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PLEASE SEND A LETTER BY MARCH 5th, 2008 to the EPA supporting the petition to ban. (Sample comment letter and submission instructions below.)

A branch of the U.S. Department of Agriculture called Wildlife Services uses sodium cyanide and Compound 1080 to kill predators. But the risks associated with these poisons are great and vastly outweigh any benefits.

Both chemicals are biological warfare agents. The Nazis commonly used sodium cyanide, and Compound 1080, a colorless, odorless, tasteless, and water-soluble poison, is banned in several countries. Lethal doses are very small, and the EPA labels both toxicants as Category 1, the highest level. For instance, the amount of toxic material found in one livestock “protection collar” could kill between two and six 150-pound people.

In January 2007, Sinapu, Public Employees for Environmental Responsibility, and several conservation and health organizations petitioned the EPA to ban M-44 sodium cyanide capsules and Compound 1080 livestock protection collars under federal law because they threaten wildlife (including threatened or endangered species), people, and pets, and pose a bioterrorism hazard.

M-44s are spring-loaded devices topped with bait lures. When an animal tugs on the bait, a spring sprays sodium cyanide powder into the animal’s mouth. The cyanide turns into gas once it mixes with moisture from the mouth that is readily absorbed into the lungs. After less than two minutes, a victim of an M-44 device dies.

* Animals typically killed by M-44s include badgers, bears, birds, bobcats, coyotes, foxes, dogs, opossums, marmots, raccoons, ravens, ringtails, and skunks. 

* According to EPA records, five Wildlife Services employees and at least five unsuspecting citizens people have been accidentally exposed to sodium cyanide after triggering devices or coming into contact with pets that had been exposed.

* M-44s have also killed endangered species, such as California condors and wolves.

Compound 1080, banned in 1972 by President Richard Nixon, was returned to use under the Reagan Administration for use in livestock protection collars, which are rubber bladders that are strapped onto the head of sheep or goats:

    * Compound 1080 is highly toxic to both birds and mammals. Scavengers that feed on the head or neck area of dead sheep wearing livestock protection collars are poisoned. Carcasses contaminated by 1080 must be handled as hazardous waste.

    * Death by 1080 is horrific, painful, and lengthy (usually between 3 to 15 hours).

    * Livestock protection collars are problem-plagued. They are often lost and they are easily punctured by trees, cacti, fences, or rocks.

Several audits by the Office of Inspector General found Wildlife Services maintained sloppy inventory control of these highly lethal agents and could not properly account for stockpiles. In November 2007, Wildlife Services itself admitted it had endured a "wake of accidents" that involved "hazardous chemicals".

Predators kill a tiny fraction of the nation’s livestock – many more livestock die unintentionally from weather, birthing complications or rustlers. Mammalian carnivores killed 0.18% of the total U.S. cattle production in 2005, and 3% of the total sheep production in 2004. By comparison nearly 4% of cattle and 5% of sheep died from non-predator causes. Because these figures are so small, Wildlife Services cannot justify the existence of these two poisons given the risks they pose.

There are a host of non-lethal controls such as fences, pens, sheds, bells, guard animals, and electronic devices that are far more practical and sustainable over the long term.

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1.  Go to http://www.regulations.gov/search/index.jsp,

2.  Paste in  "hq-opp-2007-0944" under the blue "Comment or Submission" tab and  click "go". 

3.  A page will open that shows a series of “comment submitted by . . . ” 

4.  Under each of these comments, you will see a line that says “send a comment or submission” followed by a yellow bubble. Click on this line or bubble. You will then see a screen that will allow you to either enter or upload your comment.  

5.  You may also mail to the address below -- the comment must be received by March 5th.

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SAMPLE LETTER

Date

Office of Pesticide Programs, Regulatory Public Docket (7502P)

Environmental Protection Agency, 1200 Pennsylvania Avenue, NW

Washington, DC 20460-0001

Re: Docket Number EPA-HQ-OPP-2007-0944

To Whom it May Concern:

M-44s (sodium cyanide) and Compound 1080 should be banned. These highly toxic substances pose an imminent hazard to people, wildlife (including those species that are considered threatened and endangered), and pets.

Despite the biological terror risks from Compound 1080 and sodium cyanide, the agency charged with maintaining their inventories and placing them in the field has had numerous documented problems with their inventory control.  In November 2007, the U.S. Department of Agriculture's Wildlife Services admitted that it had a "wake of accidents" involving "hazardous chemicals", and the agency failed several audits by the USDA Office of Inspector General. 

Given that few predators actually even kill livestock each year and that livestock growers have access to more effective, non-lethal methods such as guard animals, sheds, pens, fences and electronic devices to protect livestock, these poisons should be banned. Chemical warfare is unneeded to protect livestock, and the risks they pose are far too great.

Because these toxicants pose unreasonable hazards and risks, they should be banned as predator poisons in the United States.

Sincerely, 

Name

Address

Email

Thanks to Sinapu for this alert.