EVALUATION OF FACTS IN REGARDS THE REGISTRATION OF 1080

M.J de Wet

 After studying the literature received from the Poison Working Group I found nothing to support the registration of 1080. The information rather supports my viewpoint and with a final summery of the negative attributes that render 1080 unsuitable I remain committed to oppose the registration of 1080. 

One of the major problems 1080 is variation and inconsistencies. 

• In his review of hazards by 1080 to some live organisms in the United States of America, Eisler (1995) summerizes some of the environmental findings well. In distilled water solution at room temperature 1080 showed no breakdown in ten years. In an aquarium with plants and invertebrates 1080 was undetectable within 100 hours, but in a stagnant algal laden pond 1080 did not lose its biocidal properties in 12 months.

• In a study in Australia a control project ended unsatisfactorily, partly because the 1080 broke down to quickly (McIlroy et al 1986), while Twigg et al (2000) found 1080 meat baits retained it’s toxicity for more that 8 months.

• Bait preparation techniques and different kinds of baits have produced different amounts of detectable 1080 in the baits. This is attributed to biochemical reaction rather than physical loss of poison (Kramer et al 1987)

• Some species showed increased tolerance for 1080 after repeated sub-lethal dosages, while others showed cumulative effects until a lethal dose is reached (McIlroy 1981)
• Variation with age & sex of LDs of the same species.
• Variation of LDs under different temperatures.
• We know that defluorination happens through enzymatic action from microorganisms and that their presence vary form area to area and because of rain, heat and pH of the soil. Where the organisms occur in the soil defluorination can be about 90%, but sometimes it is only 2% of the applied 1080. In Australia areas were found where none of the defluorinating organisms occur in soils (Wong et al 1992, King et al 1993).

Fluoroacetate is detoxified by defluorination – In contrast with claims by Gerhard Verdoorn and Willie van Zyl that 1080 is a very labile molecule, Goldman (1965) indicated that this chemical bond has “great stability”  (it withstands boiling, non-concentrated sulfuric acid, fusion happens at 500º, and refluxing in 30% NaOH is needed to achieve complete liberation of fluoride). However, the break can be achieved enzymatically by a number of bacteria and fungi, such as species of the genera Pseudomons, Nocardia, Aspergillus, Fusarium, Penicillin) Wong et al (1992). Twigg & Socha (2001) Identified 13 bacteria and 11 fungi that defluorinate 1080 in Australian soils, and indicate that, in the drier areas the abundance of the organism numbers are greatly influenced by rain. It can be accepted that not all the organisms that can defluorinate 1080 have been identified and that an area has to be tested to know whether any of such organisms occur in that locality.

 The difference of opinion and variations in the literature on the speed of breakdown of 1080 in baits and the rest of the environment can be explained by the fact that the breakdown happens due to the bacteria and fungi.

 If the organisms are present in the environment or bait, defluorination happens quickly. If the bait is uncontaminated the 1080 remains toxic for months or even decades.

This allows for the possibility to engineer baits that can detoxify in a predictable manner, where baits can be treated with bacteriostats and fungistats, or irradiated and inoculated with known amount of a known species (of bacteria or fungus with the defluorination enzyme) that can defluorinate the 1080 in a predictable time. However this will still be related to temperature, moisture and pH as well as other factors that will regulate the growth conditions for the bacteria and fungi.

 Willie van Zijl kept accusing me of having a hidden motive for opposing 1080 registration. May I remind him that I have asked him personally for literature to support his viewpoint more than two years ago and never received anything. Even now after the enforced exchange of the literature I still received nothing to support his view. 

More points that bother me and for which I can see no obvious or short-term solutions include:

• Lack of LDs for South African animals.
• Lack of knowledge on the occurrence, abundance and effectivity of defluorinating micro-organisms in South Africa.
• Humane grounds. Except for severe symptoms in predators (worse than strychnine), sub lethal doses have been demonstrated to leave long term lesions that can be debilitating enough to prevent breeding and/or lead to the animals death over an extended period. (EPA 1995)
• It has been found that various animals, including predators, developed resistance to 1080 where plants with 1080 in them occur. This indicates an unacceptably high stability of 1080 in the food chain.
• Large number of scientific publications that indicate secondary poisoning. Possum carcass remains deadly to a dog even 75 days after the poison was placed. As Prof. Naude indicated the citrate remains in the body of the dead animal.
• Insects eating the baits may pose a threat to insectivores.
• Vomiting constant symptom and pose danger to non-target animals. Anti-vomit drugs has been tried and met with limited success.
• “The sensitivity of a species to 1080 poison is difficult to predict from toxicity data for other closely related species.” (McIlroy 1986). With the PWG project, extrapolation is done even from unrelated exotic species. This is not acceptable.
•  Prof. G Swan, Head of Pharmacology and Toxicology at the Onderstepoort faculty came out in opposition of registering 1080.
• The Veterinary Association of SA has released a press statement, opposing 1080.

 LD₅₀ VALUES FOR CLOSELY RELATED ANIMALS

LD figure in italics indicate ALD estimate as described in Calver et al 1989

Effect of resistance development by animals to 1080 where 1080 containing plants occur should not be discarded. Difference between Western Australian and Southern Australian sub-populations of the same species sometimes huge – brushtail possum 117.50 – 0.64mg/kg and grey kangaroo 47 – 0.29mg/kg. The distribution of gifblaar (Dichapetalum cymosum) is limited at present, but significant climatic changes have happened in southern Africa within the last 20 000 years that could have meant a much wider distribution of Dichapetalum and a wide contact with the plant by our indigenous animals that might have led to resistance to 1080. Once attained there is not evolutionary pressure that will reverse the resistance even if the plants distribution changes (for 70 - 100 centuries in Australia). This however opens the possibility of LD values quite different to those expected through extrapolation. 

 The literature that I received from the PWG includes quite a number of references to the process that has to be followed to register a new poison in the USA. The number of different studies necessary dwarfs the work done here to date. Even when the work is done by governmental institution in the USA, external audit for maintaining standards and ensure Good Laboratory Practice (GLP) is compulsory. Formal study protocols are written that has to be inspected by a quality control (QC) officer. Standard Operating Procedures (SOP) are written for each research component. 

 Should we try to act responsibly to our environment or should a product be pushed through and registered on third world standards just because we might be able to get away with it?

 SLD bait is the worst of all the alternatives for damage control of jackal. The majority of damage causing individuals will not take bait. “…the real sheep killer among the black-backed jackal is impartial to carrion.” …”usually only the young, the stupid, and famished older jackals are trapped by poison.” “ …Persons setting out poison, should bear in mind that when dealing with a sheep killing black-backed jackal this will be in vain, …” Van der Merwe (1953)

 I cannot imagine why anybody would consider a toxin with this amount of variation and promote it as a viable solution to the current problems with poisons and it certainly has no advantages over the current strychnine.

 All my knowledge and experience with jackal cause me to believe that the dropper bait system has practically no chance of succeeding. It takes no cognition of known aspects of jackal behavior and phenomena like neophobia. The current experiment is based on indirect data – results will be based on default and not positive data. Will this be enough to register a new poison? I hope not!

 The African Large Predator Research Unit (ALPRU) under prof. H.O. de Waal commented on serious scientific problems in the design of the field test experiments for 1080. These comments has not been accommodated.

 There certainly are a number of negative aspects, as well as lots of uncertainty, on the desirability of 1080 in our environment – enough to invoke the Precautionary Principle of the environmental legislation and stop the registration of 1080.

 In an e-mail dated 21/06/04 Tim Snow requests about 160 publications on 1080. This is not in the spirit of cooperation as minuted by dr. King in the meeting of 30/04/2004. Reference lists would be exchanged and key references will be requested by the parties, to clarify the differences in perception that exists about 1080. Of the 160 publications at least half was published in well known, easily obtainable, scientific magazines with a worldwide distribution, dating from ‘70s trough to the ‘90s by well-known authors on 1080 like McIlroy and Twigg in Australia. Tim visited Australia some time ago to investigate the use of 1080. This request clearly indicates to me that the PWG did not do a proper literature survey to support their claims for registration of 1080.

 EVALUATION OF DOCUMENT TITLED “A Review Of Literature On The Use Of Compound 1080 (Sodium Monofluoroacetate) In Problem Animal Control Internationally”. BY WILLIE VAN ZYL AND REVIEWED BY PROF. G.H. VERDOORN AND MR. T.V. SNOW. (Dated 25 June 2004) 

I started reading the document with great interest, but was almost immediately disillusioned on the scientific content and incompleteness of the document. It is an obvious one-sided statement quoting only literature that suits the viewpoint of authors in an attempt to justify the use of this poison, while ignoring abundance of evidence that contra-indicate the use. In documents drawn up by myself 260 scientific articles are quoted and this list have been in the possession of the Poison Working Group for more then six months. This “literature review” quotes only about 60 articles and ignores well known authorities like J.C. McIlroy and L. Twigg who clearly illustrates serious problems, secondary poisoning and long term stability of 1080 in the environment. Both these authors each have published more than 15 articles from the 1980s through into the new millennium in scientific journals with international status and these are easily available in South Africa. I was able to obtain access to these articles with very limited time and resources to do so. The PWG has staff permanently on this subject and wants to introduce and register a poison in South Africa. It therefore is their duty to obtain all relevant data and present the full picture instead of the biased one presented at this stage.

 I find this document so incomplete and lacking that I will not dignify it with any further comment.

 I have a document on the table that can serve as the base. The Poison Working Group is welcome to disagree and comment, as long as they can substantiate their opinion with a holistic scientific backing.

 If the Poison Working Group refuse to look at the issue holistically there is no point in the continuance of our meetings and in that case other avenues to prevent their registering this unacceptable and environmentally damaging poison will be explored.

Literature:

 Calver M.C.; McIlroy J.C.; King D.R.; Bradley J.S. & Gardner J.L. 1989 Assessment of an approximate lethal dose technique for determining the relative susceptability of non-target species to 1080 toxin. Aust.Wildl.Res. 16  33-40

 Eisler R. 1995 Sodium Monofluoroacetate (1080) hazards to fish, wildlife and invertebrates: A synoptic review. Biological report 27, US Dept.Interior.

 EPA 1995 Registration Eligibility Decision (RED) Sodium Fluoroacetate. Report, United States Environmental Protection Agency.

 Goldman P 1965 Enzymatic cleavage of the carbon-fluorine bond in fluoroacetate. J.Biol.Chem. 240(8) 3434-343

 King D.R., Kirkpatrick W.E., Wong D.H. & Kinear J.E. 1993 Degradation of 1080 in Australian soils. In Seawright & Eason eds. 1993

 Kramer H.L., Merrell P.W. & Burren B.J. 1987 Use of sodium fluoroacetate (compound 1080) in the control of dingoes I. Meat bait preparation techniques. Aust.Wildl.Res. 14 p65-68

 McIlroy J.C. 1981 The sensitivity of Australian animals to 1080 poison. I. Intraspecific variation and factors affectig acute toxicity. Austr.Wildl.Res. 8 pp369-383

 McIlroy J.C. 1986 The sensitivity of Australian animals to 1080 poison IX. Camparisons between the major groups of animals and the potential danger non-target species face from 1080-poisoning campiagns. Austr.Wildl.Res. 13 pp39-48

 McIlroy J.C., Cooper R.J., Gifford E.J., Green B.F. & Newgrain K.W. 1986 The effects on wild dogs, Canis familiris, of 1080-poisoning campaigns in Kosciusko National Park, NSW. Aust.Wildl.Res 13 p535-544 

 Saewright A.A, & Eason C.T. 1993 Proceedings of the workshop on 1080. December 1993, Christchurch, New Zealand. The Royal Society of New Zealand Miscellaneous series 28.

 Twigg L.E. & Schoda L.V. 2001 Defluorination of sodium monofluoroacatate by soil microorganisms from central Australia. Soil Biology & Biochemistry 33 p227-234

 Twigg L.E., Eldridge S.R., Edwards G.P., Shakshaft B.J. dePreu N.D. & Adams N. 2000 The longevity and efficacy of 1080 meat baits used for dingo control in central Australia. Wildl.Res.27 473-481

Van der Merwe 1953 The jackal. Fauna and Flora. No. 4.

 Western Australian Government 2002. 1080 characteristics and use. Farmnote no.28/2002

 Western Australian Government 2002. 1080 summery information. Miscellaneous Publications no. 011/2002

 Wong D.H., Kirkpatric W.E., King D.R. & Kinnear J.E. 1992 Defuorination of sodium monfluoroacetate (1080) by microorganisms isolated from Western Australian soils. Soil  Biology & Biochemistry 24(9) 813-838