Download Impacts of Wild dogs, Foxes and Feral Pigs on

Wording for recommendation to have Sodium fluoroacetate permitted for use on
organic properties to manage wild dogs, foxes and feral pigs under emergency feral
animal management purposes and technical details on compound 1080 (sodium
fluoroacetate) and its use in Australia
Wording request for inclusion/amendment.
Permit the use of Sodium Fluoroacetate (1080) poison under the National Standard for the
control of introduced predators/feral animals, namely wild dogs, foxes, feral cats and feral
pigs, under emergency management situations in order to:
a) prevent animal welfare implications on livestock from predation and attack;
b) prevent biodiversity impacts from introduced predators through predation as well as
habitat degradation as a result of foraging in case of feral pigs;
c) Manage biosecurity risks associated with disease and parasites in livestock as a
consequence of unmanaged introduced predator populations;
d) Allow organic producers to adequately control declared feral animal populations
under relevant state and local legislative requirements.
Page 1 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Executive Summary
Implications for organic producers from introduced feral animals as a consequence of
not being permitted to use Sodium Fluoroacetate for emergency management
purposes.
• Organic properties are currently experiencing increased levels of predation on livestock due to
feral animal population’s particularly wild dogs, European Red foxes (foxes) and feral pigs.
Populations of these feral animal species fluctuate from year to year in response following these
favourable seasonal conditions. The increase in abundance in feral animal populations puts
livestock at significant risk of predation particularly young cattle and small livestock such as
sheep and goats.
 Lack of adequate pest control is generating significant animal welfare outcomes which are
contrary to the principles of organic livestock production. Feral pigs, wild dogs and foxes are
responsible for maiming and killing cattle, sheep and goats with many producers are concerned
that they cannot adequately protect their livestock from harm resulting in some organic
producers leaving the industry.
 The ability to use Sodium fluoroacetate (1080) for emergency pest animal control would
significantly reduce the negative animal welfare impacts on livestock due to attack and/or
predation by these introduced predators following these periods of increased predator
populations, control would not need to be continuous or on an annual basis and would be
delivered based on potential risk of predation ae part of an integrated feral animal control
program;
• These impacts are more pronounced in rangeland environments where the larger properties
cannot adequately control feral animal populations using the organically preferred but more
costly and time consuming methods such as trapping, fencing or and shooting. Other factors
limit the use of these tools in some states due to various state regulations and legislation such as
firearms laws and animal welfare regulations around 24hr trap checking times which is nearly
impossible on large range land properties ranging in size from 50,000ha to 10,000km2;
• Without the ability to adequately control these population increases, the organic producer will
inevitably suffer increased predation on livestock which will ultimately result in the maiming
and killing of significant number of livestock between seasons.
• The resulting treatment of injured animals as a result of attacks by feral animal’s only results in
the need to use veterinary products, if permitted, which then renders the animals unfit for use in
the organic market and therefore further reduces profit margins.
 Organic producers in each state have a legislative responsibility to adequately control declared
feral animal species on their property and therefore to prevent any impact on neighbouring
properties. The inability to use sodium fluoroacetate on organic properties is in some cases
preventing organic produces from meeting their legislative responsibilities for feral animal
control in their properties. Allowing the use of the toxin 1080 for the purpose of emergency pest
management once or twice a year would allow producers to meet these obligations.
Page 2 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
• In addition to the immediate loss of income and welfare impacts on livestock organic certified
producers are often persecuted by the wider community as they are seen as harbouring feral
animal populations which ultimately reinvade adjoining properties which have just controlled
their feral animal populations by participating in coordinated community control programmes.
• The angst and animosity towards organic certified producers in some parts of the country due to
inadequately controlled feral animal populations is a very real concern and often results in
mental health issues as owners, managers and their families often get ostracised from rural
communities.
• In addition to the negative welfare outcomes, failure to control wild dogs, fox and feral pig
populations on organic certified properties is also causing significant environmental degradation
as feral pigs, foxes, cats and wild dogs are all recognised by various state and the federal
governments as declared pest species which are known to threaten Australian wildlife species
through predation and habitat destruction.
 Wild dogs, foxes and feral pigs are all listed under the Environmental Protection and
Biodiversity Conservation Act 1999 (EPBC 2009) as threatening the existence of threatened
native animal, plant and floristic communities as a result of predation and habitat degradation.
• The potential impacts on the environment and biodiversity resulting from inadequately
controlled feral animals populations is also in contravention to the principles of organic
production – to promote and support biodiversity and environmental sustainability.
• There are also significant biosecurity concerns as a result of inadequately controlled feral animal
populations. All of the introduced pest animals species described here are known to harbour and
spread disease which drastically affect herd health as well as potentially human health.
Treatment of infected herds will once again result in the use of veterinary chemical or vaccines
but may also put the persons at danger of contracting these diseases.
• These risks are quite high particularly for those areas where producers use natural water points to
access domestic water supply. The risk of diseases such as leptospirosis (which causes Wheels’
disease in humans), Sparganosis and Q Fever are just a few.
•
Prevalence of larger number of feral animals are a major national concern in the case of a
biosecurity outbreak such as foot and mouth being a major concern.
What is 1080 and why is it important for feral animal management in Australia.
 Sodium fluoroacetate is the most target specific and environmentally sensitive toxin available for
feral animal control in Australia;
 About 40 species of endemic Australian plants produce fluoroacetate as a chemically mediated,
anti-herbivore defence strategy. Most are Gastrolobium spp in south-western Australia, which
contain up to 2600 mg 1080 /kg dry weight (up to 6500 mg 1080/kg in seeds). Such plants (two
species of Gastrolobium and Acacia georginae) also occur in northern Australia but are less
abundant, patchily distributed and only contain up to 180 mg/kg fluoroacetate.
Page 3 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
 Sodium fluoroacetate itself is not toxic and needs to be absorbed and converted in other
metabolic products which in turn before it become toxic, unlike other predator control toxins
such strychnine and cyanide.
 The sodium fluoroacetate used for feral animal control is nature identical and retains all of its
natural characteristics.
 As a simple monovalent anion, fluoroacetate would be expected to be mobile in the environment
and to be easily degraded. Available data confirm these expectations. Studies of the
environmental fate of fluoroacetate have confirmed that it is readily degraded in biologically
active systems, such as soils, surface waters and living organisms. Where 1080-bearing plants
occur, the presence of 1080 in soils and surface waters is negligible. The absence of significant
contamination is consistent with its ready degradation in soils and water.
 1080 is susceptible to microbial degradation, except under arid conditions when microbial
activity is low. The ready microbial degradation under moist conditions conducive to microbial
activity and the low treatment rates mean that significant leaching through soil is not expected to
occur.
 Meat baits are also detoxified by rainfall, and more so by blowfly larvae. If not taken, meat baits
are likely to remain lethally toxic to dogs and foxes for up to 8 weeks if not picked up after 7
days in accordance with state guidelines;
 General environmental exposure to 1080 from feral animal control programs is extremely low, as
overall application rates of 1080 are commonly much less than a gram per hectare. The use of
1080 for feral animal control programs does not lead to contamination of air, soil or water, its
dispersal in bait form represents a potential hazard to non-target animals that may take the baits.
 Comparisons cannot and should not be drawn between Sodium fluoroacetate use in NZ for
the control of possums and deer with Australian use patterns for the control of introduced
predators. Estimated usage of 1080 in 2002 in Australia was approximately 200kg per year
compared to four tonne used in NZ over the same period. The difference in use patterns
between the two countries is due to the different pest species and ecological and production
impacts they pose.
 Native animals, particularly those from the southwest corner of WA that have co-evolved in
close association with fluoroacetate-bearing vegetation, tend to have greater tolerance to 1080
than their counterparts from the eastern states of Australia. This tolerance is most pronounced in
herbivores but is also present in omnivores and carnivores. Some unadapted Australian
omnivores and carnivores (bandicoots and dasyurids) also appear to be less sensitive to
fluoroacetate than their placental counterparts.
 The introduced species identified here are all very susceptible to 1080 and as such relatively
small concentrations are used in baits for control purposes, much less required than for other
native non-target species.
Page 4 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
• The relatively cheap manufacturing cost of the product and effectiveness makes it the most cost
effective form of control for large scale regional control programs and smaller scale strategic
programs on farm.
• Given its target specificity it is readily used throughout the country to manage feral animals for
conservation and primary production outcomes.
•
Fluoroacetate is used widely throughout the country to manage feral pigs, foxes and wild dogs
for the protection of biodiversity assets and conservation. One example would be the Bridled
nail-tail wallabies in western Queensland, a species that wouldn’t currently exists in national
parks with adequate control of foxes, wild dogs and feral cats from within the two last known
locations of the species.
• Coordinated baiting programmes delivered and the appropriate scale, have been shown to
effectively reduced pest animal populations and promote biodiversity and threatened species
recovery.
Managing Non-target uptake
 Target specificity can be achieved in many ways given the mode of action and susceptibility of
different groups of mammals to the toxin;
 Adjusting the concentration of Fluoroacetate used in baits can immediately exclude some groups
of mammals and other non-target species
 By understanding the ecology and biology of the pest species being controlled we can further
modify target specificity of the control programmes by using different bait types for the species
being controlled, eg. Using meat baits for predatory species excludes non target herbivore
species
 Further refinement of baiting programmes can also achieve successful non target outcomes such
as targeting bait placement, burying or placing baits in known locations, using smaller amounts
of bait and being more strategic with their placement to enhance the chance of a bait take by the
target species.
 In other instances devices have been developed to prevent bait take by non-target species, such
as the Hog Hopper, which was developed by the IACRC to exclude non target animals from
accessing baits delivered for feral pig control.
 Further research and registration of new tools to minimise uptake of toxins/ baits by non target
animals are currently underway, however Fluoroacetate is still the key toxin that will be used in
these devices as no alternative toxins are registered for use in Australia at present
 The use of sodium fluoroacetate is heavily regulated by federal and state regulations and
guidelines to prevent accidental misuse and non-target impacts.
 Restrictions on who, where and when 1080 products can be used occur in each state.
Page 5 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
 Furthermore the Invasive Animals Cooperative Research Centre continues to work with research
and partner organisation to improve pest animal control techniques and develop best practice
management guidelines for their use.
In Summary
 Allowing the use of sodium fluoroacetate for the control of feral animal populations for
emergency situations will allow organically certified livestock producers to protect livestock
from harm and animal welfare implications resulting from predation, stress due the constant risk
of attack and predator born disease risks.
 Allowing the use of sodium fluoroacetate will also allow the protection of native animal species
from predation and disease, while limiting habitat degradation and environmental damage by
feral pigs. Therefore meeting there obligation under the organic principle to promote and protect
biodiversity and environmental values;
 The application of sodium fluoroacetate which is a nature identical product will only occur at
extremely small rates, approximately less than 1gram per hectare which is significantly less than
its occurrence in natural plant communities where fluoroacetate bearing plant communities exist;
 The nature identical characteristics of the toxin mean that it is the most environmentally sensitive
toxin available, readily diluting to nothing in water and digested by microorganisms in the soil.
As a consequence 1080 is broken down so rapidly in the environment that it is virtually
undetectable in soil, plant or animal material;
 Any risk associated with non-target uptake can be managed through current well established best
practice management procedures and protocols in addition to the relevant state regulations and
guidelines pertaining to use and training.
 Furthermore allowing the use of sodium fluoroacetate on organic farms will greatly enhance the
mental health of producers struggling with the stress of dealing with mauled and maimed
livestock when there intent for being organic is to provide a safe and stress free life for the
livestock they produce.
 Allowing organically certified livestock producers to control feral animals in emergency
situations with sodium fluoroacetate will ultimately see many current producers remain in the
industry but may also see the industry expand as other producers have the confidence that they
can manage stock attacks adequately in the future if they are permitted to use the sodium
fluoroacetate under specific circumstances.
Page 6 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Impacts of Wild dogs, Foxes and Feral Pigs on livestock production
and the environment
Impacts of introduced predators on agriculture, the environment and human health.
Feral animals cause considerable economic costs to Australian agricultural industries. The annual
agricultural losses due to pest animals were conservatively estimated to be $AUS284.9 million,
including $187.7 million in the beef industry, $71.3 million in wool, $20.0 million in lamb and $5.9
million in grain (Gong et al 2009). The loss to Australia’s agricultural industry from the species
being considered here are estimated at $48.5 Million for wild dogs, 21.2 million for foxes and 9.2
million for feral pigs. (Gong et al 2009).Predation by wild dogs can severely affect the sheep, cattle
and goat industries, and limit the location where small livestock enterprises can operate (Fleming et
al 2001). Economic losses are strongly associated with loss of livestock, harassment of livestock,
disease impacts, costs associated with direct control, and consequent changes in production methods
(McLeod 2004, Gong et al 2009).National production losses from wild dogs were conservatively
estimated in 2004 to be $32.4M to the cattle industry and $15.9M to the sheep industries with an
additional $18M in associated management costs (McLeod 2004). More recently, Gong et al. (2009)
estimated the annual total economic surplus losses for the sheep and beef industries at $21.9M and
$26.7M, respectively.
Similarly, production losses in Queensland were conservatively estimated in 2003 to be $18 m to
the cattle and sheep industries industry, with an additional $5.4 m in associated management costs
(Rural Management Partners 2004). The estimates for Queensland were updated in 2009 to be $24.9
m to the cattle industry, $16.9 m to the sheep and goat industries, $5.2 m associated with livestock
disease management, with an additional $19.9 m in associated management costs (Hewitt 2009).
Similar economic impacts are reported in other wild dog-affected jurisdictions.
Figure 1.
Inadequate wild dog management will result in poor animal welfare
outcomes and potential impacts on biodiversity across a range of landscapes and
organic production systems across Australia. The use of 1080 in a regulated and
emergency response approach can assist in mitigating these impacts.
Page 7 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Notwithstanding the varying economic assessments above, industry sectors have a reasonable basis
to assert that the Australia-wide impact of wild dogs on the cattle and sheep industries is in the
order of ‘hundreds of millions’ of dollars per year. The Northern Territory Cattlemen’s Association
(2012) stated that “an estimated 60,000 calves and young weaners were killed directly or were
maimed and died of secondary wounds and infection after dog attacks during 2011-2012 at a cost
of $80 mill ion”.
Figure 2.
The European Red Fox is a major threat to lamb and goat kid
production across the country and has been implicated as the cause of many mammal
extinctions on mainland Australia since its arrival in the 18th century. Baiting with
1080 is an extremely effective means of controlling foxes given their opportunistic
diet and scavenging behaviour
Lamb losses caused by fox predation are equally as damaging. Most of the fox’s mainland
distribution directly overlaps with sheep grazing land (Allen and Fleming 2004). Of 35 million
lambs that are marked (10 weeks old) in Australia, approximately 2% are taken by foxes (Saunders
et al 1997). This amounts to the annual sheep production loss of $17.50 million, excluding future
lost earnings from wool and genetic improvements (McLeod 2004). In areas without fox control,
36% of lambs were taken by foxes (Lugton 1993) severely impacting on the economic viability of
sheep producers in the study area.
Wild dogs and foxes often kill or attack animals that they do not intend to eat, and they often kill
more animals then they need to for food alone. This is called ‘surplus killing’ and is a common
behaviour of many predators around the world. The reasons why wild dogs and foxes do this are
unknown, but it may be related to learning and development, amusement, or their innate drive to
hunt. Wild dogs are ‘programmed’ to chase and kill things that run away, so many surplus killings
might occur simply because wild dogs see something fleeing. This is often what happens between
wild dogs and sheep and may result in the wounding and maiming of several animals during attack
on flocks of sheep. In many instances these wounded and maimed animals die in the paddock as a
result of trauma and shock with many having to be destroyed by producers due to their wounds.
Domestic cats often do the same thing around the home, killing wildlife not because they need to,
but because it is innate predator behaviour.
Page 8 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Figure 3
Wild dogs are often responsible for surplus killing of livestock and
native fauna. These events are more frequently in herding animals where large numbers
of individuals can be attack and mauled because they are bunched up together. Many
animals attacked die from stress and shock as a result of their injuries.
Feral pigs are estimated conservatively to cost the agricultural industry over $100 million per year,
through predation on lambs and damage to property and crops (Choquenot et al 1996, McLeod
2004)). Pigs are responsible for damage to a variety of industries. They reduce the yields of grain
crops (Benson 1980, Caley 1993), damage and consume pastures (Hone 1980), reduce yields of
sugar cane and some tropical fruits such as bananas, mangoes, pawpaw and lychees (McIlroy 1993),
damage netting fences, damage and pollute water sources (Tisdell 1982; O’Brien 1987) and prey
upon newborn lambs (Plant et al 1978; Pavlov et al 1981; Hone 1983; Choquenot 1993). Lamb
predation by feral pigs is estimated to range from 18.7% to 32% for the semi-arid rangelands but
may increase depending on seasonal conditions (Pavlov et al 1981; Plant et al 1978).
Page 9 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Managing these predatrors also has ecological benefits as foxes and wild dogs also threaten
biodiversity through predation and the spread of disease, such as hydatid worms. Predation by foxes
is recognised by the Australian Government as a Key Threatening Process in the schedules of the
Environment Protection and Biodiversity Conservation (EPBC) Act 1999. NSW Government has
also recognised predation by wild dogs as a Key Threatening Process for threatened species,
populations and communities in New South Wales including koalas and other small mammal
species. Hybridisation with wild dogs was also listed as an ongoing threat to the purity of the dingo
under this threatening process listing.
Predation by foxes is considered to be a threatening process for over 111 species of native fauna
with National and state level threat abatement plans in place to manage the impacts of foxes on
native species thought the delivery of strategic and coordinated control programs. The large
majority of the species threatened by fox predation are birds, mammals and reptiles as well as some
amphibians and ecological communities, including Malleefowl (Leipoa oceallata), Long-footed
Potoroo (Potorous longipes) and Loggerhead Turtle (Caretta caretta). Direct competition from
foxes can also threaten some species, such as quolls. Predation by wild dogs was recently listed as a
Key Threatening Process for threatened species, populations and communities in New South Wales
and is a known or potential threat to a variety of other native species elsewhere. There are presently
14 national-level recovery plans that identify wild dogs as a known or potential threat to some
native mammal, bird and reptile species under the national Environment Protection and Biodiversity
Conservation Act 1999, including the endangered Southern Brown Bandicoot, Northern Hairy
Nosed Wombat, Bridled Nail Tail Wallaby and the Hooded Plover.
The Environment Protection and Biodiversity Conservation Act 1999 and the feral pig threat
abatement plan, identify 40 threatened species are at risk of feral pig predation, habitat degradation,
competition and disease transmission. Habitat degradation is probably the most obvious form of
environmental damage caused by pigs. Feral pigs damage vegetation in a range of ways the most
obvious signs of damage is through the disturbance and digging of soils using their nose looking for
roots and small animals. The rooting behaviour of pigs has been linked to areas of high soil
moisture such as drainage lines and swampy areas (Hone 1988, 1995; Mitchell 1993) although it
occurs across their entire range depending on seasonal conditions. This rooting behaviour can
severely disrupt the composition of the soil microorganisms, and subsequent nutrient cycling.
Rooting can also disrupt the regeneration of plants, change the composition of the plant community,
and allow water erosion to occur in drainage areas where the soil has been severely disturbed. The
feral pig has also been implicated in the transmission of plant diseases such as rootrot fungus
(Phytophthora cinnamomi) and other plant pathogens. Feral pigs are known to consume numerous
native animals including earthworms, amphipods, centipedes, beetles and other arthropods, snails,
frogs, lizards, snakes, the eggs of freshwater crocodiles (Crocodylus johnstoni), turtles and their
eggs and small ground nesting birds and their eggs (Pullar 1950; Tisdell 1984; McIlroy 1990;
Mitchell 1993; Roberts et al 1996).
Controlling introduced predators in the form of wild dogs, foxes and feral pigs, means that these
environmental impacts can be mitigated or minimised and form part of biodiversity conservation as
well as livestock protection. Controlled and replicated field experiments have discovered that
populations of several native species increase quickly after the removal of foxes, usually by toxic
Page 10 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
baiting using compound 1080 (see Saunders et al 2010). This certainly is in line with one of the
principles of organic production: the protection, maintenance and enhancement of the environment.
Furthermore, not effectively managing these pests is contradictory to another of the principles of
organic production: animal and human welfare. The effects of stress and suffering of livestock need
to be minimised in accordance with the relevant Codes of Animal Welfare Practice as mentioned in
the National Standard. Introduced predators, can cause physical damage (eg bites and
environmental degradation) as well as stress to the livestock animals through predation attempts
and/or risks. Additionally, human welfare is negatively affected by these pest animals. Landholders
suffer from emotional distress from having to deal with killed and injured livestock (Hewitt 2009).
A report by ABARES in 2014 found that producers that were dealing with constant attacks on their
livestock by wild dogs suffered emotional and mental trauma similar to that experienced by
returned servicemen and survivors of major motor vehicle accidents (Wicks et al 2014). Therefore,
being able to control these animals with cost-effective and proven pest management measures
including the use of sodium Fluoroacetate (1080) means that the welfare of both animals/livestock
and humans/landholders will be enhanced.
Both animal and human welfare can be further enhanced by undertaking effective control of wild
dogs, foxes and feral pigs by reducing the disease risks and food safety issues posed by these feral
animals. Pest animals mentioned here, such as the fox, wild dog and pig, are known as vectors of
various endemic and exotic diseases that could seriously harm livestock, domestic animals, native
fauna and/or people (Henderson 2009). Recent research has found that wild dogs, including
dingoes, are definitive hosts of Neospora caninum, the parasite that causes neosporosis, a
reproductive disease responsible for abortion outbreaks in cattle herds in Australia and worldwide
(King et al 2010). This disease is estimated to cost the Australian beef and dairy industries in excess
of $110 million annually (Reichel and Ellis 2009).
Feral pigs can transmit various diseases, including leptospirosis, brucellosis, melioidosis,
tuberculosis, porcine parvovirus, sparganosis and other arbovirus (McLeod 2004). Feral pigs can
also transmit and act as reservoirs for exotic diseases, such as Foot and Mouth Disease (FMD) and
Japanese encephalitis (McLeod 2004). It is estimated that a year-long outbreak of FMD would
reduce revenue by more than $9 billion in Australia (Productivity Commission 2002). Recent
research has also found that domestic piggeries, especially free-range piggeries in a region with
high numbers of feral pigs, are subject to a significant biosecurity risk with a considerably high
exposure probability to Mycoplasma hyopneumoniae (via air) and Lawsonia intracellularis (via
direct contact of feral to domestic pigs) (Pearson 2012). Thus, managing disease/pathogen
transmission risks from these pest animals is essential to ensure the welfare of domestic/livestock
animals and humans/landholders/consumers.
Page 11 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Technical details on sodium fluoroacetate and its use in Australia
The origin of 1080 and its mode of action
Odourless and tasteless, 1080 (the structural formula: FCH2COONa; empirical formula:
C2H2FNaO2) is the sodium salt of fluoroacetic acid, chemically and toxicologically identical to the
naturally occurring fluoroacetic acid that exists in many native plants in Australia, Africa, South
America and India (Eason et al 2011). Around 40 species of Western Australian native plants
produce fluoroacetate as a “chemical” defence against overgrazing by herbivores (DAFWA 2012,
Eason et al 2011). Such plants include the genera Acacia, Gastrolobium and Oxylobium, some
species of which extend from southwest Western Australia up through the Northern Territory and
down into the central highlands of Queensland (Oliver et al 1977). As it is impractical to naturally
extract the toxin in sufficient quantities, 1080 used in vertebrate pest control is synthetically
produced/manufactured in the USA. Nonetheless, the active constituent is identical to the naturally
occurring chemical molecule, therefore the chemically synthesised sodium fluoroacetate used feral
animal control is a nature-identical input (DAFWA 2012; Saunders et al 1995).
Fluoroacetate itself is not actually a toxin. After ingestion fluoroacetate is metabolised in the
mitochondria of cells to fluorocitrate by a process known as a ‘lethal synthesis’. Fluorocitrate is a
potent inhibitor of the enzyme aconitase and acts to block a vital step in the citric acid or Krebs
cycle, which is the major energy-producing pathway in the body. When this cycle is blocked, the
cell ceases to function through lack of energy and citrate accumulates in the tissues and plasma
(Green 2004; Twigg et al 2009). This build-up of metabolites in conjunction with a lack of energy
production is what causes death in the target species. Each major animal group, such as reptiles,
mammals and birds, have different metabolic rates, meaning that they also vary in their ability to
convert fluoroacetate to fluorocitrate (Twigg et al 2009) resulting in varied resistance and
susceptibility to the toxin 1080 based on their digestive system and metabolism.
Native animals, particularly those from the southwest corner of WA that have co-evolved in close
association with fluoroacetate-bearing vegetation, tend to have greater tolerance to 1080 than their
counterparts from the eastern states of Australia. This tolerance is most pronounced in herbivores
but is also present in omnivores and carnivores. Some unadapted Australian omnivores and
carnivores (bandicoots and dasyurids) also appear to be less sensitive to fluoroacetate than their
placental counterparts. For example, spotted-tail quolls (LD50 = 1.85 mg/kg) are less sensitive to
1080 than feral cats (LD50 = 0.4 mg/kg). This probably reflects the lower basal metabolic rate of the
native marsupial species. This inherent tolerance to 1080 by Australian native animals and the
extreme sensitivity introduced placental predators such as cats, foxes and wild dogs, provides the
ability to use 1080 in a very target specific manner. By altering the dose rates and bait substrates
used we can limit the effects on non-target native species. For example the 6mg/kg dose used in
meat baits for wild dog control is insufficient to harm an eastern grey Kangaroo given their
tolerance to sodium fluoroacetate, however by placing the toxin in meat that is not palatable to that
species then we further reduce any risk of non-target impacts.
Page 12 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Environmental safety of 1080
Sodium Fluoroacetate, 1080, is the most target specific and environmentally sensitive toxin
available for predator control in Australia. In addition to the benefits in target specificity derived
from the tolerance of Australian Native fauna to 1080, the toxin itself is extremely environmentally
sensitive and will rapidly degrade in water and soil to form harmless by-products and does not
accumulate in the environment (Lien et al 1979; Eason et al 1992; Partfitt et al 1995; Saunders et al
1995; Eason and Wickstrom 2001; Green 2004; Twigg et al 2009). Although highly water-soluble,
1080 has high chemical stability, meaning that it is stable under normal environmental conditions
and that it is suitable to be used in baits (DAFWA 2012). The concentration of sodium fluoroacetate
in plants is far greater than that used for feral animal control in most cases. Most Gastrolobium spp.
in south-western Australia, contain up to 2600 mg 1080 /kg dry weight (up to 6500 mg 1080/kg in
seeds). Such plants (two species of Gastrolobium and Acacia georginae) also occur in northern
Australia but are less abundant, patchily distributed and only contain up to 180 mg/kg fluoroacetate.
General environmental exposure to 1080 from feral animal control programs is low as the total
amount used is small and overall application rates are low, generally no more than a few grams per
hectare, which is considerably less than the concentration per hectare in regions where
Gastrolobium spp occur (APVMA 2008). Even in areas with fluoroacetate-bearing plants (eg
Western Australia), which can have up to 550 g of fluoroacetate per ha, fluoroacetate does not
persist because of environmental degradation and dilution degradation (Twigg et al 2009).
Degradation of 1080 results from leaching by rain, defluorination by soil microorganisms (eg
Pseudomonas and Fusarium species) and conversion to non-toxic inorganic fluoride compounds
(Twigg and Socha 2001). Fusarium oxysporum, in particular, is the most efficient and prolific defluorinator of 1080 of all the microorganisms capable of detoxifying 1080 (Twigg and Socha 2001).
Such soil microorganisms tend to be more abundant (ie soil has greater defluorinating ability)
during or following periods of high rainfall (Twigg and Socha 2001). Leaching by rainfall causes a
significant detoxification especially during the early stages of weathering when baits are fresh and
biological decomposition is limited (see McIlroy et al 1988). Loss of toxicity means that baits can
lose an average of 64% of their initial loading of 1080 within four days of distribution (McIlroy et
al 1988). McIlroy et al (1988) indicated that maggots (Calliphoridae larvae) were responsible for
much greater loss of 1080 than rainfall during summer. When maggots are present, 1080 baits
remain toxic only for 6-13 days for a 25 kg dog (with most wild dogs weighing less than 20 kg),
which becomes shorter if baits are subjected to rain within 24 hours of distribution (McIlroy et al
1988). In general, 1080 wild dog baits typically contain 6 mg bait, which is well within the
observed defluorinating ability of the soil microflora in Australia, meaning that pest control
operations using 1080 are extremely unlikely to result in any long-term environmental
contamination (Twigg and Socha 2001). Under favourable conditions (ie 11-20°C and 8-15%
moisture), 1080 may be significantly defluorinated in one to two weeks (Eason and Wickstrom
2001). Moreover, 1080 baits are normally well spaced (>500 m) and approved users are encouraged
to pick baits up after seven days where possible, which also helps with its environmental safety
(Twigg and Socha 2001).
Regarding human safety in the use of 1080, the theoretical routes of human exposure to 1080 are
considered to be from:
Page 13 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard




Drinking contaminated water
Ingestion of toxic baits
Consumption of food contaminated by contact with bait
Inhalation of bait dust or contact with 1080 solution.
Eason et al (2011) stated that the most significant source of generic public exposure to 1080 is
contamination of surface water in public water supply catchments by aerially sown baits, because
the other routes are highly unlikely. For instance, 1080 is unlikely to be present in meat for human
consumption owing to its comparatively rapid elimination (Eason et al 2011). Jackson et al (2007)
also assured that there is no risk of 1080 poisoning to people using the current methods employed in
Australia as the quantity of 1080 contained in each bait does not constitute anywhere near the lethal
dose for humans (adult or child). Dilution and biodegradation are two means by which any 1080
present in water will be reduced to undetectable and toxicologically insignificant amounts (Eason et
al 2011). Substantial biodegradation can occur over the first 24 hours of 1080 entering water, but
the effect of dilution will be immediate and occur before significant biodegradation (Eason et al
2011). Even when maximum 80 baits were deliberately placed in study streams with greatest water
discharge, 1080 was detected only at very low concentrations for less than 12 hours, and no effects
of 1080 were detected on any of aquatic invertebrate species (see Eason et al 2011). Such 1080
concentrations in water are unlikely in the real world, because baiting along or in proximity to
waterways is prohibited by law. New Zealand most heavily uses 1080 in the world (eg four tonnes
of 1080 power annually in comparison to 200 kg in Australia) (Twigg et al 2009). Nonetheless,
their monitoring since 1990s has shown that there has been no evidence of significant or prolonged
1080 contamination of surface waters after aerial baiting operations in the country where 1080 is
most heavily used in the world (Eason et al 2011).
Non-target issues and their management
The natural occurrence of 1080 benefits its use in feral animal control programs. Some native fauna
have coevolved with toxic plants and developed tolerance to fluoroacetate, but introduced animals,
such as the fox and wild dog, are highly sensitive (Saunders et al 1995; DAFWA 2012, McIllroy
1986). In particular, 1080 is useful in Western Australia, where native species are 1080-tolerant
(Saunders et al 1995). Generally speaking, herbivores are the most 1080-tolerant and omnivorous
species are moderate in their tolerance (DAFWA 2012). Birds are generally moderate in their 1080sentitivity while most reptiles and amphibians are relatively resistant to the toxin (DAFWA 2012).
One of the main non target species impacted by 1080 baiting programs is domestic dogs (APVMA
2008). The review conducted into 1080 use by the APVMA (2008) found that most non target
deaths of domestic dogs were avoidable and in general were attributable to human error through
poor management practices and or a failure to restrain domestic dogs to their property of residence
during control programs despite comprehensive notifications process associated with the delivery of
those programs. It was also noted that roaming domestic dogs are also responsible for significant
impacts on livestock and wildlife and as such behave and are controlled as wild dogs.
In Australia, 1080 use is tightly regulated to minimise potential negative effects on non-target
species; prior notification of baiting and the erection of warning signs in baited areas are
compulsory in addition to distance restrictions (eg minimum distance away from a dwelling and
Page 14 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
water bodies) (APVMA 2008). Appendix 1 outlines the guidelines for use of 1080 products from
NSW. All states in Australia have similar guidelines in place and training requirements for users of
1080 products. Such tight regulations mean that potential risks to domestic dogs are preventable
(Twigg and Parker 2010). Carnivores, such as carnivorous marsupials and bandicoots, are also the
least tolerant to 1080, including the spotted-tailed quoll (Dasyurus maculatus) in eastern Australia
(Kortner and Watson 2005). Nevertheless, non-target exposure can be minimised by careful choice
of the bait type and placement and other strategies described below.
Another way to ensure target specificity is to develop or use baits which are highly attractive to the
target species but are less palatable to non-target species. An example is dried meat baits used for
fox control, which are less attractive to quolls (Saunders et al 1995). Fox baiting can also be
conducted relatively safely with specially-designed manufactured baits, such as Foxoff® baits,
because this type of bait is most often rejected by quolls when encountered (Fleming 1996; Kortner
et al 2003). To minimise exposure of larger species, such as the spotted-tail quoll, burying baits, for
instance, can minimise their exposure to 1080 significantly as they are less inclined to dig for food
than introduced canids (Saunders et al 1995; Thomson and Kok 2002; Glen and Dickman 2003).
Choosing ground-based baiting, rather than aerial-based baiting, can also ensure target-specific
control as it requires fewer baits than aerial baiting (Fleming 1996).
Nonetheless, large areas of Western Australia are baited from the air as native species in Western
Australia are most tolerant to 1080 (Saunders et al 2010). The pattern of bait placement can also
reduce bait encounter by non-target animals. For instance, wild dogs and foxes frequently travel
along roads or tracks (Fleming 1996; Meek and Saunders 2000), meaning that placing baits along
their travel paths may increase target-specificity of 1080 baiting. Additionally, using dyes or
chemical deterrent can diminish attractiveness of baits to non-target species; to date, 1080 baits are
normally dyed green to prevent access by birds (McIlroy 1986). With baits being buried and dyed
green, bait removal by birds such as crows (Corvidae) was rare despite considerable numbers of bait
nights (Fleming 1996). Having baits available only after dark can also minimise risks to birds by
making them not obvious or visible (McIlroy 1986; Thomson and Kok 2002). As a recommended
practice, removing any remaining baits after the operation can reduce risks to non-target species
(Saunders et al 2000).
Importantly, concerns regarding exposure of non-target species to 1080 are often related to their
‘sensitivity’ tested in laboratory environments and/or to bait removal. That is, the fate of bait after it
is removed in the field is not taken into account. The ‘sensitivity’ of an animal to a particular toxin,
such as 1080, refers to the quantity of toxin required to produce a lethal effect, usually expressed in
terms of the median lethal dose (LD50). The LD50 is a statistical estimate of the dose required to kill
50% of a test population (McIlroy 1981). Estimates of sensitivity are usually obtained under
laboratory conditions, meaning that the toxin is administered by oral gavage, rather than being
incorporated into a bait (Glen et al 2007). Additionally, conditions, such as ambient temperature,
diet and stress levels of animals, may differ between the laboratory and the field, meaning that
captive trials may not reflect the sensitivity of wild animals (Glen et al 2007; Twigg and Parker
2010). Moreover, the animal’s propensity to locate and consume poison baits is unknown in
laboratory experiments. Even if a non-target animal locates and removes a bait, such bait uptake or
removal does not necessarily mean bait consumption, meaning that the animal does not receive a
Page 15 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
lethal dose (Kortner et al 2003). Instead, the ‘susceptibility’ of non-target species to 1080 should be
considered, which takes into account factors such as the sensitivity of the species to 1080 and the
likelihood that they locate, consume and receive a lethal dose from toxic baits (APVMA 2008; Glen
et al 2007).
Spotted-tail quoll populations are the non-target animal of principal concern when meat baits are
used for canid control because of their rarity, sensitivity and dietary preferences (APVMA 2008).
Nonetheless, quolls are known to persist in areas with long ground and aerial baiting histories
(Fleming 1996; Kortner and Watson 2005). Three studies have now been undertaken in NSW to
investigate the impacts of aerial baiting with 1080 for wild dog control on populations of Spotted
tail Quoll two of which were in the New England region (Kortner and Watson 2005, Kortner 2007)
and the third was in southern Kosciusko both in NSW(Claridge and Mills 2007,). A total of 73
individual spotted tail quoll were captured during these three studies of which over a third were
found to have eaten baits containing 1080 with no observable detrimental impacts. The use of a
biological dye in the meat baits allowed researchers to see how often 1080 meat baits were ingested
by individual quoll with some ingesting all or part of up to 6 baits (Kortner and Watson 2005,
Kortner 2007, Claridge and Mills 2007). Further observation of radio collared animals in these trials
showed no observable impact on quoll populations even in areas with no previous aerial baiting
history.
Similarly, in Western Australia, no western quolls (Dasyurus geoffroii) that consumed 1080 sausage
baits died as a consequence (see Glen et al 2007). Even with a ‘replacement-baiting’ strategy (ie the
daily replacement of baits that had been removed by target animals until few or no baits are taken),
quolls rarely visited bait stations that used manufactured baits (nine visits in 6806 bait-nights)
despite that wild dogs, foxes and quolls all co-occurred at all baiting sites (Fleming 1996). In
southern Queensland, the mortality rate from 1080 baiting was very low, and the quoll population
remained numerically stable over a four-year period of baiting (see Glen et al 2007). Such low rate
of bait consumption by quolls reflects bait avoidance, which can be because 1080 is not tasteless or
odourless at least for some species (Eason and Wickstrom 2001; Kortner et al 2003). In summary,
previous baiting events had no significant short-term effect on the population of quoll being studied.
The effects of 1080 baits on other non-target native species, such as southern bush rats (Rattus
fuscipes assimilis) and brown antechinus (Antechinus stuartii) were also studied (eg Fenner et al
2009). These small mammals rarely consumed 1080 baits, meaning that there was negligible impact
of baiting on the non-target animals. Fenner et al (2009) argued that with the current maximum bait
rate (specified by relevant state agencies), non-target animals are unlikely to find enough baits to
affect their population size substantially. In South Australia, for instance, single baits are to be laid
on the ground at minimum intervals of 200-500 metres along trails, and a maximum of only 10 baits
per square kilometre is allowed for fox control to avoid potential non-target exposure and caching.
Movements of small mammals tend to be restricted to much smaller areas compared to introduced
canids, which suggests that the current bait density only exposes a small proportion of their overall
populations to baits (Fenner et al 2009). Furthermore, foxes are known to cache baits to secure food
when it is abundant (Saunders et al 1999), so minimising bait density (but sufficient enough for
them to take a lethal dose) prevents this caching behaviour. Although caching can potentially result
in bait uptake by non-targets, Jackson et al (2007) found that no non-target species removed radio-
Page 16 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
transmitted baits that were cached by foxes. Overall, no studies published to date have ever found
significant reductions in populations of non-target species following 1080 baiting (Glen et al 2007)
To ensure target-specific baiting, it is important to investigate the presence and frequency of
occurrence of non-target species in baiting areas using bait stations, remote camera traps and sand
plot monitoring techniques. After this prior monitoring, target-specific baiting can be conducted by
baiting where only pest activity has been confirmed with no non-target species occurrence.
Furthermore, baiting can be highly target-specific with an appropriate delivery method. In feral pig
control, for example, the use of a HogHopper™ can ensure highly target-specific baiting operations
by exploiting the unique feeding behaviour of feral pigs. The HogHopper™ is a metal hopper with
baits presented inside, which requires the nose structure and strength of a feral pig to lift the device
when trying to feed on the baits (see ACTA 2010). For canid control, the use of the Canid Pest
Ejector can be highly useful to deliver 1080 to the target animals as only larger species can pull a
lure with an enough upward pulling force to trigger the ejection of toxicant (Marks et al 2002).
Using the ejector also means that bait movement and caching by foxes is prevented. The Invasive
Animals CRC has submitted an application the Australian Pesticides and Veterinary Medicines
Authority to have the device registered for use nationally.
In addition to potential primary poisoning (from consuming baits) above, there is public concern
over the potential for secondary poisoning of non-target species (from scavenging poisoned
carcasses or vomitus). This is particularly the case when 1080 is used for feral pig baits, which
require higher doses of the toxin (e.g. 72mg of 1080 per 250g of PIGOUT® bait) (APVMA 2008).
Feral pigs are known to vomit, which was considered to provide a potential hazard to some nontarget animals (i.e. secondary poisoning) (Choquenot et al 1996). Studies, such as Twigg et al
(2005), found that vomiting did not often happen and that its occurrence did not compromise the
effectiveness of baiting because sufficient fluoroacetate had already been absorbed by the poisoned
pigs before this happened (O’Brien 1988; Twigg et al 2005). Cowled et al (2006), in contrast, found
a higher incidence of vomiting than Twigg et al (2005), but non-target animals (especially
scavengers such as C. coronoides) did not consume vomitus in their field trials. APVMA (2008)
reported that secondary poisoning risks in Australia appeared to be restricted to cats, dogs and
foxes. Furthermore, secondary poisoning risks are relatively low in general because of the rapid
metabolism of 1080 in living animals and the consequent low level of residues in tissues and organs
of poisoned animals’ carcasses (APVMA 2008). For instance, most 1080 is metabolised and
excreted within one (most mammals) to three (reptiles) days, meaning that 1080 does not persist or
accumulate in the food chain (Green 2004; Twigg et al 2009)
Benefits of 1080 use for conservation management purposes
Importantly, it should not be neglected that while there are non-target risks, which can be
preventable, benefits that wildlife populations receive from predator control far outweigh the
occasional deaths of non-target animals (Glen et al 2007). For instance, indices of fox and wild dog
activity dropped significantly after aerial baiting, but those of the spotted-tailed quoll showed a
highly significant increase, suggesting quolls having release from interference competition (Kortner
and Watson 2005). Furthermore, broad-scale fox baiting in Western Australia, known as ‘Western
Shield’, has had a positive effect on Western Australia’s native animals. This program has been
conducted since 1996, the largest and most successful conservation program ever undertaken in
Page 17 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Australia (DEC 2012). For instance, tammar wallaby (Macropus eugenii) and quenda (Isoodon
obesulus fusciventer) are no longer on Western Australia’s threatened species list owing to their
population recoveries (DEC 2012). In western NSW populations of rock wallabies and Mallee fowl
are also increasing following successful fox control (APVMA 2008). Additionally, high fledging
success in threatened shorebirds has been observed in coastal regions after fox control (APVMA
2008). These positive benefits of pest control must not be neglected when non-target issues are
addressed.
Animal welfare issues related to the use of 1080
Animal welfare of pest control programs is often questioned because toxins, such as 1080, disrupt
physiological processes in poisoned animals in inducing death. Lethal methods, such as toxic
baiting, evoke a wide range of emotions and ethical stances, and the assessment of animal welfare,
or ‘humaneness’, is always subjective (APVMA 2008; Twigg and Parker 2010). This means that
complete agreement on humaneness of a pest control method, such as toxic baiting, is unlikely to
ever be reached, but an acceptable middle ground needs to be found to maintain agricultural
production and biodiversity (Twigg and Parker 2010). In fact, pest control can result in an overall
gain in animal welfare outcomes from, for instance, decreased lamb predation by wild dogs and
foxes (Twigg and Parker 2010). Twigg and Parker (2010) offered scientific evidence-based
assessments of humaneness of 1080 and criticised previous papers that used inappropriate criteria to
judge humaneness of 1080, particularly Weaver (2006) and Shirley (2007).
First of all, ‘humaneness’ tends to be judged based on time from laboratory-based administration of
1080 to death (eg Sherley 2007). However, this approach is thought to be problematic because a
latent period, or the lag phase, associated with 1080 toxicity is not accounted for. The lag phase is
between the time when fluoroacetate is ingested and the appearance of first signs of poisoning,
during which there is minimal discomfort or pain to poisoned animals (Twigg and Parker 2010).
This means that time from 1080 administration to death overestimates the period during which
animal welfare may become compromised (Twigg and Parker 2010). Moreover, the terminal phase
of 1080 poisoning is controversial as researchers disagree with whether poisoned animals are likely
to experience levels of distress during this phase (Sherley 2007; Marks et al 2009; Twigg and
Parker 2010; Eason et al 2011). Twigg and Parker (2010) argued that during the terminal phase of
1080 poisoning, poisoned animals are unlikely to experience undue levels of distress because they
are hardly conscious or aware, although the appearance of convulsive muscle spasms looks
distressing to observers. These authors stressed that a more accurate estimate would be from the
time between overt signs of poisoning and the beginning of the terminal phase where discomfort or
pain could potentially be experienced. For example, the mean time from 1080 administration to
death in foxes was 310 min, but 205 min was a lag phase and around 40 min was spent in the
terminal phase, suggesting that the time in which the welfare of foxes could potentially be
compromised was approximately 80 min (Marks et al 2000), much less than laboratory-based
assessments. In contrast, Sherley (2007) argued that such unconscious state caused by central nerve
system disruption from fluorocitrate during the terminal phase should not be considered distressfree. Sherley (2007) does however acknowledge that the extensive CNS disruption in the late stages
of 1080 poisoning poses a dilemma as abnormal electrical activity in the brain makes judgements
regarding consciousness and perception difficult to make, and CNS involvement in the toxicoses
Page 18 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
may alter behavioural indicators of pain and distress. As the involvement of the CNS is progressive,
an assessment of humaneness thus becomes more difficult to make as poisoning progresses. The
final judgement on humaneness in Sherley (2007) is not in fact based the pain associated with 1080
toxicoses but rather on the number of symptoms exhibit to death based on Mason and Littin (2003)
describing a humane toxin as one which poses as few symptoms as possible before death. This
assumption is based not on the level of pain felt or exhibited by the individual and one must
question the validity of the conclusion as exhibiting a number of pain free symptoms leading to
death must be more human than suffering one of two excruciating symptoms for a short period of
time before death. Eason et al (2011) suggests that the benefits of baiting through the prevention of
predation and animal welfare impacts on livestock and native wildlife should outweigh the
perceived adverse effects of animal welfare considered here for the feral animals species involved.
Limitations of Alternative feral animal control techniques
Here, particular attention must be paid to the need of toxic baiting in managing pest animals costeffectively, such as the wild dog, foxes and feral pigs. There are relatively cheap and effective
biological control options available for rabbits, such as RHDV (rabbit haemorrhagic disease virus),
which is regarded as a ‘natural’ virus, a ‘beneficial’ organism, or ‘biological’ control by Australian
organic certifying organisations (eg ACO Standard 2010 Annex 1). In contrast, such cost-effective
biological control options do not exist for controls of other major pest animals, including wild dogs,
foxes and feral pigs. Currently, various lethal and non-lethal options are available to control these
introduced predators, including toxic baiting (using 1080, or sodium fluoroacetate), trapping,
shooting, den fumigation (for foxes), exclusion fencing and guard animals. Another potential
control method the Canid Pest Ejector is being considered for registration as a technique to control
foxes and wild dogs in Australia, using 1080. This method is considered to be highly target-specific,
and use of ejectors is currently permitted on New South Wales Department of Environment’s land
for vertebrate pest control. Of the control techniques available, ground baiting with baits containing
compound 1080 (sodium fluoroacetate) is an important technology for controlling wild dogs and
foxes (Saunders et al 1995). Importantly, baiting using 1080 is regarded as the most cost-effective
way of significantly reducing the pest numbers and the most suitable lethal technique (Saunders et
al 1995; Gentle 2005; Saunders et al 2010).
When comparing control techniques available for pest management, shooting is labour-intensive
and opportunistic, especially in low pest densities, and is ineffective at reducing populations
significantly in the longer term as rapid immigration can offset the control efforts (see Saunders et
al 2010). The cost of a typical baiting program using 1080 is around $5 per fox, but that of shooting
is around $40 to $72 per fox (McLeod et al 2007). Trapping is also considered inefficient and timeconsuming as it is labour and capital intensive, and it is recommended for use only in areas where
conventional means of control, such as shooting and baiting, cannot be used (Saunders et al 1995).
Moreover, both trapping and shooting are unsuitable for broad-scale control, which is often
desirable in pest management (Saunders et al 2010).
Non-lethal methods, such as fencing and use of guard animals, can exclude pest animals however
these methods are very much landscape specific and less effective in larger production settings. The
cost involved in establishing predator proof fences is prohibitive for large scale production
Page 19 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
properties. At a cost of approximately $6-8,000 per kilometre fencing is a limited option for small
scale organic livestock producers on small holdings. The cost to organic livestock producers on
larger properties or rangeland environments is prohibitive.
The use of guardian animals is also advocated by the IACRC as part of integrated management of
feral animals however their use often requires significant investment in time and training. The
effectiveness of guardian animals is also limited by landscape, property size and feral animals in the
region (IA CRC 2012). More often than not the success of guardian animals in protecting livestock
is often dependent on the reduction of predator densities by coordinated baiting programs in the
surrounding area.
Such consideration of costs of control and investment of time is important for primary producers
because costs of pest control can be a financial burden to producers; for instance, total costs of fox
control are estimated to be $16 million per year in Australia (Fleming et al 2006). Hence, access to,
and the ability to use, a cost-effective control measure, such as baiting with 1080, is important for
organic producers to reduce both significant agricultural losses and control costs, thereby gaining a
competitive advantage.
Overall conclusions on the evaluation of 1080 for inclusion in National Standard
Use of 1080 on organic-certified land is essential where feral animals are causing considerable
economic loss to producers and poses a significant animal welfare concern for livestock. The use of
1080 is requested for use in emergency management situations in order to mitigate these impacts. In
the event these impacts cannot be managed adequately then organic livestock producers will be
competitively disadvantaged and the loss in come from predation and disease so great that there will
be no benefit to being organically certified and as such they will pull out of the industry. This is
already happening within the industry at present.
Pest management improves the welfare of both animals and humans that suffer from feral animal
problems and contributes to disease risk management and food safety Successful pest control also
contributes to biodiversity conservation, as many pest animals including foxes, dogs and pigs are
key threatening processes to native wildlife and ecological communities.
1080 can be safely used for feral animal management purposes on organic properties for emergency
response purposes. Firstly, it is a chemically-synthesised nature identical product to fluoroacetate
found in natural plants across the globe and potential non-target risks in baiting operations can be
prevented by carefully choosing bait types, placement, delivery methods and timing. It is
biodegradable and does not accumulate in the environment and relevant state and national
guidelines for use further limit access and provide safeguards against misuse.
Page 20 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Additional Links:
APVMA Federal Government review of 1080 use in Australia
http://apvma.gov.au/sites/default/files/sodium-fluororacetate-1080-phase8-final-review-report.pdf
Australian State Guidelines and regulations for use of 1080.
http://www.depi.vic.gov.au/agriculture-and-food/farm-management/chemical-use/agriculturalchemical-use/bait-use-and-1080/directions-for-the-use-of-1080-pest-animal-bait-products-invictoria
http://www.epa.nsw.gov.au/pesticides/1080pcofactsheet.htm
https://www.daff.qld.gov.au/plants/weeds-pest-animals-ants/pest-animals/control-methods/baiting
http://www.animalcontrol.com.au/regulations.htm
http://www.pir.sa.gov.au/__data/assets/pdf_file/0007/154627/1080_Bait_for_the_Control_of_Foxes
_Directions_for_Use.pdf
https://www.agric.wa.gov.au/1080/bait-and-poison-directory-vertebrate-pests-western-australia
Information on Current best practice techniques for the control of feral animals in Australia
www.pestsmart.org.au
Page 21 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
References
Animal Control Technology Australia (ACTA) (2010). HogHopper™ - Responsible Feral Pig
Management. ACTA, Somerton, Victoria, Australia.
Allen LR and Fleming PJS (2004). Review of canid management in Australia for the protection of
livestock and wildlife – potential application to coyote management. Sheep & Goat
Research Journal 19: 97-104.
Australian Pesticides and Veterinary Medicines Authority (APVMA) (2008). The reconsideration
of registrations of products containing sodium fluoroacetate and approvals of their
associated labels. Review Findings - Technical Report, APVMA, Canberra, Australia,
Backholer JR (1986). A survey of landholders on the wild dog problem in eastern Victoria: a
preliminary analysis. Department of Conservation, Forest and Lands, Victoria, Australia.
Barrat J, Al-Qassab S, Reichel MP and Ellis JT (2008). The development and evaluation of a nested
PCR assay for detection of Neospora caninum and Hammondia heydorni in feral mouse
tissues. Molecular and Cellular Probes 22: 228-233.
Choquenot D, McIlroy J and Korn T (1996). Managing Vertebrate Pests: Feral Pigs. Bureau of
Rural Sciences and Australian Government Publishing Service, Canberra, Australia.
Choquenot D and Ruscoe W (1999). Assessing the effect of poisoning programs on the density of
non-target fauna: design and interpretation. New Zealand Journal of Ecology 23: 139-147.
Claridge AW and Mills DJ (2007). Aerial baiting for wild dogs has no observable impact on
spotted-tailed quolls (Dasyurus maculatus) in a rainshadow woodland. Wildlife Research
34: 116-124.
Coutts-Smith AJ, Mahon PS, Letnic M and Downey PO (2007). The threat posed by pest animals to
biodiversity in New South Wales. Invasive Animals Cooperative Research Centre, Canberra,
Australia.
Department of Agriculture and Food Western Australia (DAFWA) (2012). Code of Practice for the
Safe Use and Management of 1080 in Western Australia. Department of Health, Department
of Agriculture and Food and Department of Environment and Conservation, South Perth,
Australia.
Department of Employment, Economic Development and Innovation (DEED), Queensland
Government (2009). Toxin 1080: A guide to safe and responsible use of sodium
fluoroacetate in Queensland, DEEDI, Brisbane, Australia.
Department of Environment and Conservation (DEC), Western Australia (2012). Western Shield.
See http://www.dec.wa.gov.au/management-and-protection/programs/western-shield.html
(accessed 30/11/12).
Page 22 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Eason C, Miller A, Ogilvie S and Fairweather A (2011). An updated review of the toxicology and
ecotoxicology of sodium fluoroacetate (1080) in relation to its use as a pest control tool in
New Zealand. New Zealand Journal of Ecology 35: 1-20.
Eason CT, Wright GR and Fitzgerald H (1992). Sodium monofluoroacetate (1080) water-residue
analysis after large-scale possum control. New Zealand Journal of Ecology 16: 47-49.
Eason CT and Wickstrom M (2001). Vertebrate pesticides toxicology manual (poisons):
information on poisons used in New Zealand as vertebrate pesticides. Department of
Conservation Technical Series 23: 1-122.
Eldridge SR and Bryan R (1995). Dingo questionnaire survey June-November 1995. Parks and
Wildlife Commission, Alice Springs, Northern Territory, Australia.
Fenner S, Kortner G and Vernes K (2009). Aerial baiting with 1080 to control wild dogs does not
affect the populations of two common small mammal species. Wildlife Research 36: 528532.
Fleming PJS (1996). Ground-placed baits for the control of wild dogs: evaluation of a replacementbaiting strategy in north-eastern New South Wales. Wildlife Research 23: 729-740.
Fleming PJS, Allen LR, Lapidge SJ, Robley A, Saunders GR and Thomson PC (2006). A strategic
approach to mitigating the impacts of wild canids: proposed activities of the Invasive
Animals Cooperative Research Centre. Australian Journal of Experimental Agriculture 46:
753-762.
Gentle M (2005). Factors affecting the efficiency of fox (Vulpes vulpes) baiting practices on the
central tablelands of New South Wales. PhD Thesis, University of Sydney, Sydney,
Australia.
Gentle MN, Saunders GR and Dickman CR (2007). Persistence of sodium monofluoroacetate
(1080) in fox baits and implications for fox management in south-eastern Australia. Wildlife
Research 34: 325-333.
Glen AS and Dickman CR (2003). Monitoring bait removal in vertebrate pest control: a comparison
using track identification and remote photography. Wildlife Research 30: 29-33.
Glen AS, Gentle MN and Dickman CR (2007). Non-target impacts of poison baiting for predator
control in Australia. Mammal Review 37: 191-205.
Gong W, Sinden J, Braysher M and Jones R (2009). The economic impacts of vertebrate pests in
Australia. Invasive Animals Cooperative Research Centre, Canberra, Australia.
Gooneratne R, Eason CT, Milne LM, Arthur DG and Wickstrom M (2008). Acute and long-term
effects of exposure to sodium monofluoroacetate (1080) in sheep. Onderstepoort Journal of
Veterinary Research 75: 127-139.
Page 23 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Green W (2004). The use of 1080 for pest control – a discussion document. The Animal Health
Board and the Department of Conservation, Wellington, New Zealand.
Henderson WR (2009). Pathogens in invasive animals of Australia. Invasive Animals Cooperative
Research Centre, Canberra, Australia.
Hewitt L (2009). Major Economic Costs Associated with Wild Dogs in the Queensland Grazing
Industry, AgForce Queensland, Brisbane, Australia.
Invasive Animals Cooperative Research Centre (IA CRC) (2012). Tools and strategies for wild dog
management. PestSmart Toolkit Publication, IA CRC, Canberra, Australia.
Jackson J, Moro D, Mawson P, Lund M and Mellican A (2007). Bait uptake and caching by red
foxes and nontarget species in urban reserves. Journal of Wildlife Management 71: 11341140.
King JS, Slapeta J, Jenkins DJ, Al-Qassab SE, Ellis JT and Windsor PA (2010). Australian dingoes
are definitive hosts of Neospora caninum. International Journal for Parasitology 40: 945950.
Korn TJ and Livanos G (1986). The effect of dosing technique on the 1080 content of meat baits.
Australian Wildlife Research 13: 455-459.
Kortner G, Gresser S and Harden B (2003). Does fox baiting threaten the spotted-tailed quoll,
Dasyurus maculatus? Wildlife Research 30: 111-118.
Kortner G and Watson P (2005). The immediate impact of 1080 aerial baiting to control wild dogs
on a spotted-tailed quoll population. Wildlife Research 32: 673-680.
Kortner (2007) 1080 aerial baiting for the control of wild dogs and its impact on spotted-tailed quoll
(Dasyurus maculatus) populations in eastern Australia. Wildlife Research, 2007, 34, 48–53
Lugton IW (1993). Diet of red foxes (Vulpes vulpes) in south-west New South Wales, with
relevance to lamb predation. Australian Rangeland Journal 15: 39-47.
Marks CA, Gigliotti F and Busana F (2009). Assuring that 1080 toxicosis in the red fox (Vulpes
vulpes) is humane. II. Analgetic drugs produce better welfare outcomes. Wildlife Research
36: 98-105.
Marks CA, Gigliotti F and Busana F (2002). Estimated 1080 dose rate for the M-44 ejector for the
control of red foxes (Vulpes vulpes). Wildlife Research 29: 291-294.
Marks CA, Hackman C, Busana F and Gigliotti F (2000). Assuring that 1080 toxicosis in the red
fox (Vulpes vulpes) is humane: fluoroacetid acid (1080) and drug combinations. Wildlife
Research 27: 483-494.
Page 24 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Mason G and Littin KE 2003 The humaneness of rodent pest control. Animal Welfare 12: 1-37
McIlroy JC (1981). The sensitivity of Australian animals to 1080 poison I. Intraspecific variation
and factors affecting acute toxicity. Australian Wildlife Research: 369-383.
McIlroy JC (1986). The sensitivity of Australian animals to 1080 poison IX. Comparisons between
the major groups of animals, and the potential danger non-target species face from 1080
poisoning campaigns. Australian Wildlife Research 13: 39-48.
McIlroy JC, Gifford EJ and Carpenter SM (1988). The effect of rainfall and blowfly larvae on the
toxicity of 1080-treated meat baits used in poisoning campaigns against wild dogs.
Australian Wildlife Research 15: 473-483.
McLeod L, Saunders G, McLeod S and Walter M (2007). Effective implementation of regional fox
control programs. Final report to the Bureau of Rural Sciences, Department of Agriculture,
Fisheries and Forestry. New South Wales Department of Primary Industries, Orange,
Australia.
McLeod R (2004). Counting the Cost: Impact of Invasive Animals in Australia 2004. Cooperative
Research Centre for Pest Animal Control, Canberra, Australia.
Meek PD and Saunders G (2000). Home range and movement of foxes (Vulpes vulpes) in coastal
New South Wales, Australia. Wildlife Research 27: 663-668.
O’Brien PH (1988). The Toxicity of Sodium Monofluoroacetate (Compound 1080) to Captive Feral
Pigs, Sus Scrofa. Australian Wildlife Research 15: 163-170.
Oliver AJ, King DR and Mead RJ (1977). The evolution of resistance to fluoroacetate intoxication
in mammals. Search 8: 130-132.
Parfitt RL, Eason CT, Hoff H and Heng LK (1995). Sodium monofluoroacetate leaching through
soil. Bulletin of Environmental Contamination and Toxicology 55: 162-169.
Pearson HE (2012). Understanding and mitigating the risk of pathogen transmission from wild
animals to domestic pigs in Australia. PhD thesis, Faculty of Veterinary Science, the
University of Sydney, Sydney, Australia.
Productivity Commission (2002). Impact of a Foot and Mouth Disease Outbreak on Australia.
AusInfo, Canberra, Australia.
Reichel MP and Ellis JT (2009). Neospora caninum – how close are we to development of an
efficacious vaccine that prevents abortion in cattle. International Journal for Parasitology
29: 1173-1187.
Saunders GR, Greentree C and McLeod L (1997). Fox Predation: Impact and Management on
Agricultural Land and Associated Remnant Habitat, Final Report to the BRS, NSW
Department of Agriculture, Orange, New South Wales.
Page 25 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Saunders GR, Gentle MN and Dickman CR (2010). The impacts and management of foxes Vulpes
vulpes in Australia. Mammal Review 40: 181-211.
Saunders G, Kay B and McLeod L (1999). Caching of baits by foxes (Vulpes vulpes) on agricultural
lands. Wildlife Research 26: 335-340.
Sherley M (2007). Is sodium fluoroacetate (1080) a humane poison? Animal Welfare 16: 449-458.
Thomson PC and Kok NE (2002). The fate of dried meat baits laid for fox control: the effects of
bait presentation on take by foxes and non-target species, and on caching by foxes. Wildlife
Research 29: 371-377.
Twigg L, Lower T and Martin G (2005). Sodium fluoroacetate residues and carcasses degradation
of free-ranging feral pigs poisoned with 1080. Wildlife Research 32: 573-580.
Twigg L, Lowe T and Martin G (2009). 1080 – Characteristics and Use. Department of Agriculture
and Food Western Australia (DAFWA), Perth, Australia.
Twigg LE and Socha LV (2001). Defluorination of sodium monofluoroacetate by soil
microorganisms from central Australia. Soil Biology and Biochemistry 33: 227-234.
Twigg LE and Parker RW (2010). Is sodium fluoroacetate (1080) a humane poison? The influence
of mode of action, physiological effects, and target specificity. Animal Welfare 19: 249-263.
Weaver SA (2006). Chronic toxicity of 1080 and its implications for conservation management: A
New Zealand case study. Journal of Agricultural and Environmental Ethics 19: 367-389.
West P and Saunders G (2003). Pest animal survey 2002: an analysis of pest animal distribution
and abundance across NSW and the ACT. NSW Agriculture, Orange, Australia.
Wong DH, Kirkpatrick WE, Kinnear JE and King DR (1991). Defluorination of sodium
monofluoroacetate (1080) by microorganisms found in bait materials. Wildlife Research 18:
539-545.
Page 26 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Appendix 1 An Example of the stringent regulations and guidelines for use of Sodium
Fluoroacetate use in Australia. NSW Pest Control order for 1080 products to control
wild dogs.
Schedule 1
USE OF 1080 LIQUID CONCENTRATE AND 1080 BAIT PRODUCT FOR
CONTROL OF WILD DOGS
1. PRODUCTION OF 1080 WILD DOG BAIT
An Authorised Control Officer may produce 1080 bait material for the purpose of controlling
wild dogs, but only in accordance with the following conditions:
1.1 An Authorised Control Officer may use 1080 liquid concentrate products to produce 1080 bait
material. Where an Authorised Control Officer uses material to produce 1080 bait material, the
Authorised Control Officer must only use boneless red meat, offal (tongue, kidney and liver)
and manufactured sausage. Each red meat bait produced must weigh approximately two
hundred and fifty (250) grams prior to any drying process. Persons preparing 1080 bait material
must follow wild dog bait preparation instructions on the approved label of the 1080 liquid
concentrate product. When using the ACTA 1080 Concentrate product or PAKS 1080
Concentrate product all bait material, as indicated above, must be injected with 0.2ml of the
product per bait.
1.2 An Authorised Control Officer must not freeze any 1080 bait material produced as per condition
1.1.
2. USE OF CERTAIN 1080 WILD DOG BAIT PRODUCTS
2.1 A person authorised to use 1080 bait products under clause 9 of this Order must, when using
1080 bait products for the purpose of controlling wild dogs, only use the 1080 bait products
referred to in conditions 2.2 and 2.3.
2.2 A person authorised to use 1080 bait products under clause 9 of this Order may use any 1080
bait products produced by an Authorised Control Officer under condition 1.1 above for the
purpose of controlling wild dogs.
2.3 A person authorised to use 1080 bait products under clause 9 of this Order may use 1080
products that have been specifically manufactured for the control of wild dogs, are registered
by the APVMA and approved for the use of controlling wild dogs in NSW, such as Doggone
Wild Dog Bait (APVMA Product Registration Number 49384) and Paks DE-K9 1080 Wild
Dog Bait (APVMA Product Registration Number 60308) (and any other similar 1080 product
that is produced after the commencement of this Order for the purpose of controlling wild dogs.
Page 27 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
2.4 A person must not freeze any 1080 wild dog bait produced as per condition 1.1.
2.5 1080 bait material prepared under condition 1.1 above and 1080 bait products referred to in
condition 2.3 will henceforth be referred to as “1080 wild dog bait”.
3. POSSESSION OF 1080 WILD DOG BAIT
A person authorised to possess 1080 wild dog bait under clause 9 of this Order must only do so in
accordance with the following conditions:
3.1 An Authorised Control Officer may supply 1080 wild dog bait to a person authorised to possess
1080 wild dog bait. An Authorised Control Officer may conduct a risk assessment to determine
if it is appropriate to supply 1080 wild dog baits to a person. Risk assessment guidelines can be
found in the DII publication “Vertebrate Pest Control Manual”. If the Authorised Control
Officer makes a determination that it is not appropriate to supply a person with 1080 wild dog
baits then the Authorised Control Officer must not give any 1080 wild dog bait to that person.
The Authorised Control Officer may withhold 1080 wild dog baits, if, in the opinion of the
Authorised Control Officer, they are not satisfied that the 1080 wild dog baits will be used
safely or effectively by a person.
3.2 If an Authorised Control Officer withholds 1080 wild dog baits from a person, the officer must
record in a logbook or diary, the date, time and specific reasons for refusing to supply 1080
wild dog baits to a particular person.
3.3 An Authorised Control Officer must only supply 1080 wild dog baits in either a plastic bag
labeled in accordance with attachment 1 or in a container supplied by the manufacturer of an
APVMA registered 1080 wild dog bait product.
3.4 A person taking possession of 1080 wild dog baits must first complete and sign an indemnity or
consent/indemnity form for each property on which 1080 wild dog bait is intended to be used.
An Authorised Control Officer or an employee of an LHPA must give a copy of the indemnity
or consent/indemnity form to any person taking possession of 1080 wild dog baits.
3.5 An Authorised Control Officer must issue 1080 wild dog baits only to the landholder of the land
on which the 1080 wild dog baits are to be used, their authorised agent or a person under the
direct supervision of the Authorised Control Officer.
3.6 An Authorised Control Officer or an employee of an LHPA issuing 1080 wild dog baits must
give a copy of this pesticide control order with this Schedule to any person receiving 1080 wild
dog baits from them.
3.7 An Authorised Control Officer issuing 1080 wild dog baits must establish that the intended enduser for the 1080 wild dog baits holds a qualification that meets the requirements of this Order
before handing over 1080 wild dog baits. Where this cannot be established then 1080 wild dog
baits must not be supplied.
Page 28 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
3.8 All persons receiving 1080 wild dog baits from an Authorised Control Officer must only
temporarily possess and store 1080 wild dog baits. 1080 wild dog baits must be stored in a
lockable storage area away from children, animal food, foodstuffs, seed and fertiliser. Where
1080 wild dog bait is required to be placed in a refrigerator, the refrigerator must not be
concurrently used to store food and must be located in a lockable storage area. All 1080 bait
material for wild dog control must be used within seven (7) days. All unopened manufactured
and registered 1080 bait product (such as Doggone and DE-K9 product) must be returned to the
issuing Authorised Control Officer within one (1) month of completion of the baiting program.
All opened manufactured and registered 1080 bait product (such as Doggone and DE-K9
product) must be destroyed within one (1) month after completion of the baiting program, by
burial in accordance with condition 4.8 below.
3.9 All persons receiving 1080 wild dog baits from an Authorised Control Officer must store 1080
wild dog baits in either the labelled plastic bag supplied by the Authorised Control Officer
(labelled in accordance with attachment 1) or in a container supplied by the manufacturer of an
APVMA registered 1080 wild dog bait product.
4. DIRECTIONS FOR USE – GENERAL RESTRICTIONS
A person authorised to use 1080 wild dog bait under clause 9 of this Order must only do so in
accordance with the following general conditions:
4.1 A person in possession of 1080 wild dog baits must transport and store the 1080 wild dog baits
in such a way that other persons cannot access the 1080 wild dog baits. A person transporting
1080 wild dog baits must store the 1080 wild dog baits in a secure location of their vehicle
when transporting 1080 wild dog baits.
4.2 A person must not place the 1080 wild dog baits in a position accessible to children, livestock,
domestic animals or pets.
4.3 A person must not feed 1080 wild dog baits to non-target species.
4.4 A person must not apply 1080 wild dog baits to, or in, crops which are in mid to late
developmental stages. A person must not apply 1080 wild dog baits to, or in, crops if
application of 1080 wild dog baits is likely to lead to contamination of the crops.
4.5 A person must ensure that 1080 wild dog baits do not contaminate foodstuffs, or feed, for
human or non-target animal consumption.
4.6 A person must not use containers (including plastic bags) which have been used to contain 1080
wild dog baits for any other purpose and must dispose of such containers by burial or burning
as follows:
Page 29 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
4.6.1 Burial
Containers (including plastic bags) must be buried as follows:
(a) Containers must be triple rinsed or pressure rinsed;
(b) Empty rinsed containers must be broken, crushed or punctured and disposed of either at the
property where the 1080 wild dog baits were used, or at a site approved by the Authorised
Control Officer or in local authority landfill;
(c) Containers and rinsate must be buried in a pit and covered with at least five hundred (500) mm
of soil;
(d) The disposal pit must be specifically marked and set up for this purpose and clear of waterways
(permanent or ephemeral). .
4.6.2 Burning
Empty plastic bags must be burnt by open fire in accordance with an approval issued under
the Protection of the Environment Operations (Clean Air) Regulation 2002. A person that
disposes of plastic bags by way of burning must also comply with the following conditions:
(a) The amount of plastic bags burnt at any premises on any single day must not exceed one
hundred (100) bags without the prior written approval of the EPA.
(b) The burning of plastic bags must be carried out at least five hundred (500) metres from any
habitation.
(c) The burning of plastic bags must be carried out in accordance with any requirement of the Rural
Fires Act 1997 and the Fire Brigades Act 1989, as administered by the relevant local
authority and the NSW Fire Brigades.
(d) The open fire burning must not be carried out on a day subject to a no-burn notice declared by
the EPA under provisions of the Protection of the Environment Operations Act 1997.
(e) The burning of plastic bags must only be carried out in dry weather using such practicable
means as may be necessary to minimise visible smoke emissions causing air pollution.
4.7 A person must not pollute dams, rivers, streams, waterways or drains with 1080 wild dog baits
or used containers (including plastic bags). Pollution of waters is an offence under s 120 of the
Protection of the Environment Operations Act 1997.
4.8 At the end of any ground baiting program conducted in accordance with this Schedule, a person
using 1080 wild dog baits must make a reasonable effort to ensure that all untaken baits are
Page 30 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
collected and removed from baiting locations. All collected and unused 1080 wild dog baits
must be disposed of as soon as possible at the property where the 1080 wild dog baits were
used, or in the case of a coordinated baiting program, on a property or location identified and
agreed to by the Authorised Control Officer coordinating the program. All collected and unused
1080 wild dog baits must be buried in a disposal pit and must be buried under at least five
hundred (500) mm of soil. The disposal pit must be clear of waterways (permanent or
ephemeral) so as to not cause pollution of water in accordance with Part 5.3 of the Protection of
the Environment Operations Act 1997.
4.9 At the end of any baiting program coordinated by an Authorised Control Officer, an Authorised
Control Officer or a person under their supervision may dispose of 1080 wild dog baits on a
property or location identified for disposal by burying the 1080 wild dog baits at a depth of less
than 500mm of soil but only if the Authorised Control Officer has done a risk assessment and
implements control measures that are appropriate to minimise the risk to non-target animals
and the environment.
4.10 Ongoing baiting may be necessary in some instances to reduce the impacts of wild dogs on
native fauna. Such programs may be undertaken only if the risk to non-target species is low
(see also 11.0 Risk to Domestic Animals and 12.0 Risk to Environment and Wildlife).
5. DIRECTIONS FOR USE – DISTANCE RESTRICTIONS
A person authorised to use 1080 wild dog bait under clause 9 of this Order must only do so in
accordance with the following distance restrictions:
5.1. The minimum distances for the laying of 1080 wild dog baits have been set to minimise the risk
to people and to non-target animals. A person authorised to use 1080 wild dog baits must not
place 1080 wild dog baits where they can be washed into or contaminate surface or ground
waters. 1080 wild dog baits must not be laid in areas where distance restrictions cannot be met.
Other wild dog control methods must be used in those areas.
5.2 1080 wild dog baits must not be laid within close proximity to urban areas unless the baiting
program is planned in conjunction with, and has been approved by, an Authorised Control
Officer. A program approved under this condition must include strategies for minimising risk to
non-target animals. This condition applies to proposals for baiting in closely settled farming
areas or areas within four (4) kilometres of a village or any street.
5.3 Property Boundary:
5.3.1 Ground Baiting: 1080 wild dog baits must not be laid within five (5) metres from any property
boundary.
5.3.2 Aerial Baiting: 1080 wild dog baits must not be laid:
(a) within ten (10) metres from any property boundary by helicopter, or
Page 31 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
(b) within one hundred (100) metres from any property boundary when using a fixed winged
aircraft. Use of fixed winged aircraft is restricted to Western Division only.
5.3.3 Exemption for Group Baiting: Conditions 5.3.1 and 5.3.2 do not apply to the laying of 1080
wild dog baits as part of a group baiting program that has been planned by an Authorised
Control Officer and where that Officer has obtained written consent from the landholders
involved in the baiting program for the laying of the 1080 wild dog baits. This exemption
does not apply to property boundaries of landholders not involved in the baiting program.
5.4 Habitation:
5.4.1 Ground Baiting: 1080 wild dog baits must not be laid within five hundred (500) metres of a
habitation except:
(a) where a landholder uses 1080 wild dog baits on their own property, in which case the landholder
may lay the 1080 wild dog baits at a distance of less than five hundred (500) metres from their
own habitation. If a landholder lays 1080 wild dog baits less than one hundred and fifty (150)
metres from their own habitation then the landholder must dig a shallow hole and bury the
1080 wild dog baits.
(b) where an Authorised Control Officer plans a baiting program, in which case the 1080 wild dog
baits may be laid at less than 500 metres but no closer than 150 metres from a habitation,
subject to the following conditions:
(i) The Authorised Control Officer must undertake a risk assessment in accordance with the
provisions of the DII Vertebrate Pest Control Manual (as in force from time to time) and
determine that 1080 wild dog baits can be laid at distances of less than 500 metres but no
closer than 150 metres from a habitation;
(ii) Any baiting program planned by an Authorised Control Officer must include strategies for
minimising risk to non-target animals;
(iii) Any adjoining landholders must agree in writing to use or allow the use of 1080 wild dog baits
as part of a coordinated wild dog control program at distances of less than 500 metres but no
closer than 150 metres from a habitation on the landholder’s property;
(iv) Where an Authorised Control Officer implements a coordinated wild dog control program, they
must not implement the program UNLESS:
(1) ALL the landholders in the group are made aware of the hazardous nature of 1080 wild dog
baits in closely settled areas; AND
(2) EVERY landholder in the group signs an agreement that they:
(A) understand the hazards associated with the use of 1080 wild dog baits in closely settled areas;
AND
Page 32 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
(B) agree to allow 1080 wild dog baits to be laid on adjoining properties at distances of less than
500 metres but no closer than 150 metres from any habitation on their property in writing;
AND
(C) agree to allow implementation of a 1080 wild dog poisoning program and accept all
responsibility for any problems arising from the program; AND
(3) ALL the landholders of the outermost properties of the group abide by all the distance
requirements in relation to adjoining properties not covered by the group activity.
5.4.2 Aerial Baiting: 1080 wild dog baits must not be laid:
(a) within five hundred (500) metres of a habitation by helicopter, or
(b) within one thousand (1000) metres of a habitation by a fixed wing aircraft. Use of fixed winged
aircraft is restricted to the Western Division only.
5.5 Domestic Water Supply or Water Draw Point:
5.5.1 Ground Baiting: 1080 wild dog baits must not be laid within ten (10) metres of a domestic
water supply.
5.5.2 Aerial Baiting: 1080 wild dog baits must not be laid:
(a) within twenty (20) metres of a domestic water supply by helicopter, or
(b) within one hundred (100) metres of a domestic water supply by a fixed winged aircraft. Use of
fixed winged aircraft is restricted to the Western Division only.
6. PUBLIC NOTIFICATION
A person authorised to use 1080 wild dog bait under clause 9 of this Order must notify certain
persons of the use of 1080 wild dog baits in accordance with the following conditions:
6.1 A person must not lay any 1080 wild dog baits on any land unless the person has first given a
minimum of three (3) days notice of the date on which they will lay 1080 wild dog baits. This
notice must be given to the occupier, manager or authorised agent of every property which has
a property boundary within one (1) kilometre of a baiting location (“notification”).
6.2. The notification may be given by telephone, email, or in person, or, where this is not possible,
by mail (including letter box drop). If notification cannot be made by telephone, email,
personal contact or mail, or the number of persons to be notified is more than twenty five (25),
then notification may be made by advertisement in a local newspaper. Likewise for large group
baiting programs (more than 25 participants) organised or approved by an Authorised Control
Officer, notification may be via advertisement in a local newspaper.
Page 33 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
6.3 The use of 1080 wild dog baits may be conducted for longer than seven (7) days but must
commence within ten (10) days of notification otherwise further notification of intended baiting
is required.
6.4 Where baiting programs are ongoing notification must be given every six (6) months.
7. EMERGENCY BAITING (Ground application only)
A person authorised to use 1080 wild dog bait under clause 9 of this Order may undertake
emergency baiting, but only in accordance with the following conditions:
7.1 A person whose livestock are being attacked may lay 1080 wild dog baits (by way of ground
baiting only) without the need to comply with condition 6.1 (3-day prior neighbour
notification). A person who undertakes emergency baiting must, however, notify each
landholder whose property boundary lies within one (1) kilometre of a baiting location before
laying any 1080 wild dog baits. A person who undertakes emergency baiting may lay up to
fifty (50) 1080 wild dog baits but only with the prior approval of an Authorised Control
Officer.
7.2 A person who undertakes emergency baiting must comply with all requirements in relation to
the use of 1080 wild dog baits, except as provided for in condition 7.1.
8. 1080 POISONING NOTICES
A person authorised to use 1080 wild dog bait under clause 9 of this Order must erect notices
in accordance with the following conditions:
8.1 A person who uses 1080 wild dog baits must erect notices before laying 1080 wild dog baits on
any land. These notices must remain up for a minimum of four (4) weeks after the last day of
baiting. Notices must be placed:
(a) at every entry to the baiting location; and
(b) at the main entrance to a private property or holding where baiting is undertaken; and
(c) at up to five (5) kilometre intervals along all public thoroughfares which border or pass through
the baiting location.
8.2 The notices must specify the following:
(a) that 1080 wild dog baits are being laid on this property; and
(b) the dates on which 1080 wild dog baits are first laid or the dates between which baits will be
laid; and
(c) contact details of the person who will lay the 1080 wild dog baits; and
Page 34 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
(d) a warning that non-target animals may be affected.
8.3 Under the Pesticides Regulation 2009 (clauses 19 to 23) public authorities have additional
public notification obligations that must be complied with. There are also other notification
requirements in the Regulation.
8.4 1080 Poison Notices may be obtained from Authorised Control Officers.
9. GROUND BAITING WITH 1080 WILD DOG BAIT
A person authorised to use 1080 wild dog bait under clause 9 of this Order must only
undertake ground baiting in accordance with the following conditions:
9.1 A person who lays 1080 wild dog baits must:
(a) not lay more than four (4) 1080 wild dog baits per kilometre of trail or sixteen (16) baits per
hundred (100) hectares; and
(b) not lay more than fifty (50) 1080 wild dog baits on any one (1) property or holding unless the
baiting program is approved by an Authorised Control Officer; and
(c) lay the 1080 wild dog baits in such a way that any untaken 1080 wild dog baits can be found
readily and destroyed in accordance with condition 4.8.
9.2 1080 wild dog baits should be buried in a shallow hole and covered with soil. If practical, tether
the 1080 wild dog baits to a fence and mark the burial spot.
9.3 A person who lays 1080 wild dog baits on a property of less than one hundred (100) ha must
check the 1080 wild dog baits within five (5) days of laying the 1080 wild dog baits and must
collect any untaken 1080 wild dog baits within seven (7) days of laying the 1080 wild dog bait.
All untaken 1080 wild dog baits must be disposed of in accordance with condition 4.8. This
condition does not prevent a person from replacing 1080 wild dog baits that are taken for a
period of longer than seven (7) days where 1080 wild dog baits continue to be taken.
10. AERIAL BAITING WITH 1080 WILD DOG BAIT
A person authorised to use 1080 wild dog bait under clause 9 of this Order must only
undertake aerial baiting in accordance with the following conditions:
10.1 Aerial baiting should be restricted to areas where ground control is impractical and:
• where livestock losses are continuing; or
• where records indicate there is a high likelihood of stock losses; or
• where the impacts of wild dogs on any threatened species are likely to be significant.
Page 35 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
Approval for every aerial baiting program must be obtained from the Director-General of DII or his
or her delegate. Aerial baiting must be organised through either Wild Dog Control
Associations, the Wild Dog Destruction Board, LHPAs, DECCW or other NSW public
authorities. All programs involving aerial application of 1080 wild dog baits must comply
with the guidelines contained in the DII humane pest animal control codes of practice and
standard operating procedures and DII Vertebrate Pest Control Manual and require careful
planning and consultation. Your local LHPA has full details.
10.2 Notwithstanding any other condition contained in this Schedule, a person who undertakes
aerial baiting must only use red meat, manufactured sausage baits, Doggone Wild Dog Bait
(APVMA Product Registration Number 49384) or Paks DE-K9 1080 Wild Dog Bait
(APVMA Product Registration Number 60308) for aerial baiting.
Page 11 of 38
10.3 A pilot who operates an aircraft which is used to aerially apply 1080 wild dog baits must use
onboard GPS navigation equipment mounted in the pilot’s line of sight to navigate along
agreed flight paths. The GPS navigation equipment must be of the type that has a moving map
display with topographic features which provide accurate guidance to the pilot. The GPS
equipment must have full data logging capabilities and all flight paths must be preprogrammed into the GPS navigation equipment before commencement of 1080 wild dog
aerial baiting.
10.4 A pilot who operates an aircraft which is used to aerially apply 1080 wild dog baits must make
a record of the GPS flight path which includes the start and finish drop point data, for 1080
wild dog bait, for each aerial run. The record must be kept for a period of at least three (3)
years after the date on which the 1080 wild dog bait was aerially applied. A pilot must make
any records available to the EPA on request.
10.5 The employer or contractor of a pilot must ensure that a pilot of any aircraft used to aerially
apply 1080 wild dog baits complies with conditions 10.3 and 10.4.
10.6 A person coordinating or organising aerial baiting programs must ensure that pilots are given
digitised flight paths for all areas where 1080 wild dog baits are to be dropped from an aircraft
which is used to aerially apply 1080 wild dog baits.
10.7 A person on the aircraft that is responsible for dropping 1080 wild dog baits must not be given
the task of navigating the aircraft. A pilot is responsible for navigation and must ensure that
1080 wild dog baits are dropped along the agreed flight path.
10.8 A person who drops 1080 wild dog baits from an aircraft which is used to aerially apply 1080
wild dog baits must hold as a minimum the qualification specified in clause 9(2)(c)(iii)(A) of
this Order.
10.9 A person who drops 1080 wild dog baits from an aircraft which is used to aerially apply 1080
wild dog baits must not drop more than ten (10) 1080 wild dog baits per kilometre of agreed
Page 36 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard
flight path on any land in NSW unless the person is permitted to do otherwise under an
APVMA permit.
11. RISK TO DOMESTIC ANIMALS
11.1 A person who uses 1080 wild dog baits should avoid poisoning of domestic pets. As 1080 is
particularly lethal to domestic dogs, the person using the baits should advise neighbours to tie
up dogs and ensure they do not enter the baiting location during poisoning operations or to
muzzle dogs if paddocks have to be mustered after poisoning. In the event of accidental
poisoning seek immediate veterinary assistance.
12. RISK TO ENVIRONMENT AND WILDLIFE
12.1 A person who uses 1080 wild dog baits must not pollute streams, rivers or waterways with
1080 wild dog baits or plastic bags and containers that have held 1080 wild dog baits.
12.2 1080 wild dog baits may be toxic to some native wildlife. To the extent possible, the person
using the 1080 wild dog baits should time baiting programs for when non-target species are
least active or least susceptible.
12.3 To the extent possible, a person who uses 1080 wild dog baits should recover carcasses of
animals poisoned by 1080 wild dog baits and bury them in accordance with the disposal
instructions for 1080 wild dog baits in condition 4.8. Any incidents where there are
reasonable grounds to suspect that non-target animals may have been poisoned by 1080 wild
dog baits should be reported to the EPA.
Page 37 of 37
Addressing the criteria to evaluate compound 1080 for inclusion in National Standard