Dear National Institute of Water and Atmospheric Research Limited,

With regard to the original experiment that resulted in this research output:

Suren, A.M.; Lambert, P. 2006. Do toxic baits containing sodium fluroacetate (1080) affect fish and invertebrate communities when they fall into streams? New Zealand Journal of Marine and Freshwater Research 40: 531-546.

please supply a copy of the Principal Investigator's Research Ethics Application, plus the accompanying approval from the NIWA Committee, and any relevant correspondence.

thank you.

Dear Annabelle Watson,

Thank you for supplying the Animal Ethics Application and approval letter for these research studies. However, I needed to see ALL the ethics applications. Please therefore clarify that no Human Ethics Application was completed for these studies - if that was indeed the case (?) And if there WERE no Human Ethics Applications, please supply the name(s) of the person(s) who was qualified to make this decision, and the full, scientific, peer-reviewed rationale upon which it was based.

With the above in mind, I draw NIWA’s attention to their social responsibility in using highly toxic substances, which include the following 3 issues:

1) The fact that during the experiment, up to eighty 1080 toxic poison baits per stream were added – 10 times the approx. amount distributed during a typical aerial 1080 application. The manufacturer of this poison in the US specifically warns against using this poison in or near any waterways, because of its acute toxicity. This experiment was only carried out for four days - a very limited time-frame considering its potentially harmful effects - and therefore any longer-term potential consequences of the toxin contamination – whether histological or generational or other – to aquatic life and/or humans – was not recorded. For instance, Compound 1080 is a powerful insecticide (registered in NZ e.g. to kill wasps).

2) It appears the longer-term monitoring of the study site was not considered - for the wildlife or the humans. This was concerning considering there has been no research into how long 1080 poison persists in treated areas. In the ERMA documents it was recognised that it might persist indefinitely at low concentrations. It has been found to persist in many varied situations including dry places, cool water, water lacking aquatic plants, some types of soil, in carcasses and concrete water pipes (Eisler, 1995). The rate of breakdown of 1080 poison in New Zealand forests and streams is unknown, but it is extremely slow at around 5 degrees Celsius. Thus ERMA’s Agency warned that “No studies have been conducted using standard international guidelines to assess the route and rate of degradation of 1080 in soil. The rate of such degradation under New Zealand conditions is uncertain.” And regarding water: “Overall, the relevance of the aquatic plant/water studies to the degradation of 1080 in water in NZ is not clear.” (Pollard, 2011)

3) In the Animal Ethics Application you have sent me, it states clearly that both the fish and the crayfish were returned to these (publicly accessible) streams after being subjected to the 1080 poisoning (those that survived after 4 days), and that it also clearly acknowledges that these fish and crayfish are common sources of food for New Zealanders. MoH have acknowledged that no public health studies exist into 1080 despite numerous scientists pointing out how crucial this is (e.g. Scanlon, 2010)

Please note that on page 534 of Suren’s (2006) published article he states that one of the fish cages were stolen. Clearly then, this study site was accessible to the public and other residential areas were nearby and downstream from the site. The crucial need for a Human Ethics Application for this experiment therefore seemed obvious, especially when there are no known epidemiological studies of the potential impact of Compound 1080 on public health. This concern applies to individuals directly drinking the contaminated water and/or eating of contaminated vegetation, fish and/invertebrates involved in the study - or otherwise become part of the food-chain that evolved from it (Eason et al., 2013).

I await your response with interest.

References
Eason, C.T., Ross J. & Miller, A. (2013) Secondary Poisoning risks from 1080-poisoned carcasses and risk of trophic transfer – a review. NZ Journal of Zoology Vol 40 (3) pp 217-225 http://dx.doi.org/10.1080/03014223.2012....
Eisler, R. (1995) Sodium Monofluoroacetate (1080)Hazards to Fish, Wildlife and Invertebreates: a Synoptic Review. Available at: https://www.pwrc.usgs.gov/eisler/CHR_30_...
Pollard, J. (2016) Aerial 1080 poisoning in New Zealand: Reasons for concern. Scientific Reviews: http://1080science.co.nz/aerial-1080-poi...
Scanlon P. (2010) Letter to Parliament, available at: https://www.parliament.nz/resource/mi-nz...