The EPA is seeking public comments requesting that the Agency issue a Notice of Intent to Cancel the registration of M-44 sodium cyanide capsules and sodium fluoroacetate (commonly known as "compound 1080"). The Petitioners request this action to obtain what they believe would be proper application of the safety standards of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The EPA extended the comment period from January 16, 2008 to March 5, 2008.
The AVMA believes strongly that federal and state agencies that deal with wildlife and domestic animal interactions should be required to use science-based evidence and peer-reviewed research to direct their policies and regulations. The AVMA recommends that the EPA perform an in-depth quantitative or semi-quantitative risk analysis on these products and their alternatives relative to human safety and public health, animal welfare, wildlife populations, livestock production, and economic and environmental consequences. This risk analysis should clearly identify all hazards (a full hazard analysis should be performed), identify and weigh all risks and benefits of potential impacts, effects and consequences, include full details of appropriate risk management strategies (mitigating actions for avoiding potential adverse consequences), identify and evaluate the viability and impacts of any alternatives, and include a plan for communicating the results of this risk analysis to all stakeholders.
The AVMA believes that using science-based evidence will allow the EPA to justify whether the registration of M-44 sodium cyanide capsules and sodium fluoroacetate should be cancelled or continued.
|
= AVMA/SAVMA Members Only
