In February 2006, a 2-year-old dog named Jenna tugged on a smelly lure set out for coyotes on federal public lands in eastern Utah. The lure was part of an M-44, a cyanide trap used to kill coyotes and other native carnivores. When an animal tugs on the bait, a spring shoots a capsule containing sodium cyanide powder into the animal's mouth. Mixing with moisture, the cyanide turns into a deadly gas. Jenna asphyxiated from the cyanide in 90 seconds.

Jenna's owner, Sam Pollock, was returning from a rabbit-hunting trip when Jenna triggered the M-44. She died in Pollock's arms.

Distraught, Pollock carried Jenna's poisoned body two miles back to his truck so he could bury her at home.

Pollock later complained of a headache and a metallic taste in his mouth to a state agriculture agent who investigated the incident. Despite his secondary exposure to cyanide from the M-44, no action was taken against the U.S. agency that places M-44s on public lands, the Department of Agriculture's Wildlife Services, and no compensation was provided to Pollock.

Between 2004 and 2006, Wildlife Services killed 6,156,223 animals (including an average of 515 dogs and 1,143 cats per year) to protect agricultural interests — at an annual cost of $100 million. Most were killed with lethal poisons. Roughly 13,000 animals each year, or 1.6 animals per hour, were killed with sodium cyanide.

Compound 1080, a colorless, odorless substance also used in animal control, is banned in several countries and all but 11 U.S. states. Both sodium cyanide and Compound 1080 are biological warfare agents.

In a post 9/11 world, this Wildlife Services' program poses a national security hazard, not only to those who enjoy recreating on federal public lands, but to us all. In 2004, 2005 and 2006, the USDA Office of Inspector General released audits revealing that Wildlife Services was not in compliance with the Bioterrorism Preparedness and Response Act. In November 2007, Wildlife Services itself admitted that it had experienced a "wake of accidents" and announced that it was undertaking an internal self-examination of its national program — including its toxics programs.

Despite the prevailing myth, the economics of livestock production do not justify the risks predator poisons create for people, pets and wildlife. Wolves, grizzly bears and California condors protected under the Endangered Species Act have all been killed with these deadly poisons. In fact, tens of thousands of nontarget species are killed each year, including badgers, birds, bobcats, black bears and many more. Yet less than 1 percent of the U.S. cattle production in 2005 was killed by predators.

It is time for livestock growers to use effective nonlethal protection measures such as night penning, sheds, fences, guard animals and electronic scaring devices. Using poisons to manage wildlife is inhumane, unnecessary, unjustifiable and poses far too many dangers.

The Environmental Protection Agency is taking public comments on whether to ban sodium cyanide and Compound 1080 until March 5.

Wendy Keefover-Ring, M.A., is the carnivore protection director for WildEarth Guardians in Boulder, Colo.

Lisa Upson, J.D., is a wildlife advocate for Natural Resources Defense Council in Bozeman, Mont.