UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
January
24,
2002
SUBJECT:
Endangered
Species
addendum
to
EFED's
Disulfoton
Science
Chapter
FROM:
Henry
Craven,
Biologist
EFED
Thomas
Steeger,
Acting
Branch
Chief
ERB
3,
EFED
Larry
Turner,
Mammalogist
FEAD
Arty
Williams,
Branch
Chief
EFB,
FEAD
TO:
Christina
Scheltema,
Chemical
Review
Manager
SRRD
This
memo
reflects
EFED's
consultation
with
FEAD
and
presents
the
results
of
a
preliminary
assessment
for
potential
risk
to
endangered
birds
and
mammals
from
disulfoton's
use
in
the
following
situations:

Asparagus­­
foliar
application
of
liquid
in
CA
and
WA
Barley
­­
foliar
application
of
liquid
in
CO,
ID,
MT
and
WA
Christmas
trees
­­
spot
broadcast
of
granular
in
NC
Coffee
­­
spot
broadcast
of
granular
in
Puerto
Rico
Cotton
­­
in
furrow
application
of
granular
and
liquid
in
LA,
MO,
OK,
NC
and
SC
Potatoes
­­
foliar
application
of
liquid
in
ID
and
WA
Wheat
­­
foliar
application
of
liquid
in
KY
Appended
to
this
memo
are
two
print
outs
from
OPPs
Endangered
Species
data
base
that
compares
USDA's
Agriculture
Census
information
on
crop
and
county
overlap
with
USFWS
information
on
the
location
of
endangered
species
to
the
county
level.
One
print
out
applies
to
Christmas
trees
in
N
Carolina
and
the
second
is
for
the
other
crops
(except
coffee)
and
states.
Since
the
data
base
does
not
include
information
on
Puerto
Rico,
Larry
Turner
had
personal
communication
with
Felix
Lopez,
Environmental
Contaminants
Specialist
USFWS,
Tel
#.
787­
851­
7297
(ext.
26).
The
results
of
a
cursory
screen
of
the
two
print
outs
and
the
phone
call
are
as
follows:

Two
species
were
identified
as
possibly
needing
some
form
of
mitigation.
These
species
are
the
Puerto
Rican
plain
pigeon
in
coffee
plantations
and
the
Mountain
plover
in
barley
fields.

Puerto
Rico
has
no
endangered
mammals,
however
two
endangered
ground
feeding
birds,
i.
e.
Yellow
shouldered
blackbird
and
Puerto
Rican
plain
pigeon,
could
consume
granules
as
grit.
Only
the
Puerto
Rican
plain
pigeon
utilizes
coffee
plantations.
Puerto
Rico
is
divided
up
politically
into
72
municipalities.
The
Puerto
Rican
plain
pigeon
resides
in
5
municipalities
of
which
4,
i.
e.
Cayey,
Cidra,
Comerio,
Utuado,
contain
coffee
plantations.
Utuado
has
~7500
acres
of
coffee,
which
is
about
1/
4th
the
area
of
the
municipality;
the
other
three
have
less
than
100
acres
each.
Mitigation
could
be
assured
by
off
labeling
for
the
4
municipalities.

There
was
no
county
overlap
between
asparagus
in
Washington
and
California
and
endangered
species.

With
respect
to
disulfoton
use
on
barley,
only
the
Mountain
plover
is
at
potential
risk
from
ingesting
soil
invertebrates
in
soil
that
has
been
sprayed
directly
or
received
wash
off
from
the
foliage.
However,
residues
would
likely
be
lower
than
what
would
be
required
to
cause
an
adverse
effect.
The
overlap
between
the
number
of
counties
where
barley
is
grown
and
the
bird
may
occur
includes
14
in
Colorado
and
17
in
Montana.
Additionally,
like
other
plovers,
the
bird
prefers
unvegetated,
open
areas;
if
the
barley
is
taller
than
3
inches
before
it
is
sprayed
there
is
little
likelihood
the
bird
would
utilize
the
field.
Therefore,
a
label
statement
limiting
application
of
disulfoton
to
when
the
crop
is
at
least
3
inches
tall
could
provide
a
reasonable
measure
of
mitigation
of
risk
from
disulfoton
exposure.
Finally,
the
species
has
been
proposed,
but
is
not
officially
listed
as
endangered.
Regardless
of
the
status,
OPP
needs
to
be
aware
of
the
potential
for
exposure.

Although
carnivorous
birds
(ie.
owls
and
eagles)
and
mammals
(ie.
Black­
footed
ferret,
grizzly,
Gray
wolf
and
Red
Wolf)
were
located
in
the
same
counties
as
all
crops
except
coffee,
they
are
not
at
risk
because
secondary
poisoning
studies
on
representatives
from
these
two
classes
did
not
indicate
concern.

Several
crops
such
as
cotton,
wheat
and
Christmas
trees
were
located
in
the
same
counties
as
endangered
bats.
However
bats
are
not
at
risk
from
disulfoton
sprays
as
they
would
only
be
feeding
on
flying
insects
from
dusk
to
dawn.
If
spraying
is
restricted
to
daylight
hours,
bats
would
not
be
exposed
to
disulfoton.
Bats
would
not
be
exposed
to
granules.

With
respect
to
Christmas
trees
in
North
Carolina,
in
addition
to
some
of
the
organisms
stated
above
there
are
several
birds
and
mammals
which
although
they
could
be
in
or
around
the
vicinity
of
Christmas
tree
plantations
are
not
considered
at
risk
especially
from
use
of
granules.
The
Wood
Stork
feeds
on
fish
and
the
Piping
plover
resides
on
sand
bars
and
feeds
on
aquatic
invertebrates;
therefore
neither
of
these
species
are
likely
to
be
impacted.
Because
disulfoton
is
systemic,
there
is
a
slight
potential
for
low,
undetermined
dietary
exposure
to
the
Northern
flying
squirrel
and
the
Red­
cockaded
woodpecker.
The
squirrel
consumes
organisms,
i.
e.
lichens,
fungi
and
insects,
or
plant
parts,
i.
e.
buds
and
seeds
that
could
take
up
disulfoton
residues
from
the
xylem.
However
as
the
squirrel
is
a
cavity
nester
it
prefers
tall
deciduous
trees
to
conifers
in
the
same
proximity.
The
woodpecker
requires
old
growth
(at
least
60
years)
living
pine
trees
in
which
to
make
cavities;
they
feed
on
insects
found
under
the
bark
of
conifers
where
the
trunk
is
larger
and
more
accessible
than
in
young
Christmas
trees.

Concerning
uses
other
than
Christmas
trees
and
coffee
the
following
endangered
species
are
forest
dwellers
and
are
not
associated
with
agricultural
sites:
Northern
Idaho
Ground
Squirrel,
Marbled
murrelet
(feeds
on
fish),
Woodland
caribou,
Brown
Pelican
(feeds
on
fish),
Red
cockaded
woodpecker,
Carolina
northern
flying
squirrel,
Preble's
meadow
jumping
mouse
(resides
in
high
elevation
meadows).
These
species
would
not
be
considered
at
risk.
In
addition
to
the
forest
dwellers,
Wood
storks
feed
on
fish,
Whooping
cranes
feed
on
aquatic
invertebrates,
Black
capped
vireos
reside
in
scrub
areas
and
feed
on
flying
insects,
Piping
Plovers
reside
principally
on
sand
bars
and
feed
on
aquatic
invertebrates,
and
Idaho
ground
squirrels
inhabit
meadows.
These
species
would
not
be
considered
at
risk.

Considering
the
biology
of
the
species
mentioned
above
and
the
specific
recommendations
to
avoid
exposure
of
disulfoton
to
the
Puerto
Rican
plain
pigeon
and
the
Mountain
plover,
we
believe
there
will
be
no
effect
on
threatened
and
endangered
species.
