I would imagine their statement about "unlawful to - injection with any chemical not sold for the purpose of euthanizing animals" is related to the typical acetone
use by some for skunks, but possibly just to say you can't inject because you aren't a vet without a vet permitting you to do so.
But the inhalants are not listed in this section, meaning that though I know of several inhaled options including CO2 that most states would recognize, I don't see
where they explicitly say you can use chloroform, but as you say, they likewise aren't stating clearly you can't use it.
In its current form your regs are pretty much open to a warden or an ACO officer investigating a report by someone of illegal use of this chemical to interpret for themselves
if what you did was legal or not, though with a good lawyer it looks like the regs don't speak clearly enough that you couldn't work your way out of the issue if called to the
carpet for it.
I've been trained 4 times during a 10 year career with the feds. All of those trainings for chemical immobilization and euthanasia by multiple parties all of which know what your
average field scenario is, even in absence of drug availability or ability to use it without a vet as we nearly all fall into that category while in the field with an animal needing euthanasia,
chloroform has never ever been suggested or even discussed while all others have including CO2 and a couple of others.
Thats about all I'd need to know, along with the veterinarians I've asked about it specifically to know that I wouldn't want to utilize it, luckily I also don't need it with the work I do
being nearly 100% bats and birds.
They are leaving you folks open though to suggestion, I see your point as well and also know Dave's point is justified too as there are many many things about using a chemical like
this that could get folks in a bind, just depends on who answers the call so to speak when someone phones in or mentions to someone in passing that "my wildlife company used this
awesome technique where they knocked down the young skunks (or raccoons) with chloroform..."
Some folks won't even know that option exists, others will never think it would be illegal and others will immediately think that doesn't sound right... Open to suggestion and interpretation
isn't a place I like to live, or base my livelihood on, but I get that some folks are going to use it regardless of what is said unless specifically stated as illegal in their state for wildlife control work.