Warfarin

Fact Sheet:

Agriculture Commissioner Sid Miller Adopts

An Illegal “Emergency” Rule to Allow A Sole-Source

Provider Poison For Use on Feral Hogs

Summary: On February 21, 2017, Texas Agriculture Commissioner announced an “emergency” rule change to allow the use of a warfarin-based poison for use on feral hogs in Texas. The rule and the program are ill-advised and would be counterproductive. If not stopped, the program will damage Texas hunters, the Texas feral-hog meat industry, ranchers and other landowners, Texas wildlife, and the environment. In fact, the program will damage, rather than assist, the effort to control feral hogs in Texas. Additionally, the rule is illegal on its face: no legal “emergency” existed to authorize a dark-of-night “emergency rule” that will favor a sole-provider manufacturer of a single warfarin-based product for use on feral hogs, Kaput®. Scimetrics Ltd. Corp., a Colorado based company, is the sole manufacturer of the product. Texas should reject this program.

Why Warfarin Will Not Work in Texas—The Key Logical Flaw:

Overwhelmingly Texas lands are owned by private landowners—that’s true for approximately 95.8% of Texas land. Thus, if a private landowner poisons feral hogs on his or her ranch, almost immediately the feral hogs on adjoining properties will move in. Poisoning an entire region of ranches is unfeasible because:

  • Many property owners want to hunt and consume feral hogs, or lease their land to feral-hog hunters—not poison the feral hogs.
  • Many property owners don’t like or trust poison or the effects and risks of poison on domestic animals (e.g., dogs, cats), livestock, wildlife, and the environment.
  • Many property owners don’t want to incur the expense of a program that is doomed to failure or, at best, minimal, temporary success.
  • The sole-source product that Commissioner Miller has proposed, Kaput®, according to its own instructions, cannot be used in grazing areas:
    • For example, a rancher who owns 1,000 acres would have to move livestock from the pasture designated for poison.
      • First, according to the product instructions, several weeks of separation would be necessary to “condition the hogs” to learn to “open” the poison containers. (As discussed below, those containers are flawed and potentially expose children and animals to the poison.)
      • Second, the separate pasturing would have to continue for a substantial period to address the inevitable, continuing influx of hogs from surrounding properties. In fact, that influx would never end.
      • Third, according to Kaput® instructions, the separation would have to continue for 90 days after the last use of the poison.
    • Additionally, according to Kaput® instructions, the product also cannot be used near water or creeks.
    • Further, Kaput® instructions require “burial” of poisoned feral hogs. But feral hogs can travel 5 to 20 miles in a day. A poisoned feral hog may well end up on neighboring property, and the property owner may have no idea that a poisoned hog is on the property, much less any program or desire for burial. That would expose the poison-containing carcass to other wildlife, including bird of prey (eagles have been photographed dining hog carcasses), vultures, coyotes, raccoons, etc.—or even domestic dogs and cats.

Australia’s Bad Experience with Warfarin:

Sid Miller’s press release cited the use of warfarin in Australia. He said this: “Warfarin, an anticoagulant, was used for many years as a feral swine toxicant in Australia.” But he omitted the important facts about the Australia experiment. Here are those facts he omitted:

  • Australia, in a government-conducted study, experimented with the use of warfarin in 1987 in the Sunny Corner State Forest.
  • The study area was 60 square miles and the study period was 3 months.
  • Over the course of 3 months, 187 of 189 feral hogs were poisoned to death, using 69 poison sites and placing the poison in wheat left in the open, not in containers.
  • This application took an average of 2.7 man-hours per feral-hog poisoning.
  • Ultimately, Australia concluded that the method of death was so cruel, that use of warfarin should be outlawed—even though Australia is not a culturally “squeamish” country and even though Australia has more feral hogs than people. Warfarin is an anti-coagulant, so hogs die by bleeding to death—including bleeding out the eyes, nose, mouth, and other body orifices. The death is painful and gruesome.
  • Australia found that the timeline for feral-hog death was 4-17 days.

In short, the Australian experience conclusively showed that warfarin poisoning is a badly flawed program.

Warfarin Poisoning Will Cause Substantial Economic Damage to Texas Hunters, the Hunting Industry, Meat Processors, and Other Industries from Warfarin Poisoning—and Will Reduce in the Effectiveness of Feral-Hog Control in Texas

Texas currently has a vibrant, growing economic segment focused on hunting feral hogs and on the consumption and use of feral-hog meat and byproducts. Thousands of Texas hog hunters participate in safe, reliable harvesting of feral hogs. Hunting is one of the two most effective means of controlling the feral-hog population. Ranchers and other property owners earn substantial revenues from hunting leases and guided hunts for feral hogs. Feral-hog meat processors have developed a sustainable, environmentally sensible industry to use feral-hog meat products for human consumption in the United States and abroad and for the pet industry. Feral-hog hides are used for boot making. And on and on.

Collectively, those industries result in harvesting tens of thousands of feral hogs annually in Texas. A warfarin-poisoning program will substantially reduce or destroy those businesses. Given the flawed concepts on which warfarin-poisoning is based, that program will result in a net reduction in the number of feral hogs removed from Texas ranches annually.

In short, the warfarin-poisoning program will reduce, not increase, the number of feral hogs killed each year in Texas. The program will make the feral-hog control problem worse not better.

The Cost of Warfarin Poisoning

The costs of a warfarin-poisoning program are substantial for any participating landowner. Based on the information provided by the single-source provider of Kaput® and Kaput products:

  • Each “hog feeder” (poison-bait station) must be purchased through the sole-source provider (Kaput) and can be used for only one feeding cycle.
    • Therefore, after each warfarin-poison “experiment,” landowners will have to buy more feeders.
  • Each hog feeder (poison-bait station) holds only 25-50 lbs. of poison.
  • Studies suggest that a feral hog would have to ingest the poison for 5 days to die. That means that a hunter or property owner could shoot and consume a feral hog, not knowing that it contains poison.

Dangers to humans, animals, and wildlife:

  • Kaput® instructions state:
    • “Hazardous to Humans”
    • “Harmful if swallowed”
    • “Keep away from humans”
    • “Keep Out of Reach of Children”
    • “ If Swallowed: call a poison control center or doctor immediately for treatment advice”

“Burial” problems:

  • According to the manufacturer of Kaput®, when a feral hog dies from warfarin poisoning, the property owner must bury the hog 18” below the ground. That is impractical (and often impossible) because:
    • As discussed below, the death-by-bleeding that results from warfarin poisoning is slow. It can take up to five days. Feral hogs can travel 5 to 20 miles per day. It is highly likely that feral hogs that die from warfarin poisoning will be on some other property owner’s property. That owner well may not know that someone else has a poison program underway, much less have any desire to bury the feral hog. The dead feral hog will mostly likely remain exposed to being consumed by other animals, birds of prey, or even dogs or cats.
    • Even if the carcass of a poisoned hog is found, and even if the person who finds it has the motivation to bury it, burying a feral hog that weighs 200 pounds (or more) is not easy, simple, or cheap. At a minimum, it requires a backhoe. In some soils, burial is not feasible at all. It can be prohibitively difficult, expensive, labor-intensive, and time-consuming. In short, often it won’t happen at all.

Problems with Poison Bait Stations

  • The sole-source manufactured bait stations for use of Kaput® warfarin-based poison have many problems.
  • First, the doors weigh only ten pounds. Many animals can lift ten pounds. Texas Parks and Wildlife has documented raccoons lifting 28 pounds with just their front paws. So a raccoon opens the bait station, removes and distributes the poison, and then what happens? The risk to wildlife is obvious.
  • Deer have been known to literally pick each other up while fighting during the rutting season. Deer can weigh over 150 pounds.
  • Goats – anyone who has been rammed by a goat knows that 10 lbs is a fraction of the force that a goat can generate.
  • Cows have been known to flip over small vehicles.
  • Even human children can pick up 10 pounds.
  • Kaput® requires posting bilingual signs in the treated areas, specifically public roads, trails, and pathways. Unfortunately, children, raccoons, dogs, cats, deer, goats, and cows don’t read. The risks are obvious.

Other Environmental Hazards from Warfarin Poison

Kaput® itself lists these Environmental Hazards to wildlife (including domestic dogs and cats):

  • “This product may be toxic to fish, birds, and other wildlife”
  • “Dogs and other predatory and scavenging mammals and bird might be poisoned if they feed upon animals that have eaten the baits”
  • “Do not apply this product directly to water, to areas where surface water is present or to intertidal areas below the mean high-water mark”

Regulating Warfarin Use, Licensing, Enforcement:

  • In theory, only licensed pesticide applicators can legally use warfarin for feral-hog control. But even some property owners have licenses. Licensing standards are lax, and enforcement against violators has been nonexistent in Texas.
  • Many enforcement issues lack satisfactory answers, including:
    • Who supplies, supervises, renews, and ensures compliance with the licenses to purchase, transport, and use the product?
    • Who monitors that use restrictions and safeguards are complied with?
    • What are the penalties for violating the use restrictions?
    • Who will pay for a regulatory and enforcement program, and how much will that cost?

Alternatives to Warfarin Poisoning:

  • Texas A&M University and Texas Parks and Wildlife Department have been studying a safer alternative to warfarin: Sodium Nitrite.
  • Sodium nitrite is used to cure bacon. Humans consume it. It does not harm humans, but can be lethal to feral hogs. Thus, it would not cause the collateral economic damage to the hunting industry and the feral-hog meat industry in Texas.
  • Studies show that with properly administered sodium nitrite, feral hogs typically die within 2 hours of consumption. But sodium nitrite is not harmful to humans or pets. Secondary-poisoning risks from sodium nitrite are much less than from warfarin.

Why the Warfarin-poison Program Would Likely Increase the Feral Hog Population In Texas:

  • Currently the most effective feral-hog-control programs result from the kill-to-eat motivation of the majority of Texas hog hunters. Because of the risks from warfarin poisoning, harvesting for human consumption will inevitably decrease. (The Texas Hog Hunters Association opposes the warfarin-poisoning program.) The result will be removal of fewer feral hogs in Texas. The feral-hog population will increase.
  • The same is true of the burgeoning kill-to-sell feral-hog industry in Texas. Warfarin poisoning will reduce or eliminate that industry entirely, eliminating thousands of Texas jobs.
  • The same is true of the trap-to-sell industry in Texas. Trapping is one of the most effective means of feral-hog control in Texas. But many trappers sell the hogs for human or pet-products consumption. That will no longer be feasible. Warfarin can remain in a feral hog for up to 17 days. Thus, to be safe, trappers would have to feed feral hogs for three weeks to be used for human consumption. That is cost prohibitive.
  • The bottom line is that a warfarin-poison program is likely to result in a net decrease in the number of feral hogs harvested in Texas, and net increase in the population of feral hogs in Texas. That is the very definition of counterproductive!

Conclusion

Implementation of a warfarin-poisoning program in Texas is a bad idea that will have substantial adverse economic consequences for Texas hunters, Texas hunting-supply industries, Texas ranchers and other property owners, and the feral-hog meat processing industry. The program would cost Texas jobs and money, it would cause substantial damage to the Texas environment and wildlife—and ultimately, the program likely would make the problem of feral hogs in Texas worse, not better. In every sense, it is a lose-lose proposal for Texas. Texans and the Agriculture Department should reject this bad idea.