Here is the definitive answer taken from my email correspondence with WDFW:
Karen, it is illegal to fish for any Game Fish in freshwater with live fish as bait in Washington State, but this does not include critters such as worms, leeches, crawfish, salamanders, crickets, grasshoppers, and other (non-fish) aquatic animals found in the same body of water you are fishing. The intent of this bait rule is to avoid the spread of any aquatic species from one body of water where it might be indigenous, to another body of water where it may be classified as, or could become, invasive. This does not apply to marine areas (such as Puget Sound) during an open season, where live bait is a commonly used (and legal) practice. There have been no changes regarding the use of bait while fishing for Food Fish. Anglers can never use live fish as bait for Game Fish (see page 16), but this rule does not affect Food Fish species such as Salmon, Halibut, Ling Cod, Sturgeon, Bottomfish, etc. in saltwater.
During an open season, if you happen to catch something like Bass, Trout, Crappie, Catfish, Bluegill, Pumpkinseed, etc., you could cut that (dead) fish up to use as bait (in the same body of water where it was caught), but it would count towards your daily limit for that particular species – if it had one. The above information also applies to saltwater, meaning that you could catch something like Kelp Greenling to use as live bait for Ling Cod or Halibut, or catch Herring to use as live bait for salmon, but that Kelp Greenling or Herring would have to be counted as part of your daily limit for that individual species.
If you do not have a copy of the new 2014/2015 regulation pamphlet, you can respond with your surface mailing address and we would be happy to send one to you, or with your internet capability, you may view/download the WDFW online pamphlet at the following web address:
http://wdfw.wa.gov/fishing/regulations/" onclick="window.open(this.href);return false;.
Please make sure you check for emergency rule changes before you harvest as follows:
Fishing Rule Change Hotline at (360) 902-2500 Shellfish Rule Change Hotline at 1-866-880-5431 Or, try our searchable emergency rule link off our website at:
https://fortress.wa.gov/dfw/erules/efishrules/index.jsp" onclick="window.open(this.href);return false;
Additionally, for shellfish, make sure to call the Dept. of Health Marine Toxins PSP Hotline at 1-800-562-5632.
If you have further questions, please email again or call (360) 902-2700. Our Customer Service hours are 8:00 a.m. to 5:00 p.m., Monday through Friday.
We hope this information helps.
Sincerely,
Fish Program
Sent: Wednesday, June 11, 2014 6:36 PM
To: Fishing Regulations (DFW)
Subject: Game Fish Bait
Hi,
In a public forum there is a discussion as to if it is legal to take a piece of meat or eyeball from a game fish (perch, bass, etc) and use it as bait for another fish.
In past publications, I thought I read where this is not legal.
Is this referenced in the 2014 Regs and if so what page number and where? Thank you. KJKS