26 



Although this bill does not directly address the issue of humaneness, we be- 

 lieve one of the underlying rationales for its introduction was alleged brutality 

 in the harvest of fur seals. This issue has been met. 



The method of killing fur seals, a single blow on the fragile skull immediately 

 followed by sticking, has been criticized by many groups. The present killing 

 method fully conforms to the Humane Slaughter Act and compares favorably 

 with the methods used in slaughtering livestock. Over the years, questions con- 

 cerning killing methods have been raised not only by Government scientists, but 

 also by representatives of leading animal protection societies. However, after a 

 visit to the Pribilof Islands in 1968, Dr. Elizabeth Simpson of the World Federa- 

 tion for the Protection of Animals rei>orted : 



"In conclusion, I find that from my observation of herding and killing methods 

 and from post mortem findings, that the Pribilof fur seal harvest is at present 

 being carried out in a reasonably humane fashion, which could however be im- 

 proved by attention to a few details. The method of killing the 4 and 5 year old 

 fur seals, that of club'bing, is a primitive method, and one which is subject to 

 human error, but the safeguards of using only experienced men to do the clubbing, 

 of supervising them closiely, of limiting the length of time they work, of pay- 

 ment by time and not by piece, and the fact that the killing takes place on land 

 and at temperatures of about 50° F, appears to result in the method being used 

 effectively. The finding of only 1.9 percent unfractured skulls is a measure of this. 

 The fact that the skull of the immature seals harvested is relatively thin, in com- 

 parison with the enormous bony development of the occipital region of the ma- 

 ture bull, malies clubbing practicable. Of other methods of killing large numbers 

 of animals presently available, for example the captive bolt pistol, electrical stun- 

 ning and COz stunnning prior to sticking. I feel that, given the situation of the 

 fur seal harvest, and the safeguards presently applied to the method of clubbing, 

 followed by eflBcient sticking, this method is probably the best. Any method in- 

 volving more handling of the animals would, I feel, be a step in the wrong 

 direction." 



Notwithstanding our belief, based on available data, that clubbing is the most 

 humane method of killing fur seals, there was established in 1968 a Task Force 

 to examine alternative methods and to review all harvesting practices on St. 

 Paul Island of the Federal agency responsible for the management of the fur 

 seals. At that time the Federal agency concerned was the Bureau of Commercial 

 Fisheries in the Department of the Interior. (The Bureau of Commercial 

 Fisheries was abolished by Reorganization Plan No. 4 of 1970. The functions of 

 the Bureau of Commercial Fisheries are being carried on by the National Marine 

 Fisheries Service as part of the newly created National Oceanic and Atmospheric 

 Administration, Department of Commerce. ) The Task Force included representa- 

 tives from the former Bureau of Commercial Fisheries, the Bureau of Sport 

 Fisheries and Wildlife, the Universdty of Minnesota (National Science Founda- 

 tion nominee), the Humane Society of the United States, and the Department of 

 Agriculture. A representative of the International Society for the Protection of 

 Animals was present as an observer. 



Consideration was given to asphyxiation, electrocution, shooting, concussion 

 bolts, drugs and tranquilizers during the tests. At the conclusion of exploratory 

 studies, the Task Force reported that none of the alternative methods proposed 

 were then feasible for use in the fur seal harvest. In response to recommenda- 

 tions of the Task Force on driving conditions and animal stress, driving dis- 

 tances have been reduced by about 50 i^ercent, obstacles liave been removed from 

 drive paths and additional clubbers have been added to the crew. 



Research conducted in 1960 and 1970 by the Virginia Mason Foundation for 

 Medical Education and Research on the present and alternative killing methods 

 has confirmed earlier studies that the present method — a blow on the cranium 

 by a club, followed by immediate sticking of the heart and subsequent bleeding, 

 results in the most rapid death onset of all body tissues. Nevertheless, the De- 

 partment of Commerce is continuing its research efforts to develop alternative 

 means of killing the animals. Representatives of the American Veterinary Medi- 

 cal Association's Panel on Euthanasia observed the 1971 seal harvest on the 

 Pribilof Islands to evaluate present harvesting techniques in all their aspects and 

 to make recommendations as appropriate. Their report, a copy of which was sub- 

 mitted to the committee, states in part, "clubbing followed by exsanguination 

 constitutes painless, humane euthanasia." In addition, we are planning for new 

 contract research seeking other methods of conducting the harvest. 



Section 303 of the bill, in addition to establishing the National Seal Rookery 

 Preserve and Bird Sanctuary states that the native Aleuts should be given 



