Submit to the APVMA rodenticide review | Rat Poison

Submit to the APVMA rodenticide review

The Australian Pesticides and Veterinary Medicines Authority (APVMA) is currently seeking submissions on the proposed regualtion of dangerous rat poisons.

Join us in calling for all SGARs to be removed from public sale, to protect our wildlife into the future.

Be sure to personalise the template below and include your details so that your comments are considered.

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To: Australian Pesticides and Veterinary Medicines Authority (APVMA)

I am writing to express my deep concern about the continued public availability of Second-generation Anticoagulant Rodenticides (SGARs) in Australia and the inadequacies of the proposed regulatory measures to prevent harm to wildlife.

During the 4 years the APVMA spent reviewing the dangers of SGARs, countless wildlife has continued to die from SGAR poisoning. A substantial body of Australian and international evidence demonstrates that SGARs pose an unacceptable risk to native wildlife through both primary and secondary poisoning. Scientists further uncovered alarming levels of SGAR poison in Aussie birds, with one study spanning two decades in Tasmania found SGAR rat poison has been found in 74% of dead, endangered Wedge-tailed Eagles (Pay et al, 2021). Over 100 species of Australian bird, mammal, reptile, and amphibian have been exposed to deadly SGARs. Wildlife exposure to secondary poisoning often occurs, even in compliance with label instructions.

Instead of removing these toxic poisons from shelves, the APVMA has proposed a set of inadequate measures that won’t stop the killing of our precious native wildlife. There is no evidence that the use of bait boxes, pack size limits, proximity to building rules and label changes will prevent wildlife exposure under real world conditions. Importantly, they also do nothing to stop the predominant pathway killing our wildlife: secondary poisoning. A poisoned animal does not die at the bait station; they become toxic time bombs, wandering around sick for up to 10 days...easy prey for predators and scavengers, like threatened raptors and quolls.

Consumers should be able to walk into stores under the reasonable assumption that the products readily available to them are not going to inadvertently kill native animals, even when they follow the labels. Routine, widespread public use of long-lasting SGARs is killing wildlife on a national scale. Australia’s wildlife doesn’t need more paperwork or new fine print on labels; it needs less poison in the environment. The proposed changes won’t do this.

Other countries (e.g. US, Canada, and many countries in Europe) have already prohibited public sale of SGARs to protect wildlife and ecosystems. Australia is lagging severely behind. We’re an international outlier, and our wildlife is dying because of it.

I strongly urge the APVMA to:

1. Permanently withdraw all SGAR products from public sale and restrict their use to licensed, trained professionals under strict regulatory controls.

2. Create a National Stewardship Program to perform tasks such as: review training and certification courses for professional pest controllers, track SGAR use and deployment by licensed professionals, implement and fund wildlife-monitoring programs, and create an online reporting tool for alleged instances of non-compliance.

3. Promote safer, wildlife-friendly alternatives, including mechanical or electronic traps and non-anticoagulant options that pose much lower risks to wildlife and pets.

4. Recommend Integrated Pest Management (IPM) strategies that prioritise non-SGAR control methods (e.g. owl nest boxes to support owls that eat rodents) for rodent management.

Protecting Australia’s unique biodiversity and precious pets is critical. Please act now to reduce the devastating impact of SGARs. The best way to ensure that birds are protected from unnecessary poisoning is to suspend the public use of SGARs permanently.

Thank you for considering my submission.

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