Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note. November 2019

Purpose This guidance note outlines the requirements for landholders to obtain, possess, use and dispose regulated poisons under the Health (Drugs and Poisons) Regulation 1996 (HDPR) approved for use as baiting products (hereafter referred to as baiting products, defined as those containing fluoroacetic acid (1080), strychnine or 4-aminopropriophenone (PAPP)) for the control of invasive pest animals.

Background Under the HDPR, an Endorsement is required to lawfully obtain, possess, use and dispose of poisons such as 1080, strychnine, and PAPP in baiting products. “Endorsement” is the generic term used in the HDPR to describe either a permit for strychnine or an approval for 1080 and PAPP. An applicant will only need to complete one application for one or any combination of these poisons.

The Australian Pesticides and Veterinary Medicines Authority (APVMA) has recently approved PAPP capsules as well as 1080 capsules in ejector devices for use in Queensland. This has increased the choice of baiting products available to landholders. Queensland Health, in collaboration with the Department of Agriculture and Fisheries, has developed an application process under the HDPR to enable these products to be made available to landholders and suitable persons.

Obtaining this Endorsement is a separate process to the coordinated invasive animal management programs operated by local governments. If you are participating in such programs you do not need to apply for an Endorsement under the HDPR. As a landholder you are able to obtain, possess, use and dispose fresh or manufactured baits containing up to 0.03% of 1080 provided by a local government officer who is an authorised person under the Biosecurity Act 2014. You are still, however, required to comply with written instructions you receive with the baits from the local government officer.

You do not need to complete an application form if you intend to only purchase and use approved manufactured baits containing 1080, however you are still required to comply with the APVMA approved label requirements (see Appendix 2 for the List of baiting products).

Please note that a separate application form is required for each property or group of properties that are listed on separate local government rates notices. However, if all the properties that you intend to bait on are in one local government rates notice, you only need to submit one application.

Regulated poisons in baiting products –Endorsement application guidance note Health (Drugs and Poisons) Regulation 1996

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 2

Applying for an Endorsement You may apply to Queensland Health to obtain, possess, use and dispose of baiting products for a period of up to two years. The application form can be found on the Queensland Health website using the following link:

https://www.health.qld.gov.au/system-governance/licences/medicines-poisons/licensing-fees/poison-permits/default.asp There is no fee associated with this application.

You will need to familiarise yourself with the instructions including the ‘Directions for Use’ on the APVMA approved label for the baiting product you are applying for or the APVMA Permit (see Appendix 1) in the case of strychnine. You will also need to submit a number of documents with your application. The required documents are listed in the application form. Please note: your application will not be processed if you do not provide the required documentation.

You may submit your application form and supporting documents by email to licensing@health.qld.gov.au, or by post to the address shown at the end of this document. You must ensure the scanned documents are legible to enable processing of your application.

Please note that strychnine can only be used in pre-plant and fallow land, forests, non-agricultural land and pasture situations.

If you are applying to use the 1080 capsules and PAPP baiting products you are now required to submit certified copies of your competency in:

1. AHCCHM307 – Prepare and apply chemicals (formerly RTC3704A and AHCCHM303); and 2. AHCCHM304 – Transport, handle and store chemicals (formerly known as RTC3705A and

AHCCHM304A).

These competencies are mandatory under the Chemical Usage (Agricultural and Veterinary) Control Act 1988. These competencies are available online or through training workshops held state-wide. If you hold similar qualifications that you think may meet the core components of these modules please contact your local Public Health Unit to discuss further.

Considerations in granting an Endorsement You will be required to provide proof of identity and proof of ownership or legal occupancy of the property where you apply to conduct baiting activities. A scaled map (or survey plan which accurately measures and records the boundaries of your property) indicating sites or areas where baiting will occur, locations of dwellings, water courses, public access, stock routes, etc. must also be provided. This information will be used to conduct a public health risk assessment relating to the use of dangerous poisons on your land. A scaled map can be obtained from your nearest Department of Natural Resources and Mines Business Centre or online (e.g. http://qtopo.dnrm.qld.gov.au/desktop/). Hand drawn maps will not be accepted, but it is acceptable to print a map and hand draw features (such as dwellings or roads) on it. Regardless of where you get your map you must ensure it shows five kilometres of land outside the borders of the property, and must have appropriate scale to identify water courses, roads, dwellings, etc.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 3

An Endorsement will not be granted for use on properties less than 20 hectares in size. Where this criterion cannot be met on an individual property, neighbouring landholders may submit applications to undertake baiting jointly so that the 20 hectares criterion is able to be met. Each property owner will be required to submit a separate, complete application. It will be a condition of Endorsement that such applicants conduct their baiting activities simultaneously to ensure the distance requirements between baits, dwellings etc. can be met.

The quantity of 1080 capsules and PAPP capsules for use in ejector devices and the quantity of strychnine will be restricted depending on the outcome of the risk assessment. The maximum amount of strychnine allowed for baiting is 25g which is sufficient to prepare over 400 baits. For trapping, the quantity of strychnine will be limited to 100g. Requests for greater quantities will be considered upon risk assessment and consultation. However, there will be no restrictions placed on the number of manufactured baits containing PAPP you can obtain, possess, use and dispose.

As part of the consideration of your application, Queensland Health will consult with Biosecurity Queensland and the local government your property is located in. The information sought will include the extent of the invasive animal problem in the area, as well as any previous public health concerns surrounding the use of vertebrate poisons. You are encouraged to participate in the coordinated baiting programmes in your area if available. Please contact your local government for information about the programme.

Scaled map When preparing the scaled map (or maps) as part of your application, we highly recommend you use Queensland Topography, Department of Natural Resources and Mines (http://qtopo.dnrm.qld.gov.au/desktop/) Go to the “Click here to” drop-down menu and select “Search for a property description, suburb or conservation area”, or just search by address. Once you have the property showing on the map it is essential to maintain an extra 5km around the borders of the property. Once you have a map of the right scale and size, select “generate a printable map”, or if your property is on a standard map sheet you can use that instead.

You may have to use the zoom (in or out) function on the map so that five kilometres can be seen around your property. This may affect your ability to indicate the required information on the map. If this is the case it is acceptable to submit two maps. For examples of maps please refer to Appendices one and two.

Issuing of Endorsements Once your application has been assessed you will be notified by mail. Your Endorsement authorises you to obtain, possess, use and dispose of baiting products. If you applied for the 1080 capsules and/or PAPP capsules to be used in the ejector devices, your Endorsement will include the amount of capsules permitted to be obtained during the life of the Endorsement. Your Endorsement will also contain a number of conditions that you are required to comply with. Please read these carefully as you are legally obligated to comply with these requirements.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 4

Manufactured baiting products (containing less than 0.03% fluoroacetic acid) will be available for purchase from retailers licensed to sell poisons such as your local agri-business store. The availability of strychnine is dependent on your local supplier (i.e. your local pharmacy). You must present your Endorsement to the retailer at the time of sale and ensure that the sale quantity is recorded in the ‘Record of Purchase’ for strychnine and 1080 capsules attached to your Endorsement.

You do not need an endorsement to purchase and use manufactured baits containing less than 0.03% fluoroacetic acid. If you are authorised to use 1080 capsules, PAPP capsules and strychnine there will be a table attached to your Endorsement that the retailer will complete at the time of purchase indicating how many capsules have been purchased. If you run out of capsules you will need to make a new application for an Endorsement.

You will be required to follow the ‘Directions for Use’ and label instructions on the baiting products (1080 and PAPP). The 1080 capsules and PAPP capsules and strychnine must be stored in a secure locked storage area and transported in a locked container to prevent access by an unauthorised person. Please note that the distance requirement for laying baits near a formed road in Queensland is 50m. This differs from the distance of 5m in the ‘Directions for Use’ documents.

Please note that you are no longer required to obtain neighbour consent when baiting using strychnine within 2km of baiting site. However, strychnine baits must not be laid within 500m of any dwelling (not including your own). You must also notify all adjoining neighbouring property owners 7 days prior to baiting. This will be a condition imposed on your Endorsement.

A Queensland Health Inspector may undertake site inspections to ensure the conditions of the Endorsement are being complied with.

Expiry of Endorsement An Endorsement will be granted for a period of up to two years. If you have any baits including capsules and strychnine powder left unused at the end of this period it is your responsibility to ensure that you apply for a new Endorsement or alternatively you can dispose of any unused baits in accordance with the disposal of regulated poisons guideline which can be found at https://www.health.qld.gov.au/system-governance/licences/medicines-poisons/poisons-management/default.asp. You will be required to declare quantities of any remaining strychnine, 1080 capsules and PAPP capsules on your renewal application.

If the information you provided in your last application has not changed you can apply for a renewal of your Endorsement and you will be required to make a declaration to this effect on the application form. If the information has changed e.g. you have sold a parcel of land, you will be required to submit a full application. If you have not previously submitted a map as described above you will be required to submit one and make the declaration.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 5

Verification of documents Copies of the required documents to support the application for an Endorsement must be verified. Below is the list of individuals that are accepted to verify documents.

• Health professionals: Medical doctor, Dentist, Medical practitioner, Nurse, Optometrist, Pharmacist, Physiotherapist, and Psychologist.

• Public Health Unit Officer

• Legal professions: Legal practitioner, Patent attorney, and Trademarks attorney. • Court positions: Bailiff, Justice of the Peace, Judge, Magistrate, Registrar, or Deputy

Registrar, Clerk, Master of a court, and CEO of a Commonwealth court. • Commissioner for Affidavits, or Commissioner for Declarations (dependent on

jurisdictions) • Government representatives (elected): Federal, State or Territory or Local. • Public servants: Federal, State or Territory or Local – employed for five years or more.

• Permanent employees of the Australian Health Practitioner Regulation Agency • Bank officer, building society officer, credit union officer, finance company officer –

employed for five years or more • Veterinary surgeon • Accountant (member of ICA, ASA, NIA or CPA, ATMA, NTAA)

• Minister of religion or marriage celebrant • Member of:

− Chartered Secretaries Australia,

− Engineers Australia, other than at the grade of student, − Australian Defence Force (an officer; or a non-commissioned officer with 5+ years of

continuous service; a warrant officer), and − Australasian Institute of Mining and Metallurgy.

• Notary public

• Holder of a statutory office • Police officer

• Sheriff or Sheriff’s officer • Teacher (full-time) at a school or tertiary education institution

The verifying officer must be contactable during normal working hours.

Further information For further information you can contact the Department of Health by phone on (07) 3328 9310, or by email at environmentalhazards@health.qld.gov.au. Alternatively you can contact your nearest Queensland Health Public Health Unit, a list of which can be found on our website: https://www.health.qld.gov.au/system-governance/contact-us/contact/public-health-units/default.asp

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 6

Appendix 1

PERMIT TO ALLOW SUPPLY AND USE AN AGVET CHEMICAL PRODUCT TO CONTROL WILD DOGS AND FOXES IN QUEENSLAND ONLY

PERMIT NUMBER -PER14004

This permit is issued to the Permit Holder in response to an application granted by the APVMA under section 112 of the Agvet Codes of the jurisdictions set out below. This permit allows a person, as stipulated below, to use the product in the manner specified in this permit in the designated jurisdictions. This permit also allows any person to claim that the product can be used in the manner specified in this permit.

THIS PERMIT IS IN FORCE FROM 1 JULY 2013 TO 31 MARCH 2019.

Permit Holder: BIOSECURITY QUEENSLAND 41 BOGGO ROAD DUTTON PARK QLD 4102 Supplier:

Only persons authorised by the Chief Executive Queensland Health may supply this poison. Persons who can use the product under this permit: Only persons authorised by Chief Executive Queensland Health may use/apply this poison.

Product: ANY PRODUCT CONTAINING EITHER: • 975 g/kg STRYCHNINE HYDROCHLORIDE as its only active constituent

OR • 999 g/kg STRYCHNINE ALKALOID as its only active constituent.

Conditions: • Authorised users involved in the application of strychnine, under this permit, must read,

understand and comply with: Document prepared by Queensland Health on the “Requirements for possession and use of strychnine for wild dog and fox control in Queensland” (https://www.health.qld.gov.au/publications/public-health/industry-environment/pest-management/strychnine-requirements.pdf ).

• Apply baits in accordance with those directions and conditions as contained in either: Attachment 1: FOR THE PREPARATION AND USE OF A STRYCHNINE TREATED CLOTH FOR THE CONTROL OF WILD DOGS & FOXES WHEN USED IN CONJUNCTION WITH A WILD DOG or FOX TRAP OR Attachment 2: FOR THE PREPARATION AND USE OF A STRYCHNINE BAIT FOR THE CONTROL OF WILD DOGS & FOXES

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 7

Issued by the Australian Pesticides and Veterinary Medicines Authority. PER14004 Permit Version 2 Page 1 of 3

ATTACHMENT 1

FOR THE PREPATION AND USE OF A STRYCHNINE TREATED CLOTH FOR THE CONTROL OF WILD DOGS & FOXES WHEN USED IN

CONJUNCTION WITH A WILD DOG OR FOX TRAP

Directions for Preparation and Use: Cloth Preparation: to contain: 100-500 mg STRYCHNINE HYDROCHLORIDE OR STRYCHNINE ALKALOID PER CLOTH. • Prepare impregnated cloth by cutting either cotton or close weave hessian material into

strips 50mm wide by 200mm long. • Lay a maximum of 100mg of strychnine in the long centre of the strip finishing no less

than 25mm from each end. • Carefully fold the cloth so that the strychnine is contained in the centre. • Place the folded cloth in a sealed leak proof container. • Prior to setting trap attach the folded cloth to one jaw of the trap using tie wire or plastic

ties to secure it in place. • Destroy any affected animals found and dispose of them and remaining cloth strips and

other contaminated material by deep burial. Alternatively, a strip of hessian approximately 4-6 cm wide and 20-30 cm long should be wound around the trap jaw, impregnated with 100-500 mg strychnine powder and secured to the jaw with wire.

Use: Prepared cloths may only be used in conjunction with a dog trap in the following situations: Pre-plant and fallow land, forests, non-agricultural land and pasture situations only. Attach 1 or 2 treated cloths to the jaws of traps. Jurisdiction: QLD only. Other conditions: • DO NOT store prepared cloths.

• Prepare sufficient cloths for immediate use only.

• Users must adhere to all conditions set down in the authorisation issued by the Chief

Executive Queensland Health governing strychnine use and the occupational health and safety requirements necessary to ensure safe handling and use.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 8

• THIS PERMIT provides for the use of a product in accordance with conditions imposed

by the Chief Executive Queensland Health.

• PERSONS who wish to prepare for use and/or use products for the purposes specified in this permit must read, or have read to them, the details and conditions of this permit.

ATTACHMENT 2

FOR THE PREPARATION AND USE OF A STRYCHNINE BAIT FOR THE

CONTROL OF WILD DOGS & FOXES

Directions for Preparation and Use: Bait preparation: to contain: 60 mg STRYCHNINE HYDROCHLORIDE OR STRYCHNINE ALKALOID PER BAIT.

• Prepare using approximately 250 grams piece of boneless meat. • Make a small cut down the centre of the bait with a sharp knife and place in the centre of the bait 60mg of strychnine. • Place the strychnine well inside the bait. • Close the cut and allow the bait to stand for two hours to enable the cut partially seal. • Keep baits in a closed leak proof container until they are laid. • Place bait or baits in an area known to be frequented by the target animal. • Tie or bury the bait to limit non-target removal. • Retrieve baits after 7 days or when the target animal has been killed. • Destroy any affected animals found. • Dispose of target animals and uneaten baits and other contaminated material such as

used containers by deep burial.

Use: Prepared baits may only be used in the following situations: Pre-plant and fallow land, forests, non-agricultural land and pasture situations only. DO NOT exceed 5 baits per hectare. Jurisdiction: QLD only. Other conditions:

• DO NOT store prepared baits.

• Prepare sufficient baits for immediate use only. • Users must adhere to all conditions set down in the authorization provided by the Chief

Executive Queensland Health governing strychnine use and the occupational health and safety requirements necessary to ensure safe handling and use.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 9

• THIS PERMIT provides for the use of a product in accordance with conditions issued

by the Chief Executive Queensland Health.

• PERSONS who wish to prepare for use and/or use products for the purposes specified in this permit must read, or have read to them, the details and conditions of this permit.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 10

Appendix 2

List of baiting products containing fluoroacetic acid registered for use in Queensland

Name Constituent statement

% sodium fluoroacetate

Target species

Approval required to buy and use

Canid Pest Ejector wild dog capsules

6g/L 0.6 Wild dogs Yes

Canid Pest Ejector fox capsules

3g/L 0.3 Foxes Yes

X-IT 1080 Wild Dog Bait

0.12g/kg 0.012 Wild dogs No

Foxshield Fox Bait 0.085g/kg 0.0085 Foxes No

PAKS 1080 Concentrate

30g/L 3 No

Pigout Feral Pig Bait 0.3g/kg 0.03 Wild pigs No

PAKS DE-K9 1080 Wild Dog Bait

0.2g/kg 0.02 Wild dogs No

PAKS DE-Fox 1080 Fox Bait

0.125g/kg 0.0125 Wild foxes No

Pro-Bait 1080 1080 Fox Bait

0.085g/kg 0.0085 Foxes No

Doggone Wild Dog Bait

0.1g/kg 0.01 Wild dogs No

Notes

1. The HDPR restricts the use of fluoroacetic acid that can be used without an Endorsement to baiting products containing less than 0.03% of fluoroacetic acid

2. This list is current as of 13 December 2017. Please check the APVMA’s Public Chemical Registration Information System Search at https://portal.apvma.gov.au/pubcris.

3. Strychnine and PAPP are also registered for use in baiting products.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 11

Appendix 3 Here is an example of a large property for which it’s possible to see roads, water courses, etc., as well as the five kilometre radius. For the purposes of an example only we have used Undara Volcanic National Park. For reference, the total area of this park is over 70,000 hectares.

Regulated poisons in baiting products –Endorsement application guidance note - Health (Drugs and Poisons) Regulation 1996 - Regulated poisons in baiting products –Endorsement application guidance note Page 12

Appendix 4 Here we used Tewantin National Park as an example of a property which is both very small, and is nearby to residential settlement, i.e. peri-urban.

The upper picture uses Google Maps, satellite view (there are other satellite view services available online) to show the relevant Public Health Unit where there are settlements nearby.

The second map shows the property’s topography and features marked by hand. As mentioned earlier, this is a perfectly acceptable method to indicate your map’s features. The map itself was generated from QTOPO and originally printed on A4 paper, and in colour to help to distinguish features. For reference, the total area of this park is approximately 50 hectares.

© State of Queensland (Queensland Health) November 2019 creativecommons.org/licenses/by/3.0/au