Regulated poisons in baiting products Endorsement application guidance note - Queensland Health

Health Act 1937
Regulated poisons in baiting products
                                                                           Health (Drugs and Poisons)
Endorsement application guidance note                                                 Regulation 1996

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 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.

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. AHCCHM303 – Prepare and apply chemicals (formerly RTC3704A and AHCCHM303A); 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.
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

 HDPR RPBP GN v1 February 2018                                                                 -2-

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 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 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.
Manufactured baiting products (containing less than 0.03% 1080) 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% 1080. If you are authorised to use 1080 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.

 HDPR RPBP GN v1 February 2018                                                                  -3-

You will be required to follow the ‘Directions for Use’ and label instructions on the baiting products
(1080 and PAPP). The 1080 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
and 1080 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.

 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

 HDPR RPBP GN v1 February 2018                                                                 -4-

   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

 HDPR RPBP GN v1 February 2018                                                            -5-

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

Issued by the Australian Pesticides and Veterinary Medicines Authority.

PER14004                             Permit Version 2                                          Page 1 of 3

 HDPR RPBP GN v1 February 2018                                                                         -6-

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.

    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.

PER14004                                 Permit Version 2                                         Page 2 of 3

 HDPR RPBP GN v1 February 2018                                                                             -7-

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.

       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.

PER14004                                      Permit Version 2                                  Page 3 of 3

HDPR RPBP GN v1 February 2018                                                                          -8-

APPENDIX 2

  List of baiting products containing fluoroacetic acid registered for use in Queensland
 Name                   Constituent      % sodium        Target               Approval
                        statement        fluoroacetate species            required to buy
                                                                              and use
 Canid Pest Ejector wild   6g/L              0.6                Wild dogs                 Yes
 dog capsules
 Canid Pest Ejector fox    3g/L              0.3                Foxes                     Yes
 capsules
 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                 30g/L             3                                            No
 Concentrate
 Pigout Feral Pig Bait     0.3g/kg           0.03               Wild pigs                  No

 PAKS DE-K9 1080 Wild      0.2g/kg           0.02               Wild dogs                  No
 Dog Bait
 PAKS DE-Fox 1080 Fox      0.125g/kg         0.0125             Wild foxes                 No
 Bait
 Pro-Bait 1080 1080 Fox    0.085g/kg         0.0085             Foxes                      No
 Bait
 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 (sodium fluoroacetate).

   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.

HDPR RPBP GN v1 February 2018                                                                    -9-

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.

HDPR RPBP GN v1 February 2018                                                                - 10 -

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.

         HDPR RPBP GN v1 February 2018                                                                         - 11 -