Avitrol is advertised as a humane way to get rid of nuisance birds. In fact, a closer reading of its label reveals that it is a restricted-use neurotoxin that can only legally be applied by a licensed applicator due to its “acute oral and dermal toxicity and due to its toxicity to birds and mammals.” Target birds are baited with food laced with Avitrol. Applicators are required to keep people and pets out of the area until all carcasses are retrieved. However, birds will often travel long distances before dying, creating high risk of non-retrieval and secondary exposures.
In 2014 and 2018, Portland experienced two major incidents involving Avitrol in which large numbers of dead and dying crows literally fell from the sky across dozens of city blocks after being poisoned with the Avitrol™ and landed in yards, neighborhoods, public parks, parking lots, roads, sidewalks, and businesses. Some crows were dead when they hit the ground while others convulsed and experienced seizures on the ground before dying. Due to the risk of exposure to people, pets, and other wildlife, the incidents necessitated the mobilization of major public resources including the City, state and federal wildlife and enforcement agencies, as well as Portland Audubon. This involved a multi-day effort to retrieve carcasses spread across dozens of city blocks. As a result of these incidents, the City of Portland banned the use of Avitrol on City owned lands in 2019. It is time to ban this poison nationwide.
Please tell the EPA the following:
- You are commenting on the registration review of the avicide Avitrol (4-aminopyridine) Docket # EPA-HQ-OPP-2016-0030
- Avitrol cannot be used safely. Its method of application results in a situation in which applicators cannot control how much poison individual birds ingest or how far they travel before they succumb to the effects of the poison. This makes retrieval of poisoned birds extremely difficult if not impossible and puts non-target wildlife, pets, and people at risk.
- Portland, Oregon has already had two major Avitrol incidents in 2014 and 2018 in which dead and dying crows poisoned with Avitrol rained down over dozens of city blocks landing on streets, sidewalks, parks, yards, and businesses. These incidents were extremely frightening to the community and required major mobilization of public and non-profit resources to resolve.
- Avitrol is inhumane. Birds poisoned with Avitrol in Portland literally fell from the sky, crashed into the ground and then seizured, convulsed and screamed for extended periods before dying.
- Since it cannot be used safely, the EPA should ban the sale and use of Avitrol as an “imminent hazard.” It is not acceptable for the EPA to permit the use of a poison for which the labeling requirements create a high risk of scattering highly toxic carcasses either across densely populated human landscapes or in locations where there is a risk of secondary poisoning of protected wildlife.
- If the EPA does choose to continue allowing the use of Avitrol, the agency should require much more stringent labeling requirements including the following:
- The local government should be notified in writing at least 14-days in advance of the intended application of Avitrol including the specific location(s), date(s) of application, target species, and should include a copy of the applicators restricted use pesticide applicators license.
- All property owners within a 3.000 foot radius of the application site(s) should be notified in writing (mail, door hangers, etc.) at least 14 days in advance of the application of the specific location(s), date(s) of application and target species. Notice should also include the applicators restricted use pesticide applicators identification #, applicator’s 24-hour/ day contact information, instructions on what to do if a potentially poisoned live/ dead animal is found, and instructions on what to do if a potential exposure of people or pets has occurred.
- Warning signs should be posted on the actual site on which Avitrol is applied throughout the duration of the application.
- Applicators must maintain 24 hour/ day contact availability for at least 3 days following application to respond to public inquiries/concerns related to the application.
- Applicators must remain on site during the entire duration of the application process until all poisoned bait is consumer or removed