Page No. Source Quotes from Decision Documents
349 13 Agency App. C “Data gaps..reproductive toxicity to birds” (lizards, invertebrates, frogs, bats, fish not studied either)
349 4 Agency App. C [1080 pellets do not trigger this hazard- terrestrial invertebrate ecotoxicity]”
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”
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”
351 6 Agency App. C “1080 is highly toxic to terrestrial invertebrates”
354 1 Agency App. C “non-standard, non [Good Laboratory Practice]…A brief summary only of the test results [on aquatic plant uptake of 1080] was reported..test conditions not specified..weight basis for concentration in plants not specified, no statistical analyses reported, [plant species studied not reported] information provided on effects on..aquatic invertebrates in the test aquaria..Eason et al., 1993”
354 2 Agency App. C “[after 0.1 mg/L 1080 added to aquaria with plants and invertebrates, amount and source not specified]..residues were detected in the plants reaching a maximum of 0.051 mg/kg after one hour [with a 70% decline in 1080 in the after  24 hours]”
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”
361 4 Agency App. C “Daphnia magna, 48 hour..EC50 350 mg/L..comments as for Collins [no access to the original study so the Agency is not able to fully verify the summary information]”
361 4 Agency App. C “Mosquito larva..48 hours [test]..15% mortality at 0.025 mg/L..40% mortality at 0.05 mg/L..65% mortality at 0.1 mg/L”
369 3 Agency App. C “The presence of blowfly..maggots increased the rate of loss of 1080 under experimental conditions”
369 4 Agency App. C “The reasons for the slow rate of degradation [of 1080 in carcasses] are not clear, but the Agency considers it may be a function of low pH in the gut, absence of bacteria able to degrade 1080, toxicity to gut bacteria, low levels of..invertebrate activity, accompanied by cool temperatures at the time of 1080 bait distribution”
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 the test with garden snails..attributed to degradation of 1080 in the samples in storage”
386 1 Agency App. C “NOEC [in a British earthworm species] cocoon production 50 mg/kg dw soil”
386 2 Agency App. C Total number of cocoons produced in the control did not meet test reliable values were obtained..possible lack of sexual maturity [of worms]
386 3 Agency App. C “97.5 mortality [of a British earthworm species]at 250 mg/kg dw soil”
386 4 Agency App. C “reductions in bodyweight and mortalities in all treatments which were not dose-dependent [a British earthworm species tested at 0, 10, 25, 50, 100, 200 mg/kg dw soil]
387 1 Agency App. C “[concentrations of 1080 in garden snails were measured] after 8 months’ 20°C”
387 2 Agency App. C “residues in snails [after 28 days exposure to 1080 in soil] 1.9mg/kg-61 mg/kg”
416 3 Agency App. C “Measured residues in flies in casual contact with baits were 31 and 33 mg/kg and in close contact were 26 and 91 mg/kg”
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”
421 3 Agency App. C “Despite the uncertainty in the data, the Agency considers that technical grade 1080 can be classified as 9.4A..based on..honeybee and ant data.”
422 1 Agency App. C “Some ‘house’ bees died several hours after the start of the trial, having received toxic bait from the foragers”
422 2 Agency App. C “A delayed action was observed (2 hours after feeding) with vigorous shaking, inability to hold onto comb, and death [in bees accessing 1080 jam baits]”
422 3 Agency App. C “0.001% 1080 causes some individual mortality [in wasps]”
423 1 Agency App. C “LD 50 42 mg/kg..=0.08 μg/ant”
423 2 Agency App. C “Species [of ant] choice based on difficulty in maintaining the forest ant Huberia brouni under laboratory conditions”
423 3 Agency App. C “5.51 mg/kg ants [one day after exposure to 0.03% 1080 in sucrose] with rapid decline in week following exposure but still measurable after 7 days (0.27 mg/kg ants)”
423 4 Agency App. C “Dead ants frozen at -20°C for later analysis [1999]”
423 5 Agency App. C “the application states..LD 50 of 60 μg/weta which is not correct..the text following..has the LD 50 of 365 μg/weta”
423 6 Agency App. C “Wellington tree weta..LD 50..360 μg/weta [males]..430 μg/weta [females]”
424 1 Agency App. C “[Tree] weta dosed [with 1080] by micro-syringe and then killed at various times after dosing”
424 2 Agency App. C “0.033 mg/kg at 240 hours [residues in tree weta after dosing with 15 mg/kg 1080]”
425 2 Agency App. C “Most exposed [native] cockroaches died during the 14 day period [after being fed 0.08% 1080 cereal bait]”
427 1 Agency App. C “100% mortality [of aphids on broad bean plants growing in 0.1 mg 1080 in 400g sand], plants remained toxic for at least 10 days..100% mortality [of aphids on broad bean plants grown in 0.00005% 1080 culture solution]”
427 2 Agency App. C “1-2 [days after treatment] no mature eggs..misshapen and collapsed oocytes…yolk deficient [wasps dosed with 0.025-0.063 mg/kg bw 1080]”
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 would classify as 9.4A highly toxic to terrestrial invertebrates” (bee data criticised on page
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.”
509 3 Agency App. F “Additional seed produced [after browsing animals were removed from Rangitoto Island] may have led to increased seed consumption by rodents..[which] also consume large quantities of invertebrates, also reducing the resources available to birds”
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”
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 artefact of the difficulties in observing invertebrates feeding under baits]”
512 1 Agency App. F “The proportion of cereal bait with [terrestrial] invertebrates present was consistently higher than for carrot in all months except October 1996”
512 2 Agency App. F “113 taxa [of invertebrates were] caught [on baits] and a second least 133 [taxa were found], with 43% of baits observed with invertebrates present”
512 3 Agency App. F “where toxic [cereal] baits were replaced at days 13-15, a reduction in visits to the baits [by invertebrates] occurred, and was greater than that observed during the initial toxic bait placement at days 4-6”
512 5 Agency App. F “The replacement of toxic [cereal] baits within a week of the first application resulted in a greater reduction in invertebrates, which was significant at day 18”
513 1 Agency App. F “invertebrates from 20 taxa (insects..spiders..harvestmen..millipedes..centipedes..slaters..amphipods)..were collected from [cereal] baits”
513 2 Agency App. F “Residues [of 1080 in cave weta collected from cereal baits, on nights 1, 2, 3, 4 and 6 after the operation, respectively] were 32, 53, 53, 130 and 60 mg/kg..samples of other invertebrates [on nights 1, 2, 3, 6 and 8 respectively were 22, 46, 24 and 14 mg/kg]”
513 3 Agency App. F ” [1080 residues in a pooled sample of] invertebrates collected from pitfall traps during the 10-day collection period [after a 1080 cereal drop] contained 0.8mg 1080/kg..spiders collected from baits..and pitfall traps contained 14 mg 1080/kg”
513 4 Agency App. F “Cave weta may have a better escape response compared with tree effects [of population changes]..may be less readily observed”
513 5 Agency App. F “Invertebrates from 21 orders..were caught in sticky traps in the [tree] canopy, of which 44 individuals were confirmed as having ingested [non-toxic cereal bait fragments lodged in the tree canopy]
514 1 Agency App. F “Variable occupancy of [artificial] refuges [for invertebrates] in both [aerial 1080 treated and untreated] 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” (a near exponential increase seen over 2 years after poisoning)
515 1 Agency App. F “one live but lethargic tree weta ..10 mg [1080]/kg [after cereal bait operation]”
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 2 Agency App. F “22% [of 1080 cereal] baits had invertebrates on them- the most common..amphipods, [ants], millipedes, harvestmen, weevils and weta”
516 3 Agency App. F “most common [invertebrates on cereal 1080 baits]..ants” (communal insects that may transfer 1080 to other ants, as seen between bees)
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]”
516 8 Agency App. F “repeated [poisoning experiment to monitor invertebrates, in same area] in July [due to bad weather after first poisoning]”
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)
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 2 Agency App. F “Snail abundance..P. Gilliesi..1.5/100m²..P. Hochstetteri 0.7 to 1.3 per 100m²..Snails take about 3 years before young big enough to detect [numbers counted 2 x in Parapara, 5 x in Gouland Downs, 5 x in Burnett Range]”
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)
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”
605 1 Agency App. L: Current controls “The authority considers that..the regulation [49, that protects terrestrial invertebrates, specifically bees] should not be deleted. The intent is that if formulations were changed to include substances attractive to bees, then the regulation would take effect” (Regulation 49 was deleted in the new controls, p 169 Decision Appendix A)
512 4 Agency App. N “In the third study, non-toxic baits were placed [every 20 cm away from toxic baits, from 20-140 cm]..the reduction in invertebrate numbers extended to 20cm from the toxic bait” (significant effects also seen at 100 cm)
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 7 Agency App. N “Available monitoring data indicate that invertebrates which feed on baits are not adversely affected at a population level”
723 8 Agency App. N “Available monitoring data indicate that..the extent of any impact [of 1080 on invertebrates] is very localised to within a short distance of a toxic bait” (one trial, artificially laid baits (no dust), no data or statistics, one measurement (no. invertebrates on nearby non-toxic baits), no consideration of secondary poisoning eg maggots, spiders, ants, no acknowledgement that significant effects were seen at 100 cm as well as 20 cm)
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”
724 2 Agency App. N “No effects [on aquatic biota] are likely based on the number of baits that have been recorded falling into streams” (no consideration of small streams, ponds, 1080 loss during sample storage, poor data)
726 2 Agency App. N “[1080 residues in] pooled sample of invertebrates collected from cereal baits..57 mg/kg [max 130 mg/kg]”
727 1 Agency App. N “[1080 residues in cave weta] 130 mg/kg”
727 2 Agency App. N “[1080 residues in tree weta] 0.033 mg/kg at 240 hours”
735 2 Agency App. N “Ingestion of sub-lethal doses may alter invertebrate behaviour resulting in abnormal daytime activity, and increased likelihood of ingestion by birds”
751 3 Agency App. N “Secondary poisoning from ingestion of 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”
752 1 Agency App. N “Using an LD 50 of 0.15 mg/kg bw [for bats, a lethal dose could be delivered by invertebrates making up] 3.1%..- 0.3% of the total daily intake”
753 1 Agency App. N “A wide range of [invertebrate] species has been found feeding on all bait types”
754 1 Agency App. N “The Agency asked the applicants for an update on any on-going research on invertebrate repellents/antifeedants and was advised that they are not aware of any”
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 very old report of effects [of 1080] on mosquito larvae at 25-100 μg/l”
865 1 Agency App. T: Submissions “I am aware of the threat to these fauna [Powelliphanta snails] near my home is largely from rats, and that 1080 causes a boom and bust population swing in rats. They breed rapidly after possum competition is removed and soon pose a larger threat to snails than possums ever did”
4 1 Applicants’ references “[1080 at sublethal doses inhibited reproduction in male and female fleas of 2 species and also had] some effect on adults developing from larvae that had eaten the faeces of fleas that contained poisoned blood” (Alekseev et al, 1971)
36 1 Applicants’ references “[1080] was very toxic to the [beetle] larvae” (Cohen & Levinson, 1974)
45 1 Applicants’ references “Kauri snails were not contaminated. These analyses were based on a small sample and should be treated accordingly” (Eason et al., 1991)
67 1 Applicants’ references “Acute toxicity to fish and aquatic invertebrates appears to be relatively low” (Fisher & Eason, 2003)
92 1 Applicants’ references “50% of the weta offered the toxic [1080 ‘grain based’] baits died, while the other 50% suffered sublethal poisoning which altered their behavioural patterns” (Hutcheson, 1990)
109 2 Applicants’ references “Invertebrates were collected and assayed for 1080 content, and results indicated that short-tailed bats, and other vertebrate insectivores, are vulnerable to secondary poisoning after aerial 1080 operations” (Lloyd & McQeen, 1998)
115 1 Applicants’ references “In the American cockroach and mouse..fluoroacetate..poisoning led to large citrate concentrations in the body” Matsumura & O’Brien, 1963)
123 3 Applicants’ references “Comparison of the Whitecliffs data with that of other lowland podocarp/broadleaf forests over one year, shows that 1080 has a severe impact on many other invertebrates. At Whitecliffs, insect larvae, comprising coleoptera, hymenoptera, diptera and lepidoptera dropped dramatically from July through to October, then stabilised for the rest of the year at the crash level. Insect larvae in other forests followed the normal pattern of continual rise from July until the onset of the following winter” (Meads, 1994)
127 1 Applicants’ references “Fluoroacetic acid is a potent and specific inhibitor of reproduction in the nematode Caenorhabditis elegans” (Middendorf & Dusenbery, 1993)
139 1 Applicants’ references “Stoats..contained mostly rats, and some birds and mice..ferrets..ate lagomorphs and invertebrates”(Murphy et al., 1998)
142 1 Applicants’ references “At least 9 invertebrate orders are prone to 1080 poisoning. Invertebrates have been observed eating baits..their habitats are contaminated by residues leaching from baits, and from animal by-products and carcasses..1080 should not be used where susceptible invertebrate species or rare insectivores are found” (Notman, 1989)
149 3 Applicants’ references “earthworm tissue residues at the conclusion of the experiment [28 days of exposure to soil initially dosed with 1080] were either close to, or below, the analytical..limit of detection (0.01 mg/kg)” (O’ Halloran et al., 2003)
153 1 Applicants’ references “Compound 1080 is highly toxic to bees as a stomach poison” (Palmer-Jones 1958)
161 1 Applicants’ references “Low concentrations of 1080 were found in the insects [tested after an aerial cereal 1080 drop in 1990]” (Pierce & Montgomery, 1992)
183 3 Applicants’ references “Fluoroacetate-induced changes in the fecundity and fertility of Bracon hebetor [wasp] females” (Smith & Grosch, 1985)
187 1 Applicants’ references “common species found on [non-toxic] baits [were] the least 8 species of weta, at least 9 species of least one species of least 3 species of harvestmen..and at least 3 species of mites..populations of invertebrate species, found to eat bait [should be monitored] during pest control operations” (Spurr & Drew, 1999)
192 1 Applicants’ references “No major changes to the [aquatic] invertebrate communities was observed, except for a decrease in the total number of taxa collected in some streams 5 days after the [1080] drop.. [and a] slight decline in the EPT taxa collected 5 days after the drop. Such decreases were not evident at the control site” (Suren & Lambert, 2002)
200 1 Applicants’ references “[1080] is well known as a toxic substance and has been used as an insecticide” (Tonomura, 1969)
2 1 Submitter 8606 “I am a retired Conservator of Wildlife ..have been opposed to the bulk sowing of 1080 since the late 50s and early 60s..when I witnessed its obvious ability to kill other than the target species in large numbers. Its use on rabbits decimated the huge quail and chukor population of Central Otago as well as every other species of ground bird, hawks, moreporks and falcons that were attracted to the baits, the dead rabbits and the secondary kill of rats and insects etc.”
3 1 Submitter 9143 “Invertebrate populations were assessed before, during, and after a 1080 poisoning operation in Whitecliffs Conservation Area, using pitfall traps from 21 June 1991 to 28 February 1993” (Meads, 1994) (Meads was diagnosed with cancer in 1995 and has passed away.)
16 1 Submitter 9143 “My results show clearly that those insects associated with leaf litter breakdown..are the most severely impacted by 1080..a possible mechanism can be inferred from the work of Hilton et al (1969) [who] state ‘the high degree of adsorption of monofluoroacetate to leaf and root tissue, as well as to other cellulosics such as filter paper, was entirely unexpected’ is possible that the fibrous bait components are assimilated into the forest litter after rain..[and] became attached to the highly cellulosic and fibrous leaf litter where it remained for at least 3 months” (Meads report)
16 1 Submitter 9143 “Hilton et al (1969) state ‘the high degree of adsorption of monofluoroacetate to leaf and root tissue, as well as to other cellulosics such as filter paper, was entirely unexpected’.” (Meads report, indicates water sample analysis using filter paper may remove 1080)
17 1 Submitter 9143 “It would be reasonable to assume that populations of those insects with short life cycles (springtails) would recover far more quickly than those that have life cycles of 3 years and more (some beetles, cicadas, hepialid moths)” (Meads report)
33 1 Committee Decision [Hazard classification table, cereal pellets are not considered toxic to terrestrial invertebrates]
40 8 Committee Decision “Possums and rodents also feed on invertebrates”
41 1 Committee Decision “The Committee was informed that possums have been observed preying on bats while roosting..and to eat Dactylanthus flowers which provide food..for bats and to feed on invertebrates, a key food [for bats]”
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”
42 1 Committee Decision “ground-browsing animals…impact on invertebrates through trampling and soil compaction”
42 2 Committee Decision “the research indicated that populations [of Powelliphanta snails] actually increased after [aerial] operations”
42 3 Committee Decision “Ground-based control could be used to protect known locations of threatened species”
59 6 Committee Decision “The Committee notes that in general terms, 1080 is not toxic to fish or aquatic invertebrates”
63 3 Committee Decision “only a very small number of the total invertebrates present on the forest floor within an application area will be affected”
63 4 Committee Decision “sub-lethally poisoned invertebrates are able to metabolise and excrete 1080 and so residues remain in their tissues for a short time only”
63 5 Committee Decision “The Committee considers the adverse effects of 1080 on invertebrate populations to be very small”
92 1 Committee Decision “[The Committee is imposing a control requiring information about each aerial operation]..the information must include..details of pre- and post-operation monitoring of fauna..details of post operation monitoring of water quality”
100 3 Committee Decision “While some of the formulated substances containing 1080 are classified as ecotoxic to terrestrial invertebrates..none of them is attractive to bees..therefore regulation 49 (1)(a) does not apply..the control can be deleted”
188 1 Decision App. A [any person who applies aerial 1080 must supply information on]..pre- and post-operational monitoring of birds and invertebrates (if available)..and water quality (if available)”