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THE BIOLOCiC AND ECONOMIC ASSESSMENT OF

STRYCHNINE

STRYCHNINE SULFATE

1080/101)1

A report of the Strychnine, Strychnine Sulfate, 1080/1081 assessment team to the rebuttable presumption against registration of Strychnine, Strychnine Sulfate, 1080/1081

Submitted to the tnvironmental Protection Agency on March 7, 1977

UNITED STATES IN COOPERA TlON WITH TECHNICAL BULLETIN DEPARTMENT OF STATE AGRICULTURAL EXPERIMENT STATIONS NUMBER 16;16 AGRICULTURE COOPERATIVE EXTENSION SERVICE OTHER STATE AGENCIES DEPARTMENT OF AGRICULTURE OFFICE OF THE SECRETARY

WASHINGTON, D.C. 20250

March 7, 1977

Technical Services Division (WH-569) Office of Pes,ticide Programs U. S. Environmental Protection Agency 401 M Street, S. W., Room 401, E. Tower Washington, D. C. 20460

Re: OPP-.30000/8

Gentlemen:

Enclosed is the U. S. Department of Agriculture's (USDA) response to the U. S. Environmental Protection Agency's (EPA) Rebuttable Presumption Against Registration and Continued Registration of Certain Products, used on the Compounds 1080, 1081, strychnine and strychnine sulfate which appeared in the Federal Register on December 1, 1976.

To meet the March 7, 1977 deadline which EPA set as a 60-day extension of the initial timeframe indicated in the aforementioned Federal Register Notice, it was necessary to submit the response lacking annotation of references used by the Assessment Team. We will submit an updated version, including the reference citations, to EPA within two days of the receipt of this report.

Significant information pertaining to recent EPA/USDA rodent field tests exists in a final report that was not available to the Assessment Team prior to the March 7, 1977 deadline. We,therefore, request the opportunity to evaluate this report and submit to EPA our comments as an addendum to the March 7, 1977 response.

Sincerely,

For: ERRETT DECK Coordinator Office of Environmental Quality Activities

Enclosures ii PREFACE

This report is a joint project of the U.S. Department of Agriculture and the State Land-Grant Universities, and is the third in a series of reports recently prepared by a team of scientists from these organizations in order to provide sound, current scientific information on the benefits of, and exposure to, strychnine, strychnine sulfat~, sodium fluoroacetate (Compound 1080), and f1uoroacetamide (Compound 1081).

The report is a scientific presentation to be used in connection with other data as a portion of the total body of knowledge in a fina.l benefit/risk assessment under the Rebuttable Presumption Against Registration Process in connection with t he Federal Insecticide, Fungicide, and Roden ticide Act.

This report is a slightly edited version of the report submitted to the Environmental Protection Agency on March 7, 1977. The editing has been limited in order to maintain the accuracy of the information in the original report.

Sincere appreciation is extended to the Assessml.mt Team Members who gave so generously of their time in the development of information and in the preparation of the report.

Strychnine, Strychnine Sulfate, 1080, 1081 Assessment Team

John R. Wood Team Leader Animal and Plant Health Inspection Biologist Service. USDA, Hyattsville, Maryland

Samuel L. Beasom Wildlife New Mexico Dept. of Game and Fish Scientist Santa Fe, New Mexico

Margaret Breinholt Attorney Litigation Division, DGC, USDA Washington, D. C.

Glenn L. Crouch Wildlife Rocky Mountain Station, U.S. Forest Biologist Service, Fort Collins, Colorado

Samuel G. Gesell Entomologist Pennsylvania State University Extension University Park, Pennsylvania

Frank R. Henderson Wildlife Kansas State University Extension Manhattan, Kansas

Paul Levingston Program Pesticide Registration, California Supervisor Dept. of Agriculture, Sacramento, California

Clair E. Terrill Livestock Agricultural Research Service Specialist USDA, Beltsville, Maryland

iii CONTENTS

SUMMARY. v

I NTROfXJCTI (X\[ 1 ASSESSMENT 1EAM • 3

RISK OF EXRJSURE 10 HUMANS AND N:X-JT~T ANIM4LS 3

Forrrulation 3 Packaging 4 Methods of Use 4 Restrict ions • 5 Directions for Use 5 Commonly Recognized Use Patterns. 5

EMERGENCY 1REAThfENT - 1080 and 1081 • 8

Avai labi l ity of Pesticides. 8 Dose Likely to be Consumed. 8 Treatment of Poisoning Cases • 8 Ava i lab i l i ty of Emergency Trea tmen t 9 Working Group Conclusions an the Emergency Treatment Criterion 9

BENEFITS 9

CONCLUDING (X)WENTS 10

LITERATURE CITED • 12

SUPPORTING~FERENCES WI' CITED 22

Issued August 1980 iv SUMMARY

The presumption against registra­ there are no unreasonable adverse envi­ tion and continued registration of ronmental eff'ects, and such uses will rodenticide products containing strych­ accomplish the claims made about them. nine, strychnine sulfate, and Compounds 1080 and 1081 can be rebutted by avail­ The A. D. Little report and other able documen tation regarding the documen tation demonstrate that benefits products. from proper use of the pesticides exceed the risks involved in such uses. All four rodenticides can be highly toxic mammalian and avian pesticides. Because of the similarity in use patterns of these pesticides (except for The distribution of treated baits 1081) and the identical triggers used to is specific to target species and con­ issue the rebuttable presumption (except trols them effectively. Most of the for emergen.cy treatmen t for 1080 an d 1080 and strychnine are used on open 1081), the following comments will apply ranges and agricultural lands west of to both notices of rebuttable presump­ the Mississippi River. Compound 1081 is tions. used primarily in control of sewer rats. It is felt that inadequate assess­ It is contended that because of men t was given to t he various control their acute toxicity the compounds are procedures that are involved in the use too dangerous to mammals and birds, and of these pesticides under field condi­ that a significant number of nontarget tions. The population dynamics and kin­ species are adversely affected. The etics of both the target and non target Environmental Protection Agency (EPA) species are extremely complex and are further contends that factors supporting best understood following actual field the lack of emergency treatment are such experience. It would appear that the that the human victim will "inevitably information used may have been such that die if a 'fatal' dose en ters the blood­ it does not represent a full analysis. stream." Evidence is presented to rebut these conten tions. The suspension and cancellation of 1080, strychnine, and sodium cyanide, as The history of use of the compounds predacides, were based substantially on demonstrates that product labels and use the information in the Cain Report, the restrictions practically eliminate haz­ 1971 reviews of EPA, and the position ards to humans. If necessary, directions paper of the Environmental Defense Fund. for use can be revised to minimize On biological grounds, we question the effects on nontarget species. Based on adeq uacy of some of the information current use patterns, no endangered utilized in this action. species are likely to be adversely affected; and state restrictions provide The Working Group (of EPA) appears added protection to endangered species. to have relied rather heavily on intor­ mation from California. We do not find The known first aid treatments and that contrary evidence was addressed or supportive therapy and antidotes avail­ that any conclusions regarding the able for treatment of exposures to 1080, difference in evidence were reached. 1081, strychnine, and strychnine sulfate A draft environmental statement of are sufficient to protect human health February 8, 1972 on animal damage and meet regulatory requirements for control by the Bureau of Sport Fish­ registration and rereblstration. eries and Wildlife, Depay'tment of the Interior', does not corroborate the The available documen tation indi­ conclusions of the Cain Report and cates that when the four roden ticides serves to rebut the presumptions issued are used according- to label directions, by EPA against these compounds .•

v We do not find that the Working highly toxic materials can be stored in Group assessed these chemicals as an child-resistant con tainers. economically feasible method available to users to control their roden t For several years the Denver Wild­ problems adequately, particularly in life Research Center, Fish and Wildlife relation to the regulations requiring Service has developed techniques to data as outlined in the Guidelines tor provide the most specific and acceptable Registering Vertebrate Pesticides. It bait and baiting techniques for target is strongly felt that the more than 30 species. In addition the University of years' history of use of these compounds California, at Davis, has developed and coupled with the available information provided specitic directions tor use of on uses and the established effects of these pesticides. We were not able to these uses were not adequately consid­ determine whether this information was ered. This is particularly tr'ue when considered. one also considers the information that is required to be printed on each label The studies 01' Schitoskey and for every registered pesticide. Strych­ Hegdal appear to have been the major nine and 1080 have been the subjects of sources of information to support the Section 18 requests by various States. rebuttable presumptions against 1080 In these requests, considerable informa­ and 1081. Practical experiences of tion is required to permit proper the State of California mitigate the evaluation of the requests. We were not conclusions of S chitoskey and Hegdal. able to find where the Working Group For example, although the San Joaquin considered this information, even though kit tox is classified as an endangered it would have provided val.uable insight species, the fox appears to have into local needs. expanded to fill its entire range in California. As a result of the increase There are indications that the loss in its population numbers, the State of of these pesticides will result in California has requested the Department significant adverse economic impacts in of the Interior to declassify the kit the form of additional losses of fox as an endangered species. The agricultural commodities. Where these black-tooted ferret is also an endan­ pesticides are no longer permitted and gered species. Although there have been the pest problem continues, less effec­ no sightings of this animal for 3 years, tive control measures will have to be nevertheless in some States (e.g. South used. The alternate pesticides that Dakota) no treatments of 1080 or 1081 have been suggested as replacements also are allowed to control praIrIe dog have many of the same characteristics colonies if there is any indication of that are present in these RPAR'd the presence of black-tooted ferret. pesticides. Another endangered species is the The toxicity of strychnine, strych­ California condor, which depends to a nine sulfate, 1080, and 1081 has been large extent on highway-killed carrion known for some time. The position paper for its food. The condor's limited food does not establish that as a result supply, as well as its limited reproduc­ of this toxicity factor significant tion base, apparently is the explanation adverse effects actually have occurred for t he small number 01' condors. in local, regiona!, or national popula­ tions of nontarget species. Although Keywords: Strychnine, strychnine the toxicity of the material is sUlf'ate, Compound 1080, Compound 1081, important, the toxicity itself does not roden t control, roden ticide, rat con trol determine risk. This is exemplified in sewers, predacides, field rodent con­ by the regulation on occupational safety trol, predator control, vertebrate pest of the Occupational Safety and Health control, rodenticide bait, crop losses, Administration and the conclusion by the pesticide registration, RPAH., environ­ Consumer Product Safety Commission that mental exposure, human exposure. vi INTRODUCTION

The purpose of this report is to (2) In the case of a pesticide develop biological, exposure, and presumed against pursuant to the chronic economic information ,'elated to the uses toxicity criteria, "that when considered of strychnine, strychnine sulfate, 1080, with proposed widespread and commonly and 1081. recognized practices of use, the pesti­ cide will not concentrate, persis t or As indicated in the letter of accrue to levels in man or the environ­ transmittal (page ii) to the Environ­ ment likely to result in any significant mental Protection Agency (EPA), t.his chronic adverse effects"; or, information was provided in an original benefits assessment report (March 7, (3) In either case, that "the 1977) to EPA followin.g its issuance of a determination by the Agency that the rebutta.ble presumption against registra­ pesticide meets or exceeds any of the tion (RPAR) against these registered criteria for risk was in error." uses of strychnine, strychnine sulfate, 1080, and 1081. The regulations also provide that evidence may be submitted as to whether Title 40, 162.11, of the Code of the economic, social, and envir'onmental Federal Regulations for the Federal benefits of the use of the pesticide Insecticide, Fungicide and Rodenticide subject to the presumption outweigh the Act (FIFRA) as amended (86 Stat. 971, 89 risk of use. If the ri$k presumptions Stat. 751, 7 U.S.C. 136 etseq.) provides are not rebutted the Administrator (of that a rebuttable presumption against EPA) will consider the information in registration (RPAR) or reregistration determining the appropriate regulatory shall arise if the Environmental Protec­ action. tion Agency (EPA) determines that the pesticide meets or exceeds any of the In the Federal Register of December risk criteria relating to acute or 1, 1976, the Environmental Protec­ chronic toxic effects set forth in the tion Agency published the announcements Regulations (Section 162.11 (a)(3)). A of the rebuttable presumption against notice of RPAR is issued when the evi­ registration and continued registra­ dence ,.'elated to risk meets the criteria tion of certain products con taining set forth. strychnine, strychnine sulfate, Compound 1080 (sodium fluoroacetate) , and Com­ The RPAR may be rebutted by proving pound 1081 (fluoroace tamide) (56, 57). that: EPA has determined that these (1) In the case of a pesticide pesticides meet or exceed the cri­ presumed against pursuant to the acute teria set forth in 40 CFR 162.11 toxicity or lack of emergency treatmen t (a)(3). criteria, "that when considered with the formulation, packaging, method of An extension of time permitted use, and proposed restrictions on the in terested parties to submit commen ts to directions for use and widespread and the EPA up to the close of business on commonly recognized practices of use, March 7, 1977 (58,59). the anticipated exposure to an appli­ cator or user and to local, regional Pesticide products containing or national populations of nontarget strychnine or strychnine sulfate were organisms is not likely to result in determined, by EPA, to meet or exceed any significant adverse effects"; and, the cr"Ueria of acute toxicity hazards

1 to wildlife and the effects on nontarget the available toxicity data can reason­ organisms as follows: ably be applied to nontarget organisms.

Available toxicity data, use pat­ It is further stated that the terns, nonselectivity, and mode of extreme toxic nature of lOBO and 1081 action of strychnine and strychnine and the nature of most uses indicate sulfate clearly indicate that acutely that their use might reasonably be lethal residue levels in the form of an ticipated to result in significan t poisoned baits will be available to population reductions in non target exposed nontarget species. These com­ species. The absence of valid field pounds exhibit a narrow range of toxic evidence of such occurrences is doses among exposed animals. Therefore, acknowledged. the same toxic properties which account for the efficacy of these compounds AHhough there is no validated in kilLing target organisms win also evidence that the use of lOBO and 10Bl cause the deaths of nontarget organisms. has resulted in deaths of endangered Thus, the available toxicity data can species, the wOt'k of Schitoskey (146) be reasonably applied to nontarget is cited as experimental laboratory organisms. evidence that such deaths can reasonably be anticipated. EPA has determined that the placement of strychnine and strychnine The above statements are indicated sulfate in animal burrows will not in the announcement of the RPAR as result in significant exposure to non­ evidence that the criteria. for acute target species, Accordingly, products toxicity -- hazard to wildlif.2 and the containing strychnine and strychnine hazards to endangered species -- have sulfate which are registered for above been met or exceeded. ground use meet or exceed the cri­ teria for acute toxicity -- hazard to In the announcemen t it is also wildlife. indicated that no reasonably available but effective emergency treatment is The field studies of Howell and known for lOBO or 1081 in toxication. Wishart regarding the poisoning of This statemen t is based on: 1) One Canada geese were cited as support bait placement represents a lethal dose of the likeLihood of significant for humans; 2) once a sufficient amount populations of nontarget species (98). of 1080 or 10B1 is absorbed into the A study by Schitoskey on the secondary bloodstr'eam, the outcome is invariably hazard of three rodenticides to the fatal; 3) symptoms of lOBO or 1081 kit fox was presented as experimental poisoning may not occur until a fatal evidence suggesting that death of dose has already been absorbed in to endangered species can be anticipated the bloodstream; 4) the potentially (146). mo~t effective treatment for lOBO or 10B1 poisoning, monoacetin, is not Regarding lOBO and 10B1, the available in a pharmaceutical grade; and available toxicity data, use patterns, 5) although lOBO and 1081 are restricted nonselectivfty, and mode of action of to some extent, use around domestic lOBO and 1081 indicate that acutely dwellings is not specifically prohib­ Lethal residue levels in the form of ited, and has resulted in accidental poisoned baits will be available to child pOisoning. Pf particular concern exposed nontarget species. These com­ is the fact that the symptoms of 1080 pounds exhibit a narrow range toxic dose or 1081 poisoning may not occur until among exposed animals. Therefore, the a considerable amount of the poison same toxic properties that account for has already been absor'bed into the the efficacy of these compounds in bloodstream. Once a sufficient dose killing target species will also cause is absorbed, the outcome is invariably deaths of nontarget organisms. Thus, fatal.

2 The above statements are cited as information can be evaluated and uti­ evidence that the criteria regarding lized in arriving at decisions relative first aid have been met or exceeded. to the likely degree of risk that is actually present in the environment. For more detailed information the reader is directed to the Federal Regis­ Studies are underway regarding the ters that have been cited. Additional use of 1080 and strychnine for the con­ information may be obtained from the trol of certain ground-dwelling roden ts Environmental Protection Agency. (76,101,190). Although the results of these studies are not available for The issues raised by the rebuttable inclusion in this report, we believe presumptions against registration are that the information that will be gained compounded by the absence of hard data. will be beneficial to all who are Nevertheless, we believe that available interested in these problems.

ASSESSMENT TEAM

In response to the RPAR notice the U.S. Department of Agriculture. published in the Federal Registers, a Extensive use of published and unpub­ National Assessment Team for Strychnine, lished information was made and is Strychnine sulfate, 1080, and 1081 was cited in the appropriate places in assembled. The members of this team the report. In addition, other were chosen based on their expertise in published and unpublished informa­ the field of animal control. tion was consulted and many of these references, though not specifically The information presented in this cited in the report, are listed as report was developed by this group of supporting references. Coupled with knowledgeable experts from the State this information is the in-depth Land-Grant Colleges and Universities and knowledge of the members of the team.

RISK OF EXPOSURE TO HUMANS AND NONTARGET ANIMALS

The discussion follows the indi­ The grain bait is formulated with oat vidual categories of concern expressed grain that is especially cultivated by the Environmental Protection Agency because of the large size of the seed. in the position documen ts relating to The extra dimension allows it to be the presumptions raised against the rolled in to a flattened grain, which individual compounds (2,51,53,56,57, distorts the appearance and also allows 60,61,63,64). for better absorptkm of the technical pesticide combined with a fixative. Formulation Grain treated with 0.11% 1080 toxicant is used for open rangeland applications, The registered 1080 and 1081 roden­ and grain treated with 0.55% 1080 ticide formulations are of the following toxicant is used in forestry application general types: wet bait, grain, cab­ (118). By contrast, the level of zinc bage, paste, and coyote bait station. phosphide for rangeland application is 0.92%. These formulations were developed primarily by research conducted by the It less control is achieved, a Fish and Wildlife Service of the Depart­ longer bait exposure period is required ment of the Interior and the University to control the same population (49). of California at Davis, California (1,8, A second application may be required, 22,28,30,33). These formulations are making the compound more available considered as the most efficacious. to other susceptible species. Thus,

3 formulation is critical to the success Methods of Use of any rodent control program. The 1080 formulations are at near optimum as a The methods of use are controlled result of extensive research investiga­ to some extent by the target pest's tions and feedback from field use (4,6, acceptance or rejection of the treated 8,31,68,70,140,166,167,168,177). Fur­ bait( s) (10,12,19,30,52,115,129,145,148, ther investigations may result in better 150,160,184). Certain techniques, if formulations with less active ingredien t administratively required, will alter per unit of bait. the opportunity for exposure, and hence the risk, that triggered the rebuttable Risk depends upon exposure. If the presumption. In addition, these tech­ exposure is limited through proper niques will reduce the potential for placement, formulations, and so forth, effect on non target organisms (136,150, the risk will be limited and . the pesti­ 160,174,177) • cide will have little or no significant adverse effect on the environment (13, The roden ticide 1081 is used effec­ 30,38,39,72,73,74,99,102,136,152,186). tively in sewers for t he control of rats (14,17,21,81,185). Placement in Packaging tamper-proof boxes that are locked and have a baff7.e en trance effectively The review of the documentation restricts the t-'x;:wsure and subsequent accompanying the RPAR did not indicate risk. The physical location in the any comments regarding the packaging of sewers automatically reduces the oppor­ the pesticides. It will be beneficial tunity for exposure to nontarget to review the present packaging for the animals. This use would certainly qual­ registered pesticides under discussion. ify for restrictions to use by certified The goal should be to minimize exposure, app licators. both to the finished bait and the tech­ nical materials. During transport, the The roden ticides 1080 and strych­ materials should be in tamper-resistant nine have been used effectively in the and leakproof containers. All contain­ control of r~dents in agricultural ers designed for public use should be of structures, unoccupied buildings, and in the child-proof type. Where the materi­ agricultural and forestry pest control als are to be used in the control of programs(19,24,27,38,39,40,43,75,83,95, pests in structurally-related situa­ 115,116,117,130,136,148,150,156,164,170, tions, the bait boxes or stations should 176,180,185). Some States require the be constructed of either wood or metal mapping of each bait location (13,124, and should be tamper-proof with baff7.e 190). Requirements are in force in some entrances. These requirements are not areas regarding a schedule for new baits new; and the pest control industry has to be put out and the uneaten baits to had considerable experience in the use be picked up (12,124,169,170). Unoccu­ of properly constructed bait boxes or pied buildings can be effectively stations (13,21,23,35,36,66,67,68,69,70, treated by including requirements that 71,122,123,152.173,188). the buildings be temporarily fenced, locked, or rendered inaccessible until Aspirin has been one of the leading after the treatment has been completed causes of accidental injury and death and all unused baits and dead pests have to children (87). The use of child­ been collected (13,19,124,169). The resistant containers has markedly 1080 training manuals of Lystad, Inc. reduced the incidence of harm. Although (113), as well as the training documents the new caps have not eliminated the of the various professional pest con trol risk, they have dramatically reduced organizations (3,13,67,68,69,70,122,123, the number of harmful incidents. 124,161,162,163,169,186), describe many Requirements for safe packaging are of the practices that can be utilized one of the regulatory functions of the to permit the safe and effective use of EPA. these pesticides.

4 The use of the pesticides that con­ and around the home, it is possible tain 1080 and 1081 should be restricted that someone may store them in or to certified ap plicators. In addition, around the home unless it is especially the uses should be limited to those prohibited. ) presently registered where the direc­ 4. Not for sale to, or use by, the tions incorporate proper restrictions general public. as to methods of application, qualifica­ 5. The technical materials not to tions of ap plicators, location of bait be sold to formulators in less than 10­ stations, and other necessary safe­ pound tamper-resistan t packages. guards. 6. Formulated baits should be shipped in tamper-resistant packages and The purposes of this RPAR trigger, should be restricted to a certified ap­ the basic exposure problem, and plicator or a designee of the certified especially the danger to children, can applicator. Use could be restricted to be addressed by proper labeling as to a certified applicator or the certified hazard and strict restriction as to site applicator could be required to be pres­ of use and qualification of user. ent during the application and recovery. 7. Commodities normally recognized The bulk of the accidents involving as human foods should not be used as children has occurred in and around the baits. Appropriate colo'~ing or other home (55,65). These materials should appropriate means of marking should be a not be registered or labeled in a way requirement. that will permit their use or storage in 8. Structural and sewer applica­ or near the home. This problem can be tions should be applied only in locked, solved by use of existing regulations tamper-proof, baff7.ed boxes of wood or and authorities. We believe the FIFRA metal and bearing appropriate warnings amendments recognized problems of this an d iden tification. nature and provided for them in the 9. Baits for structural or agri­ training and certification requirements cultural uses should be of the type that for the use of pesticides. Requirements cannot be carried away by rodents. for exposure prevention provided by 10. All dead roden ts, resulting leakproof and tamper-resistant closures from structural treatment, as well as and containers, properly placed and all uneaten baits, should be collected locked bait boxes and stations, strict and destroyed. Destruction can be restrictions on applicators, and the accomplished by incineration or burying. conditions of use are the answer to If incineration is used, the ashes the problem, not the banning of the should be buried. pesticides. Directions for Use Restrictions On July 24, 1972 the EPA sent a Pesticides containing 1080 and 1081 letter (93) to the Department of the should be used only by certified appli­ Interior regarding the labeling of zinc cators. Warnings and restrictions on phosphide. We believe that the instruc­ these pesticides should appear promin­ tions given in this letter will serve as ently on the main or principal panel of an excellent basis for the development the label (13,62,66,67,68,69,70,71,90, of the appropriate directions for field .169,186) to indicate, for example: use. 1. For use by trained and certi­ fied ap plicators only. Commonly Recognized Use Patterns 2. Not for use in or around homes or other occupied dwellings. The directions for use and the 3. Not to be stored in or around appropriate restrictions on the label the home or other dwellings. should be adhered to strictly. When (Although it is recognized that these pesticides have been applied these pesticides are not to be used in according to directions on the label,

5 unreasonable adverse effects on the the use of these chemicals. The range environment have not occurred (128,132, of the condor is influenced by the 164,190). availability of carrion more than by any other factor. The greatest concen­ One of the triggers for the rebut­ tration of carrion is along highways. table presumptions is that the residue, The limitation on the amount of carrion immediately after application of bait, and the reproduction ratio appear to be presents an undue hazard to nontarget the major factors in inhibiting the organisms. Such evidence that presently growth of the condor population (18,29, exists fails to substantiate the hazard 83,149). ( 177,190). Some bird losses have been report~d According to the report of the associated with rodent control programs. A,·thur D. Little Company (111), more In some cases the association is well than 50% of the use of 1080 for ground established, whereas in others the cause sq uirrel control programs has been in of death is not so well identified (11, California. Based on the monitoring 15,16,24,37,38,39,135). These losses, programs that have been conducted in however, do not represent a significant conjunction with the control programs in adverse effect on bird populations (83, California, significant adverse effects 119,148). With the exception perhaps of have not been indicated (83,95,96,99, endangered species, which are or can 114,189) • be protected by Federal or State regu­ lations, the losses associated with The risk to nontarget species and programs will be rather rapidly replaced to humans is reduced by limitations by normal means (142,155). The reports on use. For example, California re­ of bird losses suffer from an apparent quires special authorization for aerial failure to separate losses associated application of bait (33). Long-term with rodent control from normal losses assessments have demonstrated the lack due to the probabilities of dying, th.e of hazard to endangered species in age of the populations, the general that State (94,149,190). The California health of the population, the time of Department of Fish and Game has not the year, and other population param­ opposed the use of these materials when eters (5,9,20,45,48,82,103,121,134,135, applied according to specific ins truc­ 137,138,141,144,147.153;183,185,191). tions (33). To this may be added the fact that the International Association The nationwide breeding bird survey of Fish and Game Commissioners has of 1,600 routes measured by the Patuxent indicated the approval of the retention Wildlife Research Center does not of such uses (126). indicate any problems associated with the proper use of the pesticides under In California, where an endanger'ed discussion. An examination. of the species may be involved in a rodent win ter field studies of the Audubon control program, the area occupied by Society and the American Bird Study does the end(1.ngered species is defined and not indicate any such problems. The set aside and no treatment is permitted enforcemen t reports on migr-atory birds ( 107.,120,157.,190). In South Dakota con­ do n(l~ show any significant adverse trol programs for pratrlB dogs, the effr;cts on local, regional, or national prairie dog town is carefully examined populations (190). for the presence of the black-footed ferret. If there is any sign of the The Department of the Interior's presence of the ferret, the prairie dog guidelines for the use of poisons in town is not treated (109,110). nonpredatory an;mal damage control (172), primarily fie!d rodenticides, We do not believe that the state that: "Since baits are treated California condor has been affected by at the lowest concentration effective rodent control programs as a result of against target animals, the possibility

6 of secondary pOisoning effects occurring discussion (103). The bird simulation under field conditions is remote." The models of the Department of the Wildlife Research Report Number 1 of Interior, that are currently in use, the Department of the Interior, covering do not demonstrate the likelihood of an analysis of the population dynamics significant adverse effects to these of select.ed avian species, states that same bird populations (46,190). the impact of pesticides on mortality and recruitment rates of nongame birds The wild nontarget mammals that are indicated no increase in postfledgling most likely to be affected are the mortality rates of species during carnivores. The population responses of' the past 25 years (since 1945) (92). these mammals to morbidity and mortal­ Inasmuch as there was no evidence of ity from deliberate harvest demonstrate increased mortality rates, the Depart­ that the few individual animals lost to ment of the Interior concluded that the the animal damage control programs, accelerated decline of several species where the pesticides under discussion studied resulted from lowered reproduc­ are properly used, do not represent tive success and not from pesticides. a significant adverse effect to the The Department reports that no change in population of that species or to the "recruitment rates" was apparent among environment on a local, regional, or the species feedJ\ng primarily on national basis. The nontarget species mammals. have not in previous control programs experienced significan t population The Department of the Interior, in reductions greater than that which a letter (175) dated June 2, 1975 to can be compensated for by reproduction Mr. Laird Noh, pointed out that the and ingress (11,77,127,143,159,182,187). eagles autopsied by the Department of This compensation ability is shared by the Interior from March 11, 1975 to the predacide tat.,get populations (38,39, May 1, 1975 were not killed by either 77,150,159). ' 1080 or 1081. These eagles were recov­ ered from States whose programs include The review by the National Assess­ the use of 1080 and strychnine for men t Team indicates that the furbearers field rodent control. In addition, the are the mammalian carnivores most likely Department's Denver Wildlife Research to be affected. The analysis shows that Center's analysis of residues found in even when 25 to HO% of' populations such eagles since the early 1950's indicates as fox, opossum, skunk, racoon, musk­ that such residues would have no effect rat, coyote, weasel, nutria, and badger up until "almost a full lethal dose" are deliberately taken out of normal (112,137,190). The lethal dose of 1080 populations, no significan t adverse for an eagle is estimated to be 5 mg/leg. effects occur. This is biologically The Department of the Interior points evident when population dynamics, kinet­ out that "there is no way one can infer ics, and energetics are examined for the or imply that those eagles died of 1080 potentially affected species (34). simply because they showed traces." An analysis conducted by Dr. R. W. Studies of removal repopulation Risebrough of the eff'ects of' pesticides of' breeding birds ( 142, 155) do not and other toxicants shows that even support the concern expressed in the losses of 10,000 or more birds have not documentation (60,61) accompanying the Significantly affected those species. rebuttable presumption regarding the Dr. Risebrough indicated that the judi­ adverse effects on the local, regional, cious use of methods or control utiliz­ or nationaL populations of those bird ing chemicals does not mean Significant species reportedly affected by 1080, adverse effects on Wildlife (139). 108.1, strychnine, or strychnine sult'ate. The factors that affect the yearly Drs. Stearns and Ro.ss (154), in abundance of passerine birds have not their chapter on the effects of urbani­ been r.elated to the compounds under zaticn and technology on wildlife, show

7 t hat power lines killed 15,000 birds of programs conducted by the U.S. Forest 149 different species in Florida during Service, there has been no indi­ a 6-year period without significant cation of impacts that would adverse effects on any species. Their support the triggers used for the data indicate that vehicles on and rebuttable presumption (179,180, off the road kill thousands of mammals 181). annually. 1',10 significant adverse effects have .been reported in the local, The Smithsonian Institution Center regional, or national skunk, fox, for S hort-U'IJed Phenomena informa­ racoon, and porcupine populations. tion does not indicate any adverse effect to mammals or birds from the use Where these pesticides have been of the pesticides under discussion used correctly in forest pest control (151).

EMERGENCY TREATMENT -- 1080 AND 1081

In the EPA position paper (60) be such that it is not permissible to regarding the lack of emergency formulate baits in such a manner that treatments for 1080 and 1081, seven they can be confused with human foods. sub-areas were presented. We would This in itself will further reduce the like to comment on each of these in probability of accidental ingestion by turn: humans.

Availability of Pesticides Treatment of Poisoning Cases

The EPA Working Group (60) indi­In the in terest of a safe trans­ cated its desire to limit the household ition from the use of chlorinated use of these pesticides, primarily hydrocarbon pesticides to the organo­ because of the child exposure. We con­phosphate pesticides the EPA, in cur with this desire and will support cooperation with many others, conducted programs in this area. a very successful program known as "Project Safeguard." The written Dose Likely to be Consumed supporting material for this project included three types of treatments As soon as the pesticides are that are important in the treatment of removed, by regulation, from the home pesticide poisoning cases (54). They environment, the opportunity .for con­are: sumption by chUdren will be greatly decreased. The Working Group (60) indi­1. Supportive therapy. cated its concern with the consumption 2. Decon tamination of patient. of the bait possibly exceeding the 3. Administration of antidotes LD50' Although we share this con­when available. cern, we would like to point out that a LD 50. is a probit level with certain All three types of treatment conridence limits which probably have are available for 1080, 1081, not been definitely ascribed to humans. strychnine, and strychnine sulfate We take little comfort in the thought poisoning (7,26,41,47,54,78,79,80,85,86, that the LD indicates the level at 88,100,124,125,131,133,158,189). It is which one-ha~¥ of the test population commonly recognized that there ar'e not died. A single serious injury or death, specific antidotes for aU chemicals which could have been avoided, is a and that final diagnosis may require shocking and grievous occurrence. With extensive laboratory and clinical test­ regard to baits to be used in the field, ing with t he accompanying time periods. including properly safeguarded build­Supportive therapy can begin almost ings, registration requirements should immediately.

8 Supportive therapJI has been suc­Working Group Conclusions on the cessful in a number of very intensive Emergency Treatment Criterion 1080 poisonings (131). One case involved an individual who had inhaled The assumption that once a fatal technical 1080; however, through the use dose of 1080 or 1081 enters the of supportive therapy and decontamina­bloodstream the victim inevitably will tion, he survived. It is reported that die is not supportable from a toxicolog­ during the entire incident the patient ical or enzYTiwtic standpoint. Several experienced no actual pain or discomfort case histories have shown that symptoms other than that of alarm and anxiety. have occurred before a fatal dose has Evidence indicates that the longer the been absorbed into the bloodstream and patient is given supportive therapy, supportive treatment has been instituted even in conditions of convulsion, the (131,189). more likely the patient is to recover. In one case a young boy who ingested The current labels do not restrict 1080 received supportive therapy for 6 1080 and 1081 around homes. We believe days, and upon recovery was determined that this restriction should be on to be "clinically well" (131). the label. The National Pest Control Association has supported this restric­ Availability of Emergency Treatment tion for several years (122).

The position paper (60) indicated There are cases where people, that first aid treatment is available. including children, appear to have This, plus supportive therapy, may give ingested "lethal doses" of 1080 and have the patient sufficient time to reduce been in the convulsive state for more the level of toxicant sufficiently to than 24 hours and recovered completely permit complete recovery. Cases of poi­(41,131). We believe that 1080 and 1081 soning were cited in the position paper. can be packaged and labeled to the It is not our inten tion to dispute these degree necessary for Class 1 pesticides cases, but only to point out that we with the appropriate warnings and first believe that there are similar cases in aid treatments with supportive therapy. which the patient recovered. The expo­A good overview is provided by 40 CFR sure to these compounc.s does not auto­162.10(h)(1)(iii)(A), which was matically lead to serious consequences originally published in the Federal such as death. The cases that were Regis ter on March 9, 1972. cited can, we believe, be prevented in the future by the adoption of the Fluoroacetate is a competitive suggestions in the Project Safeguard inhibitor of aconitate hydratase and recommendations (54), as well as those can be rever-sed. In the laboratory, that have been made regarding changes in both the central nervous system and labeling and uses of the pesticides. cardiac effects of fluoroacetate may Because there are relatively few cases be prevented and reversed (32). The of pesticide poisoning in the records of authors (32) concluded that mono­ county, city, state, and federal healt h acetin is an "effective and practical agencies, it is very d~fficult to deter­antidote for fluoroacetate poisoning." mine the actual impact of pesticides in Monoacetin is not available in a general or any pesticide in particular pharmaceutical grade, but may be in (42,44,50,55,84,89,171,178). the future.

BENEFITS

EPA's Arthll.r D. Little's draft cient to outweigh the risks. The Little report "Economic Review of Rodenticide document is the only indepth analysis Usage in the U.S. rr (111) indicates presen tly available on the economics of that benefits are substantial and suffi- vertebrate animal damage control.

9 A proprietary report, "A Risk Energy saved, equivalent barrels Benefit Analysis of Compound 1080 and crude oil in alfalfa farming and 1081 and Strychnine" by Ketron, Inc., in range operations analyzed the A. D. Little report and Range other documents and concluded that Alfalfa Operations the benefits of the use of the California 10,000 20,000 three compounds outweighed the risk United States 25,000 330,000 (104). These are partial benefits -­ the The Ketron report (104) takes the total benefits could be much higher. position that the benefits of using 1080 alone amount to at least $10 million The U.S. Department of the Army's annually. Furthermor'e, it concludes "Draft Environmental Impact Statement-­ that the substitute use of zinc phos­Ground Squirrel Control, Fort Ord phide for strychnine would amount to Complex" (165) and "Orientation on a loss of between $5 million and $23 Military Services Pest Control Programs million in citrus groves, zero to and Procedures" (106) analyzed by $27 million in Washington State apple Ketron, Inc. show that when 1080 is used orchards, and about $23 million in in ground squirrel con trol to con tain alfalfa. diseased populations, it will not neces­ sarily cause any unreasonable adverse In addition, the report estimated effects on humans or nontarget species. that the use of anticoagulants in place of 1080 for structural-agricultural The Ketron, Inc., report provided rodent control would result in a loss of an analysis of alternativ-:. methods of nearly $7.5 million. ground squirrel control and determined that the preferred and most effective Ketron estimates that in California control agen t is t he toxic chemical alone an additional $1 million loss approach using Compound 1080 (106). would occur through the use of zinc phosphide in ground squirrel control on Ketron, Inc., estimated that the range lands, and $2 million additional costs of the Army's aerial application loss would occur if diphacinone were of ground squirrel control were consid­ used (104). erably less than the costs the Army would have suffered had it used zinc A second proprietary report by phosphide or strychnine. They concluded Ketron, Inc. (105) , estimates that that a denial of registration of 1080 the energy savings directly attributable would be a faiLure to safeguard the to rodent control programs are as public, or the environment, or both, in follows: emergency conditions.

CONCLUDING COMMENTS

In its position papers (60,61), the who have questioned these conclusions Working Group appears to rely rather (97,190). Neither the Cain Report heavily on the findings of the Cain (25) nor the Leopold Report (108) Report (25). We are informed that not provides sufficient data to support all of the authors continue to agree the recommendations of the Working with the conclusions of the report. 11 Group. The compounds under consid­ In addition, there are other scientists era.tion were suspended .02 predacides, not rodenticides. The public c'Jn­ cern at the time of both reports was related to a misuse of the 1/ Wagner, F. H. 1973. Personal pr'oducts as pr'edacides, not as roden­ communication. ticides.

10 No significant adverse effects ground squirrels dictates a rather have been demonstrated, in the posi­ rapid "melt down" of the carcass. The tion papers, to local, regional, or amount of treated bait that may remain national populations of nontarget in the cheek pouches or the viscera spec.ies as a result of strychnine use. of the dead squirrels normally will be Schitoskey's report (146) does not low. The extent of the hazard is contain the field data necessary to reduced by the tendency of squirrels to support a finding of significant return to or remain in their burrows potential risk. The study of acute when poisoned. toxicity does not demonstrate that the risks to endangered species can be The . strychnine geese poisonings extrapolated to field conditions because reported (57,61,98) in the EPA position it does not take into consideration many papers were clearly a case of misuse of the variables that are normally as indicated by the admission of the encountered in the field. The small applicator. The numbers of geese lost, number of test animals in Schitoskey's although regrettable, were few compared laboratory study, and the lack of the with the legal harvest that is permit­ inclusion of the variables known to ted. The legal harvest has been found occur in food preference testing, not to affect significantly the overall detract from the confidence one can population of the geese. place in the study. Strychnine, s trychnine sulfate, With regard to Hegdal's studies, we 1080, and 1081 are effective for the have serious reservations regarding the use(s) intended, and registered, and manner in which the programs were con­ when used as directed by the label, ducted, particularly as the programs including the warnings and cautions, do would be related to preferred field not cause an unreasonable adverse impact activities (91). From the study, it on the environment. The history of ap pears that there may ha.ve been errors these compcunds substantiates the in the study that could have had a conclusion that the public has been profound impact on the results. For protected and that further protection example, we question the extrapolation can be obtained by updating the label of bird counts from across the 9,000 warnings and directions for use. In acres and believe that there is room to addition, the EPA has within its question the biometrical confidence of jurisdiction sufficient legislative and the results and the statisticaL signifi­ regulatory authority to cause appro­ cance of the counts. A failure to color priate changes in registrations, or the bait properly prior to baiting labeling, or both, to restrict these appears to have been a potentially pesticides to properly trained and significant factor in the primary poi­ certified individuals and to include soning of the nontarget birds. As far requirements on packaging. In view of as secondary poisoning is concerned, the very specialized use requirements when strychnine is used above ground, for these pesticides and the long the field conditions are such that it experience history associated with these does not appear that the hazard of a pesticides, we believe that the public substantial effect on nontarget animals interest would best be served by is a considerable pOSSibility. The time retaining these rodenticides with modi­ of the year that field treatmen ts are fications in registration where such normally applied for the control of modifications are indicated.

t t t t t t t

11 LITERATURE CITED

1. Aceto Chemical Co. 11. Beasom, S. L. 1963. Fluorakil 100 (blend of 1977. Population responses of technical fluoroacetamide); nontarget animals. [Unpublished Technical data. report, 16 pp.J Dept. of Wild­ 2. Alford. H. G. life and Fisheries Sciences, 1972. Substantial question of Texas A&M Univ. safety. [Memorandum to W. M. 12. Beck, J. R. Upholt, March 21, 1972.J Envi­[No date.J Magpie contl~ol in ronmental Protection Agency, northwestern North Dakota. Office of Pesticide Programs. 13. 3. American Public Health Association. 1976. ASTM standards on verte­ 1967. Safe use of pesticides; brate control agents. Annual A manual for public health Book of ASTM Standards, Part personnel. 46, 20 pp. 4. Anonymous. 14. and P. W. Rodeheffer. [No date.J Summary of some 1965. Cause and control of sewer selected literature references rats. Public Works 96(4): 116­ relating to compound 1080 118. sodium monofluoroacetate. 15. Beebe, F. L. 5. [No date.J The myth of the 1921. Threatened extinction of vanishing Peregrine; A study in our "Bird of Freedom." Current the manipulation of public and Opinion 70( 6): 811. official attitudes. Canadian. 6. Raptor Society, North Surrey, 1976. Chemical industry leads in B. C., Canada. hazard analysis. Eur. Chem. 16. Belisle, A. A., W. L. Reichel, L. News 29(747):17. N. Locke, T. G. Lamont, B. M. 7. Arena, J. M. Mulhern, R. M. Prouty, R. B. 1975. Medical emergency manage­DeWolf, and E. Cromartie. ment, poisoning general 1972. Residues of organ.ochlorine treatment and prevention; Part pesticides, polychlorinated bi­ II. JAMA 233(4):358-363. phenyls, and mercury and 8. Atzert, S. P. autopsy data for bald eagles, 1971. A review ·of sodium mono­1969 and 1970. Pestic. Monit. fluoroacetate (compound 1080); J. 6(3):133-138. its properties, toxicology, and 17. Bentley, E. W., and J. H. Greaves. use in predator and rodent con­1960. Some properties of fluoro­ trol. USDI, Fish and Wildlife acetamide as a rodenticide. Services, Bureau of Sport J. Hyg. 58: 125-132. Fis heries and Wildlife, Special 18. Berryman, J. H. Scientific Report Wildlife 1968. Letter to Miss Kelly Long No. 146. 34 pp. from Chief, Division of Wild­ 9. Balser, D. S. life Services, Fish and 1976. Letter to L. Noh from Wildlife Service, USDI, March Chief, Section of Predator Dam­28, 1968. age, Denver Wildlife Research 19. Bjornson, B. F., and C. V. Wright. Center, Fish and Wildlife [No date.J Control of domestic Service, USDI, Oct. 27, 1976. rats and mice. Training Guide 10. Barnett, S. A., an.d M. M Spencer. - Rodent Control Series, HEW, 1953. Response of wild rats to Public Health Service. 25 pp. offensive smells and tas tes. 20. Boeker, E. L. Br. J. Anim. Behav. 1: 32-37. 1974.. Status of golden eagle

12 surveys in the Western States. investigation project: eco­ WiLdl. Soc. Bull. 2(2):46-49. nomic poisons (pesticide) 21. Boocock, D. investigation, toxicity tests, 1976. Use of 1080 and 1081 in Project W-52-R-6. the United Kingdom. Pest 31. Campt, D. D. Cont roI 44 ( 8 ) : 72 . 1972. Possible re-registration 22. Brooks, J. E. of predator control products. 1963. F'luoroacetamide -- a new [Letter with attachments to British-developed roden ticide. E. L. Johnson, Pesticide Pro­ California Vector Views 10(1). grams.J Pesticide Registration 4 pp. Division, EPA, Nov. 27, 1972. 23. Brown, P. I., and R. J. O'Brien. 32. Chenoweth, M. B., AD Kandel, L. B. 1973. Considering liability in Johnson, and D. R. Bennett. product design. Ind. Res. 1951. Factors influencing flu­ 15(13):28-31. oroacetate poisoning, practical 24. Butz, E. L. treatment with glycerol mono­ 1974. So reason might rule. acetate. J. Pharmacol. Exp. [Sp8&chJ [Address presented be­Ther. 102:31-49. fmoe Symposium on Establishing 33. Clark, D. O. a Rule of Reason on Toxicologi­1975. Vertebrate pest control cal Issues, March 8, 1974.J handbook. Division of Plant 25. Cain, S. A. Industry, State of California, 1972. Report to the Council on Department of Food and Agricul­ Environmen tal Quality and the ture. 146 pp. Department of the Interior. 34. Colorado Department of Agriculture, Advisory Committee on Predator Division of Wildlife. Control. 207 pp. 1973. Fur market outlook 1973-74 26. California Department of Agricul­season. ture, Division of Plant Industry. 35. Consumer Product SafetyCommission. 1961. 1080 first aid treatment. 1976. Poison prevention packag­ Weed Vertebra Pest Control News ing act regulations. Federal 1(5):1­ Register 41(172):37124-37128. 27. California Department of Agricul­36. ture, Weed and Vertebrate Pes t 1976. Protection of human Con trol. subjects. Federal Register 1973. Ground squirrel control; 41(172):37120-37123. and, Effects of ground squirrel 37. Cromartie, E., W. L. Reichel, L. N. control on other wildlife. Locke, A. A. Belisle, T. E. Kaiser, Report of Projects VP-2 and T. G. Lamont, B. M. Mulhern, R. M. VP-2.11. Prouty, and D. M. Swineford. 28. California Department of Fish and 1975. Residues of organochlorine Game. pesticides and polychlorinated 1965. Notes on sodium fluoro­biphenyls and autopsy data for acetate and other chemicals bald eagles, 1971-72. Pestic. used for field rodent control Monit. J. 9(1):11-14. in California. Pesticides In­38. Crouch, G. vestigation Project, FWLR-3. 1977. Above-ground uses of 1080 29. California Department of Fis hand (sodium fluoroacetate) in for­ Game, The Resources Agency. estry. [Unpublished report 1976. At the crossroads; A re­ from USDA, Forest Service, port on California's endangered Rocky Mountain Forest and and rare fish and wildlife. Range Experiment Station, Fort Third biennial report. 101 pp. CoLlins, Colorado, 12 p p. J 30. California Wildlife Investigations 39. Laboratory. 1977. Above-ground uses of 1962. Job completion report, strychnine in forestry. 13 [Unpublished report from USDA, 49. Emlen, J. T., Jr., H. Young, and Forest Service, Rocky Mountain R. L. Strecker. Forest and Range Experiment 1958. Demographic responses of Station, Fort Collins, Colo­two house mouse populations to rado. 10 pp.] moderate suppression measures 40. Cummings, M. W. with 1080 ;·odenticide. Ecology 1972. Statemen t substantiating 39(2):200-206. the desirability' of retaining 50. Entomological Society of America, the use of Cvyote-Getters Committee for Publication Infor­ ( M-44's) in coyote con trol. mation. University of California, 1963. Insecticides and the Davis. 3 pp. 41. Dana, R. H. health of people, domestic animals and poultry. Report of 1968. Memorandum with attach­February 15, Distribution Code ments to all supervIsmg ARS-SPRO and ARS-PPCP-2. biologists. December 6, 1968. 51. Environmental Protection Agency. J. H., J. E. and A. 42. Davis, Davies, 1973. Certain rodenticides; J. Fisk. Intent to hold hearing; and, 1969. Occurrence, diagnosis, and Issues to be discussed in treatment of organophosphate hearing. Federal Register pesticide pOisoning in man. 38(122):16796. Ann. N. Y. Acad. Sci. 160(1): 52. 383-392. 1973. Draft of: Standard method 43. Dean, D. W. of test for efficacy of acute 1967. 1080 rodenticide - aerial mammalian predacides. Septem­ application. [Memorandum to ber 26, 1973. W. Hays, Pesticides Regulation 53. Division, ARS, USDA.] Pesti­ 1976. In house fact sheet on the cides Regulation Division, ARS, RPAR system and open decisions USDA, May 16, 1967. on pesticide safety. 44. DeEds, F. 54. 1950. The significance of chron­Office of Pesticide Programs. ic toxicity studies. Food 1972. Diagnosis and treatment of Technol. 4 ( 2): 40-42. pOisoning by pesticides. 45. Devoe, A. 55. 1938. Down to earth, the vanish­Office of Pesticide Programs, ing i\,merican Symbol. Am. Technical Services Branch, Epidemi­ Mercury 44(175):338-341. ologic Studies Program. '46. Dolbeer, R. A., C. R. Ingram, and 1976. National study of hospital J. L. Seubert. admitted pesticide poisonings. 1976. Modeling as a management April 1976. 121 pp. tool for assessing the impact 56. of blackbird control measures. Pestici,de Programs. Proc. Seventh Vertebrate Pest 1976. Rebuttable presumption Conf. pp. 35-45. against regis tration and 47. Dreisbach, R. H. continued registration of pes­ 1971. Fluoroacetate. In R. H. ticide products containing com­ Dreisbach, Handbook-of Poi­pound 1080 and 1081. Federal soning. Lange Medical Publica­Register 41(232):52792-52809. 'tions, Los Altos, California. 57. p. 113. Pesticide Programs. 48. Emergency Conservation Committee. 1976. Rebuttable presumption 1935. Can the bald eagle still against registration and con­ be saved from extinction? tin ued regis tration of certain Emergency Conserv. Publ. No. pesticide p roduct s con tainin g 44:3-27. strychnine and strychnine 14 sulfate. Federal Regis ter 65. 41(232):52810-52855. Pes ticides Regulation Division, 58. Environmental Protection Agency, Acciden t Investigat ion Section. Pesticide Programs. 1972. Pesticide investigations 1977 • Rebuttable presumption in fiscal year 1971. Report against registration and con­reference number 12. tinued registration of certain 66. pesticide products containing Pesticides Regulation Division, compound 1080 and compound Roden ticide Handbook Staff. 1081; Extension of time. 1970. R-5 Arsenic rodenticide; Federal Register 42(9):2713. Directions for use. 59. 67. Pesticide Programs. Pesticides Regulation Division, 1977. Rebuttable presumption Roden ticide Handbook Staff. against registration and con­1971. R-9 Strychnine rodenti­ tinued registration of certain cide; Directions for use. pesticide products containing 68. strychnine and strychnine sul­Pesticides Regulation Division, fate; Extension of time. Fed­Roden ticide Handbook Staff. eral Register 42(9):2713-2714. 1971. R-20 Pocket gopher; Direc­ 60. tions for hand bait placement. Pesticide Programs, Agency Working 69. Group on 1080 and 1081. Pesticides Regulation Division, 1976. Compound 1080 and 1081; Roden ticide Handbook Staff. Position document 1. Office of 1971. R-23 English sparrow Special Pesticide Reviews, EPA, (Passer domes!icus) and Washington, D.C. Feral pigeon (Columba livia); 61. Directions for bait place­ Pesticide Programs, Agency Working ment. Group on Strychnine and Strychnine 70. Sulfate. Pesticides Regulation Division, 1976. Strychnine and strychnine Rodenticide Handbook Staff. sulfate; Position document 1. 1971. R-27 Muskrat (Ondatra Office of Special Pesticide zibethicus) and Nutria Reviews, EPA, Washington, D.C. (Myocaster coypus); Directions 62. for bait placement. Pesticide Registration Division, 71. Rodenticide Staff. Registration Division. [No date.] House mice in the 1974. Wyoming Department of home, problems, controls, and Agriculture; Strychnine alka­ hazards. loid in an emergency rabid 63. skunk con trol program. Federal Pes ticides Regulation Division. Register 39(169):31549. 1972. Draft cancellation notice 72. Fabrikant, C. for products containing sodium 1972. [Memorandum to D. Domi­ fluoroacetate (1080) and nick.] Pesticides Regulation strychnine. Division, EPA. January 31, 64. 1972. Pesticides Regulation Division. 73. Federal Working Group on Pest 1972. Environmental impact Management. report regarding certain regis­1972. Proc. of the National tered strychnine, sodium Conference on Protective fluoroacetate and calcium cya­Clothing and Safety Equipment nide products for control of for Pesticide Workers. field rodents and birds. March [Atlanta Georgia, May 1 and 2, 6. 1972. 1972.] 15 74. Federal Working Group on Pest 82. Gruennagen, R. P. Management. 1970. Bald facts about bald 1974. Occupational exposure to eagles. Virginia Tech News pesticides; Report to the Fed­Services, Release Sept. 27, eral Working Group on Pest 1970. Management, from the Task 83. Hagan, H. Group on Occupational Expo­1972. A review of the use of sure to Pesticides. toxic mat erials for mammalian 75. Fitzwater, W. D. animal con trol in California. 1972. Economics and control of State of California, The certain rodents. Internal EPA, Resources Agency, Department Pesticides Regulation Division or Fish and Game, Wildlife report. Management Administrative 76. Frizzell, K.. Report No. 72-5. 1976. Letter to Congressman 84. Hansen, G. H. W. R. Poage, Subcommittee on 1959. Report of accidental human Livestock and Gains, Committee consumption of 1080 treated on Agriculture, from Under Sec­meat. [Memorandum to District retary of the Interior, USDI. Agents, Region I, May 6, 1959.J November' 29, 1976. Portland, Bureau of Sport 77. Giles, R. H., Jr., C. D. Buffing­Fisheries and Wildlife, USDI. ton, and J. A. Davis. 85. Harrison, J. W. E., J. L. Ambrus, 1969. A topographic model of and C. M. Ambrus. population stability. J. Wildl. 1952. Fluoroacetate (1080) poi­ Manage. 33(4):1042-1045. soning. Ind. Med. Surge 21(9): 78. Gleason, M. N., R. E. Gosselin, H. 440-442. C. Hodge, and R. P. Smith. 86. Hashimoto, Y., T. Makita, T. Mori, 1976. Fluoroacetate. pp. 163­T. Nishibe, and T. Noguchi. 166, In M. N. Gleason, R. E. 1970. Toxicologic and pharmaco­ Gosselin, H. C. Hodge, and R. logic studies on acetamide, as P. Smith, Clinical Toxicology an antidote against mOlLofluoro­ of Commercial Products, 3rd acetamide poisoning; Studies on ed., Williams & Wilkins Co., t he selective toxicity, XVII . Balt imore, Md. Pharmacometrics 4( 3): 451-:462. 79. Gleason, M. N., R. E. Gosselin, H. 87. Hayes, W. J., Jr. C. Hodge, and R. P. Smith. [No date.J How toxic is toxic? 1976. Strychnine. pp. 303-307, Vanderbilt Univ. In M. N. Gleason, R. E. Gos­ 88. selin, H. C. Hodge, and R. P. 1963. Sodium fluoroacetate. Smith, Clinical Toxicology of pp. 79-82, In W. J. Hayes, Jr., Commercial Products, 3rd ed., Clinical Handbook on Economic Williams & Wilkins Co. , Poisons; Emergency Information Baltimore, Md. for Treating Poisoning. U.S. 80. Goodman, L. S., and A. Gilman. Dept. of Health, Education and 1967. Fluoride and other anions. Welfare, Public Health Service, pp. 815-819, In L. S. Goodman Public Health Publ. W 476. and A. Gilman-;-The Pharmacolog­89. ical Basis of Therapeutics, 1964. 0 ccurrence of' poisoning by 3rd ed., The MacMillan Co., pesticides. [Read before the New York. American Medical Association 81. Gratz, N. G. Congress on Environmental 1966. A critical review of the H ealt h Problems, Chi.cago, ILL., curr'ently used acu te­May 1-2, 1964.J rodenticides. WHO/Vector 90. Health, Education and Welfare. Control/66.217. pp. 79-86, 1972. State and local hazardous 88. labeling requirements for 16 househoLd products; Federal California, June 24, by Pesti­ preemption. FederaL Register cides Investigation Project, 37(179):18628-18630. FWI-R-3.J California Dept. of 91. Hegdal, P. L., and T. A. Gatz. Fish and Game. 1977 • Hazards to seedeating 100. Hutchens, J. 0., H. Wagner, B. birds and other wildlife Podolsky, and T. M. McMahon. associated with surface strych­1948. The effect of ethanol and nine baiting for Richardson's various metabolites on fluoro­ ground squirrels. Final Report acetate poisoning. J. Pharm­ to EPA, EPA-IAG-D4-0449. acol. Exp. Ther. 95:62-70. 92. Henny. C. J. 101. Johnson, E. L. 1972. An analysis of the popula­1975. Letter to L. T. Wallace, tion dynamics of selected avian California Dept. of Food and species, with special referen ce Agriculture, November 3, 1975. to changes during the modern Office of Pesticide Programs, pesticide era. USDI, Fish and EPA. Wildlife Service, Wildlife 102. Research Report 1, Jacket No. 1976. Letter to U.S. Represent­ 459-324. ative W. R. Poage, November 93. Hood, G. A. 30, 1976. Office of Pesticide 1972. Zinc phosphide -- a new ProG,'ams, EPA. look at an old roden ticide for 103. Kendeigh, S. C., and S. P. field roden ts. Proc. Fifth Ver­Baldwin. tebrate Pest Conf. pp. 85-92. 1937. Factors affecting yearly 94. Horn, E. E. abundance of Passerine birds. 1939. Factors in nesting losses Ecol. Monographs 7( 1): 91-123. of the California valley quail. 104. Ketron, Inc. USDA, Bureau of Biological 1977 • A risk benefit analysis Survey, Division of Wildlife of compound 1080 and 1081 and Research, Section of Wildlife strychnine. File label KFR Surveys, Wildlife Research and #105-77, February 15, 1977. Management Leafl. BS-124. 105. 1977. The of rodenticides 95. HowardJ W. E. use 1959. Statement on California's as an energy conservat ion use of Compound 1080. [Submit­measure. File label KFR ted to Assembly Interim #105-77, February 22, 1977. Committee on Agriculture hear­106. ing held in Stockton on 1977 • Orientation on military Nov.ember 20, 1959.J services pest control programs 96 and procedures. File label 1960. 1080 - A roden t poison of KFR #.110-77B, March 3, 1977. controversy. Calif. Farmer 107. Leach, H. R. 212(18,21):240, 350, 354. 1974. Rare and endangered wild­ 97. life problems and solutions. 1972. Predator Control - 1971. Proc. Sixth Vertebrate Pest J. Wildl. Manage. 36(4): 1373­ Conf. pp.188-197. 1374. 108. Leopold, A. S. 98. Howell, J., and W. Wishart. [No date.J Reports of the 1969. Strychnine poisoning in Special Advisory Board on Canada geese. Bull. Wildl. Wildlife Managemen t, for the Dis .• Assoc. 5: 119. Secretary of the Interior, 99. Hunt, E. G. 1963-1968. Reprinted from the 1966. Dangers of rodenticides to Transactions of the North nontaJ~get wildlife. [SpeechJ American Wildlife and Natural [Presented at meeting of Resources Conf., Vol. 28, 29, Board of Forestry, Eureka, and 33.

17 109. Linder, R. L., chairman. 118. Martin, W. E. 1976. Recovery plan submitted 1971. Toxicants commonly used to U • S • Fis h and Wildlife in t he animal damage con trol Service. Report draft by program of the Division of Black-Footed Ferret Recovery Wildlife Services. [Unpub­ Team, October I, 1976. lished report] USDI, Bureau 110. Linder, R. L., and C. N. Hillman. of Sport Fisheries and Wild­ 1973. Proc. of the Black-Footed life, Branch of Pesticide Ferret and Prairie Dog Work­Appraisal and Monitoring. shop. [Held Sept. 4-6, at 119. Marvin, P. H. South Dakota S tate University, 1964. Bird numbers increase Brookings, South Dakota.] 208 during pesticide years. C rop­ pp. life: May. 111. Little, A. D. 120. Morrell, S. H. 1976. Economic review of roden­1975. San Joaquin Kit Fox dis­ ticide usage in the U.S. Final tribution and abundance in draft report prepared for Cri­1975. California Department teria and Evaluation Division, of Fish and Game, Wildlife Office of Pesticide Programs, Management Branch Admin. EPA. Report No. 75-3. 112. Loveless, C. M. 121. Mulhern, B. M., W. L. Reichel, L 1975. Letter to L. J. Bourret, N. Locke, T. G. Lamont, A. Wyoming Dept. of Agriculture, Belisle, E. Cromartie, G. E. June 4, 1975. Denver Wildlife Bagley, and R. M. Prouty. Research Center, Fish and 1970. Organochlorine residues Wildlife Service, USDI. and autopsy data from bald 113. Lystad, Inc. eagles. Pestic. Monit. J. 1963. Supplemental labeling to 4(3):141-144. EPA Registered Label No. 122. National Pest Control Association, 2881-12. Lystad, Inc., Grand Rodent Control Committee. Forks, North Dakota. 1970. Good practice in t he use 114. Mallette, R. D., and H. T. Harper. of the roden ticide sodium fiu­ 1964. Population studies of oroacetate by the pest con trol ring-necked pheasants in Cali­operator. Technical Release fornia. Calif. Fish and Game No. 19-70. 50(4);292-304. 123. 115. Marsh, R. E. Rodent Control Committee. 1965. Repor't of studies; Aerial 1971. Good pr'actice in the use technique as a means of dis­of the roden Hcide strychnine persing toxic grain for ground by the pest control operator. sq uirrel control (Merced Technical Release No. 5-71. County experimental trails). 124. National Research C ouncL~ .- Dept. of Animal Physiology, Chemical-B iological Coordination Univ. of California, Davis. C en ter, Subcommittee otMammalogy. 116. 1948-1949. Instructions for 1967. A guide for aerial bait­using sodium fluoroacetate ing of ground sq uirrels. (compound 1080) as a rodent [Report presented at Third poison. October 1948 revision Vertebrate Pest Conf., San plus January 1949 addendum. Francisco, California, March 125. National Research Council Insect 7-9, 1967.] Control Committee, Subcommittee on 117. Rodent Control •• 1968. An aerial method of dis­[No date.] First aid, in case pensing ground squirrel bait. of 1080 poisoning. J. Range Manage. 21( 6): 380­126. Neugebauer, R. J. 384. 1972. What writers are saying;

18 Chemical toxicant ban. Out­Probable causes of bald eagle doors Unlimited, p. 10. mortality, 1964-1972, February International Association of 6, 1976.J Patuxent Wildlife Game, Fish, and Conservation Research Center, Fish and Commissioners. Wildlife Service, USDI. 127. Noh, L. 135. Reichel, W. L., E. Cromartie, T. 1973. Statement of Laird Noh, G. Lamont, B. M. Mulhern, and R. Predatory Animal Committee of M. Prouty. the National Wool Growers 1969. Pesticide residues in Association before the Sub­eagles. Pestic. Monit. J. committee on Fisheries and 3(3):142-144. Wildlife Conservation and the 136. Reid, N. Environment of the Committee 1971. Inf'ormation statemen t on on Merchant Marine and Fisher­ Compound 1080 (sodium monoflu­ ies. [Presented before the oroacetate) and its use by the United States House of Repre­Bureau of' Sport Fisheries and sentatives, March 20, 1973.J Wildlife, Division of Wildlife 128. Services. [U.S. Senate Hear­ 1975. Letter to W. R. Poage, ings on Predator Control, 92nd House of Representatives, May Congress, 1st Session FY-72, 13, 1975. Predatory Animal pp. 48-54, April 1971.J Committee, National Wool 137. Reidinger, R. F., Jr., and D. G. Growers Association. Crabtree. 129. Ochs, P. M. 1974. Organochlorine resi­ 1972. Efficacy testing of ver­ dues in golden eagles, tebrate pest control agents. United States -- March 1964- Proc. Fifth Vertebrate Pest July 1971. Pestic. Monit. J. Conf. pp. 138-141. 8 ( 1) : 37-43. 130. Ochs, P. M., J. R. Wood, andW. D. 138. Ricklefs, R. E. Fitzwater. 1969. An analysis of nesting 1973. Predator control research mortality in birds. Smithson­ meeting. [Memorandum to ian Contributions to Zoology, W. G. Roessler, CED, April No.9. 18, 1973.J Pesticide Regis­139. Risebrough, R. W. tration Division, EPA. 1976. The eff'ects of pesticides 131. Pattison, F. L. M. and other toxicants. [Paper 1959. Toxic aliphatic fluorine given at National Symposium compounds, 211 pp, In E. "Wildlif'e and America" held on Browning (ed.), ElsevierMon­Sept. 29-30, Washing-ton, D.C.J ographs of Industrial Toxic 140. Ritch, J. B., Jr. Agents. Elsevier Publishing 1973. Information on rodenti­ Co., New York. cides for formal hearings. 132. Peters, J. A. [Memorandum to L. Axelrod, 1975. Contamination of' !'ores t Criteria and Evaluation ecosystems by sodium fluoro­Division, December 18, 1973.J acetate (compound 1080). Registration Division, EPA. Proc. New Zealand Ecol. Soc. 141. Robbins, C. S. 22:34-41. 1960. Status of the bald eagle, 133. Peters, R. A. summer of' 1959. USDI, Fish 1952. The puzzle for therapy in and Wildlife Service, Wildlife fluoroacetate poisoning. Br. Leafl.418. Med. J. 4795:1165-1170. 142. Robbins, C. S., and others. 134. Reichel, W. L. 1963. Measu.rement of a known 1976. [Letter to L. J. Bourret, mortality rate in a small Wyoming Dept. of Agriculture; bird population. Work Unit with attached table titled: No. D-12.2 from Annual

19 Progress Report, Patuxen t strychnine sulfate to mammals Wildlife Research Center. and birds. 143. Robinson, W. B. 152. Spear, P. J. 1953. Population trends of 1967. Good practice in verte­ predators and fur animals in brate pest control. Proc. 1080 station areas. J. Mammal. Third Vertebrate Pest Conf. 34(2):220-227. pp. 31-35. 144. Rogers, A. J. 153. Spencer, D. A. 1972. Eagles, affluence, and 1969. The peregrine falcon; pesticides. Mosquito News Diagnosing the causes for the 32(2):152-157. declining numbers. Briefing 145. Rowe, F. P., J. H. Greaves, P. paper BP10. National Agricul­ Redfern, and A. D. Martin. tural Chemicals Association. 1970. Rodenticides -- problems 154. Sterns, F., and J. E. Ross. and current research. Proc. 1976. The effects of urbani­ Fourth Vertebrate Pest Control zation and technology on Conf., Sacramento, California. wildlife. [Paper given at pp. 126-128. National Symposium "Wildlife 146. Schitoskey, F., Jr. and America" held on Sept. 1975. Primary and secondary 29-30, Washington, D.C., hazards of three rodenticides Chapter 14.J to kit fox. J. Wildl. Manage. 155. Stewart, R. E., and J. W. Aldrich. 39(2):416-418. 1951. Removal and repopulation 147. Seierstad, S., A. Seierstad, and of breeding birds in a spruce­ I. Mysterud. fir forest community. Auk, Q. 1967. Estimation of survey J. 68(4):471-482. efficiency for animal popula­156. Sutton, R. M., Jr. tions with unidentifiab le 1967. Animal control - prog­ individuals. Nature 213( 5075): ress, problems and profession­ 524-525. alism. Proc. Third Vertebrate 148. Shepard, K. D. Pest Conf. pp. 41-44. 1967. Aerial application feasi­ 157. Swick, C. C. bility study for control of 1973. San Joaquin Kit Fox -- an ground squirrels in Elko impact report on secondary County, Nevada. hazards of aerial app lication 149. Sibley. F. C. of 1080 grain baits for 1966. Study on 1080 gl~ound ground squirrel control in squir,~el poisoning operation. San Luis Obispo County. Informal study project in Supported by Federal Aid in Kern County, California, by Wildlife Restoration, Project U.S. Fish and Wildlife W-54-R4. Service. 158. Thomas, P. 150. Smith, H. C. 19·75. 1080 Antidote. [Letter 1976. 1080 and strychnine use to M. E. R. Godfrey, Davis, in the state of Nevada and California, October 16, 1975.J argumen ts for its continued New Zealand Agricultural Pests registration. [Letter with Destruction Council. supporting documents to 159. University of California. Pesticides Division, Region 1975. The effects of con trol on IX, EPA, December 6, 1976.J coyote populations. Coopera­ 151. Smithsonian Institution Center for tive Extension Bull. 1872. Short-Lived Phenomena. 160. U.S. Department of Agriculture. 1977. Computer search for data 1937. Research studies in the collected by Center which control of destructive mam­ relates to adverse effects of mals. Wildlife Research and 1080, 1081, strychnine and Management Leafl. BS-91,

20 Bureau of Biological Survey, January 6, 1969. Fish and Division of Game Managemen t. Wildlife Service, Division of 161. U •S. Departmen t of Agriculture. Wildlife Services. 1962. Respiratory devices for 170. pr'otection against certain 1971. Information statemen t on pesticides. Publ. ARS-33-76, compound 1080 (sodium mono­ Agricultural Research Service, fluoroacetate) and its use Entomology Research Division. by the Bureau of Sport Fisher­ 162. ies and Wildlife, Division of 1963. Checklist for pesticide Wildlife Services. Bureau of safety. Agricultural Research S port Fisheries and Wild­ Service, Plant Pest Control life, Division of Wildlife Division. Services. 163. 171. 1967. Safe use of agricultural 1972. Draft, Environmental and hou.sehold pesticides. statement DES 72-32, Proposed Agricultural Research Service. Animal Damage Act of 1972, Agric. Handb. No. 321. February 8, 1972. Bureau of 164. Sport Fisheries and Wildlife. 1973. Response of the Secretary 172. of Agriculture to the issues 1972. Department guidelines for to be discussed in the admin­use of poisons in non­ istrative hearing concerning predatory animal damage certain rodenticides. [Hear­control. Part 517 DM of the ing before EPA Administrator, Departmental Manual. Office delivered by P. A. Vander of the Secretary. Myde, I. F. & R. No. 294.]. 173. 165. U.S. Department of Defense. 1972. Guidelines for the 1977. Ground squirrel control, operation of cooperative bait­ Fort Ord Complex, California. mixing plants. [Memorandum Draft, environmen tal impact from the Director to Regional statement. U.S. Army. Directors, August 25, 1972.] 166. U.S. Department of Interior. Bureau of Sport Fisher'ies and 1945. Service policy on the Wildlife. use of compound 1080 (sodium 174. fluoroacetate). [Memorandum 1974. [Memorandum from tele­ No. 121.] Fish and Wildlife phone conversation of January Service, Division of Predator 31, 1974 with N. Miner, and Rodent Control. Montana State Super'visor.] 167. Fish and Wildlife Service, 1946. Service policy on the use Division of Wildlife Services. of compound 1080 (sodium 175. fluoroacetate). [Memorandum 1975. [Letter with attachment No. 121, Supple No.4.] Fish from the Director to L. Noh, and Wildlife Service, Divi­Predatory Animal Committee, sion of Predator and Roden t National Wood Growers Associa­ Control. tion, June 2, 1975.] Fish and 168. Wildlife Service. - 1954. Mouse control of forest 176. areas. [Memorandum No. 154, [No date.] Analysis of 1080, Supplement No. 1.] Fish and strychnine alkaloid, and zinc Wildlife Service, B ranch of phosphide as rodenticides for Predator and Rodent Control. controlling field rodents. 169. Bureau of Sport Fisheries and 1969. Urban rat control Wildlife, Denver Wildlife handbook. Review draft, Research Center.

21 177. U.S. Department of Interior. 185. Wade, D. A. [No date.] Effects of rodenti­1975. Political factors in cides upon beneficial animal animal damage control. [Pre­ life. Fish and Wildlife sented at "Advancement in Service. Pesticides" Seminar, Helena, 178. u.s. Food and Drug Administration. Montana, September 17, 1975.] [No date.] Poison control 186. Wade, D. A., chairman. statistics 1968-1974. 1975. New standard guidelines U.S. Forest Service. for the use and development of 1972. Draft; Environmen tal sodium monofluoroacetate (com­ statement on the control of pound 1080) as a pr'edacide. pocket gopher in Texas. ASTMCommitteeE-35.17, Preda­ 180. tor Task Group. 1972. Uses of strychnine 187. Wagner, F. H. in forestry. Report dated 1975. The predator-control June 2, 1972. scene as of 1974. J. Range 181. Manage. 28(1):4-10. 1973. Environmental statement, 188. Wiersma, G. B. Pocket gopher damage control. 1974. The National Pesticide Rough draft of February 9, Monitoring Program, an over­ 1973. view of the first ten years of 182. U.S. House of Representatives the program's operation. Committee on Merchant Marine and 189. Wood, J. R. Fisheries, Subcommittee on Fisher­1976. Public health risk. ies and Wildlife Conservation and Internal report of Plant the Environment. Protection and Q uaran tine, 1973. Predatory animals. [Hear­ Animal and Plant Health ings of March 19 and 20, Inspection Service, USDA. Serial No. 93-2, pp. 212, 190. Wood, J. R., A. Araji, S. Beasom, 380-395. ] G. Crouch, S. GesseLL, R. Hender­ 183. van N arne, W. G. son, and C. Terrill. 1921. Threatened extinction of 1977 • Expert panel for strych­ the bald eagle. Ecology nine and 1080 biological 2(1): 76-78. assessment. Coordinated by 184. Virginia Polytechnic Institute and the Office of Environmental State University. Activities, USDA. 1970. Rats and their control. 191. Yapp W. P. Publication 272. Extension 1956. The theory of line tran­ Division. sects. Bird Study 3(2) :93-104.

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Alford, H. G. Baxter, W. L., and C. W. Wolfe. 1972. Suspension and cancellation of [N 0 date.] The ring-necked p heasan t strychnine sulfate 1 gram, Reg. No. in Nebraska. Nebraska Game and Parks 9038-1, March 10, 1972. [Letter to Commission, Federal Aid in Wildlife C. M. Bundy Co.] Pesticides Regula­Restoration Act, Pittman-Robertson tion Division, EPA. Projects W-28 and 1V-38-R. Baxter, W. L., and C. W. Wolfe. Beck, J. R. 1973. Life history and ecology 1974. An overview of ASTM's activi­ of the ring-necked pheasant in ties in establishing standards for Nebraska. Nebraska Game and Parks vertebrate pest control materials. Commission, Lincoln, Nebraska. Proc., Sixth Vertebrate Pest Conf. pp. 3643, 5356. pp. 55-57.

22 Berryman, J. H. Environmen tal Protection Agency. 1972. {Letter to F. G. Evenden, The 1972. Rodenticide hearings - verte­ Wildlife Society, September 21, brates as pests. 1972.J Division of Wildlife Services, Fish and Wildlife Service, 1973. Environmental impact statement; USDI. Registration of sodium cyanide for Bjornson, B. F. use with the M-44 device and capsule 1961. House mouse, public health for predator control. importance, biology !lnd control. , Pesticide Programs. --=-:::-=­ U.S. Department of Health, Educa­1976. Reliability of pesticide test tion, and Welfare, Public Health reports; Advance notice of proposed Service, Communicable Disease rulemaking. Federal Regis ter 41: Center, Atlanta, Georgia. 9 pp. 43920. Cain, S. A. -..."..,..,,.... , Pesticide Registration Division. 1972. Predator control -- 1971. J. {N 0 dates. J Toxicity data from agency Wildl. Manage. 36(4):1373-1375. files, from various cited research California Dept. of Fish and Game, reports. Castroville Area. Errington, P. L. 1968. Prepesticidal census. Three 1947. Special article; A question of separate pages dated July 2, values. J. Wildl. Manage. 2(3):267­ July 17, .and July 1-5, 1968. 272. Capp, J. C., chairman. Evenden, F. G. 1975. Survey of pocket gopher 1971. Wildlife exploitation; Is pres­ research in the Western United ervation the answer? {Presented to States. Report by the Working National Science Teachers Associa­ Group of the Northwest Forest tion, North Central Regional Pocket Gopher Committee, Oregon­Conference, Milwaukee, Wisconsin, Washington Silvicultural Council, October 1, 1971.] Western Forestry and Conservation Association. 1972. Progress in humane wildlife Chapman, J. A., and A. L. Harman. control; A panel before the American {No date. J The breeding biology of a Humane Association. {Presented by brush rabbit population. pp. 816­author, Executive Director, The 823. Wildlife Society, in Denver, Collins, B. D. Colorado, on October 10, 1972.] 1967. An evaluation of application Faulkner, C. E. of zinc phosphide for rat control 1962. Urban bird problems. National reclamation district 1000, Bird Control Seminar, July 11-12, Sacramento and Sutter counties, Bowling Green State University, California. Internal report of Bowling Green, Ohio. Pesticides Investigation Project Fisler, G. G. of the California Department of 1969. Mammalian organizational sys­ Fish and Game. 7 pp. tems. Contributions in Science (Los Cross, C. E. Angeles County Museum), No. 167. 1976. Balancing risks and benefits; Fullerton, R. W. Is EPA evaluating scientific evi­1976. Court of Appeals opinion dence? Agrichemical Age 19(7):9. affirming EPA's decision to suspend Dixon, M., and E. C. Webb. the registrations of most uses of 1964. Enzymes. 2nd ed. Academic chlordane and heptachlor. [Memm'an­ Press, Inc., New York. dum to Pesticide Committee members, Dudderar, G. R. November 17, 1976. J Litigation Divi­ 1968. Report on the use of 0.25% sion, Office of General Counsel. strychnine tre.ated whole corn for Gorham, J. R. the control of sprout pulling 1975. Filth in foods; Implications by birds. Virginia Polytechnic for health. .T. Milk Food Technol. Institute. 38(7):409-418.

23 Gunn, D. L. Masson, W. V., and R. U. Mace. 1972. Dilemmas in conservation {'or 1970. Upland game birds. Oregon appUed biologists. Ann. Appl. State Game Commission, Wildl. Bull. Biol. 72:105-127. No.5. Headley, J. C., and A. V Kneese. McCabe, R. A., and E. L. Kozicky. 1969. Economic implications of pesti­ 1972. A position on predator cide use. Ann. New York Acad. Sci. managemen t. J. Wildl. Manage. 160(1):30-39. 36(2):382-394. Health, Education, and Welfare. McLean, L. A. 1969. Complexities of terminology. [No date.J The necessity, value and pp. 258-263, In HEW, Report of the safety of pesticides. Velsicol Secretary's Commission on Pesticides Chemical Corporation. and their Relationship to Environ­ Messick, J. P., E. G. Bizeau, W. W. mental Health. U.S. Government Benson, and W. H. Mullins. Printing Office, Washington, D. C. 1974. Aerial pes ticide app lications ---, Public Health Service. and ring-necked pheasants. J. WiLdl. 1970. First draft of rat control Manage. 38(4):679-685. bibliography. Internal document, Myers, S. Insect and Rodent Control Branch. 1972. [Letter to T. C. Nelson, U.S. Howard, W. E. Forest Ser'vice, October 12, 1972.} 1973. My visit to Washinton, D.C., Office of Federal Activities, EPA. March 18-22, 1973 con,cerning H R National Academy of Sciences, National Predator Control Bills, April 11, Research Council, Committee on Pest 1973. [ Memorandum to w hom it may Control and Wildlife Relationships. concern.J Univ. of California, 1961. A symposium on pest control and Davis. Wildlife relationships. Pub lication 897. 1973. S tatemen t before the Subcommit­ National Pest Control Association. tee on Environment of the Senate 1976. Vertebrate pests, commensal commerce Committee. [Delivered May rodent.s. Dated July, number'ed ESPC 10, 1973.J Dept. of Animal Physi­ 041003-14. ology, Univ. of Cal.ifornia, Davis. Nichols, C. W. Hyde, K. M., J. B. Graves, A. B. Watts, 1975. [Memorandum to L. T. Wallace, and F. L. Bonner. California Dept. of Food and 1973. Reproductive success of mallard Agriculture, October 6, 1975.} ducks fed mirex. J. Wildl. Manage. Plant Industry, California Dept. of 37(4):479-484. Food and Agriculture. Jones, G. S. N.L.M.'s National Intel'active Retrieval 1973. [Letter to Anson M. Keller, Service, Toxline. November 16, 1973.J External 1975. Acetamidej 26 citations Affairs Unit, EPA. prin ted. Judenko, E. O'Brien, J. 1965. The assessment of economic 1977. [Letter to J. R. Wood, PPQ, effectiveness of pest control in APHIS, USDA, February 23, 1977.J field experiments. Econ. Effec­ Nevada Dept. of Agriculture. tiveness in Field Experiments 2(3): Robison, ~;I. H. 359-365. 1970. Acute toxicity of sodium Kenaga, E. E. monofluoroacetate to cattle. J. 1968. Guidelines for evaluating the Wildl. Manage. 34( 3): 647-648. properties of pesticides for safe Roest, A. [. use in t he wildlife environmen t. 1970. Tolerance of a tl.!.rkey vul­ Down to Earth 23(4):11-18. ture to 1080-poisoned ground Litchfield, J. 1'., Jr. squirrels. [Unpublished report, 1965. Predictabili.ty of conventional ApriLJ California State Poly­ animal toxicity tests. Ann. New technic College, San Luis ObiSpo, York Acad. Sci. 123:268-272. California.

24 Roseberry, J. L. bluebirds and house wrens. U.S. 1974. Relationships between selected Forest Service Research Paper population phenomena and annual bob­PNW-185. white age ratios. J. Wildl. Manage. U.S. Court of Appeals for the District 38(4):665-673. of Columbia Circuit. Ruckelshaus, W. D. 1976. Case No. 75-2259, 76-1181, 1971. Statement of Honorable William 76-1245. and 76-1247 pertaining D. Ruckelshaus, Administrator, EPA. to EPA's suspension of regis­ [Made before the Committee on trations for chlordane and Appropriations, Subcommittee on heptachlor. Agricultural and Environmental U.S. Court of Appeals for the Seventh Agencies, United States Senate, Circuit. June 2, 1971.J 1972. Petitioner, Stearns Electric Paste Company on petition for review 1972. Notice to manufacturers, of an order of the A dminis trator formulators, distributors, and of the Environmental Protection registrants of suspension of regis­ Agency, Decision of May 11, 1972. tration for all products containing Petition No. 71-1112. thallium sulfate, PR Notice 72-3, U.S. Department of Agriculture. March 9, 1972. 1975. Rebuttal to statemen t of Schmidt, J. L. Gerald A. Carlson, Witness for EPA. 1974. Mourning dove facts. Coopera­Draft of EPA mirex Administrative tive Extension Service, South Dakota Hearings of August, 1975. State University. Schwartz, C. C., and J. G. Nagy. 1977. Review of the EPA! USDI Wyoming 1974. Pesticide effects on in vitro Research Report on primary and dry matter digestion in deer.--:r: secondary hazards of roden !icides on Wildl. Manage. 8(3):531-534. nontarget species. Smithsonian Institution, Science Infor­, Agricultural Research Service, mation Exchange. -=--,-~Pes ticides Regulation Division. 1969-1971. Computer print-out of 1968. Withholding regis tration for ongoing projects on pest control certain pr'oducts on the basis of of birds, rodents, or other package size. PR Division Memo­ mammals. randum No. 909.026, dated Stanford, J. A. August 1, 1968. [No date.J Quail Management. , Agricultural Resear'ch Service, Missouri Department of Conserva­---Pesticides Regulation Division. tion, Jefferson City: Missouri. 1970. Registered vertebrate animal Stockdale, T. control agents list with computer 1973. Population estimates. Proc. data codes. Rodenticide Handbook Sixth Bird Control Seminar', Staff· Bowling Green State University, , Consumer Marketing Service. pp. 268-270. -Y§"68. Federal Seed Act of August 9, Stuart, R. W. 1939. reprinted April 1968. 1975. Depredation, a continental pp. 33-37. problem. Duck Unlimited, Sept.-Oct. , Federal Extension Service, and -:-7"'--:::: pp. 42-45. the Bureau of Sport Fisheries and Wild­ Texas Department of Health, Veterinary life, U.S. Department of the Interior. Public Health Division. 1965. Birds on the farm; Benefits 1973. Poison bait rabies can.trol and damages. For internal use program conducted in Concho and only. Menard counties, Texas. October'. U.S. Department of the Interior. Thomas, J. W., and D. C. McC Luskey. 1959. Characteristics of common 1974. Effects of aerial appLication roden ticides. Fish and Wild­ of DDT for tussock moth control of life Service, Wildlife LentZ. nestling survival of mountain 337.

25 U.S. Department of the Interior. environmental hazards (pesticides). 1965. Economic poisons registered by [Part 4 of Hearings of August 20 and the Division of Wildlife Services, 21, p. 936.] Bureau of Sport Fisheries and Wild­Wagar, J. V. K. life. Bureau of Sport Fisheries and 1972. Humane wildlife control. Proc. Wildlife, Division of Wildlife of The 96th Annual Meeting of Services. the American Humane Association, October 8-11, Denver, Colorado. pp. 1965. Pesticide-wildlife studies by 48-65. states, provinces, and universities; Wagner, F. H., C. D. Besadny, and C. An annotated list of investigations Kabat. through 1964. Circular 224. Fish 1965. Population ecology and manage­ and Wildlife Service. ment of Wisconsin pheasants. Wisconsin Conservation Department, 1972. Damage reduction methods. Tech. Bull. No. 34. pp. 2-5. Bureau of Sport Fisheries and Ward, J. C., and D. A. Spencer. Wildlife, Denver Wildlife Research 1947. Notes on the pharmacology Center. of sodium fluoroacetate-compound 1080. J. Pharm. Sci. 34(2): --r973. Trapping. [Memorandum from the 59-62. Director to the Assistant Secretary Wiens, J. A., and M. 1. Dyer. for Fish and Wildlife and Parks, 1973. Application of an avian November 27, 1973.] Bureau of Sport bioenergetics simulation model to Fis heries and Wildlife. red-winged blackbird-crop relations. Proc. Sixth Bird Control Seminar, 1976. Progress report on: Effects of Bowling Green State University. pp. environmental contaminants on wild­139-163. life ecology; Cooperative safety Wingard, R. G., and C. R. Studholme. tests of se.lected chemicals on 1976. Wildlife damage con trol. nontarget organisms, 1975-1977. Wildlife Management Extension, DFTM Activity No. 3.6.1. Pennsylvania State University, University Park, Pennsylvania. [No date.] Mammal damage con­Wood, J. R. trol research-mainland agricultural 1973. Appendix: report--efficacy of crops. Work Unit DF-103.6, Quar­coyote control methods and livestock terly Report, pp. 45-56. Bureau of losses. [From an EPA Environmental Sport Fisheries and Wildlife, Denver Impact Statement.] Wildlife Research Center. World Health Organization. 1962. Toxic hazards of pesticides to [No date.] Mammal damage con­man; Twelfth report of the Expert trol research-Hawaiian agricultural Committee on Insecticides. Techni­ crops. Work Unit DF-103.7, Quar­cal Report Series No. 227, Geneva. terly Report, pp. 46-47. Bureau of pp. 25-26. Sport Fisheries and Wildlife, Denver Wildlife Research Center. 1962. Occupational healt h problems in U.S. Senate Committee on Government agriculture; Fourth report of the Operations, Subcommittee on Reorganiza­joint ILO/WHO Committee on Occupa­ tion and International Organizations. tional Health. Technical Report 19.63. Interagency coordination in Series No. 246. pp. 16-18.

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