EXPERIMENTAL USE PERMIT APPLICATION 

BY: 

Scimetrics Ltd. Corp. 

Wellington, CO 80549 

TITLE: 

Field Efficacy of Kaput® Feral Hog Bait for Population Control of Feral Hog (Sus scrofa) in 

Texas 

DATE OF APPLICATION: 

June 7, 2013 

MAIN CONTACT: 

Sue Valentine 

Scimetrics Ltd. Corp. 

P.O. Box I 045 

Wellington, CO 80549 

Ph. 970-482-1330 

sue@scimetricsltd.com 
EUP Application Page 2 of20 

Table of Contents 

Section A: Chemical and Physical Properties of Test Chemical and Statement of Formulation of 

Active and Ineti Ingredients ...................................................................... ........... ........................... 3 

Section B: Proposed Experimental Label ........................................................... ........................... 5 

Section C: Toxicity Data .................................................... ........................................................ .... 9 

Section D: Residue Data ........................ ............ .......................................................................... 10 

Section E: Effectiveness Data ...................................................................................................... 11 

Section F: Tolerance Data ............................................................................... ............................. 12 

Section G: Proposed Experimental Program .......... ...... ... ............................................................ 13 
EUP Application Page 3 of20 

Section A: Chemical and Physical Properties of Test Chemical and Statement of 

Formulation of Active and Inert Ingredients. 

TEST CHEMICAL: Warfarin C19H1604 (M.W. 308.4g) 

0 

NOMENCLATURE: Common name warfarin (BSI, E-ISO, BAN); warfarine ((m) F-ISO); 

coumafene (France); zoocoumarin (USSR); coumarins (JMAF, also applied to coumatetralyl 

(q. v.)); no name (The Netherlands). 

IUPAC name (RS)-4-hydroxy-3-(3-oxo-1-phenylbutyl)coumarin; 

3- (o. -acetenyl benzyl) -4-hydroxycoumarin 

Chemical Abstracts name 4-hydroxy-3-(3-oxo-l-phenylbutyl)-2H-l-benzopyran-2-one 

Other names coumaphene 

CAS RN [81-81 -2] unstated stereochemistry; [5543-58-8] (R)-(+)-

isomer; [5543-57-7] (S)-(-)- isomer EC no. 201-377-6 (RS)· isomers; 226-908-9 (R)- isomer; 

226-907-3 (S)- isomer 

PHYSICAL CHEMISTRY: Mol. wt. 308.3 M.f. C19H1604 

Form The racemate forms colourless crystals. M.p. 161 -162°C V.p.l.S x 10·

3 mPa Solubility In 

water 17 mg/1 (20°C). Very slightly soluble in benzene, diethyl ether and cyclohexane. 

Moderately soluble in methanol, ethanol and isopropanol. In acetone 65, chloroform 56, dioxane 

100 (all in g/1 , 20°C). Dissolves in aqueous alkalis with the formation of water-soluble salts. 

Sodium salt: in water up to 400 g/1; insoluble in organic solvents. Stability Very stable, even to 

strong acids. pKa It is acidic 

APPLICATIONS: Biochemistry General internal bleeding is induced by reduction of the 

prothrombin content of the blood. Mode of action Anticoagulant rodenticide. Repeated ingestion 

is necessary to produce toxic symptoms. The ( 5)-(-)- isomer has 7-fold greater rodenticidal 

activity than the (R)-(+)- isomer (B. D. West et al., J. Am. Chem. Soc., 1961, 83, 2676). Uses 

Control of rats and mice; also control of grey squirrels for tree protection, by presentation of bait 

in special hoppers. There is no tendency to bait-shyness. Compatibility Compatible with other 

rodenticides. 
Page 4 Redacted (Confidential Statement of Formula for Product} 
EUP Application Page 5 of20 

Section B: Proposed Experimental Label 
EUP Application Page 6 of20 

FOR EXPERIMENTAL USE ONLY 

Not for sale to any person other than a participant or cooperator of the EPA-approved 

Experimental Use Program. 

{Back/Side/Below} 

Kaput® Feral Hog Bait 

Active Ingredient: 

Warfarin (CAS Number81-81-2) ......................................................... 0.005% 

Other Ingredients .................................................................................. 99.995% 

Total ......................................................................................................... 100.000°/o 

Keep Out of Reach of Children 

CAUTION 

See back [side] panel for First Aid and additional Precautionary Statements. 

EUP No. _ _ __ _ EPA Est. 72500-C0-1 

Net Wt. lbs. 

{251bs.- 100 lbs.} 

[11 .34 kg - 45.36 kg] 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. 

This label must be in the user's possession at the time of product application. 

READ THIS LABEL: 

Read this entire label and follow all use directions and use precautions. 

IMPORTANT: Do not expose children, pets, domesticated animals or other non-target wildlife to this product. To help 

prevent accidents: 

1. Store product not in use in locations out of reach of children, pets, domesticated animals and wildlife. 

2. Apply this product only as specified on this label. 

3. Dispose of product container as well as unused, spoiled, or recoverable unconsumed bait, as specified on this 

label. 

USE RESTRICTIONS: This product may be used to control only feral hogs (Sus scrofas) on rangeland, forests, noncrop areas, and crop lands. 

• Do not apply this bait on the ground. 

• Use a HOGHOPPERTM feeder or similar feeder with heavy lid that prevents non-target animals from accessing 

the bait. 

• Apply bait in fenced areas and avoid application in open range areas. 

• Wear protective gloves when handling bait or animal carcasses. 

• Store this product out of reach and away from humans, domesticated animals, pets and wildlife. 
EUP Application Page 7 of20 

• Do not allow young children, pets, domesticated animals or persons not associated with the application to be in 

areas where the bait is being applied. 

SITE ASSESSMENT: Before applying this product, observe the area to identify where feral hog activity and trails are 

evident. Look for damaged crops, rutting of the soil and tracks to ensure activity in the area. 

BAIT APPLICATION: Place 25-100 pounds of bait into each feeder. The animal access door must be closed limiting 

access only to feral hogs. Treatment should continue for 10-21 days and the feeder monitored and refilled as 

needed, approximately every 2-5 days depending on number of feral hogs visiting the feeder. Leave no bait on soil 

surface or outside the feeder. Collect and properly dispose of all bait that may have spilled outside the feeder. After 

treatment, collect and properly dispose of any bait that may have fallen out of the feeder. 

SURVEILLANCE AND FOLLOW UP: Dead feral hogs may begin to appear in or near the treatment areas within 4-7 

days after bait placement. Applicators must return to the treatment site within 4 days of application, and at 2-5 day 

intervals thereafter, to inspect each feeder and to collect and properly dispose of any bait or dead or dying feral hogs 

found on the surface. All carcasses found must be collected and disposed of properly. Bury carcasses on site in 

holes dug at least 18 inches deep. If burial is not practical (due to frozen ground, etc.) and other disposal methods 

are allowed by state and local authorities, collected carcasses may be disposed of by other methods to insure that 

carcasses are inaccessible to scavengers. Continue to collect and dispose of feral hogs and search for non-target 

animals for at least two weeks after the last filling of the bait feeder boxes. Deaths of any animals other than feral 

hogs, that appear to be the result of baiting, must be reported to state authorities. 

STORAGE AND DISPOSAL 

Do not contaminate water, food or feed by storage or disposal. 

Pesticide Storage: Store in original container in a cool, dry place inaccessible to children and pets. 

Pesticide Disposal: Wastes resulting from the use of this product may be disposed of on site or at an approved 

waste disposal facility. Container Handling: Non-refillable container; do not reuse or refill this container. Offer for 

recycling, if available, or reconditioning, if appropriate; otherwise, dispose of empty container in a sanitary landfill. 

{Per PR Notice 2007-4 the batch code/lot number will appear on the label or container.} 

PRECAUTIONARY STATEMENTS 

Hazards to Humans and Domestic Animals 

CAUTION: Harmful if swallowed. Keep away from humans, domestic animals and pets. Any person who retrieves 

carcasses or unused bait following application of this product must wear protective gloves. 

FIRST AID 

Have the product container or label with you when calling a poison control center or doctor or going for treatment. 

You may also contact the National Poison Information Center at 1-800-858-7378 for emergency medical treatment 

information. 

If swallowed, immediately call a poison control center or doctor for treatment advice. Have person sip a glass of 

water if able to swallow. Do not induce vomiting unless told to do so by the poison control center or doctor. Do not 

give anything by mouth to an unconscious person. 

If in eyes, hold eye open and rise slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, 

after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice. 

TREATMENT FOR PET POISONING 

If animal eats bait, call veterinarian at once. 
EUP Application Page 8 of20 

NOTE TO PHYSICIAN OR VETERINARIAN 

Contains Warfarin, an anticoagulant. If swallowed, this material may reduce the clotting ability of the blood and cause 

bleeding. For humans or animals that have ingested this product and/or have obvious poisoning symptoms (bleeding 

or prolonged prothrombin times), give Vitamin K1 intramuscularly or orally. 

ENVIRONMENTAL HAZARDS 

This product may be toxic to fish, birds and other wildlife. Dogs and other predatory and scavenging mammals and 

birds might be poisoned if they feed upon animals that have eaten the bait. Do not apply this product directly to 

water, to areas where surface water is present or to intertidal areas below the mean high-water marl<. Do not 

contaminate water when disposing of equipment wash waters. 

Manufactured by: 

~ Suimet.r•it;s LTD. C 0 RP. 

New Solurions :o O ld P roblems 

[Pest Management Solutions) 

P.O. Box 1045 

Wellington, CO 80549 

(970) 482-1330 

customerservice@kaputproducts.com 

Made in USA 

{ } Denotes language that does not appear on the market label 

[ ) Denotes alternate language 
EUP Application Page 9 of20 

Section C: Toxicity Data 

Warfarin Toxicity Data 

Species Acute Oral LD50 (mg/kg/ Chronic Oral LD50 (mg/kg/day)' 

Mouse 374 0.6 for 3-9 days 

Rat 3.0 0.4 for 4-15 days 

Rat 50-100 1 for 5 days 

Rabbit 800 30.0 for 6-15 days 

Swine 3 0.05 for 7 days 

Dog 20-50 5 for 5-15 days 

Cat 6-40 3.0-5.0 for 10 days 

Cat 5-50 l for 5 days 

Ruminants - 200 for 12 days 

Chicken 1000 - I . .. Tunm, R. M. 1994 Vertebrate PestiCides. Pages G26-G29 In (S.E. Hyngstrom, R. M. Timm, and G. E. Larson, 

eds.) Prevention and Control of Wildlife Damage. University ofNebraska Cooperative Extension. 

Adfusted Toxicity Data for Warfarin Concentration Found in Bait 

Species Acute Oral LD50 Chronic Oral LD50 

(mg of Bait/kg) (mg of Bait/kg/day) 

Mouse 7,480,000 12,000 for 3-9 days 

Rat 60,000 8,000 for 4-15 days 

Rat 1,000,000-2,000,000 20,000 for 5 days 

Rabbit 16,000,000 600,000 for 6-15 days 

Swine 60,000 1,000 for 7 days 

Dog 400,000-1 ,000,000 100,000 for 5-15 days 

Cat 120,000-800,000 60,000-100,000 for I 0 days 

Cat 100,000-1,000,000 20,000 for 5 days 

Ruminants - 4,000,000 for 12 days 

Chicken 20,000,000 -

MAMMALIAN TOXICOLOGY: Oral Acute oral LD50 for rats 186, mice 374 mg/kg. Oral 

LD50 for rats 1, pigs 1, cats 3, dogs 3, cattle 200 (all mg/kg daily for 5 days). ADIIRID (EC) 

Not applicable [2006]; (EPA) cRfD 0.0003 mg/kg b.w. [1988]. Other Organ damage is 

observed, as well as inhibition of blood coagulation. Only slightly dangerous to humans and 

domestic animals when used as directed, but care must be taken with young pigs, which are 

especially susceptible. Toxicity class WHO (a.i.) lb; EPA (formulation) 1. EC classification 

R611 T; R48/25 1 R52, R53 for (R)-, (5)-, or (RS)- isomers). 
EUP Application Page 10 of20 

Section D: Residue Data 

Not applicable- Studies will be completed on rangelands and the product will be applied in a 

HOGHOPPERTM or similar feral hog specific feeder. 
EUP Application Page II of20 

Section E: Effectiveness Data 

The effectiveness of this product will be determined by the data generated from this EUP 

research. However, previous studies conducted by Genesis Laboratories, Inc. have shown 100 % 

efficacy of a 0.005 % warfarin feral hog bait in pen trials. The acute LD50for warfarin in swine 

is 3 mg/kg for single dose or 0.05 mglkg for 7 days. In light of this data we are confident that 

bait formulations used in this EUP research will be shown to be effective. 
EUP Application Page 12 of20 

Section F: Tolerance Data 

There are no EPA Maximum Residue Levels for residues of warfarin in food or feed. The 

product will be applied in a manner to prevent contact with vegetation or crops. All test animals 

that consume the test product will be sampled to determine residue levels. Dye 

will also be evaluated on test animals as a preventative against human consumption of exposed 

animals. The test animals will be disposed to prevent any consumption of test animals. 
EUP Application Page 13 of20 

Section G: Proposed Experimental Program 

1. Participants and Collaborators 

Field testing using Kaput® Feral Hog Bait containing 0.005% warfarin will be organized 

and completed by Genesis Laboratories, Inc. having its principle place of business at 

101 22 N.E. Frontage Rd., Wellington, CO 80549. All major participants in this study 

will be University graduates with backgrounds in biology wildlife biology or associated 

field. The key participants are: 

Richard M. Poche 

Robyn R. Raban 

Christopher S. DePemo 

Kevin J. Aldrich 

President and Technical Manager of Genesis Laboratories, 

Inc. with an M.S. in Wildlife Biology and over 40 years of 

experience in pest control product development. I have 

conducted research in over 50 countries including projects 

in wildlife management and management of invasive and 

pest species. I have led development of several pest and 

vector management products which includes acqumng 

patents and bringing products to market. 

Senior Vector Ecologist at Genesis Laboratories, Inc. with 

M.S. in Medical Entomology and Ph.D. candidate in Vector 

Biology and Arbovirology. Has been the principal 

investigator for multiple vector control projects. 

Associate Professor, Fisheries, Wildlife, and Conservation 

Biology at North Carolina State University. Certified 

Wildlife Biologist with over 22 year of experience and over 

stx years of experience conducting feral hog disease 

research. 

Biologist/ Assistant Lab Manager at Genesis Laboratories, 

Inc. with a M.S. in Biology and over 12 years of laboratory 

and research experience. I have conducted research in, 

wildlife management, animal disease diagnostics, swine 

epidemiology research, and ecotoxicology research. I have 

been the study director for multiple animal research 

projects and have extensive experience as an Institutional 

Animal Care and Use Committee (IACUC) chairperson. 

2. State in Which Product will be used 

This study will be conducted in the state of Texas with final field locations yet to be 

determined. The field sites will be determined based on sufficient numbers of feral hogs 

and perimeter fencing to eliminate human disturbance to field sites. 
EUP Application Page 14 of20 

3. 

The treatment area will be approximately 1- 10 km2 depending of feral hog densities. 

Study site will be chosen to ensure 50 to 100 feral hogs. The treatment area will not 

exceed 10 km2

. The total amount ofbait applied will not exceed IO,OOOJbs. 

Target Species Feral hog (Sus scrofa) 

Location of Study Texas: Hall, Motley, Jones, or Briscoe counties. 

Sites of Application Bait will be applied in feeders located at sites with active feral 

hog sign. The feeders will be spaced to limit duplicate hog 

visitation. 

Desire Time of Bait may be applied from spring to summer and not overlapping 

Application big game hunting seasons. 

Use Pattern Bait stations will be regularly monitored and will be kept filled 

for the duration of the 3 week experimental phase of the study. 

Plot Size Not to exceed 10 km" or 2,471 acres. 

Dose Rate Ad libitum. 25-100 lbs. of bait will be applied to each bait 

station. 

Frequency of Bait stations will be refilled as needed for the duration of the 3 

AQPlication week experimental phase. Approximately every 3-4 days. 

Method of Application Bait will be presented in feeders designed to restrict access 

animals other than feral hogs. 

Season of Use Late spring, summer, or early fall. 

Amount of bait Kaput® Feral Hog Bait maximum amount required = 12,600 lbs. 

required 

Amount of Active 0.63 lbs. warfarin. 

Required 

Disposition of Unused Genesis Laboratories, Inc. will arrange to have unused bait 

Bait incinerated. 

4. Information on Prior Testing. 

Previous work conducted at Genesis Laboratories, Inc. has provided preliminary data 

needed for this field study. In pen trials several bait concentrations were evaluated for 

efficacy as a feral hog bait. Baits with warfarin concentrations of 0.025% were found to 

have 100% efficacy when fed for 2 days. Baits with warfarin concentrations of0.0125% 

were found to have 1 00% efficacy when fed for 5 days. Baits with warfarin 

concentrations of 0.005% were found to have 100% efficacy when fed for 5 days. Based 

on these results it was determined that bait with 0.005% warfarin would be effective and 

reduce any risk to non-target animals. 

A 0.005 % warfarin bait such as Kaput® Feral Hog Bait provides several advantages. 

With anticoagulant baits such as this symptoms of poisoning will not develop until after a 

lethal dose is consumed preventing development of bait shyness(Godfrey & Lyman, 

1980). Therefore, baits can be used that require multiple feedings to provide a lethal 

dose. Because the warfarin bait lends itself to multiple feedings it allows for the dose to 

be reduced drastically which will reduce risk to non-target animals. With multiple doses 
EUP Application Page 15 of20 

required, non-target poisoning is much less likely because the non-target animal~ will 

need to consume multiple doses in succession to receive a lethal dose. In the same 

manner multiple doses reduce the risks of secondary. 

5. Objectives of the proposed EUP program 

The objectives of the proposed study are to determine the following: 

A. To determine the efficacy of Kaput® Feral Hog Bait for control of feral hogs, 

containing 0.005% warfarin, when presented in HOGHOPPERTM feral hog 

feeders in a field setting. 

B. To generate product performance data in support of FIFRA registration for 

Kaput® Feral Hog Bait for control of feral hogs. 

C. To generate safety data during field use of product including; preventing nontarget animal exposure by using hog specific bait station, preventing potential 

human exposure by evaluating Dye presence in baited animals, 

and determining secondary expo luating residue levels in tissues of 

baited animals. 

6. Justification of Quantity of Material Requested 

The material requested was calculated by estimating the consumption for an average size 

feral hog at approximately l 00 lbs. A hog this size would typically need about 5-6 lbs. of 

grain per day. Therefor for a maximum of 100 hogs that consume 6 lbs. bait per day for 

the maximum of 21 days of treatment we will use a maximum of 12,600 lbs. The actual 

amount used will not exceed 12,600 Jbs. and will be monitored and documented. Any 

excess test material will be incinerated. 

7. Duration of the EUP program 

The study will include a pre-exposure census of approximately 3 weeks. During this time 

a passive tracking index will be calculated following the method described by (Engeman, 

Constantin, Nelson, Woolard, & Bourassa, 2001). Additional census methods may be 

employed as needed depending or terrain and population densities. The exposure period 

will be conducted directly following the pre-exposure census and will last up to 3 weeks. 

Following the exposure period there will be a 3 week post-exposure census. The total 

duration of the experimental phase of the study will be approximately 9 weeks with up to 

3 weeks of bait application. The duration may be longer if data justify a need for 

additional study. 
EUP Application Page 16 of20 

S tu d y Ph ase A ,pprox1mate D ura f 10n 

Pre-exposure census 3 Weeks 

Exposure period 3 Weeks 

Post-exposure census 3 Weeks 

8. Disposition of any Unused Material 

Any remaining Kaput® Feral Hog Bait will be disposed of by Genesis Laboratories, Inc. 

at the conclusion ofthe study. 

9. Special Concerns 

Four special concerns have been addressed to meet suitable risk to implement a feral hog 

toxicant using warfarin as an active. 

1) Large amounts of anticoagulant bait in bait stations: There is concern that there 

will be a large amount of toxic bait in relatively small areas. This could pose a 

risk to non-target animals if they are able to access the bait stations. 

Response: The HOGHOPPERTM bait stations have been thoroughly tested and 

found to be effective at eliminating access to non-target animals. The bait stations 

will be continuously monitored by motion activated camera to assure that nontarget animals are unable to gain access to the bait. At the concentrations 

proposed in this study the bait requires multiple exposures to be lethal to nontarget animals. Given the unlikely access of non-targets to the bait and the 

continued monitoring it is extremely unlikely that non-target animals would be at 

risk from the presence of large amounts of bait in the bait stations. Additionally, 

by having the bait in specific sites rather than broadcast it will limit the number of 

non-target animals that will be in close proximity of the test substance and 

therefore reduce potential for non-target animal exposure. 

2) Spillage from the bait station during feral hog consumption: There is concern that 

some of the bait may be spilled by the feral hog or that small amounts might be 

transported by the feral hogs to distant locations and not consumed. This could 

make the bait available to non-target animals as primary consumers. 

Response: While some spillage is possible it should not pose a threat to nontarget animals for the following reasons: Any spillage will likely be limited to 

small areas localized around the bait station. The bait is specifically designed for 

optimal palatability for feral hogs and as such it is likely that many non-target 

animals will not fmd it palatable. The active concentration is low and would 

require multiple feedings to cause poisoning. The bait stations will be regularly 

monitored and if spillage of bait is observed it will be removed to prevent nontarget access. Access to enough spilled feed for multiple feeding is unlikely from 

spilled feed. Additionally, the active in use has a vitamin K antidote for 

inadvertent exposure to companion animals. 
EUP Application Page 17 of20 

The greatest overall risk assessment for birds and mammals as determined by 

(Erickson & Urban, 2004) for 250 ppm warfarin showed a greatest primary risk to 

birds to be 0.04 and for mammals 0.83. When adjusted by l/5th for the proposed 

bait at that is l/5th 250 ppm the concentration, the greatest primary risk for birds 

drops to 0.008 and for mammals 0.17. This level ofrisk is quite low considering 

that there are additional procedures in the bait presentation to further limit nontarget exposure. 

Genesis Laboratories, Inc. has conducted studies to assess risks to non-target 

animals that may directly consume warfarin baits. A 14 day choice test study 

with Bobwhite quail (Colinus virginianus) exposed to a bait with the same active 

as proposed in this EUP showed results that indicated the non-target exposure risk 

to be quite low(Soniat, 2010). The bait in the study was ground up to have a 

similar consistency to the challenge diet, which is a good representative of spilled 

or partially eaten baits by feral hogs. The choice test showed a low acceptance of 

ll %. This is to be expected when a bait formulation is designed for a different 

target animal and would suggest that non-target animals would choose other diets 

when available, which should be the case in the field setting for this study. In 

addition, the consumption of bait containing 250 ppm warfarin over 14 days did 

not lead to any observable signs of poisoning. A similar study was also done with 

Mallard duck (Anas platyrhynchos) exposed to a 250 ppm warfarin bait in a 14 

day choice test and 7 day no choice test (Poche, 2008 MRID 48528603). This 

study showed an avoidance of the bait in the choice test and no signs of poisoning 

in the choice or no choice tests. In the table below please see a summary of 

toxicity studies conducted by Genesis Laboratories, Inc. The summary also 

includes studies conducted on other actives that are more toxic than warfarin. 

Summary ofRelated Primary Exposure Studies Conducted by Genesis 

Laboratories, Inc. 

Active Bait Choice/ Test Animal Mortality Reference/ 

Ingredient Concentration No MRID 

Choice 

Warfarin 250 ppm Choice Bobwhite None Genesis 

Quail 10010 

Warfarin 250 ppm Both Mallard None 48528603 

Diphacinone 25 ppm Choice Mallard None 48373005 

Diphacinone 25 ppm Bobwhite None 48373002 

Quail 

3) Secondary Poisoning of Birds and Mammals from Poisoned Hogs: There is 

concern that the feral hogs that consume the bait be consumed by predators and 

scavengers that could acquire the toxin secondarily. 

Response: Feral hogs are particularly sensitive to warfarin. When chronically 

exposed the LDSO is 0.05 mg/kg/day for 7 days. For this reason relatively low 

concentrations of active in the bait are effective. With the concentration of active 
EUP Application Page 18 of20 

proposed it is expected that the residues in the tissues of baited feral hogs will be 

at low risk levels. (Saunders, Kay, & Parker, 1990) determined that secondary 

poisoning risks are low due to the fact that warfarin residues in feral hog tissues 

decline rapidly and that baited feral hogs typically die several days after the 

poison has been consumed. Considering that the mean half-life of warfarin in 

humans is only 42 hours (Penumarthy & Oehme, 1978), and that bait 

consumption will decrease rapidly when toxicological symptoms begin, it is 

reasonable to conclude that feral hogs that die due to bait consumption should 

pose minimal risk to scavengers and predators. 

The greatest overall risk assessment for birds and mammals as determined by 

(Erickson & Urban, 2004) for 250 ppm warfarin showed a greatest secondary risk 

to birds to be 1. 72 and for mammals 1.32. When adjusted by 1/51

h for the 

proposed bait at that is 1 /51

h 250 ppm the concentration, the greatest secondary 

risk for birds drops to 0.34 and for mammals 0.26. This level of risk is quite low 

considering that the residues in the carcasses of feral hogs should decline rapidly. 

Genesis Laboratories, Inc. has conducted several studies to investigate to possible 

secondary toxicity to various animals that consume carcasses of warfarin 

poisoned animals. A study of Black-billed Magpies (Pica pica) that were fed 

warfarin poisoned Norway rat carcasses for 5 consecutive days showed zero 

mortality (Mach, Jeff J. and March, 1997 MRID 44995004). The Norway rats 

were fed a 500 ppm bait until mortality was observed which is 10 times higher 

than the concentration proposed in this EUP application. A similar study of 

domestic ferrets (Mustela putorius furo) that were fed warfarin poisoned Blacktailed prairie dogs (Cynomys ludovicianus) carcasses for 5 consecutive days 

showed zero mortality (Mach, 1998 MRID 44995003). A secondary toxicity 

study using the American Alligator (Alligator mississsippiensis) that were fed 

warfarin poisoned Norway rat carcasses for 5 consecutive days showed zero 

mortality(Poche, 2008 MRID 48373008). Warfarin blood residues were 

investigated and a maximum of 200 ppb was detected and a mean of 110 ppb at 1 

day after exposure. The Norway rats in this study were fed a 250 ppm warfarin 

bait until mortality was observed. In the table below please see a summary of 

secondary toxicity studies conducted by Genesis Laboratories, Inc. The summary 

also includes studies conducted on other actives that are more toxic than warfarin. 

s urnmarv o fS econdarv T oxic1tv Studies c on d ucted b G >V enes1s Laboratones I nc. 

Active Ingredient Bait Secondary Mortality Reference 

concentration Animal MRID 

given to primary 

animal 

Warfarin 500 ppm Black-billed None 44995004 

Magpie 

Warfarin 500 ppm Domestic Ferret None 44995003 

Warfarin 250 ppm American None 48373008 

Alligator 
EUP Application 

I Bromadiolone I 50 ppm I Prairie 

Rattlesnake I 

Page 19 of20 

None 

4) Consumption of Poisoned Animals by Humans: There is concern that may people 

hunt and eat feral hogs and could potentially eat a has eaten the bait. 

Response: We have developed a strategy to use Dye in the baits. 

When eaten this dye will be sequestered in that fat of the animal turning the fat 

tissue a bright blue color. The color alone should be enough to discourage any 

consumption of the dyed animal products. However, advertisement can be 

included in hunting regulations to warn hunters not to eat tissues from animals 

that show the blue color. Please see the attached picture to see that dramatic 

effect of the Dye that should drastically discourage human 

consumption of any pOisoned feral hog. 

Dye. 

5) Risk of Warfarin Entering Ground Water: The baits will be exclusively used in 

bait stations that will keep the bait off the ground and out of any standing water. 

The solubility of warfarin is only 17mg/l limiting the risk of hazardous amounts 

of warfarin entering the ground water. Additionally, the bait will be in a wax 
EUP Application 

References: 

Page 20 of20 

block form which will further prevent the possibility of warfarin leaching out of 

the bait and into the ground water. 

Erickson, W., & Urban, D. (2004). Potential Risks of Nine Rodenticides to Birds and Nontarget 

Mammals: a Comparative Approach (pp. 1-225). 

Godfrey, M., & Lyman, C. (1980). Preliminary dosing trials of a new anticoagulant, 

brodifacoum, as a toxicant for the rabbit, Oryctolagus cuniculus (L.). New Zealandjournal 

of experimental ... , (May 2013), 37~1. Retrieved from 

http://www.tandfonline.com/doi/full/1 0.1080/03015521.1980.10426224 

Mach, J. J. (1998). Secondary Hazard Study Using Warfarin-Killed Prairie Dogs (Cynomys 

ludovicianus) Fed to Domestic Ferrets (Musella putorius furo) (pp. 1- 64). 

Mach, Jeff J. and March, K. L. (1997). Secondary Hazard Study Using Warfarin-Killed 

Laboratory Rats Fed ro Black-billed Magpies (Pica pica) (pp. 1- 21 ). 

Penumarthy. L., & Oehme, F. (1978). Treatment and protherombin responses during warfarin 

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