EXPERIMENTAL USE PERMIT APPLICATION BY: Scimetrics Ltd. Corp. Wellington, CO 80549

TITLE: Field Efficacy of Kaput® Feral H og Bait for Population Co ntrol of Feral H og (Sus scrofa) in Texas

DATE OF APPLICATION: June 7 , 2013

MAIN CONTACT: S u e Valentine Sc imetri cs Ltd. Corp. P.O. Box I 045 Wellington , C O 80549 Ph. 970-48 2 -1330 sue @ scimetricsltd.comEUP Application Page 2 of20

Tab le of Content s Section A: Chemical and Physical Properties of Test Chemical and Statement of Formu l ation of Ac tiv e and Inet i Ingre d ients
.............................................................. . ..... .. ....... . . .. ......... .... .......... .... 3 Section B: Proposed Experime ntal Labe l
... .... ...... .... ........... .. ........ ... . .. ... .. .. ... . .. .. . .. ...... ... ............... 5 Section C: T oxici t y Data
...... ..... ...... .......... . ................... .. . .. ........ .. ............................................ .. .... 9 Section D: Residue D a t a ... ........ . ......... ... .......... .. .. . ....... .... ..... ... . .. . .. .. ............ . .................. .. . ....... . .. 10 Section E: Effec tiveness D ata
...... . ........... . .. . ....... . ...................................................... . .. .. ........ ... . . 11 Section F: Tol erance Data
.. .......... .. .. . ....... . ........................................... . . . ...... .. .. . ........ .. . .. ......... .. . . 12 Section G: Proposed Ex perimental Program
. ...... . .. .... .. . .. ........ ..... ....... . . .... ...... ..... . . ....... . ....... . ..... 1 3EU P Application Page 3 of20
Section A: Chemical and Physical Properties of Test Chemical and Statement of Formulation of Active and Inert Ingredients.

T EST CHEMICAL: Warfarin C19H1604 (M.W. 308.4g) 

## 0

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

- ISO) ; coumafene (France) ; zoo coumarin (USSR); coumarins (JMAF, also applied to coumatetralyl (q. v.)) ; no name (The Ne th erla nds). IUPAC name (RS)-4-hydroxy-3 -(3- oxo -1-pheny lbutyl)coumarin; 3- (o. -aceteny l 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)-( -)- i somer EC no. 201-377-6 (RS)· isomers; 226-908-9 (R)- isom er; 226-907-3 (S)- isomer PHYS ICAL CHEMI STRY: Mol. wt. 308.3 M.f. C19H1604 Form The racemate forms co l ourless crystals. M.p. 161 -162°C V.p.l.S x 10 · 3 mPa Solubility In water 17 mg/1 (20 ° C). Very slightly solub le in benzene, diethyl ether and cyclohexane. Moderately so luble in methano l , ethan o l and iso propan o l. In acetone 65 , chlo roform 56 , dioxane 100 (all in g/1 , 20°C). Disso lves in aqueous alkalis with the formati on of water-soluble salts. Sodium salt: in water up to 400 g/1; insoluble in organic solvents. Stability Very stab le , even to strong ac i ds. pKa It i s acidic APPLICAT IONS: Biochemistry General internal bleed ing is induced by reduction of the prothrombin co ntent of the blo o d. Mode of action Anticoagul ant rodenticide. Repeated inges tion is necessary to produce toxic symptoms. The (5)-(-)

- isomer has 7- fold greater rodenticidal activity than the (R) -( +) - i somer (B. D. West et al., 

### J. Am. Chem. Soc., 1961, 83, 2676). Uses Co ntro l of ra ts and m ice; al so control of grey sq uirrels fo r tree protection , by presentation of bait in special hoppers. T here is no tendency to bait- s hynes s. Compatibility Compatible with other rodenticides.Page 4 Redacted (Confidential Statement of Formula for Product}EUP Application Page 5 of20



### Section B: Proposed Experimental LabelEUP Application Page 6 of20
FOR EXPERIMENTAL USE O NLY 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 l bs

.} [11

.34 kg
- 45

.36 kg]

DIRECTIONS FOR USE It is a violation of Federal l aw to use this product in a manner inconsi stent with its labeling. Th i s la be l must be in the user' s possession at the time of product app licatio n. 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 chil dren , pets , domesticated an imals an d wildlife. 2

. Apply this product on ly as specified on this labe l. 3. Dispose of product container as well as unused , spoiled , or recove rable unconsumed bait, as specified on this label. USE RESTRICTIONS: This product may be used to control on ly feral hogs (Sus scrofas) on rangeland , forests , noncrop areas , and crop l ands. • Do not apply thi s bait on the ground. • Use a HOGHOPPER TM feeder or similar feeder with heavy lid that prevents non- t arget animals from accessing the bait. • Apply bait in fenced areas and avoid application in open range areas. • Wear protective gloves when handl i ng bait or animal carcasses . • Store this product out of reach and away from humans , domesticated animals , pets and wil dl ife.EU P Applicatio n 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 so il 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 ba it 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 interva ls thereafter , to i nspect 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 i s not practical (due to frozen ground , etc. ) and other di sposal methods are allowed by state and local authorities, collected carcasses may be di sposed of by other methods to insure that carcasses are inaccessible to scavengers. Conti nue to collect and dis pose 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 disposa l. 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 landfil l. {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 la bel with you when calling a poison control center or doctor or going for treatment. You may also contact the National Poison Information Center at 1-800-858-73 78 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 le n ses , if present , after the first 5 minutes , then continue ri ns i ng 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 Pag e 8 of20

NOTE TO PHYS I CIAN OR VETER I NARIAN 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 (b leed i ng or prolonged prothrombin times) , give Vitamin 

### K1 intramu scu larly 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 ba it. Do not app ly this product directly to water , to areas wh ere surface water is present or to intertidal areas be l ow the mean high-wa ter marl<. Do not contaminate water when disposing of equipment wash waters.

Manufactured by:

# ~ 

# Suimet. r•it;s

LTD. C 0 RP. New So lurions :o O ld P rob lems [Pest Management Solutions) P

.O

. Box 1045 Wellington, CO 80549 (9 70) 482-1330 customerservice@kaputproducts

.com Made in USA

{ } Denotes language that does not appear on the market label [ ) Denotes alternate languageEUP Application Page 9 o f20
Section C: Toxicity Data

Warfarin Toxicity D ata Species Acute Oral LD50 (m g/kg/ Chronic Oral LD50 (mg/kg/day)' Mouse 374 0.6 for 3-9 days

Rat 3.0 0.4 for 4-15 day s R at 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 1 0 days Cat 5-50 l for 5 days Ruminants

- 200 for 12 days

Chicken 1000

- I

. ..

Tunm , R
. M
. 1994 Vertebrate PestiCides. Pages G 2 6-G29 In (S.E. Hyngs trom , R. M. Timm , and G. E. Larson , eds.) Prevention and Co ntro l of Wildlife Damage. University ofNebraska Cooperative Extension. Adfusted Toxicity Data for Warfarin Concentration Found in Bait Species Acute Oral LD50 Chronic O r al LD50 (mg of Bait/kg) (mg of Bait/kg/day) Mouse 7,480,000 12,000 for 3-9 day s

Rat 60 , 000 8,000 for 4-15 day s 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 dail y 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. Onl y s lightly dangerou s to humans and domestic animals when used as directed , but care must be take n with young pigs , which are especially suscept ibl e. Toxicity class WHO (a .i .) lb ; EPA (formu lation) 

### 1. EC classification R611 T; R48/25 1 R5 2 , R53 for (R)- , (5)-, or (RS)

- i somers).EU P Application P age 10 of20


### Section D: Residue Data

Not applicab le- Studies will be compl eted on rangelands and the product will be applied in a HO GHO PPER TM or si mil a r fe ral h og spec ifi c feeder.EUP Application Page II of20
Section E: Effectiveness Data

Th e effectiv en ess of this product will b e determin ed by the data ge nerated from this EUP research . H owever , prev ious stu dies conducted by Ge nes i s Lab oratories, Inc. have shown 100 % efficacy of a 0.005 % warfarin feral ho g bait in pe n trials. The acute LD5 0for warfarin in swi ne is 3 mg/kg for s ingle dose or 0.05 mglkg for 7 days. In light of thi s data we are co nfiden t that bait formul ati o ns u sed in this EU P research will be s hown to be effec tive.EUP Application Page 12 of20


### Section F : Tolerance Data

There are no EPA Maximum Residue Levels fo r 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 lev els. Dye will also be evaluated on test animals as a preventativ e again s t human consumption of exposed ani mal s . The t est animals will be disposed to prevent any co nsumption of te st animals.EUP Application Page 13 of20
Section G: Prop osed Experimental Program 1. Participants and Collaborators Field testing using Kaput® Feral Ho g 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. Fro ntag e Rd
. , Wellington, C O 80549. All major participants in th is study w ill 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 Lab oratories , Inc. with an M.S. in Wildlife Bi o logy and over 40 years of experience in p est control product development. I have conducted research in ove r 50 countries including projects in wildlife management and management of invasive and pest species. I have led development of severa l pest and vecto r management products which includes acqumng patents and bringing products to market. Senior Vector Eco lo g ist at Genesis Laboratories , Inc. with M.S. in Med ical Entomology and Ph.D
. candidate in Vector Biology and Arbovirology. Has been the principal investigator for multiple vector control projects. Associate Professor, Fi sheri es, Wildlife, and Conservation Biology at North Carolina State University. Certifi ed 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 d iagnos tic s , swine epidemiology research, and ecotox icology research. I have been th e stu dy director for multiple animal research projects and hav e exte nsive experience as an Institutional A nim al Care and U se Committee (IACUC) c hairpers on. 2. State in Wh i ch Product will be used This s tudy will be conducted in the state of Texas wi t h final field locations yet to b e determ ined
. The field s ites will be determined based on sufficient numbers of feral hogs and pe rimeter fenc ing to eliminate human disturbance to field sites.EU P Application Page 14 of20

3. The treatment area will be approximately 1- 10 km2 depending of fera l hog densities. Study site will be chosen to ens ure 50 to 100 feral hogs. The treatment area w ill not exceed 10 km 2

. The total amount ofbait app li ed will not exceed IO,OOOJbs.
Target Specie s Feral hog (Su s scrofa) Location of Stud y Tex as: Hall, Motley, Jones , or Briscoe counties. Sites of Application Bait will be appl ied in feeders l ocated at sites w ith active feral hog sign. The feeders will be spaced to limit duplicate ho g visitation. Desire Time of Bait may be applied from sprin g to summer and not overlapping Application big game hunting seas ons. Use Pattern Bait station s will be regularly monitored and will be ke p t filled for the duration of the 3 week experim ental ph ase o f the study. Plot Size Not to exceed 10 km " or 2,471 acres . Dose Rate Ad libitum
. 25-1 00 lbs. of bait will be appli ed to eac h bait sta t ion. Frequency of Bait sta tions w ill be refilled as needed fo r the dura t ion of the 3 AQPlication we ek ex perim e ntal phase. Approximately e ve r y 3- 4 days. Method of Applicat ion Bait wi ll be presented in feeders designed to restrict access animals other than feral hog s. Seaso n of Use Late spring , su mmer, or e arl y fa ll. Amount of bait Kaput ® Feral Hog B ait maximum amount required = 12 , 600 lbs. required Amount of Active 0.6 3 lbs. warfa rin. Required Di spos it ion of Unused Genesis Lab o ratories, Inc. will arran ge to h ave unused bait Bait incinerated. 4. Information o n Prior Tes tin g. Previous work conduct e d at Genesis Laboratories, Inc. has provided p rel imin ary d ata ne eded for this fi e ld s tudy. In pen tria l s several ba i t concentratio ns w ere evaluated for efficacy as a feral ho g bait. Baits with warfa rin co nc entrations of 0.025% we re found to have 100% e fficacy whe n fed for 2 days . B ait s with w arfarin conce ntratio ns of0.0125% we re found to have 100 % efficacy when fed for 5 day s. Baits wi th warfarin co n centra ti on s of 0.00 5% were found to have 100% efficacy when fed for 5 days. Based on the se results it was de te rm i ned that bait with 0.005 % warfarin would be effective and r edu ce any ri sk to non-target animals. A 0.005 % warfarin bait such as Kaput ® Feral Ho g Bait provides several advan tages. With an ticoa g ulant b ait s such as this sy mptom s of po isoning will not dev e lop until after a lethal dose is consumed preventing development of ba i t shyness(Godfrey & Lym an , 1980). Ther e fore, baits can be used that requi re multiple feedings to provi d e a lethal dose. Becau se t he w arfarin bait lend s itse lf to multiple fee din gs it allows for t he dose t o be reduced drastically wh ich w ill redu ce risk to non-target animals. With multiple dosesE U P Application Page 15 of20 

### required, no n -target poisoning is much less likely because the non - targe t**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 determi ne the efficacy of Kap ut ® 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 pro duct perfo rmance 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 leve l s in tissues of bai ted 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 n ot exceed 12 , 600 Jbs. and will be monitored and documented. Any e xce s s 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 e xperimental phase of the study will be ap proximately 9 weeks with up to 3 weeks of bait application. The duration may be longer if data justify a need for additional s tudy.EUP Application Page 16 of20
S d Ph

tu y ase A ,pprox1mate 

## D f ura 10n Pre-exposure census 3 Weeks Exposure period 3 Weeks Po st-ex po sure 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 suitab le risk to implement a feral hog tox icant using warfarin as an active
. 1) Large amounts of anticoagulant bait in bait station s : There is concern that there wi ll be a large amount of toxic bait in relatively small areas. This could pose a ri sk to non-target animals if they are able to access the bait stations. Response: The HOGHOPP E RTM bait stations have been thoroughly te sted and found to be eff ective at eliminating access to non-target animals. The bait sta tion s will be con tinu o usl y monitored by motion activated camera to assure that nontarget animal s are unable to gain access to the bait. At the concent rations proposed in this study the bait requires multip le ex posures to be lethal to nontarget animals. Given the unlikely access of non-targets to t h e bait and the co ntinu ed monitoring it is extremely unlikely that non -target animals would be at risk from the presence of large amounts of bait in the bait sta tion s. Additionally , by having the bait in specific s ites rather than broadcast it will lim it th e number of non-target animals that will be in close proximity of the test substance and therefore reduc e potential for non-target animal exposure. 2) Spillage from the bait stat ion during feral hog consumption: There is concern that so me of the bait may be spilled by the feral hog or that small amount s might be transported by the feral hog s to distant loc at ions and not consumed. This could make the bait available to non-target animals as primary consumers. Response: Whi le some spillage i s possible it should not pose a threat to nontarget anima l s for the following reasons: Any spillage will likely be limited to small areas localized around the bait station. The bait is spec ifically 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 conce ntratio n is low and would require multiple feedings to cause poisoning. T he bait stations will be regularly mon itored and if spilla ge of bait is observed it will be removed to p reve nt nontarget access. Access to enough spilled feed for multip le feeding i s unlike ly from sp illed 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 ri sk asse ssment for bird s and mammals as determin ed by (Er ick so n & Urban , 2004) for 250 ppm warfarin s howed a greatest primary risk to birds to be 0.04 and for mammals 0
. 83. When adjusted by l/5th for the proposed ba it at that is l/5th 250 ppm the co nc entration , the greatest pr i mary risk for birds drops to 0.008 and for mammals 0.17. This level ofrisk is quite low considering that there are addition al procedures in the bait presentation to further limit nontarget ex po s ure. Genesis Laboratories , Inc. has co ndu cted studies to assess ri sks to non-target animals that may directl y consume warfarin baits. A 1 4 day cho ice test study wi th Bobwhite quail (Colinus virginianus) exposed to a bait with the same ac t ive as p roposed in this EUP s ho wed results that indi cated th e non-target exposure ri sk to be quite low(Soniat , 2010). The bait in the study was ground up to have a s i milar consistency t o the challenge d iet, whi ch is a good representative of sp ill ed or partially eaten baits by fe ral hogs
. The c hoic e test showed a low acceptance of ll %. This is to be expected when a bait formulation i s designed for a different targe t an imal and would suggest that non-target animals would choose other diet s when avai lab le , which should be the case in the field sett ing for this study. In add i tion, the consumption of bait containing 250 ppm warfarin over 14 days did not lead to any observable signs of pois o ning
. A s imilar study was also do ne with Mallard duck (Anas platyrhynchos) exposed to a 250 ppm warfari n bait i n a 14 day choice test and 7 day no choice test (Poche, 20 08 MRID 48528603). Thi s study s howed an avo idance of the bait in the choice test and no sig n s of poiso ni ng in the choice or no choice tests. In the table below p lease see a summary of toxicity studi es conducted by Genesis Laboratories, In c. The summ a ry also includes studies conducted on other activ es that are more toxic than warfar in.
Su mmary ofRelated Pr imary Expos ure Stud ies Conducted by Genesis Laboratories, Inc. Active Bait C hoice/ Test Animal Mortal ity Reference/ Ingred ient Conce n tration No MRID Ch oice Warfarin 250 ppm Choice Bobwhite None Ge nesi s Qua il 100 1 0 Warfarin 250 ppm B o th Mallard None 48528603 Diphac i none 25 ppm Choic e Malla rd None 48373005 Diphac inone 25 ppm B obwhite None 48373002 Quai l
3) Secondary Poi so ning of Birds and Mammals from Poisoned Hogs: There is concern th at the feral hogs that co n sume the bait be cons umed by pred ators and scavengers that could acquire the toxin secondarily. Response: Feral hogs are particularly se nsitive to warfarin
. Whe n chronically exposed the 

### LDSO is 0.05 m g/kg/d ay for 7 day s . F or t hi s reason rel atively low concentrations of activ e in the bai t are effective. With the concentration of activeEU P Application Page 18 of20
prop osed it is ex pect ed that the res idues in the tissue s o f baited feral hog s will be at low risk levels. ( Sa unders, Kay , & Parker , 1990) determined that secondary poi so ning ri s k s are low due to th e fact that warfarin residues in feral ho g ti s sues de c line rapidl y and that baited fe ral ho gs typi call y die several days afte r the poi so n has bee n consumed. Considering that the mean half-lif e of warfarin in humans is only 42 hours (P enumarthy & Oehme , 1 978) , and that bait consumption will decrease rapidly when t oxi colo g ica l symptoms be gi n, it is reaso nabl e to co nclude that f er a l hogs th at di e due to bait consumption sh o uld po se minima l ri sk to scavengers and predators . The g reatest overall risk assessme nt for b irds and mammals as determin ed by (Erickson & Urban, 2004) for 250 ppm wa r fari n showed a greatest se cond ary risk to birds to be 1. 72 and for mammal s 1. 32
. When adjusted by 1/5 1h for the prop ose d bai t at that i s 1 / 5 1 h 250 ppm th e concentrati on, the greatest seco ndary ri sk for birds drops to 0.34 and f or mamm a ls 0.26
. T hi s level of ri sk i s quite lo w con s idering th at the re s idu es in th e carcasses of feral ho gs should decline ra pidly. Gen es is Laboratories, In c. has conducted several studies to invest igate to poss ible seco ndary toxicity to various a nimal s that cons ume car casses of warfarin poi so ned animals. A s tudy of Black-billed Magpie s 

### (Pica pi ca ) that were fed warfarin poi so ned Norway r at carcasse s for 5 consecutive days showed zero mortality (Mach , Jeff J. a nd March, 1997 MRID 44995004). The Norway rats were fe d a 500 ppm bait until mortali ty was observed which i s 10 time s higher th an the conc e ntration proposed in this EUP applic a tion. A s imi l ar study of domestic ferrets 

### (M ustela putorius fu ro ) that were f ed warfarin poisoned Bl ackta il ed prairi e dogs 

### ( C ynomys ludovicianus) carcasses for 

### 5 co n se cutiv e days showed zero mortality (Mac h , 1998 MRID 4499500 3 ). A secondary tox ic ity study usi n g th e Ameri can Allig a tor 

### (Alliga tor mississs ippiensis) that were fed w arf ari n poi soned No rway r at carcasses for 5 consecutive d ay s sh owed zero mortality( Poche, 2008 MRID 48373008). Warfari n blood residue s were investiga ted and a ma x imum of 200 ppb was detected and a m ean of 1 10 ppb at 1 day afte r exposure . The No rw ay rats in thi s study were fed a 250 ppm warfarin bait until morta lity was observed. In the table bel ow p le as e see a summary of seconda ry toxici ty studies conducted by Gen esi s Laboratories, Inc. T h e summary al so include s s tudies conducted on ot her acti ves that are more to x ic than warfarin. 

## s fS

urnmarv o eco ndarv T oxic1tv Studies 

# c d b G o n ucted >V enes1s Lab oraton es I nc. Acti ve Ingredient Bait Secondary Mortality Ref erenc e concentration Animal MRI D g ive n to primary animal W arfarin 500 ppm Bla ck- billed None 44995004 Magp ie Warfa rin 500 ppm D omestic Ferret None 44995003 Warfa rin 250 ppm American None 48 3 73008 A lli gatorEUP Application 

# I Bromadiolone 

# I 50 ppm 

# I Prairie Rattlesnake 

# I Page 19 of20
None 4) Consumption of Poisoned Animals by Hum ans: There i s 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 co lor. 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 hun ters not to eat tissues from animals that show the blue color. Ple ase 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 so lubility of warfarin is onl y 17mg/l limiting the risk of hazardous amounts of 

### warfarin entering the ground water. Additiona lly, the bait will be 

### in a waxEUP Application

References: Page 20 of20
block form which will further prevent the pos s ibility of warfarin leaching out of the bait and into the gro und wat er.

Erickson, W., & Urban , D. (2004)
. Potential R isks of Nine Rodenticides to Birds and Nontarg e t Mammals: a Co mparativ e Approach (pp. 1-2 25). Godfrey , M. , & Lyman , C. ( 1 980). Preliminary do si ng trials of a new anticoagulant , brodifacoum , as a toxicant for the rabbit , Oryctol agus cuniculus (L.). Ne w Zea landjournal of experimen tal
... , (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 Us ing Warfarin-Killed Prairie Dogs (Cynomys ludovicianus) Fed to Domestic Ferret s (Muse lla putorius furo) (pp. 1

- 64)
. Mach, Jeff J. and Ma rch , K
. L. ( 1 997). Secondary Hazard Study Using Warfa rin-Killed Laboratory Rats Fed ro Black-billed Magpies (Pic a pica) (pp. 1

- 21 )
. Penumarthy. L. , & Oehme, F. ( 1 978). Treatment and protherombin respon ses during warfarin toxicos i s in rats and mice . Toxi cology, 10,**37 7~01.**  Retrieve d from http://www. sc ienc edi rect.co m/sc ience/arti cle /p ii /0300483X78900859 Poc h e , Richard M., and Jef f J. Mach
. "Wild li fe primary an d secondary toxici t y stud ies w ith warfarin." A CS Symposium Series . Vol. 771. Washington , DC ; American Chemical Society; 1999 , 2 000
. Poche, D. (2008). Ex po s ure of Nutria Bait to Mallard Ducks (Anas platyrhyncho s) (p p . 1-2 0). Poche, R
. M. (2008)
. Se co ndar y Toxicity Study with American Alligators (A lligator mississippiensi.s)fed War fa rin Killed No rwa y Rat s ( Rattu s nor vegicus) (pp. 1

- 26). Saunder s , G. , Kay , B. , & Parker , 

### B. ( 1 990). Evaluat ion of a warfarin poisoning programme for f eral pi gs (Su s sc r ofa)
. Wildlife Research, (1987 ) , 525

- 533. Retrie ved from http ://www .pub li sh.csiro.au/?paper ==WR9900525 S oniat , M. (2010). Expo sure ofKaput Combo B ait M ini Blocks to North ern B obwhite Quail (Colinu s virginianus) EPA Regi s trati o n No. 72500- I4 , (72500) , 1**~0.**