UMITEDSTATESENirbRSMR4ENIALPROTEGTIQMAGENCY WAS!-!iNC;TON. D.Z. 2i3460

SUBJECT: Sodium fluoroacetate RED- EEB science Chapter
TO: Dave Farrar Science ~nalysis and Environmental Fate FROM: Anthony F. Maciorowski, Chief Ecological Effects Division Environmental Fate and Effects
Attached is the EEB Science Chapter for the Sodium fluoroacetate

(Compound 1080) RED. The EEB has sufficientdata and/or information to complete a comprehensive risk assessment for both terrestrial and aquatic organisms from the use of Compound 1080 in the Livestock Protection Collar (LPC). The following is a summary of EEB1sassessment: 

## * Residue data indicatethat thegreatest exposureand potential for hazard comes from scavenging the neck area of the dead collared livestock and that secondary hazard from scavenging the carcass of the dead coyote and/or consuming vomit is, highly unlikely to pose any unacceptable risk. 

## * Results of feeding tests, simulated studies and actual field studies indicate that feeding behavior for many scavengers, decompositionof livestock carcasses,and the emeticnature of 1080 are all factors that greatly reduce the likelihood of exposure to non-target organisms below the Agency's level of concern. Inaddition, environmentalhazard statements,special use restrictions, and endangered species protection statements, that are required to be placed on the label, greatly reduce primary hazard to non-target organisms including endangered species. 

## * Based upon results of field studies, monitoring reports, low volume usage, environmental fate data, which suggests that 1080 is not likely to get into aquatic habitats, and residue analysis, that shows that the total amount of 1080 likely to be released into the environment is quite low, the EEB

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## ' DP BARCODE: D205845 REREG CASE # 3073 CASE: 819149 DATA PACKAGE RECORD DATE: 07/25/94 SUBMISSION: S470471 BEAN SHEET Page 1 of 1 

## * * * CASE/SUBMISSION INFORMATION

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. , CASE TYPE: REREGISTRATION ACTIOfJ: 623 INITIATE RED CHAPTER CHEMICALS: 075003 Sodium fluoroacetate 190.00 % ID#: 075'003 COMPANY: PRODUCT MANAGER: 51 VIRGINIA DIETRICH 703-308-8157 ROOM: CS1 3H3 PM TEAM REVIEWER: LEONARD RYAN 703-308-8067 ROOM: CS1 3M1 RECEIVED DATE: 07/25/94 DUE OUT DATE: 01/21/95 

## * * * DATA PACKAGE INFORMATION 

## * * * DP BARCODE: 205845 EXPEDITE: N DATE SENT: 07/25/94 DATE RET.: 

### / / CHEMICAL: 075003 Sodium fluoroacetate DP TYPE: 102 Phase V Review I i CSF: N LABEL: N ASSIGNED TO DATE IN DATE OUT ADMIN DUE DATE: ~22./2-3-/93

DIV : EFED 

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## * DATA REVIEW INSTRUCTIONS 

## * * * Please review and prepare RED chapter for Sodium Fluoroacetate, Case# 3073,AI# 75003.

I Attachments: Checklist for deliverables LUIS reports/Labels 

# I Post phase 4 correspondence issues Product Chemistry data on Technical (EFGWB) 

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## * No evaluation is written for this data package



## * * * ADDITIONAL DATA PACKAGES FOR THIS SUBMISSION 

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~ECOLOGICAL EFFECTS BRANCH REREGISTRATION ELIGIBILITY DOCUMENT FOR SODIUM FLUOROACETATE SCIENCE CHAPTER I. TOXICITY DATA

,. 

### 'A. Topical Summaries 1. Avian Species In order to establish the toxicity of sodium fluoroacetate tobirds, the following tests are required using thetechnical gradematerial: one avian single-dose oral LD50 study on one species (preferably the mallard duck (Anas plat~rhvncos) or the bobwhite quail (Colinus virainianus);two subacutedietary studies (LC50)on one species of waterfowl (preferably the mallard duck) and one species of upland game bird (preferablythebobwhite quail or thering-necked pheasant (Phasianuscolchicus).
a. Acute Oral The acute oral LD50 value for the technical grade of sodium fluoroacetate (1080) for avian species has been reported in the literature, Hudson et al., (1984) reported the acute oral LD50 values for the ring-necked pheasant, mallard duck and chukar (Alectorisgraeca) to be 6.4 (95%C.I. = 3.85-10,8), 9.1 (95%C.I. = 5.6-14.6) and 3.51 (95%C.I. 2.58-4.78) mg/kg, respectively. Ward and Spencer (1947)determined the acute lethal doses for numerous avian speciesand reported LD50values as lowas 3.0, 5.0, and 15 mg/kg for the widgeon (Mareca americana), golden eagle (Aauila chrvsaetos), and black vulture-(Cartharistaurubu)

## ,respectively. Atzert (1971) reportedtheLD50 fortheblack-billed magpie (Picapica) to be 1 mg/kg. In addition, the USDA conducted a series of acute oral LDSqtests on the magpie to get toxicity data for a species that is likely to scavenge the carcasses of coyotes and/or livestock (Burns and Connolly, 1992)

# .Resultsof these studies showed that the acute oral LD50 for the magpie ranged from 1.78-2.3 mg/kg, depending on temperature and season. These results indicate that 1080 can be classified as being very highly toxic toavian species on an acute oral basis. The guideline requirements forthistest have been satisfied. Table 1 is a data summary for the acute toxicity of 1080 to avian species.1
TABLE 1: AVIAN ACUTE ORAL TOXICITY DATA

b. Dietary Campbell et al. (1994) reported that the avian dietary LCs0values of 1080 for the mallard duck and bobwhite quail were 231 (95%C.I.=150-338) and 486 (95%C.I.=339- 696) ppm, respectively (MRID #s 43210602; 43210601). Based on these data, 1080 can be ,classifiedas being highly toxic to avian species on a dietary basis. The guideline requirements for a dietary study have been 

## - satisfied. Table 2 is a data summary for the dietary toxicity of 1080 to avian species. Conclusions Reference

Acceptable Hudson et al., (1984) Acceptable Hudson et al., (1984) Acceptable Hudson et al., (1984) Acceptable Ward and Spencer, 1947 Acceptable Ward and Spencer, 1947 Acceptable Ward and Spencer, 1947 Acceptable ~tzert, 1971 Species Mallard duck Chukar Ring-necked Pheasant Widgeon Golden eagle Black vulture Magpie LD," mg/kg 9.1 3

# . 5 6.4 3.0 5.0 15.0

1.0

E DIETARY TOXICITY DATA
I I TABLE 2: AVIAN SUBACUT 

# I Conclusion 

## IReference . I Acceptable Campbell et al., 1994 Acceptable Campbell et al., 1994 MRID#43210602 Species Bobwhite quail

Mallard duck LC,, (PP~) 486

231as acute and subacute testing, intended use pattern, and pertinent environmental fate characteristics. Because
I theproposed usepattern is specifically designed totake a wild mammal (e., coyote), wild mammal toxicity testing is required. Ward and Spencer (1947)determined theacute lethal doses of 1080 for numerous mammalian species and reported LD50 values as low as 0.1 mg/kg for both the cotton rat

(Sicmodonhis~idus) and coyote (Canislatrans). They also reported that theLD5, for thedeer mouse (,Peromvcus 

## m.) was 4.0 mg/kg. Beasom (1982) reported that the LD5O values fortheopossum (Didel~his virainiana)and raccoon (Procvon lotor) were 41.6 and 1.1 mg/kg, respectively. Atzert (1971) reported that the LD50 of 1080 to the striped skunk (Me~hitus me~hitus) and opossum is 1and 60 mg/kg, respectively. Thesedata indicate that 1080canbe classified as being very highly toxic to mammals on an acute oral basis. The guideline requirement for thewild mammal toxicity test has been satisfied. Table 3 is a data summary for the acute toxicity of 1080 tomammals. TABLE 3: MAMMALIAN ACUTE TOXICITY DATA
Species 

# I~onclusions 

# IReference I I I 

# I Coyote 0.1 Acceptable Ward and Spencer, 1947 Cotton- rat 0.1 Acceptable Ward and Spencer, 1947 Deer mouse 4.0 Acceptable Ward and Spencer, 1947

opossum 41.6 Supplemental Beasom, 1982 i I 

# I Skunk 

# I 1.0 

### ( Acceptable 

# IAtzert, 1971 

# n 3. Toxicity to Aquatic Animals i. ~reshwater Fish In order to establish the toxicity of a pesticide to freshwater fish, the minimum data required on the technical grade of the active ingredient are two freshwater fish toxicity studies. One study should use a coldwater species (preferablythe rainbow trout), and the otHer should use awarmwater species (preferablythe bluegill sunfish)

# .Collins (1993)reported that the 96-hour LC5 values of technical grade 1080 to the rainbow trout [~ncrhvnchus mvkiss) and bluegill sunfish (Le~omis macrochirus) were 54 mg a.i./l and 

### > 970mg a.i./l, respectively. Based on ' these data, 1080 can be classified as being slightly

toxictocoldwater fish speciesand practically non-toxic to warm water fish species. The guideline .requirements for freshwater fish toxicity tests have been satisfied (MRID #s 42961601; and 42961602). Table 4 is a data summary for the toxicity of 1080 to freshwater fish. TABLE 4: FRESHWATER FISH ACUTE TOXICITY DATA



### ii. Freshwater invertebrates 

# -

r
Theminimum testing required to assess the toxicity of 

### a pesticide to freshwater invertebrates is a freshwater aquatic invertebratetoxicity test,preferably using the first instar Daphnia magna or early instar amphipods, stoneflies, mayflies, or midges (ChironomidsB.). Collins (1993)conducted an acute static toxicityteston

/ daphnids and determined that the 48-hour EC50 of 1080 was 350 mg a.i./l (MRID# 42961603). Based on these data, 1080 canbe classified asbeing practically non-toxic to freshwatl?rinvertebrates. The guideline remirement for

. the freshwater toxicity test has been satisfied. Table 5 is a data summary for the toxicity of 1080 to freshwater invertebrates. Species Rainbow trout Bluegill sunfish

TABLE 5: FRESHWATER INVERTEBRATE TOXICITY DATA 96-hour LC (mg a.i./B 54 970

iii. Estuarine and Marine Animals Acute toxicity testing with estuarine and marine 1 Conclusions Acceptable Acceptable

Species Daphnia magna Reference Collins, 1993 MRID# 42961601 Collins, 1993 MRID# 42961602

48-hour EC50 (mg a.i./l) 350 Conclusions Acceptable Reference ' Collins, 1993 MRID# 42961603organisms is required when an end-use product is intended for direct application to the marine/estuarine environment or is expected to reach this environment in significantconcentrations. Becausetheterrestrialnonfood use of 1080 will not result in exposure to the estuarine environment, the data requirement is not required. 4. Toxicity to Plants, Terrestrial plant testing (seed germination, seedling emergence and vegetative vigor) is required for herbicides which have terrestrial non-food or aquatic non-food (except residential) use patternsandwhich have endangered or\threatenedplant species associated with the site of application. Because 1080 is not a herbicide, the data requirement is not required.

I 11. FIELD STUDY DATA From 1978 to 1980, the U.S. Fish and Wildlife Service conducted field research invarious states to assess the primary and secondary hazards from the use of the 1080 LPC (Connolly, 1980). ,It was found that the primary scavenger of collared goats that were killed by coyotes in Texas were turkey (Cartfiarista aura) and black vultures while red-tailed hawks, caracaras and ravens infrequently scavenged kills. No scavenging by mammals was observed. InMontana and Idaho,magpieswere themost conspicuous scavengers of coyote killed sheep with infrequent scavengingby ravens. With regard toprimary poisoning the follawing summary was reported: Insummary,coyote-killed col'laredlivestock were known to have been scavenged by turkey vultures, black vultures, magpies, ravens, red-tailed hawks, caracaras, a skunk and a coyot& during the present studies. No 'scavengerwas known or believed to have been poisoned. Scavengers ignored the collars and fed instead upon the 

# - viscera and muscle that has been exposed by the killer coyote

# . Field observations of secondary poisoning, studies, conducted in Texas and Montana showed that turkey vultures were the only scavengers of dead coyotes eventhough numerous other scavengers such as golden eagles, ravens 

## , magpies, skunks and other potential scavengers were abundant in the area. From 1981 to 1983, the New Mexico Department of Agriculture conducted an experimental field program evaluating the efficacy and safety of the toxic collar. A total of 330 collars ware used over approximately 1,000 days. Twelve collared lambs were attacked but only 5

\



# -

t A- -- *-. "I(--7 a L ~>r=-~sa*II"*~*~~~~-~~-~ X-I---IIF-ii -.l 1- *-\ \\ collars were actually punctured by predators. A total of 18 collarswere accidentally punctured while 21 collars were lost. A total of three predators (2 coyotes and 1 bobcat, (Lvnx rudus) were found dead. The only nontarget believed to have been poisoned during the study was a skunk. The resultsof this study suggest thatnon- , targetexposure to 1080 fromeither feeding on thecoyote carcass or the neck area of the collared livestock was low and did not result in any significant adverse ecological effects (Littauer, 1983). As part of the registrationrequirements,theRegistrant

(USDA/APHIS)had to submit data/information on any nontarget hazards resulting from the use of the 30 ml Livestock Protection Collar (LPC) that was collected as a result of its use in Montana, Wyoming, New Mexico, South Dakota and Texas (USDA/APHIS, 1991). The major findings from the actual use of the collar during 1988, 1989 and 90 as well as a report on the field and laboratory research conducted from 1978 to 1980 are as follows: 

# - the contents of a small portion (13%)of the collars placed on livestock were actually released into the environment. The total amount of 1080 involved in the release (assuming that each collar was completely emptied) was 88.2 grams. This is an average of 29.4 grams/year over the four state area where the ,collars were used (none used in South Dakota). 

# - there were no 'reportsof deaths of non-target animals associated with the use of the LPC collars during this period; 

# - only limited scavengingoccurredon coyote carcassesby 2 species of vulture and a caracara. 

# - livestock carcasses were scavenged by vultures, magpies, ravens, red-tailed hawks, caracaras, skunks and coyotes but none of these -non-target species were poisoned as a result. 

# - scavenger species tended to feedmainly on viscera and muscle of hind quarters. 

# - of the 13% (294) of the collars, that had there contents released,duringthe time period, only 5% (108) were punctured by ,coyotes.11. EXPOSURE ASSESSMENT- ESTIMATED ENVIRONMENTAL CONCENTRATIONS 1080 residues on the necks of collared livestock Knowlton and Ebbert (1991) conducted a physiologic marker study, using radio-labeled 1080, to determine the amount of 1080 likely to be consumed by the coyote and the amount of 1080 likely to occur on the necks of collared goats (ga~ra spp.) when the pouches on the 30 ml livestock protection cbllarwere punctured. They found that the average amount of dispensed fluid from the 30 ml collar was 19.2 (11.9-27.8) mls, while the average amount of fluid ingested by the coyote was 1.0 (0.1-2.9) mls. The average amount ~f fluid contaminating theneck of the goat was 75mg (range39-118mg) whereas the average amount of fluid not identifiedwas 113 mg

(range 0-234 mg.). It was also determined that, once punctured, thepouches containingthe 1080discharged over 85% of their contents, within a very short period of time, and that relatively little of the 1080 is actually ingestedby the coyote (i.e., 6 of the 15 coyotes ingested less than 5mg in the process of killing the goat. Savarie et al. 1990, also conducted a study designed to determine the amount of 1080 contamination likely to occur on the necks of collared lambs (gvis SWW.) that are killed by coyotes. They found that 12 1080-contaminated sheepskins contained an average of 96mg la80 with the range from 23 to 200 mg. A comparison of the data between these two studies suggest that the amount of 1080 exposure on the neck of the collared livestock i's similar regardless of the species of livestock. For instance the average amount of 1080 released from the collar in the goat studywas 130mg compared to 135mg for the sheep studywhile the amount of lost or unaccounted for fluid from the collar was 5.6 mg for the goat study 

### D. 6.1 mg in the sheep study (USDA/APHIS, 1991b). 1080 residues in covote tissue Connolly (1980)reported on the amount of 1080 residues found in muscle tissues from captive coyotes that received known oral doses of 1080. At a known oral dose of 5.0 mg the residue in muscle was determined to be 0.10 ppm while the 10 mg dose resulted inmuscle residues of 0.19 ppm. Based on this relationship, a coyote-that ingests an average of 1ml (10mg) will havemuscle tissueresiduesof 0.19 ppm 1080. Thehighest 1080 residue level found in muscle tissue was 0.93 ppm. Compound 1080 residues in coyotes*' that have killed sheep wearing the 30ml collar have also been determined (Burnset. al. 1984). They reported that the average 1080 residues for muscle tissue, stomach contents and vomitus, were 0.15, 0.5 and 0.35 ppm, respectively. Thehighest residue found occurredin the stomach contents and was 2.3 ppm. Knowlton and Ebbert (1991) analyzed muscle tissue from 10 coyotes that were killed as a result of puncturing the collars. Residues were detected in the muscle of all the coyotes. The mean amount of 108'0 in the muscle tissue was 0.089 ppm (range of 0.05 

# - 0.280 ppm) while themean f SE of 1080 lost from the 12 collars'was 92 56mg (rangefrom 3-183 mg) fIAZARD ASSESSMENT Aauatic Hazard Assessment Compound 1080 has been classified as being practically, non-toxic to warmwater fish

~ species and aquatic invertebrates, onZy slightly toxic to coldwater fish species,(MRID#42961603; 42961601; 42961602). Theuse of the collar is such that the likelihood of 1080 getting into any body of water is extremely low and has never been reported. Therefore,because of its low toxicity to aquatic organisms and because exposure is low, the 

### EEB concludes that use of the collar does not exceed the Agency's unacceptable risk criteria. Terrestrial ~azard~~ssessment Non-target exposure from the use of the Livestock Protection Collars (LPCs) comes from four potential sources (1) contaminated sheep or goat carcasses with either broken (punctured) or unbroken collars (primary hazard) (2) toxicant that has been spilled on the ground/vegetation as a result of the collar being punctured (primary hazard) (3) the carcasses of the poisoned coyote that has not been found (secondary hazard) and (4)thevomitus of poisoned coyotes (primary hazard). Primary hazard has been defined as that effect which results from direct ingestion of the toxicant, while secondarypoisoning canonly result from scavenging the remainsi of an animal that-hasdirectly ingested the toxicant (Connolly,1980). i. Primary Hazards 3 Contaminated neck areas < The residue data clearly demonstrate that the greatest environmental exposure comes from 1080 contamination on the neck of the collared livestock. In the Knowlton and Ebbert study, the average amount of fluid contaminating theneck oi thegoatwas 7.5 (3.9-11.8) mls. This amounts to approximately 75 mg of 1080 toxicant which clearly exceeds toxicity values for numerous birds and mammalsthat could scavenge the carcass and indicates that primary hazard to .these scavengers is quite high. However, resultsof field studies suggest thatmortality to scavengers, that feed on these carcasses, is minor. Forexample, ithasbeen observed thatvultures,magpies, ravens (Corvus corax), red-tailed hawks (Buteo iamaicensis),caracaras (Polvborus cheriwav),coyotesand skunks all scavenged the carcasses of coyote killed collared livestock yet none of these non-target species were poisoned as a result (USDA/APHIS, 1991; Connolly, 1980; Littauer, 1983). There are several factors that may account for this

. apparent discrepancy. First of all, because of the typical behavior of scavenging birds to feed at the wounds or openings in the carcass or where the skin has been tornaway from the carcass (asopposed to feeding on
- the contaminated neck area), the likelihood of primary hazard to avian species such as the bald eagle

(Haliaeetusleucoce~halus) maybegreatly reduced (USFWS, 1984 ;USFWS, 1985). For example, Connolly (1980), in order to simulate the primary hazard to non-target animals, conducteda seriesof testsexposing magpies and domestic dogs (Canis familiarus) to dead collared livestock. Although the dogs and magpies fed heavily on the carcass, neither the dogs nor magpies were poisoned. Connolly further observed that both themagpies and dogs tended to feed on the exposed parts (i.e. where the coyote had fed on the animal) of the dead livestock rather than on the neck area (where the highest contamination is likely to occur) and concluded that .."the intrinsic feeding behavior of scavengers confers a degree of protection against accidental poisoning by livestock collars. Secondly, toxicitydata sugqest that, in general, birds, especially raptors, that are likely to scavenge dead carcasses, are less susceptible to 1080 poisoning than most mammals, especially canids (Haegeleet ale,1984; Ward and .Spencer, 1947 and Atzert, 1971). In addition, emesis has been clinically observed as being a early symptom of 1080 poisoning (Ward and Spencer, 1947) and may cause certain raptors to discontinue feeding before lethal amounts sf 1080 are absorbed (Dana, 1971). This characteristicwould greatly reduce exposure to raptors scavenging on livestock carcasses and, in addition, probably make them less likely to continue feeding on them. Another factor that can greatly influence the extent of primary hazard is the fact that livestock carcasses decomposerapidlyunder field conditionswhichmay render them ,unpalatableto many avian and mammalian species (Burnset al. and Connolly).S~illed/lost toxicant Based on the data presented by Knowlton and Ebbert

(1991),theaverageamount of fluid not identified (lost) was 11.3 (0-23.4) mls or approximately 113 mg of 1080

(nearly 33% of the total amount in the 30ml collar). It is believed that most of the unidentified fluid is spilled on the ground. The amount of fluid lost from the collar is not considered to be a primary hazard because 1080 exhibits a high degree of adsorption to vegetative material and is not likely to .becarried from the site where itwas deposited (Hiltonet al. 1969). Inaddition, because fluoroacetate is rapidly broken down by soil bacteria and other organisms it isdoubtfulthat spillage will pose any significant route of exposure to nontargets (David and Gardiner 1966). As such, the EEB believes 'that there is no real hazard to non-target organisms from the 1080 that spills on the ground as a result of the collar being accidentally punctured or deliberately punctured by the attacking coyote. , ii. Secondary HazardsContaminated covote tissue Table 7 shows the approximate amounts of muscle tissue, stomach contents and vomitus, from coyotes killed with the 30 ml LPC, that scavengerswould have to consume to obtain an LD50 of 1080 (Burnset al., 1984). These data suggest that secondary hazard to non-targets that may feed on a contaminated coyote is unlikely (Burnset al., (1984)

## ,Connolly, (1980)andKnowlton and Ebbert, (1991)

# . TABLE 7: Approximate amounts of tissue from coyotes killed with the 30 ml LPC that scavengerswould have to consume to obtain an LD50 of 1080. Amountsthatcontainone LD50 doseMuscle Tissue Calculations show that most species would have to consume considerable amounts of contaminated muscle tissue, relative to their body weight, to obtain lethal dosages of 1080. For example, theblack vulture, golden eagleandmagpiewould have to consume 100X, 33X, and 6.6X their body weights, respectively, to obtain an equivalent LDS0from just eating muscle tissue. Even themost sensitive species tested (i.e., the coyote) would have to eat approximately 67% of its body - weight toget an LDS0from scavenging on themuscle tissue from a coyote killed by the 30 ml toxic collar. 9.08

Stomach Contents 

### - 6.36

Examination of Table 7 also shows that,because of thehigher concentrations of 1080 present in the stomach contents, scavengers, which feed primarily on the viscera, may be at

. greater risk than those that feed primarily onmuscle tissue. For example, theblack vulture, golden eagle and magpiewould have to consume 30X, 10X and 2x their body weight, respectively, to obtain an equivalent LDS0doses from eating the stomach contents. These data indicate that, under natural conditions, it ishighly unlikely that,scavengers could either find and/or consume sufficient quantities of contaminated coyotes to be secondarily poisoned from these carcasses. 21.2.

Vomitus 3-.18

Clinical observations suggest the 1080 exerts an emetic action; especially to canidswhich have digested more than an LD50 (Wardand Spencer, 1947 and TAMUS, 1983)

# .Observationsof coyote behavior made during the TAMUS study not only demonstrated thisbut also found that some coyoteswould cache the vomitus (whichmay further reduce this source of exposure).

, Connolly (1980)reported that residue levels in vomitus from four poisoned coyotesranged frombelowdetectable limits (0'. 1 ppm) to 0.72 ppm. In addition, the average amount of 1080 in
i vomitus, from five coyotes that attacked sheep wearing the 40 ml collar, has been reported to be 0.35 ppm (USDA/APHIS, Unpublished Report, 1986)

# .Although these levelsmay be toxic to certain species that are very sensitive to 1080, the EEB believes that it is unlikely that sufficiently large amounts ofvomituswould everbe available and/or foundby non-targets under field conditions to exceed the Agency's risk criteria. For example the coyote and skunkwould have to consume 280.5% and 280% of their body weights, respectively, to obtain LD50 equivalents from eating vomitus. These calculations suggest that the coyote may be at risk from consuming vomitus, however, even if non-targets coyotes were to feed on the 1.0 3.18 I' Skunkvomitus, it isdoubtful, because thetotal amount of exposure associated with the vomitus is extremely low, that adverse effects would exceed theAgency's risk criteria.
Burns et al. (1986) also conducted a study to determine secondary effects to coyotes killed wi$h single drop baits (SDBs)treated at 5mg/bait. They found that the average 1080 residues in coyotes killed by the SDBs were 0.29, 0.30 and 0.31 ppm for muscle tissue, small intestinesand theatomach, respectively. They concludedthat thesevalueswere similarto

, those found in the 30 ml LPC study conducted by Connolly (1980). They also conducted a series of feeding tests to determine if there was any potential for secondary hazard to non-target animals that fed on coyotes poisoned by the SDBs. All of the removed tissue, except the gastrointestinal tract, was fed to 3 dogs (Canis familiaris), 3 coyotes, 4 striped skunks and 15magpies for periods ranging from 14 to 35 days. The total amount of contaminated tissue \consumed, and expressed as percent of body weight averaged 67% for dogs, 152% for coyotes, 117% for skunks and 371% for the magpies. Still, none of the test species exhibited any signs of 1080 poisoning orhad any aetectable 1080 residues in theretissue. Again, these data indicate that even if non-target species were to feed on the carcass of a coyote killed by the collar, it is highly unlikely that they could ingest sufficient quantities of the contaminated tissue to cause any secondary hazard. Finally, As part of the registration requirements, the US. FishandWildlife Service, was required toconduct research on the potential secondary hazards to non-target organisms from the use 

### of the 30 ml LPC. In order to simulate secondary poisoning, coyotes were administered doses of 4mg, 100mg and 400 mg of 1086. Upon death, all the coyotes were skinned, eviscerated ,and all muscle tiSsue was removed from the skeleton. All the tissue, except the gastrointestinal tract, was ground-up and then fed (100to 200 g) to stripped skunks, raccoons and opossums. Results of this study indicated that only those coyotes receiving more than 200 mg of 1080 would present any secondary hazard, and then only to those species that have a relatively low tolerance to the chemical (TAM'S, 1983). The dosages that caused effects greatly exceed those found tobe administered to the coyoteby the LPC and indicate that mortality to non-target from the operational use of the collar is unlikely. iii. Total Collar Use In addition to knowing residue levels, that are likely to occur in dead coyotes and/or on the necks of livestock, it is also important to put into perspective, from a hazard standpoint, just howmany collars'arelikely tobe used under typical coyote control operations. It appears, based on theresults of several field studies, conducted invarious states, that thetotalnumber of collarsused and totalamoulit of 1080 actually jost to the environment are both quite low. For example, in the study conducted in New Mexico, only 23 of 330 (7 %) collars were ever punctured and of the 23 only 5 (22%) were punctured by coyotes (Littauer, 1991). During the three year study conducted in Wyoming, Montana, Texas and New Mexico only 294 out of 2257 collars (13%) were actually punctured and had their contents released to the environment: The totalamount of 1080 involved 'inthisrelease (assuming that each collar was completely emptied) was 88.2 grams. This is an average of 29.4 grams/year over the four state area where the collars were used. What is even more significant is that only 108 collars, out of the total 294 (36.7%) collars that were punctured, were punctured by coyotes. The total amount of 1080 released from collars punctured by-coyote attacks (assuming that each collar was emptied)was 32.4 grams or an average of only 10.8 grams/year over the four state area. Additionally, data show that nearly as many collars (80 collars or 4%) were punctured from vegetation and other unknown causes as were punctured from coyoteattacks. This sourceof 1080 exposuredoesnot pose any primary or secondary hazards because neither the collared livestock nor attacking coyote become a source of exposure to scavenging by non-target organisms. I All of thesedata suggest that there is very little secondary hazard tonon-target organisms that feed on coyoteskilled by the LPC and/or their vomitus. Because such consumption is unlikely to occur under natural conditions, may explain why therehavebeen so few field observationsofmortality tonontarget species that feed on coyotes that have been killed by the LPC. Endanaered Species On March 21, 1985, the EEB requested formal Section 7 Consultation relative to the United States Department-of Interior's Application to register Compound 1080 Livestock Protection Collar. On June 14, 1985, theUSFWS-OES responded and concluded that the use of the 1080 collar, as proposed, \ with all.the use directions and restrictions, posed no

, jeopardy to the bald eagle, San Joaquin kit fox, black-footed ferret (Mustelaniariwes)

## , and gray wolf (Canis lupus) but was likely to jeopardize the 

### continues existence of the grizzly bear (Ursusarctos horribilus), Rocky Mountain wolf

(Canis lupus irremotus) and California condor (Gvmnoavs californianus) (USFWS, 1985)

# . At this time theUSFWS-OES provided specific state and county recommendations for avoiding adverse effects to the nonjeopardy species as well as reasonable and prudent alternatives for precluding jeopardy to the three species injeopardy fromtheuse pattern. Based on this information,, the EEB developed specific endangered species label precautions and use restrictions for the 30 ml 1080 toxic collar. These use restrictions have been included in a Technical Bulletin that accompanies the labeling. In 1987, as a result of informal consultation with field operationspersonnel fromtheUSFWS, theEEBbecame aware that additionalprecautions, specifically addressingtheuseof the LPC in Texas, were required to protect both the ocelot (Felis pardalis)and jaguarundi (Felisvasouarundicacomitei) (USFWS, 1986). These additional use precautions were reviewedby the Agency and subsequently included into the Technical Bulletin. 

### VII. SUMMARY The major routes of exposure to nontarget wildlife, from the

- use of the Compound 1080 LPC, comes from four potential sources; .(I)contaminated sheep or goat carcasseswith either broken ,(punctured)or unbroken collars (primary hazard) (2) toxicant that has been spilled on the ground/vegetation as a result of the collar being punctured (primary hazard) (3) the carcasses of the poisoned coyote that has not been found

(secondary hazard) and (4) the vomitus of poisoned coyotes (primary hazard)

# . Residue data indicate that thegreatest exposureand potential for hazard comes from scavenging the neck area of the dead collared livestock and that secondary hazard from scavenging the carcass bf the dead coyote and/or consuming vomit is highly unlikely to pose any'unacceptablerisk. Results of feeding tests, simulated studies and actual field studies indicate that feeding behavior for many scavengers, decompositionof livestockcarcasses, and theemetic nature of 1080 are all factors that greatly reduce the likelihood of exposure to non-target organisms below the Agency's level of concern. Inaddition,environmental hazard statements, special use restrictions, and endangered species protection , statements, that are required to be placed on the label, greatly reduce primary hazard to non-target organisms including endangered species.
- Based upon results of ,fieldstudies,monitoring reports, low volume usage, environmental fate data which suggests that 1080 is not likely toget into aquatichabitats, and tissueresidue analysis, that shows that the total amount of 1080 likely to be released into the environment is quite low, the EEB believes that theuse of theCompound 1080LPC will not exceed theAgency's unakceptable risk criteria for either non-target aquatic or terrestrial species.I VIII

# . LABELING

IX. The current label precautions, restrictions, and directions regulating the use of the Compound 1080 Livestock Protection Collar are some of the most comprehensive and stringent for any registered pesticide. In addition to the standard environmental hazard statements and use restrictions, the label also contains 19 special use restrictions that regulate the use, and disposal of the collars as well as a Technical Bulletin that provides specific information regarding endangered species (AppendixI). TheEEB believesthatcurrent labeling is adequate toprotect non-target fish and wildlife resources.
RISK MITIGATION MEASURES The EEB believes that Technical Bulletin Use Restriction No. 8 should be mopified to further reduce risk to non-targets. Specifically,7fhe EEBbelieves that allowinguse of thecollar /- in areaswhereannual precipitation is lessthan 20 inches and the vegetation of the pasture is sparse makes very little difference in finding carcasses if topographical features are not considered. The EEB believes that very few, if any, ranching operations in the west could bear the additional expense or take the time to routinely ground search (every 7 days according to use restrictions) for dead animals that could be spread over a,15.6 sq. mile (10,000 acres) area. Instead the EEB recommends 'thatfenced pastures should be limited tonomore than 5,000 acres in size. Even with theuse restriction, there will be some areas where an effective search for dead collared animals and/or the carcasses od dead coyotes would be greatly hindered by vegetative and topographical features. Thecurrent size limitation amountsto , an open range use.I Literature Cited
Atzert, S. P. 1971). A review of sodium fluoroacetate (Compound 1080): its properties, toxicology and use in predator and rodent control. Spec. Sci, Rep. 

# - Wildlf. No. 146, U.s> Fish and Wildl. Serv., Washington, D.C. -34pp.

, Beasom, S. 

### L. 

## , (1982)

# .Reporton-Efficacy of the 1080toxic collars as a predator damage control method (July 1, 1982 -September 30, 1982). Texas A 61 M University, College Station, Texas, Burns, R. J. 

## , G. Connolly, D.L. Meeker, I. Okuno, and P. 3. Savarie. 1984. Efficacy and hazards of Compound 1080 in toxic collars. 

### A submission to the Environmental Protection Agency in supportofRegistrationof the sodium fluoroacetateCompound (1080) Livestock Protection Collar. U. S. Fish and Wildlife Service, Denver, Colorado. November 15, 1984. 32pp. Burns R. J., .Connolly, G. E. and Okuno, I. (1986). Secondary toxicity of coyotes killed by 1080 single-dose baits. Denver Wildlife Research Center, USDA/APHIS. Proc. 12th Vertebrate Pest Conf, San Diego, California. p324-329. Burns, R.J. and G.E. Connolly 1992. Toxicity of Compound 1080 to Magpies'and the Relationship of Dose Rates to Residues Recovered. . USDA, Denver Wildlife Research Center. Proc. 15th Vertebrate Pest Conf., Newport Beachli Ca. p403 (6)

# . Campbell, S. M., J.B. Beavers and J. Grimes 1994. Sodium fluoroacetate: A dietary LCs0 study with the Northern bobwhite (Unpublished Report. QA-297. Denver Wildlife Research Center, Denver, Colorado). 27pp. (MRID 

### # 43210601) Campbell, S. M., J.B. Beavers and J. Grimes 1994. Sodium fluoroacetate: A dietary LC5, study with the Mallard (Unpublished Report. QA-298. DenverWildllfeResearch Center, Denver, Colorado). 26pp. (MRID

### # 43210602) Collins, M.K.. 1993. Sodium fluoroacetate- Acute toxicity to bluegill sunfish (Lepomis macrochirus) under static renewal conditions. SLI Report No. 93-7-4847. Performed by Springborn Laboratories, Inc., Wareham, MA. Submitted by U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Denver, Colorado. (MRID#42961601) coliins,M.K. 1993. Sodium fluoroacetate-Acute toxicityto rainbow trout (Oncorhnchusmykiss) under static conditions. SLIReport No. 93-8-4885. Performed by Springborn Laboratories, Inc., Wareham, MA. Submitted by U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Denver, Colorado. (MRID#42961602) Collins, M.K. 1993. Sodium fluoroacetate- Acute toxicity to Daphnids (Da~hnia maana) under static conditions. SLI Report No.
I
L

,93-78-4844. Performed by Springborn Laboratories, Inc., Wareham, MA. Submitted by U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Denver, Colorado. (MRID#42961603) Connolly, G. E. 1980. Use of Compound 1080 in livestockprotection , collars to kill depredating coyotes; 'A report on the field and laboratory research. November 1978-March 1980, U. S. Department of the Interior, Fish and Wildlife Service, Denver Wildlife Research Center, Denver, Colorado. Dana, R. H. 1971. Vertebrate pest control in California. Unpublished mimeo. rep. California Dept. of Agriculture. 14pp. David, W. A., and B.O. Gardiner. 1966. Persistence of fluoroacetate and fluoroacetamide in soil. Nature. 209: 1367- 1368, Hegdal, P. L.,, T.A. Gatz, 

### K. A. Fagerstone, J. 

### I?. Glahn and G. H. Matschke. (1979).Hazards towildlife associatedwith 1080baiting for California ground squirrels. Hilton, H. W., Q.H. Yuen, and N.S. Nomura. 1969. Absorption of monofluoroacetate-2C ion and its translocation in sugarcane. 3. Agric. Food Chem. 17:131-134. Hudson, R. KO,R. K. Tucker, and M. A. Haegele, 1984. Handbook of toxicity of pesticides to wildlife, 2nd edition. U.S. Dept. of Interior, Fish and Wildlife Service, Resource Publication 153, Washington, D.C. 90pp.

, Knowlton, F.F., and S.M. Ebbert. 1991. Develop physiologic markers to identify coyotes that kill sheep or goats. (Unpublished report to the EPA

# - QA-090) USDA/APHIS, Denver Wildlife Research Center, Denver, Colorado. 27pp. Savarie, P. J., Burns, R.J. and Zemlicka, D.E. (1990). Sodium fluoroacetate (Compound 1080) contamination on the necks of lambs with Livestock Protection Collars (LPCs) that are killed by coyotes. Unpublished report by Denver Wildlife Research Center, USDA/APHIS/S&T (QA-65). 227 pp. (MRID#41514901). TAMUS (TexasA&M University System). 1983. Efficacy of the 1080 toxic collar as a predator damage control method. Final report to theU.S. Fish andWildlife Service for Cooperative Research Project No. 14-16-0009-81-934, September 1, 1980- June 30, 1983. Department of Wildlife and Fisheries Sciences, Texas Agricultural Experiment Station. Data report submitted to the Environmental Protection Agency to support modification of .the Texas A&M University System, College Station, TX. 134 pp. USDA/APHIS, 1986. Unpublished Report entitled: Residues of sodium fluoroacetate (1080) in coyotes and on the necks of sheep due to theuse of large (60ml)compound 1080 livestockprotection collars.\ 

# -

- F
DenverWildlife Research Center, Denver, Colorado. A data report to support the registration of the 60 ml collar. Laboratory and Pen Studies. September 1985- January 1986. 10 pp. USDA/APHIS, 1991. Correspondence from P. Joseph, summarizing the infbrmation on the use of the Compound 1080 Livestock Protection Collar during FY-1988, 1989, and 1990 in fivewestern states. c USDA/APHIS, 1991b. Correspondence from P. Joseph, validating results of report entitled "Sodium fluoroacetate (compound 1080) contamination.on 'the necks of lambs with Livestock Protection Collars that are killed by coyotes. (MRID# 41514901) USFWS, 1984~ Formal Section 7 Biological Opinion regarding 1 year extension of experimental use permit for the 1080 toxic collar in Idaho, Montana and Texas. (6704-EUP-14). (FWS/OES EPA-84-3) 5pp. USFWS, 1985. Formal Section 7 Biological Opinion on the 1080 livestockprotection collar. Region 6 (6-RO-85-001) 18pp. USFWS, 1986. Letter fromAllan J. Mueller, Acting Field Supervisor Division of Ecological Services, Houston, Texas to Roger Mulder, Regulatory Division, Texas Department of Agriculture, regarding endangered species use restrictions for Texas. Ward, J. C. and D.A. Spencer. 1947. Notes on the pharmacology of sodium fluoroacetate-compound 1080. Journal of the American Pharmaceutical Association. 36(2): 59-62.

\

C



### .

ITechnical Bulletin



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### -. ... 

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# . EPA
... Registration Numbe 

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. .- Compound 1080 Livestock Protection Collar

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## :

. :.. DON~T ., -..in : -. . , _. ... . . 

### ._. -. . . . . : .. . . : ..
.. . 

### . 

## -- waste time by placing collared animals where coyotes wonltattack them

, 

# 6 -- use collars if your livestock can be protected more easily or economically by other measures 

# -- use so few collared animals that coyotes won't find them

--. use more than 20 collars in any-100-acre or smaller

. . . pasture, .ormore than-50,.colKars p.er section.(640. acres) of pasture (see'page18) 

# a -- use collars on unfenced, open range (see page 14) 

# -- use collars where their use is prohibited to protect endangered wildlife (seepage 16-17) 

# -- use collars without required authorizations from the t 

## (i Fish and Wildlife Service Endangered Species Office (seepages 16-17) 

# -- use contaminated animals for food or feed (seepage 18) 

# -- use leaking or damaged collars 

# -- remove toxicant from collars

,

... , -, -c I

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## ..
.-, 

### . 3, + ,,. 

## ...

,. 0.

....



### .. 

# 3 ,c.7/91)
. ,

..- Compound 1080 Livestock Protection Collar

The Livestock Protection Collar (LP Collar), invented by Roy M.cBri.deof Alpine, Texas, exploits.the coyote's .habitQf k'illingsheep and goats by bites to the throat (photo 1).

. As described.'in McBridefsU-S,Patent No'. 3,842,806 (issued in.1974).;.coyotes.'that.attackcollared livestock--usually.

.... bite through the collars and .reiceive 'oral* doses of the contents. When used with a toxicant such as sodium fluoroacetate (CompoundY080), 

### LP Collars kill the attacking coyotes. Collars may be used only by specifically certified LP Collar applicators or persons under their direct supervision (see Section 11. 2). This Technical Bulletin is part of the EPA-approved labeling and contains detailed instructions for safe and effective use of LP Collars.



## . Coyotesf attacking and feeding behaviors do not seem to be affected.by ,thepresence of 

### LP Collars. Attacking coyotes

. usually kill and feed:-up~n. :col;laredanimals.just. as they

. . would'if no collar were present. ~fter' a lethal dose of sodium fluoroacetate (compound 1080) has been ingested, 

# R symptoms of intoxication typically do not appear for 2 or more hours. Death occurs from 2 to 7 hours (average 4 hour 20 minutes) after the collar is punctured. When 

### LP collars are used properly, coyotes may puncture them in 75 percent or more of their attacks, 

### A 100 percent 

# t 'puncturerate is unlikely to be'achieved because coyotes sometimes attack body sites other than the throat (photo 2). Effective use of 

### LP Collars requires not only that collars be positioned correctly, but also that coyote attacks be directed or targeted to collared livestock. Targeting may be difficult or impossible under\some conditions, If coyotes are killing less than once per week, the collar technique may be impractical. Collars are recommended for ranches with high rates of coyote predation and management conditions that permit effective targeting of predations to collared livestock.



### ...... a,. ... ~x~erienced persons usually can evaluate local conditi'ccs'



### ...... quickly to decide whether or not 

### LP collars will be 

### . . .. effective. In addition to the basic problem of targeting,,


### ....



### . . other factors to consider in deciding whether or not to use collars include availability and effectiveness of othat"'.

...... control methods; costs of collars; labor requirements to". The LP Col1ar.i~ a rubber bladder that contains a solution. of Compound'1080, with neck straps forattachment.to a sheep or goat. The type of collar used most up to 1985 has two .velcroRneck straps (0.75-.incheswide and 22-24. inches long on new collars). ~hree-strapmodels also are available and

. . are.intended for use 6n goats; Each collar has two toxicant reser~obqs. that:contain 15.0..mg (0.; 15.grams),of sodium
...... . . / fluoroacetate (active ingredient),. ~ach collar contains a total of 300mg (0.3 grams) of sodium fluoroacetate (active ingredient)

# . 6 LP Collars of two sizes have been developed (photo 3), but the large collar has not yet been approved for field use. The small collar is intended for lamb,sand kids weighing from 25 $0 50 pounds. LP collars are not recommended for small animals (under 25 lbs).. A small collar, properly in place on a lamb, is shown in photo 4.

... ..

. . . . ... . . '

### D

# . MANAGMENT OF LP COLMS '*ON 'SHEEP AND 'GOATS 

# .t 1. Things to do before putting LP collars on livestock:
a. Be sure you have enough LP collars (see Section E). b. Inspect all LP collars for leaks and inspect straps to be sure they are securely attached. Do not use leaking or torn collars (photo 7) or collars on which the straps are coming loose (photo 8). Loose straps may be reattached by sewing.
c. Check the fence around the pasture where collared animals are to be placed and repair as necessary to keep animals within the pasture. d, Establish locations for warning signs (Appendix B), and be sure you have enough signs (see use restriction 10). ,,,..I a 

# '.

. a' *' '



# .., * e. Inform neighbors of your intent to use LP ColLars 

### ":": 

# ., and advise them of the potential hazards tq-,*, .a,.. free-roaming dogs. .a 

# . . ..... 48.4 a ,.a. ..a,. 2 

# . .. . ~om~ound 1080 ~Lestock Protection Collar

.

# -

.. 

### . . .... . . ..... .. 

## . . 

### ....... ...... ..... .. 

### . .. 

### ........... 

### ... ..:. ..i*. 

## ...; L : ,-:*<1.; .;a. 

### .!..' ,...y2f.<:;- ;.!,,.*- :.

### ..,..-,.. : ..-4... 

### -... -8.- 

## .. .. ... 

### .... ... ....... .. 

# 3 :., i. '

. 

### .. . .- .... . enough that the.applicatorcan insert.2 fingers
... 

### : . . -,

.. "bekween 'theptrap 

### aria the ariiniai. Collars stay



### ... .... . . in place well on animalswith wool or mohair, but may be difficult tokeep in position on newly
. . ..... . . shorn'or ~ldc~necked animals, parti'cularly goats ' (photo 

### 11). Head and neck conformation varies -

. 

### among., animals 

### and 

### it may 

### be impossible to.keep
. . 

### . . .... 

### . . -. collars in place on same individuals. They 

### - should be taken out-ofthe collared flock. 

### _..

..... ..

### - .

### . :

### .. . . 

### - ..... . .-. . . .- .-........ .....- . , . i. ...... .. :. 

## -.- d. A* suitable hiithod

# of pt&anentlk. identifying

. . individual animals in a target flock is required tokeep track of LP collared livestock. One such method is the use of numbered ear tags. Tags 

# 4 that can be read from a distance of 50 feet or. more are most useful (photo 15). If you are using ear tags, attach them before the animal is collared.

.. e. When the LP collar is in place, release the

. ,, animal into a.corral or other confined area and

. .- 

### ... .observeit carefqlly, Listen .forlabored '.- . . breathing that may indicate the collar is.too ' tight. When first released, collared sheep and 

## 3 goats often shake their heads, rub or-makeother attempts to rid themselves of the collars. This behavior will stopwithin a few hours if collars are not too tight. After you are satisfied that the collars are properly attached, move collared animals to the desired location.

I@ f. Place warning signs at logical points of access (see Section 11. 10 and Appendix B). g. After handling LP Collars, wash your hands with soap and water. 3. Monitoring 

### LP collared livestock
a. Once 

### LP collared animals are in the desired location, the pasture should be checked every 7 days or more often if frequent predation is expected. During each check try to 1ocate.eqqh :-la. animal and observe collars to be sure the~'~Rs'in ' position. 

### If the collar has slipped out of

.. ,, .
a a


## ..... position, catch the animal and reposition

# ws a,, collar. Inspect each animal's neck for ye2lossr ,,... dye, which could indicate a punctured or lea-g collar. If dye is seen, catch the animal aha' .111.1 , ,

'.. .

-.- Compound 1080 Livestock Protection Collar

...... ... ... .. . .- i

... . .. .... ......... . ............... 

### ......:..... :: ,,', :e.....I 4.. ..+ 

### .......'.'.I.. ... ..:;.,. ..; <...:-; 

### ,-., ;., *.... ;. .J. ... ; ..

.. ... . .

.

### .

... have .been..cariied. or d~agged away by qoyo,tes.

. ...

,." :~onie were 'Pound as far .ashalf.a mile away f 

### rem ... . . kill sites, but about half of themissing collars /

...were neyer recovered. Coyotes,spmetimes,cache
. (hid'e*orbury) 'them. 'Whenever a collar is missing, make a reasonable effort to find it.

... .... See Section IT. 11.

. . f. '1f'yousee an animal that you think may have been

.... 

### ...i 

### .... ,paisoned,:report it.pr.omptLy.to.'the .,a.ppropriate. 

### ... regulatory agency': Any suspected poisoning of threatened or endangered species must be reported immediatelv. See Section 11. 6. 

# 6 4. Handling LP collars and contaminated,animal remains, vegetation, clothing, water and soil.
a. The toxic solution in\theLP Collar contains a yellow dye, tartrazine, which is used as a marker for the presence of 10.80on punctured, damaged or

. broken collars; on clothing, animal remains,

... . vegetation,

### .'so.il., .or other. mate.rials;and in

. water. Always use waterproof gloves when handling collars or any materials known to be contaminated by 1080. b. Inspect carcasses of 

### LP collared animalsto
1 determine the cause of death. When the carcasses are fresh (within-24,hours after death), coyote kills usually are obvious (photo 17)- Remove punctured collars carefully and examine the punctures. Holes made by coyote teeth usually can be 'distinguishedfrom accidental punctures. When collars are punctured by cactus thorns, the thorns sometimes remain in the holes (photo 18).
c. If the LP collar was punctured, remove it carefully tominimize leakage and place in a leakproof plastic bag or other container for transport toyour disposal site. If necessary, doublebag toprevent leakage. Examine the carcass for contamination as indicated by yellow dye. Cut away the contaminated parts for
.. disposal along with the punctured collar. 'g9e' Section 11. 12-13.

. Dispose of the remainder-of the carcass using your normal practice. Cnt.or 1 dig up contaminated forage and soil and plbc~ them in a leakproof container for transport.to the disposal site.Compound 1080 Livestock Protection Collar

.... . . . I ... .. 

### ........ ......... 

### .; 

### .-......

### ." ',, I..,. 

### .-...' *..-,* 0.:. : 

### ..... 3

### ..\

... 

## .:.; ...,,I ...

..,: 

### .... .;.\: ;

### ...... .;. 

## .; :.:. I' .I. .. .. .

### - -..

. . . . Incineration may:.be used instead qf burial for .'.

. . disposal
.

### in.the

### fZeld (pref ekably.onpkoperty '

### .

## - ' owned or managed by the applicator) at least 

## 5 mile from.humanhabitation and-watersupplies.

.

### .

. Place .collarsand wastes (listed above) in an incinerator or refuse hole, saturate with diesel

. . fuel, and ignitp. Attend.the burp until the contaminated material is completely tonsumed.

...
. 

### -

..... .,AlternativeJy,contact .your- State Pesticioe

### or .. . . .... 

## ,. .~mrironhentalcontrol ~~ency 

### .'&.theHazard Waste . representative at,thenearest EPA Regional Office for guidance in disposing of wastes at approved hazardous waste disposal facilities. 

# 6 b. When snow or frozen ground make on site disposal impractical, up to one cubic foot of wastes may be stored in a leakproof container, in a dry, locked place for up to 90 days.

a_. . E. DIRECTING .COYOTEPREDATION TO LP COLLARED LIVESTOCK

....... .... -... ... 1. General comments The orocess of directing coyote predation - - to LP collared of targeting ---- livestock is called targeting. Knowledge 

## ----- - - is in its infancy and should improve as more people gain experience with LP Collars. Three different approaches or tarqeting straxegies are described here. Ranchers and led to apply predation control specialists are encourac these methods as necessary to achieve the Desc resulLs in their own circumstances. 2. Targeting Strategies Place LP coilars on vulnerable livestock. Collaring all sheep or goats on a ranch would solve the targeting problem. This strategy has not been tested due to the cost of collars and the large number that would be required in large flocks (over 100 animals). Nevertheless, in small flocks (50 or fewer animals) it may be practical to collar all the.lambs or kids, In flocks with 50 to 100 lambs or kids, it may.& worthwhile to collar the smallest 20 to 50 

# . individuals. Do not use more than 20 coll?.rs in any pasture under 100 acres, or more than'50. collars per square mile of fenced pasture.,Compound 1080 Livestock Protection collar



### ... .. .... ....... . . x$e...:. q2. ... 

### .. 

### ............. ..I.. .'. ...................... 'I :.:.. :'.
............... i,:.,

### .....:;

. ... -... - .... .... .I .. Placina.collarswhere 

### red at ion ist~o~infreauerit.

. .. 

## . C In'one.:such.case'icoliakeii:sgeepwere'exposed for .

### - four weeks during which no predation occurred. 

### he users then lost.interest and r.emoved the callars.

... 'There. wks .nofurther.'pr&dation on 'thisranch for several months. Collars cannot be used effectively where there is little or no predation.
.

.. c... Usins taraet flocks that are too small. In a.

. Man.tana.-$rial;. 'Six, -LP-collared: lambswere..placed. 

### in

...... a 640 'acrepastuee.' coyotes passed through.tkie

. pasture without finding the collared animals and then killed sheep from a large flock in an adjacent pasture. The larger the flock, the more likely it 2s to attract coyotes, The optimum size for target flocks has not been determined, but pastures of 100 acres or more should probably contain at least 50 head. d. ; usins taraet f1.ocks. that. are.not sufficientlv

. . isolated.fromuncollared livestock. On one small

... ... . . . .farm,:

### .a. group.

### ~k. ewes, and. 

### LP.:.collaredlambs .was:
.. . . e~posed~while other sheep.onethe place were penned each night, Instead of killing in the collared 

# e flock, coyotes switched to a neighbor's unprotected flock half a mile away. With small farm flocks, a,djacent land owners may have towork together to achieve effective targeting.

.- e, Usina small collars on larae shee~ or soats. When small LP collars are used on large sheep or goats, 

## 0 the throat region is inadequately covered (photo 10). Coyotes frequently kill these animals without puncturing the LP collars.



### ..

. f. Attachina collars im~ro~erlv or insecurelv. When LP collars are attached improperly, or they slip out of position (photo 13), coyotes will kill these animals but are unlikely to puncture the collars. LP collars in proper position are shown in photos 4, 5, 6, 11 and 16. g. Placins collars on sick or cull animals. Placing collars on sick or cull animals in an effort to avoid sacrificing more valuable livestock may be false economy, as coyotes may_notattack ill cr lethargic animals. Collars should be used only &n animals of the size and kind that coyotes have'been killing locally. 11 (7'1~1)-. - Compound 1080 Livestock Protection Collar



### .... ... 

### .. 

## .. -. 

### ....... . ...... . . 

### ..... . . . 

### ....... .... .. 

### -. ;;

## .. :.-. ..:

............ 

### ..,.-. %b<'.. :-:a;. .?.-...-:.

.. 

### ......... -. 

## . . .,.* ,...- ,--:. -.:: .:-..:

... . . ...'...'- 

### :

# :..: -1

. " '. 

### .' '87 .

.. .... -. .... .a -

. . a.............. ..... :(dl Instructions on .recordkeeping..



### . . . 

### ....... .

### .-. .... 

### . . 

### ... 

## -

... 

### ,... ."

. . .'

. . . 4. ~egistrants or thei; agents shall' keep recbrds df all

, .. ..: 

### . 

## . ... . 

### . collars sold or transferred at their address of record. .Recordsshall-include the name, addreb~, Ltate where I;P . Collar certification was issued, certification number of -eachrecipient, and dates,andnumbers of collars sold or

. transferred. 

## ... .

. . .

### - .:.. 

### -5. ~ach. .applichtor:..s.hlJ. keep .r@cor.ds.deaiing with the use 'OX. LP COI.I*S 

### arra the.rGsdltsof such.ibe; R;?&M=.-: 

### .-......... .._. shall be maintained in accordance with appropriate State or Federal regulations but for not less than two years following disposal or loss of collars. Such records C shall include, but need not be limited to: (a) The number of LP collars attached on livestock. (b) The pasture(s) where LP collared livestock were

.placed.

, .($)The dates of each attachment, inspection, and

.



### . removal.
.

. . .. ... (dl..The nflmbe-rand .locations of livestbck, found with.

. _-.

.. 

### - - ruptured or punctured 

### LP..collars..ande the appargnt cause of the damage. (e) The number, dates, and approximate location of LP collars lost. 4 (f) The species, locations, and dates of all suspected poisonings of humans, domestic animals or 

### - non-target wild animals resulting from LP collar use. 6. Any suspected poisoning of threatened or endangered species must be reported immediately (withinthree days) to the Environmental Protection ~gency),as will each suspected poisoning of humans, domestic-animals or non-target wild animals. 7. Only the registrant or collar manufacturer is authorized to fill 

### LP collarswith 1080 solution. Certified applicators are not authorized to fill LP collars. Compound 1080 solutionmay not be removed from collars and used for any other purpose.



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## - + C '~obertA. Forrest (PM-14), Registration Division (H-75?5- C)

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Compound 1080 Livestock protection Collar

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### If. more than nine (9) LP colsars are unaccounted for . 

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### -- excessive Xoss df collars. '.' ' ' 12.

. .~amaged,' punctured, or leaking LP collars shall be rehoved from the field-forrepair or pro@er.disposal.; Damaged collars shall be placed individual1y:in

.... leakproof-.cont.ai.r?ers :whsle .awai.tingrepa.jr, 

### .or pr~per&. .a.s... ..... ....... ... -,disposal. ~uthorized. colltar repairs are limited' 

### to

. minor repairs of straps and fastenings- Leaking or . punctured collars must be properly disposed. 

### .@ 13. Dispose of 1080 wastes (punctured, leaking, or otherwise unrepairable LP collars; contaminated leather clothing, animal remains, wool, hair, vegetation, water, and soil) under three feet of soil,'at a safe\location,preferably on property owned or managed by the applicator and at 

### - ... . least 1/2 'mile. from 'humanhabitations and water
. . . supplies. No more than 10 collars may'be buried -inany one hole., If buried .ina.trench,.each group of 10, .. :.. . . . . . . ..
.. 'collars musf be .atleast. i.0 feet
.apart

# .' '
.Y Incineration may be used instead of burial for disposal in the field (preferably on property owned or ,managedby the applicator) at least mile from human habitation and water supplies. Place collars and wastes (listed
- above) in an incinerator or refuse hole, saturate with diesel fuel, and ignite- Attend the burn until the contaminated material is completely consumed.fk Alternatively, contact your State Pesticide or Environmental Control Agency or the Hazardous Waste representative at the nearest EPX Regional'Office.for guidance in disposing of wastes at approved hazardous waste disposal facilities. When snow or frozen ground make on-site disposal impractical, up to one cubic foot of wastes may be , ,, stored in a leak-proof container, in a dry, lockedp!.ace ' for 90 days. , 

### .
8 Metal Container: Triple rinse contaminated and

. uncontaminated containers with water. Puncture and dispose of contaminated container and rinsate as a~ove.
,,

t Plastic Container: Triple rinse with water. Thel~. puncture and dispose of container and rinsate as abovre.1- U- 

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A Compound 1080 Livestock Protection Collar

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