SEPA
               United States
               Environmental Protection
               Agency
              Office of
              Pesticides and Toxic Substances
              Washington DC 20460
September 1980
               Pesticides
 Strychnine
Position Document No.   2/3
.

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Strychnine Position Document 2/3

Office of Pesticide Programs
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency

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                             Acknowledgements

Project Team

Kyle Barbehenn, Biologist, HED
Dennis Carluzzo, Attorney, OGC
Douglas Chambers, Biologist, BFSD
David Eberly, Project Manager, SPRD
Thomas Edwards, Pharmacologist, HED
Linda Garczynski, Writer/Editor, SPRD
Andrew Gordon, Attorney, OGC
Roger Holtorf, Economist, BFSD
William Jacobs, Biologist, RD
Daniel Peacock, Biologist, RD


EPA Pesticide Chemical Review Committee (PCRC)

Charles Gregg, OWWM
Richard Hill, OPTS
Allen Jennings, 0PM
Donna Kuroda, ORD
Lois Jacobs, OE
Ray Smith, OANR
Marcia  Williams, Chairperson, SPRD, OPP
Michael Winer, XC

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                              Table of Contents
I.    Introduction                                                         1

      A.   Background                                                      1

           1.  The RPAR Process                                            1
           2.  Strychnine RPAR                                             2

      B.   Strychnine                                                      3

           1.  Physical and Chemical Properties                            3
           2.  Production                                                  3
           3.  RPAR Uses                                                   3
           4.  Estimated Usage                                             7

II.   Rebuttal Analysis                                                    9

      A.   Background                                                      9

      B.   Risk Criterion - Acute Toxicity to Birds and Mammals            9

           1.  LD™ Range                                                  9
           2.  Exposure to Bait                                           10
           3.  Other studies on Birds                                     10

      C.   Risk Criterion - Significant Reduction in Population
           Nontarget Species and Endangered Species                       1 1

           1.  Hegdal and Gatz Study                                      11
           2.  Howell and Wishart Study                                   13
           3.  Rebuttals Regarding Other Field Observations               14
           4.  Rebuttals on Secondary Poisoning and Endangered            14
               Species
           5.  Miscellaneous Rebuttals                                    15

III.  Risk Analysis                                                       17

      A.  Strychnine                                                      17

          1.   Methods of Application for Target Species                   17

              a.  Ground Squirrels                                        17
              b.  Prairie Dog                                             17
              c.  Other Mammals                                           18

                  1) Jackrabbit                                           18
                  2) Kangaroo and Cotton Rats           -                  18
                  3) Porcupines                                           18

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                     Table of Contents (Continued)

                                                                     Page
          d.  Pigeons and House Sparrows
          e.  Cropland Birds
     2.   General
                                                                       19
          a.  Toxicology                                               '^
          b.  Acute Toxicity                                           ^
          c.  Subacute and Chronic Toxicity                           I)?
          d.  Bioaccumulation and Tissue Residues                      ^
          e.  Secondary Toxicity                                      ^n
          f*  Summary

     3.   Direct Risks to Nontarget Species                           ^.
     4.   Indirect Risks to Nontarget Species                          ^
     5.   Risks to Members of Endangered Species                      2'

          a.  Black-Footed Ferret                                     31
          b.  San Joaquin Kit Fox                                      32
          c.  California Condor                                       32
          d.  Peregrine Falcon                                         33
          e.  Other Species                                            3*+

     6.   Human/Domestic Risks                                         34

B.   Alternatives - Mammals                                            36

     1.   Sodium Fluoroacetate (Compound 1080)                         36

          a.   Method of Application                                   37

               1)   Ground Squirrel                                    37
               2)   Prairie Dog                                        37

          b.   General                                                 37

               1)   Toxicology                                         37
               2)   Acute Toxicity                                     38

                    a)   Laboratory Data                               38
                    b)   Field Studies                                 38

               3)   Subacute and Chronic Toxicity                     j*2
               4)   Bioaccumulation and Tissue  Residues               42
               5)   Secondary Toxicity                                JJ3
               6)   Human Risks

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                 Table of Contents (Continued)

                                                                Page

2.   Zinc Phosphide                                              45

     a.   Method of Application                                  45

          1)  Ground Squirrel                                    45
          2)  Prairie Dog                                        45

     b.   General                                                45

          1)  Toxicology                                         45
          2)  Residue                                            46
          3)  Acute Toxicity                                     46

              a)  Laboratory Data                                46
              b)  Field Studies                                  47

          4)  Secondary Toxicity                                 47
          5)  Human Risks                                        48

     3.   Anticoagulants                                         48

          a.  Method of Application                              48
          b.  Toxicity                                           48

              1)  CPN                                            48
              2)  DPN                                            49
              3)  Other Anticoagulants                           49

          c.   Human Risks                                       50

               1)  CPN                                           50
               2)  DPN                                           50
               3)  Other Anticoagulants                          50

     4.  Fumigants                                               50

         a.  Carbon Disulfide                                    50
         b.  Gas Cartridges                                      51
         c.  Methyl Bromide                                      51
         d.  Other Fumigants                                     51

     5.  Repellents                                              51
     6.  Relative Risks and Comparative Data                     51
     7.  Summary                                                 55

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                          Table of Contents  (Continued)

                                                                         Page

     C.  Alternatives - Bird Control                                       56

     D.  Summary of Relative Risks by Use Pattern                          56

         1.  General                                                       56

         2.  Rangeland and Pasture Rodents                                 57

             a.  Prairie Dogs                                              57
             b.  Ground Squirrels                                          57
             c.  Miscellaneous Rodents and Lagomorphs                      57

         3.  Cropland Rodents                                              58

             a.  Prairie Dogs                                              58
             b.  Ground Squirrels                                          58
             c.  Miscellaneous Rodents and Lagomorphs                      58

         4.  Nonagricultural Sites for Rodents and Lagomorphs              58
         5.  Cropland Birds                                                58
         6.  Nonagricultural Sites for Birds                               58

IV.  Benefit Analysis                                                      59

     A.  Introduction                                                      59
     B.  General Production and Use Patterns                               60
     C.  Analysis of Benefits of Strychnine Use on                         60
         Rangeland/Pasture

         1.  Ground Squirrels                                              60
         2.  Prairie Dogs                                                  63
         3.  Other Rodents and Lagomorphs                                  65

     D.   Analysis of Benefits of Strychnine Use on Cropland                65

         1.  Prairie Dogs                                                  65
         2.  Ground Squirrels                                              67
         3.  Other Rodents                                                 67

     E.   Analysis of Benefits of Strychnine Use on Cropland for            67
         Bird Control

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                        Table of Contents (Continued)
     F.  Analysis of Benefits of Strychnine Use on Non-                    69
         agricultural Sites

         1.  Birds                                                         69
         2.  Rodents and Lagomorphs                                        71

V.  Risk/Benefit Analysis and Regulatory Options                           73

    A.   General                                                           73
    B.   Risk/Benefit Analysis                                             73

         1.  Rangeland Rodents                                             73
         2.  Cropland Rodents                                              75
         3.  Nonagricultural Site Rodents and Lagomorphs                   76
         4.  Cropland Birds                                                76
         5.  Nonagricultural Site Birds                                    76

    C.   Regulatory Options                                                77

         1.  Rangeland Rodents - ground squirrels                          77
         2.  Rangeland Rodents - prairie dogs                              84
         3.  Rangeland Rodents - other rodents and lagomorphs              85
         4.  Cropland Rodents - ground squirrels                           88
         5.  Cropland Rodents - prairie dogs                               88
         6.  Cropland Rodents - other rodents and lagomorphs               89
         7.  Rodents and Lagomorphs on Nonagricultural Sites               89
         8.  Birds on Cropland                                             90
         9.  Birds on Nonagricultural Sites                                91

    D.   Proposed Actions                                                  93

         1.  Rangeland Rodents - ground squirrels                          93
         2.  Rangeland Rodents - prairie dogs                              95
         3.  Rangeland Rodents - other rodents and lagomorphs              95
         4.  Cropland Rodents - ground squirrels                           97
         5-  Cropland Rodents - prairie dogs                               97
         6.  Cropland Rodents - other rodents and lagomorphs               97
         7.  Rodents and Lagomorphs on Nonagricultural Sites               97
         8.  Birds on Cropland                                             98
         9.  Birds on Nonagricultural Sites                                99

    E.   Summary                                                          100

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                                 List of  Tables

Table         Title

1-1           Strychnine,  Federal-State  Registrations                      4

1-2           Percentage of Use  by  Site/Pest  Combination                   8

III-1         Acute Oral Toxicity of Strychnine  Alkaloid                  20

III-2         Acute Oral Toxicity of Compound 1080                         39

III-3         Relative Risks of  Alternative Toxicants                     52

IV-1          Estimated Annual Above-Ground Usage of                      61
              Strychnine Bait to Rodent  and Bird Control,
              1977-78

IV-2          Chemical Alternatives to Strychnine for Rodents             62
              and Lagomorph Control

IV-3          Estimated U.S. Acreage of  Range  and Pasture                  64
              Infested with Prairie Dogs

IV-4          Estimated Acreages of Cropland Treated  with                  66
              Strychnine for Prairie Dogs and  Ground  Squirrels,
              1978

IV-5          Chemical Alternatives to Strychnine for Bird                 70
              Control

IV-6          Major Pests on Nonagricultural Sites Controlled             72
              with Strychnine

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                            Appendices

Appendix          Title

  A               Strychnine, Position Document  1 and RPAR
                  Notice, Dec.,  1, 1976.

  B               List of Rebutters.

  C               Rebuttal Analysis.

  D               USDI Fish and Wildlife Service Endangered
                  Species Report.

  E               Preliminary Benefit Analysis.

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                              I.  Introduction

                                A.  Background


 1.   The RPAR Process

     Through the Federal Insecticide,  Fungicide and Rodenticide Act as
 Amended (FIFRA),  the United States Environmental Protection Agency (EPA) has
 the authority for regulating the use  of pesticides.  This authority includes
 the registration, reregistration, and classification of pesticides.  The
 process for administering this authority provides for the identification of
 pesticides that appear to cause unreasonable adverse effects on human health
 and the environment.

     Under this process, each pesticide and its metabolites or degradation
 products is evaluated for its potential to meet or exceed any of certain risk
 criteria.  The three general risk criteria (acute toxicity, chronic toxicity,
 and lack of emergency treatment) are  described in 40 CFR 162.11.  If the
 Agency's evaluation of a pesticide, from available information, indicates that
 the potential for unreasonable adverse effects exists,  a notice of rebuttable
 presumption against registration and  continued registration (RPAR) is published
 in  the Federal Register.  The notice  explains the reasons for the presumption(s)
 and provides an opportunity for registrants,  applicants,  and other interested
 parties to rebut or support the presumption.

     EPA examines the rebuttals and the supporting evidence to determine  if the
 original presumption(s) are still valid.   If the rebuttal analysis results in a
 conclusion that one or more of the criteria is met or exceeded, a complete risk
 assessment is performed.  This assessment documents the risks associated with
 the use(s)  of the pesticide,  methods  for  reducing or eliminating these risks,
 and the risks associated with the substitution of alternatives.  A benefit
 analysis of the use(s)  of the pesticide is also performed.   The principal
 concern in the benefit analysis is an assessment of the economic impacts on
 pesticide users and on the consumers  of the user's products.   The benefit
 analysis identifies the major and minor uses of the pesticide and the
 registered  alternative  products.   A determination is made of the change  in
 costs  for treatment with available substitute products.   The regulatory  impact
 on  use  productivity,  in terms  of yield per acre or total  output,  is assessed.
 Also,  the impact  on major agricultural commodities and  retail food prices,
 should  the  uses of  the  pesticide  be cancelled,  is assessed.

     A comparison  of the risks  and benefits of each use  is made and available
 regulatory  options  are  developed.  The impact on the risks  and benefits  is
 evaluated  for  each  regulatory  option.   The final Agency decision is based upon
achieving the  goal  of a  pesticide performing  its intended function without
causing unreasonable adverse effects  on the environment. Tnus,  the Agency
attempts to determine the  regulatory  position at which  benefits exceed risks
and at which further risk  reduction is not appropriate  given the corresponding
benefit reduction which could occur.

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2.  Strychnine RPAR

    The RPAR notice for strychnine was published in the Federal Register of
December 1, 1976 (41 FR 52810).  The presumption was against all outdoor above-
ground uses of strychnine.  Three other actions by the Federal government
involving strychnine should be noted.  In March of 1972, Executive Order 11643
was issued.  This order prohibited the use of all toxicants, including
strychnine, for control of predators on Federal lands or in Federal programs.
In the same year, EPA cancelled the registrations of thallium sulfate,
cyanide, strychnine, and compound 1080 for predator control.  Additionally, in
February 1978, EPA restricted use of several pesticides, including strychnine
formulations with concentrations greater than 0.5 percent, for use only by
certified applicators (43 FR 5791).  The criteria influencing the restriction
for strychnine were acute oral toxicity, hazards to nontarget species, and use
and accident history.

    The criteria that were determined to have been met or exceeded for the
outdoor above-ground uses of strychnine are:  1) acute toxicity to mammals and
birds and 2) significant reduction in populations of nontarget organisms and
fatalities to members of endangered species.  The reasons for the determination
were explained in detail in the RPAR notice and accompanying Position Document 1
(Appendix A).  The following paragraphs summarize the information available at
the time the PD1 was issued.

    The acute toxicity criterion was based on a determination that nontarget
mammals and birds are likely to consume lethal quantities of strychnine bait.
A lethal quantity could be consumed directly by eating the bait, or indirectly
by eating a strychnine-poisoned organism.  Strychnine LD^Q values were not,
and are not, available for many of the suspected nontarget species.  Risk
to such nontarget species was based on available LD,-  values of target and
                                                         ^
                                                   ,-Q
nontarget species of the same genus as those for which LD^ values  were
unavailable.

    The reasoning that the significant reduction in nontarget organism
populations criterion was met is based on three items .  First , t u acute  oral
toxicity data suggest a risk to nontarget species through direct  ingestion of
strychnine-treated bait can reasonably be expected.  The second factor  was the
deaths of eight Canada geese in 1968.  Their deaths were attributed  to  the
ingestion of strychnine-treated gopher bait (Howell and Wishert,  1969).   The
third item was a draft report on a study assessing the field hazards of 0.5
percent strychnine ground squirrel bait (Hegdal, 1976).  The preliminary
conclusion was that several thousand birds could have been killed as a  result
of the treatment with strychnine of 9,000 acres for ground squirrel  control.

    The criterion for endangered species was based on a laboratory study  that
demonstrated a hazard to the endangered San Joaquin kit fox from  secondary
poisoning.  In this study, a kangaroo rat was killed with a quantity of
strychnine that could be consumed by the rat by ingesting strychnine treated
grain bait.  A desert kit fox, a subspecies of kit fox related to the San
Joaquin kit fox,  was fatally poisoned by eating the kangaroo rat.
                                     - 2  -

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                             B.   Strychnine

1.  Physical and Chemical Properties

    Strychnine is a highly toxic product extracted  from  the  seeds  of an Asiatic
tree (Strychnos nux-vomica).  The crude extract may be purified  to form
strychnine alkaloid, strychnine sulfate, or other strychnine salts.   Strychnine
alkaloid is a colorless or white solid which  is practically  insoluble in water,
alcohol, and ether, but is slightly soluble in chloroform and benzene.
Strychnine sulfate is soluble in water and alcohol  and insoluble in  ether.
Strychnine compounds are stable in the environment  but are either  metabolized
or excreted by animals.

2.  Production

    The entire U.S. strychnine supply is imported,  mainly as strychnine or  its
salts.  A small quantity of the seed is imported for processing  in the  United
States.  In  1978, India supplied 91 percent and Israel nine  percent  of  the
approximately 14,500 pounds of the processed  strychnine  imported by -the United
States.  The bait is then formulated in the United  States for domestic  use.  In
previous years, France, United Kingdom, West  Germany, Canada,  and  Laos  have
also exported strychnine to the United States (Pesticide Review, USDA,  1978).

3.  RPAR Uses

    Currently 116 strychnine products are federally registered for control  of
major rodent  pests (including ground squirrel, prairie  dogs,  house mice, and
field mice of the genus Microtus ); minor rodent pests (including
chipmunks,woodchucks, kangaroo rats, cotton rats, porcupines,  and  field mice of
the genus  Peromyscus ); lagomorphs (jackrabbits);  and birds (pigeons and
house sparrows).

    In addition, 277 products have state registrations.  Certain  states  have
issued their own state registrations for strychnine uses covered by  Federal
registrations.  Also, specific states have issued their  own  registrations for
uses not covered by Federal registrations.  For example, California  has
registered strychnine for use against marmots, rabbits,  blackbirds, cowbirds,
horned larks, house finches, white-crowned sparrows, and golden-crowned
sparrows.  Wyoming has registered strychnine  for mountain beavers, opposums,
marmots, and magpies.  Nevada has registered  strychnine  for  magpies, and Oregon
has registered strychnine for rabbits.  See Table 1-1 for a  summary of  the
registered uses of strychnine.

    For the purposes of analysis, the uses of strychnine have been grouped  into
five site/pest categories.  In many cases, these sites are not specified on
labels, and the analysis reflects historical  use.
                                     - 3  -

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                                                                         Table 1-1.

                                                           Strychnine,  Federal-State Registrations
Pest
A. Biros
o Pigeons
o House sparrows
o Blackbirds
o Cowbirds
o Horned larks
o Starlings
o House finches
o White and goloen
crowned sparrow
o Magpies
o Meadowlark
o Crows
o Bluejays
Regis-
tration
Fed.
Fed.
State (Ca.)
State (Ca.)
State (Ca.)
State (Ca.)
State (Ca.)
State (Ca.)
State (Nv. & Wy.)
State (Ca.)
State (Ca.)
State (Ca.)
Major use sites
Agricultural Nonaqricultural
Cash Range, Forests, Buildings,
crops, pasture, reforestation areas, warehouses Non-Crop £/
livestock fallow tree plantations and homes I/
Ca. X
Ca. X
X
X
X
X
X
X
X
X
X
X
I/  Induces  aojacent areas.
2/  Includes  golf courses, parks, cemeteries,  athletic  fields, ditch banks, canals  and  levees.

    Source:   Feoeral Registration:  Site/pest  listing  from EPA registration files,  I960
             State  Registration:    State Agencies:  California Department of  Food  and  Agriculture
                                                    Nevaoa Department  of Agriculture
                                                    Oregon Department  of Agriculture
                                                    Wyoming Department of Agriculture

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                                                                          Table 1-1.

                                                            Strychnine,  Federal-State Registrations




Agricultural
Pest
B. Mammals
o House mice
o Ground squirrels
o Prairie dogs
o Jackrabbits
o Deer mice
o Meadow mice
o Kangaroo rats
o Cotton rats
o Chipmunks
o Porcupines
o Marmots/
Wooochucks
o Rabbits
o Mountain beavers
o Opossums
Regis-
tration
Fed.
Fed.
Fed.
Fed.
Fed.
Feo.
Fed.
Feo.
Fed.
Fed.
Fed.
State (Ca. & Or.)
State (Wy.)
State (Wy.)
Cash
crops,
livestock

X
X
X
X
X
X
X
X

X
X


Range ,
pasture,
fallow

X
X
X
X
X
X
X
X

X



Major use sites
Nonagricultural
Forests, Buildings,
reforestation areas, warehouses Non-Crop 2/
tree plantations and homes I/
X
X X
X
X
X
X
X
X
X
X
X
Or.
X
X
I/  Includes adjacent areas.
£/  Includes golf courses, parks, cemeteries, athletic  fields, ditch banks, canals and levees.

    Source:  Federal Registration:  Site/pest listing from EPA registration files, I960
             State Registration:    State Agencies:  California Department of Food and Agriculture
                                                     Nevada Department of Agriculture
                                                     Oregon Department of Agriculture
                                                     Wyoming Department of Agriculture

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a.   Rangeland/pasture rodents:

     sites - rangeland and pastures

     pests - ground squirrels, prairie dogs, jackrabbits, deer mice, meadow
             mice, kangaroo rats, cotton rats, chipmunks, and
             raarmots/woodchucks.

b.   Cropland rodents and lagomorphs:

     sites - field crops such as grains and forages
             and horticultural crops such as nuts, fruits, and
             vegetables

     pests - ground squirrels, prairie dogs, meadow mice, deer mice,
             chipmunks, rabbits, cotton rats, kangaroo rats, jackrabbits,
             and marmots/woodchucks

c.   Nonagricultural rodents and lagomorphs:

     sites - grain elevators, other crop storage areas
             and facilities, commercial buildings and
             warehouses, open dumps, farmsteads, urban
             dwellings, ditch banks, levees, dikes,
             canals, earthen dams, golf courses,
             parks, cemeteries, athletic fields,
             recreational areas, airport turf runways,
             military bases, tree nurseries, tree
             plantations and reforestation areas.

     pests - rabbits, jackrabbits, chipmunks, marmots/
             woodchucks, ground squirrels, prairie
             dogs,  kangaroo rats, cotton rats, deer mice,
             meadow mice, house mice, porcupines,
             mountain beavers, and opossums

d.   Cropland Birds:

     sites - grape, cherry,  lettuce, sugarbeet, rice, tomatoe,
             plum,  melon, strawberry, vegetable crop, soft fruit,
             and small grain areas.

     pests - house  finches (linnets), horned larks, meadow larks,
             starlings, cowbirds, crows, magpies, blackbirds,
             pigeons (rock doves), house sparrows
             (English sparrows),  and crowned sparrows.
                               - 6  -

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    e.   Nonagricultural birds:

         sites - structures and roosting sites
         pests - pigeons and house (or English) sparrows

4.  Estimated Usage

    Approximately one-half million pounds of strychnine bait were used annually
for above-ground control of rodents, lagomorphs, and birds during  1977-1978.
The majority of the bait usage was in 17 western states for controlling ground
squirrels and prairie dogs.  Ninety percent of the bait was used for rodent
control, the remaining 10 percent for birds.  Rangeland/pasture use and
cropland use were approximately equal and accounted for 91 percent of the
strychnine bait.  The other nine percent was used on nonagricultural sites.
The percentage of use for each site/pest combination is shown in Table 1-2.

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PEST
                                 Table 1-2





                  Percentage of Use by Site/Pest Combination



                                    SITE



                  Rangeland/Pasture     Cropland     Nonagriculture   Total
Prairie Dogs 17.6?
Ground Squirrels 27.6%
Other Rodents 1 and 0.4?
Lagomorphs—
All Rodents and
Lagomorphs
Birds
Total 45.6$
2.8%
38.4?
0.9?

3.6?
45.7?
20.4?
66.0?
1.3?
2.4? 2.4?
6.3? 9.9?
8.7? 100.0?
J/  Other than prairie dogs and ground squirrels.

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                             II.  Rebuttal  Analysis

                                 A.  Background

    Registrants and other interested  parties  were offered  an opportunity to
review the data upon which  the RPAR against strychnine was based and to submit
information to rebut the presumptions.  Respondents  could  rebut  the  presumption
by showing that the Agency's initial  determination of risk was in error or by
showing that common use patterns and  actual exposure indicate that use of the
pesticide is not  likely to  result in  any  significant adverse effects (40 CFR
    Registrants and other  interested  persons  were  also  offered  the  opportunity
to submit evidence as to whether the  economic,  social,  and  environmental
benefits of continuing  to  use  this  pesticide  outweigh the risks of  its use
(I62.11(a)(5)(iii)).  These comments  are considered  in  the  development of
Section IV of this document.

    The Agency received 100 rebuttal  submissions in  response  to the RPAR  on
strychnine.  No scientific data were  submitted  to  support the majority of the
comments received.  Moreover,  the little scientific  data submitted  were either
insufficient or contained  inadequate  test methods  to support  the position
taken.  Significant rebuttal comments and the Agency's  responses are presented
in this Section.  The complete rebuttal analysis is  contained in Appendix C.

             B.  Risk Criterion - Acute Toxicity to  Birds and Mammals

1.  LD   Range
    A number of respondents said that the Agency erred in PD  1 by stating  that
there is a narrow range of LD,-n values for strychnine among birds and mammals
tested  (30000/7: #  1B, 1C, 1D? 74, 82, 89, 94).

    Admittedly, the LD,-Q values in Table III-l  (page 20) show a range from
0.7 mg/kg (coyote) to ?12 mg/kg (California Quail).  The specific values or the
range of toxicity values are not the only factors to consider in evaluating the
hazard  to nontarget species.  The similarities  between target and nontarget
species in terms of exposure to the bait and feeding behavior must also be
considered .

    Of  the 40 species for which toxicity data were available, however, all but
four (nutria, California quail, sage grouse, turkey) had LD^Q'S approximately
equal to or less than that of major target species (ground squirrels and
pigeons).  Thus, baits formulated to control ground squirrels and pigeons  are
potentially hazardous to most other species. From this consideration alone, the
presumption is not rebutted for this risk criterion.
                                   - 9  -

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2.  Exposure to bait

    Many respondents maintained that relative toxicity alone was inadequate  to
presume that risks to wildlife exist.  Proper selection of baits (form, size,
color) and method of application coupled with the behavior and ecology of
target and nontarget species greatly influence the results (30000/7: #  1B,  1C,
1D, 39, 74, 81, 82, 91, 96).  The use of dyes to deter birds from  feeding on
baits used in rodent control was emphasized in these rebuttals.

    The Agency agrees in principle that there are several factors  that deter-
mine the degree of risk to any particular local population from a  particular
treatment.  Whether or not, for instance, the routine use of dyes  in surface
baiting for rodents can be relied on to substantially reduce risks to birds  is
a germane question, since it provides a potential method for reducing risk,  and
one that is easily enforceable.

    The Agency has reviewed all documents submitted to support the contention
that dyes are effective in protecting birds (Kalmbach, 1943, Kalmbach and
Welch, 1946, Howard, 1950, Davidson, 1962, Clark, 1975).  The accumulated
observations suggest that the use of certain dyes may prevent some birds  from
taking lethal doses of treated grain.  There is nothing in these studies,
however, that could enable predictions of the general degree of risk reduction
in the field or to understand those factors that influence the success of risk
reduction in any particular operation.  Furthermore, the general enthusiasm  for
the usefulness of dyes as a feeding deterrent is not without some
qualifications.  Schaefer (1978) stated that dyes provide only a short term
deterrent and that their effect is soon lost unless it is reinforced by
ingestion of doses of bait that cause illness.  Hegdal et al. (1979) noted that
the bright yellow dye applied to a compound 1080 bait faded noticeably after
three to four days of exposure to the sun and that exposed surfaces of the dyed
oats were virtually indistinguishable from undyed oats after two weeks. In
conclusion, the use of dyes may contribute some degree of protection to various
bird species, but this has not been quantified under normal conditions of use.

    Other relevant comments regarding exposure and its reduction will be
considered by the Agency in assessing risks and in developing regulatory
options for each use.  In general, however, current levels of use  do not
preclude exposure to all nontarget organisms and, thus, rebuttals  on the  acute
toxicity criterion based on exposure arguments are not valid.

3.  Other Studies on Birds

    Howell and Wishart's (1969) report of Canada geese killed by strychnine  was
used by the Agency in its presumption to illustrate that the use of strychnine
can result in wildlife mortality.  This report was criticized by several
respondents (30000/7: # 1B, 1C, 1D, 7, 39, 82, 91) on the following grounds:
that the death of eight geese is insignificant compared to the number killed by
hunters; that there was no conclusive evidence that strychnine was the cause of
death or that the deaths resulted from the stated use of strychnine; that there
was no evidence that the bait had been properly dyed; that the surface baiting
for gopher control did not follow directions for use.
                                   -  10  -

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    All of the above arguments  fail  to  rebut  the  Agency's  point.   The deaths of
the geese illustrate the  potential for  causing  wildlife mortality and the
magnitude of this particular  incident is  not  relevant.   The laboratory analysis
which indicated  the presence  of strychnine  in the gizzards and livers of the
geese strongly supports the conclusions that  strychnine was the cause of
death.

    The dying of bait  for surface application is  not  a  requirement on federally
registered labels and  the application of  bait around  the burrows  of ground
squirrels and prairie  dogs is a usual practice.   Thus,  it  is reasonable to
conclude that proper application of  strychnine  baits  for certain  registered
uses presents a  risk to geese and other susceptible species that  may be feeding
in the treated area.

    Several respondents referred to  studies that  lead to the conclusion that
strychnine-treated baits  present little or  no hazard  in gallinaceous birds
(30000/7: # 1B,  1C,  1D, 7, 39,  74, 81,  82,  91,  96).   The inference was that
risks were negligible  for birds in general.

    The referenced studies (Ward, et. al.  1942, Scheffer,  1922, Oman,  1923,
Garlough and Keyes,  1925,  and Knowles,  1937)  all  suffer from deficiencies in
procedures that  are not acceptable by current standards (Appendix B).   Major
weaknesses include inadequate sample sizes  and  exposure protocols.   However,
collectively, the studies suggest that  strychnine baits are not highly toxic to
several species  of gallinaceous birds and such a  result is  consistent  with
available information  on  LD^g's. These limited data  suggest that
gallinaceous bird are  the least susceptible of  all bird species tested and,
therefore, one cannot  infer a lack of acute toxic risk  to birds in  general.

    In summary,  the Agency's  presumption  that the use of strychnine treated
baits would result in  the exposure of nontarget wildlife to toxic levels  of
strychnine has not been rebutted either on  the grounds  of basic.toxicity  of
common formulations to most species  or  on the absence of exposure.

           C.  Risk Criterion - Significant Reduction in Populations of
                                 Nontarget Species

    In presuming that  the above-ground  use  of strychnine caused significant
reductions in local population,  the  Agency  cited  studies by Hegdal  and Gatz
(1976) and by Howell and  Wishart (1967).  One or  both of these studies were
criticized by a  number of respondents (30000/7: # 1B, 1C,  1D,  7,  39,  74,  82,
91, 96).

1.  Hegdal and Gatz Study

    Under an Environmental Protection Agency  (EPA) Interagency Agreement,  The
Fish and Wildlife Service  (Denver Wildlife  Research Center)  evaluated  the
hazards associated with surface  strychnine  baiting for  Richardson's ground
squirrel.   In south-central Wyoming  (during late  April  and  early  May 1976)
                                   -  11 -

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 approximately 3650 ha (hectare)—  (9000 acres)  were treated with 0.5
 percent  strychnine-treated  bait.   Approximately one tablespoon of bait was
 placed (from horseback)  at  or near ground squirrel burrows.  Application rate
 varied between one and two  kg/ha  (one to two Ib/acre).  Treated areas were
 scattered between .Saratoga  and Encampment,  Wyoming.  Effectiveness on ground
 squirrels varied,  with some plots showing almost no effect while others
 indicated up to 85 percent  control.   An average of 3.5 dead ground 'squirrels/ha
 searched (1.4/acre) were found.   Data also indicate many territorial horned
 larks were killed by the bait.  An average of 2.5 dead horned larks/ha searched
 (1.0/acre) were found.  In  addition,  after treatment,  horned larks were scarce
 in treated areas and most marked  horned larks were killed by the bait.
 Blackbirds,  especially red-winged and Brewer's,  were killed early in the
 season,  while migrating  through the area.   Territorial red-winged and yellow-
 headed blackbirds appeared  to be  reduced in number-  Populations of vesper
 sparrows and western meadowlarks  were not  seriously affected.  Mourning doves
 did not  arrive until early  May  when baiting was  well underway.  Nevertheless,
 an average of 1.1  dead doves/ha searched (0.4/acre) were found.  In addition,
 telemetry data coupled with residue data indicate that many radio-equipped
 doves using treated areas were  killed by the bait.   Two female ducks (one
 mallard  and one pintail) nested in treated  fields and  telemetry data indicated
 they were not affected by the treatment but one treatment-killed mallard was
 found.  No detrimental effects  on raptors  and mammalian predators were detected
 and most active raptor nests fledged  relatively high numbers of young.

     Respondents argued that the bait  had not been dyed,  that it had been
 applied  from horseback and  therefore  could  not  have been placed under cover as
 required on the label and that  the application  rate was higher than that on the
 label (but less than that reported by Hegdal and Gatz).   Questions were also
 raised regarding the adequacy of  the  area  sampled,  the limited number of dead
 birds analyzed for strychnine,  the lack of replication,  and the ability of the
 Agency to draw conclusions  from this  study  concerning  risks to be expected from
 other uses of strychnine and other geographical  areas.

     While many of  these  comments  point  to difficulties inherent in the conduct
 of comprehensive research on wildlife risks associated with pesticide usage,
 they do  not,  either individually  or collectively,  constitute a rebuttal against
 the general  presumption  of  risk.   In  the absence of valid risk measurements
 from other use situations,  the  Agency must  exercise appropriate judgment in
 weighing available  evidence and in making  extrapolations.

     It is important  to note that  the  study  by Hedgal and Gatz was conducted
 under the auspices  of the Wyoming Department of Agriculture and that the
 poisoning operation  was  under the supervision of the Carbon County Weed and
 Pest Control  District  using a registered label.   The only unusi il aspect of the
 control  operation was  that  the effects  were monitored  by the U.S. Fish and
 Wildlife Service under an agreement with the EPA.   The Agency has no basis,
 either from comments by  respondents or  otherwise,  for  believing that the
]_/    One hectare = 10,000 square meters or  2.4?  acres
                                    - 12  -

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 practices used,  whether or not they were in precise accordance with the
 label  directions,  were not representative of widespread and commonly recognized
 practice.

     The  state of California does require that rodent baits be dyed but this is
 not  a  federal requirement  and the formulation used in Wyoming was produced by
 the  USDI (EPA Reg.  No. 6704-58).  The label is internally inconsistent in that,
 while  it does state that all placements  must be made in or under cover where a
 hazard to wildlife  is  present, directions for treating ground squirrels (and
 kangaroo rats) direct  the  user to "scatter one teaspoon of bait over a square
 foot of  clean ground within two or three feet of the burrow entrance."
 Conceivably,  horned larks  and blackbirds are not considered as "wildlife" by
 many users and the  spring  arrival of doves after the bait had been placed might
 not  be anticipated. Direction for treating prairie dogs, on the same label,
 call for the  scattering of "tablespoon quantities of bait at the edge of
 mounds,  where forage and soil meet."  Thus, while it may be true that over-
 baiting  was done in the Wyoming operation (some prairie dogs were present), and
 this apparent mis-use  may  have led to greater bird mortality than otherwise
 would  have occured, the use of such quantities is recommended for prairie dog
 control  and one  could  anticipate a hazard from this use.

     While the 19.5  ha  searched for dead  animals may appear small (0.5 percent)
 in relation to the  3,650 ha treated,  the effort assigned to this task had to be
 consistent with  available  resources and  priorities allocated to components of
 the  total project.   The number of birds  analyzed for strychnine was intention-
 ally limited  so  that most  carcasses would be available to assess risks to any
 scavengers.   The failure of chemical analysis to detect strychnine in the
 gastrointestinal tract of  some of the dead birds is an anticipated result since
 just-lethal doses would be  totally absorbed before death.   The Agency's  judg-
 ment regarding the  significance of the observed mortality will be described
 below, but it is notable that an independent consultant (Ketron,  Inc.,  1979),
 employed by the  USDA to assess the results of this study,  indicated that
 "Mortality resulting from  strychnine as  used for control of ground squirrels
 would  occur just before the breeding season-that is,  at the worst possible
 point  in the  population cycle.   Pesticide-induced mortality of 10 to 20  percent
 at this  time,  especially if sustained from year to year,  would probably  have
 significant effects on local  populations of mourning  doves  ..."  Hegal and Gatz
 observed a strychnine-induced mortality  of 49 percent (23 out  of 47) among the
 doves  tracked by radio-telemetry.

 2.   Howell and Wishart Study

     The  Agency agrees  with  rebuttal  comments that the data  regarding mortality
 to geese (Howell and Wishart,  1969)  are  insufficient  to conclude  that the
 incident represents a  significant  reduction of a local  population.   The
observed mortality  (two  geese  at  the  baited  site  and  six falling  from the air)
may  or may not represent the  total mortality and  it  is  impossible  to know the
                                    -  13  -

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relationship between a migrating flock and a local breeding population.   The
incident does indicate a potential for significant impacts from  the  use  of
strychnine.

    In general, the argument that mortality in local populations is  quickly
compensated for by natural processes (30000/7: # 74) is not acceptable.   It
cannot be assumed, a priori, that all local nontarget populations are  substan-
tially less susceptible to poisoning than is the target population.   If  the aim
is to significantly reduce the target population, it follows  that some local
nontarget populations will be similarly affected.

3.  Rebuttals regarding other field observations

    Several respondents claimed that the Agency failed to adequately demonstrate
hazards to nontarget species and that few or no nontarget animals have been
found dead in searches following strychnine treatments (30000/7:  #  1B,  1C,  1D,
8, 8A, 44, 81, 91).  Such allegations of no observable effect are difficult to
evaluate.  Presumably there may be conditions where the use of strychnine has
not led to substantial nontarget mortality but, even where searches  have been
made, it is possible that the actual mortality has been underestimated for
various reasons.  Many of the birds (Hegdal and Gatz 1976) and mammals (Hegdal
et al. 1979) found by Hegdal and his associates would have gone  undetected had
it not been for the use of radio telemetry.  To balance the general  denial of
observed mortality, the Agency should note the report from Nevada (30000/7:  #8)
indicating that 16 dogs, 18 cats, 44 cottontails, 142 jackrabbits, 12  field
mice, one badger, three hawks, 33 crows, and 24 magpies were found dead  fol-
lowing a baiting operation of strychnine treated cabbage.  Although  no chemical
analyses for strychnine were conducted, it would be unreasonable to  assume that
the observed mortality was somehow independent of the baiting operation.   How-
ever, the significance of the mortality to local populations cannot  be assessed
from the available information.

4.  Rebuttals on secondary poisoning and endangered species

    The Agency relied primarily on a laboratory study by Schitosky (1973)  to
demonstrate that endangered species such as the kit fox, the black-footed
ferret, and the California condor were at risk from indirect exposure  to
strychnine through the consumption of poisoned rodents.  Several respondents
maintained either that the laboratory demonstration could not be used  to
predict risks of secondary poisoning in the field or that various field
observations failed to support the predication in any substantial way  (30000/7:
# 1B, 1C, 1D, 8, 39, 74, 81, 82, 91, 94, 96, 100 ).

    While there are limits on the ability to quantify risks in the field from
laboratory studies, the potential for risk can only be rebutted  by demonstrat-
ing either that the study was invalid or that the Agency's interpretation of
the study was faulty.  Respondents did not demonstrate any basic flaw  either in
the laboratory study or in the Agency's interpretation.  Some respondents
(30000/7: # 8, 81, 86) have reported deaths of cats, dogs, gray  foxes, coyotes
and other species in close association with strychnine baiting operations for
                                    - 14  -

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rodents.   While  none  of this  mortality was confirmed by residue analysis, it is
reasonable to  conclude  from the basic toxicity data and the anecdotal reports
that  some  secondary poisoning of carnivores has occurred from the use of
strychnine to  control rodents.   Additionally,  the Agency has new information on
raptor mortality associated with the use of strychnine to control pigeons.
These data will  be  presented  below in the risk assessment.   The risk criterion
has not been rebutted by claims that secondary poisoning cannot occur in the
field.

    Respondents  (30000/7:  # 1B, 1C,  1D,  74,  82,  94) also argued either that
endangered species  generally  were not being jeopardized by  pesticides but by
habitat loss;  that  the  population of the San Joaquin kit fox was increasing;
that  designation of some populations as  endangered species  is based on a
taxonomic  technicality;  or that no endangered  species were  present in many
areas of use.  Such arguments do not serve to  rebut the criterion.

    While  habitat loss  may be the major  reason for the endangerment of some
species, it does not  logically follow that additional losses due to pesticides
will  not exacerbate the situation.   The  precise  status of most species is
difficult  to establish.   Claims that the number  of kit foxes is increasing
rests on estimates  so crude that little  confidence can be placed on the
suggested  trend.  Until  such  time that the species may be removed from
the endangered list,  any losses due  to pesticides are of significant concern
to the Agency.

    The authority for designating endangered species and their critical habitat
rests with the Department  of  Interior, and the EPA makes appropriate responses
to their determinations  on the  status of various populations when it can be
expected that  the use of a pesticide will  cause  mortality to individuals.   Most
current strychnine  labels  do  not restrict  the  use of strychnine in ways that
would preclude exposure  to endangered species, and allegations concerning  the
absence of endangered species in certain locations where strychnine is likely
to be used  do  not serve  to rebut the general criterion.   The Agency agrees that
endangered species  do not  reside in  many areas where the use of strychnine is
desired.   The  feasibility  of  permitting  use  under such circumstances is
considered  in  formulating  regulatory options in  Section V.

5.  Miscellaneous Rebuttals

    Many respondents  indicated  that  special  formulations or  modes  of
application for certain  pests reduced  or eliminated  exposure  to nontarget
species.   Comments  regarding  bird control  (30000/7:  # 1B, 1C,  49,  56,  82),
porcupine control (30000/7: # 50, 51,  74,  85), commensal rodent control
(30000/7:  #44, 74,  96), rabbit  control on crops  and  rangeland and certain
other minor uses  (30000/7:  #  63, 71,  83, 89, 90,  91,  95)  failed to rebut all
presumptions but the appropriate details of  these  submissions  will be  discussed
in the risk/benefit  analysis and regulatory options  (Section  V).   Comments
regarding rabbit control in reforestation areas  (30000/7: #  85)  and  mountain
beaver control (30000/7: # 50) deal with unregistered  uses.   Comments  on skunk
                                    -  15  -

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control (30000/7: # 49, 94) and on the pocket gopher/mole control  (30000/7: #2,
8, 48, 57, 56, 58, 62, 65, 74, 79, 91, 98) deal with uses that are not the
subject of the strychnine RPAR.  Coranents on these latter uses, therefore,
will not be discussed.
                                   -  16 -

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                           III.   Risk Analysis

    The risk analysis  is a detailed  study  of the  risks  associated  with the
registered uses  of the RPAR chemical.   The specific risks examined are those
for which the RPAR notice  was issued.   In  the case  of strychnine,  the focus of
the analysis is  the risk to nontarget birds and mammals,  including members of
endangered species,  from exposure  to treated bait.

    The approach taken is  to first present the common methods of baiting for
various target birds and mammals.  This information will  form the  background
for the subsequent analysis of  the risks to nontarget species.  Next, acute and
chronic toxicity data,  from laboratory and field  studies,  are presented.  Tne
data are for both target and nontarget organisms, and form the basis  for the
assessment of the risks associated with the baiting practices.

    The same approach  is used in analyzing the risks of the various
alternatives.  The alternatives examined are those  that are currently
registered for the same uses as strychnine.

    Following the analysis of the  risks of using  strychnine and the
alternatives, the relative risks are assessed and-summarized for each use
pattern.

                              A.  Strychnine

1.  Methods of Application for  Target Species

    a.   Ground  Squirrels

         Strychnine is  mixed into  baits, usually  grains such as oats  or  barley,
but also chopped cabbage or dandelion  greens.   Tne  final use strength of the
baits ranges from 0.2 percent to 0.52  percent strychnine alkaloid.  Either  one
teaspoon or one  tablespoon of bait is  scattered near the burrow entrance or on
runways used by  the  ground squirrels.   This is most often  done in  the spring
during the breeding  season but  some  labels  call for repeated treatments  if
squirrels remain after  initial  treatment.   Many of  these labels recommend that
bare ground is the  best bait placement  site.   A few others  call  for placing the
bait in the burrow or under brush  cover if other  wildlife  is present.  On the
average,  there are approximately 80  bait placements per pound of bait and a
pound should treat  10-15 acres.  For heavy infestation, one pound  may treat
only two-three acres.   Oat  baits may retain full  strength  for three days or
more on the ground  in the  absence  of rain.   Approximately  an 85 percent  residue
loss through degradation occurred  in baits  10-18 days after application  (Hegdal
and Gatz, 1977a).

    b.   Prairie Dog

         The concentration  of the active ingredient  of  strychnine  grain  baits
for control of prairie dogs vary from 0.3 percent to 0.5 percent.   Two
teaspoons to one tablespoon of bait  is  scattered near prairie  dog  mounds on the
                                   -  17 -

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side away from the dirt pile.  About 0.5 to 3.0 pounds of bait are used per
acre in this manner.  Some labels caution against use if black-footed ferrets
are in the area or direct the user to place the bait under cover of brush or
weeds if wildlife hazards exist.

    c.   Other Mammals

         1)   Jackrabbits

              Baits consist of grains (mostly rolled barley, but oats are also
used), root vegetables and fruit, or greens.  The concentration of strychnine
in the bait ranges from 0.28 percent to 1.5 percent for grain baits.  For
green baits, formulations range from one ounce of five percent strychnine on
three pounds of bait (0.1 percent) to one ounce of 99.5 percent strychnine on
20 pounds of bait (0.3 percent).

              A variety of methods are used for applying the bait; a heaping
tablespoon of bait in mounds 10 feet apart, a half cup at locations where pre-
baiting is accepted, one or two heaping tablespoons at intervals of 35 to 50
feet, or one teaspoonful where pre-baiting is accepted.  Applications are made
along the rabbit trails, around the perimeter of the field, along tree rows or
where trails meet.

         2)   Kangaroo and Cotton Rats

              Strychnine grain bait is formulated at concentrations of from
0.25 percent to 1.0 percent.  Application rates are made by hand in amounts
of one or two teaspoonfuls eight to ten feet apart.

         3)   Porcupines

              Strychnine treated salt blocks (5.8 percent concentration)
are nailed to trees, placed in porcupine dens, or placed under shelters.  Also,
strychnine pellets are placed in bait boxes.

    d.   Pigeons and House Sparrows

         For pigeon control, whole corn bait with a concentration of 0.6 percent
strychnine is scattered on the ground following prebaiting with untreated grain.
For house sparrows, grain bait with a concentration of 0.25 percent to 0.8 per-
cent strychnine is either scattered on the ground or placed in troughs.

    e.   Croplands Birds

         For orchards and vineyards, troughs containing bait are placed in
trees or on standards.  The bait may be milo,  rice, oats, corn or vegetables
and the concentration of strychnine ranges from 0.25 percent to 0.90 percent.
For the protection of sprouting vegetable seeds, baits may be applied on the
ground between the furrows.
                                    -  18  -

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 2.   General

     a.   Toxicology

         The  toxic  effect  of strychnine  is  reported to be  primarily against  the
 nervous system.   The  threshold  for  stimulation  of motor effects  by  external
 stimuli is lowered, resulting in  such signs and symptoms as  apparent hyperacusis
 (painful sensitiveness  to  sounds),  recurrent convulsions or  tetanic seizures.
 Slight touches or light stimuli produce  exaggerated responses  and often
 seizures (Tucker  and  Crabtree,  1970).

         The  fact that  symptoms appear in many  species as  soon as  10 minutes
 after ingestion and that recovery of  survivors  is generally  complete within  a
 few  hours implies rapid and  thorough  absorption of strychnine.   Also implied is
 rapid metabolism  in the animal  body and/or  elimination of  the  compound  and
 metabolites (Tucker and Crabtree, 1970).

         A compound which  is rapidly  absorbed in undiluted form  and either
 produces death quickly,  or rapid  recovery,  often displays  a  "feed-dilution
 effect."  That is, a  high  concentration  of  the  material, quickly ingested and
 absorbed, will produce  toxic effects.  However,  if the compound  is  in such low
 concentration in  feed that absorption is  slowed,  some  of the ingested dosage
 may  be detoxified before all is absorbed.   This would  effectively reduce the
 toxic effect  (Howard  and Marsh, 1973).   Strychnine appears to  be subject to
 this effect and hence there  are reports of  somewhat lower  toxicity  from baits
 than would be expected  from  single  oral  tests (Ward, et al., 1942).   If
 administered  slowly,  repeated oral  treatments may appear to  produce  increased
 tolerance of  strychnine.   This  apparent  tolerance may  be the result  of
 increasingly  rapid elimination  and/or metabolism.

         Gross pathological  examination of  numerous wildlife species treated
 with strychnine at lethal  levels  revealed occasional hyperemia (excess  of
 blood) and hemorrhaging  of the  gastrointestinal tract,  minor endocardial
 hemorrhages,  and  massive hemorrhages in the  myocardium.  Very often  no  gross
 pathological  change attributable  to the action  of strychnine occurred.

     b.   Acute Toxicity

         Table III-1  provides a summary of  acute  oral  toxicity values for
 strychnine relating to various  species of mammals,  amphibians, and birds.

         The  acute oral  ID™  values for the  species given  in Table III-1
 range from 0.75 mg/kg for  trie coyote and desert kit fox to 112 rag/kg for the
 California quail.  Most LD,-Q  values fall into the  range of 1.0 to 25 mg/kg
 for  both mammals  and birds.

     c.   Subacute and Chronic Toxicity

         While there are few  reports of effects of long-term, low-level
exposure to strychnine,  it seems likely that  rapid metabolism and/or
                                    -  19  -

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               TABLE III-l - ACUTE ORAL TOXICITY OF STRYCHNINE ALKALOID
SPECIES
                                          /kgl/
mg/kg.
                                                                REFERENCE!/
I.   MAMMALS

     WILD RODENTS & RELATIVES
Calif, ground squirrel
Black-tailed prairie dog
Northern pocket-gopher
Banner-tailed kangaroo rat
Meadow .vole
Calif, meadow vole
Norway rat (wild)
White rat (male)
White rat (female)
Black rat
Polynesian rat
Black-tailed jack rabbit
Nutria
19.9 -28.0
1.5
8.3
3.7
6.8
22.2
12.0
14.0
5.8
10.1
6.8
4.4
27.0 - 42.0
DWRC Files,
DWRC Annua
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Files
DWRC Annua.
                                                                Reports/DWRC
                                                                Unpublished Data
     !/  Data marked (S)  if the sulfate was known to be used.
     !/  DWRC indicates  Denver  Wildlife Research Center.

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                               TABLE  III  -  1  (Continued)
SPECIES
        i/
   mg/kgA/
REFERENCE!/
B.   CARNIVOROUS MAMMALS






     Cat




     Dog




     Desert kit fox




     Coyote






C.   OTHER MAMMALS






     Man




     Hog




     Horse




     Cow




     Sheep




     Mule deer






II.  AMPHIBIANS






     Bull frog






III.  BIRDS






A.  WATERFOWL






     Mallard




     Canada goose
    0.75




   1-1.2




    0.75




    0.7
    1.0




   10.0




    2.0




   15.0




    7.5




17.0 - 24.0
    2.21
    2.9




    4.0
  DWRC Files




  DWRC Files




  DWRC Files




  DWRC Files
  Howard and Marsh




  DWRC Files




  DWRC Files




  DWRC Files




  DWRC Files




  Tucker and Crabtree
  Tucker and Crabtree
  Tucker and Crabtree



  Tucker and Crabtree
     I   Data marked  (S) if the sulfate was known to be used.

     2/  DWRC indicates Denver Wildlife Research Center.

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                              TABLE  III -  1  (continued)
SPECIES







B.  UPLAND GAME BIRDS AND RELATIVES







     Mourning dove




     Pigeon




     Ring-necked pheasant




     Ring-necked pheasant




     Chukar




     California quail




     Sage grouse




     Turkey




     Coturnix






C.  PASSERINES







     Robin




     House finch




     English sparrow




     English sparrow




     Starling




     Red-winged blackbird
L°50 i/
rng/kgl/
                                                                REFERENCE!/
 5.12(S)




 21.3




 24.7




  8.48 (S)




 16.0




  112




35-50




   50




 22.6
 10.0




  5.6




  4.18




  4.0 - 8.0 (S)




  5.0(S)




  6.0
DWRC Files




Tucker and Crabtree




Tucker and Crabtree




Tucker and Crabtree




Tucker and Crabtree




Tucker, et al




Ward, et al




DWRC Files




Tucker and Crabtree
DWRC Files




DWRC Files




Tucker and Crabtree




Tucker and Crabtree




Schafer




DWRC Annual Reports
     ~    Data marked (S)  if the sulfate was known to be used.

     !/  DWRC indicates  Denver Wildlife Research Center

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                               TABLE III - 1 (continued)


                                        LD50
SPECIES                                 mq/kgl/                 REFERENCE?./
D.  RAPTORS



     Golden eagle                        5.0                      Tucker and Crabtree


     Golden eagle                       >5.0  (S)                  Tucker and Crabtree
         Data marked  (S) if the sulfate was known to be used.
         DWRC indicates Denver Wildlife Research Center

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elimination of this material would preclude cumulative toxic action to any
marked degree.  In addition, the bitter taste of strychnine and rapid onset of
symptoms have been demonstrated to produce "bait-shyness" or poor reacceptance
of strychnine-containing diets by many species.  This phenomenon is known for
sage grouse (Farm Chemicals Handbook, 1973), pheasants (Schaffer, 1973), and
other species.  It is conceivable that "bait-shy" animals might consume such
baits after prolonged starvation.  Two pheasants starved for two days died
within an hour after consuming 20 and 34 grams, respectively, of a bait
containing one ounce, strychnine per 10 Ibs. grain.  Unstarved pheasants,
however, accepted this bait poorly and showed no signs of intoxication (Rudd 4
Genelly, 1956).  Twenty grams of this bait would contain 125 mg. strychnine.
Assuming a body weight of 1.2 kg, the total dosage for the starved pheasants
amounted to 104 mg/kg, substantially more than the acute oral LA-0 of 24.7
rag/kg.  Pheasants typically eat 50-100 grams of grain feed per day (Tucker,
Personal Communication 1978).  Thus, if bait shyness did not occur, ingestion
of lethal amounts of strychnine could occur.

     d.  Bioaccumulation and Tissue Residues

         There is little evidence in the literature to indicate that elevated
residues of strychnine can accumulate in animal tissue.  Data from a study of
530 albino mice showed no accumulation of strychnine and no tolerance
development to increasing dosages of the chemical. Detoxification seemed to be
complete within the first 24 hours after administration (Kalning, 1968).

    e.   Secondary Toxicity

         Low persistence of strychnine residues in tissues of animals greatly
reduces the chance for secondary toxicity.  However, unabsorbed residues in the
gastrointestinal tract or cheek pouches of an animal ingesting a large dosage
and quickly dying could be sufficient to poison a raptor or carnivore ingesting
it.  The calculation that fifty squirrels killed by strychnine would have to be
eaten by a hawk for a fatal dose (Garlough and Ward, 1932) ignores this major
source of risk. There is also a report, described briefly in Section I, of
secondary poisoning of a kit fox as a result of ingesting strychnine-poisoned
kangaroo rats under laboratory conditions (Schitosky, 1975).

    f.   Summary

         Indications are that any likely potential field effects will not be
the result of the compound's properties in regard to accumulation, chronic
toxicity, reproductive effects, or secondary hazard from the consumption of
flesh.  Any potential for ecological vulnerability of terrestrial wildlife
would appear to be the result of the high degree of acute toxicity by the oral
(including dietary) route from either the bait or bait residue in the
gastrointestinal tract or cheek pouches of poisoned animals.

3-  Direct Risks to Nontarget Species

    Since the purpose of placing strychnine treated bait in the field is to
kill offending mammals and birds, it is obvious that a risk is present to
                                    - 24  -

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 individuals  of many  nontarget  vertebrate species that  may feed on the bait.
 The major  issue  is whether such feeding generally results in significant
 population reductions  in  the nontarget  species.   The best available
 information   regarding this issue can be found in the  observations of Hegdal
 and Gatz  (1977a).

    By using various methods to monitor the effects  of applying  0.5 percent
 strychnine on steam-rolled oats to control  ground squirrels  in Wyoming,  Hegdal
 and Gatz  (1977a) determined that a majority of the territorial horned larks  in
 the treated  areas was  killed,  as were several  blackbirds.  Large  numbers of
 mourning  doves were  also  killed.  The impact on certain other species of birds
 (vesper sparrows and meadowlarks) appeared  to  be substantially less (only three
 dead birds found).

    The observed mortality varied substantially from area to area,  presumably
 in relation  to habitat details.   For  instance,  of 19-5 ha searched,  42 percent
 (54/129)  of  all birds  found dead were in a  two ha plot in a  wheatfield.   Three
 "rangeland"  plots totalling four ha produced only eight dead birds  while a two
 ha lot in  "crested wheat  rangeland" yielded 24 bird  carcasses. A two ha plot
 in alfalfa produced  but a single bird carcass.

    The observed impact on birds ranged from 0.5 to  27 deaths per ha.  However,
 no conclusion can be drawn from the study as to  whether the  site  (i.e.
 cropland,  pasture and  range, noncropland) had  any effect on  the risks to the
 birds.  Therefore, extrapolation of the results  of this study to  predict the
 effects in other situations cannot be accomplished with a high degree of
 accuracy.

    A reasonable conclusion is that reductions  in local populations  are  likely
 but that the  magnitude of this impact may vary with  the species present  and  the
 area treated.  Any long-term impact on  vulnerable species  could vary with
 factors such  as the  frequency  of application,  the scale of the operation and
 the distribution and abundance of the species.   The  Agency has no reason to
 believe that  there are substantial geographical  areas  where  strychnine might be
 used in surface baiting operations without  exposure  to one or more susceptible,
 nontarget  species.

 4.  Indirect  Risks to  Nontarget  Species

    A potential for  an indirect  or secondary risk to vertebrates  that  feed on
 rodents killed by strychnine has  been demonstrated (Schitosky,  1975).
 Translating this potential  into  realistic probabilities, however, should be
 done with  caution.   Sublethal  doses of  strychnine may  be rapidly  metabolized
 and eliminated from  the body and,  presumably, death occurs when this  defense
mechanism  is overwhelmed by the  dose.   A general  assumption,  therefore,  is that
most of the strychnine absorbed  by a  victim  has  little  potential  for  secondary
poisoning; the major risk comes  from  the strychnine that may  remain in the gut
and in the cheek pouches.
                                    -  25  -

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    If a 0.5 kg ground squirrel were to eat two g of a 0.5 percent strychnine
bait, the ten mg of strychnine ingested may be just the lethal amount, since
its LD,-n is 20 rag/kg.  Little or no strychnine would remain in the gut.
Hegdal and Gatz (1977a) analyzed three Richardson's ground squirrels that
apparently had been killed by strychnine.  One contained 0.03 mg  (2.8 ppm)
strychnine in the stomach but no strychnine was detected at the limit of 0.5
ppm in the other two squirrels.  These three squirrels would have posed little
risk to any predator/scavenger-  Three squirrels, however, are hardly an
adequate sample and the Agency does not know the probability of a squirrel's
consuming substantially more than a lethal dose of this rapidly acting poison.
There is some evidence that ground squirrels poisoned by the strychnine remove
the contents of the cheek pouches before dying (Stephl and Gates, 1928), but,
again, the Agency has no reasonable measure of the level of pouched poison to
be expected or the likelihood that such material will be ingested by predators
and scavengers.  The meager evidence suggests that secondary risk from ground
squirrel control may be generally low.

    On the other hand, should a prairie dog ingest the same two g of 0.5
percent strychnine, the situation may be quite different.  Since the LDcQ for
prairie dogs is only  1.5 mg/kg as much as eight mg may remain in the gut.
Such quantities of strychnine would be highly lethal for any swift fox or black-
footed ferret that fed on the gut of the prairie dog.  Again, data are not
available as to how much bait a prairie dog is likely to consume before it
dies, but it seems reasonable to conclude that the risk from eating a
strychnine-poisoned prairie dog may be much greater than that from eating such
a ground squirrel.

    In the case of birds poisoned by strychnine, substantially more information
is available.  Hegdal and Gatz (1977a) analyzed the gastrointestinal tracts of
40 mourning doves apparently killed by strychnine baits.  Of these birds, the
maximum amount of strychnine found was 1.6 mg and the next highest amount was
0.86 mg.  The median level was 0.1 mg strychnine. It should be noted that most
of these spring immigrants were not exposed to fresh bait since they did not
arrive until the baiting was well underway and that the strychnine level in the
bait decreased progressively with time.  The levels of strychnine in the doves
also decreased according to the length of time elapsed after baiting before
they consumed lethal doses.  A reasonable assumption is that if most of the
doves were killed on the day the bait was placed, the levels of strychnine in
the gastrointestinal tract would have averaged somewhat higher.  Nevertheless,
of the amounts of strychnine found, most were not at levels that would be
generally hazardous to scavenging vertebrates. Six of the 39 birds contained
more than 0.5 mg strychnine and such amounts would be of toxicological signifi-
cance only to small carnivores whose LD^'s are in the 0.7 to 1.0 mg/kg
range, such as the swift fox.

    While the Agency cannot conclude that the available evidence is entirely
adequate for an accurate risk assessment, the weight of the evidence suggests
that the use of strychnine to control ground squirrels is not generally likely
to create a high risk to nontarget species from secondary poisoning.  Risks
from prairie dog control, however, may be substantially higher.
                                   -  26 -

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5.  Risks to Members of Endangered Species

    Section 7 of the Endangered Species Act of  1973  (ESA)  (16 USC  1531 et seq.)
requires all Federal agencies, in consultation with and with assistance of the
Secretary of the Interior, to take such action as is "necessary to insure that
actions authorized, funded, or carried out by them do not jeopardize the
continued existence of ... endangered species and threatened species or result
in the destruction or modification of habitat of such species which is deter-
mined by the Secretary .... to be critical."  Accordingly, the Departments of
the Interior and Commerce have established joint regulations implementing
Section 7 of ESA, which include provisions for interagency cooperation and
consultation concerning endangered and threatened species and their habitats
(50 CFR 402, 43 FR 870-875).

    On March 13, 1978, EPA requested formal consultation with the U.S.
Department of Interior, Fish and Wildlife Service, under Section 7 of the
Endangered Species Act of 1973» on the above-ground uses of strychnine as they
affect endangered and threatened species.

    As a result of that consultation, 43 endangered species were identified
as likely to be exposed to strychnine as presently registered by EPA
(Appendix D).  These are listed as follows:
                                   -  27 -

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           Endangered Species Likely  to  be  Exposed to Strychnine









Reptiles









American Alligator (Alligator mississippiensis)




American Crocodile (Crocodylus actus)




Eastern Indigo Snake (Drymarchon nnrais  couperi)









Birds









Aleutian Canada Goose (Branta canadensis leucopareia)




Hawaiian Goose  (Nene) (Branta sandvicensis)




Marianas Mallard  (Anas outstaleti)




Hawaiian Duck  (Koloa) (Anas wyvilliana)




California Condor  (Gymnogyps californianus)




Hawaiian Hawk  (Buteo solitarius)




Bald Eagle  (Haliaeetus leucocephalus)




American Peregrine Falcon  (Falco  peregrinus anatum)




Arctic  Peregrine  Falcon  (Falco peregrinus  tundrinus)




Attwater's Greater Prairie  Chicken  (Tympanuchus cupido attwateri)




Masked  Bobwhite  (Colinus virginianus  ridgewayi)




Mississippi Sandhill Crane  (G_rus  canadensis pulla)




Whooping Crane  (Grus americana)
                                         28

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Hawaiian Gallinule  (Gallinula chloropus sandvicensis)




Hawaiian Coot  (Fulica americana alai)




Hawaiian Stilt  (Himantopus himantopus  knudseni)




LaPerouse's Megapode  (Megapodius laperouse)




Puerto Rican Plain  Pigeon  (Columba  inornata wetmorei)




Palau Ground Dove  (Gallicolumba canifrons)




San Clemente Loggerhead Shrike  (Lanius ludoricianus  mearnsi)




Ponape1 Mountain Starling  (Aplonis  pelzelni)




Yellow-shouldered  Blackbird  (Agelaius  xanthomus)




Laysan and Nihoa Finches  (Psittirostra cantans  cantans;  P.c.  ultima)




Cape Sable Sparrow (Ammospiza maritima mirabilis)




Dusky Seaside  Sparrow (Ammospiza maritima nigrescens)




San Clemente Sage  Sparrow  (Amphispiza  belli clementae)









Mammals









Grizzly Bear  (Ursus arctos horribilis)




Black-footed Ferret (Mustela nigripes)




San Joaquin Kit Fox (Vulpes  macrotis mutica)




Red Wolf  (Canis rufus)




Gray Wolf  (Canis lupus)




Eastern Cougar (Felis concolor  cougar)




Florida Panther (Felis concolor coryi)




Utah Prairie Dog  (Cynomys  parvidens)




Delmarva Peninsula Fox Squirrel  (Sciurus  niger  cinereus)
                                        29

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Morro Bay Kangaroo Rat (Dipodomys heermanni morroensis)




Salt Marsh Harvest Mouse (Reithrodontomys raviventris)




Key Deer (Odocoileus virginianus clavium)




Columbian White-tailed Deer (Odocoileus virginianus leucurus)




Sonoran Pronghorn (Antilocapra americana sonoriensis)
                                      30

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    Strychnine's ability to kill members pf endangered  species  is  anticipated
because strychnine is highly toxic  to mammals and birds and  strychnine-treated
baits may be applied in areas inhabited by endangered species.

    As with other nontarget species, those endangered species with feeding
habits similar to target animals would be expected to eat the treated baits
placed above ground for the target  organisms.   Additionally, indirect exposure
may occur if predators or scavengers feed on the carcasses of strychnine
victims, such as doves, ground squirrels, prairie dogs,  and  pigeons.

    Of the 43 endangered species in the preceeding list,  18  were identified by
the USD! as likely to be jeopardized if strychnine is used where these species
are found. They are the Utah prairie dog, Morro Bay kangaroo rat,  salt marsh
harvest mouse, red wolf, masked bobwhite, dusky seaside  sparrow, Cape Sable
sparrow, Mississippi sandhill crane, Puerto Rican plain  pigeon, Attwater's
greater prairie chicken, yellow-shouldered blackbird, California condor, black-
footed ferret, San Joaquin kit fox, gray wolf, and grizzly bear, Laysan finch
and Nihoa finch.  The Agency does not believe a possibility  exists for
strychnine use on the islands of Laysan and Nihoa, since they are  not
inhabited by man.  Therefore, the Laysan and Nihoa finches will not be
considered as needing special precautions.  The specific use(s) of strychnine
of concern for each of the other 16 species is discussed in  Section V. The
Agency believes that certain other  species, the Peregrine Falcon and the
Aleutian Canada Goose, require special concern.  The following  analyses provide
the bases for the Agency's assessment of risks to the various species from the
use of strychnine.

    The Agency's interim procedure  for estimating a "no  effect" level in
assessing risks to endangered bird  and mammals  (EPA, 1980) utilizes either a
value of 1/5 the subacute dietary LC^ or 1/5 the acute  LD-Q expected to
occur in or on the average daily intake of treated feed  to which members of the
species may be exposed.  This information is not available for  strychnine.  The
only basis for assessing risk consists of various LD^Q values,  anticipated
exposure levels, and the knowledge  that strychnine appears not  to  be cummula-
tive in its effects.

    Accurate use of the available data is hampered by the facts that the LDcn
data provide no information on the  range of individual variability and that
interspecific sensitivity to strychnine is relatively high.  The limited data
base indicates that two species in  the same genus (Microtus) have  LD^'s
that differ by a factor of three and, within the same family, the  chokar is
seven times as sensitive as the California quail (Table  III-1).

    As an interim procedure for strychnine, the Agency will  consider, for each
endangered species, the suitability of the toxicity data in  regard to related
species, the probabilities of various exposures and the  status of  the
endangered species in making determinations as to whether the margins of safety
are sufficient.

    a.   The Black-Footed Ferret

         This rare mammal is thought to be highly dependent  on  the existence  of
prairie dog colonies.  Its present  plight is doubtlessly due to the fact that
prairie dogs have been eliminated over the majority of  the acreage previously
occupied.  While further reduction  of prairie dog acreage by whatever means
                                    -  31  -

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cannot but serve to worsen the situation of the ferret, mere maintenance  of the
present prairie dog population by controlling with strychnine has a high
potential for killing ferrets by secondary poisoning.

         The USDI (Appendix D) has concluded that the use of strychnine to
control prairie dogs could jeopardize the continued existence of the black-
footed ferret.  The Agency concurs in this opinion.  While the  critical
habitat of the ferret has not been defined by the USDI, the Agency believes
that any area now occupied by prairie dogs must be considered with great
concern due to the relationship between the ferret and the prairie dog.

         The USDI did not address the problem of controlling ground squirrels.
White-tailed prairie dogs generally occur at lower densities than do black-
tails and their populations are frequently intermixed with those of certain
species of ground squirrels (Richardson's, Uinta and, to a lesser extent,
Townsend's).  For ground squirrel control grain bait is usually applied in the
spring before green vegetation becomes available   For prairie  dogs, baiting is
usually done in the late summer after the vegetation has become dry.   Due to
the different baiting seasons, prairie dogs are not especially  vulnerable to
control efforts aimed at ground squirrels, although some mortality can be
expected  (Hegdal and Gatz, 1977a).

    Available data suggest that the use of strychnine to control ground
squirrels is substantially less hazardous to the ferret than is the use to
control prairie dogs.  However,it must be recognized that a potential  risk
exists to the ferret if ground squirrel control is conducted when prairie dogs
are present.

    b.   The San Joaquin Kit Fox

         The USDI (Appendix D) has concluded that the use of strychnine within
the area of this sub-species of the kit fox would jeopardize its continued
existence.  The Agency concurs in this opinion.  The major target species
within this area would be the California ground squirrel and, by extrapolation
from limited data, the probability of risk to the kit fox would appear to be
moderate were strychnine to be used for squirrel control.  The  use of
strychnine to control birds in cropland poses negligible risk to the species
since kit foxes are unlikely to range in those cultivated fields, orchards and
vineyards where strychnine is used.

    c.   The California Condor

         Only 25-35 individuals of this species remain (Wilbur, 1980)  and the
USDI concludes that "the loss of even one condor must be considered signifi-
cant" (Appendix D).  Current uses of strychnine in the condor's range  are
mainly for underground pocket gopher control and for horned larks and  finches
in cultivated land and orchards.  The Agency concurs with the USDI that these
uses are unlikely to expose condors to strychnine.  A concern,  however, remains
for the potential use of strychnine to control ground squirrels.
                                   -  32  -

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         While strychnine is registered to control ground  squirrels,  little,  if
any, is used for this purpose in the condor's range  because compound  1080 is
judged to be much more efficacious.  Should this use of compound  1080 be
cancelled under the RPAR process, use of strychnine  could  increase.

         Of the species for which strychnine toxicity data are available, the
one most closely related to the condor is the golden eagle, for which the
LD^gis 5 mg/kg.  For a nine kg condor, 45 mg strychnine may be highly lethal
and an exposure of as much as two mg would not provide an  acceptable  margin of
safety for this highly endangered species.  This level of  exposure can be
obtained indirectly from consuming 0.4 g of a 0.5 percent  bait.  Such exposure
from the use of strychnine for rodent control appears likely since the condor's
diet consists entirely of dead animals including poisoned  ground  squirrels
(Koford, 1953)-  While the amounts of strychnine to  be expected in the car-
casses of the poisoned animals are largely unknown,  the potential for an excess
of 0.4 g bait in a dead squirrel is easily visualized and  the Agency  must
conclude that an ample margin of safety for the condor has not been
demonstrated for this use of strychnine.

    d.   The Peregrine Falcon

         The USDI concluded that peregrines could be adversely affected by a
strychnine pigeon cont: ol program if proper precautions (unspecified) are not
followed.  Since there was no evidence of improper precautions the USDI opinion
was that the continued use of strychnine is not likely to  jeopardize  the con-
tinued existance of the Arctic or American peregrine.  Since that assessment,
the Agency has received the following new information and  conducted additional
analyses that lead it to conclude that, when strychnine is used according to
current practices for control of pigeons and ground  squirrels, some risk to
peregrine falcons is likely.  /

         1. Several raptors, including owls and hawks, have been  poisoned by
strychnine in association with a control operation for pigeons in Duluth,
Minnesota (Redig, 1978).  This event clearly indicates that a potential exists
for secondary poisoning of some species of raptors associated with this use of
strychnine.  Procedures such as pre-baiting flocks of pigeons and exposing them
to high concentrations of bait are likely to maximize residue levels.  Redig's
(1978) observation that the dead raptors did not contain bait casts doubt on
the generalization (derived from studies with rats)  that the flesh of animals
killed with strychnine is not hazardous.

         2. A prairie falcon was killed during a pigeon control operation
in Colorado in January 1980 (Locke, 1980).  Similarities in the feeding
patterns of prairie and peregrine falcons demonstrate the  potential risk to the
peregrine.

         3. In Baltimore, Maryland, July, 1979, a young peregrine was
observed to exhibit convulsions. Several days later, its body was found (Cade,
1980).  Autopsy revealed feathers and seeds in the bird's  stomach.  Although  a
chemical analysis for strychnine had not been conducted at that time  (Locke,
1980, personal communication), the presence of seeds in the falcon's  stomach
                                    - 33  -

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demonstrates that peregrines could be exposed to strychnine bait  in  pigeon
control operations.

         4. Strychnine levels found in the gastrointestinal tracts of
poisoned doves  (Hegdal and Gatz,  1977a) were at a maximum of  1.6  rag  and a
median of 0.1 rag.Poisoned birds represent the most  likely form of exposure for
peregrines and  1.6 mg of strychnine would provide a dose of 3 mg/kg  for a 0.5
kg bird and 1.5 mg/kg for a  1.0 kg bird.  Compared  to  the LD^Q of 5  mg/kg for
a golden eagle, such a dose  is of critical concern.  The median exposure of 0.1
mg strychnine would be of marginal concern.

         Whether a quantity  of strychnine in the gut of a bird poses a risk
to a peregrine  depends on several circumstances.  Peregrine falcons  are
unlikely to feed on carrion; a falcon must be on the scene when a poisoned bird
is in distress.  A flock of convulsing pigeons is much more likely to attract a
falcon than is  a single dove in convulsions.  Having secured  a poisoned bird,
the risk to the falcon depends largely on how much  strychnine is  in  the
gastrointestinal tract and how much of that present is consumed.  For pigeons
and larger birds, the gizzard may be eaten intact but  the contents of the crop
are less likely to be eaten by a  peregrine (Cade, 1980).  For doves  and smaller
birds, the entire carcass may be  eaten.

         Risks  to the peregrine falcon from the use of strychnine to control
birds and rodents vary.  If a falcon is in the vicinity of a  pigeon  control
operation, the  risks are high —  virtually every poisoned individual of the
target species may be potentially lethal to a peregrine.  The risks  from birds
poisoned incidental to the control of rangeland rodents are somewhat lower.
About 15 percent of the doves analyzed by Hegdal and Gatz (1977)  contained
toxicologically significant levels of strychnine (>0.5 mg).   In order for the
use of strychnine to not jeopardize the continued existence of peregrine
falcons, proper precautions beyond those currently  being employed are necessary
for ground squirrel and pigeon control.  For sparrow control,  however,  little
or no risk is probable because these small target species are unlikely to be
fed on by peregrines.

    e.   Other Species

         The Agency concurs with  the USDI for the remaining species  listed as
likely to be jeopardized by the above-ground use of strychnine  with  the
exception of the Laysan and Nihoa finches.  In addition to the  peregrine
falcon, however, the Agency believes that the Aleutian  Canada goose  merits
special concern due to a potential exposure to strychnine bait.   These geese
arrive in the Sacramento Valley in October, then move mainly  to the  upper San
Joaquin Valley by winter.  They generally return north  to the vicinity of
Crescent City in March and depart for the Aleutians in  April  (Woolington
et al., 1979).  Although ground squirrel control operations are not  likely to
take place at the time these geese are present on their wintering grounds,  such
operations could expose large flocks of geese to toxic  baits.

6.  Human/Domestic Risks

    The lack of emergency treatment criteria was also examined  in the PD1 in
deciding if strychnine qualified as an RPAR chemical.   After  reviewing the
available information, the conclusion reached was that  an emergency  treatment
(activated charcoal,  barbituates,  and muscle relaxants) did exist and a
presumption against registration because of that criteria was  not warranted.
                                    - 34  -

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    A recommendation was made by  the  Agency  working  group,  however,  for
consideration of three points during  the  reregistration  process.   These are:

    o  Products with concentrations above 0.5 percent  should  be restricted  to
certified applicators.

    o  Dilute baits should only be available to  untrained applicators when
adequate packaging (child resistant containers),  labeling,  and use
cautions are used.

    o  Intentional poisoning of domestic  animals

    Since the RPAR notice, additional data on morbidity  and mortality have  been
analyzed.  Data on poisonings, hospitalizations,  and fatalities were obtained
from four sources: 1) rodenticide poisonings and inquiries  for the years  1974-
1976 from the National Clearinghouse  for  Poison  Control  Centers, Food and Drug
Administration, 2) hospital!zation figures from  "National Hospitalization Study
of Acute Pesticide Poisoning, Admitted to General Care Hospitals", 1976,
3) mortality data based on episodes reported to  the  Pesticide Episode Reporting
System (PERS) for the years  1967-1976, and 4) pesticide  poisoning  reports by
Wayland Hayes, MD, PhD, Vanderbilt University School of  Medicine (1956,  1961,
1969, 1973-74).  The data for the three categories (poisonings, hospitaliza-
tions, fatalities) were thus from different  sources and  for different years.

    For the years 1974-1976, 5,610 cases  of  inquiries  and poisonings were
reported for rodenticides.  Of these, 26  were confirmed  as  being strychnine
related.  Since many cases do not specify the rodenticide,  26 is the lower
bound on the number of strychnine poisonings.  Fifteen of the 26 involved
children under five years of age.

    Hospitalization figures for 1971-1973, based on a  12 percent sample of
general-care hospitals in the United  States,  were classified as being occu-
pational, non-occupational,or intentional.   Estimated  numbers were obtained by
multiplying each observation by eight to  approximate hospitalization figures
for all general-care hospitals.  The  estimated hospitalizations for uninten-
tional, non-occupational strychnine poisonings ranged  from  16 to 48 and totaled
88 for the three years.  Twenty-seven percent of the cases  involved children
under five years of age (3 of 11).

    Sixty four reports were located in the PERS  files  that  involved strychnine
(out of over 10,000 entries).  Twenty eight  reports involved humans, 28
involved domestic animals, five involved  wildlife, and three were  for environ-
mental contamination.

    Thirty people were affected in the 28 reports involving humans.  Ten  of the
people died from strychnine poisoning.

    Nineteen of the 28 reports were for incidents occurring in the home and all
involved children age 15 or younger.  Five of the 19 episodes resulted  from the
ingestion of strychnine baits placed  in the  home for rodent control. Two  of the
                                    -  35 -

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five resulted in fatalities.  The other eight fatalities were one agricultural
worker, two 15-year-olds who ingested LSD cut with strychnine (not a
pesticide), three suicides, and two preachers who ingested strychnine as  part
of the religious service.

    The Hayes studies reported a total of 21 deaths due to strychnine for the
years 1956, 1961, 1969, 1973 and 1974.  Four were children five years old or
younger.  Three of the 21 were also reported in the PERS data, leaving  a  total
of 28 deaths reported in the two sources.  Tnese are not the total deaths due
to strychnine, but rather those deaths that were documented for specific  years.

    Domestic use also includes areas where pets may be in contact with  a
pesticide (40 CFR 162.3 (m)).  As stated earlier, the PERS data contained
reports of 28 domestic animal poisoning incidents.  Twenty-six incidents  were
home related and all involved dogs (one also involved cats).  Twenty-three of
the incidents were fatalities (86 dogs and 5 cats).  Tne majority of the
poisonings resulted from undetermined sources (14 reports) or intentional
poisonings (10 reports).  Two resulted from ingesting rodent control baits
(two dogs).

    In summary, the availability of strychnine for domestic use has resulted in
human and pet poisonings and fatalities.  For the years 1974-1976, 26 cases of
strychnine poisonings and inquiries were reported.  Fifteen involved children
five years old or younger.  For the years 1971-1973, an estimated 88 hospitali-
zations occurred for unintentional, non-occupational strychnine poisonings.
Twenty-seven percent involved children five years old or younger.  For  the
years 1956 through 1976, 28 deaths were reported.  Six of the 28 were children
five years old or younger.

    Although emergency treatment is available and possible, as concluded  in
PD 1, it must begin within 30 minutes of ingestion.  The case histories
examined for PD 1 did not include any fatalities.  The data reviewed since then
indicates a risk to humans, particularly to children.  Most of the hospitaliza-
tions and fatalities, however, involved strychnine use that was unrelated to
rodent control, (e.g. suicide) or a misuse of the rodenticide.  Also, as
stated in Section I, strychnine products with concentrations greater than
0.5 percent are now restricted for use only by certified operators.  The  Agency
is of the opinion, therefore, that the human risk from the registered uses of
strychnine that are the subject of this RPAR are not sufficient to warrant the
consideration of regulatory actions.

                          B.  Alternatives - Mammals

1.  Sodium Fluoroacetate (Compound 1080)

    A rebuttable presumption against registration was issued by the Agency for
compound 1080 in December, 1976.  Its use as a strychnine alternative will
depend on the result of the RPAR review currently underway.  The following
discussion in no way implies its continued availability.
                                    - 36  -

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    a.   Method of Application

         1)   Ground Squirrel

              Sodium fluoroacetate (compound 1080) is registered in California,
Nevada, and Colorado used for ground squirrel control as a spot bait on bare
ground near burrows.  It is also ground applied by mechanical broadcaster or
aerially applied in approximately 30-foot-wide swaths.  The baits are usually
made with oat groats, barley, chopped cabbage, or chopped dandelion greens.
The concentration of compound 1080 in the various baits ranges from 0.05
percent to 0.12 percent.  When hand applied it is most often accomplished by
scattering a teaspoon to a tablespoonful over two to three square feet of bare
ground near each active burrow.  When applied by air or broadcast, about five-
six or five-ten pounds per swath acre are used.  Treatments are usually in the
late spring.

         2)   Prairie Dog

              A single state registration for prairie dog control (Colorado)
was found for an 0.11 percent grain bait with yellow dye.  According to the
product use directions, the bait is to be scattered over three square feet
near burrows, but the amount per bait placement was not stated.

    b.   General

         1)   Toxicology

              Compound 1080 is essentially colorless, odorless, and nearly
tasteless (Atzert, 1971).  The onset of signs and symptoms of poisoning
generally occur after a delay period which would allow ingestion of a complete
meal containing the toxicant before effects commenced.  Regurgitation is not
commonly induced by compound 1080.  For these reasons bait acceptance is
usually excellent.

              Because the LD^Q'S by intravenous and oral routes are usually
similiar, it can be inferred chat compound 1080 is well absorbed from the
gastrointestinal tract.  Gal, et al. (1961) determined by radioisotope tracer
technique upon rats that intraperitoneally administered compound 1080 was
rather evenly distributed in the animal four hours post administration.  Little
had been expired as   CCL or excreted in the urine.  It is generally
thought that compound 1050 is not changed in the body to any great extent and
is largely eliminated in the urine intact.

              Signs and symptoms of compound 1080 poisoning vary.  However,
they may be classified into three categories:  CNS (central nervous system),
cardiac, and depression syndromes.  The CNS syndrome is characterized by
hyperactivity, phonation, tonic spasms and convulsions which lead to respir-
atory paralysis.  The cardiac syndrome is associated with blanching of the
retina, muscular weakness, clonic convulsions, and ventricular fibrillation.
The depression syndrome is associated with decreased activity, respiratory
                                    - 37  -

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 depression,  and  bradycardia.   Additionally,  muscarinic  effects  are  produced in
 certain  species  of terrestrial  wildlife  such as  ferrets.   The onset of symptoms
 of  poisoning almost always exceeds  1/4 hour  and  death most often occurs between
 one hour and one day  after ingestion  of  a  lethal dosage.   Long  latent periods
 preceding symptoms are common.

               The development of pathologies is  frequent,  even  after single
 dosages.   Definite histologic abnormalities  in the myocardium have  been
 reported (Chenoweth,  1950).  Heraorrhagic changes in  the liver,  heart, aorta,
 and brain are  sometimes evident.  Gastrointestinal purpura and  petechial
 pulmonary hemmorrhages particularly occur  in poisoned mammals.

               Biochemically, compound 1080 is thought to exert  its  toxic effect
 by  inhibition  or blocking of citrate  and succinate metabolism within the Kreb's
 cycle  (Atzert,  1971).

          2)    Acute Toxicity

               a)   Laboratory Data

                   Table III-2  gives  a summary of acute oral  toxicity figures
 of  compound  1080 for numerous species of mammals, amphibians, and birds.   The
 median lethal  single oral dosages (mg 1080 per kg. animal  wgt.)  range from a
 very low  figure  of 0.056 mg/kg  for nutria  to 60  mg/kg for  the opossum.   Even
 though a  1000-fold range in susceptibility exists between  species,  all  species
 listed are very  sensitive to the toxic action of compound  1080.   Relatively few
 pesticidal chemicals in use are more  orally  toxic than  compound  1080.

                   Generally, mammals are most sensitive,  notably nutria,
 prairie dog, kit  fox, other members of the dog and cat  families, and  the  big
 brown bat.   Over  a third of the species  listed in the table exhibit LDcg's
 below one mg/kg.   This compound, like strychnine, is not readily absorbed
 through intact skin.  Inhalation contact for wildlife is not likely (Pattison,
 1959).

              b)   Field Studies

                   Under an Environmental Protection Agency (EPA) Interagency
 Agreement, the U.S. Fish and Wildlife Service, Denver Wildlife Research  Center
 (DWRC) evaluated  the hazards to wildlife associated with aerial  1080  baiting
 for  California ground squirrels.  The study was conducted in Tulare County, in
 south-central California,  in the eastern foothills of the San Joaquin Valley.
 The  study monitored a large-scale operational baiting program conducted by the
 Tulare County Agricultural Commissioner.

                   During  early June  1977,  (in the vicinity of the study  area)
about 25,000 ha (60,000 acres)  were  spot-treated with 0.075 percent 1080-
 treated oat groats at about 6.7 kg/ha (6 Ib per swath acre).  The actual
surface area baited was about  3.4 percent of the range.
                                   -  38 -

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                     TABLE  III-2  - ACUTE ORAL TOXICITY OF COMPOUND 1080i/
SPECIES

I.   MAMMALS
                                       LD50
                                       mg/kgf/
               REFERENCES!/
     A.  RODENTS
          Wood rat
          Calif. Ground squirrel
          Tuza pocket gopher
          Northern pocket gopher
          Fresno kangaroo rati/
          Polynesian rat
          Black rat
          Norway rat
          White rat (male)
          White rat (female)
          Cotton rat
          Rice rat
          House mouse
          White mice
          Meadow mouse
          Meadow vole
          Deer moused/
          Plains prairie dog
          Plains prairie dog-i/
          Black-tailed prairie dog
          Nutria

          DOMESTIC MAMMALS
                                       1.5            Chenoweth
                                       0.35           DWRC Files
                                       0.25  (60%)     Howard and Marsh
                                       0.33           DWRC Files
                                       1.0  (100%)     DWRC Files
                                       6.60           DWRC Files
                                       0.10           Chenoweth
                                       0.22-3.0       Chenoweth
                                       2.1            DWRC Files
                                       2.2            DWRC Files
                                       0.1            Chenoweth
                                       3.4            DWRC Files
                                       8.0            Chenoweth
                                      12.0            Chenoweth
                                       0.5            Chenoweth
                                       0.92           Atzert
                                       4.0-5          Howard and Marsh; Chenoweth
                                       0.3  (100%)     Howard and Marsh
                                       0.9  (100%)     Howard and Marsh
                                       0.33           DWRC Files
                                       0.056          Atzert
          Hereford cows
          Hereford calves and steer
          Mules  (M & F)
                 (M & F)
Horse
                     F)
Swine (M
Sheep
Dog, mixed breeds-*^

OTHER MAMMALS

Man (children only)
Rhesus Monkey
Mule deer (Male)
Domestic ferrets (Male)
Big brown bat
0.393          Robinson
0.221          Robinson
0.22-0.44      Tucker and Crabtree
0.35-0.55      Tucker and Crabtree
1.0            Chenoweth
0.25-0.50      Atzert
0.06           DWRC Files
                                                 2.0 est.       Howard and Marsh
                                                 4.0            Chenoweth
                                                 0.30-1.00      Tucker and Crabtree
                                                 1.41           Tucker and Crabtree
                                                 0.15           DWRC Files
I/ Oral Toxicity by gavage unless otherwise indicated.
2/ If % mortality other than 50%, this appears in parentheses after the mg/kg figure.
3/ DWRC indicates Denver Wildlife Research Center.
4/ Voluntary Feeding
5_/ Intravenous

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              TABLE III-2 - ACUTE ORAL TOXICITY OF COMPOUND 1080  (Continued)!/
SPECIES
          Commercial mink
          Desert kit fox
          Black-tailed jack rabbit
          Opossum
          Black Bear
          Bobcati/
II.  AMPHIBIANS

          Bull frog (Male)

III. BIRDS

     A.   RAPTORS
          Golden eagle
          American rough-legged hawk!./
          Marsh hawk!/
          Great horned owl!/
          Turkey vulture
          Black vulture
54.4
 1.25-5.0
10.0
10.0
10.0
20.0 (71%)
15.0
                REFERENCE!/

                DWRC Files
                DWRC Files
                DWRC Files
                Atzert
                Atzert
                Atzert
Tucker and Crabtree
Tucker and Crabtree
Howard and Marsh
Howard and Marsh
Howard and Marsh
Howard and Marsh
Howard and Marsh
A/ Oral Toxicity by gavage unless otherwise indicated.
"L' If % mortality other than 50%, this appears in parentheses after the mg/kg  figure.
I/ DWRC indicates Denver Wildlife Research Center
!/ Voluntary Feeding
^/ Intravenous
£/ Intraperitoneal

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              TABLE  III-2  -  ACUTE ORAL TOXICITY OF COMPOUND 1080  (Continued)!/
SPECIES
 mg/kg
REFERENCE!/
     B.   GAME BIRDS

          Gambel's quail  (young)—/
          Pigeon
          Mourning dove
          Ring-necked pheasant  (Male)
          California quail  (Female)
          Chukar partridge  (M & F)
          Coturnix (Male)
          Merriam's turkey  (Female)

     C.   PASSERINES

          Brewer's blackbird!/

          English sparrow
          Magpie

     D.   WILD WATERFOWL

          Mallard (Male)
          Mallard (Female)
          Pintail (Male)
          Pintail (Female)
          Widgeon (Male)
          White-fronted goose

     E.   DOMESTIC BIRDS
10.
 4.24
 8.55-14.6
 6.46
 4.63
 3.51
17.7
 4.0
 2.0-3.0
  (33%)
 3.00
 0.6-1.3
 9.11
15.0
10.0
 8.0
 3.0
 5.90
Chenoweth
Tucker and
Tucker and
Tucker and
Tucker, et
Tucker and
Tucker and
Tucker and
    Crabtree
    Crabtree
    Crabtree
    al.
    Crabtree
    Crabtree
    Crabtree
Howard and Marsh

Tucker and Crabtree
Atzert
Tucker
Howard
Howard
Howard
Howard
Tucker
and Crabtree
and Marsh
and Marsh
and Marsh
and Marsh
and Crabtree
          White leghorn chicken
          Rhode Island red chicken
          Pigeon - Florida
          Pigeon - Colorado!/
 7.5
 5.0
10.0 (42%)
 2.0-3.0
Chenoweth
Chenoweth
Howard and Marsh
Howard and Marsh
.i/ Oral Toxicity by gavage unless otherwise  indicated.
2/ If % mortality other than 50%, this appears  in parentheses after  the mg/kg  figure.
.?_/ DWRC indicates Denver Wildlife Research Center
A/ Voluntary Feeding

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                   California ground squirrel populations were reduced about 85
percent following baiting.  Primary hazards to seed-eating birds appeared
minimal as indicated from intensive carcass searching and the results from 31
radio-equipped mourning doves and ten radio-equipped California quail.  One of
two white-breasted nuthatches found dead after treatment contained compound
1080 residue.  One of two samples of dead ants also contained compound 1080
residue.  Twelve cottontail rabbits were found dead after treatment and four
contained 1080 residue, indicating some primary hazard to this species.

                   Secondary hazards to raptors and mammalian predators were
evaluated by attaching radio transmitters to 24 raptors (red-tailed hawks,
turkey vultures, a golden eagle, great horned owls, barn owls, a screech owl,
common ravens, a common crow), and 42 mammalian predators (bobcats, coyotes,
gray fox, badgers, striped skunks, raccoons, and opossum) and monitoring their
movements before, during, and after treatment.  Five of the six radio-equipped
coyotes and three of the ten radio-equipped bobcats (one bobcat was emaciated,
possibly the  result of a trap injury) were found dead after treatment.  Three
dead striped skunks (not radio-equipped) were also found dead after treatment
and one contained compound 1080 residue.  No other treatment-related
mortalities were indicated among the remaining radio-equipped birds or
mammals.  Also, monitoring of 58 active raptor nests indicated no treatment-
related mortalities.

         3)   Subacute and Chronic Toxicity

              While it was determined that the single oral LDj-Q of compound
1080 for mallards was 9.11 mg/kg, repeated oral dosages of just 0.5 mg/kg/day
for 30 days produced mortality in the same mallard stock. Relative to a number
of other pesticides, this indicates a moderate to high degree of cumulati/
toxic action for this species (Tucker and Crabtree, 1970).

              Repeated sublethal doses of compound 1080 have increased the
tolerance of some species to subsequent challenging doses.  This increase in
tolerance is most often slight, however.  In other species, such as in the
mallard, cumulative intoxication occurs.  Accumulation and tolerance for
compound 1080 are time-related phenomena such that short-interval treatments
(less than 30-hr- spacing) are more likely to accumulate.  Longer interval
treatments (three or more days apart) are more likely not to have cumulative
effects.  Reports concerning effects of long-term feeding upon low levels of
compound 1080 were not found.

         4)   Bioaccumulation and Tissue Residues

              As previously stated, the distribution of compound 1080 in animal
tissues after ingestion is widespread and somewhat evenly concentrated in most
soft tissues of the body.  Residue chemists often use the whole carcass, or
stomach and intestinal tract, as the sample for analyses in suspected compound
1080 poisoning cases.  Massive concentrations can be found in the gastroin-
testinal tract, but residues are not frequently found in higher than LDcQ
amounts in absorbed form.
                                    - 42  -

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               Thus,  tissue  residues  in  compound 1080-killed  animals  may not
exceed  the LA-n amount  and  in  many cases  may be somewhat  lower than  the
LD(-Q while gastrointestinal contents may  sometimes  be much higher.

               Rats fed  5.8  mg/kg  were killed after  five hours and tissues
analyzed.  Heart, brain, kidney,  skin plus  hair,  and  whole carcass contained
five ppm  (Rudd and Genelly,  1956). In summary,  compound 1080 does not  tend to
accumulate to  any great degree.   Death  of the animal  normally prevents  great
residue buildup in any  tissue  or  organ  system except  the  gastrointestinal tract,

          5)    Secondary Toxicity

               Several laboratory  studies  lead to the  conclusion that secondary
poisoning of animals (poisoning of animals  which eat  a species directly
exposed)  can readily occur  with compound  1080.   Chemical  stability of  compound
1080 would favor the possibility  of  secondary poisoning.

               Tucker (1965-72) offered  domestic ferrets the  intact bodies of
albino rats which had been  stomach-tubed  with compound 1080  two hours
previously.  As the  ferrets ate their respective rats over several days,  the
stated amounts (expressed as mg of compound 1080 per  kg of ferret) were not
ingested  at once nor completely and  represented much  higher  than the actual
dosage to the  ferrets.  Even so,  ferrets  eating rats  containing dosages of 2.0
mg/kg or  less  exhibited strong symptoms while 8.0 mg/kg and  above on this basis
was fatal to ferrets.

               A similar experiment by Tucker with Peromyscus sp.  and ferrets
produced death in ferrets if the mice eaten had been  stomach-tubed to contain
one mg 1080/kg or more  for  the ferret.  The acute oral LD5Q  of 1080  stomach-
tubed in aqueous solution directly to ferrets was found to be  1.41 mg/kg.   If
fed in ground  beef,  the LD^Q was  between  one and  two  mg/kg.   It was
concluded that a ferret which  receives  two  mg/kg  whether  by  direct ingestion or
by feeding upon a prey  species is very  likely to  succumb  and that levels  as low
as 0.5 mg/kg can produce severe symptoms  lasting  up to a  week.   From this,  it
was considered likely that  a 650-gram ferret  ingesting 1.3 mg  (2 mg/kg) of 1080
could die.  This would  mean  that  if  a little  as 1.0 gram  of  a  2 oz/100  Ib.
(0.125 percent) bait were ingested directly by  a  ferret it would likely be
lethal.  If compound 1080-poisoned prairie  dogs were  fed  upon  by black-footed
ferrets a similar hazard could exist.   The  domestic ferrets  in  these studies
ate all parts of the mice completely and  variable parts of the  rats, including
the gastrointestinal tract.  Some left only portions of the  pelt.

              In an experiment by Rudd and  Genelly (1956), a dog was killed by
eating the heart tissue of a horse five hours after the horse had eaten
4.41 mg/kg of compound  1080.
                                   -  43 -

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         6)   Human Risks

              The RPAR notice against compound 1080 was based on  three
criteria, one of them being the lack of emergency treatment for human poison-
ing.  Since the RPAR review has not been completed on this chemical, the
treatment question cannot be addressed here.  The data on potential risks,
however, will be presented.

              The USDI reported 22 human poisonings with compound 1080  for  the
period 1946-1949.  This period was the first 4 years of compound  1080 use as  a
rodenticide, and before use was restricted and controlled.  Of these 22 cases,
four were reported as suicides and 16 were accidents involving children.  Two
were accidental adult poisonings.  Eleven of the 16 children died.  One of  the
two adults died.

              More recently, reports of three cases of human poisonings have
been published.  Two (1970 and 1975) were accidents involving children.  Both
survived.  One child was reported to have suffered neurological damage.  A
third accident involved an adult, said to be a suicide.  EPA's Registration
files contain a report of the accidential fatal poisoning of a man, who
ingested 436 rag (estimated) of compound 1080 from a bottle left by a licensed
pest control operator.

              Another case (1968) was reported in the rebuttal from the
California Department of Food and Agriculture (30000/7:#82) and involved a
child, who recovered following hospitalization.

              Eighteen accidental cases and four cases alleged to have  been
suicides were reported for the four years ending with 1949.  For  the period
1950-1976, nine poisonings were reported.  For these 26 years, the average  was
approximately one poisoning every 21/2 years.

              The completeness of accident reports can always be  questioned but
it appears that there have been few human poisonings by these compounds since
restrictions and controls were placed on compound 1080.  The greatest hazard  is
still in and around the home.

              The EPA's PERS reports, for the period 1972- May 1976, include  94
to 104 (the number in one group was estimated as 40 to 50) poisoning deaths of
domestic pets associated with compound 1080.  These include 69-70 confirmed
compound 1080 pet poisonings.  Forty-four to fifty-five were considered the
results of deliberate vandalism using compound 1080.  Four were identified  as
occurring in locations near industrial sites where compound 1080 was used.
Five were near a home where mice had been poisoned with compound  1080 by a  pest
control operator.  This last group of poisonings occurred in 1975.
                                    - 44  -

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2.   Zinc Phosphide

     a.   Method  of  Application

         1)   Ground  Squirrel

              Oat groat,  rolled  oat,  cabbage  or  dandelion  baits  are  used  for
zinc phosphide.  The  concentration of the active ingredient  in the bait varies
from 0.5 percent to 2.0 percent.  Baiting is  accomplished  by scattering a
tablespoon of bait  over two  to three  square feet at  the  side of  a burrow  on
bare ground or around rock or  log piles  used  by  ground squirrels.  Such bait
may  be broadcast by ground equipment  or  by airplane  at about six pounds per
swath acre.  Zinc phosphide  is registered in  California  and  Nevada for this use.

         2)   Prairie Dog

              A  2.0 percent  steam-rolled oat  bait is placed  in a heaping
teaspoon (4 gm)  amount on open ground near a  burrow.  Formerly,  heaping .
tablespoon amounts  (14 gm) per bait placement were recommended.  Usually  the
rate works out to about 0.35 pounds of bait per  acre.  Ihe label recommend
baiting in late  summer or fall.  Zinc phosphide  is federally registered for
this use.

     b.   General

         1)   Toxicology

              Zinc  phosphide is  a heavy, finely  ground gray-black powder  that
is practically insoluble  in  water and  alcohol.   When exposed  to  moisture,  it
decomposes slowly and releases phosphine gas.  Phosphine, which  is highly
flammable, may be generated  rapidly if the material  comes in  contact with
dilute acids.  Zinc phosphide  concentrate is  a stable material when kept  dry
and hermetically sealed.

              When  zinc phosphide comes  into  contact with dilute acids in the
stomach, phosphine  (PRO  is  released  and it is this  substance which probably
causes death.  Animals that  ingest lethal amounts  of bait usually succumb
overnight with terminal symptoms of convulsions,  paralysis, and  coma. Death
usually results  from  asphyxia.   If death does not  occur  for  several days,
intoxication occurs similar  to that observed with  yellow phosphorous in which
the liver is heavily  damaged.  The surface of the  liver  is spotted and dis-
colored.  Prolonged exposure to phosphine can produce chronic phosphorous
poisoning.   To this extent,  zinc phosphide may possess some characteristics of
accumulative toxic materials.

              Early symptoms of zinc phosphide poisoning are:  nausea, vomiting
(yielding black stomach contents and smell of phosphine), abdominal pain,  chest
tightness,  excitement, and a feeling of  coldness.  In fatal cases, there  is
liver,  kidney and heart damage.  The time between  ingestion and  death is  fre-
quently about 30 hours.  Victims who are alive three days after  exposure  are
                                    - 45  -

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said to recover completely.  Mild poisoning from breathing minute amounts  of
phosphine gas can be mistaken for food poisoning because of the diarrhea and
stomach pains produced.

              Zinc phosphide baits have a strong, pungent, phosphorous-like
odor (garlic-like), this characteristic seems to attract rodents, particularly
rats, but apparently makes the bait unattractive to some other animals.

         2)   Residue

              In soil, zinc phosphide breaks down rapidly to phosphine which is
either released into the atmosphere or converted to phosphates which remain as
a residue and zinc complexes.

              There is only a small amount of deterioration of zinc phosphide
on baits due to the evolution of phosphine gas; therefore, dry baits must  be
considered to be toxic indefinitely and must be used accordingly.  Lecithin-
mineral oil, added to zinc phosphide to adhere it to grain bait, offers pro-
tection aginst moisture, and therefore, may increase its stability.  Under
field conditions, zinc phosphide baits may remain toxic for several months
until eroded by weathering or decomposition of the carrier or the grain is
removed by insects.  Physical erosion does not seem to occur rapidly.  In  one
instance zinc phosphide-treated bait, exposed in the field for two to three
months and ten to twelve inches of rain, continued to maintain some toxicity.

              Residues of zinc phosphide in treated baits collected from the
ground were at 1/3 of pre-treated amounts by one day post-treatment but did not
further decline for 21 days.  About ten percent of the original residue was
found 200 days post-treatment (Hegdal and Gatz, 1977).

         3)   Acute Toxicity

              a)   Laboratory Data

                   A 2.5 percent zinc phosphide wheat bait single oral ID™
for ring-necked pheasants was determined to be 1067 mg/kg.  This value is
equivalent to 26.7 mg/kg actual zinc phosphide.  For the gray partridge
(Perdix perdix), the LD™ was 16.0 mg/kg for zinc phosphide.  On this basis
18 to 25 poisoned wheat kernels would be lethal to some pheasants and six  to
nine kernels would be lethal to some partridges.  Neither zinc phosphide nor
the red color on the bait prevented the birds from consuming the grains.   More
than 80 percent of the bait strength remained after 3-27 days exposure to
weather including multiple rains (Janda and Bosseova, 1970).  There is evidence
that black dye on bait exerts some repellency to bobwhite quail (Hines and
Dimmick, 1970).

                   The oral LD™ of zinc phosphide to a wide array of avian
species lies in the 10 to 30 mg/kg range.  Among the more sensitive are geese
(7.5 - 8.8 mg/kg), pheasants (8.8 - 26.7 mg/kg) and California quail (13.5
mg/kg) (Tucker and Crabtree, 1970).  A 5-day dietary LC,-n for mallard
ducklings was reported to be 1285 ppm (Hill, et al. 19757.  Ungulate and
                                    - 46  -

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carnivorous mammal  LDcn  values  are  40-50 mg/kg.   Most  rodents are in the  15-
40 mg/kg  range  with exceptions  (nutria,  5.6;  northern  pocket  gopher,  6.8;
kangaroo  rats,  8.0  mg/kg).   The jackrabbit  LD5Q  is 8.2 mg/kg  (Hood,  1972).

              b)    Field Studies

                    A field  study (Collins,  1966) used  8-14 pounds of two
percent zinc phosphide with oat groats (not cracked corn)  aerially applied  to
96 miles  of ditches and  canals  for  rat control,  researchers found seven dead
and 71 live pheasants along the route.  Other dead nontarget  animals included
two mallards, two bitterns, and one rabbit.  Whether zinc  phosphide  was the
cause of  the deaths was  not determined by residue analysis.

                    The degree of persistence of  the toxicity  of two  percent
cracked corn zinc phosphide baits is shown  by data of  Hayne (1951).   When such
baits are allowed to weather outdoors, the  laboratory  mouse LDc-Q from dosing
with these baits increased  from 2.8 mg/kg as zinc phosphide on day zero to  4.4
mg/kg in  4-6 days,  to 14.6  mg/kg in 27 days (USDI,  May,  1974).

                    In a  nontarget wildlife  safety study done  under field
conditions (Hegdal  and Gatz, 1977),  some mortality among rabbits and  pheasants
resulted  from orchard mouse control  on several square  miles of orchards with
zinc phosphide.  Chemical residue analyses  established zinc phosphide poisoning
as the cause of the mortality.   One  blue jay was also  killed  by zinc
phosphide.  Otherwise, raptors,  predatory mammals,  passerines,  gallinaceous
birds, waterfowl, and avian scavengers suffered  no  observed mortality.
Radiotelemetry  tracking  of  nontarget wildlife provided a useful tool  in
monitoring the  effects.

          4)   Secondary  Toxicity

              Golden eagles, great  horned owls,  and coyotes receiving multiple
feedings  of zinc phosphide-poisoned  jackrabbits  showed no  signs of secondary
intoxication (Evans,  1970).

              Bell  and Dimmick  (1975)  briefly describe several  secondary hazard
tests with zinc phosphide involving  the  feeding  of  prairie  voles  to red foxes.
Two individuals were  fed voles  which were dead or dying  from  zinc phosphide
treatment at 5.3 times the  LD5Q  for  the  voles (a total of  86.94 mg/kg).  The
red foxes consumed  11.5  voles each  in  3  days  or  10.64  mg/kg zinc phosphide  (if
the toxicant had been unaltered)  and survived though exhibiting briefly altered
behavior.  The  study concluded  that  "little  hazard...may"  exist from  secondary
poisoning.

              Zinc  phosphide failed  to be lethal in a  study in  which  secondary
toxicity of compound  1080 and strychnine  was  shown  for kit  foxes  ingesting
poisoned kangaroo rats.   These foxes survived repeated feedings of kangaroo
rats each killed by 480  rag of zinc phosphide.  This  is equivalent  to  3  times
the LDgQ for a kit  fox and 29 times  the  amount one  kangaroo rat might consume
in fieia-applied baits (Schitoskey,  1975).  The  direct dose LDc0  of zinc
phosphide for the kit fox was 93 mg/kg.
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              Collectively, the literature on secondary poisoning for zinc
phosphide shows the low probability of secondary hazard to predatory wildlife
which consume target rodents (USDI, April, 1976).  Some risk to predators  may
be associated with the consumption of bait stored in the cheek pouches of
certain rodents.

         5)   Human Risks

              No reports of dermal toxicity determinations were found.
Although the pesticide is toxic when inhaled, no LD5Q figures are available.
The Agency has no data on skin or eye irritation, but workers are required to
wear gloves when prepairing or handling baits to prevent skin contact.


3.  Anticoagulants

    a.   Methods of Application

         CPN (Chlorophacinone) ground squirrel grain baits (usually oat
groats or chopped cabbage or dandelion greens) range from 0.005 percent to
0.01 percent CPN.  Typically, about one to five pounds of bait are placed  in
a bait box or hopper bait station intended to exclude wildlife larger than the
squirrel.  Bait is replenished every few days to give 1-to-4 week repeated
exposure to the squirrels.  Some labels call for broadcasting a handful of bait
every other day, three times over a 40-50 square foot area near each burrow or
runway.

         The methods and rates of DPN (Diphacinone) application are nearly
identical to those for CPN given above.  Residue persistence data for CPN and
DPN were not found.

         The other anticoagulants, Pival, Fumarin, Warfarin, PMP, and
Talon, are applied in a nearly identical manner as CPN, but the concentration
of the active ingredient is approximately five times greater than for CPN.

    b.   Toxicity

         1)   CPN

              Chlorophacinone (CPN) causes death from internal bleeding by
hindering blood clotting and increasing capillary permeability.

              A great degree of species selectivity occurs with CPN.
Rodents such as pine voles and deer mice have single oral LDc-n values of 3.58
mg/kg and 0.49 mg/kg, respectively.  On.the other hand, the LD,-0  values for
red-winged blackbirds, mallards, and ring-necked pheasants are 430, greater
than 100, and greater than 100 mg/kg, respectively (Giban, 1969).

              In 1969, Giban conduted an experiment to measure the toxic
effects of CPN 0.0075 percent baits on the gray partridge during a 15-day
exposure.  A daily oral dose of 2.25 mg CPN per bird was calculated to be the
                                    - 48  -

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equivalent of  free-feeding  on 0.0075 percent  baits.   All  10 partridges  survived
 15 consecutive daily  doses  of 2.25 mg.   None  of 10 survived this level  for 30
daily doses.   Seven of  10 survived  15 daily doses of 4.5  rag/bird (Giban,  1969).

          2)    DPN

               Diphacinone (DPN),  as  with CPN,  causes death  from  internal
bleeding  by hindering blood clotting and increasing  capillary  permiability.
With the  amounts of DPN used  in baits,  rodents must  ingest  several  bait
applications in order to receive  a lethal  dose.  DPN is also used in human
medicine  as an anticoagulant.

               The acute oral  LD^o in rats  of  the technical  material is
2.31 mg/kg.  An acute dermal  LD5Q was not  found in the literature.  It  was
reported  that  three or  four rabBits  were killed in a dermal toxicity test  in
which a 200 mg/kg dose  was  used.

               The Velsicol  Chemical  Corporation-(1976) reported  the average
5-day dietary  LC™ of DPN (technical) to be 4485 ppm for  14-day-old bobwhite
quail.  Concentrations  of 1000 and 2150  ppm produced 10 and 20 percent
mortality.  A  similar study with  14-day-old mallards found  an LC,-Q  of greater
than 10,000 ppm, although 20 percent mortality and reduced  food  cons.ir.ption
occurred  at this level.  (Velsicol Chemical Corporation,  1976).

               Truslow Farms,  Inc. (1976) reported on an eight week  secondary
toxicity  study with sparrow hawks (Falco sparverius)  in which 0.005 percent DPN
baits were fed to Swiss mice for  three to  five days.  Six wild hawks (which had
been trapped)  received  two  treated mice  each  day.  After  10 days of exposure
the hawks were fed untreated mice and held  for six weeks observation.   There
was no effect  upon the  hawks except  lack of weight gain.  The mice  were
terminally poisoned at  the  time of ingestion by the  hawks as shown  by studies
on identically treated  mice not fed  to the  hawks.

               Mendenhall and Pank (unpublished) demonstrated a potential
hazard to avian predators of secondary poisoning from DPN in an  experiment
using three species of owls.  Two DPN poisoned mice  were fed twice  daily to the
owls for  five  days.   The mice had consumed  a lethal  dose of 0.01 percent DPN
bait over a 10-day period.  Three of the four  owls in the test died 7-14 days
after the experiment  began.

         3)   Other Anticoagulants

              The effects of the other anticoagulants, Warfarin, Pival,
Fumarin,  PMP,  and Talon are  similar  to CPN and DPN in that  they  all cause death
through hemorraging.   Repeated doses are generally required to cause death.
                                    -  49  -

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    c.   Human Risks

         1)   CPN

              Human volunteers were given a 20 mg/kg dose and their
prothrombin ratings were monitored for eight days thereafter.  The rating fell
to 35 percent of normal, but it almost completely recovered by the end of the
study.  It was concluded that ingestion of 400 g of a bait containing 0.005
percent chlorophacinone would depress prothrombin activity to dangerously low
levels.

              Pesticide Incident Monitoring System (PIMS) files for the
year 1966 to June 1979 contain nine reports on CPN poisoning.  Five of the
reports involved children,  one report involved an adult, and the other three
involved animals. None of the human incidents were fatal.

         2)   DPN

              The Agency has no data on the human risks associated with the
use of DPN as a rodenticide.

         3)   Other Anti-Coagulants

              The Agency has no data on the human risks associated with the
use of Warfarin, Pival, Fumarin, PMP, or Talon as a rodenticide.

4.  Fumigants

    a.   Carbon Bisulfide

         Carbon disulfide is a highly volatile liquid which boils at
84.1°C (183.4 F). Its LD5Q (subcutaneous in rabbits) is 300 mg/kg.

         Carbon disulfide vapor is absorbed largely through the lungs,
although toxic quantities can also be absorbed through the skin. Its effects
are mostly on the nervous system; single exposures are characterized by
narcosis and its sequelae.   Human symptoms of repeated exposure are
nervousness, irritability,  indigestion, bizarre dreams leading to insomnia,
excessive fatigue,  loss of appetite, headaches,  euphoria, restlessness, mocous
membrane irritation, nausea, vomiting, unconsciousness, and terminal
convulsions.

         PIMS files for the period 1966 to August 1979 contain 21
reports of carbon disulfide exposure through inhalation .  Eleven incidents
involved carbon disulfide alone.  The other ten cited carbon disulfide in
combination with other ingredients.  Five fatalities resulted, all adults, and
all from exposure of fumigants where carbon disulfide was one of two or more
active ingredients.
                                   -  50 -

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     b.    Gas Cartridges

          Gas cartridges emit gases,  mostly carbon monoxide,  and smoke when
 ignited.   The cartridges are cardboard cylinders filled  with sulfur,  charcoal,
 red  phosphorus,  mineral oil, sodium  nitrate,  and sawdust.

          The affects  on animals  is assumed to be the same  as those on
 humans,  i.e.,  unconsciousness followed by a drop in blood  pressure, loss of
 muscular  control,  and finally a  stoppage in breathing.

     c.    Methyl  Bromide

          Methyl  bromide is  a colorless liquid that boils at  4.5°C  (40.1°F).
 It is 3-5 times  heavier than air, has  a burning  taste, and an odor resembling
 that of chloroform.   Methyl bromide  is usually packaged, under moderate
 pressure,  in metal cylinders.

          The effects  of methyl bromide are on both the respiratory and
 central nervous  systems.  The central  nervous system effects occur with  or
 follow the respiratory system effects  by several hours.  Respiratory  effects
 include coughing,  chestpains,  painful  breathing,  and broncho-pneumonia.
 Central nervous,  system effects include nausea, vomiting, blurred vision,
 convulsions,  muscle weakness,  and respiratory paralysis.

          Methyl  bromide can cause burns if allowed to saturate clothing,  or
 if splashed  in the eye.

     d.    Other Fumigants

          Calcium cyanide  is applied  as a dust for house  mouse control.   For
 woodchuck  control, it  is  applied either as a  solid or a  dust.   Death  is  caused
 by respiratory arrest,  following nausea,  unconsciousness,  convulsions, and
 paralysis.   Reactions  to  the gas occur within seconds after  inhalation,  and
 death results within minutes.

          Carbon  tetrachloride  (under RPAR review),  paradichlorobenzene,  and
 ethylene dichloride, all  contained in  one product,  are applied  as  a liquid.
 Death results from either respiratory  arrest  or  circulatory  collapse.

 5.   Repellants

     The repellants Hinder and  Thiram are  sprayed  on plants and  trees  prior to
 the  onset of damage.   No  risks to nontargets  are  anticipated  since these  are
 not  toxicants.

 6.   Relative Risks and Comparative Data

    Data for making precise  comparisions  of relative  toxicity are  not abundant;
however,  some reasonable generalizations  can  be derived from  Table III-3-  The
values for the LD^'s are from a variety  of sources and have  been  freely
                                    -  51  -

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                                                     TABLE II1-3
                                       Relative Risks of Alternative Toxicants
  LD50
       Strychnine
       (0.5% bait)
  LD50            Relative
(mg/kg)           Risk!/
    Compound 1080
    (0.075%  bait)
 LD50          Relative
(mq/kg)          Risk!/
     Zinc Phosphide
        (2.0% bait)
  LD5Q       Relative
(mq/kg       Risk!/
Quail
Pheasant
Duck
Goose
Dove
Blackbird
Sparrow
Eagle
Ground Squirrel
Prairie Dog
Jackrabbit
Cat
Dog
Kit Fox
135.0
25.0
5.0
4.0
9.0
5.0
5.0
5.0
20.0
1.5
4.4
0.75
1.1
0.75
1.0
1.9
6.7
8.4
8.2
3.3
4.0
1.7-6.6
1.0
3.0
8.4
13.0
9.1
31.0
4.0, 20.0
7.0
5.0
5.0
11.0
2.5
3.0
1.2, 5.0
0.35
0.3
5.6
0.2
0.06
0.22
5.1, 1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
8.6
2.3
1.0
7.4
25.0
16.0
13.0
18.0
36.0
8.0
34.0
24.0
-
-
33.0
18.0
8.2
40.0
40.0
93.0
42.0
10.0
3.7
17.0
8.6
2.7
-
-
2.4
1.0
18.0
1.0
1.0
1.0
I/  The least toxic bait for each animal  is  arbitrarily assigned a value of 1.0.

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rounded and averaged.  Each of the table values has been derived from one or
more species or tests as appropriate.

    Some variation between species in reported LD^Q'S is apparent.  The
source of this variation is uncertain and most reported differences have not
been considered important for the present purposes of seeking generalizations.
Substantial variation in toxic response is reported among quail for compound
1080; the LD50 for the California quail is about four mg/kg while that for
the Gambel's quail is 20 mg/kg .  With limited data, therefore, the accuracy
of the values is uncertain and the generalizations to be made cannot apply to
any similar species that may be either extremely sensitive or extremely
resistant to a particular toxicant.

    To obtain the relative risk from the consumption of bait for each
species, the LD^0 values for each toxicant were divided by the concentrations
of the toxicant in the bait formulation employed by the USDI.  This procedure
gives the relative amount of bait that is equitoxic to the species.  Assigning
an arbitrary value of 1.0 to the least toxic formulation and dividing the
relative amount of bait for the formulation by that for an alternative gives
the relative toxicity of the alternative- .  Thus, for pheasant, compound
1080 has the lowest ID™ but its dilution (0.075 percent) in the bait makes
it the least hazardous, other things being equal.  Strychnine is less toxic to
pheasants than compound 1080 but its higher concentration in bait makes the
bait about twice as toxic to pheasants.  Considering the quality of the data
and other variables, however, the observed difference between the estimates of
the two formulations cannot lead to a conclusion that substantial differences
in risk can be anticipated from use in the field.

     For zinc phosphide, different estimates of the ID™ for pheasant (9-27
mg/kg) range from near that for compound 1080 to several times as great;
however, the concentration of "zinc" in the bait gives a relative risk factor
of from 7 to 21 and averaging 10.  From this analysis, it is reasonable to
conclude that the risk to pheasants from the use of zinc phosphide is
substantially greater than that for both strychnine and compound 1080.

    Allowing for the variable quality of these data, and species variability,
Table III-3 indicates some generalizations that are relevant for a comparative
risk assessment.

    1.   For a wide variety of birds, compound 1080 bait is the least
hazardous.  For gallinaceous birds, zinc is the most hazardous but for
waterfowl, doves and blackbirds, zinc and strychnine are about equal.
 \J    Example: Dividing each ID™ for the pheasant by the concentration of
      the bait for each pesticide yields the following:  strychnine = 25/0.5 =
      50; compound 1080 = 7/0.75 = 93; zinc phosphide =  18/2 = 9.  Tne relative
      risk for each toxicant is therefore: strychnine =  93/50 =  1.9; compound
      1080 = 93/93 =  1.0; zinc phosphide = 93/9 =  10.
                                    -  53 -

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     2.    Responses among rodents and rabbits appear to be more variable and
 hence less predictable.   Zinc phosphide is the most toxic bait for the
 jackrabbit and the least for the prairie dog (black-tailed).  Compound 1080 is
 the most toxic bait for  the ground squirrel (California) and least for the
 jackrabbit.

     3.    For carnivores, the risk from zinc phosphide appears to be relatively
 low although good toxicity data are difficult to obtain because zinc phosphide
 may induce vomiting in treated animals.  The risk of secondary hazard is
 further reduced by detoxification of zinc phosphide in the stomach of poisoned
 animals.  In general,  the risk to carnivores from strychnine and compound 1080
 bait do not differ substantially.  The most common exposure of carnivores to
 grain baits is, however, indirect.  The greatest hazard'from feeding on
 strychnine-killed animals is associated with the ingestion of unabsorbed poison
 in the digestive tract.   This factor would generally make secondary hazards to
 carnivores lower for strychnine than those for compound 1080.

     4.    For raptors (including vultures) comparative data are limited to those
 on strychnine and compound 1080 for the golden eagle.   Because of the problem
 of indirect exposure to  strychnine bait in the digestive system,  it is not
 clear that a substantial difference in secondary risk  exists between strychnine
 and 1080.  While no raptor toxicity data for zinc phosphide are available,  the
 detoxification of zinc in the stomach of victims would lead to a  prediction of
 relatively low risk to raptors.  Some degree of confidence in this prediction
 is supported by the observations that (1)  compared  to  strychnine  and 1080,  the
 variability of toxic response is low (reported LDcn range over two orders  of
 magnitude  in strychnine  and 1080 and less than an order of magnitude for zinc
 phosphide) and thus more predictable,  and (2)  raptors  are capable of
 regurgitating their stomach contents (although not  reported for raptors, zinc
 phosphide  may induce regurgitation in carnivores).

     Comparative data for anticoagulants are  not extensive.   Studies using
 ducks,  quail,  and blackbirds have suggested  very low potential for risk.
 BDwever, some secondary  mortality to raptors has'occurred and recent laboratory
 studies  confirm that owls are sensitive to diphacinone poisoning  (Mendenhall
 and  Pank,  unpublished).   Additionally,  fatalities to dogs have been associated
 with the use of diphacinone to  control  orchard mice and it is apparent  that
 these compounds,  which have  long  been emphasized because  of their relative
 safety  to  humans, may  pose  significant  risks for raptors  and carnivores.

     Fumigants will  kill most  vertebrates  inhabiting  the treated burrow.  The
 occupants  may include black-footed  ferrets, burrowing  owls,  snakes and  other
 species in addition  to the  target species.  No  secondary  hazards  are
 anticipated  from  the use  of fumigants.

     The above observations on apparent  relative risk are  generally supported  by
 field observation (Hegdal and Gatz  1977,  1977a,  1979).   It  can be  concluded
 that all rodenticides pose risks of  varying degree  for  nontarget  birds  and
mammals and that the substitution of one toxicant for another may merely shift
 the risk from one set of nontarget species to another.  For  instance,
                                    - 54  -

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substituting zinc phosphide  for strychnine may substantially  reduce  risk  to
carnivores but would increase risks  to gallinaceous birds and not  substantially
alter the risks for waterfowl, doves, and passerines.   The actual  magnitude of
any effects or changes in effect can not be predicted but the direction of the
change in risks from substitute rodenticides can reasonably be anticipated.

    Variation in concentrations of the toxicants, acceptability of the bait and
other factors influencing exposure must be considered in the  assessments.   Of
substantial concern in this  regard is the persistence of toxic bait  in the
field.  Fresh baits (leaves, fruits) and pelletized baits may be expected  to
lose their attractiveness to birds and mammals rather rapidly when exposed to
the environment.  Highly persistent  poisons would thus  not be needed with  fresh
baits since acceptance would be low.  The observation that strychnine-treated
oats were still killing doves after  more than two months in the field (Hegdal
and Gatz 1977), however, is  disturbing, since little benefit  is likely to  be
derived from such persistence.

7.  Summary

    Considering use rates, treatment strategies, toxicity data, and  field
studies, the following discussion characterizes the relative  risks inherent in
the use of compound 1080 and strychnine and their alternatives for ground
squirrel control on pasture  or rangeland.

    The risk of strychnine as used in above-ground squirrel control  appears to
center upon population reduction of  small birds, such as songbirds and doves,
by direct poisoning of birds eating  the bait.  Other birds and mammals may also
be killed but available field evidence does not demonstrate that this effect is
generally substantial.

    The risk of compound 1080 appears to center upon carnivorous species such
as coyotes or bobcats by way of secondary poisoning. Other unrelated families
of wildlife, though susceptible according to toxicological studies, did not
appear to suffer significant mortality from current compound  1080  ground
squirrel control techniques  in California.

    Zinc phosphide provides  some demonstrable hazard to pheasants  and rabbits,
but little hazard to other unrelated wildlife species has been established.

    The anticoagulants do not appear to have produced any significant
nontarget wildlife kills, but do appear to be very selective  for rodent-type
mammals, and possess ample safety margins for most birds.  Some owls and
perhaps other untested species are susceptible to secondary poisoning by DPN.
Effects of CPN and DPN upon  small nontarget wild carnivorous  mammals would
need investigation prior to  conclusions of safety for such mammals.

    Fumigants pose no secondary risk to wildlife but will kill most  nontarget
occupants of treated burrows.
                                    -  55 -

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                         C.   Alternatives - Bird Control

     The  objective  in  using  strychnine  baits is to obtain a rapid reduction in a
 local pest  population.   Since,  when used properly, no other federally regis-
 tered pesticide  can normally achieve this objective for birds, there are no
 chemical alternatives to strychnine.  In managing a pest situation, however,
 there are alternatives  when rapid  population reduction is not required.
 Federally registered  pesticides that may provide alternative solutions to
 specific problems  include 14-aminopyridine (avitrol),  polyisobutylene, polybu-
 tene, mesurol, starlicide,  endrin  and  fenthion,  and for pigeons, azacosterol
 (ornitrol),  diphacinone,  and pival.

     The  compound 4-aminopyridine is  formulated in baits to function primarily
 as  a repellent.  Members of a flock  that ingest  lethal or near-lethal levels
 produce  distress calls  and  other behaviors that  frighten the remainder of the
 flock, causing it  to  disperse from the site to be protected.  Direct risks to
 non-target  species are  generally low since this  is not used as a toxicant and
 risks from  secondary  poisoning  seem  highly unlikely (Clark, 1975,  Schafer and
 Marking, 1975).

     Polyisobutylene,  polybutene, and mesurol are repellents with no
 recognizable risk  to  nontarget  species.   They are used,  respectively, on
 roosting places  on structures and  on certain small fruits.

     Starlicide is  a slow acting toxicant,  highly toxic to starlings, less toxic
 to  most  other birds,  and relatively  nontoxic to  rats.

     Eiidrin and fenthion  are  both used  in  artificial perches placed  in roosting
 areas around structures.  Birds landing  on the perches many absorb  lethal doses
 through  the  feet.  While,  in  proper use,  nontarget species are  unlikely to land
 on  these perches,  some  potential for secondary risks   may be associated with
 the  use  of endrin.  The  Agency  has prohibited  such use in the  vicinity of
 peregrine falcon aeries.

     Azacosterol  baits are used  to  inhibit  reproduction in pigeons.   No risks
 to  nontarget  species  are  recognized.

     In summary,  chemicals used  in control  strategies that do not require a
 rapid reduction  in the pest  population pose  less  of a  risk  to  nontarget species
 than  does strychnine.

                  D.  Summary of Relative  Risk by Use  Pattern

 1.  General

    The  following section presents the Agency's  conclusions regarding the
risk to nontarget wildlife from the above-ground  uses  of  strychnine  and its
alternatives.  These conclusions reflect a  judgment of the  available
information  presented above  and reasonable extrapolations.   In many  cases, it
was not possible  to conclude that substantial risks would result from the use
                                    - 56  -

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of strychnine to control specific pests on specific sites providing  that  proper
precautions were taken.  These extrapolations take into consideration  the fact
that site conditions vary substantially, that operator judgment is required,
and that label directions and formulations vary.  It has long been a policy in
the registration of pesticides to require that risks to wildlife be  reduced by
any appropriate means that would not substantially reduce the benefits of use.
Such reasonable precautions are required, independent of the RPAR process.

    Where appropriate, the precautions will be considered ur ier regulatory
options.  In other cases, data are not available for the Agency to determine
whether or not substantial risks are likely.

2.  Rangeland and Pasture Rodents

    a.   Prairie Dogs

         The use of strychnine may jeopardize the continued existence  of  the
black-footed ferret and cause population reductions in other nontarget species
that feed on the bait.  Use of the most likely alternative, zinc phosphide,
would substantially reduce the possibility of secondary hazards to ferrets and
other predators/scavengers that may feed on dead or dying prairie dogs.   Direct
risks to gallinaceous birds, such as prairie chickens and sharp-tailed grouse,
may increase substantially if zinc phosphide is used but specific information
on these species is unavailable.

    b.   Ground Squirrels-

         The use of strychnine may cause population reductions in various
species of birds that feed on the bait.  The extent to which dyeing  the bait
can reduce this risk is uncertain.  Use in the vicinity of various endangered
species (black-footed ferret, San Joaquin kit fox, California condor,  peregrine
falcon and others) may result in mortality to individuals.  If, in fact,  dyeing
the bait reduces risks to nontarget avian species, such as doves, indirect
risks to endangered species that may feed on those nontarget species would be
reduced.  Use of the most likely alternative, carbon disulfide, would  eliminate
all secondary risks to nontarget organisms associated with the use of  poisoned
baits.  Risks to any nontarget occupants of burrows (ferrets, burrowing owls,
snakes) would increase substantially over that associated with the use of
strychnine in any particular area.  Use of compound 1080 (California,  Nevada,
and Colorado) would probably increase the risk to carnivores (coyote,  bobcat)
and decrease the risk to birds in general.

    c.   Miscellaneous Rodents and Lagomorphs

         At this time, available evidence does not permit the Agency to
conclude that substantial risks to nontarget organisms would generally result
from the use of strychnine to meet sporadic needs to control local infestations
of various rangeland rodents if proper precautions are taken.  Some  nontarget
mortality would be expected and due concern for any endangered species must be
given.
                                     - 57  -

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 3.   Cropland Rodents

     a.    Prairie Dogs

          Risk  from  strychnine and  its  alternatives would be generally
 similar  to that for rangeland.

     b.    Ground Squirrels

          Risks from the  use of  strychnine  and  its  alternatives would be
 generally similar to those for  rangeland.   Fresh baits  in some situations are
 likely to be used instead of grain baits,  transferring  risk to a different
 subset of nontarget species and perhaps having a lower  potential for overall
 risks.

     c.    Miscellaneous Rodents  and Lagomorphs

          At this time, available evidence  does not permit the Agency to
 conclude that  substantial risks to nontarget organisms  would generally result
 from the use of strychnine to meet sporadic needs  to  control local  infestations
 of  various cropland rodents if  proper  precautions  are taken.  Some  nontarget
 mortality would be  expected and due concern for any endangered species must be
 given.

 4.   Nonagricultural Sites for Rodents  and  Lagomorphs

     At this time, available evidence does  not  permit  the  Agency to  conclude
 that substantial risk to nontarget organisms would generally result from the
 use  of strychnine to control rodents and lagomorphs on  nonagricultural sites
 if  proper precautions are taken.   Some nontarget mortality can be expected and
 due  concern must be given for any  endangered species.

 5.   Cropland Birds

     At the present  time, available evidence does not  permit  the Agency to
 conclude  that  the use of strychnine to control birds  in California  cropland
 (sprouting seeds, rice,  sunflowers, cherries,  grapes, feedlots)  is  likely to
 have  substantial effects on nontarget wildlife.  Some direct and indirect
 nontarget mortality is to be expected  and  due  precautions  must be taken to
 protect endangered  species.  The same assessment applies to  the use of
 strychnine to  control magpies in Nevada and Wyoming.

 6.  Nonagricultural Sites for Birds

    At the present  time, available evidence does not  permit  the Agency to
conclude that  the use of strychnine to control pigeons  and house sparrows on
nonagricultural sites is likely to have substantial effects  on nontarget
wildlife.  Some direct and indirect nontarget mortality is to  be expected and
due precautions must be taken to protect endangered species.
                                    -  58 -

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                          IV.  Benefit Analysis

                           A.    Introduction

     The Agency has evaluated the potential economic impacts of cancelling
 strychnine for outdoor above-ground use.  The conclusions are based on
 information, from a number of sources,  principally the Preliminary Benefit
 Analysis.-   In addition, rebuttal comments from registrants, users, and
 other  parties; federal and state vertebrate pest control specialists; and
 available  published data, were considered in the Agency's conclusions.

 The  Agency's analysis  focuses on two general types of pests - birds
 and  rodents (including rodent-like animals) and three broad areas
 rangeland/pasture,  cropland,  and nonagricultural sites.   Within these
 general categories, the Agency identified the major and  minor uses of
 strychnine; estimated  the quantities used; listed the registered alterna-
 tives,  including an evaluation of their efficacy and availability; and
 evaluated  the impact upon users and the agricultural sector.   The Agency
 estimated  the economic impact which could result if registrations of strychnine
 for  above-ground uses  are cancelled and users shift to alternative control
 materials  or strategies.   In addition,  the Agency evaluated the simultaneous
 cancellation of sodium monofluoroacetate (compound 1080)  on those sites  where
 compound 1080 is used  or  could be used  as a substitute for strychnine.

     The Agency faced severe  data limitations in this analysis and has had to
 use  considerable judgment in evaluating the potential economic consequences of
 cancelling  the outdoor, above-ground uses of strychnine.   The analysis often
 provides qualitative estimates or discussions of impacts  due  to the lack of
 sufficient  usage or comparative efficacy data to support  precise  quantitative
 estimates.   Although estimates in this  document are reported  as point
 estimates,  they represent rough predictions of strychnine bait distribution and
 economic impact.  The  Agency used reasonable assumptions  in its estimates to
 reflect  the  general economic  consequences of cancelling strychnine usage.

     In  general,  the economic  impacts of cancelling the outdoor, above-ground
 uses of strychnine  would  not  significantly affect  U.S. production or  prices of
 major commodities or services.   Impacts on agricultural productivity  and
 production  costs would generally be  limited to users  in western states.
 Regional or  local impacts to  users  are  indicated where no registered
alternatives  exist  or where registered  alternatives are more  costly,
 impractical,  or  ineffective.
\J    Prepared under contract by Development Planning and Research
      Associates, Manhattan, Kansas.  EPA Contract No. 68-01-4339.  1979.
      See Appendix E.

      Unless otherwise noted, the sources for this chapter will be
      Appendix E.
                                    - 59  -

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                    B.   General  Production and Use Patterns

     Approximately  90.1  percent  (449,200 pounds)  of the estimated 498,700
 pounds of strychnine baits - used  annually (average for 1977-78) are for
 control of rodent  or lagoraorphs (e.g.,  rabbits)  in western states (Table IV-1).
 Range/pasture  and  cropland usage for  rodent or lagornorph control comprise
 about  45.6 percent (227,400  pounds) and 42.1 percent,  (209,900 pounds)
 respectively,  of annual strychnine  bait usage,  An estimated 9.9 percent, or
 49,500 pounds  of strychnine  baits are used annually for bird control —
 3.6 percent (18,000 pounds of bait) in  cropland  and 6.3 percent (31,500 pounds
 of bait) in nonagricultural  sites.  The remaining 2.4  percent (11,900 pounds
 of bait) of annual strychnine bait  usage is in nonagricultural sites, primarily
 for control of commensal rodents.

          C. Analysis of Benefits of  Strychnine  Use on Rangeland/Pasture

     Strychnine is  federally  registered  for use in the  control of such
 rangeland rodents  as ground  squirrels (many species),  prairie dogs,
 cotton rats, kangaroo rats and  jackrabbits.   Federally registered alternatives
 for ground squirrels include  gas  cartridges,  carbon disulfide,  Thiram,  and
 carbon tetrachloride (under RPAR review).   Anticoagulants,  methyl bromide,  zinc
 phosphide,  and compound 1080  are  registered  in some states  for  ground squirrel
 control.   Zinc phosphide is federally registered  for the  control  of  prairie
 dogs,  cotton rats,  field and  meadow mice,  and  kangaroo rats.   For the control
 of jackrabbits,  the repellants  Thiram and  Hinder  are federally  registered and
 the anticoagulants are  state  registered  in California.  Table 1V-2 lists the
 chemical  alternatives to strychnine with their registrations  by  site  and pest.

 1.   Ground Squirrels

     In North America, there are  22 recognized  species  of  ground  squirrels.
 Some species contain as many as  14 subspecies  or  races which  are  distinguished
 not only by morphological characteristics  or distribution characters,  but by
 behavioral  differences and varying ecological  strategies as well.  These latter
 characteristics  frequently affect the efficacy of various control  methods.

     Currently,  six ground squirrel species are of sufficient  economic
 importance  to  justify regular control efforts:  Richardson's  ground
 squirrel,  California ground squirrel,  Columbian ground squirrel,  Belding's
 ground squirrel, Townsend's ground squirrel, and Uinta ground squirrel.
 Other  species which occasionally require control include the  antelope
 ground squirrel, thirteen-lined ground squirrel, round-tailed ground
 squirrel, golden-mantled ground squirrel, and rock squirrel.  Columbian,  Uinta,
 and Townsend's ground squirrels have increased in numbers during  recent  years,
 and demands for control  efforts are increasing.
2/ Outdoor above-ground usage only.
                                   -  60 -

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                                                   Table IV-1

                                Estimated Annual Above-Ground Usage  of  Strychnine
                                    Bait for Rodent and Bird  Control, 1977-78
Pest

Rodents
Birds
Total
Range/
Pasture Cropland Other Total
(Ibs) (%) (Ibs) (%) (Ibs) (%) (Ibs) (%)
227,400 45.6 209,900 42.1 11,900 2.4 449,200 90.1
18,000 3.6 31,500 6.3 49,500 9.9
227,400 45.6 227,900 45.7 43,400 8.7 498,700 100.0
SOURCE:  Development Planning and Research Associates,  1979.

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                                                                          Table  IV-2
                                             Chemical Alternatives to Strychnine for Rodent and Lagomorph Control
                                                                             Pest
Acute  Toxics

loeol/
Zinc
   phosphide
Enorin
                    Ground
                    Squirrels
                   Nv., Ca., Co.

                   Ca., Nv., Or.
Marmots/
 Wood-    Porcu-   Prairie   Jack
 chucks   pines    dogs      Rabbits
                                                            Co.

                                                            F
                                                                             Rabbits
                                                  Nv.

                                                  Ca.
                                                                                                Cotton
                                                                                                rats
Ca., Nv.

  F
                                                                                                            Nv.
                  Deer   Meadow            Mountain   House
                  Mice   Mice    Opossum   Beavers     mice
Ca.    Ca.                          F

F      F                            F
       F
Repellents

Hinde r
Thiram
Fumigants
Gas cartridges
Carbon disuifide
Methyl bromide
Calcium cyanide
Carbon tetra-
  chloriae!/ £/

Anti-coagulants

Pival
Fumarin
Diphacinone
Chlorophacinone
Warfarin
PMP
Talon
Haki
                   F
                   F
                   Ca., Nv.
                                                                                                                    2/
                                                                                                                            2/
                                                                                Ca.
                   4_/
                   Ca., Id.
                   Ca.
                                                                      Ca.
                                                                      Ca.
                                                                      Ca.
                                                                      Ca.
                                                            Fl.
                    3/     3/
                 Or.,Ca.   Jl.,0r.
                                    F
                                    F
                                    F
                                    F
                                    F
                                    F
                                    FRP
I/  RPAH Chemical
~2/  For ground squirrel and orchard mice control, most states have one or more anticoagulants
    registered under Section  24(c) of FIFRA  (special local need).
3/  State registrations for Ca., Co., Id., Mi., Nc., Ny., Oh., Or., Pa., Ut., Va., Wa.
j*/  State registration for Az., Ca., Co., Id., Mt., Nm., Nv., Or., Ut., Wa., Wy
5/  Formulated with paradichlorobenzene and ethylene dichloride
                                                                                                             F:     Federally Registered
                                                                                                             FRP:   Federal Registration Pending

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    In range and pasture lands, ground  squirrel  foraging  reduces  the  amount of
plant material available to grazing  livestock.   In addition  to  forage consumed,
ground squirrels eliminate vegetation by clearing and tramping  areas  near
burrows and runways.  Ground squirrels  will  invade cropland  and reduce yields
in alfalfa, small grains and a variety  of  fruit  and nut crops.  Losses are
particularly significant in fields bordered  by infested rangeland or  infested
woodland.  Crop losses of 10 to 30 percent are common while  some  small fields
(i.e. 10 to 50 acres) can be almost  completely destroyed.  In addition, damage
to harvest and other farm machinery, caused  when the equipment  runs into or
over burrows, can be quite substantial.

    If strychnine were cancelled for ground  squirrel control in rangeland, the
only registered alternative available in all states is fumigation with either
carbon disulfide, gas cartridges, or carbon  tetrachloride.   While these
materials can be used effectively, their usage has historically been  confined
to relatively limited areas due to labor requirements and high  costs,  ranging
from about $12 to $17 per acre compared to about $2.35 per acre for
strychnine.  Currently an estimated  233,110  acres or about 0.02 percent of the
grazing acreage in the 48 contiguous states  are  treated annually  with
strychnine for ground squirrel control  at a  cost of about $543,000.   If
strychnine were cancelled and compound  1080  were to be available  (currently
registered in three states) user control costs would increase by  about $900,000
annually.  If compound 1080 is not available, annual control costs would total
about $2.1 million, an increase of nearly $1.5 million.  Most likely  these
increased costs would be absorbed by users or publicly supported  rodent control
programs rather than passed along to consumers.  The annual  increased  rodent
control cost on individual ranch operations, while extremely variable, is
estimated to average about $320, which  represents annual production cost
increases of about 4 percent on smaller ranches  and about 0.5 percent  on larger
ones.  Expenditures for rangeland rodent control are extremely minor when com-
pared with other production costs such  as veterinary expenses and feed costs.
Also, only a minute amount of the grazing land is treated with  strychnine.
Consequently, the impact of cancelling  strychnine use on rangeland for control
of ground squirrels would be generally  limited to affected individuals but
should have no appreciable effects on livestock  markets or consumer meat
prices.

2.  Prairie Dogs

    Prairie dog numbers and density  decreased greatly between 1930 and
1973.  However, in recent years the  area occupied by prairie dogs has
increased from an estimated 1.3 million acres in 1973 to 2.1 million acres
in 1979 (Table IV-3).  Black-tailed  prairie  dogs, occurring  in
approximately 59 percent of this acreage, are the major pest species.

    Approximately 88,000 pounds of strychnine baits are used to treat  an
estimated 96,000 acres of range and  pasture  for  prairie dog  control.
Zinc phosphide, the most likely alternative  if strychnine use were
cancelled, is slightly less expensive (approximately $0.25/acre less)  than
strychnine and is about equally effective.   The  use of zinc  phosphide
                                   -  63 -

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                                           Table IV-3

                            Estimated U.S. Acreage of Range  and Pasture
                                    Infested with Prairie Dogs
State
N. Dakota
S. Dakota
Nebraska
Kansas
Oklahoma
Texas
New Mexico
Arizona
Colorado
Montana
Wyoming
Utah
Total


All
1973
8,000
60,000
15,000
36,000
15,000
77,500
248,000
2,000
417,000
132,000
178,500
68,000
1,257,000
1961
1,715,000
1968
Prairie Dogs
1979
11,000
300,000
55,500
60,000
20,000
90,000
300,000
5,000
500,000
309,500
300,000
190,000
2,141,000
1965
1,668,000
1971
Black-tailed
Prairie Dog
1979
11,000
300,000
55,500
60,000
20,000
90,000
200,000
	
100,000
232,000
200,000
•"*-•—
1,268,500


                           1,621,000          1,574,000
Source:   Development Planning and Research Associates,  1979

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 could  reduce total control costs by about $24,000 annually.   Therefore,  a
 shift  from strychnine to zinc phosphide would create slight  savings to the
 user and  would have no consumer or commodity market impacts.

 3.  Other Rodents and Lagomorphs

    Considering the number of the rodents and lagomorphs,  only a small group
 adversely affect rangeland under modern management.  In local situations some
 species of kangaroo rats,  cotton rats,  meadow mice, and jackrabbits can become
 problems  requiring control efforts.  Strychnine is federally registered  for
 control of kangaroo rats,  cotton rats,  meadow mice and jackrabbits
 (Table IV-2).   An estimated 4,500 pounds of strychnine baits are used annually
 for control of these pests (less than one percent of total strychnine usage).
 Alternatives are quite limited.   Only zinc phosphide and Thiram  are federally
 registered for control of cotton rats and meadow mice.  The  repellants are
 federally registered and anticoagulants are available in California for
 jackrabbit control.

    If strychnine were to be cancelled, losses on rangeland  would increase
 during periods of high population outbreaks,  since no toxicants are registered
 to replace strychnine in many states.  However, since the  estimated usage of
 strychnine for control of  these  pests is relatively small, impacts would most
 likely be limited to local user-level effects and would not  be expected  to
 appreciably affect livestock markets or consumer meat prices.

             D.   Analysis of Benefits of Strychnine Use on  Cropland

    An estimated 210,000 pounds  of strychnine baits are used on about 254,000
 acres  of  cropland annually to control depredation by ground  squirrels,  prairie
 dogs and  other rodents.   About 91 percent of  the bait (191,100 pounds) is used
 for ground squirrel control on about 240,000  acres; seven  percent of the bait
 (14,310 pounds)  is used  for prairie dog control on 14,310  acres;  and two
 percent of the bait (4,500 pounds)  is used for miscellaneous rodent control.
 In descending  order,  Nevada,  Montana,  California,  and Idaho  were  the largest
 users  of  strychnine bait for rodent control in cropland.

    The six species of ground  squirrels identified as economically important  in
 rangeland damage and the black-tailed prairie dog are also the rodents most
 often  involved  in damaging cropland.

 1.  Prairie Dogs

    An estimated 14,300  pounds of strychnine  baits are used  annually to
 control prairie  dogs  on  about  14,300  acres of cropland (Table  IV-4).

    If strychnine  were to  be cancelled  for prairie dog control in
 cropland,  the most  likely  federally-registered  alternative would  be gas
 cartridges.  Zinc  phosphide  is not  registered for use on cropland.Gas
 cartridges are more  expensive  than  strychnine and  would result in increased
 costs to users of about  $14  to $19  per  acre or  about  $206,300  to  $270,900
annually,  if used  on  all acres currently  treated  with strychnine.
                                   -  65 -

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                                  Table DM

            Estimated Acreages of Cropland Treated with Strychnine
                  for Prairie Dogs and Ground Squirrels, 1978
Region and State
Northern Plains:
North Dakota
South Dakota
Nebraska
Kansas
Southern Plains:
Oklahoma
Texas
Mountain :
Montana
Idaho
Wyoming
Colorado
New Mexico
Arizona
Utah
Nevada
Pacific:
Washington
Oregon
California
TOTAL
Prairie
dogs \J
1,800
0
1,460
340
0
3,125
0
3,125
9,385
0
0
2,640
0
6,445
0
300
0
0
0
0
0
14,310
Ground
squirrels 2/
23,214
742
5,500
11,692
5,280
978
0
978
142,040
72,007
33,957
6,383
6,200
1,807
0
3,353
18,333 y
73,692
4,875
25,155
43,662 _4/
239,923
J_/   Pounds of bait from Table IV-2 :  1 pound of bait per acre application
     rate (Henderson, 1979).

2/   Pounds of bait from Table IV-2 :  0.6 pounds of bait per acre application
     rate (Clark, 1975) unless noted otherwise.

3/   55,000 pounds of cabbage bait used mostly at 1-3 pounds per acre  (Rowe,
     1979).  It was assumed that 3 pounds per acre were applied.

4/   Includes 43,262 acres that were treated with grain bait at an assumed  rate
     of 0.6 Ibs/acre and 400 acres that were treated with cabbage bait applied
     by hand at the rate of 10 Ibs/acre (Sauer, 1976; O'Brien,  1978).

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     No macroeconomic  impacts  would  be  anticipated  if strychnine were
cancelled  for  prairie dog  control.   The  impact,  while important in
individual cases at the  user  level,  would,  in  the  aggregate,  be too  small
to result  in macroeconomic impacts.

2.   Ground Squirrels

     About  240,000 acres  of cropland  are  treated  annually with an estimated
191,000 pounds of strychnine  bait to control ground  squirrels.   Tne
mountain states (Montana,  Idaho, Wyoming,  Colorado,  New Mexico,  Arizona,
Utah and Nevada) use  6?  percent of the strychnine  bait to control
ground squirrels on cropland,  and the  Pacific  states (Washington, Oregon
and  California) use 25 percent.  Together  these  two  areas'account for nearly
92 percent of the strychnine  baits used  to control ground squirrels  on
croplands.

     The most likely alternatives to  strychnine,  depending on  available
registrations and ground squirrel species,  include diphacinone,  compound 1080,
zinc phosphide and carbon  disulfide.   If strychnine  were cancelled and
compound 1080 were available,  producer control costs could increase  by a
minimum of $5.80 per  acre  or  $1.4 million  annually.   Without  compound 1080,
producer control costs could  increase  about $1.6 million annua" ly or $6.60
per  acre.

     No macroeconomic  impacts  would be  anticipated  as a result of cancellation
of strychnine for above-ground rodent  control on cropland.  The  impact, while
important  in individual  cases  would  be,  in the aggregate,  too small  to result
in macroeconomic impacts.

3.   Other  Rodents and Lagomorphs

     Complete data on  strychnine bait usage to protect  cropland  from
rodent and rabbit damage are not available.  In  local  situations, field and
meadow mice and jackrabbits can become problems, particularly during
periods of high population outbreaks.   Since no registered alternatives
are available in many states  for control of particular pests,
cropland losses will  increase when and where such  pest outbreaks  occur.
Since only a small amount  of strychnine  bait is  used annually for control
of these pests, impacts  would most likely  be limited to the user  level
effects and should not appreciably affect  major  crop markets  or  consumer
prices.

   E.  Analysis of Benefits for Strychnine  Use on  Cropland for Bird  Control

    All Federal registration of strychnine' for bird  control are  for  use on
nonagricultural sites.   However, a variety  of strychnine products are state-
registered in California,  Nevada, and Wyoming  for control of bird depredation
in croplands.  The Agency's analysis is  limited  to California since  Nevada and
Wyoming registrations are  for magpie control only and  sufficient  data were not
available  for analysis of  this pest situation.
                                    -  67  -

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     Approximately  18,250 pounds of strychnine  bait  are  used  to kill birds on
 an  estimated  36,500 acres of  California  croplands.   No  consistent and reliable
 data are available to estimate the use of strychnine-treated  baits by
 individual  crop.  However,  principal  crops  damaged  include grapes, cherries,
 sugar  beets,  lettuce, nuts, vegetables,  rice and  other  small grains,  tomatoes,
 plums  and melons.  In general, strychnine bait is distributed across crop
 groups as follows:  45 percent on vegetables and  melons,  or  16,400 acres; 35
 percent on  fruits and nuts,or 12,800  acres; and 20  percent on field crops, or
 7,300  acres.

     If strychnine were cancelled for  this use,  the  most likely alternatives
 include repellants (on selected sites), mechanical  and  electronic
 devices, trapping, shooting,  and habitat manipulation.  However,  these
 alternatives  do not provide the toxic control  presently available only
 through the use of strychnine.  No alternative toxicants  are federally
 registered  for bird control in cropland, although starlicide is federally
 registered  for use on feedlots.

     Since no  alternative chemical toxicants are available  for control of bird
 depredation in cropland, and  since strychnine  is  used only where  bird damage
 occurs, producers who currently use strychnine  to control  depredation would
 likely suffer increased losses if strychnine were cancelled.  Quantitative data
 to  estimate the extent and value of bird depredation are generally lacking,
 spotty or incomplete.  Quantitative analysis is further complicated by the wide
 diversity of  bird species which damage a wide variety of crops.   Many crops can
 suffer losses ranging from about 5 to 20 percent of yield on  treated  acreage.
 Individual acreages of specific crops can be completely destroyed.  However,
 comprehensive infestation and damage estimates for the cropland acres currently
 treated with  strychnine are not available.

     If strychnine were cancelled for control of birds on cropland,  the
 incremental loss would occur  only on those acres where strychnine is  now
 used.  Thus, the incremental  loss would be confined to the total  area now
 treated,  about 36,500 acres.  In California, this could result  in crop losses
 estimated at $1.5 million annually.

    The estimated 36,500 acres currently treated represent about  0.4$ of the
 total acreage of fruits,  nuts, vegetables, melon and field crop produced  in
 California.   Clearly,  the use of strychnine is of minor importance to the total
 California cropland picture which totals $5.5 to $6.0 billion on about 9.1
million acres annually.   Thus, while individual producers may be  seriously
affected,  the U.S.  supply and price of fruits,  nuts, vegetables and field  crops
would be  largely unaffected by cancelling strychnine for bird control  in
cropland.
                                   -  68 -

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     F.  Analysis of Benefits of Strychnine Use on Nonagricultural Sites

1.  Birds

    Strychnine is federally registered for outdoor use in the control of
pigeons and house sparrows on structures, vacant lots, and roosting
places.  Pigeon control uses account for more than 98 percent of the
estimated 31,500 pounds of strychnine baits used annually for pigeon and
sparrow control.

    Alternatives include U-aminopyridine (Avitrol), polyisobutylene, polybutene,
azacosterol, endrin, and fenthion  (Table IV-5).  Mechanical means such as traps,
frightening devices and structural changes designed to eliminate roosting and
nesting places are also useful.

    In assessing the costs involved in a bird control program it is important
to consider the time required for a comparable level of control in addition to
the costs of materials and costs of application.  Thus the particular situation
and the reason for desiring to reduce or eliminate the pest birds and the time
required for a specific control method are factors, especially when potential
health problems are indicated.

    The costs involved in structural changes in buildings to eliminate or
screen roosting or nesting places are site-specific and usually more expensive
than chemical control, although they may represent a more satisfactory long
term solution to pigeon or house sparrow problems at that site.

    Mechanical methods may ultimately offer essentially the same level of
reduction of bird populations as strychnine.  They are, however, much more
labor intensive and thus more expensive and require a longer period of time.
For the satisfactory management of any pest species, the integration of
structural repair and improved sanitation, as well as repellants and toxicants,
is required.

    The major impact resulting from the cancellation of strychnine for outdoor
control of pigeons and sparrows would be the elimination of a very quick-acting
tool when public health is an issue.  The pigeon and the house sparrow have
been implicated in the spread of many human diseases such as, ornithosis,
salmonellosis, cryptococcosis, Newcastle disease, histoplasmosis and
encephalitis.  Birds have been implicated in the spread of livestock diseases
such as transmissible gastroenteritis (TGE).  Pigeons and house sparrows that
form large concentrations and roost near human habitations can increase the
chances for the spread of histoplasmosis, a fungus that can grow in accumu-
lation of bird droppings.  The direct impacts from cancellation of strychnine
for pigeon and sparrow control on nonagricultural sites are unknown.  In the
aggregate,  no significant consumer impacts would be expected since some
alternatives are available.  However, there could be potentially serious
Impacts in local areas due to the inability to quickly control pigeons and
sparrows.
                                   -  69 -

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                                                                           Table  IV-5




                                                      Chemical Alternatives to  Strychnine  for Bird Control
Pest
Pigeons
House sparrows
Crowned sparrows
blackbirds


Starlings

Starlings, black-
biras, sparrows
House t inches
(linnet)
Horned larks
Cowbiras
Magpies
Meadowlark
Crows
Blue jays
Site
Structure roost
Structure roost
Sprouting crops
Structure roosts
Sprouting crops
Feedlots-t/
Structure roosts
Feeolots

Cherries

Grapes
Sprouting crops
Structure roost
Crops
Sprouting crops
Koos ts
Cherries
4-amino- Star- Polyiso- Aza-
pyridine licide butylene & costerol Fenthion Mesurol Endrin Diphacinone Pival
polybutene
F Ca. F F F F Ca. Ca.
F F F F
Ca.
F
Ca.
F F
F F F F
F

F

Ca.
Ca.
F


F
F
F:  Federal Registration




I/  Strychine registered for this use only in California.

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2.  Rodents and Lagomorphs

    Strychnine is registered for use in the control of ground squirrels,
prairie dogs, cotton rats, kangaroo rats, deer mice, meadow mice, chipmunks,
house mice, porcupines, jackrabbits, marmots/woodchucks, mountain beavers,
opossums, and rabbits on nonagricultural sites.  For purposes of this
analysis, nonagricultural sites have been defined as areas which are not
involved in the direct production of crops or livestock.  They include
structures, premises, embankments, nonagricultural turf areas and private
forest areas (Table IV-6).

    Very little data are available to estimate the overall use of strychnine
on these sites.  Most of the strychnine use on nonagricultural sites appears
to be for below-ground control of pocket gophers and moles in turf.  These uses
are not part of this RPAR.   Lesser quantities are used indoors (Non-RPAR) to
control house mice.  Most of the outdoor, above-ground strychnine use is
restricted to ground squirrel treatments on embankments and turf areas and
control of porcupines.

    Federally registered alternatives for rats and mice include compound 1080,
zinc phosphide, diphacinone, chlorophacinone, warfarin, carbon disulfide
and methyl bromide.  Zinc phosphide is federally registered for control of
cotton rats and kangaroo rats.  For ground squirrel control, federally
registered alternatives include gas cartridges and carbon disulfide.  Compound
1080, zinc phosphide, diphacinone, methyl bromide, Warfarin, Fumarin, Pival,
and chlorophacinone are registered in some states for ground squirrel control.

    If strychnine were to be cancelled for use on nonagricultural sites, some
increased incidences of ditch bank, levee, and canal washouts are likely,
particularly if compound 1080 were also to be cancelled.  Each incidence of
major failure of a canal, levee, or ditch bank can cost in excess of $10,000 to
repair.  The estimated total increased incidence of this damage is not known
however. No other significant user impacts are anticipated if above-ground,
outdoor uses of strychnine for control of rodents on nonagricultural sites are
cancelled.
                                   -  71 -

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                                   Table  IV-6
                Major  Pests on Nonagricultural Sites  Controlled
                                With  Strychnine
          Nonagricultural Sites
                                                 Major Target Pests
                                               (outdoor,  above ground)
Structures, Premises and Related Sites —

  Grain elevators
  Other crop storage areas and facilities
  Coomercial buildings and warehouses
  Farmsteads
  Urban dwellings

Embankments

  Ditch banks
  Levees
  Dikes
  Canals
  Earthen dams (small)

Nonagricultural Turf Areas

  Golf courses
  Parks
  Cemetaries
  Athletic fields
  Recreational areas
  Airport turf runways
  Military bases

Forest Areas (privately owned)

  Tree nursery
  Tree plantations

  Reforestation areas
                                                      House mice
                                                      House mice
                                                      House mice
                                                      House mice
                                                      House mice
                                                      Ground squirrels
                                                      Ground squirrels
                                                      Ground squirrels
                                                      Ground squirrels
                                                      Ground squirrels
                                                     Ground
                                                     Ground
                                                     Ground
                                                     Ground
                                                     Ground
                                                     Ground
                                                     Ground
squirrels
squirrels
squirrels
squirrels
squirrels
squirrels
squirrels
                                                     Ground squirrels,  rabbits
                                                     Ground squirrels,  porcupines,
                                                       rabbits
                                                     Ground squirrels,  porcupines
I/
The strychnine RPAR applies only to outdoor, above-ground uses.  Thus,
strychnine is assumed to be registered for use inside structures and
related sites.

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                V.   Risk/Benefit Analysis and Regulatory Options

                                A.   General

The previous two sections have  examined  the  risks  and  benefits  of using
strychnine  for  the  control  of mammals  and birds  on rangeland  and pasture  sites,
croplands,  and  nonagricultural  sites.  The purpose of  this  chapter  is  to
compare the risks and benefits  for  each  use,  and to evaluate  possible
regulatory  options.  Since  the  risk and  benefit  data do not always  allow  for
specific site/pest  analysis (e.g. jackrabbits on cropland,  linnets  on
cherries),  the  evaluation will,  for the  most  part,  be  presented in  general
terms.

Certain points  are  important  in the risk/benefit evaluation.  These form  the
key issues  in developing the  actions which might be taken:

    1.   Actions to be  taken,are determined  by the existence  of risks, not the
         absence of benefits.

    2.   The use of a substitute must  not increase the risks  relative  to  the
         benefits.

    3.   Risk mitigating and  risk reducing measures must be economically
         feasible and viable.

                         B.  Risk/Benefit Analysis

1.  Rangeland Rodents

    The use of  strychnine for the control of ground squirrels,  prairie dogs and
other rodents and lagomorphs  on  rangeland and pastures presents a risk to non-
target birds and mammals, both  from primary and  secondary poisoning.   The
Hegdal and  Gatz study demonstrated  the risk of primary poisoning by documenting
the kill of the majority of the  territorial horned  larks as well as a  number of
other birds in  a ground squirrel treatment area.   Also,  the LDcn data
presented in Section III demonstrated the potential for nontarget seedeating
wildlife to ingest  a lethal dose of treated grain.

    The secondary risks associated  with  controlling ground squirrels appear to
be slight.  The relatively  high  ID™ of  the ground  squirrel suggests that
little strychnine would generally remain in the  gut for ingestion by a
predator.   The  relatively low LDfrn  of the prairie  dog,  however, suggests  that
for this mammal the possibility  or  secondary  risks  to  nontarget species does
exist.  The black-footed ferret, an endangered species that lives with and
feeds on the prairie dog, would  be  especially susceptible.

    The risks of controlling  other  rodents and lagomorphs are -similar  to  those
for ground  squirrels and prairie dogs.   The difference is one of degree,  since
less than one percent of the  strychnine  bait  used annually is for controlling
mammals other than  ground squirrels and  prairie  dogs.
                                   -  73 -

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    No comprehensive estimates are available to document rangeland and  pasture
damage caused by rodents and lagomorphs.  Damage estimates, although  largely
unsubstantiated, generally provide an indication that a pest problem  does  exist
and that control is believed to be required.

    For ground squirrel control, the increased costs from using alternatives
could range from $900,000 to $1.5 million annually, depending on  the
availability of compound 1080 (currently used in two states).  For prairie dog
control, the use of the zinc phosphide, the most likely alternative,  could
result in a slight cost reduction.  Due to data limitations, estimates  for
other rodents and lagomorphs are not available.

    Strychnine is not used extensively for rodent and lagomorph control on
rangeland.  Although this use accounts for approximately 45 percent of  the
strychnine bait used, approximately 0.02 percent of the grazing acreage in the
48 contiguous States is treated annually for ground squirrels and less  than
0.01 percent is treated for prairie dogs.

    The alternatives for ground squirrel control are few.  Only fumigants  are
federally registered and they are generally used only for spot controls.   Zinc
phosphide is available for prairie dogs.  As shown in the risk analysis, the
available alternatives for rangeland rodent and lagomorph control all present
a direct risk to nontarget wildlife, but, with the exception of compound 1080
(registered in three states)  and possibly DPN,  do not present a risk of
secondary poisoning as does strychnine.

    Although the geographical extent of the risks and benefits are limited,
they may be locally significant.  The risks are of particular importance when
the nontarget wildlife includes one or more endangered species.  The following
is a listing of the endangered species potentially at risk for each rangeland
use:

    o    pest               - ground squirrel
    o    endangered species - Utah prairie dog,  California condor, black-footed
                              ferret,  San Joaquin kit fox,  gray wolf,  grizzly
                              bear,  Aleutian Canada goose,  peregrine falcon

    o    pest               - prairie  dog
    o    endangered species - black-footed ferret,  gray wolf,  grizzly bear

    o    pest                - kangaroo rat
    o    endangered species - Utah prairie dog, masked  bobwhite,  San Joaquin
                              kit  fox

    o     pest               - cotton  rat
   o     endangered species - red  wolf,  dusky seaside sparrow,  Cape Sable
                              sparrow, Mississippi  sandhill  crane,  Attwater's
                              greater prairie chicken,  black-footed ferret
                                   - 74  -

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    o    pest                -  jackrabbit
    o    endangered species  -  Utah prairie  dog,  San  Joaquin kit  fox,  Morro Bay
                               kangaroo rat, red  wolf, masked  bobwhite,
                               Attwater's  greater prairie  chicken,  black-footed
                               ferret

    With the exception of  the  Aleutian Canada  goose  and the peregrine falcon,
both the USDI and the Agency believe the  above ground use of  strychnine, as
presently registered, is likely to jeopordize  the continued existence of the
endangered species listed above.  The Agency believes this same  risk  applies to
the goose and the falcon.

    No above ground rangeland  uses of strychnine are known to occur in the
.ranges of the salt marsh harvest mouse, the masked bobwhite,  the California
condor, the Mbrro Bay kangaroo rat, the red wolf,  the gray wolf, the  grizzly
bear, the dusky seaside sparrow, or the Cape Sable sparrow.   In  the case of an
endangered species, however, the Agency believes the potential for exposure is
sufficient basis for concern.  The benefits of use in their ranges are
apparently negligible since  strychnine is not  currently being used.

    Although strychnine may  be used in the  range of  the Utah  prairie  dog for
rodent and lagomorph control,  less than one percent  of the strychnine bait is
used in Utah.

    The winter range of the  Aleutian Canada goose overlaps that  of the
California ground squirrel.  Most ground  squirrel control in  California is
accomplished with compound 1080, however, and  the winter  residence time of the
goose in California does not generally coincide  with the  time of ground
squirrel baiting.

    The use of strychnine  in the range of the  black-footed ferret  is  relatively
extensive, since it may be found wherever prairie dogs exist. Strychnine  may
also be used in the range  of the San Joaquin kit fox for  ground  squirrel and/or
jackrabbit control.

2.  Cropland Rodents

    The risks of using strychnine for the control of rodents  and lagomorphs on
cropland are the same as those for use on rangeland. The amount of bait used
is essentially equal (227,400  Ibs. for rangeland vs. 209,900  Ibs.  for
cropland).

    As with rangeland use, the benefits are stated in terms of the cost
differential of using an alternative should strychnine be cancelled.  For
ground squirrel control, the cost would increase by  an estimated $1.4 to $1.6
million annually.  For prairie dog control, the  cost could increase by an
estimated $290,000 if fumigants were to be  used.  Due to  data limitations,
estimates for the control of other rodents  and lagomorphs are not  available.
                                    -  75 -

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     The endangered species potentially at risk from the above ground use of
 strychnine for the control of rodents and lagomorphs on croplands are the same
 as those at risk from rangeland use.

 3.  Nonagricultural Site Rodents and  Lagomorphs

     No specific risk data were available for this use.  A reasonable
 assumption, however, is that a risk to nontarget organisms does exist.  In
 particular, all of the endangered species mentioned under the preceeding
 rangeland and cropland manmal categories could potentially be exposed to
 strychnine bait.   Additionally,  the salt marsh harvest mouse, yellow-shouldered
 blackbird, and Puerto Rico plain pigeon could be exposed, although no
 strychnine uses are known to occur in their ranges.  This potential for
 exposure is a result of the wide range of site/pest uses in this category.

     No benefit data are available,  other than for the use of ground squirrel
 control on canals,  levees,  and ditch  banks.  Each canal, levee,  or ditch bank
 failure can result  in repairs costing at least $10,000, but the  total cost of
 all repairs is not  known.   Also  unknown is the increase in the number of
 repairs that  could  be anticipated  should strychnine registration be cancelled.

 4.  Cropland  Birds

     Use of strychnine to control birds on croplands accounts for approximately
 3.6 percent of strychnine use.   Only  three State registrations exist for this
 use, and two  are  for magpie control only.   California accounts for virtually
 the entire usage  of strychnine for  the control of bird depredation on
 cropland.

     No specific information is available on the risks associated with these
 uses.   A reasonable  assumption,  however,  is that some primary and secondary
 risks  to nontarget  species  do exist.   The Agency does not believe any
 endangered  species  are  at risk from the  use of strychnine to control cropland
 birds.

     Benefit data  are  limited  to  California,  and are not available for all
 individual  crops.   Only an  estimated  0.4 percent of the total cropland  in
 California  is  treated with  strychnine  for  control of birds.   Crop losses,  if
 strychnine  were to  be cancelled  and no alternative  were used,  could  increase  by
 an estimated $1.5 million annually.   As  stated in Section IV,  the total
 California  cropland production is valued at  an estimated $5.5 to $6.0 billion
 annually.

 5.  Nonagricultural Site Birds

    Approximately 6.2 percent of the strychnine  bait  is used  to  control  pigeons
and house sparrows on nonagricultural sites.   Virtually all of this  bait is
used for pigeon control.
                                   - 76  -

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    No specific risk information is available  for  this  use with  the  important
exception of a risk to raptors.  A reasonable  assumption, as with all uses  of a
toxicant such as strychnine, is that a risk to nontarget species does exist.
The data on raptor kills are evidence of a risk  to the  peregrine falcon.  Also,
although no uses of strychnine are known to occur  in  Puerto Rico, the yellow-
shouldered blackbird and the Puerto Rican plain  pigeon  could be  at risk  from
this use.

    Benefit information is similarly lacking for this use.  Other chemicals are
available, but they do not provide the fast-acting control believed  to be
necessary for public health protection.

                          C.  Regulatory Options

1.  Rangeland Rodents - ground squirrels

    Option - No Action

    With this option, the potential for risks  to nontargets, including
certain endangered species, would continue unabated.  The benefits would be
similarly unaltered.

    Option - Cancellation

    Adoption of this option would eliminate the  risks of the use of
strychnine for ground squirrel control on rangeland and pastures.  The lack of
economically feasible alternatives could produce a locally significant increase
in control costs.  Also, the risks of control  would not be completely
eliminated, since compound 1080 and fumigants, the most likely alternatives,
have risks associated with their use.  The risk  of secondary poisoning would  be
eliminated if fumigants are used, but the risk of  direct effects to  nontarget
species would still exist.  Also, an increase  in the  use of fumigants could
result in an increase in human risks.

    Option - Modification of the Terms and Conditions of Registration

    The general conclusion of the risk assessment  for most uses  of strychnine
was that available evidence did not now permit the Agency to conclude that
substantial risks to nontarget wildlife would  generally occur if proper
precautions are taken and if due concern is given  to  protect endangered
species.  Some nontarget mortality is to be expected  from all uses.  Certain
use modifications, however, could reduce the risks to an acceptable  level.
These risk reduction measures must not reduce  usage to  the point of  eliminating
the benefits, since this would result in an implicit  cancellation.

    In addition to the use of dyed bait, discussed in Section II, other  general
procedures may be appropriate for reducing risks from the use of strychnine in
vertebrate pest management.  General reductions  of risks are possible through
changes in the characteristics of the bait formulations and the  procedures  for
use.  For the protection of endangered species,  the major methods of risk
                                    - 77  -

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 reduction are changes in where and when a bait can be used.  The following
 discussion elaborates on these methods.

     Bait Formulations

     A wide variety of strychnine bait formulations are in use and it seems
 apparent that the balance between efficacy and safety can be improved.  The
 characteristics of the bait  formulations that can be manipulated include the
 concentration of the  toxicant,  the attractiveness of the bait to nontarget
 species, and the persistence of the bait.  The following discussion illustrates
 the problems and potential solutions.

     A common formulation for pigeon control contains 0.6 percent strychnine on
 whole corn1.   Since the ID™  for the pigeon is about 15 mg/kg, ingestion of
 about two g bait per  bird should give adequate efficacy (Faulkner,  1964
 estimates that six kernels are  adequate).  With proper prebaiting,  a hungry
 pigeon may quickly ingest one ounce or more bait (30 g).  A substantial
 reduction in the concentration  of strychnine in the bait could probably be made
 with no loss of efficacy.  The  observations of Hegdal and Gatz (1977) indicate
 that the level of strychnine in poisoned doves decreased with the concentration
 of strychnine remaining on the  bait.   It see;ns probable, therefore,  that risks
 can be reduced by altering bait formulations but the lowest level of strychnine
 that will maintain adequate  efficacy  must be determined.

     As discussed in Section  II,  several  rebuttals of the Agency's presumption
 of risk indicated that  dyeing the bait  inhibited its consumption by  birds.
 From the available evidence,  the Agency  could not conclude  that the  efficacy of
 this procedure had been established.   In principle,  however,  making  the bait
 less attractive to nontarget  species  has much merit.   Further development  of
 this concept is desirable.

     If a resident target  individual is not  killed by strychnine the  first  time
 it  consumes  the bait, it  is  less  likely  to  be killed by  subsequent feeding
 because of bait aversion.  In general, persistence of acutely toxic  baits
 beyond  the first  few days of exposure does  not contribute significantly to the
 success of the control  effort but, as indicated  by the observations  of Hegdal
 and  Gatz (1977a),  nontarget  immigrants or transients may continue to  suffer
 mortality.   ^  bait  that could remain  relatively  stable for  a  few days and  then
 rapidly lose its  toxic  properties could  serve to  reduce  risks that occur after
 the  control  operation is effectively complete.

     Application Procedures

     During a control effort,  factors which  may alter  the risk to nontarget
 organisms include the application rate,  the  frequency  of application  and the
 method  of distributing  bait  (broadcast vs.  spot  treatment with  or without
 prebaiting).   These variables are largely under the control of  the operator and
 involve decisions that affect efficacy,  efficiency and other  cost/benefit
considerations.  These are important components of the management strategy.
                                   -  78 -

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    Assuming that population reduction is necessary,  if  just  the  right  amount
of suitable bait could be placed so that at the economic threshold, every
individual in the target population was likely to be  killed with  little or no
bait remaining, the risks would be minimized and the  benefits, in terms of long-
term damage reduction, would be maximized.  There are practical limitations
to achieving such a goal but improvement over the present situation with regard
to various uses of strychnine is desirable.

    The Agency has no present legal or factual basis  to  prescribe general
curatives for risk situations that result from less than optimal  management
decisions to use strychnine in accordance with the label.  The development and
use of management systems that minimize risks, however,  would tend to forestall
any future findings of unreasonable adverse effects from the  use  of strychnine
and other vertebrate toxicants.

    Temporal Restrictions

    Some populations of endangered species are migratory; hence,  individuals
are at risk from the use of strychnine only during the time of year when use
coincides with their presence.  For example, Arctic peregrine falcons may be
present in any of the 48 contiguous states during the period  of migration -
generally from mid-March through April and from mid-September through October.
If uses of strychnine that would lead to the presence of poisoned birds were
prohibited during those periods, risks to this peregrine falcon would be
substantially reduced in areas that do not support a  breeding population.

    Geographic Restrictions

    Many endangered species have highly restricted distributions. Prohibiting
the use of strychnine within the areas likely to be occupied  - with an added
buffer zone if necessary - could effectively eliminate the potential for
exposure.  The scale of the restriction, whether micro-  or macrogeographic,
would vary with circumstances concerning the predictability of the species'
presence and needs to prevent disclosure of the locations of  individuals.

    Thus, the Agency believes four general risk reduction measures have the
potential for reducing risks without affecting the benefits.  These are:  1) a
reduction of the concentration of the active ingredient  in the bait, 2)
standardization of bait and post-baiting procedures to protect nontarget
species, 3) use of dyed baits to repel nontarget seedeaters,  and  4) a
prohibition of use of the pesticide where or when a significant potential
exists for exposure to endangered species.

    A fifth measure, integrated pest management  (IPM), was investigated as a
possible risk reduction method.  The goal of IPM is to reduce, if not
eliminate, the dependency on chemicals and still achieve the  degree of  pest
control believed to be necessary.  This could be through habitat  manipulation,
introduction of another species (e.g. a predator), and/or an  optimal use of the
chemical.  The optimal use of a chemical requires exposing the target species
                                    -  79 -

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 to  the  amount  necessary  to  be  fatal,  at  the time when it is most likely to
 ingest  the  bait.   This would minimize the bait exposure to nontarget species.

     The application of possible  IPM methods as substitutes or risk reduction
 measures was discussed with authorities  within the Agency, the environmental
 community,  and private enterprises.   All believed that this was a desirable
 area for research  and an ideal application of IPM.

     Unfortunately, no data  were  found to form a basis for an IPM option.  IPM
 programs are currently feasible  only  where there is sufficient knowledge of
 those parameters involved and  when  it is possible to exercise control over the
 parameters.  A knowledge of all  relevant factors within the ecosystem is
 mandatory to assure not  only the  intended results but to preclude any adverse,
 unintended  results.  Such information has not been developed for the situations
 in  which strychnine is used.   Most  IPM work to date has been confined to insect
 control on  specific crops.

     The control of mammals  and birds  on  larger areas using IPM techniques is a
 matter  for  further research.   Range management techniques are being investi-
 gated by the Agency and,  when  available,  will be evaluated.   Implementation of
 an  IPM  program presents  further  problems.   For example,  even if a program is of
 demonstrated feasibility its use  cannot  be mandated,  only stimulated through
 the  elimination or restriction of conventional alternatives.

     Therefore,  the Agency does not believe that IPM is a fea-sible option for
 reducing  the risks associated with the use of strychnine at  this time.   It
 will, therefore, not be  considered for this use,  ground  squirrels on rangeland,
 or  the  others  under investigation in  this  document.   The other four measures
 will be  developed under  this use and  the  discussions  will be  applicable,  when
 noted,  for  the  other site/pest uses.

     o     Reduction of active ingredient  concentrations -

          The registered  labels of strychnine  specify  a range  of concentrations
 and  use  instructions for the various  site/pest combinations.   On the theory
 that such formulations are designed to be  cost-effective,  all  of the labels
 except  the one  with the  lowest concentration/dosage combination would appear to
 contain more strychnine than necessary.

          Risks  to nontargets from strychnine  bait  could  then  be reduced
without reducing .benefits by standardizing  all  labels  to conform to the  one
with the  least  amount of poison per application.   For the control of ground
 squirrels on rangeland,  the bait would have an  active ingredient concentration
of 0.20 percent and a dosage of one level  tablespoon  to  cover  one-two square
 feet, as  per accession number  11150-08490,  for Riverside County,  California.

    o    Standardization of baiting and post-baiting  procedures -

         As with the previous risk reduction method,  the Agency is assuming a
lower exposure with no impact on benefits.  The procedures were taken from
                                    - 80  -

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currently registered  labels, and the  rationale  is  the  same  as for the reduction
in active ingredient  concentrations,  i.e.  standardization of best current
practice.

         For the control of ground squirrels on rangeland,  the procedures to  be
followed are:

                   do not expose bait where pets,  poultry,  or livestock  are
                   present

                   do not place bait  in piles

                   pick up and burn or bury dead animals

    o    Use of dyed  bait -

         The rebuttal analysis discussed the use of dyes  in bait  as a deterrent
to feeding by birds during rodent and lagomorph control operations.   From an
examination of available data, the conclusion was  that some risk  reduction from
dyed baits would be possible for some species of birds.   The data were not
sufficient to detail  the type or color of  the dye, nor to predict the bird
species that would be protected.  No  evidence was  presented that  argued  against
the use of dyes either due to a reduction  in efficacy or  to being an  attractant
to nontarget species.  An unpublished report by Palmateer (1980)  suggests that
some dyes may reduce  acceptance by target  species.  The increased cost involved
with producing dyed baits versus undyed is approximately  one cent a pound, an
increase of less than 0.5 percent.

         The durability of the dye in the  environment, the  effectiveness of dye
as a repellent, the time required for a bird to overcome  a  reluctance to ingest
the dyed bait, and the overall risk reduction effects are all unknown.   A
requirement that bait used for rodent and  lagomorph control be dyed in
accordance with recommendations of the Fish and Wildlife  Service  could reduce
the primary and secondary risks to nontarget organisms.   The impact on
benefits is anticipated to be negligible.

    o    Prohibition  of use in the range of endangered species -

         1.   Utah prairie dog

              A critical habitat has  not been determined  for this species.  An
estimated 5,700 members live in a six-county area  in South  Central Utah.
This is apparently the permanent residence of the  Utah prairie dog.   Thus, use
of strychnine in this area for rodent control at any time could endanger its
existence.  Theoretically, baiting might be done safely during the period of
hibernation, but the  Agency has no information  that would permit  it to
conclude that all of  the bait would deteriorate during the  winter period.

              Since the range of this species is apparently contained within
the six counties of Garfield, Iron, Kane,  Piute, Sevier,  and Wayne, and  since
                                    -  81 -

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 no  temporal  restrictions  are  applicable,  the only enforceable alternative for
 the protection of the  Utah prairie dog is prohibition of strychnine use within
 this region.   Such a prohibition of use would eliminate the risk to the Utah
 prairie  dog  associated with the registered use of strychnine.  Since very
 little use is  made of  strychnine for rodent control in this region, no impact
 on  benefits  would be anticipated.

          2.    California  Condor

               A critical  habitat has been determined for this species.  The
 estimated population of approximately 30  members inhabits an area in the
 Central  California.  Although most ground squirrel control efforts in
 California utilize compound 1080,  almost  100,000 Ibs.  of strychnine bait are
 also used.   Additionally,  over 18,000 Ibs. of strychnine bait is used in
 California for bird control.

               The risk to the condor from the use of strychnine is apparently
 slight.   The only major uses  of strychnine in the condor's range are for pocket
 gopher,  horned lark, and  finch control.   The use of strychnine for pocket
 gopher control is not  considered in the RPAR action,  and,  as discussed in
 Section  III, the risk  to  the  condor from  the use of strychnine for the control
 of  birds on cropland is generally low.

               The benefits of strychnine  would increase if compound 1080 were
 cancelled for  ground squirrel  control.  Tne  risks to  the condor for strychnine
 could also increase substantially.   For the  condor,  the loss of one member
 would be excessive, given  its  population  status.   Prohibition of use in the
 range of the condor would  eliminate the risks to the  condor from the use
 strychnine and have no  impact  on benefits.

          3.    Black-footed Ferret

               The risk  to  the  black-footed ferret from prairie dog control was
 discussed on page 31.   The question to  be  addressed  in this part is the action
 to  be taken in the areas where prairie dogs  and  ground squirrels occupy the
 same  area.  As previously  mentioned,  this  question was not addressed by USDI
 in  their report  to EPA  (Appendix D).  The  primary problem  is with the white-
 tailed prairie dog, whose  populations are  sometimes  intermixed with those  of
 ground squirrels.

               For the states affected,  (Wyoming,  and to a  lesser extent Utah
 and  Colorado)  ground squirrel  control accounted  for 23,115 pounds of strychnine
 bait  in  1977-78.  Wyoming, with  a majority of the white-tailed prairie  dogs,
 used  11,800 pounds.  The total .amount of strychnine bait for ground squirrel
 control  for all  states  in  this period was  337,230 pounds.

               If  the use of strychnine for ground squirrel  control were to be
 prohibited in  the range of the prairie dog,  fumig; its  or anticoagulants would
have to be used  for control.   Use of fumigants would eliminate the
 secondary risk to the ferret, but the potential  for such effects from the  use
                                    - 82  -

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of anticoagulants  is uncertain.   Either  would  increase ground squirrel control
costs.

              A lesser action would  be prohibition of strychnine use for ground
squirrel control within any county where the black-footed ferret has been
sighted since 1973, the year of enactment of the  Endangered Species Act.  The
use of strychnine  in any area where  a ferret has  been sighted implies a risk of
a prairie dog ingesting the poison and a subsequent risk to the ferret from
eating a poisoned  prairie dog.  This is  based  on  the knowledge that the ferret
is closely associated with the prairie dog.

              A third alternative would  be to  prohibit use of strychnine for
ground squirrel control within some  distance of a prairie dog town.   If a town
is not definable,  the locus would be an  active prairie dog burrow.

         4.   San  Joaquin Kit Fox

              A critical habitat  has not been  determined for this species.  The
current population is located in  certain areas in the San Joaquin Valley,
portions of which  are included in the range of the California ground squirrel.

              The  current risk to the kit fox  from strychnine is not high,
since compound 1080 is the primary control method for ground squirrel control
in California.  Should compound 1080 be  cancelled,  however,  the use  of
strychnine could increase.

              Prohibition of the  use of  strychnine within the range  of the San
Joaquin kit fox would eliminate the  risk from  this pesticide to the  kit fox.
The current benefit impacts of prohibition are not known but are expected  to  be
negligible.

         5.   Gray Wolf

              A critical habitat  has been determined only for that  portion of
the gray wolf population in Minnesota.   The present use  of strychnine does
not pose a serious threat to the  gray wolf, as it is rarely if ever  used in its
range.  USDI did not define a range  for  this species,  but recommended
prohibition of strychnine use in  known gray wolf  areas.   This option would
apparently have no impact on benefits.

         6.   Grizzly Bear

              Areas in four states,  Montana, Wyoming,  Idaho,  and Washington,
have been identified as important grizzly bear habitat.   Several National
Forests, Indian Reservations, National Parks and  Wilderness areas are included
in this habitat.

              The  use of strychnine  in the range  of the  grizzly appears to be
very small, if used at all.  A prohibition of  use of strychnine within known
grizzly bear areas would virtually eliminate the  risks from the use  of
strychnine and have no impact on  benefits.
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         7.   Aleutian Canada Goose

              A critical habitat has not been determined for this  species.   Its
migration route in the fall includes the northwestern California coast  and
interior California valleys.  In early spring, they migrate back to  the
Aleutian Islands.

              While total prohibition of strychnine use in the migratory range
does not seem warranted, one of two options would be advisable.  These  would be
to prohibit baiting in its California range or prohibit baiting in its
California range only during the months of October through April.

         8.   Peregrine Falcon

              At this time, the only method of reducing the risk to  the
peregrine falcon from ground squirrel control would appear to be from the
dyeing of bait.  The optimal time for controlling ground squirrels generally
coincides with the period of spring migration, making a temporal or  geo-
graphical use restriction unfeasible.  The risk to peregrines from this use
appears to be relatively low,  however.

2.   Rangeland Rodents - prairie dogs

     Option - No Action

     With this option, the potential for risks to nontargets, including
certain endangered species, would continue unabated.  The benefits would  be
similarly unaffected.

    Option - Cancellation

    The effect of this option would be an elimination of risks from  the
use of strychnine for prairie dog control on rangeland and pasture.

    Zinc phosphide, the alternative most likely to be used if strychnine
is cancelled for this use, is of approximately equal efficacy and  cost.   The
risks to gallinaceous birds (and possibly geese and rabbits) are apparently
greater from zinc phosphide than strychnine.  Otherwise, zinc phosphide  poses
little demonstrated hazard to other wildlife species when properly used.
Risks of secondary poisoning are also generally essentially eliminated.   Of
particular importance, the toxic risk to the black-footed ferret is  virtually
eliminated, since secondary poisoning would no longer be likely.   Destruction
of the ferret's habitat - prairie dog towns - would still be of concern.

    Option - Modification of the Terms and Conditions of Registration

    o    Reduction of active ingredient concentration (see discussion under
         "Rangeland Rodents-ground squirrels" on page 80) -

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          For  the control of prairie dogs on rangeland,  the  bait  would have an
active ingredient concentration of 0.35 percent and  a dosage of  two  teaspoons
per square foot (as per EPA registration number 6704-57).

    o    Standardization of baiting and post-baiting procedures  -

         The discussion under "Rangeland Rodents-ground squirrels" for this
method is applicable here also.

    o    Use of dyed bait -

         The discussion under "Rangeland Rodents-ground squirrels" for this
method is applicable here also.

    o    Prohibition of use in the range of endangered species -

         The discussions under "Rangeland Rodents-ground squirrel" for the gray
wolf and the grizzly bear are applicable here.  A prohibition of use  for
prairie dog control within the range of black-footed ferret, however,  would
amount to a cancellation, since the precise range of the black-footed  ferret  is
not known, but can be assumed to be wherever the prairie dog exists.

3.  Rangeland Rodents - other rodents and lagomorphs (kangaroo rats,
    cotton rats, deer mice, meadow mice, jackrabbits, chipmunks, woodchucks)

   Option - No Action

   With this option, the potential for risks to nontargets, includiung
certain endangered species, would continue unabated.  Tne benefits would be
similarly unaffected.

   Option - Cancellation

   This option would eliminate the risk from the use of strychnine for
the control of rodents and lagomorphs on rangeland.  Very little strychnine
bait is used for this purpose (less than one percent of the total usage), and
only the cotton rat, kangaroo rat, and jackrabbit cause enough damage to
require regular control.  Cancellation would therefore have impacts only on a
local level.   Alternatives are limited, but zinc phosphide is federally
registered for control of cotton rats, deer mice and meadow mice.  Gas
cartridges are federally registered for woodchucks, and Thiram is federally
registered for chipmucks.  Cancellation would result in an increase in losses
in local situations, particularly from pests for which no federally registered
toxic alternatives exist (i.e. jackrabbbits, chipmunks and kangaroo rats).

    Option - Modification of the Terms and Conditions of Registration

    o    Reduction of active ingredient concentration (see discussion  under
         "Rangeland Rodents-ground squirrels" on page 80) -
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          For the jackrabbit,  the concentration would  depend on whether a grain
or green  bait were used.   If  a  grain  bait  is  used  the concentration would be
0.28 percent and the dosage would  be  one tablespoon  (as  per accession number
11224-08504 for Tulare  County,  California).   If a  green  bait is used, the
concentration of strychnine would  be  0.1$  (one ounce  on  three Ibs.) and the
dosage would be four to five  alfalfa  shoots (as per accession number 11198-
05260 for Sonoma County,  California).

          Chipmunk bait  would  have  a concentration  of  0.50 percent and a dosage
of one pound per 10-15  acres  (as per  EPA registration number 6704-58).

          Meadow mouse and deer  mouse  bait  would have  a concentration of 0.20
percent with a dosage of  10-15  Ibs/acre (as per accession number 11165-08602
for San Benito County,  California).

          Woodchuck bait would have a  concentration of 0.50 percent and a
dosage of one teaspoon  (as per  EPA registration number 728-74).

          Kangaroo rat and cotton rat  bait  would have  a strychnine concentration
of 0.16 percent.  The dosage  would be three-four tablespoons if  applied by hand
or 1/2-3/4 pound per swath-acre if mechanically applied  (both the concentration
and dosage are as per accession number 11231-05307 for Ventura County,
California).

    o     Standardization  of baiting and post-baiting  procedures  -

          The discussion under "Rangeland Rodents-ground  squirrels"  for this
method is  applicable here also.

    o     Use of dyed bait -

          The discussion under "Rangeland Rodents-ground  squirrels"  for this
method is  applicable here also.

    o     Prohibition of use in  the range of endangered species -

          The discussions  under  "Rangeland  Rodents-ground  squirrels"  for the
Utah prairie dog and San  Joaquin kit  fox are applicable  here also.

          1.   Masked Bobwhite

              No critical habitat has been determined  for this species.  An
attempt is being made to  reintroduce masked bobwhites  in  Arizona.   The
locations  are in two valleys, the  Altar Valley in  Pima County and the Santa
Cruz Valley in Santa Cruiz and  Pima Counties.   These counties are included in
the ranges of the jackrabbit  and kangaroo  rat.   Although  there is no evidence
of strychnine use in these ranges,  the possibility does exist.   Also,  since
efforts are underway to establish a population,  any use would be  posing an
unacceptable risk.   No alternative toxicants are available  for the  jackrabbit
and kangaroo rat.
                                    - 86  -

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         2.    Red Wolf

               No critical habitat has  been  determined for this species.   The
range appears  to be limited to  three counties  in Texas (Chambers,  Orange,  and
Jefferson) and two parishes in  Louisiana  (Cameron and Calcasieu).   These
counties are included in the range of  the cotton rat  and  possibly  the
jackrabbit.  While no known Federal or State control  programs  occur in the
range of the red wolf, some commercial uses may  exist.  Since  the  extent would
be limited, no impact on benefit would be anticipated and the  risk would be
eliminated by  prohibition of use in it's  range.   Use  of zinc phosphide for
controlling cotton rats would reduce risks  to  the red wolf without affecting
benefits.

         3.    Dusky Seaside Sparrow

               The critical habitat has been determined for this species.  The
sparrow inhabits salt marshes in Florida  on Merritt Island and on  the
mainland near  Titusville.  The  only target  organism in this area is the  cotton
rat.  Since most of the birds inhabit  federally  controlled lands,  the chance
of their encountering strychnine is slight.

               Since the areas inhabited are apparently the permanent residence
for this bird, no temporal use  restrictions are  possible.   Also, the apparently
low probability of use indicates prohibition within the range  would not  result
in any benefit impacts.  The relative  toxicity of zinc phosphide is not
predictable for this species, but its  registered use  in cotton rat infested
areas could increase the risk to this  sparrow.   Chlorophacinone is registered
in Florida for the control of cotton rats and  would appear to  pose very  little
risk to this sparrow.

         4.    Cape Sable Sparrow

               A critical habitat has been determined  for  this  species.   The
sparrow is found only in a few  herb and brackish marshes  in .Southwest Florida.
No strychnine  use is known to occur in its  habitat at this time although it  is
included in the range of the cotton rat.  The  lack of use indicates a lack of
impact on benefits if prohibition is imposed.  This habitat appears to be  a
permanent residence, making anything less than total  prohibition in its  range
ineffective for risk reduction.  The relative  toxicity of zinc phosphide is  not
predictable for this species, but its  registered use  in cotton rat infested
areas could increase the risk to this  sparrow.   Chlorophacinone is registered
in Florida for the control of cotton rats and  would appear to  pose very  little
risk to this sparrow.

         5.    Mississippi Sandhill Crane

               The range of this non-migratory  crane is limited to  a small area
in Southern Jackson County, Mississippi.  This area is within  the  range  of the
cotton rat.  A critical habitat was determined for this species.  The
present population estimate for this crane  is  30 to 50 members.
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              Any use in the range of this species would  be  unacceptable due to
the small population.  Benefit impacts of prohibition would  be  negligible,  but
the elimination of risk is critical.  The use of zinc phosphide,  the  only
available toxicant, as an alternative may or may not reduce  the risks.

         6.   Attwater's Greater Prairie Chicken

              A critical habitat has not been determined  for this species.   The
current population is under 2,000, and is limited to the  prairies on  the
Texas Gulf Coast.  This area is included in the ranges of the jackrabbit and
the cotton rat.  Texas uses less than three percent of the total strychnine
used by all the states, virtually all going for the control  of  ground squirrels
and prairie dogs.  Thus, the cancellation of strychnine use  in  the range of the
Attwater's greater prairie chicken would have no impact on benefits.  Since the
present range is the permanent residence of the chicken,  no  restrictions other
than prohibition of use in that range would eliminate the  risks from
strychnine.  Since zinc phosphide formulations are sustantially more  toxic  to
gallinaceous birds than is strychnine, cancellation of strychnine for cotton
rat control would increase risks to this prairie chicken.

         7-   Morro Bay Kangaroo Rat

              Approximately 3,000 members of this species  exist only  in  a few
square miles on the south side of Morro Bay, San Luis Obispo  County,
California.  Roughly one square mile of private property has  been designated as
the critical habitat.

              With the possible exception of the black-tailed jackrabbit,
none of the target rodents inhabit the range of this endangered species.  Since
no evidence exists that strychnine is being used in the range of the  Morro  Bay
kangaroo rat, however, no impact or benefits should result from prohibition.
Also, no restrictions other than prohibition of use in its range would
eliminate the potential risk to the species from strychnine.  Anticoagulants
are registered in California for the control of jackrabbits,  and  they may
or may not reduce the risks to this kangaroo rat.

4.  Cropland Rodents - ground squirrels

    The available options, and their impacts, are the same as for ground
squirrels on rangeland.

5.  Cropland Rodents^- prairie dogs

    The available options, and their impacts, are the same as for prairie
dogs on rangeland,  with the important distinction that if strychnine  were
cancelled, the only federally registered alternative is gas cartridges.   This
increases the costs of control, but reduces the risk to nontarget  species,
especially the black-footed ferret.
                                    -  88 -

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6.  Cropland Rodents - other rodents and lagomorphs

    The available options, and their impacts, are the same as for other
rodents and lagomorphs on rangeland, with the exception that no  federally
registered alternatives are available for the control of cotton  rats and
kangaroo rats.  Gas cartridgesare federally registered for use on woodchucks;
repellants are federally registered for jackrabbits, and anticoagulants are
available for meadow mice and deer mice.

7-  Rodents and Lagomorphs on Nonagricultural Sites

    Option - No Action

With this option, the potential for risks to nontarget species,  including
certain endangered species, would continue unabated.  The benefits would be
similarly unaffected.

    Option - Cancellation

    Cancellation of strychnine uses to control rodents and lagomorphs
on nonagricultural sites would eliminate the risks from strychnine to non-
target organisms.  Some benefits are realized from this use, particularly for
canals and levees, but alternatives are available for the primary pest, the
ground squirrel.  Alternatives most likely to be used, fumigants, are not
without risks.  The risks are less than those for strychnine, however, and
secondary risks would be eliminated.  Federally registered alternatives are not
available for the porcupine, jackrabbit, kangaroo rat, chipmunk, opossum and
mountain beaver.

    Option - Modification of the Terms and Conditions of Registration

    o    Reduction of active ingredient concentration -

         The discussion under the rangeland uses for this method are
applicable here also.

    o    Standardization of baiting and post-baiting procedures  -

         The discussion under "Rangeland Rodents-ground squirrels" for this
method is applicable here also.

    o    Use of dyed bait -

         The discussion under "Rangeland Rodents-ground squirrels" for this
method is applicable here also.

    o    Prohibition in the range of endangered species -
                                    -  89 -

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         The discussion for all species under  rangeland  uses  are applicable
here also.  In addition, the salt marsh harvest mouse  should  be  considered.
No critical habitat has been determined for this  species.   The range is
apparently confined to certain salt marshes and adjoining  habitats around San
Francisco Bay.  No known strychnine uses occur within  this range.   The
prohibition of use within the range should eliminate any potential risks and
have no impact on benefits.


8.  Birds on Cropland

    Option - No Action

    With this option, the potential for risks  to  nontarget organisms would
continue unabated.  No endangered species are  known to be  at  substantial  risk
from these uses of strychnine.  Benefits would be similarly unaffected.

    Option - Cancellation

    This cancellation would apply to the current  state registrations in
California, Nevada, and Wyoming, since strychnine is not federally registered
for these uses.  Since no alternative toxicants are available, cancellation
could result in an increase in crop damage.  The available  alternatives  are
primary repellants or frightening agents and may or may not be as  effective as
strychnine, but comparisons with a toxicant are not possible.

         The risks to nontarget species from strychnine would be eliminated,
and, since no alternative toxicants are available, the use  of substitutes  would
present less risks than strychnine.

         Option - Modification of the Terms and Conditions  of Registration

    o    Reduction of active ingredient concentration -

         As with the uses of strychnine to control mammals, the registered
lables for strychine bait used for the control of birds specify a  range  of
concentrations.  The concentrations differ not only for different  birds, but
also for each bird.  For the available ID™ data for passerines, a reasonable
assumption is that one concentration,  namely the lowest one currently
registered, should be appropriate for all bird control operations  on cropland.
The concentration would thus be 0.20 percent (as per accession number  11019-
09355 for blackbirds in Fresno County,  California)-

    o    Standardization of baiting and post-baiting procedures -
         (See the discussion under "Rangeland Rodents-ground squirrels"on
         page 80.)
                                    - 90  -

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          For the control of birds  in orchards  and  vineyards,  the proce-
dures to  be followed are:

                   bait must be placed in  troughs  no  less  than  three  inches
                   deep (v-shaped with ends blocked to avoid  spillage).

                   troughs must be made removable  so  that  they  can  be cleaned
                   out after each change of bait.

                   troughs must be at least four feet from ground level

                   placement of troughs must be made  near  the edge  of the
                   affected field near the areas where the birds perch and
                   rest, not directly under these  perching places.  Placement
                   of troughs inside the fields must  be avoided.

                   Expose poisoned bait sparingly  - one inch deep in  each trough

                   pick up all remaining bait  at end  of day; burn any bait
                   spillage.

                   pick up and bury or burn of all dead birds at the  end of
                   each day

         For the control of horned larks on crops  the procedures to be followed
are:

                   expose bait sparsely in a depression between bedded crops

                   pick up remaining bait at the end  of day, burn any bait
                   spillage

                   pick up and bury or burn all dead  birds at the end of the
                   day

9.  Birds - on Nonagricultural Sites

    Option - No Action

    With this option, the potential for risks  to nontarget organisms, and
particularly to the peregrine falcon, would continue  unabated.  The benefits
would be similarly unaffected.

    Option - Cancellation

    The impact on benefits from this option would  apparently be limited to
the elimination of a fast-acting control of pigeons in the case of a  possible
local public health issue.  Alternatives are available, but they do not provide
this benefit.
                                    -  91  -

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          The risks from the use of strychnine would be eliminated, and the
 alternatives, with the possible exception of starlicide (registered in
 California only), do not present toxic risks equal to strychnine.  In
 particular, the risks to the peregrine falcon from the use of strychnine for
 pigeon control would be eliminated.

          Option - Modification of the Terms and Conditions of Registration

     o    Reduction of active ingredient concentration -
          (See the discussion under "Birds on Cropland" on page 90.)

          For the control of pigeons on nonagricultural sites, the bait would
 have a strychnine concentration of 0.6 percent as per al,l current federally
 registered labels.

          For the control of house sparrows on nonagricultural sites,  the bait
 would have a strychnine concentration at 0.25 percent (as per accession number
 11198-05259 for Sanoma County,  California).

     o    Standardization of baiting and post-baiting procedures -
          (See the discussions under "Rangeland Rodents-ground squirrels".)

                    pick up  and  burn or bury  any uneaten  bait

                    where uneaten bait is not easily retrievable,  place
                    bait in  trays or v-shaped troughs

                    pick up  and  bury or burn  all dead  birds daily

     o    Prohibition of use in  the  range  of  endangered species -

          1.    Puerto Rican  Plain Pigeon

               A critical habitat has  not  been determined  for  this species.   Its
 range  is  confined to a  relatively small area in  east  central  Puerto Rico  in  and
 around the municipalities of Cidra,  Camerio,  Aguas  Buenas,  Caguas, and Cayey.

               No information  is  available  on the use  of strychnine in  Puerto
 Rico,  but it  is  assumed  to  be negligible.  No  methods are  available to
 eliminate the  risk  to the pigeon, should  strychnine be used,  since the range
 described is  its permanent  residence.   Prohibition  of use  would apparently have
 no impact on  benefits.   The only potential use  would  be for the control of
 pigeons, and  federally registered alternatives are available.

         2.    Yellow-shouldered Blackbird

               A critical habitat has been determined  for this species.  The
bird is concentrated in three areas in  Puerto  Rico, coastal Southwestern  Puerto
 Rico, coastal Northeastern  Puerto Rico, and  Mona Island.   As with the  Puerto
Rican plane pigeon, the extent of strychnine use in the area of the blackbird
is not known, but is assumed to be insignificant.  Thus, no impact on  benefits
                                    -  92 -

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is anticipated  from any action taken.   The  only  option for eliminating risks
would be  prohibition of use.  The only  potential use  would be for the control
of pigeons, and federally registered alternatives are available.

          3.   Peregrine Falcon

              The potential for risk to the peregrine falcon  from
secondary poisoning is of particular concern during strychnine  baiting for
pigeon control.  The Arctic peregrine's migration route could bring  it through
any of the lower 48 States.  The American peregrine breeds west of the
Mississippi River, but its migratory patterns  are not well documented.

              The potential for peregrine falcons to  be exposed to strychnine
during pigeon control operations varies geographically.   In the eastern part  of
the country, the urban location of falcons  that  have  been established  as a
result of the restoration program are generally  well  known.   The  risks can thus
be greatly reduced by prohibition of use of strychnine  for pigeon control
within a five mile radius of aeries.

              In the Rocky Mountain Region,  most potential exposure  to
peregrines from pigeon control is to falcons that winter in or  near  urban
areas.  A prohibition of use for pigeon control  during  the winter months would
therefore greatly reduce the risk to the falcon.

              In California, a critical habitat  has been established for the
peregrine falcon.  Adults are apparently permanent residents  in California,
Oregon, and Washington.  A prohibition  of use  for pigeon control  within a
five mile radius of the critical habitat would greatly  reduce the risk  to  the
peregrine falcons.

              Prohibition of use for pigeon control nationwide  from  mid-March
through April and, from mid-September through  October would protect most Arctic
migrants.

                             D.  Proposed Action

1.  Rangeland Rodents - ground squirrel

    The Agency proposes adoption of the modification  of the terms and
conditions option.  The lack of alternatives,  the potential impact on  benefits,
and the potential for risk reduction, particularly to endangered  species,  are
the major factors in this proposed action.   With certain risk reduction
measures, the Agency concludes that the benefits will outweigh  the risks.

    For this use, then, the Agency proposes the  following modifications:

    a.   Standardize bait concentrations of 0.20 percent active ingredient,
         and a dosage of one level tablespoon/burrow
                                    -  93 -

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b.   Standardize baiting and post-baiting procedures to read:

          do not expose bait where pets, poultry, or livestock are
          present

          do not place bait in piles

          pick up and burn or bury all dead animals

c.   Use bait dyed in accordance with recommendations of the Fish and
     Wildlife Service

d.   Prohibit use for the protection of endangered species as follows:
     species

     Utah prairie dog


     California condor
                             prohibited area

                             Garfield, Iron, Kane,  Piute,  Sevier,  and
                             Wayne Counties, Utah

                             Fresno, Kern, Kings, Los  Angeles,  Merced,
                             Monterey, San Benito,  San Luis  Obispo,  Santa
                             Barbara, Santa Clara,  Santa Cruz,  Stanislaus,
                             Tulare, and Ventura counties, California

                             within one mile of a prairie  dog town or an
                             active prairie dog burrow

                             Alameda, Contra Costa, Fresno,  Kern,  Kings,
                             Merced, Monterey, San  Benito, San  Joaquin,
                             San Luis Obispo, Santa Barbara, Santa Clara,
                             Stanislaus, and Tulare counties, California

                             known gray wolf areas

                             known grizzly bear areas

                             Butte, Colusa, Contra  Costa,  Del Norte,  Glen,
                             Humboldt, Mendocino, Merced,  San Joaquin,
                             Solano, Stanislaus, Sutter, Yolo,  and Yuba
                             counties, California during the months  from
                             October through March.

         Additionally, for the general protection of all endangered
species, the following will be included on all labels:

         "This product must not be used in areas where adverse  impact on
         federally designated endangered or threatened species  is  likely.
         Prior to making applications of this product, the user must  determine
         that such species are not located in or immediately adjacent to the
         area to be treated.  Consult your Regional U.S. Fish and  Wildlife
     Black-footed
     ferret

     San Joaquin
     kit fox
     Gray wolf

     Grizzly bear

     Aleutian Canada
     goose
                                -  94 -

-------
         Service Office  (Ehdangered  Species  Specialist)  or the local Fish and
         Game Office for specific information  on  endangered species."

2.  Rangeland Rodents - prairie dogs

    The Agency proposes adoption of  the  cancellation  of  use option.  The
inability to reduce the risk to the  black-footed  ferret  and the  availability  of
zinc phosphide are the major factors in  this proposed action.  The Agency
concludes that the risks of using strychnine to control  prairie  dogs outweigh
the benefits, and that no risk reduction measures are available  to change the
situation.

3-  Rangeland Rodents - other rodents and lagomorphs

    For deer mice, meadow mice, chipmunks and  woodchucks,  the  Agency
proposes the cancellation of use option.  The  use of  strychnine  for  these uses
presents a risk to non-target species.   The benefits  of  the use  of strychnine
for these pests is very low, chemical alternatives are available for all  four
manmals.

    For the cotton rat, kangaroo rat, and jackrabbit, the  Agency proposes the
modification of terms and conditions option.   The lack of  specific risk
information, and the potential for reducing risks without  impacting  benefits
are the major factors in this proposed action.

    The Agendy concludes that, with  certain risk reduction measures, the
benefits of vising strychnine for this use will outweigh  the risks.

    For these uses, then, the Agency proposes  the following modifications:

    a.   Standardize bait concentrations at:

         for the jackrabbit, 0.28 percent with a dosage  of one tablespoon for
         grain bait or 0.1 percent with  a dosage of four-five alfalfa shoots
         for green bait; for the kangaroo rat  and the cotton rat, 0.16 percent
         with a dosage of three-four tablespoons for  hand  application or
         1/2-3/4 pound per swath-acre for mechanical  application.

    b.   Standardization of baiting  and  post-baiting  procedures  as per
         the proposal for "Rangeland Rodents - ground squirrels."

    c.   Use bait dye in accordance  with recommendations of the  Fish and
         Wildlife Service.
                                    -  95  -

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    d.    Prohibit use,  for  the  protection of  endangered  species,  as
          follows:
         species

         Utah prairie dog
         San  Joaquin
         kit  fox

         Masked bobwhite
         Red wolf
 use

 kangaroo rat
 jackrabbit

 jackrabbit
 kangaroo rat

 jackrabbit
 kangaroo rat

 jackrabbit
 cotton rat
 prohibited area

 See  "Rangeland  Rodents-
 ground  squirrel"

 See  "Rangeland  Rodents-
 ground  squirrels"

 Pima and  Santa  Cruz
 counties,  Arizona

 Chambers,  Orange,  and
 Jefferson  counties,
 Texas;  Cameron  and
 Calcasieu  Parishes,
 Louisiana
         IXisky seaside
         sparrow
 cotton rat
         Cape Sable sparrow  cotton rat
         Mississippi
         sandhill crane
 cotton rat
         Attwater's greater  jackrabbit
         prairie chicken
         Morro Bay
         kangaroo rat
jackrabbit
Brevard county,  Florida
Collier, Eade, and Monroe
counties, Florida

Jackson county,
Mississippi

Aransas, Austin,
Brazoria, Calhoun,
Chambers, Colorado,
DeWitt, Fort Bend,
Galveston, Goliad,
Harris, Jackson,
Jefferson, Lavaca,
Matogorda, Refugio,
Victoria, Waller, and
Wharton counties, Texas

San Luis Obispo county,
California
         Additionally, for the protection of all endangered species, the
same wording for labels proposed for the control of ground squirrels on
rangeland will be applicable here also.
                                    - 96  -

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    Cropland Rodents - ground squirrels
    The proposed action for this use is the same as  for ground squirrels
on rangeland, i.e., modification of the terms and conditions of registration.

5.  Cropland Rodents - prairie dogs

    The proposed action for this use is the same as  for prairie dogs on
rangeland, i.e. cancellation.

6.  Cropland Rodents - other rodents and lagomorphs

    The proposed action for this use is the same as  for other rodents and
lagomorphs on rangeland, i.e. cancellation for use to control deer mice, meadow
mice, woodchucks and chipmunks, and modification of  the terms and conditions of
registration for use to control cotton rats, kangaroo rats, and jackrabbits.

7.  Rodents and Lagomorphs on Nonagricultural Sites

    Tne only uses under this category for which the  Agency concludes that
the benefits will outweigh the risks, with modifications of the terms and
conditions of registration, are ground squirrels on  ditch banks, levees,
canals, and earthen dams, and porcupines in tree nursuries, tree plantations,
and reforestation areas (forests).  For all other site/pest uses under this
category, the Agency proposes cancellation.

For rodents and lagomorphs on nonagricultural sites, the Agency proposes the
following actions:
    rabbits and jackrabbits,
    chipmunks, marmots/
    woodchucks, prairie dogs,
    kangaroo rats, cotton rats,
    meadow mice, marmots,
    mountain beavers,
    opossums
    ground squirrels
sites

grain elevators, crop
storage areas and
facilities, commercial
open dumps, farmsteads,
urban dwellings, ditch
banks, levees, dikes,
canals, earthen dams,
golf courses, parks,
cemetaries, airport turf
runways, military bases,
forests, reforestation
areas, tree plantations
and similar nonagri-
cultural sites

ditch banks, levees,
canals, earthen dams
                                                           action
cancel
modification of
the terms and
conditions of
registration
    porcupines
forests, reforesta-
tion areas, tree
plantations
modification of the
terms and conditions
of registration
                                    -  97 -

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For the control of ground squirrels, the use modifications will be  identical
to those proposed for the control of ground squirrels on rangeland.   For the
control of porcupines, the following modifications are proposed:

              standardization of bait concentration at 5.8 percent  in salt
              blocks

              nail salt block at least ten feet above the ground

              do not use in known gray wolf or grizzly bear areas

    Additionally, for the protection of all endangered species, the same
wording for labels proposed for control of ground squirrels on rangeland will
be applicable here also.

8.  Birds on Cropland

    The Agency proposes the adoption of the modification of terms and
conditions options.  The lack of specific risks to nontarget organisms,  the
apparent low risks to endangered species, the absence of comparative  data  on
alternatives, and the potential for local impact on benefits were the major
factors in this proposed action.

    With certain risk reduction measures, the Agency concludes that the
benefits will outweigh the risks.

    For these uses, then, the Agency proposes the following modifications:

    a.   standardize bait concentrations at 0.20 percent active ingredient

    b.   standardize baiting and post-baiting procedures to read:

         For the control of birds  in orchards and vineyards:

              bait must be placed  in troughs  no less than three inches deep
              (v-shaped with ends  blocked to  avoid spillage)

              troughs must be made removable  so that they can be cleaned
              out after each change  of  bait

              troughs must be at least  four feet from ground  level

              placement of troughs must  be  made near the  edge of the
              affected field near  the areas where the birds perch and
              rest,  not directly under  these  perching places.   Placement
              of troughs inside  the  fields  must be avoided

              expose  poisoned bait sparingly  - one inch deep  in each trough

              pick up all remaining  bait  at end of day; burn  any bait
              spillage
                                    - 98  -

-------
              pick up and burn or bury all dead  birds  at  the  end  of each
              day

         For the control of horned larks on crops:

              expose bait sparsely in a depression  between  bedded crops

              pick up remaining bait at the end  of  day, burn  any  bait
              spillage

              pick up and burn or bury all dead  birds  at  the  end  of the  day

         Additionally, for the protection of all endangered species, the same
wording for labels proposed for control of ground squirrels on rangeland will
be applicable here also.

9.  Birds on Nonagricultural Sites

    The Agency proposes the adoption of the modification  of the terms and
conditions option.  The lack of specific risk information (with the exception
of the risk to the peregrine falcon), the potential for eliminating the risk to
the falcon, and the benefits of potential disease control, were the major
factors in this proposed action.  With certain risk reduction measures, the
Agency concludes that the benefits outweigh the  risks.

    For these uses, then, the Agency proposes the following modificatic >3:

    a.   standardize pigeon bait concentrations at  0.6 percent active
         ingredient

    b.   standardize house sparrow bait concentrations at 0.25 percent active
         ingredient

     c.  standardize baiting and post-baiting procedures  to read:

              pick up and burn all uneaten bait at  the end of each day

              where uneaten bait is not easily retrievable, place bait in
              trays or v-shaped troughs

              pick up and burn or bury all dead birds  daily

    d.   prohibit use for the protection of endangered species as follows:

         species             prohibited area

         Yellow-shouldered   Puerto Rico
         blackbird

         Puerto Rican        Puerto Rico
         Plain Pigeon
                                    - 99  -

-------
         species             prohibited area (Continued)

         Peregrine falcon    In the Eastern U.S:  prohibit use within five
         (pigeon control     miles of aeries
          only)
                             In the Rocky Mountain Region:  prohibit use from
                             November through March

                             In California, Oregon, and Washington prohibit
                             use within five miles of critical habitats.

                             48 contiguous states:  prohibit use during the
                             months from mid-September through October and
                             mid-March through April.

         Additionally, for the protection of all endangered species, the same
wording for labels proposed for control of ground squirrels on rangeland will
be applicable here also.

                             E.   Summary

    For each use of strychnine to control a pest on an outdoor, above-ground
site, the Agency has proposed either cancellation of use,  or a modification of
the terms and conditions of registration.  This section summarizes those
proposed actions.

    For rangeland and pasture uses,  the proposed action for each pest is:

    ground  squirrels   - modification of the terms and conditions of registra-
                         tion

    prairie dogs       - cancellation

    deer mice          - cancellation

    meadow  mice        - cancellation

    chipmunks          - cancellation

    marmots/woodchucks - cancellation

    cotton  rats        - modification of the terms and conditions of
                         registration

    kangaroo rats      - modification of the terms and conditions of
                         registration

    jackrabbits        - modification of the terms and conditions of
                         registration
                                  -  100 -

-------
 For  cropland uses, the proposed activity for each pest is:
 ground squirrels   - modification of the terms and conditions of
                     registration
prairie dogs
deer mice
meadow mice
chipmunks
- cancellation
- cancellation
- cancellation
- cancellation
marmots/woodchucks - cancellation
cotton rats

kangaroo rats

jackrabbits

birds
- modification of the terms and conditions of
  registration
- modification of the terms and conditions of
  registration
- modification of the terms and conditions of
  registration
- modifications of the terms and conditions of
  registration
For nonagricultural site uses, the proposed action for each pest is:
jackrabbits        - cancellation
chipmunks          - cancellation
marraots/woodchucks - cancellation
prairie dogs
kangaroo rats
cotton rats
deer mice
meadow mice
- cancellation
- cancellation
- cancellation
- cancellation
- cancellation
mountain beavers   - cancellation
opossums
rabbits
- cancellation
- cancellation
                               -101  -

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ground squirrels


porcupines


pigeons


house sparrows
- modification of the terms and conditions of
  registration

- modification of the terms and conditions of
  registration

- modification of the terms and conditions of
  registration

- modification of the terms and conditions of
  registration
                             - 102 -

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properties, toxicology and use  in predator and  rodent control.  U.S. Department
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Bell, H.B. and R.W. Dimmick, 1975. Hazards to predators  feeding on prairio
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Cade, T.,  Feb. 29, 1980.  Personal communication.

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Clark, D.O., 1975.  Vertebrate Pest Control Handbook.  California Dept. of Food
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Collins, B.D., 1966.  The effects on wildlife from Norway rat control using
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Cutler, J.V., 1925.  Amount of strychnine  in poisoned finches.  J. Dept. Agr.
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Davison, V.E., 1962.  Taste, not color, draw birds to berries and seeds.
 Audubon Magazine , 346-350.  From rebuttal #91.

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Evans, J., 1962.  United States Department of the Interior, Fish and Wildlife
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Hogdal, P.L. and T.A. Gatz, 1977.  Hazards to  pheasants and cottontail rabbits
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Hines, T. and R.W. Dimmick,  1970.  The acceptance by bobwhite quail of rodent
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Vert. Pest Conf. , 5th, 85-91.                                        	

Howard,  W.E., 1950.   Wildlife depredations on broadcast seedings of burned
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-------
Howard, W.E. and R.E. Marsh, 1973.  Study guide for agricultural pest control —
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acute oral toxicity of 14 pesticides to mallard ducks of several ages.   _J_._
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Wi Idl. Conf. Trans.,  8:408-415.  From rebuttal #82.

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Tucker, R.«. and D.G. Crabtree, June  1970.  Handbook of toxicity of pesticides
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Velsicol Chemical Corporation.

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United States Department of the Interior, Fish and Wildlife Service, Denver
Wildlife Research Center Annual Reports, 1967 and 1968.

United States Department of the Interior, Fish and Wildlife Service, Denver
Wildlife Research Center.  Evaluation of hazards to wildlife associated wiith
aerial 1080 baiting for California ground squirrel.  EPA Interagency Agreement
with FWS.

United States Department of the Interior, Fish and Wildlife Service, Denver
Wildlife Research Center Files, Nov. 4, 1971 memo to the director.

U.S. Department of the  Interior, Fish and Wildlife Service, May, 1974.
Petition proposing the  issuance of a regulation establishing a tolerance for
phosphide from the use  of zinc phosphide in a rodenticide  bait in range
vegetation  in the western United States.  Accession #093967-

United States Department of the Interior.  Human poisonings wiith 1080 for the
years 1946-1949.

United States Environmental Protection Agency, August, 1979.  Pesticide
Incident Monitoring System.  Report No. 211.  Summary of reported pesticide
incidents involving carbon disulfide.

United States Environmental Protection Agency.  Consultation with U.S.
Department of the Interior, Fish and Wildlife Service, March 13, 1978
concerning endangered species likely to be exposed to strychnine.

United States Environmental Protection Agency, June, 1979.  Pesticide  Incident
Monitoring System.  Report No. 180.  Summary of reported pesticide  incidents
involving chlorophacinone.

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United States Environmental Protection Agency.  Pesticide Episode Reporting
System.  Reports of poisonings and mortality data involving strychnine for the
years 1967-1976.  Report No. 70.

United States Environmental Protection Agency.  Registration files.  Report of
accidental  fetal poisoning of a man from 1080.

United States Environmental Protection Agency, August, 1980.  Standard
Operative Procedure 3065.1, Protection of Endangered or Threatened Species
during Pesticide Registration Activities.

Velsicol Chemical Corporation, 1976.  Eighty-day dietary LCgQto bobwhite
quail.  Technical diphacinone final report, Accession #225250,  Ecological
Effects Branch, EPA.

Ward, J.C., Martin, M.,Allred, W., 1942.   The susceptibility of sage grouse to
strychnine.  J. WiIdI. Mgrnt.,  6(1):55-57.   From aappendix to Strychnine PD 1.

Wilbur, S.R., 1980.  Estimating the size  and trend of the California condor
population, 1965-1978.  CaI if. Fish and Game , 66(1):40-48.

Woolington, D..W.,  P.P.  Springer and D.R. Yparraguirre.   1979.   Migration and
Wintering Distribution of Aleutian Geese,  pp. 299-309.   J_n_R.L.  Jarvis and
J.C. Bartonek (eds.).   Management and Biology of Pacific Flyway Geese;  A
Symposium.   OSU Book Stores, Inc., Corvallis, Oregon.

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         Strychn ine RebuttaI Submissions C ited  i n Position Document

Arbaugh, H.L., Dec. 31, 1976. Ar. Chem.  Corp., Portsmouth, Ohio (30000/7 #44).

Bingham, D.J., Mar. 4, 1977. Calif. State Dept. of Food and Agric. (30000/7
#82).

Bourret, L.J., Feb. 28, 1977.  Wyoming State Dept. of Agric., Cheyenne, Wyoming
(30000/7 #91).

Gel Ian, T.. Dec. 31,  1976.  Soda Springs, Idaho  (30000/7 #49).

Clayton, S.E., Agricultural Commissioner, Jan.  14, 1977. Monterey Co. Dept. of
Agric., Salinas, Calif. (30000/7 #56).

Deck. E., Coordinator, Dec. 20, 1976, Office of Environmental Quality
Activities, U.S. Dept. of Agric., Wash., D.C. (30000/7 #7).

Gal I  ion, S., Environmental  Protection Specialist, Dec. 20, 27, 1976. EPA Region
IX,  San Francisco, California (30000/7 #8,8A).

Gauditz, I., Program  Manager, Mar. 3, 1977..Forest Pesticides, Forestry
Research Center, Centralia, Wash. (30000/7 # 85).

Grisham, J.R., Commissioner, Jan 24, 1977.  Siskiyou Co. Dept. of Agric.,
Yreka, California  (30000/7  #58).

Harkness, B.J., President,  Dec. 31, 1976.  Montana Farm Bureau Federation,
Bozeman, Montana (30000/7 #57).

Hooven, E.F., Associate Professor, Jan 3,  1977.  Oregon State Univ., Dept. of
Forest Science, Corvallis,  Oregon (30000/7 #50).

Hoverson, R., Feb  15, 1977.  Boise, Idaho  (30000/7 # 95).

Humphreys, L.M., Dec. 8,  1976.  Korinek Remedy  Company  (30000/7 #2).

Judge, T.L., Mar.  8,  1977.  Office of the Governor, Helena, Montana  (30000/7
#94).

Kaczor, S., Mar. 16,  1977.  J.D. Ehrlich Chem. Co., Inc. (30000/7 #96).

Lou, E.E., Feb. 14, 1977.   Soda Springs, Idaho  (30000/7 # 63).

Lewandowski, E., Fob. 15, 1977.  Boise,  Idaho (30000/7 #93).

Miller, E., Feb. 15,  1977-  Boise,  Idaho (30000/7 #83).

Morrison, H. and W. Morrison, Feb. 25, 1977. Caldwell,  Idaho  (30000/7 #79).

Morrison, J., Fob. 23, 1977.  Caldwell,  Idaho (30000/7 #98).

Pank, L. Staff Biologist, Mar. 7, 1977.  U.S. Dept. of  the  Interior, Fish  and
Wildlife Service,  Wash., D.C. (30000/7 #81).

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Roberts, B.H., Jan. 20, 1977. Weiser,  Idaho  (30000/7  #62).

Rogers, R., Technical Director, Mar. 3,  1977.  B&G Company,  Dallas,  Texas
(30000/7 #  IB, 1C, ID)-

Rydolius, J.A., Reforestation Supervisor, Jan. 3,  1977.   Simpon  Timber Co.,
Arcata, Calif. (30000/7 #51).

Sebesta, O.L., Dec. 31, 1976.  Sebesta Bait Mixing Plant, Mitchell,  South
Dakota (30000/7 # 39).

Spear, P.J., Acting Executive Director, Mar. 4,  1977.  National  Pest Control
Association, Inc., Vienna, Virginia (30000/7 #74).

Stee, R.L., Director of Regulations and  Inspection Division,  Dec.  27,  1976.
South Dakota  Dept. of Agric., Pierre, South Dakota (30000/7  #48).

Stewart, C.W., Feb. 15, 1977.  Boise,  Idaho (30000/7  #71).

Stewart, D.W., Feb 15, 1977.  Boise, ldaho(30000/7 #90).

Stewart, R., Feb. 15, 1977.   Individual  letter (30000/7 #89).

Stout, R.,  Feb. 15, 1977.   Weiser,  Idaho (30000/7 #65).

Trevcott, G., Associate Director, May  16, 1977.  U.S. Dept. of the  Interior,
Wash., D.C. (30000/7 #100).

Wright, K.W., Mar. 7, 1977.  Modoc Co. Dept. of Agric., Alturas, California
(30000/7 #86).
                                               U. S. GOVERNMENT PRINTING OFFICE ; 1980 — 341-085/3941

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