Process
for
Endangered
Species
Assessment
and
Mitigation
for
Aldicarb
D.
L.
Fischer
and
A.
T.
Hall
Bayer
CropScience
Ecotoxicology
August
31,
2005
ES
Assessment
Options
with
the
Counterpart
Regulations
and
ACA
1.
Interagency
Exchange
of
Information

EPA
request
for
species
or
critical
habitat
information
2.
Advance
Coordination
for
FIFRA
Actions

EPA
request
for
designated
Services
representative
for
effects
determination
3.
Alternative
Consultation
Agreement
for
Not
likely
to
Adversely
Affect
Decisions

Following
agreed
upon
assessment
procedures
can
reach
NLAA
decisions
4.
Formal
Consultation
for
potential
may
affect
decisions

Where
is
aldicarb
in
the
process?
ES
Assessment
­
Overview
Document

Problem
Formulation

Use
characterization

Assessment
endpoints
 
direct
and
indirect
effects,
critical
habitat

For
endangered
species
 
will
provide
initial
scope
of
action
area

Analysis
­
Characterize
exposure
and
effects

Screening
level
assessment
and
refined
assessment

Risk
Characterization

Screening
level
assessment
­
risk
quotients

Refined
assessment
 
refined
risk
quotients
and/
or
risk
curves

Species
specific
and
habitat
specific
assessments

Co­
occurrences
with
crop

Biological
or
physical
characteristics

Incident
information

Sales
and
Use
information

Local
use
practices

Monitoring
data
2005
EFED
screening
assessment:

aldicarb

Taxa
identified

Birds
(
56
species)


Mammals
(
57)


Reptiles
(
27)


Amphibians
(
18)


Fish
(
87)


Crustaceans
(
20)


Arachnids
(
12)


Insects
(
40)


Snails
(
28)


Clams
(
70)


Plants
(
490)???
LOC
exceeded
for
birds,
mammals,
freshwater
and
saltwater
fish,
freshwater
and
saltwater
invertebrates
LOC
not
exceeded
for
terrestrial
and
aquatic
plants
honey
bees
(
terrestrial
arthropods)???

Preliminary
IMS
scoping:

25,000
species­
county­
crop
"
hits"
BCS
proposal
of
ES
evaluation
process
1.
Starting
point
is
EFED
Screening
Assessment
2.
Conduct
refined
risk
assessment,
exclude
taxa
or
use
patterns
that
no
longer
exceed
the
LOC
3.
Generate
T&
E
species
list
for
uses
that
still
exceed
the
LOC
(
IMS)

4.
Species­
specific
assessments
­
exclude
species
with
minimal
potential
for
exposure
based
on
ecological
(
natural
history)
factors
5.
Determine
what
"
hits"
can
be
excluded
on
the
basis
of
pre­
existing
protections
already
in
place
6.
Determine
what
"
hits"
can
be
excluded
on
the
basis
of
spatialtemporal
non­
overlap
with
aldicarb
use
areas
(
action
areas)

7.
For
remaining
hits,
identify
appropriate
risk
mitigation
and
involve
stakeholders
8.
Document
all
steps
of
the
assessment
via
the
IMS.
Submit
all
documentation
to
EPA
for
review.
Refined
Risk
Assessment
Step

Problem
Formulation

Refined
estimates
of
exposure

Higher
tier
aquatic
exposure
modeling

Higher
tier
terrestrial
exposure
modeling

Regional
application
scenarios

Refined
estimates
of
toxicity

Use
of
closely
related
lab
surrogate
species

Use
of
dose­
response
curves,
SSDs,
etc.


Refined
risk
estimates
 
LOC
still
exceeded?

Example:
LOC
for
molluscs
not
exceeded
when
one
considers
oyster
toxicity
data
Exclusion
of
species
on
the
basis
of
ecological
factors

Check
for
natural
history
attributes
that
may
support
exclusion

Nature
Serve
data
 
biological
descriptions

FWS
listings,
biological
opinions,
expert
opinions

University
scientist
publications,
expert
opinions

Other
credible
information
Examples

Red­
cockaded
Woodpecker,
never
found
in
habitats
where
aldicarb
is
applied

Indiana
and
Gray
Bats
 
aerial
foragers
with
no
potential
to
ingest
granules
or
food
with
high
residues
Exclusion
of
hits
on
the
basis
of
protections
already
in
place
(
e.
g.
county
bulletins)


Assess
existing
protections
and
utilize
as
appropriate

Examples

For
various
species
and
locations:


Do
not
apply
this
pesticide
in
the
species'
primary
habitat
 
within
40
yards
of
the
water's
edge
for
ground
applications,
nor
within
200
yards
for
aerial
applications.


California
for
aquatic
and
avian
species

Do
not
use
in
currently
occupied
habitat .


Provide
a
20
foot
minimum
strip
of
vegetation
(
on
which
pesticides
should
not
be
applied)
along
rivers,
creeks,
streams,
wetlands,

vernal
pools
and
stock
ponds
or
on
the
downhill
side
of
fields
where
run­
off
could
occur .


Conduct
irrigations
efficiently
to
prevent
excessive
loss
of
irrigation
waters
through
run­
off ..


For
sprayable
or
dust
formulations:
when
the
air
is
calm
or
moving
away
from
habitat,
commence
applications
on
the
side
nearest
the
habitat
and
proceed
away
from
the
habitat.
When
air
currents
are
moving
toward
habitat,
do
not
make
applications
within
200
yards
by
air
or
40
yards
by
ground
upwind
from
occupied
habitat ..
Proposed
ES
Assessment
Process
1.
EFED
Screening
Assessment
Results
2.
Conduct
Refined
Risk
Assessment
3.
Species­
specific
Ecological
Assessment
4.
Species­
county
level
assessment
of
existing
protections
5.
Spatio­
temporal
analysis
of
EOs
and
aldicarb
uses
6.
Propose
mitigation
for
remaining
hits
Eliminate
taxa
and
use
patterns
that
do
not
exceed
the
Level
Of
Concern
Eliminate
species
with
minimal
exposure
Eliminate
EOs
already
protected
Risk
excluded
or
mitigated
for
all
EOs
Eliminate
species
with
minimal
exposure
Submission
and
review
process
1.
Problem
Formulation
for
Refined
ERA
2.
Refined
ERA
3.
ES
exclusions
based
on
ecological
factors
and/
or
protections
already
in
place
4.
ES
Overlap
Analysis
5.
Proposal
for
mitigating
remaining
ES
"
hits"
Submit
and
meet
9/
05
Submit
and
meet
11/
05
Submit
and
meet
2/
06
Submit
and
meet
5/
06
Submit
and
meet
6/
06
Discussion

FWS
Involvement
in
the
aldicarb
ES
assessment
process
and
meetings?


Is
the
proposed
timeline
appropriate?


Feedback
process
on
submissions

Consideration
of
grower
interest?


IMS
training
needs?
