As a signatory to the following petition, I hereby add my name and details requesting the Australian Pesticides and Veterinary Medicines Authority ('APVMA’), as the statutory authority responsible for the regulation of agricultural and veterinary chemicals across Australia, to thoroughly, transparently and urgently review the use of sodium (mono-)fluoroacetate (CAS#62-74-8) as a vertebrate control poison. I and the signatories note that the APVMA may reconsider approval or registration at any time, as per Part 2, Division 4 of the relevant Code.

Thus, the following petition holds that:

1) Sodium (mono-)fluoroacetate, more commonly known as 1080 poison (“ten-eighty”), is a schedule 7 poison used throughout Australia in attempts to control unwanted or unwelcome wildlife. It notes that Safe Work Australia classifies 1080 poison as an extremely hazardous, highly toxic chemical and that it is considered a “homicidal poison” by law enforcement and forensic scientists. It is “highly toxic to mammals, including humans” and is considered inhumane, indiscriminate, and slow-acting. Due to these substantial and inescapable inefficiencies, the use of 1080 poison as a vertebrate poison was severely curtailed in most countries by the 1990s. Earlier, in the 1970s, the US Environment Protection Authority (EPA) issued cancellation and suspension notices, effectively banning 1080 poison via mechanisms currently available to the APVMA;

2) Under the relevant legislation, namely the Agricultural and Veterinary Chemicals Code Act 1994 (‘the Code’), the signatories of the present petition maintain that the APVMA is endowed with the legislative powers under the relevant legislation necessary to reconsider and/or review the approval and use of products, as per sections 31-34 of the Code. Part of this process involves requiring existing registrants to provide additional information when necessary, as per the compliance responsibilities cited in the Code (i.e., s132; s132A; s132D), provided these actions are not in contravention of the obligations outlined in Division 5. Further, s1A(2)(a-b) maintains that the Code must be implemented in a manner which prioritises “the health and safety of human beings, animals, and the environment” and which ensures that this process “reflects established best-practice principles for the assessment and management of risk”;

3) That S1A(2)(d) states that chemical products posing 'unmanageable risks' to human, animal, and environmental health are deemed unsuitable for use in Australia. This is contingent upon the implementation of 'appropriate, proportionate, consistent, and effective compliance and enforcement measures' (s1A(2)(f)). Additionally, s1A(2)(e) emphasizes the importance of 'community confidence' in the APVMA's regulatory actions. Under s127, licenses must be suspended or cancelled promptly and transparently if there is a risk of 'imminent harm' to human, animal, or environmental welfare due to institutional failure to act";

4) That as one of the few nations in the world that continues to use 1080 poison, Australia must urgently catch up with the rest of the world and initiate an urgent review into the unintended impacts and threats posed by this poison today;

5) That canids have been known to be extremely susceptible to 1080 poison for over five decades makes the suffering that companion animals endure tragically avoidable. That the owners of animals lost to 1080 poison experience considerable trauma in witnessing such a protracted and tortuous death must be considered;

6) That illegal baiting has been uncovered in Australian LGAs requires an urgent analysis of the risk assessment procedures applicable to 1080 poison;

7) That chemical pesticide production employees have been hospitalised is a significant matter the APVMA must also consider;

In summary, I hereby request the APVMA to transparently assess and re-evaluate contemporary risks to human health, animal safety and welfare, and product efficacy posed by its continued use. I do so on the following grounds as per the governing legislation:

1) that the APVMA is endowed with the necessary legislative powers required to reconsider and review the approval of products under Sections 31-34 of the Agricultural and Veterinary Chemicals Code Act 1994 ('the Code'). It is understood that the Code is part of a cooperative statutory scheme established to evaluate, register, and control agricultural and veterinary chemical products;

2) that part of this review process involves requiring existing and approved registrants to provide additional information on products when necessary, as per compliance responsibilities under the Code;

3) that Section 1A(2)(f) legislates that the above (b) is secured via "appropriate, proportionate, consistent, and effective compliance and enforcement measures". Critically, Section 1A(2)(e) considers "community confidence" in the APVMA's capacity to do so. I thereby hold that this present petition fulfils this criteria and, as such, requires the APVMAs transparent consideration;

4) that Section 1A(2)(d) of the Code refers to the inappropriate nature and use of chemical products if and when they pose "unmanageable risks" to the community, animals, or the environment;

5) that inspectors have monitoring powers and may draw upon these to monitor for compliance. Failure to comply may result in the "suspension or cancellation" of approvals or registration should it appear to fail safety criteria or “any requirement prescribed by the regulations”;

6) that relevant trial work may be conducted to generate results needed for consideration. It notes that under Section 31, the APVMA may do so and that it may do so "at any time" (s31(1)). The present request considers the potential and ongoing likelihood of harm to animals and the environment to warrant the application of this provision.

Finally, the present petition calls upon the APVMA to conduct a thorough and transparent review of 1080 poison across Australia. This is in line with APVMA policy regarding the encouragement of "openness and transparency in its activities and community involvement in decision-making" (APVMA 2008).

The guiding purpose of the APVMA is the "protection of the health and safety of people, animals, the environment, and agricultural and livestock industries through regulation of pesticides and veterinary medicines”. The signatories of this petition maintain that the APVMA is obliged to transparently and thoroughly consider this civil request. We hereby call on the APVMA to do so, urgently.