1. Title and introduction

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Attachment B
Final Version (Submitted 12/8/2011)
Proposal for wild harvest, keeping and breeding of Australian native snake species for the export of venom, blood and other products submitted for approval under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)
1. Title and introduction
The applicant submitting this proposal is operating as Venom Supplies. Hereafter, the applicant is referred to as Venom Supplies. This proposal relates to the harvesting and breeding of snakes for the purpose of the export of snake venom, venom derivative or venom product and any other product derived from these snakes.
Snake derived venom, blood and body parts have been used internationally for medical research into therapeutic compounds, production of human therapeutics and diagnostics, pure research and development of biological reagents. The current application proposes to continue this work.
Specimens covered:
Native venomous snakes, except those listed under the EPBC Act as threatened (excluding the conservation dependent category), legally held by Venom Supplies. Specimens may have been taken from the wild or captive born. All wild snakes including parental stock must have been legally harvested under collection permits issued by the relevant state or territory government.
The snakes are held at the premises of Venom Supplies, and the venom, venom derivative or venom product and any other product derived from these snakes can be legally exported for research and medical purposes. Export permits are required with the exception of venom, venom derivative or venom product or a naturally sloughed skin for the following species for which an existing exemption is in place:
Common Death Adder Acanthophis antarcticus

Northern Death Adder Acanthophis praelongus

Desert Death Adder Acanthophis pyrrhus

Lowlands Copperhead Austrelaps superbus South Australia and Victoria)

Pygmy Copperhead Austrelaps labialis (Kangaroo Is. only)

Stephens Banded Snake Hoplocephalus stephensii

Peninsular Tiger Snake Notechis ater niger (Kangaroo Island)

Western Tiger Snake Notechis ater occidentalis

Eastern Tiger snake Notechis scutatus

Inland Taipan Oxyuranus microlepidotus

Coastal Taipan Oxyuranus scutellatus scutellatus

King Brown Snake Pseudechis australis

Collett’s Snake Pseudechis colletti

Spotted Black Snake Pseudechis guttatus

Red-bellied Black Snake Pseudechis porphyriacus

Dugite Pseudonaja affinis

Peninsula Brown Snake Pseudonaja inframacula

Western Brown Snake Pseudonaja nuchalis

Common Brown Snake Pseudonaja textilis

Rough-scaled Snake Tropidechis carinatus

Venom Supplies is initially applying for approval of the species listed in Appendix 1 of this proposal. If additional species need to be added to the list then Venom Supplies will submit a written request to DSEWPAC requesting that the species is added to the list of approved species. Exports will not occur until Venom Supplies receives confirmation from DSEWPAC that the species has been added.
Species status under state legislation
All species listed are protected under the relevant state legislation. The status of the population of each species is taken into account by the respective state or territory government before approval to collect specimens is granted.
Most snakes are sourced from South Australia. The other parts of Australia where snakes have been sourced are Victoria and Queensland. Venom Supplies currently has approved collection permits for both South Australia and Queensland which are both subject to monitoring and reporting procedures. It is possible that snakes from other states may be required from time to time. It is impossible to predict this in advance. As mentioned previously, these snakes would be used primarily for venom extraction with blood and body parts being extracted only rarely.
The keeping and movement of native snake species in South Australia is regulated, monitored and enforced by the Department of Environment and Natural Resources (DENR), SA. Permits are required for the keeping and movement of animals and regular reports are submitted to the department. The department also issues Licences for animals used in research and teaching. Approval from an Animal Ethics Committee is also required to undertake projects using live animals.
2. General Goal/Aims
The aims and goals of making blood serums and body parts available are for medical research purposes. Snake blood contains natural inhibitors to snake venom components and are being researched in various parts of the world. Venom glands and livers are used to clone venom components and make gene libraries.
Development of a product using gene libraries with the University of São Paulo in Brazil is ongoing. Venom Supplies is also involved with various projects, using snake tissue, currently being undertaken at the University of Singapore.
Below is a selected list of published work relating to these aims:
Thurn, M.J., Broady, K.W. and Mirtschin, P.J. (1993). Neutralisation of tiger snake (Notechis scutatus) venom by serum from other Australian elapids. Toxicon 31(7): 909-912.
Flachsenberger, W., Leigh, C.M., Mirtschin, P.J. (1995). Sphero-echinocytosis of the human red blood cells caused by snake, red-back spider, bee and blue-ringed octopus venoms and its inhibition by snake sera. Toxicon 33(6): 791-797.
Butler, T.L., Jacobsen, P.F., Mirtschin, P.J., Kakulas, B.A. (1998). An In Vitro study of the effects of venom of Australian elapids on murine skeletal muscle and the protective effect of homologous plasma. J. Venom.Anim. Toxins. 4(1): 36-50.
Smith, A., Marshall, L.R., Mirtschin, P.J., Jelinek, G.A. (2000). Neutralisation of the clotting activity of Australian snake venoms by snake plasma. Toxicon 38 1855-1858.
3.1 Wild Harvest Details
Description of what is being harvested
Live snakes are collected opportunistically in small numbers. Whilst Venom Supplies has permits in South Australia and Queensland to collect snakes used for venom extraction, the number of wild harvested snakes rarely exceeds 10 per species. This permit provides for potential venom requirements and a few individuals are euthanased and used for blood extraction and harvest of body parts. Sloughed skins from various species are also required from time to time.
The snakes will be/have been opportunistically collected under state legislation controls which regulate the collecting of native species. Whilst the details of collecting requirements in each state vary slightly, they all generally require a permit to collect and an additional permit to export the snakes from the source state and a permit to import the snakes into South Australia. Details of these permits are usually available on the respective state website. All the requirements and methods used have to be approved by the respective state authority. In each case it is simply a matter of catching the snakes when opportunities arise. Collection is by hand and in most cases the snakes are collected when they are interacting with the public and are removed to reduce the risk of snake bite to the public.
Location of harvest
These species are harvested in small numbers from private lands in South Australia and Queensland (other states may be included in the future) within their normal ranges in accordance with restrictions listed in the approvals from the respective state authorities. The ranges of each species can be obtained from the books Cogger, H.G. (2000), Reptiles and Amphibians of Australia Reed New Holland, Sydney and Wilson, S. and Swan, G. (2003) A complete guide to Reptiles of Australia. Reed New Holland, Sydney.
Areas collected: Snakes are collected within their normal range in accordance with state controls. In all cases these areas are outside national and conservation parks. The respective ranges can be found in Cogger, H.G. (2000), Reptiles and Amphibians of Australia Reed New Holland, Sydney and Wilson, S. and Swan, G. (2003) A complete guide to Reptiles of Australia. Reed New Holland, Sydney.
Land Ownership: Snakes are collected from privately owned land across South Australia and Queensland (and other states if required).
Quantities harvested: In each case the number of snakes harvested is low and in accordance with state permit numbers. Snakes are collected on an opportunistic basis and in most cases when interacting with the public to remove snake hazard. Our South Australian permit allows the wild harvest of 10 individuals per species per year, except for Pseudonaja textilis and Notechis scutatus, where generally no more than 20 individuals of each species are taken each year. In most cases these limits are not reached and in fact in many instances none are collected. Again, these snakes are collected for venom extraction, and some are used for blood extraction and body parts.
Harvest Methods: Snakes are caught by hand using a snake jigger, a soft padded device attached to a handle used to safely pin the snake without harming it (see picture).

Jigger is used to gently restrain snakes

Harvest Time: Snakes are generally harvested during their active period which is mostly from September to April each year.
3.2 General Operations (including breeding)
General husbandry:

All snake husbandry and procedures used by Venom Supplies are subject to current animal ethics approval from the Animal Ethics Committee of the Institute of Medical and Veterinary Sciences (AEC IMVS, Gilles Plains, South Australia).under an agreement with the Minister for Environment and Aboriginal Affairs, South Australia.

Snakes are maintained under approved laboratory conditions under the supervision of the AEC IMVS.
Venom Supplies currently has 4 buildings and a number of secure outside enclosures (appendix 2) to maintain it’s collection of snakes and rodents (used as a food source). The facilities have 24 hour monitored security and fire systems. Venom Supplies is a recognised AQIS Quarantine Approved Facility and is subject to regular inspections from AQIS to maintain this status.
The majority of snakes at Venom Supplies are housed individually with the exception of snakes together for breeding purposes or those housed in the outdoor enclosures. Snakes (other than those in the outdoor enclosures) are housed in either a plastic ‘tub’ style enclosure or a fixed, wooden enclosure. All snakes are given a unique ID code and husbandry records are collected and recorded for all individuals during their lifetime. Breeding of snakes is performed on an as needed basis, generally in response to a direct service related requirement but also to maintain overall collection vigor and reduce the necessity of wild harvesting.
4. Impact of Wild Harvest on Ecosystems
The impact of collecting on the ecosystem is immeasurably low and the likely impact of the collecting on species abundance is negligible. In general terms the relative impact of collecting animals for any purpose compared with other environmental impacts such as habitat loss and feral animals can be realised by reading an assessment by Professor Hal Cogger regarding land clearing in Queensland (Cogger et al, 2003). The report stated that an estimated 89 million reptiles are being killed annually in Queensland by land clearing. Earlier, hugely conservative, estimates in Ehmann and Cogger (1985), Australia's endangered herpetofauna: a review of criteria and policies, reflect the true perspective of collecting compared with other classes of mortality:
Natural mortality 3,840 million 99.77%
Human induced mortality

Road kills 5.48 million 0.14%

Land clearing 3.26 million 0.08%

Research collecting 0.02 million 0.0005%

Skins and amateur collecting <0.02 million 0.0005%

5. Monitoring & Assessment (in relation to the wild harvest)
The environmental impact of the proposed activity of collecting snakes is believed to be miniscule. Monitoring is applied at both state and federal levels by state wildlife agencies through returns submitted by us, and DSEWPAC are informed through Specimen Export Records. No population studies have been carried out on these species in the areas from which they are likely to come, nor is any analysis possible.
5.1 Resource assessment (in relation to the wild harvest)
No population studies have been conducted for these species in areas from which they are likely to be taken. See above. Ecological studies of reptiles tend to be conducted in reserves. These specimens will all come/have come from private property.

6. Effective Management Strategies (in relation to wild harvest)
Population changes are hardly detectable when working with such small numbers over brief periods and would be indistinguishable from the effects of season and meteorological conditions on observable abundance.
The effectiveness of our management in the laboratory of the snakes we collect and hold is reflected in returns submitted to state wildlife authorities and AEC IMVS. Our standards are maintained at a superior level. Monitoring and feedback may result following review by these bodies of submitted returns.
7. Compliance
As noted under Section 1 Species status under state legislation, the species are protected under state legislation. The keeping and movement of native snakes in South Australia is regulated by DENR. Venom Supplies provides reports to DENR.

Compliance with permit conditions for the collection of snakes from the wild is monitored by state government agencies, particularly DENR in South Australia. This is to ensure that only legally obtained specimens are used in commercial trade.

Compliance with animal care and ethics requirements are overseen by the AEC IMVS.
8. Reports
The permits area of DSEWPAC is informed about exports through Specimen Export Records, which are provided for every consignment exported. Venom Supplies will further provide the information already being supplied to the South Australian and other state authorities if required by DSEWPAC. Venom Supplies will also maintain contact with and report to AEC IMVS.

9. Background information
Biological and ecological information on most Australian snake species is poorly known.
Professor Rick Shine from the University of Sydney is the best known in this area and an overview of biology and ecology of the Australian species involved can be found in Shine (1991), Australian Snakes: A Natural History.
Allen Greer authored a work which summarises a vast body of knowledge of the biology of Australian snakes in Greer, A.E. 1997. The Biology and evolution of Australian Snakes Surrey Beatty and Sons, Chipping Norton.
For taxonomic summaries see Cogger, H.G. (2000), Reptiles and Amphibians of Australia Reed New Holland, Sydney and Wilson, S. and Swan, G. (2003) A complete guide to Reptiles of Australia. Reed New Holland, Sydney.


Cogger, H.G. (2000), Reptiles and Amphibians of Australia Reed New Holland, Sydney

Cogger, H.G., Ford, H., Johnson, C., Holman, J. and Butler, D. (2003). Impact of Land Clearing on Australian Wildlife in Queensland. WWF Australia Report.
Ehmann, H. and Cogger, H. (1985) Australia's endangered herpetofauna: a review of criteria and policies. Biology of Australasian Frogs and Reptiles (eds G. Grigg, R. Shine & H. Ehmann), pp. 435-447. Royal Zoological Society of New South Wales, Sydney, Australia.
Greer, A.E. 1997. The Biology and evolution of Australian Snakes, Surrey Beatty and Sons, Chipping Norton.
Shine, R. (1991). Australian Snakes: A Natural History, Reed Books, Sydney.
Wilson, S. and Swan, G. (2003) A complete guide to Reptiles of Australia. Reed New Holland, Sydney.
Appendix 1

Common Name

Scientific Name

Brown Tree Snake

Boiga irregularis

Cacophis churchilli

White - Crowned Snake

Cacophis harriettae

Dwarf Crowned Snake

Cacophis krefftii

Golden Crowned Snake

Cacophis squamulosus

Papuan Whip Snake

Demansia papuensis

Yellow faced Whip Snake

Demansia psammophis

Desert Whip Snake

Demansia reticulata

Collared Whip Snake

Demansia torquata

Black Whip Snake

Demansia vestigiata

De Vi's Banded Snake

Denisonia devisi

White Lipped Snake

Drysdalia coronoides

Masters Snake

Drysdalia masteri


Echiopsis curta

Yellow - Naped Snake

Furina barnardi

Red- Naped Snake

Furina diadema

Orange -Naped Snake

Furina ornata

Brown Headed Snake

Furina tristis

Grey Snake

Hemiaspis damelii

Black Bellied Swamp Snake

Hemiaspis signata

Pale Headed Snake

Hoplocephalus bitorquatus

Papuan Taipan

Oxyuranus scutellatus canni

Little Whip Snake

Parasuta flagellum

Monk (hooded) Snake

Parasuta monachus

Mitchells Short Tailed Snake

Parasuta nigriceps

Mallee Black - headed Snake

Parasuta spectabilis

Papuan Black Snake

Pseudechis papuanus

Western Brown Snake

Pseudonaja aspidorhyncha

Speckled Brown Snake

Pseudonaja guttata

Peninsula Brown Snake

Pseudonaja inframaculata

Ingram's Brown Snake

Pseudonaja ingrami

Western Brown Snake

Pseudonaja mengdeni

Ringed Brown Snake

Pseudonaja modesta

Capentaria Whip Snake

Rhinoplocephalus boschmai

Small Eyed Snake

Rhinoplocephalus nigrescens

Black Striped Snake

Rhinoplocephalus nigrostriatus

Coral Snake

Simoselaps australis

Narrow Banded Snake

Simoselaps fasciolatus

Simoselaps incinctus

Half Girdled Snake

Simoselaps semifasciatus

Suta dwyeri

Little Spotted Snake

Suta punctata

Myall Snake

Suta suta

Bandy Bandy

Vermicella annulata

Appendix 2

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