DEMAND AN URGENT APVMA REVIEW

Dr. Chris Parker, CEO, APVMA; Ms. Lisa Croft, Deputy CEO, APVMA; Dr. Maggie Hardy, Chief Regulatory Scientist, APVMA

On Tuesday morning, the first dog died.

There is no excuse. There is no justification good enough to forgive the trauma endured by the families or the suffering their four-legged family members are forced to experience in their last hours on Earth.

The Australian Pesticides and Veterinary Medicines Authority (APVMA) has the legislative power to STOP companion animals suffering and dying by 1080 poison.

This petition calls on the APVMA to urgently, thoroughly, and transparently reconsider the approval and registration of 1080 poison.

Stand with us today. Australia, it's time: enough is enough.

1080 is inhumane. There is no antidote. Help ensure others don't suffer tomorrow by demanding an urgent APVMA review today.

Together, we can ban 1080.

To: Dr. Chris Parker, CEO, APVMA; Ms. Lisa Croft, Deputy CEO, APVMA; Dr. Maggie Hardy, Chief Regulatory Scientist, APVMA
From: [Your Name]

As a signatory to the following petition, I hereby add my name and details requesting the Australian Pesticides and Veterinary Medicines Authority (hereafter, 'the APVMA’), as the statutory authority responsible for the regulation of agricultural and veterinary chemicals, to thoroughly, transparently and urgently review the use of sodium (mono-)fluoroacetate (CAS#62-74-8) (Compound 1080 / “ten-eighty”) poison as a vertebrate control toxin in Australia. 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 of concerned Australians urges the APVMA to conduct an immediate review of the continued use of 1080 in Australia. As such, the following petition holds that:

Sodium (mono-)fluoroacetate, more commonly known as 1080, is a schedule 7 poison used extensively throughout Australia in attempts to control unwanted or unwelcome wildlife considered threats to agricultural efficiency and/or environmental amenity (TGA 2017). It notes that Safe Work Australia classifies 1080 as an extremely hazardous, highly toxic chemical (SWA 2016). It notes, further, that it is considered a “homicidal poison” by law enforcement and forensic scientists (Trestrail 2007) and is “highly toxic to mammals, including humans” (AOAC International 2015). It is considered inhumane (Sherley 2007), indiscriminate (McManus et al. 2014), and slow-acting (Howard and Schmidt 1984; Eason et al. 2010). Due to these substantial and inescapable inefficiencies, coupled with their subsequently significant and fatal flaws, 1080 as a vertebrate poison was "severely curtailed [in most countries] by 1990" (Proudfoot et al., 2006). Earlier, in mid-1972, the US Environment Protection Authority (EPA) issued cancellation and suspension notices, effectively banning 1080 via mechanisms currently available to the APVMA.

As one of the few nations in the world that continues to rely on 1080, 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.

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 and ultimately, entirely avoidable and unacceptable (Kalmbach 1948). That the owners of animals lost to 1080 experience considerable trauma in witnessing such a protracted and tortuous death must be considered. Under the relevant legislation, namely the Agricultural and Veterinary Chemicals Code Act 1994 (hereafter, ‘AGVET’ or ‘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”. That illegal baiting has been uncovered in Australian LGAs requires an urgent analysis of the risk assessment procedures applicable to 1080. That chemical pesticide production employees have been hospitalised is a significant matter the APVMA must also consider.

Significantly, s1A(2)(d) provides for “unmanageable risks” to the health and welfare of humans, animals and the environment, insofar as “the use of chemical products” that are shown to pose such risks are “not appropriate in Australia”. That this is secured via "appropriate, proportionate, consistent, and effective compliance and enforcement measures” is noted (s1A(2)(f)). As it relates to the present petition, s1A(2)(e) provides for consideration of "community confidence" in the APVMA's capacity to act as outlined above. Finally, s127 (‘Suspension and cancellation of licences’) of the Code, specifically s127(2A)(a-b), must be applied in an urgent and transparent manner insofar as an institutional failure to act in suspending or cancelling a licence may result in “imminent risk” to human, animal, and/or environmental health and welfare.

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

(a) 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. It is understood that the
Code is part of a cooperative statutory scheme established to evaluate, register,
and control agricultural and veterinary chemical products;

(b) 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;

(c) 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;

(d) 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;

(e) 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”;

(f) 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.

Thus, 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).

As an an independent statutory authority, the APVMA is responsible for the ongoing regulation of agricultural and veterinary chemicals across the country. It can reconsider the approval of any chemical so used, its registration or its approval at any time. It is noted that such a reconsideration has been undertaken in the past. The APVMA is empowered to reconsider such decisions (s166). Similarly, it is noted that a review of any subsequent decisions made in relation to this request may be made (s167).

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.

The APVMA is expected to conduct a policy of transparency as it relates to this request and future correspondence.