1080 Data Quality

Page No. Source Quotes from Decision Documents
294 4 Agency App. B “Despite efforts over the last decade to address data gaps in the toxicology database for 1080, deficiencies remain in the information”
294 5 Agency App. B “Some studies have not been carried out in accordance with modern international test guidelines. The Agency did not consider that this introduced significant uncertainty to any of the critical findings”
294 8 Agency App. B “Other data on 1080 that would be desirable are..studies on dermal absorption, acute inhalation and..the reversibility of effects on the male reproductive system”
295 1 Agency App. B “chronic toxicity [studies are] not considered by the Agency to be essential because of the negative mutagenicity data and the unlikelihood of chronic exposure to the substance”
298 1 Agency App. B “The Agency usually requires results based on studies that [meet] GLP [Good Laboratory Practice] requirements and an appropriate test guideline…however there is quite a lot of information..and the findings are consistent [on acute oral toxicity of 1080]”
299 2 Agency App. B “dermal [toxicity] data are limited”
300 2 Agency App. B “The lack of [acute inhalation] toxicity data for 1080 represents a data gap”
303 Agency App. B “Fagerstone et al…cited an unpublished skin irritation study (Savarie & Cerven, unpubl.)..[on 6 rabbits]..cited in the USEPA RED..as (Cerven 1987a)..the Agency concluded a 6.3B classification is appropriate..on the basis..[of]..this rabbit study”
304 1 Agency App. B “Fagerstone..cited an unpublished eye irritation study (Savarie & Cerven, unpublished)..cited in the USEPA RED [as] Cerven 1987b..the Agency concluded a 6.4A classification is appropriate..[on the basis of this study]”
304 2 Agency App. B “The Agency was unable to locate any studies on the ability of 1080 to cause respiratory sensitisation…therefore, found no evidence of respiratory sensitisation for 1080. There was insufficient data to assign a classification on the end point is not triggered”
304 3 Agency App. B “The Agency was unable to locate any studies on the ability of 1080 to cause contact sensitisation…therefore found no evidence of contact sensitisation for 1080. There was insufficient data to assign a classification on the end point is not triggered”
305 1 Agency App. B “The Agency was unable to verify that the mutagenicity studies reported..were carried out in accordance with an established international guideline”
305 3 Agency App. B “the results of these 3..studies were reported to provide strong support for the hypothesis 1080 is not genotoxic (Eason et al., 1999)..the final reports do not refer to a study design according to the OECD guidelines..but (to) Appendix A: Protocol..which was not available to the Agency”
305 4 Agency App. B “The Agency’s User Guide…indicates that only the in vivo tests systems provide a definitive basis for classification..The Agency considers that the negative finding in the in vivo study [one study on mice with no study design available] provides sufficient information to conclude that 1080 does not trigger mutagenicity”
306 1 Agency App. B “The Agency did not find any studies that had been carried out to determine whether or not 1080 can [cause] carcinogenicity in any mammalian species”
306 2 Agency App. B “carcinogenicity data are usually required for substances for which chronic exposure is likely..even considering its extensive proposed use, the likelihood of prolonged exposure..is very unlikely”
306 5 Agency App. B “The data for developmental studies (teratology) are relatively sparse. Detailed studies carried out in recent decades in accordance with appropriate test guidelines have only been carried out on rats. Studies in other species commonly used in regulatory decision-making, particularly rabbits are not available. Further studies..are desirable, as species variability in..developmental toxicity is well recognised”
309 2 Agency App. B “The incompleteness of the toxicology database of 1080 overall is highlighted by the fact that no comparative toxicity values (such as LD 50 values) appear to be available for..common strains of rat”
310 1 Agency App. B “no studies [on reproductive toxicity] are available which compl[y] with international guidelines”
311 2 Agency App. B “Studies on the reversibility of the male reproductive toxicity are highly desirable”
311 3 Agency App. B “the Agency is of the view that further investigations on the reproductive toxicity of 1080 are desirable due to the severity of the effects found”
312 1 Agency App. B “The Agency does not have the full study report of the investigation [on reproductive effects of 1080 in rats] carried out for Landcare..but carried out this assessment based on the summary in the paper, Eason & Turk”
312 2 Agency App. B “The method [used to study oestrus cycle effects in rats, carried out for Landcare] is not one documented in any international guidelines”
317 1 Agency App. B “The report of the first stage [Meikle et al., 1996 Landcare report on health and reproductive perfomance in sheep] was not available for review by the Agency”
330 1 Agency App. B “It may indicate that a small amount of fluorocitrate is produced from dietary fluoride..but such a conclusion is not justified on the basis of a single, unconfirmed finding”
334 1 Agency App. B “the only species in which [developmental effects of 1080] have been identified is the rat..data for other species would give some indication of..the degree of variation in sensitivity between species”
337 1 Agency App. B “Parkin et al 1977) claimed a case of chronic poisoning in an occupationally exposed rabbiter..on the basis of subsequent debate [on analytical results] and..uncertainties..the study cannot be considered to be proven, so it does not form a reliable basis for regulatory decision making”
343 1 Agency App. B “In the absence of an LC 50 value for 1080, the question remains how the classifications of the formulas can be derived. The Agency concludes the only basis for a decision was expert judgement [regarding classification for inhalation”
349 14 Agency App. C “monitoring information [on reproductive toxicity to birds] is limited by factors such as short pre-operational observation period, seasonal fluctuations”
349 5 Agency App. C “[regarding ecotoxicity classification] Many of the older data are of poor quality, with insufficient information..to allow full evaluation..some of the more recent data..also lack details which would be expected in a full regulatory report”
349 12 Agency App. C “Data gaps..adsorption/desorption in a range of soils”
349 13 Agency App. C “Data gaps..reproductive toxicity to birds” (lizards, invertebrates, frogs, bats, fish not studied either)
349 6 Agency App. C “Data gaps..Toxicity to algae..[mitigating factor is] low concentrations in water from normal operation practices but could be relevant to spills”
349 7 Agency App. C “Data gaps..Toxicity to..aquatic invertebrate species given the high toxicity to mosquito larvae”
349 8 Agency App. C “Data gaps..Toxicity to..aquatic invertebrate species [mitigating factor is] low concentrations in water from normal operating practices, but could be relevant to spills”
349 9 Agency App. C “Data gaps..chronic aquatic toxicity data”
349 11 Agency App. C “Data gaps..biodegradation in aquatic systems and in soils at varying pH, soil type and temperature”
350 1 Agency App. C “Data gaps..toxicity to..terrestrial invertebrates”
350 2 Agency App. C “monitoring information [on toxicity to terrestrial invertebrates] is limited by factors such as short pre-operational observation period, seasonal fluctuations”
350 4 Agency App. C “The Agency still has concerns regarding the applicability of the degradation studies”
350 5 Agency App. C “Loss of 1080 from soil stored at -20 oCwas identified in a Landcare report..(2003)..the Agency sought clarification from Landcare Research..their response highlights the uncertainty around the loss of 1080 from stored samples and suggests that concentrations of 1080 in such samples may have been under-reported”
350 7 Agency App. C “The accuracy of results from other laboratories may be similarly uncertain, with details of sample collection and storage similarly absent from the published literature”
350 9 Agency App. C “No standard bioaccumulation tests have been undertaken with 1080”
351 4 Agency App. C “the few soil organism toxicity data available indicate low toxicity”
351 5 Agency App. C “1080 is very toxic to vertebrates..reptiles and amphibians appear more tolerant than birds and mammals, but time to onset is slow and data on New Zealand species, which are taxonomically distinct, is sparse”
351 7 Agency App. C “hazard classifications are based on a review..supplied by the applicants..and a search for other readily available information”
352 1 Agency App. C “wherever possible, the Agency has sourced and reviewed the primary data sources in an attempt to reduce some uncertainties inherent in relying on secondary or tertiary sources”
352 2 Agency App. C “No standard guideline studies were submitted by the applicants on the aquatic fate and degradation of 1080 and none were located by the Agency other than on the hydrolysis of 1080”
357 1 Agency App. C “Results obtained from the two repeats of the test were inconsistent, with time to loss of half of the 1080 from water [5  μg/L with aquatic plants] varying markedly..[from 17.9 hours  in one test to 65.6 hours in the other]
357 6 Agency App. C “The information available on the disintegration and weathering of cereal baits has been almost invariably reported for one of two bait types..these names are largely historical and with one exception, are no longer manufactured. As such, the information presented..can only be considered as indicative for the current cereal bait formulations”
359 2 Agency App. C “The lack of data [on aquatic degradation] from a standard test method…makes the assessment of the rate of degradation more complex..”
360 1 Agency App. C “The available set of high quality acute data [on aquatic toxicity] is small. No chronic studies have been undertaken”
360 2 Agency App. C “the Agency was not able to locate, any data on the aquatic toxicity of the metabolite fluorocitrate in water or soil”
360 3 Agency App. C “the..result for mosquito larvae suggests that some species and/or life stages may be much more sensitive to 1080, but this cannot be confirmed”
360 4 Agency App. C “there is significant uncertainty regarding the aquatic classification of 1080 due to the quality of the data available. None of the aquatic plant studies has been conducted to current international standards””
365 2 Agency App. C “the aquatic hazard classification of technical grade 1080 is very uncertain..and [this also] applies to the classifications of the substances containing 1080”
367 2 Agency App. C “in most of these studies [on soil] the micro-organisms have been..[cultured]..on 1080-rich media in the laboratory..rather than using soil as in standard soil biodegradation studies”
368 1 Agency App. C “The authors noted..due to the highly heterogeneous nature of the soil environment a more comprehensive sampling would be required to adequately characterise the microbial population [regarding its ability to defluorinate 1080]”
369 2 Agency App. C “There is limited information available on the degradation of 1080 in animal carcasses..It is clear that 1080 residues remain in the guts of dead animals for prolonged periods (at least 75 days under cool winter conditions..) and only degrade slowly”
373 2 Agency App. C “No studies have been conducted using standard international guidelines to assess the route and rate of degradation of 1080 in soil..while [lab] studies have indicated the ability of some soil organisms to biodegrade 1080, the rate of such degradation under New Zealand conditions is uncertain. Likewise, no robust studies on the adsorption/leaching of 1080 were available to the Agency”
374 1 Agency App. C “No standard guideline studies on the adsorption, desorption or leaching of 1080 were submitted..or located by the Agency”
374 2 Agency App. C “the adsorption and leaching potential of 3 NZ soils [were studied by Parfitt et al]..the Agency only had access to the study as published..and a large number of deficiencies are noted”
374 4 Agency App. C “test soils were sieved to 6mm..standard method states soil..should be sieved </= 2mm..test system allowed to equilibrate for 4 hours, 24 hours is recommended..test conditions and results not well documented..non-standard, non-GLP”
375 4 Agency App. C “the information..on degradation and weathering of cereal baits [is almost all from two bait types..these names are largely historical and..no longer manufactured..information..can only be considered indicative”
376 3 Agency App. C “The [1080-treated] oats remained toxic to rabbits for the duration of the trial (7 weeks) [Australian study]..the relevance of the loss of 1080 from oats under Australian conditions to those in NZ is unknown”
377 1 Agency App. C “the rate of 1080 breakdown in baits in the field was assessed..analysis was complicated by: inconsistent recording of bait size; 1080 loading varying 0.08- 0.15%..rainfall and habitat not recorded in a way which allowed meaningful interpretation..bait type not always being recorded..small sample size (n=8 records for carrot bait)”
384 4 Agency App. C “The applicants have submitted 3 studies on 2 [introduced] earthworm species and one on the [introduced] garden snail..[these studies] are deficient..the Agency considers that..the actual exposure concentrations are not known”
384 6 Agency App. C “Springtails (Collembola) have been observed on baits..and..a study on the toxicity of 1080 to these organisms would be useful as a representative of soil insects. Collembola are recommended test organisms [internationally] due to their high abundance in soil ecosystems”
384 5 Agency App. C “there were significant issues with the analysis of the test concentrations in the soil..in the test with garden snails..attributed to degradation of 1080 in the samples in storage”
385 1 Agency App. C “Plants: The applicants submitted a..study on effects of 1080 on seedling emergence and early growth..in oats..and..lettuce. A standard regulatory assessment would normally include a greater number of species in order to assess variability in responses”
385 2 Agency App. C “On the basis of the information available [one study on lettuce and oats] the most sensitive end point is seedling growth is lettuce, with a 14-day EC50 of 10 mg 1080/kg soil and LOEC of 7 mg/kg soil”
385 3 Agency App. C “Only one study was submitted on the toxicity of 1080 on soil microbial function..ie effects on nitrogen transformation..rather than two studies as would normally be expected in a full regulatory data package [ie] a study of the effects on soil respiration has not been conducted”
386 2 Agency App. C Total number of cocoons produced in the control did not meet test criteria..no reliable values were obtained..possible lack of sexual maturity [of worms]
391 2 Agency App. C “predicting the toxicity of 1080 to an untested species from data even on closely related species is difficult given the variations in response across and within taxonomic groupings”
392 2 Agency App. C “factors such as a decrease in ‘trappability’ of possums in winter may have an influence in assessing the operational outcomes”
393 1 Agency App. C “LD 50 [for possums, values range from] 0.47 mg/kg bw to >125 mg/kg bw”
400 1 Agency App. C “The Agency only had access to the results of the studies [detailed studies on birds] as presented in the open literature, and not to the full reports”
414 1 Agency App. C “The Agency has not been able to locate any data from standard tests on the reproductive toxicity of 1080 to birds”
415 3 Agency App. C “The trials [on toxicity of 1080 in bait, prey and water to NZ native frogs] were preliminary, rather than providing standard end point data”
416 5 Agency App. C “No data are available on the toxicity of 1080 to native NZ reptiles (geckoes, skinks and tuatara)”
421 1 Agency App. C “The toxicity of 1080 to terrestrial invertebrates has not been assessed using standard international guidelines..[some studies in the 1950s] were aimed at assessing..1080 as an insecticide for commercial horticulture”
421 2 Agency App. C “there is considerable uncertainty regarding the toxicity for bees..due to the quality of the study and the lack of information on how the LD 50 was derived, and even the units for the LD 50. The relative toxicity between species is also highly uncertain”
428 1 Agency App. C “The toxicity value used by the Agency is the..honeybee LD 50 (Palmer-Jones 1958)..if the bee value is used [1080 paste] does not trigger the threshold, if the ant value is used..it would classify as 9.4A highly toxic to terrestrial invertebrates” (bee data criticised on page
434 2 Agency App. C: Fisk “The purpose of this review..is to assess whether available published evidence is sufficient to assess the persistence of monofluoroacetate”
434 3 Agency App. C: Fisk “The sources [17 papers on 1080] were provided in electronic form by ERMA. No prior review other than the published sources was provided”
435 1 Agency App. C: Fisk “The pathway and rate [of uptake by organisms] would need to be considered in order to determine whether such a process is important in determining the assessment of overall persistence”
435 2 Agency App. C: Fisk “Once basic pathways and rates [of degradation] are delineated, it is possible to use mathematical environmental models to establish whether monofluoroacetate is persistent in the total environment or individual components of it”
436 1 Agency App. C: Fisk “the half life in soil [DT 50] which is the time required to reduce the original concentration of the substance in the soil by 50% and would usually be assessed using a standard test guideline”
436 2 Agency App. C: Fisk “The papers [provided by ERMA to review are] believed to have been developed following extensive literature searching by ERMA, and therefore no additional searching was carried out”
437 1 Agency App. C: Fisk “These data [fluoroacetate and fluorocitrate in aquarium studies] are all incorrectly calculated, being 10-fold lower than actual amounts..the data manipulation is very poor and should not have passed the referees’ scrutiny” (Booth et al., 1999)
441 1 Agency App. C: Fisk “[this study on 1080 degradation by soil microbes from Australia] is clearly a summary and a few more details would be useful”
443 3 Agency App. C: Fisk “Sampling soil [for organisms that can degrade 1080]..presents a..problem of heterogeneity”
449 2 Agency App. C: Fisk “This is a summary paper with little experimental detail; however, it does have some very important conclusions..that the ability to detoxify fluoroacetate is a common attribute in soil bacteria and fungi”
453 4 Agency App. C: Fisk “There are no data as to whether the metabolic compounds are fluorocitrate (toxic) or glycolate (non-toxic) or any other potential product of metabolism [study on removal of 1080 from water by plants]”
453 5 Agency App. C: Fisk “This report is not clearly or concisely written and examination of the results shows that some of the actual conditions..differ from those stated..there is also a methods summary section that is different from the main methods section. A repeat..would be advantageous”
454 7 Agency App. C: Fisk “In soil there are no reports where degradation studies have been performed using a standard test guideline”
457 1 Ag. App. C: Sample storage “no further work has been undertaken to more fully investigate factors potentially affecting degradation of 1080 in soil during frozen sample storage [at -20°C] e.g. Soil type, water content, microbial population, and from there identify the most valid procedures for storage and processing samples..in the light of the findings by O’Halloran & Jones (2003) [1080] present in some samples..may have been degraded during storage at -20°C to present undetectable concentrations at analysis.”
467 1 Agency App. E “The timing of sampling [of environmental media] relative to an operation and the storage of samples before analysis is critical to interpretation of the results of monitoring.”
467 2 Agency App. E “Several reports provide highly summarised results [of water quality monitoring]”
467 3 Agency App. E “Limited information is available on dust drift and it is not known how representative this information is”
472 1 Agency App. E “A recent [water] sampling protocol..(2001)..[states that] ‘Samples should be taken immediately after poisoning and continue daily until after the first significant rainfall’..few of the monitoring programmes reported such frequent initial sampling, possibly because there was no regulatory requirement to do so..or because of the cost of sample analysis”
472 2 Agency App. E “Bulking of [water] samples, while expedient, may mask samples that do contain measureable amounts of 1080”
472 3 Agency App. E “In relation to environmental monitoring, the Agency notes the concerns about storage [e.g.] Eason..refers to water samples being frozen “within 5 hours” of collection, which seems a..long period before appropriate storage”
473 1 Agency App. E “the reason for so many non-detects in water monitoring..may be partly due to..rapid..dilution or loss of 1080 from, and disintegration of..baits within the first 12 hours of deposition..the author [Suren, 2006] recommends sampling within 4-8 hours..frequently resource consents require monitoring one day or more after..the operation”
474 1 Agency App. E “Due to costs of analysis, not all water samples were analysed. Sequential samples were aggregated in groups of 3 before analysis.”
475 6 Agency App. E “The Agency is not aware of any other studies reporting on dust drift from aerial application of 1080..there is insufficient information to know whether other bait types or delivery buckets would create more or less dust”
480 5 Agency App. F “The applicants provided very brief results from the monitoring of effects on non-target native species”
480 6 Agency App. F “much of the monitoring data [on non-target species] presumably exists within various contractual operational reports and is not available to the Agency..the Agency assumes the information reviewed..is likely to be representative of current investigations, and in some cases demonstrates an improvement in practice over time”
481 1 Agency App. F “The applicant did not specifically discuss effects on non-native species (other than target species) in the environmental effects register. Only a small number of reports note effects on introduced birds”
481 2 Agency App. F “the older monitoring reports did not always..mention the actual technique used [for monitoring possum numbers] and acknowledges that there may be some uncertainty”
481 3 Agency App. F “the RTCI [residual trap catch index] may not be accurate”
481 4 Agency App. F “the RTCI [has a ] decreased probability of capture [at high possum densities] and can vary seasonally..the probability of capture on farmland was lower in spring..than winter and summer..whenever possible, use of the RTCI for comparative purposes should be conducted in the same season.”
482 1 Agency App. F “Five-minute counts have been identified as not reliable for assessing population impacts after 1080 operations unless high mortality occurs..and not reliable for rarer species”
483 1 Agency App. F “Specific monitoring methods have been developed for robins [including] the time taken for a population to recover from impact”
483 2 Agency App. F “Artificial refuges may be occupied by a wide range of invertebrate species..however, immature weta are less likely to be found”
483 3 Agency App. F “mark-recapture techniques..are applicable only to larger-bodied invertebrates”
483 4 Agency App. F “the taxa found on baits may not be caught in pitfall traps in sufficient numbers for an assessment of impacts at species level.”
483 5 Agency App. F “video monitoring cannot detect..invertebrates..under baits, but may be useful for observations of large-bodied species.”
483 6 Agency App. F “A standardised foliar browse index (FBI) developed by Landcare and used by DoC since the late 1990s..has proven to be inadequate for monitoring northern..and southern rata..as has an alternative method called “Rata View”
484 1 Agency App. F “Deaths of..birds have been reported frequently after pest control operations, but generally do not give any indication of potential effects at a population level”
484 2 Agency App. F “Systematic searches for dead birds are not common practice”
484 3 Agency App. F “[the level of detail in the reports on] monitoring of bird populations..is highly variable..in many cases, the conclusions that can be drawn..are limited by lack of replication and/or lack of suitable control (untreated) blocks.”
484 8 Agency App. F “it is evident..that carrot bait may [have] inaccurate toxic loading, poor dye coverage..poor screening to remove chaff..the Agency does not have sufficient information to determine how frequently these problems..occur and what impacts they..have [on] pest control or on non-target species.”
485 1 Agency App. F “there does not appear to be [an] industry standard [for fine pieces of carrot bait], although the Agency does not have sufficient information to fully assess the matter, having only been provided with the standard operating procedure for one contractor used by the AHB (further information from the applicants, 22 December 2006)”
485 2 Agency App. F “The Agency is unaware of information on the effects of 1080 operations on game birds”
487 1 Agency App. F “Five-minute counts [used to monitor poisoning effects on birds]”
489 5 Agency App. F “Five-minute call counts [used to monitor kea after poisoning]”
491 4 Agency App. F “Five-minute counts [used to monitor tomtits after poisoning]”
494 2 Agency App. F “Five minute counts..no measurable impact on numbers [of riflemen] 2-8 weeks after the operations”
494 5 Agency App. F “5-minute counts..No detectable impacts on the numbers of [whiteheads] 2-8 weeks after the operations”
495 2 Agency App. F “Five-minute counts..60% decline in [Brown creeper bird] counts after the operation, returning to pre-operational levels one year later”
495 3 Agency App. F “Five-minute counts..were similar [for Brown Creeper birds] one year before and one year after..operations”
495 4 Agency App. F “five-minute counts [of Yellowhead]..no significant changes..immediately after the 1080 operation. Author noted deficiencies in the sampling”
496 1 Agency App. F “Five minute call counts [of Kakariki]..no detectable impact on number of counts”
498 2 Agency App. F “the proportion of (kokako) pairs which did not attempt to breed was estimated as 75% at the start of management..and decreased to 8%..attributed to male-male pairs in early stages of monitoring, with banded males pairing off with newly fledged females”
500 2 Agency App. F “Five-minute call counts..before/after [aerial 1080 operation, native forest birds] differences may reflect changes in food availability with time, and..shifts in preferred habitat with season”
501 2 Agency App. F “Five-minute call counts..before/after [aerial 1080 operation, introduced forest birds] differences may reflect changes in food availability with time, and..shifts in preferred habitat with season”
501 3 Agency App. F “call counts taken..in..one control”
503 1 Agency App. F “Call counts [monitored] in 1998 and 1999..increases [in tui and silvereye]..attributed to a heavy pohutukawa flowering”
503 3 Agency App. F “Ten-minute call counts [of moreporks, used to monitor 1080 cereal operation]..Number of birds..declined in the control block [this was] attributed to a less experienced person counting”
504 3 Agency App. F “Five-minute call counts..no measurable effects [of 1080 carrot operation on weka] insufficient number..present to assess..impact”
510 2 Agency App. F “The report [Meads, which showed a significant adverse effect of 1080 on invertebrates] was not approved by DoC..on the basis of..flaws in the methodology..and the quality and interpretation of data”
510 3 Agency App. F “pitfall traps were used [by Meads] and invertebrates trapped do not adequately reflect the full species assemblages present, but should be used to study species known to respond predictably to this method”
510 4 Agency App. F “only a single control and single treatment transect were used [by Meads]”
511 1 Agency App. F “[common species observed on cereal and carrot baits] ants..various weta species, beetles, earwigs, harvestmen, mites..whole invertebrate groups were absent from the observations (eg native earthworms) which may be..an artefact of the difficulties in observing invertebrates feeding under baits]”
513 4 Agency App. F “Cave weta may have a better escape response compared with tree weta..so effects [of population changes]..may be less readily observed”
514 1 Agency App. F “Variable occupancy of [artificial] refuges [for invertebrates] in both [aerial 1080 treated and untreated] areas..limited comparisons which could be made”
514 3 Agency App. F “Leaf-veined slugs: Increased in treatment area but attributed to environmental conditions at that site being more favourable for slugs than at the control site”
515 2 Agency App. F “the post-application observation period was too short to allow assessment [of effects of cereal 1080 application] on invertebrate numbers”
516 4 Agency App. F “Apart from one species of amphipod, too few [invertebrates were caught in pitfall traps] to allow for individual [species] analysis for changes in abundance [after cereal poisoning]”..(no results given for the amphipod)..”No significant effects on numbers on invertebrates caught when assessed at the family, order or class level”
516 4 Agency App. F “Apart from one species of amphipod, too few [invertebrates were caught in pitfall traps] to allow for individual [species] analysis for changes in abundance [after cereal poisoning]” (no results given for the amphipod)
516 5 Agency App. F “Heavy rain and gale force winds on first few nights [after bait laid]..resulted in only 2 nights of counting [invertebrates]”
516 7 Agency App. F “Samples of leaf litter [and] invertebrates [taken before and after poisoning] lost due to freezer malfunction [Spurr et al., 2002]”
517 1 Agency App. F “Apart from one species of amphipod, and the ant Huberia brouni, too few [invertebrates] were present to allow for individual analysis of changes in abundance [after poisoning]”..(amphipod or ant results not given)..”No significant effects on numbers on invertebrates caught when assessed at the family, order or class level”
517 1 Agency App. F “Apart from one species of amphipod, and the ant, too few [invertebrates] were present to allow for individual analysis of changes in abundance [after poisoning]” (amphipod or ant results not given)
517 4 Agency App. F “Apart from one species of amphipod, too few [invertebrates] were present to allow for individual analysis of changes in abundance [after carrot poisoning]”..(amphipod results not given)..”No significant effects on numbers on invertebrates caught when assessed at the family, order or class level”
517 4 Agency App. F “Apart from one species of amphipod, too few [invertebrates] were present to allow for individual analysis of changes in abundance [after carrot poisoning]” (amphipod results not given)
518 1 Agency App. F “Few studies have attempted to assess the benefits of mammalian pest control on invertebrates, other than the giant land snails Powelliphanta..though this is an area of complex research..warranting further investigation”
519 1 Agency App. F “[Powelliphanta] snail abundance [measured] in 2000 and 2002 [aerial cereal poisoning in 1995 and 2000]” (no measurements pre-poisoning in 1995)
519 3 Agency App. F “Snails take about 3 years before young big enough to detect..further monitoring [to assess effects of 1080] needed” (translocation of snails by DoC will have left juveniles, also large risk of trampling damage)
520 1 Agency App. F “Hochsetter’s..frogs were monitored..during an aerial operation..no change was detected in the Hochsetter’s..population but [statistically] there was only a very small probability of detecting an impact because the number of frogs [was] too small..no conclusions could be drawn”
520 2 Agency App. F “Archey’s frogs were monitored..during an aerial operation..declines in numbers occurred in both treatment and control areas [during the four months after control]..attributed to seasonal and/or disturbance factors”
520 3 Agency App. F “One Archey’s frog was found foaming at the mouth [which] may have indicated 1080 poisoning..however other signs of 1080 poisoning..were not observed..either due to short observation periods..or because they did not occur”
521 1 Agency App. F “Groups of bats were captured when returning to their roost and held in captivity for 48 hours (to assess mortality after a 1080 cereal operation]. No [deaths] or signs of poisoning occurred..further information..is needed..to fully assess the potential impact of 1080”
521 3 Agency App. F “There is little data available on confirmed poisonings of livestock and companion animals”
521 6 Agency App. F “the Agency does not know whether poisonings [of domestic animals occurred between 2003 and 2006] and were not formally diagnosed or were not reported via [Surveillance, MAF publication, which published cases until 2003] “
522 1 Agency App. F “Feral deer and other ungulates have been direct targets of 1080 operations..they may also be killed as accidental “by-kill”
525 2 Agency App. F “kill estimates conservative due to..likelihood of immigration [of deer in year following aerial treatment of 40, 000 ha]”
526 8 Agency App. F “no significant improvement [in Northern Rata after 1080 operation] but issues with adequacy of the Rata View monitoring method”
527 8 Agency App. F “[a critique of the DoC monitoring reports on vegetation [2003]..recommended] investigation of the accuracy of the RTCI at low possum densities”
528 1 Agency App. F “The use of non-treatment (control) sites for comparison against treated areas was fairly sparse in the reports [on vegetation monitoring] examined, limiting conclusions..in terms of effects of possum control”
528 2 Agency App. F “Fruiting and flowering data were generally not reported in the monitoring studies reviewed by Green (2003a), despite [their] significance for..ecosystem maintenance and regeneration”
528 4 Agency App. F “The Agency notes that overall, the relationship between possum density and vegetation response is complex and still not fully understood”
530 2 Agency App. F “A small short-term reduction in..stoneflies, mayflies, caddis flies was noted 5 days after the [cereal 1080] drop. A short-term drop in the total number of species was also observed in some [of 4] streams. Such reductions were not observed in the control stream..14 days [later] species and abundance were generally higher than before the operation..the authors concluded the changes were related to a flood event prior to the operation”
531 1 Agency App. F “Information on the kill rates achieved in DoC operations was..not as comprehensive as the Agency had anticipated..The Agency sought further information..where such information was provided by DoC, it is indicated in the text..DoC indicated that it would take a considerable amount of time to revisit the information..and determine whether ..additional observations [met] the criteria”
531 2 Agency App. F “No information [on kill rates achieved] was included in..the application from the AHB. The Agency sought further information..the AHB was not able to provide any information as its database is still under construction”
531 3 Agency App. F “The Agency sought further information from..the AHB on its kill rates for various species and operational conditions..the AHB was not able to provide any..information as its database is still under construction”
531 4 Agency App. F “DoC reviewed possum kill rates..a summary was included..in the application..the Agency sought clarification as to why there [were] so few results..given the time frame…Several criteria [had been applied]”
536 4 Agency App. F “However the author indicated that neither of the indices derived [for assessing goat numbers] was capable of much precision, so it was not possible to draw a conclusion”
539 1 Agency App. G “The applicants have provided little factual support to demonstrate the efficacy of aerial versus ground application of 1080 as it relates to possum control”
539 2 Agency App. G “The Agency has carried out its own evaluation of the effects of aerial 1080 on possum density as it relates to Tb control but notes that the committee may require a more detailed assessment”
539 3 Agency App. G “The Agency considers that the applicants have not fully detailed the basis for their forecast of the areas predicted to be occupied by Tb infected wildlife without the continued use of 1080”
540 1 Agency App. G “The Agency notes the applicants have provided little factual support to demonstrate efficacy of aerial compared with ground application of 1080 as it relates to possums and Tb control”
540 2 Agency App. G “The applicants..have provided very limited supporting information to demonstrate the importance of aerial 1080 operations in terms of controlling possums and the subsequent effect on the prevalence of Tb”
540 3 Agency App. G “The applicants have not referenced the statement [that possums are the main maintenance hosts for bovine Tb in NZ]”
546 2 Agency App. G “While the applicants state these negative findings of Tb [from intensive testing and wildlife surveys in operational areas], no results of such surveys or surveillance have been provided..to verify the applicants’ assertions”
547 1 Agency App. G “No data or references have been supplied by the applicants to verify that [eradication of Tb from wildlife in 5 areas] was achieved thorough the maintenance of an RTCI value lower than 2%”
548 2 Agency App. G “Tb occurs in feral cats and ferrets..their importance as significant reservoirs of Tb infection..is unknown”
550 1 Agency App. G “The Agency requested that the applicants supply the references used to compile this case study..the applicant has provided no information to support declining numbers of infected herds [in the case study]”
554 1 Agency App. G “The Agency considers that this additional explanation provided by the applicants does not fully detail the basis of the model for the “without 1080″ scenario”
557 2 Agency App. G “With regard to only aerial application being able to achieve [the AHB’s 4 objectives for possum control regarding Tb] simultaneously, the Agency has identified very little specific supporting  information”
557 3 Agency App. G “While the findings of Speedy (2003) do support the use of aerial application as the more efficacious control operation, the Agency notes that the study was only carried out at one..site..the Agency is therefore unable to comment as to whether the results obtained are representative”
558 1 Agency App. G “the Agency has been unable [to] conclusively determine that aerial application is the only method that will simultaneously achieve the four conditions stated to be required for Tb eradication from wildlife”
560 1 Agency App. H “The most relevant information on 1080 residues in meat..was Eason et al., (1994).The study established the half-lives of 1080 in [3] sheep..the half-life in sheep was..substantially longer than in goats”
560 2 Agency App. H “only 3 [sheep] were used [in a study by Eason, et al., 1994 on 1080 in animal tissues], and there appeared to be considerable variability in the half-life in different animals”
561 1 Agency App. H “No information was available to the Agency relating to residue of 1080 in milk from..cows..however one study [on ewe milk] has been reported..the Agency did not have access to the original report [by Eason]”
562 1 Agency App. H “The Agency did not find data on tissue residues [of 1080] in species which would be termed the main human meat sources, such as cattle, pigs, and deer”
562 3 Agency App. H “Note that [toxicity LD 50] values for cooler temperatures rather than under laboratory conditions are most relevant”
563 1 Agency App. H There are no data for deer or pig[s] which may also be poisoned and then taken, but the assumption is that the residues in sheep give an indication”
579 1 Agency App. J: Cullen “The economic case for 1080 is largely based upon the assertion that aerial pest control is lower cost and more effective than is ground pest control and can be used to manage large and rugged areas. Surprisingly, given the importance of these items, no references are cited in support of these assertions..the lack of documented support is..surprising as research has been completed in New Zealand on pest control costs, and effectiveness of control methods”
580 3 Agency App. J: Cullen “The Application..fails to demonstrate evidence or understanding of economic research on use of 1080, pest control or Tb..this section of the application is unsophisticated, uses crude approaches to estimate even the largest benefits and costs associated with the use of 1080, lacks awareness of many pertinent economic research techniques, seems unaware of almost all relevant economic research”
580 4 Agency App. J: Cullen “Given the importance the HSNO Act..attaches to identifying and considering benefits and costs the Application is amateurish in the way it addresses those issues..high quality economic research [is required] to ensure that informed decisions can be reached..the Application, regrettably, does not provide quality economic analysis and fails to cite existing relevant economic research”
581 1 Agency App. J: Cullen “No evidence is provided in the Application that a current estimate of possum numbers..has been obtained”
582 1 Agency App. J: Cullen “The application states the..effect [of using 1080 to control Tb on the chance of formal restrictions access to export markets] is..Major..but provides no supporting calculations [or research, but other authors have said] ‘the chance of NZ facing a ban simultaneously in our major markets is..so small..that it is almost non existent”.”
582 2 Agency App. J: Cullen “The Application seems completely unaware of the range of economic techniques available to provide..defensible estimates of..effects of trade restrictions”
582 3 Agency App. J: Cullen “No research is cited in the Application that studies the dollar losses occurring from the  loss of one or more export markets [due to market perceptions of NZ’s Tb status, however] Clough & Nixon (2000) conclude..a trade ban would be difficult to sustain under current international trade rules, the risk is very small and the expected value of an avoided trade ban is modest”
584 3 Agency App. J: Cullen Several of the effects considered [under Social and Community]..lack evidence about [their] magnitude. No evidence is provided in the Application to show there has been a search for literature to remedy that defect”
590 1 Agency App. K: Ford “The sections of the application reviewed do not reference or prove the rationale behind [the AHB’s] conditions on successful control”
591 1 Agency App. K: Ford “There is no apparent discussion on the robustness and reliability of this epidemiological monitoring [of Tb prevalence in the future]. There is no discussion or information provided about the risk or sensitivity parameters of the modelling carried out..achievement of the [Tb prevalence] target [may be] very difficult. Some discussion around the perceived ability to realistically achieve this target would be of value”
592 3 Agency App. K: Ford “There is no rationale given for the choice of the magnitude values chosen for each assessment value [in the Market Economy assessment matrices]..the assessment scales all appear to be somewhat arbitrary”
593 2 Agency App. K: Ford “there is no ability to determine the degree of confidence that can be attributed to the assessment assumptions. It may well be that average costs [from restrictions on livestock movements] are much closer to $30,000 per farm than $200,000”
594 1 Agency App. K: Ford “It would be doubtful whether the reported assumption of rabbits displacing 2 million sheep would be an accurate assumption post RHD. This is a core assumption in the assessment of the magnitude of impacts”
595 2 Agency App. K: Ford “Given the doubt and uncertainty over the validity of the major assumptions used in the assessment we would consider that the likelihood of improved productivity that would result from the use of 1080 for pest control within the next 10 years would neither be considered very likely or major and therefore may not justify the high significance rating given in the assessment.”
595 3 Agency App. K: Ford “This impact [reduced cost to agricultural sector and government associated with vector control] is difficult to review as the core assumptions are not made explicit in the assessment..no justification is given [for the classification E, extremely likely this will occur]..in order for [an E classification] there should be no doubt as to the robustness of the assumption”
596 1 Agency App. K: Ford “Justification for the assessment of this impact [decreased likelihood of loss of markets due to market perceptions of NZ’s Tb status] as E is scant..it is doubtful that a combined assessment of both very likely and of a major magnitude are a credible combination”
597 1 Agency App. K: Ford “Review of the 4 significant benefits [to the market economy from using 1080] would indicate that the assumptions and methodologies are not sufficiently robust..therefore we have doubt that they should be considered as significant..and may not justify or warrant costs or risks in order to be realised..however more rigorous assessment techniques over a longer time scale of analysis may prove that some of the magnitude ratings are achieved”
631 1 Agency App. L: Current controls “The applicant [to the Ministry of Health, to apply 1080 in an area where public health is at risk] must specify the maximum and minimum time periods during which the majority of the bait may be toxic, after application. The person acting under delegation from the Authority..must be advised in writing, when baits have ceased to become toxic” (current control (pre-decision) therefore should be plenty of data on this)
659 1 Agency App. M “[the] limited occupational monitoring data..available suggested some occupational exposures were unacceptably high. The Agency was unable to determine whether this was due to the need for further controls or whether inadequate compliance..was responsible”
663 1 Agency App. M “The Agency considers that ideally, the most appropriate parameter for whether..an adverse effect is likely to occur in humans..would be the lowest toxic dose..however [this] has not been established..so the Agency concluded the minimum lethal dose should be used instead..but..estimates of the doses of 1080 that have been taken by human cases of poisoning are rarely reported”
667 2 Agency App. M “The ADE [Acceptable Daily Exposure] is derived to protect the general population from chronic exposures, and..should normally be derived from a chronic toxicity/carcinogenicity study..there are no chronic toxicity studies for 1080”
674 2 Agency App. M “A limited amount of..testing of persons occupationally exposed to 1080 during the manufacture of cereal pellet baits was available..the data indicate that [this] may be associated with non-negligible health risks, which need to be assessed..this does not necessarily mean the other bait manufacturing activities..carried out in factories are necessarily free from similar risks, as no data on this were available… the Agency concluded that the controls relating to the manufacture of baits are sufficient to control worker exposures”
675 1 Agency App. M “A limited amount of..testing of persons occupationally exposed to 1080 during carrot bait manufacture and loading [indicates that this] may be associated with non-negligible health risks..the Agency identified the need for information on [the containment of systems where the toxin is applied to bait]..despite these uncertainties, the Agency considers that the controls are adequate to protect workers”
677 1 Agency App. M “A limited amount of..testing of persons occupationally exposed to 1080 during ground bait operations..[suggests this is] associated with relatively low exposures to 1080, although due to limitations of the monitoring this was not unequivocally demonstrated”
679 1 Agency App. M “Detailed description of the subjects was not provided [in the Landcare study on 1080 levels in workers]. Usually in operational health investigations some basic data are provided..such as..[age, nature of duties, nature of protective clothing, lifestyle aspects]..sampling times [were apparently] not in accordance with the Department of Labour..criteria.”
683 3 Agency App. M “In relation to whether or not 1080 may exert effects on the male reproductive system, a targeted investigation would be needed..the Agency emphasises that the absence of reports of adverse effects does not mean that no such effects are occurring”
689 1 Agency App. M “The Agency did not assess the risk from dermal absorption because information on dermal absorption of 1080 is sparse”
693 1 Agency App. M “There may be some uncertainty associated with the [drinking water testing] results, when sample storage information is taken into account..Eason..refers to water samples being frozen ‘within 5 hours’ of collection..this seems a relatively long time before appropriate storage of the..sample was carried out, but it reflects the reality of sampling remote water sources and traversing the..area on foot”
700 1 Agency App. M “The Agency compared both the acute and chronic exposures that could occur from aerial 1080 operations, based on the water sampling data that have been reported”
703 2 Agency App. M “A conservative estimate is that milk from a contaminated animal could contain approximately 0.14 mg of 1080/litre. The application..suggests that milk residues are actually lower..but the Agency did not have the relevant information..The Agency expects that any potentially contaminated milk or products from it would be intercepted and destroyed”
707 2 Agency App. M “The highest plant tissue level [of 4 plants] reported was Day 3 in rye grass..Possibly this sampling time is a bit long after exposure, but it has been used in the absence of other data to reflect possible residues”
710 1 Agency App. M “The Agency has concluded that the occupational health risks associated with some 1080 manufacturing and use activities are potentially significant..this relates to factory workers..and field workers loading..treated carrot and cereal..pellet baits onto aircraft hoppers.. [the limited]..data available for review suggested some occupational exposures may be unacceptably high. The Agency was unable to determine whether this was due to the need for further controls”
721 1 Agency App. N “Evaluation of literature on the effects of [1080] usage [is] complicated due to the variable reporting of the 1080 formulation used”
721 2 Agency App. N “It is recommended that all reports and papers relating to research and monitoring should include the trade name of the product being evaluated”
723 3 Agency App. N “The Agency considers that further trials with bird repellent may be warranted given the problems with trials to date, that include lack of replication, issues with monitoring possum indices after the trials and less-than-toxic loading on the carrot”
723 6 Agency App. N “Due to the level of uncertainty in the toxicity data for invertebrates, and the lack of information on the amounts of baits likely to be eaten, the Agency has not attempted to assess direct exposure to invertebrates”
723 11 Agency App. N “While invertebrates feeding on poisoned animal carcasses may be exposed to 1080 residues, the Agency has not assessed exposure from this source. Any effects are likely to be minimal”
723 9 Agency App. N “The Agency has insufficient information to evaluate the attractiveness of..baits to skinks and has made no quantitative assessment of the risks of 1080 to skinks” (geckos not mentioned)
723 10 Agency App. N “The Agency has made no assessment of risks [of 1080] to frogs”
724 1 Agency App. N “Deer are killed by 1080. Addition of deer repellents has been trialled, but monitoring of its effectiveness has been patchy and frequently inconclusive”
734 3 Agency App. N “While differences in tomtit disappearances (assumed to be deaths) were not statistically different between blocks the authors considered that there was a trend for a lower rate in the repellent block [and that] the use of repellent had a positive impact and may assist in allaying public concerns..Lack of replication limits the conclusions which can be drawn from the study.”
745 2 Agency App. N “Generally, further monitoring [of birds] was warranted when less definitive techniques (such as 5-minute call counts) had been used previously”
746 1 Agency App. N “the [bird] monitoring results available to the Agency at the time of this review are likely to be incomplete”
746 12 Agency App. N “[Discredited method of 5-minute call counts used to assess impacts of aerial 1080 on birds, species include] kea..kakariki..rifleman..whitehead..grey warbler..fantail..tomtit”
746 11 Agency App. N “New Zealand falcon..lack of information on potential impacts of 1080 [situation in 1997]”
747 9 Agency App. N “Grey warbler.. Fantail..few found dead since carrot bait screened..widespread, disperses readily..no measurable impacts based on 5-minute bird counts”
751 1 Agency App. N “The variations were suggested by the authors to be due to the same bats having been used in rat bait trials..and [they] may have become accustomed to feeding on the plain paste”
751 2 Agency App. N “Only one value has been reported for the toxicity of 1080 to bats..for the American big brown bat..the sensitivity of [NZ] species relative to [this] is unknown”
751 3 Agency App. N “Secondary poisoning from ingestion of invertebrates..is a potential risk to short-tailed bats..long-tailed bats..catch invertebrates in flight..and have not been monitored during 1080 operations as the risk from secondary poisoning is considered minimal”
755 1 Agency App. N “The Agency has..made no quantitative assessment of the risks of 1080 to skinks”
757 1 Agency App. N “5-minute bird-counts were undertaken on 3 species [after an aerial operation with 1080 carrot with and without deer repellent]..only by inexperienced observers, with the authors acknowledging that the method used didn’t have the statistical power to detect anything but a very large degree of mortality”
757 4 Agency App. N “The authors noted that the low numbers of deer seen in all blocks after the operation limited the ability to determine whether the decline in the repellent block was significantly different from the non-repellent block”
757 5 Agency App. N “The Agency requested further information on the operation from the applicants, but only received excerpts from the post-operational report from the contractor..the information provided in the excerpts is very limited in scope”
757 6 Agency App. N “no other assessment [was] apparent except a statement that “numerous sightings of pigs and deer have been reported in the treatment area since the operation”, without any clarification as to [whether this area had been treated with 1080 or 1080 with deer repellent]”
759 1 Agency App. N “The Agency has made no quantitative assessment of risks to aquatic biota..Toxicity information available for aquatic life is limited, but indicates effects on..invertebrates only at concentrations >10 mg/L…There is..one very old report of effects [of 1080] on mosquito larvae at 25-100 μg/l”
762 1 Agency App. O “The applicant estimates areas of land that would not be treated under a cyanide/trapping scenario..but there is too little justification in the application for the Agency to evaluate this analysis”
763 1 Agency App. O “No data from monitoring of environmental concentrations [of cyanide in water] has been identified”
764 2 Agency App. O “Soil is very likely to be contaminated with cyanide during cyanide operations..The Agency is unaware of any data on toxicity of cyanide to soil macro invertebrates”
765 1 Agency App. O “The Agency is unaware of any quantitative information on direct access [of non-target organisms to cyanide baits]..it would seem very likely that non-target animals would be exposed to pastes and spilled pellets”
766 1 Agency App. O “information..[indicates] weka and kiwi deaths resulting from cyanide usage and..as a result, DoC stipulates that cyanide baits must be raised above 70 cm in known weka and kiwi areas managed [by DoC]..Spurr..does not state how successful this has been..tomtit, robin, silvereye and tui deaths have also been reported after the use of hand-laid cyanide”
767 1 Agency App. O “Merhtens & Gaze (2003)..drew attention to the uncoordinated reporting [regarding cyanide]..and to try to get a better picture of weka deaths [studied] 21 weka fitted with transmitters..2 birds died before the operation began..3 birds died close to the bait lines and  a further 4 untagged weka were found dead”
768 1 Agency App. O “The Agency concludes that in the absence of such data the risks of cyanide to other bird species [than weka] are unknown”
770 1 Agency App. O “The Agency considers that the data on exposure and population monitoring during Feratox operations are insufficient to draw conclusions for anything other than weka..The impact on weka populations is sufficiently major that DoC have banned the use of Feratox where weka are present”
874 1 Agency App. T: Submissions “New information on 1080 Maximum Acceptable Value in water will soon be available; defer decision to avoid having to re-visit the 1080 protocols” (Ministry of Health)
47 1 Applicants’ references “Ecological risk assessments also..require [studies of] the entry, distribution and biological effect and fate of chemicals to fully characterise and understand the potential adverse implications of contamination” (Eason & O’Halloran, 2002)
50 1 Applicants’ references “there is a need to more clearly understand how 1080 breaks down in water and to model any consequences of 1080 contamination in waterways” (Eason et al., 1994)
68 1 Applicants’ references “Data from aerial 1080 operations for the control of..possums in NZ show that estimates of the bait size and toxic concentration..derived from the mean parameters..will not be accurate” (Frampton et al., 1999)
69 1 Applicants’ references “We have been unable to demonstrate whether the higher toxic loading..was more effective in killing deer. Several other factors including the variation in the pre-control densities of both red deer and possums between the two treatment blocks..are likely to have affected our comparison” (Fraser & Sweetapple, 2000)
70 1 Applicants’ references “[skinks] ate..[cereal] bait..sublethal effects require further study” (Freeman et al., 1996)
85 3 Applicants’ references “7-11%..of ferrets on one site and 8-15%..of ferrets at the other site apparently died of secondary 1080 poisoning [after aerial 1080 poisoning]..while we have evidence that secondary poisoning of cats does occur we monitored insufficient numbers..to reliably estimate mortality rates” (Heyward & Norbury, 1999)
93 2 Applicants’ references “Ecological consequences derive from both mammal population reduction..and..using toxins..Scientists [in NZ] have not examined the net ecological outcomes..key conservation legislation demands that [managers] do so” (Innes & Barker, 1999)
93 3 Applicants’ references “a food web could be a useful conceptual framework to generate hypotheses about toxin [1080 and brodifacoum] movement through communities..explore net outcomes of pest control at the community level..[and] to sharpen objectives for ecosystem restoration” (Innes & Barker, 1999)
101 1 Applicants’ references “Birds [yellow-billed magpies] die in the nest making recovery of the bodies unlikely” (Koenig & Reynolds, 1987)
118 2 Applicants’ references “These figures [for the LD 50 for possums in Australia] are less than those obtained by the New Zealand Forest Service and bring into question which figures are valid for free roaming possums in the bush” (McIlroy, 1983)
119 1 Applicants’ references “The sensitivity of a species to 1080 poison is difficult to predict from toxicity data from other, closely related species” (McIlroy, 1986)
164 1 Applicants’ references “We monitored birds in one treatment and one non-treatment study area to study..mortality, nesting success and survival” (Powlesland et al., 2003)
164 2 Applicants’ references “No radio-tagged kereru and too few radio-tagged kaka bred to show [effects of possum and rat numbers after poisoning]..while no radio-tagged adult male kaka died during the study, 6 females did..radiotagged kereru suffered high mortality..predation was the main cause of mortality” (Powlesland et al., 2003)
216 1 Applicants’ references “Key areas of concern revealed in the literature include evidence 1080 could have endocrine disrupting capabilities and that it is relatively slow to break down [at low temperatures]. These 2 issues are yet to be fully resolved and represent significant gaps in current knowledge.” (Weaver, 2003)
72 1 Submitter 9198 “scientific research supporting [DoC’s] claims [mostly] reaches only the lowest levels of control quality. Statistics are often poorly done, absent or selectively reported. The studies are short term and narrow in scope. There is not one randomized, blind treatment. Results are frequently misrepresented and distorted often with obvious bias. There are numerous errors of inference, omission and commission. Roughly half of the studies are only published internally..mostof the others are published in a single journal, the NZ J Ecology. There is only one study that appreaed in a peer reviewed international journal…The entire lot, excepting one or two, was produced by researchers who are financially dependent on DoC’s good will” (Whiting-O’Keefe review)
72 2 Submitter 9198 “There is not a single credible study showing that aerial 1080 pest control is either benficial to or necessary for NZ’s native forests or their inhabitants” (Whiting-O’Keefe review)
72 3 Submitter 9198 “The net overall effect of aerial 1080 on our forests and forest ecosystem cannot be determined” (Whiting-O’Keefe review)
15 2 Committee Decision “Grounds for reassessment [included]..the completion of significant research on 1080 since it was first registered in 1964”
21 2 Committee Decision “submitters…challenged the adequacy of research into [1080’s] environmental impact”
31 2 Committee Decision “The Committee…notes the wealth of relevant research..about the impact of 1080 on important species”
41 6 Committee Decision “few..studies have [assessed] impacts of mammalian species on terrestrial invertebrates…[but] studies..on effects of wasps on invertebrate abundance [have shown a] beneficial impact”
49 3 Committee Decision “While it has not been able to quantify the risks posed by Tb in terms of reduced consumer demand or market access restrictions, the Committee does consider the beneficial effect of reducing these risks to be significant”
58 1 Committee Decision “the Committee did not, however, receive any specific information supporting this concern [about effects of 1080 on soil micro-organisms]”
58 5 Committee Decision “there is little scientific data on the degradation of 1080 in New Zealand soils at cool temperatures”
59 1 Committee Decision “the available scientific data on the degradation of 1080 in water indicate the substance is biodegradable but that there is still some uncertainty regarding the relevance of some of the test data to the New Zealand environment”
60 3 Committee Decision “the Committee does recommend further research on the degradation rates of 1080 in water”
64 1 Committee Decision “trials exposing native frogs to 1080 residues in water and to cereal bait containing 1080 were inconclusive due..to the small numbers of animals used and their tendency to hide..[reflecting] the difficulties associated with testing many native species”
64 2 Committee Decision “the small numbers involved make conclusions difficult [regarding effects of 1080 on frogs]”
79 1 Committee Decision “there is some considerable uncertainty about how much by-kill of deer occurs from aerial drops”
91 1 Committee Decision “there are a number of research gaps on the effects of 1080 in relation to its aerial application”
97 1 Committee Decision “No EELs (environmental exposure limits) are set for 1080..EELs may be set at a later date when the policy for the setting of EELs under section 77b has been established. The default EELs specified under regulation 32 are accordingly deleted”
121 2 Committee Decision “The Committee acknowledges there is some uncertainty as to the magnitude and likelihood of some of the adverse effects”
128 2 Committee Decision “There is good understanding in the occupational setting for managing the effect”
133 7 Committee Decision “[Overall evaluation: biological and physical environment] There is some residual uncertainty around the adverse effects assessed as significant after taking account of existing and additional controls”
199 1 Decision App.B “There is major uncertainty around the impact of deer repellent in terms of its effectiveness in reducing by-kill of deer”
202 1 Decision App. C “Because of a lack of data, risks are often presented as singular results. In reality, they are better represented by ‘families’ of data”