountain Lion Puma concolor 2160 351 47,385 326 44,010

Small Asian Mongoose* Herpestes javanicus 19 2,175 2,583 1,793 2,129

Coyote^# Canis latrans 440 75,077 2,064,618 67,848 1,865,820

Northwestern Gray Wolf Canis lupus 1744 166 18,094 175 19,075

- Mexican Gray WolfT&E Canis lupus baileyi 1080 1 68 1 68

- Great Plains Gray Canis lupus nubilus 1440 213 19,170 188 16,920

- Feral/Free-Roaming Canis lupus familiaris 960 339 20,280 135 8,100

Red Fox^# Vulpes vulpes 240 2,222 33,330 1,540 23,100

Swift Fox Vulpes velox 78 23 112 11 54

Kit Fox Vulpes macrotis 76 13 62 9 43

Arctic Fox^ Vulpes lagopus 113 176 1,243 34 240

Common Gray Fox Urocyon 186 1,928 22,413 1,717 19,960

Brown Bear (Grizzly) Ursus arctos horribilis 6800 - - 2 850

Black Bear Ursus americanus 4000 524 131,000 435 108,750

River Otter Lontra canadensis 336 512 10,752 649 13,629

Fisher Martes pennanti 120 1 7.5 1 7.5

Long-tailed Weasel Mustela frenata 7 8 3.5 4 1.8

Short-tailed Weasel Mustela erminea 4 3 0.5 1 0.2

Mink Mustela vison 28 39 68 16 28

Badger# Taxidea taxus 272 423 7,191 381 6,477

Ringtail Bassariscus astutus 176 2 22 - -

Raccoon Procyon lotor 400 11,887 297,175 9,609 240,225

Hog-nosed Skunk Conepatus leuconotus 114 6 43 2 14

Hooded Skunk Mephitis macroura 30 9 17 6 11

Striped Skunk# Mephitis mephitis 112 6,543 45,794 4,953 34,671

Eastern Spotted Skunk Spilogale putorius 26 4 6.5 6 10

Western Spotted Skunk Spilogale gracilis 27 10 17 6 10

TOTAL PREDATORS 27 Sp. + 3 Ssp. 106,793 2,765,774 93,681 2,443,105
41

Table A2. The annual average number of hoofed mammals killed by WS in WDM between FY11 

and FY15 and FY16 and FY20 throughout the United States and its territories (only animals with 

an annual average take of 0.5 or more included) and the weight of their carcasses.

HOOFED MAMMALS

Species Scientific Name Weight 

(oz)

Annual Avg FY11- Annual Avg FY16-

Killed Total Wt Killed Total Wt 

Feral Swine* Sus scrofa 2400 32,976 4,946,400 78,648 11,797,200

Collared Peccary Pecari tajacu 752 196 9,212 134 6,298

Moose^ Alces alces 17280 2 2,160 1 1,080

Axis Deer* Axis axis 2560 376 60,160 3 480

Fallow Deer Dama dama 2050 - - 21 2,691

American Elk^ Cervus canadensis 9600 2 1200 110 66,000

Red Deer* Cervus elaphus 6040 1 378 2 755

Sika Deer* Cervus nippon 1280 3 240 1 80

Mule Deer Odocoileus hemionus 2800 67 11,725 47 8,225

White-tailed Deer^ Odocoileus virginianus 2800 5,474 957,950 8,094 1,416,450

Caribou Rangifer tarandus 4400 3 825 1 275

Philippine (Sambar) Deer Rusa marianna 8000 50 25,000 321 160,500

Pronghorn (American Antilocapra americana 1600 4 400 3 300

Nilgai Boselaphus 6260 - - 5 1,956

Feral Cattle* Bos primigenius 16000 3 3,000 6 6,000

Feral Goat* Capra aegagrus hircus 1920 13 1,560 8 960

Bighorn Sheep Ovis canadensis 2500 6 938 28 4,375

Feral Sheep* Ovis aries 1408 3 264 3 264

TOTAL 18 Species 39,179 6,021,412 87,436 13,473,889

* Introduced Species ^Introduced populations exist

Table A3. The annual average number of rodents and rabbits killed by WS in WDM between 

FY11 and FY15 and FY16 and FY20 throughout the United States and its territories (only 

animals with an annual average take of 0.5 or more included) and the weight of their carcasses. 

RODENTS AND RABBITS

Species Scientific Name Weight 

(oz)

Annual Avg FY11-FY15 Annual Avg FY16-FY20

Killed Total Wt Killed Total Wt 

Mountain Beaver Aplodontia rufa 40 109 273 263 658

Western Gray Squirrel Sciurus griseus 20 8 10 15 19

Eastern Gray Squirrel^ Sciurus carolinensis 19 145 172 158 188

Eastern Fox Squirrel^ Sciurus niger 32 155 310 124 248

Abert’s Squirrel Sciurus aberti 28 - - 92 161

Red Squirrel Tamiasciurus hudsonicus 8.0 3 1.5 12 6.0

Douglas Squirrel Tamiasciurus douglasii 6.5 12 4.9 - -

Woodchuck Marmota monax 120 4,869 36,518 1,858 13,935

Yellow-bellied Marmot Marmota flaviventris 120 1,803 13,523 1,373

Hoary Marmot Marmota caligata 224 1 14 - -

Black-tailed Prairie Dog Cynomys ludovicianus 40 193,144 482,860 215,843 539,608

Gunnison’s Prairie Dog Cynomys gunnisoni 32 19,160 38,320 9,593 19,186

White-tailed Prairie Dog Cynomys leucurus 32 2,181 4,362 2,504 5,008

California Ground Squirrel Otospermophilus beecheyi 24 9,645 14,468 7,054 10,581

Rock Squirrel Otospermophilus 26 430 699 164 267

White-tailed Antelope Ammospermophilus 2 - - 1 0.1

Paiute Ground Squirrel Urocitellus mollis 5 832 260 - -

Richardson’s Ground Urocitellus richardsonii 15 949 890 481 451

Wyoming Ground Squirrel Urocitellus elegans 12 83 62 83 62

Uinta Ground Squirrel Urocitellus armatus 13 95 77 14 11

Belding's Ground Squirrel Urocitellus beldingi 10 4,730 2,956 4,988 3,118

Columbian Ground Squirrel Urocitellus columbianus 20 1,476 1,845 23 29

S. Idaho Ground Squirrel Urocitellus endemicus 10 - - 39 24

Thirteen-Lined Ground Ictidomys tridecemlineatus 6.5 1,062 431 140 57

Mexican Ground Squirrel Ictidomys mexicanus 9.5 1,487 883 237 141

Round-tailed Ground Xerospermophilus 5.5 7,754 2,665 4,230 1,454
42

Cliff Chipmunk Neotamias dorsalis 2 - - 1 0.1

Yellow Pine Chipmunk Neotamias amoenus 2.5 - - 6 0.9

Eastern Chipmunk Tamias striatus 3.5 21 4.6 35 7.7

Beaver^ Castor canadensis 720 24,400 1,098,000 23,462 1,055,790

Ord’s Kangaroo Rat Dipodomys ordii 2.0 1,672 209 933 117

Merriam’s Kangaroo Rat Dipodomys merriami 1.5 - - 3 0.3

Yellow-Faced Pocket Cratogeomys castanops 10 3,189 1,993 684 428

Attwater's Pocket Gopher Geomys attwateri 8.5 234 124 - -

Desert Pocket Gopher Geomys arenarius 8.5 1 0.5 - -

Knox Jones’ Pocket Gopher Geomys knoxjonesi 8.5 9 4.8 2 1.1

Plains Pocket Gopher Geomys bursarius 8.5 1,093 581 108 57

Texas Pocket Gopher Geomys personatus 12 1 0.8 - -

Botta's Pocket Gopher Thomomys bottae 5.6 5,030 1,761 211 74

Camas Pocket Gopher Thomomys bulbivorous 16 463 463 106 106

Northern Pocket Gopher Thomomys talpoides 3.7 2,847 658 127 29

Western Pocket Gopher Thomomys mazama 3.4 5 1.1 188 40

Arizona Pocket Mouse Perognathus amplus 0.5 - - 9 0.3

N. Giant (Gambian) 

 

Cricetomys gambianus 43 2 5.4 - -

Cactus Deermouse Peromyscus eremicus 1 - - 19 1.2

California Deermouse Peromyscus californicus 1.6 - - 2 0.2

Cotton Deemouse Peromyscus gossypinus 1.4 1 0.1 -

North American Deermouse Peromyscus maniculatus 1.0 211 13 5,527 345

White-footed Deermouse Peromyscus leucopus 0.85 18,720 995 7,307 388

Eastern Woodrat Neotoma floridana 10 2 1.3 1 0.6

Mexican Woodrat Neotoma mexicana 6.5 2 0.8 - -

White-throated Woodrat Neotoma albigula 7.5 - - 7 3.3

White-toothed Woodrat Neotoma leucodon 7.5 - - 24 11

Big-eared Woodrat Neotoma macrotis 11 - - 9 6.2

Dusky-footed Woodrat Neotoma fuscipes 11 - - 2 1.4

Bushy-tailed Woodrat Neotoma cinerea 14 8 7.0 2 1.8

Southern Red-backed Vole Myodes gapperi 1 - - 1 0.1

Sagebrush Vole Lemmiscus curtatus 1.0 576 36 - -

Gray-tailed Vole Microtus canicaudus 1.8 4,000 450 - -

Long-tailed Vole Microtus longicaudus 1.7 158 17 - -

Montane Vole Microtus montanus 2.0 999 125 604 76

Prairie Vole Microtus ochrogaster 1.3 7,095 576 37,105 3,015

Tundra Vole Microtus oeconomus 2.1 - - 12 1.6

Meadow Vole Microtus pennsylvanicus 1.8 13,414 1,509 12,985 1,461

Woodland (Pine) Vole Microtus pinetorum 1.0 4,466 279 11,944 747

Muskrat Ondatra zibethicus 48 2,261 1,199 3,597

House Mouse* Mus musculus 0.8 25,532 1,293 2,156 109

Brown (Norway) Rat* Rattus norvegicus 8.5 535 285 988 525

Pacific (Polynesian) Rat* Rattus exulans 2.2 2,331 321 54 7.4

Black Rat* Rattus rattus 7.5 6,562 3,076 4,381 2,054

North American Porcupine Erethizon dorsatum 304 243 4,617 165 3,135

Nutria* Myocastor coypus 280 1,981 36,785 1,776 31,080

Desmarest's Hutia Capromys pilorides 288 77 1,386 1 18

North American Pika Ochotona princeps 5.2 - - 1 0.3

Brush Rabbit Sylvilagus bachmani 24 - - 1 1.5

Eastern Cottontail^ Sylvilagus floridanus 48 1,169 3,507 1,483 4,449

Mountain Cottontail Sylvilagus nuttallii 35 78 171 12 26

Desert Cottontail Sylvilagus audubonii 32 6,232 12,464 3,488 6,976

Swamp Rabbit Sylvilagus aquaticus 77 4 19 19 91

Feral (European) Rabbit* Oryctolagus cuniculus 136 46 391 11 94

Snowshoe Hare Lepus americanus 24 - - 2 3.0

White-tailed Jackrabbit Lepus townsendii 120 44 330 97 728

Black-tailed Jackrabbit^ Lepus californicus 80 1,519 7,595 2,422 12,110

TOTAL 82 Species 387,366 1,786,309 368,971 1,733,224

Table A4. The annual average number of other mammals killed by WS in WDM between FY11 

and FY15 and FY16 and FY20 throughout the United States and its territories (only animals with 

an annual average take of 0.5 or more included) and the weight of their carcasses.

OTHER MAMMALS

Ave Annual FY11-FY15 FY16-FY20
43

Species Scientific Name Weight Killed Total Wt Killed Total Wt 

Nine-banded Armadillo Dasypus novemcinctus 200 277 3,463 491 6,138

Patas Monkey* Erythrocebus patas 333 221 4,600 13 271

Rhesus Monkey* Macaca mulatta 233 281 4,092 98 1,427

Elliot’s Short-tailed Shrew Blarina hylophaga 0.60 1 0.04 1 0.04

Northern Short-tailed Shrew Blarina brevicauda 0.60 2 0.1 14 0.5

North American Least Shrew Cryptotis parva 0.20 14 0.2 9 0.1

Cinereus (Masked) Shrew Sorex cinereus 0.15 4 0.04 8 0.1

Vagrant Shrew Sorex vagrans 0.25 14 0.2 1 0.02

Star-nosed Mole Condylura cristata 2.0 - - 2 0.3

Eastern Mole Scalopus aquaticus 3.6 17 3.8 7 1.6

Coast Mole Scapanus orarius 2.0 19 2.4 - -

Townsend’s Mole Scapanus townsendii 5.0 17 5.3 2 0.6

Brazilian Free-tailed Bat Tadarida brasiliensis 0.50 3 0.1 5 0.2

Big Brown Bat Eptesicus fuscus 0.50 2 0.1 5 0.2

Eastern (Tri-colored) Bat Pipistrellus subflavus 0.17 1 0.01 - -

Cave Myotis Myotis velifer 0.30 - - 1 0.02

Little Brown Myotis Myotis lucifugus 0.30 3 0.1 13 0.2

Unidentified Bat Chiroptera (30 possible 0.25 8 0.1 - --

TOTAL 17 sp + 1 group 884 12,167 670 7,840

* Introduced Species

Table A5. The annual average number of landbirds killed by WS in WDM between FY11 and 

FY15 and FY16 and FY20 throughout the United States and its territories (only animals with an 

annual average take of 0.5 or more included) and the weight of their carcasses.

LANDBIRDS

Species Scientific Name Weight 

(oz)

Ave Annual FY11-FY15 FY16-FY20

Killed Total Wt Killed Total Wt 

Helmeted Guineafowl* Numida meleagris 48 1 3.0 3 9.0

Northern Bobwhite Colinus virginianus 6 - - 1 0.4

Gambel's Quail Callipepla gambelii 6 3 1.1 8 3.0

Wild Turkey^ Meleagris gallopavo 203 329 4,174 389 4,935

Sharp-tailed Grouse Tympanuchus 30 2 3.8 10 19

Gray Partridge* Perdix perdix 14 4 3.5 2 1.8

Ring-necked Pheasant* Phasianus colchicus 40 953 2,383 125 313

Indian Peafowl* Pavo cristatus 150 13 122 16 150

Gray Francolin* Francolinus 11 2,007 1,380 1,371 943

Black Francolin* Francolinus francolinus 16 1,868 1,868 1,006 1,006

Red Junglefowl* Gallus gallus 32 477 954 - -

- Feral Domestic Chicken* Gallus gallus domesticus 32 2,547 5,094 2,237 4,474

Chukar* Alectoris chukar 21 4 5.3 8 11

Erckel's Francolin* Francolinus erckelii 46 311 894 187 538

Rock Pigeon* Columba livia 9 94,752 53,298 69,489 39,088

Island Collared Dove* Streptopelia bitorquata 7 156 68 484 212

Eurasian Collared Dove* Streptopelia decaocto 7 3,660 1,601 2,604 1,139

Spotted Dove* Streptopelia chinensis 6 6,617 2,481 3,362 1,261

Zebra Dove* Geopelia striata 1.9 17,096 2,030 11,462 1,361

Common Ground Dove Columbina passerina 1.1 - - 26 1.8

White-winged Dove Zenaida asiatica 5 104 33 100 31

Zenaida Dove Zenaida aurita 4 - - 69 17

Mourning Dove^ Zenaida macroura 4.2 18,146 4,763 21,495 5,642

Smooth-billed Ani Crotophaga ani 3.7 - - 1 0.2

Greater Roadrunner Geococcyx californianus 13 5 4.1

Common Nighthawk Chordeiles minor 2.2 68 9.4 78 11

Lesser Nighthawk Chordeiles acutipennis 1.8 - - 1 0.1

Chimney Swift Chaetura pelagica 0.81 1 0.1 5 0.3

Black Vulture Coragyps atratus 70 4,773 20,882 9,700 42,438

Turkey Vulture Cathartes aura 64 1,541 6,164 1,363 5,452

Osprey Pandion haliaetus 56 66 231 119 417

White-tailed Kite Elanus leucurus 12 1 0.8 - -

Swallow-tailed Kite Elanoides forficatus 15 - - 3 2.8

Golden Eagle Aquila chrysaetos 160 2 20 1 10

Northern Harrier Circus cyaneus 15 142 133 123 115

Sharp-shinned Hawk Accipiter striatus 5 6 1.9 11 3.4

Cooper's Hawk Accipiter cooperii 16 42 42 79 79

Bald Eagle Haliaeetus leucocephalus 152 1 9.5 - -
44

Mississippi Kite Ictinia mississippiensis 10 91 57 129 81

Harris's Hawk Parabuteo unicinctus 321 2.0--

Red-shouldered Hawk Buteo lineatus 22 25 34 46 63

Broad-winged Hawk Buteo platypterus 141 0.9 10 8.8

Swainson's Hawk Buteo swainsoni 30 78 146 142 266

Red-tailed Hawk Buteo jamaicensis 38 1,117 2,653 1,669 3,964

Rough-legged Hawk Buteo lagopus 35 42 92 18 39

Ferruginous Hawk Buteo regalis 56 23 81 20 70

Barn Owl^ Tyto furcata 16 186 186 284 284

Great Horned Owl Bubo virginianus 50 18 56 40 125

Snowy Owl Bubo scandiacus 643 1214

Burrowing Owl Athene cunicularia51 0.34 1.3

Barred Owl Strix varia 263 4.93 4.9

Short-eared Owl Asio flammeus 12 12 9.0 13 9.8

Belted Kingfisher Megaceryle alcyon51 0.33 0.9

Acorn Woodpecker Melanerpes formicivorus 2.83 0.52 0.4

Gila Woodpecker Melanerpes uropygialis 2.3 68 9.8 121 17

Golden-fronted Woodpecker Melanerpes aurifrons 2.92 0.4--

Downy Woodpecker Picoides pubescens 0.952 0.1 11 0.7

Hairy Woodpecker Picoides villosus 2.31 0.1--

Northern Flicker Colaptes auratus 4.6 77 22 44 13

Pileated Woodpecker Dryocopus pileatus 101 0.6--

Crested Caracara Caracara cheriway 359 20 23 50

American Kestrel Falco sparverius 4.1 490 126 565 145

Merlin Falco columbarius 6.59 3.7 15 6.1

Peregrine Falcon Falco peregrinus 26--1 1.6

Prairie Falcon Falco mexicanus 26--1 1.6

Monk Parakeet* Myiopsitta monachus 3.53 0.72 0.4

Rose-ringed Parakeet* Psittacula krameri 4.1 697 179 281 72

Rosy-faced Lovebird Agapornis roseicollis1-- 132 8.3

Western Kingbird Tyrannus verticalis 1.4 346 30 420 37

Eastern Kingbird Tyrannus tyrannus 1.4 38 3.3 116 10

Gray Kingbird Tyrannus dominicensis 1.5-- 45 4.2

Scissor-tailed Flycatcher Tyrannus forficatus 1.5 151 14 83 7.8

Eastern Phoebe Sayornis phoebe 0.71 0.041 0.04

Say's Phoebe Sayornis saya 0.741 0.054 0.2

Loggerhead Shrike Lanius ludovicianus 1.7 16 1.73 0.3

Black Drongo* Dicrurus macrocercus 1.8--5 0.6

Steller's Jay Cyanocitta stelleri 3.7 47 11- --

Blue Jay Cyanocitta cristata31 0.25 0.9

California Scrub-Jay

> Aphelocoma californica

31 0.22 0.4

Woodhouse’s Scrub-Jay

> Aphelocoma woodhouseii

3--1 0.2

Black-billed Magpie Pica hudsonia6 371 139 647 247

American Crow Corvus brachyrhynchos 16 11,151 11,151 7,968 7,968

Fish Crow Corvus ossifragus 10 75 47 129 81

Common (Northern) Raven Corvus corax 42 9,640 25,305 9,182 24,103

Eurasian Skylark* Alauda arvensis or 1.4 597 52 732 64

Horned Lark Eremophila alpestris 1.1 2,109 145 1,371 94

Bank Swallow (Sand Martin) Riparia riparia 0.47 102 3.0 24 0.7

Tree Swallow Tachycineta bicolor 0.7 84 3.7 143 6.3

Violet-green Swallow Tachycineta thalassina 0.49--1 0.03

Purple Martin Progne subis2 56 7.0 83 10

Northern Rough-winged Stelgidopteryx serripennis 0.564 0.15 0.2

Barn Swallow Hirundo rustica 0.67 857 36 1,032 43

Cliff Swallow Petrochelidon pyrrhonota 0.74 2,370 110 1,695 78

Cave Swallow Petrochelidon fulva 0.53 84 2.8 12 0.4

Red-vented Bulbul* Pycnonotus cafer 1.5 1,033 97 531 50

Cedar Waxwing Bombycilla cedrorum 1.17 0.58 0.6

Gray Catbird Dumetella carolinensis 1.31 0.11 0.1

Pearly-eyed Thrasher Margarops fuscatus 2.5--7 1.1

Northern Mockingbird Mimus polyglottos 1.7 74 7.9 105 11

European Starling* Sturnus vulgaris 2.9 1,619,236 293,487 813,198 147,392

Common Myna* Acridotheres tristis 3.7 7,023 1,624 6,150 1,422

Common Hill Myna Gracula religiosa 7.5--1 0.5

Eastern Bluebird Sialia sialis 1.19 0.65 0.3

American Robin Turdus migratorius 2.7 272 46 529 89

African Silverbill* Euodice cantans 0.53 353 12 131 4.3

Java Sparrow* Padda oryzivora 0.9 7,335 413 7,023 395

Scaly-breasted Munia* Lonchura punctulata 0.49 19,969 612 12,731 390
45

Chestnut Munia * Lonchura atricapilla 0.46 26,781 770 17,028 490

Red Avadavat* Amandava amandava 0.25 1,179 18 164 2.6

Common Waxbill* Estrilda astrild 0.28 749 13 114 2.0

House Sparrow* Passer domesticus 1.0 6,760 423 8,584 537

Eurasian Tree Sparrow* Passer montanus 0.8 303 15 2,253 113

American Pipit Anthus rubescens 0.74 19 0.9 26 1.2

Gray-crowned Rosy-Finch Leucosticte tephrocotis 0.91 1 0.1 - -

House Finch^ Haemorhous mexicanus 0.74 3,194 148 1,884 87

Purple Finch Haemorhous purpureus 0.88 1 0.1 2 0.1

Pine Siskin Spinus pinus 0.53 - - 2 0.1

Lesser Goldfinch Spinus psaltria 0.33 1 0.02 9 0.2

American Goldfinch Spinus tristis 0.46 5 0.1 - -

Lapland Longspur Calcarius lapponicus 0.95 5 0.3 1 0.1

Snow Bunting Plectrophenax nivalis 1.5 13 1.2 2 0.2

Grasshopper Sparrow Ammodramus 0.6 4 0.2 1 0.04

Lark Bunting Calamospiza 1.3 355 29 95 7.7

Chipping Sparrow Spizella passerina 0.42 - - 2 0.1

Field Sparrow Spizella pusilla 0.44 3 0.1 7 0.2

Brewer’s Sparrow Spizella breweri 0.37 - - 1 0.02

Fox Sparrow Passerella iliaca 1.1 1 0.1 3 0.2

Dark-eyed Junco Junco hyemalis 0.67 3 0.1 1 0.04

White-crowned Sparrow Zonotrichia leucophrys 1 179 11 29 1.8

Savannah Sparrow Passerculus 0.7 66 2.9 18 0.8

Song Sparrow Melospiza melodia 0.7 - - 13 0.6

Lincoln's Sparrow Melospiza lincolnii 0.6 4 0.2 - -

California Towhee Melozone crissalis 1.5 17 1.6 2 0.2

Yellow-headed Blackbird Xanthocephalus 2.3 831 119 787 113

Bobolink Dolichonyx oryzivorus 1.5 5 0.5 8 0.8

Eastern Meadowlark^ Sturnella magna 3.4 1,198 255 1,468 312

Western Meadowlark^ Sturnella neglecta 3.2 1,013 202 1,081 216

Red-winged Blackbird Agelaius phoeniceus 1.8 476,632 53,621 472,460 53,152

Brown-headed Cowbird Molothrus ater 1.5 765,183 71,736 300,266 28,150

Rusty Blackbird Euphagus carolinus 0.21 - - 1 0.01

Brewer’s Blackbird Euphagus cyanocephalus 2.2 7,560 1,040 768 106

Common Grackle Quiscalus quiscula 4 126,191 31,548 78,525 19,631

Greater Antillean Grackle Quiscalus niger 3 65 12 95 18

Boat-tailed Grackle Quiscalus major 6.1 524 200 236 90

Great-tailed Grackle Quiscalus mexicanus 5.4 9,522 3,214 936 316

Northern Cardinal^ Cardinalis cardinalis 1.6 163 16 40 4.0

Dickcissel Spiza americana 0.95 1 0.1 7 0.4

Red-crested Cardinal* Paroaria coronata 1.5 4,006 376 1,465 137

Saffron Finch* Sicalis flaveola 0.63 8 0.3 178 7.0

TOTAL 148 Spp. + 1 Domestic 3,274,616 609,489 1,882,214 400,934

* Introduced Species ^Some population introduced/invasive

Table A6. The annual average number of waterbirds killed by WS in WDM between FY11 and 

FY15 and FY16 and FY20 throughout the United States and its territories (only animals with an 

annual average take of 0.5 or more included) and the weight of their carcasses.

WATERBIRDS

Species Scientific Name Weight 

(oz)

Annual Avg FY11-FY15 Annual Avg FY16-FY20

Killed Total Wt Killed Total Wt 

Black-bellied Whistling Duck Dendrocygna autumnalis 29 24 44 44 80

Brant Goose Branta bernicla 50 256 800 106 331

Canada Goose Branta canadensis 157 22,728 223,019 23,509 230,682

Cackling Goose Branta hutchinsii 56 10 35 39 137

Ross's Goose Chen rossii 43 1 2.7 - -

Snow Goose Chen caerulescens 102 28 179 37 236

Feral Graylag/Swan Goose * Anser anser/cygnoides 110 82 564 37 254

Greater White-fronted Goose Anser albifrons 77 42 202 42 202

Mute Swan* Cygnus olor 352 1,793 39,446 1,309 28,798

Trumpeter Swan1 Cygnus buccinator 368 1 23 5 115

Tundra Swan Cygnus columbianus 219 1 14 3 41

Egyptian Goose Alopochen aegyptiaca 44 - - 1 2.8
46

Feral Domestic Muscovy Cairina moschata 80 34 170 115 575

Wood Duck Aix sponsa 21 35 46 59 77

Cinnamon Teal Anas cyanoptera 14 12 11 17 15

Blue-winged Teal Anas discors 13 117 95 117 95

Northern Shoveler Anas clypeata 21 74 97 111 146

Gadwall Anas strepera 32 44 88 60 120

American Wigeon Anas americana 26 38 62 67 109

Mallard Anas platyrhynchos 38 2,515 5,973 2,280 5,415 - Feral Domestic Mallard* Anas platyrhynchos 80 209 1,045 136 680

Mottled Duck Anas fulvigula 35 23 50 27 59

American Black Duck Anas rubripes 42 42 110 20 53

Northern Pintail Anas acuta 29 35 63 33 60

Green-winged Teal Anas carolinensis 12 122 92 133 100

Canvasback Aythya valisineria 431 2.73 8.1

Redhead Aythya americana 37 13 30 11 25

Ring-necked Duck Aythya collaris 24 25 38 17 26

Greater Scaup Aythya marila 37 61 141 38 88

Lesser Scaup Aythya affinis 29 29 53 29 53

Common Eider Somateria mollissima 753 141 4.7

Harlequin Duck Histrionicus histrionicus 212 2.6--

Surf Scoter Melanitta perspicillata 343 6.4--

Long-tailed Duck Clangula hyemalis 266 9.8 11 18

Bufflehead Bucephala albeola 13 35 28 61 50

Common Goldeneye Bucephala clangula 308 155 9.4

Barrow's Goldeneye Bucephala islandica 30 14 267 13

Hooded Merganser Lophodytes cucullatus 22 37 51 42 58

Common Merganser Mergus merganser 54 47 159 47 159

Red-breasted Merganser Mergus serrator 374 9.33 6.9

Ruddy Duck Oxyura jamaicensis 19 38 45 72 86

Pied-billed Grebe Podilymbus podiceps 16 23 23 15 15

Red-necked Grebe Podiceps grisegena 351 2.21 2.2

Horned Grebe Podiceps auritus 161 1.01 1.0

Eared (Black-necked) Grebe Podiceps nigricollis 112 1.44 2.8

Virginia Rail Rallus limicola3--1 0.2

Sora Porzana carolina 2.6--1 0.2

Common Gallinule Gallinula galeata 113 2.11 0.7

American Coot Fulica americana 22 2,966 4,078 547 752

Sandhill Crane Grus canadensis 143 21 188 40 358

Black-necked Stilt Himantopus mexicanus6 36 14 14 5.3

American Avocet Recurvirostra americana 114 2.83 2.1

American Oystercatcher Haematopus palliatus 22--1 1.4

Black-bellied Plover Pluvialis squatarola8 13 6.5 13 6.5

American Golden-Plover Pluvialis dominica5 22 6.91 0.3

Pacific Golden-Plover Pluvialis fulva 4.62 0.6 19 5.5

Killdeer Charadrius vociferus 3.3 2,101 433 3,119 643

Semipalmated Plover Charadrius semipalmatus 1.6 26 2.6 33 3.3

Wilson’s Plover Charadrius wilsonia 2.1--3 0.4

Upland Sandpiper Bartramia longicauda6 381 143 82 31

Whimbrel Numenius phaeopus 14 16 14 15 13

Long-billed Curlew Numenius americanus 21 22 29 10 13

Hudsonian Godwit Limosa haemastica 115 3.4--

Marbled Godwit Limosa fedoa 131 0.81 0.8

Sanderling Calidris alba 2.1 12 1.67 0.9

Dunlin Calidris alpina 2.1 53 7.08 1.1

Rock Sandpiper Calidris ptilocnemis 2.51 0.2--

Least Sandpiper Calidris minutilla 0.7 77 3.4 40 1.8

White-rumped Sandpiper Calidris fuscicollis 1.53 0.3--

Buff-breasted Sandpiper Calidris subruficollis 2.2--1 0.1

Pectoral Sandpiper Calidris melanotos 2.65 0.8 10 1.6

Semipalmated Sandpiper Calidris pusilla 0.88 16 0.95 0.3

Western Sandpiper Calidris mauri 0.917 0.4 30 1.7

Short-billed Dowitcher Limnodromus griseus 3.93 0.78 2.0

Long-billed Dowitcher Limnodromus 42 0.55 1.3

American Woodcock Scolopax minor71 0.4--

Wilson's Snipe Gallinago delicata 3.7 30 6.9 38 8.8

Spotted Sandpiper Actitis macularius 1.41 0.11 0.1

Solitary Sandpiper Tringa solitaria 1.81 0.14 0.5

Lesser Yellowlegs Tringa flavipes 2.8 21 3.7 14 2.5

Willet Tringa semipalmata8 10 5.07 3.5
47

Greater Yellowlegs Tringa melanoleuca 6 22 8.3 22 8.3

Wood Sandpiper Tringa stagnatilis 1.8 - 1 0.1

Red-necked Phalarope Phalaropus lobatus 1.2 - 4 0.3

Red-legged Kittiwake Rissa brevirostris 13 2 1.6 - -

Bonaparte's Gull Chroicocephalus 7 63 28 89 39

Laughing Gull Leucophaeus atricilla 11 5,264 3,619 4,719 3,244

Franklin's Gull Leucophaeus pipixcan 10 311 194 1,194 746

Heermann's Gull Larus heermanni 18 2 2.3 2 2.3

Short-billed Gull Larus brachyrhynchus 15 182 171 133 125

Ring-billed Gull Larus delawarensis 18 6,053 6,810 6,103 6,866

California Gull Larus californicus 21 1,762 2,313 1,454 1,908

Great Black-backed Gull Larus marinus 58 438 1,588 267 968

Glaucous-winged Gull Larus glaucescens 35 3,762 8,229 1,343 2,938

Western Gull Larus occidentalis 35 258 564 277 606

Glaucous Gull Larus hyperboreus 50 12 38 22 69

Herring Gull Larus smithsonianus 40 5,251 13,128 4,113 10,283

Iceland Gull Larus glaucoides 29 - - 1 1.8

Gull-billed Tern Gelochelidon nilotica 6 16 6.0 6 2.3

Caspian Tern Hydroprogne caspia 22 10 14 4 5.5

Royal Tern Thalasseus maximus 16 3 3.0 1 1.0

Sandwich Tern Thalasseus sandvicensis 7 3 1.3 - -

Common Tern Sterna hirundo 4.2 4 1.1 13 3.4

Forster's Tern Sterna forsteri 6 2 0.8 - -

Black Tern Chlidonias niger 2.2 41 5.6 10 1.4

Parasitic Jaeger Stercorarius parasiticus 16 1 1.0 5 5.0

Long-tailed Jaeger Stercorarius longicaudus 11 2 1.4 4 2.8

Parakeet Auklet Aethia psittacula 11 1 0.7 - -

Pacific Loon Gavia pacifica 59 1 3.7 2 7.4

Magnificent Frigatebird Fregata magnificens 53 - - 1 3.3

Anhinga Anhinga anhinga 43 17 46 20 54

Brandt's Cormorant Phalacrocorax 74 2 9.3 1 4.6

Pelagic Cormorant Phalacrocorax pelagicus 62 1 3.9 8 31

Double-crested Cormorant Phalacrocorax auritus 74 19,674 90,992 9,973 46,125

Neotropic Cormorant Phalacrocorax brasilianus 42 - - 7 18

American Bittern Botaurus lentiginosus 24 1 1.5 1 1.5

Yellow Bittern Ixobrychus sinensis 3.3 18 3.7 100 21

Great Blue Heron Ardea herodias 102 593 3,780 570 3,634

Great Egret Ardea alba 30 327 613 384 720

Snowy Egret Egretta thula 13 150 122 126 102

Little Blue Heron Egretta caerulea 12 16 12 48 36

Tricolored Heron Egretta tricolor 13 3 2.4 3 2.4

Cattle Egret^ Bubulcus ibis 12 5,607 4,205 5,992 4,494

Green Heron Butorides virescens 7 24 11 24 11

Black-crowned Night-Heron Nycticorax nycticorax 30 31 58 24 45

Yellow-crowned Night-Heron Nyctanassa violacea 24 33 50 57 86

White Ibis Eudocimus albus 24 140 210 207 311

Glossy Ibis Plegadis falcinellus 19 10 12 11 13

White-faced Ibis Plegadis chihi 21 10 13 10 13

Roseate Spoonbill Platalea ajaja 53 1 3.3 1 3.3

American White Pelican Pelecanus 262 50 819 61 999

Brown Pelican Pelecanus occidentalis 131 3 25 2 16

TOTAL 131 Sp. + 1 Domestic - 84,658 415,571 70,177 355,450

* Introduced Species ^Some populations introduced/invasive 1 Includes escaped trumpeter x whooper swans 

Table A7. The annual average number of reptiles, amphibians, and fish killed by WS in WDM 

between FY11 and FY15 and FY16 and FY20 throughout the United States and its territories 

(only animals with an annual average take of 0.5 or more included) and the weight of their 

carcasses. 

CROCADILIAN, TURTLE AND LIZARD SPECIES

Species Scientific Name Weight 

(oz)

Annual Avg FY11- Annual Avg FY16-

Killed Total Wt Killed Total Wt 

American Alligator^ Alligator mississippiensis 800 7 350 12 600

Spectacled Caiman* Caiman crocodilus 640 1 40 11 440
48

Eastern Box Turtle Terrapene carolina 32 - - 1 2.0

Pond (Yellow-bellied) Slider^ Trachemys scripta 64 33 132 41 164

Painted Turtle^ Chrysemys picta 14 9 7.9 10 8.8

River Cooter Pseudemys concinna 80 1 5.0 1 5.0

Texas Cooter Pseudemys texana 80 1 5.0 - -

Common Snapping Turtle^ Chelydra serpentina 300 241 4,519 356 6,675

Spiny Softshell^ Apalone spinifera 208 3 39 1 13

Unidentified Turtles Order Testudines (~24 200 2 25 1 13

Common Agama* Agama agama 14 - - 1,012 886

Black (Gray’s) Spinytail Ctenosaura similis 88 673 3,702 769 4,230

Green Iguana* Iguana iguana 88 1,057 5,814 1,941 10,676

Brown Basalisk* Basiliscus vittatus 14 11 9.6 55 48

Northern Curly-tailed Lizard* Leiocephalus carinatus 14 - - 33 29

Argentine Black-and-white Salvator merianae 167 1 10 1 10

Nile Monitor^ Varanus niloticus 240 2 30 - -

Brown Tree Snake* Boiga irregularis 16 21,491 21,491 18,651 18,651

Western Ratsnake Pantherophis obsoletus 44 - - 1 2.8

Eastern (Common) Lampropeltis getula 32 2 4.0 1 2.0

Gophersnake Pituophis catenifer 32 16 32 8 16

Northern Watersnake Nerodia sipedon 12 1 0.8 - -

Plains Gartersnake Thamnophis radix 12 6 4.5 - -

Copperhead Agkistrodon contortrix 16 1 1.0 - -

Cottonmouth Agkistrodon piscivorus 16 3 3.0 2 2.0

Western Diamondback Crotalus atrox 32 8 16 13 26

Western Rattlesnake Crotalus oreganus 5 - - 13 4.1

Red Diamond Rattlesnake Crotalus ruber 32 - - 1 2.0

Prairie Rattlesnake Crotalus viridis 16 8 8.0 2 2.0

Burmese Python* Python bivittatus 1600 - 2 200

Marine (Giant, Cane) Toad* Rhinella marina 32 60 120 5 10

American Bullfrog* Lithobates catesbeianus 18 3 3.4 - -

Longnose Gar Lepisosteus osseus 72 - - 1 4.5

Bowfin Amia calva 200 - - 1 13

Goldfish* Carassius auratus 60 112 420 - -

Grass Carp* Ctenopharyngodon idella 80 1 5.0 - -

Common Carp* Cyprinus carpio 80 26 130 12 60

Northern Pikeminnow Ptychocheilus oregonensis 32 48,501 97,002 59,302 118,604

Unidentified Suckers Catostomus spp. (3 48 40 120 - -

Channel Catfish^ Ictalurus punctatus 160 - - 1 10

Bluegill^ Lepomis macrochirus 16 350 350 - -

Smallmouth Bass^ Micropterus dolomieu 36 - - 47 106

Largemouth Bass^ Micropterus salmoides 48 1 3.0 2 6.0

Walleye^ Sander vitreus 128 - - 9 72

Unidentified Fish Unknown 60 - - 1 3.8

TOTAL 42 Species + 2 Group 72,672 134,401 82,320 161,595

* Introduced Species ^Some introduced populations/invasive

Table A8. Weight of white-tailed deer harvested in 2015-2017 and road kills from insurance 

claims in State Fiscal Year 2018 (July 2017-June 2018) (QDMA 2019), and of the annual 

average waterfowl harvested by sportsmen for FY11-FY20 in the United States (USFWS 2012, 

2014, 2016, 2018, 2020).

WHITE-TAILED DEER HARVEST/ACCIDENTS

Species Scientific Name Est. Harvest Weight (oz) Total Wt (tons)

White-tailed Deer Harvest (2015-2017 Annual Average) 5,900,000 2,800 516,250

White-tailed Deer Car Collisions (July 2017-June 2018) 1,300,000 2,800 113,750

TOTAL 7,200,000 2,800 630,000

AVERAGE ANNUAL WATERFOWL HARVEST (FY11-FY20)

Greater White-fronted Goose Anser albifrons 264,463 77 636

Snow Goose Chen caerulescens 357,046 102 1138

Ross's Goose Chen rossii 56,316 43 76

Brant Branta bernicla 20,533 50 32

Cackling/Canada Goose Branta hutchinsii/canadensis 2,350,084 106 7785

Wood Duck Aix sponsa 1,151,441 21 756
49

Gadwall Anas strepera 1,488,431 32 1488

American Wigeon Anas americana 651,513 26 529

American Black Duck Anas rubripes 89,571 42 118

Mallard Anas platyrhynchos 3,667,402 38 4355

- Feral Domestic Mallard* Anas platyrhynchos 7,362 80 18

Mottled Duck Anas fulvigula 42,175 35 46

Blue-winged/Cinnamon Teal Anas discors/cyanoptera 1,076,970 13.5 454

Northern Shoveler Anas clypeata 683,647 21 449

Northern Pintail Anas acuta 527,500 29 478

Green-winged Teal Anas carolinensis 1,652,152 12 620

Canvasback Aythya valisineria 112,147 43 151

Redhead Aythya americana 240,085 37 278

Ring-necked Duck Aythya collaris 485,960 24 364

Greater Scaup Aythya marila 67,369 37 78

Lesser Scaup Aythya affinis 281,692 29 255

Common/King Eider Somateria millissima/spectabilis 11,146 75 26

Surf/Black/White-winged Scoter

Melanitta 

perspicillata/americana/deglandi

53,928 34 57

Long-tailed Duck Clangula hyemalis 29,227 26 24

Bufflehead Bucephala albeola 222,417 13 90

Common/Barrow’s Goldeneye Bucephala clangula/islandica 81,650 30 77

Hooded Merganser Lophodytes cucullatus 94,569 22 65

Common/Red-breasted Merganser Mergus merganser/serrator 33,288 46 48

Ruddy Duck Oxyura jamaicensis 41,733 19 25

TOTAL 35 sp. USFWS 2012/14/16/19/21 15,841,817 20,516