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"I welcome the APVMA’s interim suspension of Second-generation Anticoagulant Rodenticides (SGARs). To ensure the long-term safety of Australia's wildlife and pets, this temporary measure must be made permanent. I urge the regulatory authorities to adopt the following measures:

• Permanently classify all SGAR products (e.g., brodifacoum, bromadiolone, difenacoum, and flocoumafen) as Restricted Chemical Products (RCPs).

• End to Public Retail Sales: Prohibit the over-the-counter sale of SGARs at supermarkets, hardware stores, and garden centres, ensuring these highly toxic poisons are not accessible to the general public.

• Mandatory Licensing: Restrict the purchase and use of SGARs strictly to licensed, trained pest management professionals who operate under strict environmental and bait-station protocols.

• Enforce Safer Alternatives: Encourage the widespread use and public availability of less toxic alternatives (such as first-generation baits or non-chemical pest control methods).

Reasons for Support: Preventing Secondary Poisoning

• SGARs built up in the food chain and accumulate in animals' bodies. Because the poisons do not break down like first generation rodenticide poisons, native predators like owls, eagles, quolls tasmanian devils, frogs and many other native animals that consume anti-coagulant poisons suffer lethal secondary poisoning. Unregulated residential use also leads to frequent accidental poisoning of domestic pets. Sadly, people deliberately leave baits in parks for animals to ingest.

• Unacceptable Environmental Risk: Decades of undisputed scientific evidence demonstrates that the current unregulated availability of SGARs presents an unacceptable risk to non-target, native Australian animals. Many whom are already listed as threatened.

• Very little control over containment: No matter how careful consumers are with the product, a poisoned rodent can travel for days before dying after ingesting SGAR rat baits, making it impossible to contain, track or safely dispose of once the animal has died.

• While the 12-month suspension is important, more long-term regulatory reform is essential to stop the unregulated poisoning of non-target animals.

Thank you for the opportunity to be involved in the decision on this critical conservation and animal welfare issue.