The USDA's War on Wildlife

Photo of severed heads of 11 cougars killed by Wildlife Services

Cougars killed by Wildlife Services.
DETAILS


We're working to reform an utterly misnamed program within the USDA called "Wildlife Services." They have historically killed millions of wild animals each year using methods that endanger humans and kill countless pets. Their methods are also cruel, indiscriminate, ineffective, and funded by tax dollars.


Overview & Kill Data

Wildlife Services is a strategically misnamed federal program within the USDA that wastes millions of dollars each year killing wild animals with traps, snares, poisons, gas, and aerial gunning at the request of corporate agriculture and the hunting lobby. According to their official reports, they have slaughtered close to 30 million animals in just the last decade. Even worse, we've had whistleblowers tell us repeatedly that Wildlife Services' real kill numbers are significantly higher, just not reported.

In 2022 alone they claim to have killed over 1.8 million animals, including 384,300 native wild animals. 2022 kills include the following vital native predators:

  • 56,089 coyotes (plus unknown # of pups in 200 destroyed dens)
  • 2,432 foxes
  • 515 bobcats
  • 450 black bears
  • 219 gray wolves
  • 205 mountain lions (cougars)
  • 7 grizzly bears (federally protected)

The officially released data on animals killed is available on the USDA website. The presentation is not exactly user-friendly, which is telling.

Wildlife Services policies and procedures have been questioned almost since the inception of the program. Although livestock damage is a valid concern, Wildlife Services also kills animals for eating flowers and pet food, digging in gardens, frightening people, and other concerns that could easily be addressed by nonviolent methods. And Wildlife Services runs programs to control bird damage, primarily in the eastern U.S. and at airports, as well as programs to remove damaging non-predatory wildlife. Wildlife Services programs operate on both private and public lands. See Program Directives

Wildlife Services wastes millions of taxpayer dollars by spending far more to kill predators than the actual damage those predators cause. Scientific proof that Wildlife Services practices control livestock damage is markedly lacking.

Despite the opposition of environmentalists and concerned citizens, and a series of scathing advisory reports over the years, Wildlife Services has survived and prospered, primarily as a pet program of the powerful livestock industry. In recent years, Wildlife Services has been branching out to increase its programs to remove wildlife from urban areas and to promote itself to the public and to schools and other organizations.

The agency has refused Congressional requests for transparency and has refused to account for their spending. Changing the barbaric, indiscriminate and wasteful predator control methods used by Wildlife Services is a primary focus of our legislative work and public outreach. We have gained a lot of traction in recent years, and the work continues.

In the News

Sacramento Bee Exposé on Wildlife Services Leads to Call for Congressional Investigation

We worked for several years with Tom Knudson, a Pulitzer Prize-winning journalist from the Sacramento Bee, on an exposé on USDA Wildlife Services' out-of-control "predator control" program. The Bee came through with an impressive, in-depth piece of investigative journalism indicting this brutal government program, along with a number of insightful editorials and features linked below:

Sacramento Bee Exposé

Sacramento Bee Editorials

Sacramento Bee Follow-up Articles

Sacramento Bee Videos

 

*NOTE: The request for a Congressional investigation and oversight hearings on Wildlife Services mentioned above is an effort we have worked on intensively for many years. In their letter to the Chairman of the Committee on Oversight and Goverment Reform, the two U.S. Representatives we've been working with—Peter DeFazio (D-Oregon) and John Campbell (R-Irvine)—cite the program's waste of federal dollars, harm to ecosystems, and secrecy regarding practices and spending. Read letter to Committee Chairman, Darrell Isssa. We also worked for over a year with the family in Texas who lost their dog to the M-44 placed by the Wildlife Services employee being fined. Read Bella's story

Victims of Wildlife Services (aka, your tax dollars at work)

The following links and photos illustrate the very real risk Wildlife Services' traps and poisons pose to wildlife, people, and their pets. Most show animals injured or killed as the result of Wildlife Services' methods.

WARNING: Many pictures are very graphic and may not be suitable for children.

History

Animal Damage Control (ADC) began in 1886 as a program to advise people on how to control damaging birds. It began killing predators in 1914 and has continued to do so ever since.

ADC has been the subject of scathing reviews by many bodies: the American Society of Mammalogists in 1930, the Advisory Board on Wildlife Management for the Department of the Interior in 1963, the Advisory Committee on Predator Control for the Department of the Interior in 1971, and the Animal Damage Control Policy Study Committee for the Department of the Interior in 1978.

While these hearings have been harshly critical of ADC’s predator-killing policies, little substantive change has resulted. For a time, poisons were banned, but the bans have been rescinded for the most part, with only widespread broadcasting of Compound 1080 and strychnine still unpracticed. ADC’s response to anti-poison campaigns in the ‘80’s was to facilitate its move from the Department of the Interior, U.S. Fish and Wildlife Service, which livestock owners felt was too soft on predators, to the presumably less "predator-friendly" Department of Agriculture.

Wildlife Services Chronology

1886 - USDA creates the Branch of Economic Ornithology and Mammalogy, after interviewing farmers about bird damage. Programs concentrate on bird damage and control, and researching poisoning of house sparrows. No direct work conducted.

1890 - Name changed to Division of Ornithology and Mammalogy

1896 - Name changed to Division of Biological Survey

1905 - Name changed to Bureau of Biological Survey. Advice on coyote and wolf control becomes a priority.

1913 - Direct control efforts begin, controlling plague-bearing rodents.

1914 - Direct predator control work begins.

1915 - Congress allots $125,000 for predator control.

1916 - Eradication Methods Laboratory opens in Albuquerque for poison research.

1921 - Laboratory moves to Denver, CO. Years later, it becomes the still existing Denver Wildlife Research Center, which still invents new wildlife killing poisons and devices.

1924 - Name changed to Division of Predatory Animal and Rodent Control (PARC).

1930 - American Society of Mammalogists issues a paper condemning PARC. This paper almost lead to $1 million in Federal funds being canceled. Congress holds hearings on PARC.

1931 - After the hearings, President Hoover signs the Animal Damage Control Act of 1931, which authorizes direct and cooperative control programs by PARC. This is still the primary statutory law under which ADC operates today.

1934 - Name change to Division of Game Management, Section of Predator and Rodent Control.

1936 - Pocatello Supply depot, which manufactures poisons, traps, etc., opens in Idaho.

1938 - Name change to Division of Predator and Rodent Control (PARC).

1939 - PARC is transferred from USDA to the Department of the Interior, Fish and Wildlife Service.

1948 - Name change to Branch of Predator and Rodent Control.

1963 - After growing criticism from environmental groups, Secretary of the Interior Stewart Udall appoints the Advisory Board on Wildlife Management to look into predator control in the U.S.

1964 - "Predator and Rodent Control in the United States", usually referred to as the Leopold Report, after advisory committee member A. Starker Leopold, is published. The report was sharply critical of predator control as being indiscriminate, nonselective, and excessive. The report led to only minor, primarily administrative, changes in predator control practice. Another name change made, this time to the euphemistic Division of Wildlife Services.

1970 - Faith McNulty writes "Must They Die?", which criticizes ADC’s role in endangering the black-footed ferret.

1971 - "Slaughter the Animals, Poison the Earth", a book highly critical of ADC, by Jack Olsen is published. Lawsuits from animal welfare groups over excessive poison use lead to the appointment of the Advisory Committee on Predator Control, headed by mammalogist Stanley Cain.

1972 - The Cain report is published. It calls for an end to the use of poisons, and states that the benefits of predator control programs are highly exaggerated. Fifteen recommendations were made, including banning poisons. As a result, President Nixon signed Executive Order 11643, which banned the use of poisons by federal agents and on federal lands. The Environmental Protection Agency cancels all registrations for Compound 1080, thallium, sodium cyanide, and strychnine.

1973 - The Endangered Species Act is passed.

1974 - Name changed to Animal Damage Control.

1975 - Gerald Ford amends the Executive Order to allow usage of M 44’s.

1976 - Gerald Ford amends the Executive Order to allow usage of sodium cyanide.

1978 - Yet another committee is appointed by the Department of the Interior to study ADC—the Animal Damage Control Policy Study Committee. The report was extremely critical of the ADC program, and called for it to be terminated. The Department of the Interior then issued "Predator Damage in the West A Study of Coyote Management Alternatives".

1979 - The report leads to an order from Secretary of the Interior Cecil Andrus to stop denning and research on Compound 1080 and to consider non-lethal control methods. ADC issues its firs Environmental Impact Report.

1980 - "Incident at Eagle Ranch" by Donald Schueler, a book exposing unethical and illegal predator control practices in Texas, is published. The Western Regional Coordinating Committee, composed of ADC employees and University Extension personnel who used ADC services, opposes Andrus’ policy and calls for a transfer of ADC to USDA, saying that the Department of the Interior does not respect the needs of the livestock industry.

1981 - The EPA holds hearings on ADC. Secretary of the Interior James Watt rescinds the ban on denning. President Reagan signs an executive order revoking President Nixon’s ban on poisons.

1985 - Pressure builds to return ADC to USDA.

1986 - Legislation passes and ADC returns to USDA under the Animal and Plant Health Inspection Service (APHIS). Yet another panel is formed by the USDA to study ADC--the National Animal Damage Control Advisory Committee. Out of 20 members, one is an environmentalist and one an animal welfare advocate. Among other panelists are representatives of the livestock, timber, and fur industries.

1989 - ADC begins official claims that its policy is "integrated pest management".

1990 - The U.S. Fish and Wildlife Services Law Enforcement discovered Wildlife Services’ illegal trade of poisons, including Compound 1080. This investigation was called the “Wyoming Sting”.

1990 - Draft Environmental Impact Statement is issued. GAO report finds that ADC kills coyotes even when damage has not occurred.

1993 - Environmental Impact Statement issued.

1994 - GAO investigation finds that ADC uses primarily lethal control methods.

1998 - For 24 hours Wildlife Services’ Lethal Control Program was in jeopardy of being completely eliminated. A bill introduced by Congressman Peter DeFazio of Oregon passed in the House that would have cut all federal funding for lethal predator control. The amendment passed 229 to 193. Unfortunately, after passage, powerful Republican house members Bob Smith of Oregon and Joe Skeen of New Mexico worked the phones overnight with the help of the American Farm Bureau to invalidate this vote. In an unprecedented move, they called for a revote the following day based on a technicality in amendment wording. In the revote the bill failed 232 to 191.

2006 - An audit conducted by the USDA Office of Inspector General found that biological agents and toxins used by Animal and Plant Health Inspection Service to kill wildlife they consider a nuisance are poorly safeguarded. (Wildlife Services is a branch of APHIS.) The audit faulted the agency for: 1) failing to keep accurate inventories of agents or toxins, 2) not restricting access to agents or toxins, and 3) not having complete security plans. Auditors visited 10 of 75 registered entities where agents are kept and found that none of the 10 complied with security regulations.

Financing

Wildlife Services costs Americans millions of tax dollars annually to kill approximately 100,000 predators using methods that are ineffective and cruel.

Who benefits? Many western ranchers enjoy this subsidy but they are under no obligation to change their livestock management practices to reduce predator conflicts.

Methods

Leghold traps

Leghold traps work by catching the target animal by the toes, foot or leg with a tightly-gripping metal trap, usually chained to a stake in the ground. The trap may be lightly padded. Trapped animals suffer severe injuries, exposure, thirst, and hunger.

Conibear Traps

Conibear traps are a "quick-kill" trap that crushes an animal to kill it. They are primarily used for water animals such as beaver and muskrat. Pets have been found in these traps--some still alive. Meet a Conibear trap victim.

Snares

ADC uses two types of snares, which are not differentiated in the statistics. Foothold snares are designed to catch large animals by the foot and hold them. They pose less of an injury risk than legholds, although there are still problems with exposure, etc. This type of snare is used mainly on bears and mountain lions, and occasionally coyotes.

The other type of snare is a killing snare, which is designed to catch an animal by the neck and strangle it. These snares also catch animals around the body, with lethal results. These are used to catch many types of smaller animals and coyotes.

Cage traps

Although cage traps may seem innocuous, it must be noted that the majority of animals Wildlife Services traps in them are killed, not released. Wildlife Services uses cage traps primarily for "cosmetic" and liability issues in urban areas.

Aerial gunning

Wildlife Services kills thousands of coyotes and red foxes by chasing them down and shooting them from helicopters and fixed-wing aircraft.

Shooting

Many predators are killed by calling and shooting, which is the use of a call making a sound resembling a prey animal to lure predators in close enough to be shot. Others are simply shot outright.

Hunting dogs

Some dogs are used to track and tree raccoons, bears and mountain lions. Others kill animals such as coyotes. "Decoy dogs" are also used to lure coyotes in to be shot.

Compound 1080

Compound 1080, whose chemical name is sodium fluoroacetate, is a tasteless, odorless, colorless poison that is especially lethal to canines but is extremely poisonous to all mammals.

In the past, large chunks of meat were baited and left out where they killed any predator or scavenger that ate them. At present, the only legal use of Compound 1080 is in "livestock protection collars" (LPC’s), which are rubber bladders that are filled with a water solution of 1080 and placed around the necks of sheep or goats. However, ADC employees have been convicted in the past for illegally trading in 1080. There is a widespread belief by federal investigators that a black market for both still exists.

Coyotes normally attack sheep by biting them in the neck. When a coyote punctures an LPC, a few drops of the poison enter the coyote’s mouth. The remainder drips onto the wool and into the torn flesh of the target sheep (which invariably dies) and onto the ground or plants where the sheep is attacked.

The poisoned coyote can take hours to die. While in most species 1080 kills by causing ventricular fibrillation or other cardiac problems, in canines death is preceded by vomiting, convulsions, severe abdominal pain, staggering, whimpering, and drooling. The meat that poisoned coyotes vomit up is extremely toxic to scavengers. In the days when 1080 was used to bait carcasses and frequently poisoned dogs, the vomit from one dog sometimes wiped out whole packs of hunting hounds.

While Wildlife Services is required to attempt to find poisoned coyotes, less than 10 percent are recovered. These carcasses serve as poison bait stations to scavengers, as does that of the dead sheep, which under regulations can remain on the range as long as a week. In addition, the collars are often punctured by barbed wire or vegetation, or simply fall off the sheep.

According to the Predator Project (now Predator Conservation Alliance, a wildlife advocacy group in Bozeman Montana), "Historically, there has been insufficient monitoring and record-keeping of the LPC [Livestock Protection Collar]. Texas was one of the first states to reissue the LPC and is its greatest proponent. In a report issued by the Texas Center for Policy Studies ("TDA's Failed Enforcement for Predator Poisons," April 1995), the Texas Department of Agriculture (TDA) was found to be keeping inconsistent and contradictory records of LPC use within the state. The Texas Center for Policy Studies (TCPS) found that 1) in 1994, TDA did only 50% of the required inspections of LPC users, and 2) TDA has not done any of the required inspections during any of the last 4 years. TCPS concludes that without the inspections, the public and the EPA cannot be assured the Compound 1080 is being stored, used, and disposed of properly; and TDA cannot carry out enforcement against misuse of these dangerous poisons. This pattern of inadequate supervision cannot be assumed to be specific to Texas as much as it may be specific to use of the LPC." There is no antidote for Compound 1080 poisoning. Learn more about Compound 1080

M-44’s

M-44’s are spring-propelled sodium cyanide cartridges. A small pipe is spring-loaded with the cartridge then pounded into the ground and topped with an absorbent wick scented with carrion, musk, etc. When an animal pulls on the wick, the spring propels the cyanide charge into the animal’s mouth. The animal can die within minutes or it can suffer as long as eight hours.

M-44’s are primarily used for coyotes and, to a lesser extent, red foxes. They have one of the largest percentages of non-target kills of any device, as any animal that is attracted to the scent of carrion can be lured and killed.

Sodium cyanide is extremely lethal to humans as well. Wildlife Services employees and anyone else who places or services M44s is supposed to carry amyl nitrate to counteract the cyanide. Hikers, children, or others who stumble across such a device will have no such protection. Cyanide is lethal and can kill within minutes. Learn more about M-44s

 

The Myth of Selectivity

Wildlife Services repeatedly claims that its methods are "selective," implying that they only remove animals actually causing damage. For example, the Wildlife Services customer-service brochure states that, "We will support the most humane, selective, and effective control techniques."

However, the reality is that most Wildlife Services methods are nonselective, in the sense that they will kill many animals apart from the ones doing damage. Coyotes, the predator killed in the greatest number by Wildlife Services, make a good example. Approximately 75,000 to 90,000 coyotes are killed every year by Wildlife Services—vastly more than are reported as problems.

Selectivity of Lethal Control Methods

Shooting from fixed-wing aircraft and helicopters is not selective. With this method aircraft fly over a large area and all coyotes observed are shot.

Shooting is selective if the animals are shot in the act of doing damage. Shooting coyotes on sight is not selective.

Leghold traps and snares are somewhat selective in cases where an animal actually killed by a coyote is used as the bait. However, in most cases bait or lures are used to attract the coyotes, which makes these methods non-selective. Many non-target animals are caught with this method.

M-44 cyanide ejectors are not selective. Any animal attracted to carrion, or other scent, used to attract coyotes will be affected.

Calling and shooting are not selective. Any coyote within range that responds to the call will be shot.

Hunting with dogs can be selective. In coyote hunting, dogs are often used to lure parent coyotes away from dens regardless of whether these coyotes have done damage. Their use in such a fashion is not selective. More often Wildlife Services uses dogs to hunt cougars and bear.

In short, most of the above methods will be used against all coyotes in a given area, not against specific coyotes causing damage.

Wildlife Services' Poisons Arsenal

The use of poisons to control predators is as old as the West. Trappers, ranchers, and Wildlife Services agents all use a myriad of poisons on both public and private lands. The poisons that are used are delivered by different mechanisms.

The deadly “tools” of USDA’s Wildlife Services include:

Alpha Chloralose
Aluminum Phosphide
Aminopyridine, Avitrol, 4-AP
Bone Tar Oil
Brodifacoum
Cholecalciferol (Quintox)
DRC-1339
Fenthion
Immobilizing/ Euthanizing Agents
Mineral Oil: Petroleum Distillates
Glyphosate
Polybutene
Sodium Cyanide
Sodium Fluoroacetate
Sodium Nitrate
Strychnine
Zinc Phosphide

Alpha Chloralose (C8H11Cl3O6): Immobilizing agent used on waterfowl and other birds. Classified as a soporific, which is a central nervous system depressant designed to immobilize target species at sublethal levels. The compound is slowly metabolized, resulting in a recovery within a few hours from ingestion. Possible accumulation in species that have undergone multiple treatments. Secondary risks to predators a factor if target species not removed promptly after administration of the compound. FDA classified as a narcotic. Primary and secondary toxicity listed as low when the target species is removed. There is no probable aquatic risk due to the use pattern and lack of solubility in water.

Aluminum Phosphide - AIP (55% or 57%) Also known as Fumitoxin, Phostoxin and Detia-Rotox: The compound is registered as a fumigant designed for the control of burrowing rodents. To be used by certified personnel only. Target rodents include pocket gophers, prairie dogs, moles, ground squirrels, muskrats, marmots, voles, and Norway rats. The compound is not persistent in soil due to the conversion to deadly phosphine gas when in contact with moisture, and ultimately (in several days time) to inorganic phosphate. The EPA has placed this compound in their highest toxicity category. The chance of non-target toxicity to burrowing animals is extremely high in targeted areas, and any animal coming in contact with the poison gas will likely be killed.

4-Aminopyridine (C5H6N2), Avitrol, 4-AP: Lethal frightening agent used on grain baits for killing house sparrows, pigeons, blackbirds, and starlings to safeguard public health and safety and to protect against property damage caused by those species. Can be used only by State-certified pesticide applicators. Acutely toxic to both avian and mammalian species. Compound is very water-soluble. It is also highly mobile in soils and has the potential to leach to the ground water. Aquatic organisms are acutely affected at low levels. Biodegradation of the compound is slow in soil and water? its soil half-life extends up to 22 months. Non-accumulative in tissues, and is generally rapidly metabolized by many birds. Secondary poisoning, known for magpies and crows, is a potential.

4-Aminopyridine (Avitrol Concentrate; 25%): Same as above except for the concentration. Used to control gulls. Primary and secondary poisonings probable unless each targeted species is gathered.

Bone Tar Oil (Magic Circle Deer Repellent; 93.75%): Used as an odor repellant to deer. There is no probable risk to primary, secondary, or aquatic toxicity.

Brodifacoum (Weather Blok) ( C31H23O3Br; 0.005%): Federally registered for the control of the Polynesian rat in Hawaii only. The "second generation" anticoagulant compound is contained in a rodent specific application box, so primary, secondary and aquatic toxicity potentials are all low due to the design of the applicator.

Cholecalciferol (Quintox) (C27H44O; 0.075%): Also known as vitamin D3, which is used by humans for dietary supplementation. The compound is used in the control of rodents. As above, this compound is applied in a target-specific box which results in "target only" toxicity. The compound is not mobile in soils. There is little chance of bioaccumulation in plant or animal tissue. The primary, secondary, and aquatic toxicity potentials are all low.

DRC-1339 (C7H9NCL2): Slow-acting avicide used widely throughout the United States. Lethal in a single feeding. Concentrate may only be used by APHIS Wildlife Services personnel trained in bird damage control or persons under their direct supervision. Commercially available avicide may be used by Wildlife Services personnel as well as others who are State certified in pesticide application. Highly toxic to starlings, blackbirds, and magpies and other birds. More toxic to birds than to mammals. DRC-1339 (98% Feedlots): Used to control blackbirds, starlings, pigeons, crows, cowbirds and grackles. 0.1% concentration tarlicide is a brand name for this: Similar to above, but is not a restricted use pesticide. Federally registered for the control of starlings and blackbirds. Could affect non target species. DRC-1339 (98% Eggs and Meat bait): Similar to above, but in a powder that is applied to bait (eggs and meat). Used primarily to prevent livestock depredation by ravens. Could affect any non-target species that were to consume the poison.

Fenthion (C10H15O3S2P), also known as Rid-A-Bird: Organophosphate compound used on bird perches to poison birds which land or come in contact with it. Also used as an insecticide (mostly mosquito control). Toxic to all avian species. Affects non target species that come in contact with it. Could potentially affect peregrine falcons and other raptors, which are all particularly sensitive to fenthion contamination. Estimated to break down in a week or so under normal conditions.

Immobilizing/ Euthanizing Agents (Ketaset, Beuthanasie-D, Rompun): These are several drugs used by Wildlife Services to target individuals for sedation or death. They are normally injected directly into the animal, so the chance of non target toxicity is negligible.

Mineral Oil: Petroleum Distillates: A petroleum product that is highly lipophilic and easily bioaccumulates in tissues, especially fat tissues. Used primarily for the control of gulls. The product is sprayed on the gull eggs to asphyxiate the embryos. Claimed to be non-toxic to hatched birds as a result of limited studies. Secondary and aquatic toxicity both claimed to be low due to the low degree of toxicity.

Glyphosate (C3H8O4PN): Nonselective herbicide for use in aquatic environments. Designed for control of cattails where blackbirds roost. Used primarily in the summer when the cattails are more affected by the herbicide. It is moderately persistent in soils (50% lost in 60 days). It has a low mobility, but translocates easily into foliage. Low risk of toxicity to animals because the compound was designed as a herbicide. Claims to have no potential risk to primary, secondary, or aquatic species.

Polybutene (80%) also known as Eaton's 4-the-Birds: A transparent, sticky compound that is designed to discourage birds from roosting or perching on treated ledges. Primary, secondary, and aquatic toxicity none due to the non-toxic product. This product can be lethal if applied incorrectly. There are instances where birds will suffer from an excess of the adhesive on their wings and feathers. This compromises their temperature regulation and usually results in death from exposure.

Sodium Cyanide (NaCN): M-44 Cyanide Capsules, 88.62%. Found in a 1 inch tall by 0.44 inch diameter (M-44) ejector mechanism. When in contact with moisture, as when the M-44 ejects the sodium cyanide into the oral cavity, the compound reacts to form a gas, hydrogen cyanide. Hydrogen cyanide is the actual toxicant that causes asphyxiation when inhaled. Specifically developed for the control of coyote depredation on livestock. The devices are to be checked weekly at the very least. The compound is highly mobile in soil. Primary toxicity is a serious potential for non target species. Secondary toxicity is thought to be unlikely due to the nature of the compound and its limited ability to assimilate into tissue.

Sodium Fluoroacetate (FCH2COONa; Compound 1080, 1.04%): Used and modified for the control of coyote depredation to livestock. Originally designed for rodents, but the nontarget effects from the primary and secondary toxicities caused the compound to be cancelled. It was registered again for use in 1985 only in a device called the Livestock Protection Collar (LPC). This is a velcro harness for small sheep and goats with two rubber bladders on each side of the throat which contain a one percent solution of the compound. That amounts to approximately six lethal doses for coyotes. Primary nontarget hazards could result from any animal that comes in contact with the poison or poison-carrying device. Secondary nontarget hazards could arise from any animal coming in contact with an infected organism.

Thought to only attract target species such as coyotes and other canines, Wildlife Services records show a surprising number of other species have succumbed to the poison. Raptors in particular need several days to recover from a sub-lethal exposure to the compound, and have died from lethal doses. There are several raptors and scavenging birds for which compound 1080 poses a serious threat. The compound remains in the tissues of species exposed to the poison. There are also instances of poisoning of domestic animals due to ruptured poison bladders on the collars from vegetation or fencing. An animal that even so much as licks the wool or fur of an infected carcass could receive a lethal dosage.

Unfortunately, little is known about the environmental fate of the compound. It is known that the compound is extremely soluble in water. The potential of plants bioaccumulating the compound in their cells is high. Compound 1080 represents one of the most harmful compounds that Wildlife Services uses. It is an indiscriminate killer. The lethal dose for most animals is around a milligram per kilogram of body weight. There are several threatened or endangered species that could be affected. Since the location of infected animals is seldom known (coyotes and other victims are seldom found), the potential for any of a number of non-target species to come in contact with an infected carcass is incredibly high. After ingesting the poison, it may take up to six hours for death to occur, so the victim can be miles away.

Sodium Nitrate (NaNO3): A pyrotechnic fumigant that emits toxic fumes when burned. If not ignited, the compound is relatively nontoxic. Has been manufactured for more than 40 years. Used mostly in coyote dens. The product is highly mobile in soils. There is little potential for bioaccumulation. When ignited, the gas emitted is carbon monoxide, which causes death by asphyxiation. It has been placed in the highest toxicity category due to the inhalation hazard. Primary toxicity is high. Secondary toxicity is potentially low.

C21H22N2O2: Historically used in the control of vertebrate pests. It is currently restricted to below ground applications in burrows and runways for killing rodents. Can only be used by state-certified pesticide applicators. The compound has moderate mobility in soil. There is a half life of 28 to 112 days depending on conditions (more oxygen = higher rate of biodegradation). This would then be classified as having a moderately low persistence. There is a high primary toxicity in both birds and mammals. There is also a good chance that secondary toxicity may occur to predators and scavengers. Aquatic toxicity is potentially high due to the nature of the poison. This compound is highly toxic to almost anything it may come in contact with. There are several variations of the formula that are designed to target specific species such as pocket gophers, ground squirrels, marmots, woodchucks, and prairie dogs.

Zinc Phosphide (Zn3P2): One of the most widely used rodenticides in the world. Has the ability to kill in one dose, but normally that option is not available due to the offensive taste and odor. Can only be used by state certified pesticide applicators. Primarily used on state owned range land and private lands. Not likely to be mobile in soil, but is fairly persistent. The compound has not been known to bioaccumulate in plant or animal tissues. There is a high avian toxicity, a potential for secondary toxicity due to the persistence of the compound in the gut, and a varying aquatic toxicity.