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McGaughey B.D.,Compliance Services International | Anderson L.W.J.,University of California at Davis | Bodenchuk M.J.,Texas Wildlife Services
ACS Symposium Series | Year: 2012

This chapter is based on a publication originally sponsored by the Council for Agricultural Science and Technology (CAST). In that issue paper, CAST explored why the Endangered Species Act consultation process is not functioning efficiently or effectively. In part, this dysfunctionality is because important stakeholders are disenfranchised. The lack of an established, transparent process impedes decisions and undermines trust amongst the affected stakeholders, resulting in necessary interagency communications being inhibited. And as a further result, litigation, which is not the most effective way to recover listed species, proliferates. In this chapter, we restate and expand upon the intersections between agriculture and the Endangered Species Act as explored in the CAST issue paper. We examine the polarity that can occur and endure in endangered species matters. We then discuss how the process should be improved, with an emphasis on the consultation process and pesticide regulation. © 2012 American Chemical Society.


Clark S.L.,Pacific EcoRisk | Ogle R.S.,Pacific EcoRisk | Gantner A.,Pacific EcoRisk | Hall L.W.,University of Maryland College Park | And 6 more authors.
Environmental Toxicology and Chemistry | Year: 2015

Hyalella azteca are epibenthic invertebrates that are widely used for toxicity studies. They are reported to be more sensitive to pyrethroid insecticides than most other test species, which has prompted considerable use of this species in toxicity testing of ambient surface waters where the presence of pyrethroids is suspected. However, resident H. azteca have been found in some ambient water bodies reported to contain surface water and/or sediment pyrethroid concentrations that are toxic to laboratory reared H. azteca. This observation suggests differences in the sensitivities of laboratory reared and field populations of H. azteca to pyrethroids. The goal of the present study was to determine the sensitivities of laboratory reared and field populations of H. azteca to the pyrethroids bifenthrin and cypermethrin. Specimens of H. azteca were collected from resident populations at field sites that are subject to varied land-use activities as well as from laboratory populations. These organisms were exposed to bifenthrin- or cypermethrin-spiked water in 96-h water-only toxicity tests. The resulting data demonstrated that: 1) field-collected populations in urban and agricultural settings can be >2 orders of magnitude less sensitive to the pyrethroids than laboratory reared organisms; 2) field-collected organisms varied in their sensitivity (possibly based on land-use activities), with organisms collected from undeveloped sites exhibiting sensitivities similar to laboratory reared organisms; and 3) the sensitivity of field-collected "tolerant" organisms increased in subsequent generations reared under laboratory conditions. Potential mechanisms for these differences are discussed. © 2015 SETAC.


Poletika N.N.,Dow AgroSciences | Teply M.,Cramer Fish science | Dominguez L.G.,Cramer Fish science | Cramer S.P.,Cramer Fish science | And 6 more authors.
Integrated Environmental Assessment and Management | Year: 2012

This risk assessment applied a framework for determining probable co-occurrence of juvenile spring Chinook salmon (Oncorhynchus tshawytscha) with agricultural pesticides in the Willamette Basin, Oregon (Teply et al. this issue) to characterize risk to the threatened population. The assessment accounted for spatial and temporal distribution of 6 acetylcholinesteraseinhibiting insecticides in salmonid habitat within the basin and their relative contributions to mixture toxicity estimated from chemical monitoring data. The 6 insecticides were chlorpyrifos, diazinon, malathion, carbaryl, carbofuran, and methomyl. Seasonal distributions of the juvenile salmon prey base across the basin were determined and compared to co-occurrence with the insecticide mixture to determine the probability of prey reduction and reduced production of juvenile fish. Probability of effect on freshwater aquatic invertebrates was based on acute toxicity species sensitivity distributions (normalized to the most potent compound, chlorpyrifos) using a novel approach to apply the toxicological concept of concentration addition to species sensitivity distributions with differing slopes. The chlorpyrifos distribution was then used to determine relative sensitivity among various species tested within the important taxa making up the prey base. A prey base index was devised, incorporating diet composition and prey availability, to evaluate the indirect effects of the insecticide mixture on juvenile salmon production occurring as a result of a reduction in the prey base. Our analysis targeted fish use of backwater and off-channel habitat units, because they generally coincide with agricultural lands in lowlands and represent shallow habitat with limited water exchange. The percentage of agricultural land use within 300mof critical habitat stream reaches was used to scale chemical measurement data from a site with high agricultural land use across the full extent of the basin to provide estimates of chemical exposure in each reach. Seasonal impacts were evaluated from mean monthly concentrations. Stressor impact on 5 key taxa was evaluated at each time step and for each reach, and the outcome was compared to a conservation threshold assigned to the prey base index. Only 13% of juveniles reared in backwater, off-channel habitat within 300m of agricultural land. Percent reduction of carrying capacity as a consequence of reduced prey was estimated to be 5% over the entire brood year. This can be considered lost capacity that is probably compensated elsewhere via increased occupancy (emigration to other habitat units within the reach), which is not accounted for in the model. © 2011 SETAC.


Racke K.D.,Dow AgroSciences | McGaughey B.D.,Compliance Services International
ACS Symposium Series | Year: 2012

Shortly after the U.S. Environmental Protection Agency (EPA) assumed responsibilities for federal pesticide regulation under FIFRA (Federal Insecticide, Fungicide and Rodenticide Act), the Endangered Species Act (ESA) became law. Although FIFRA deals with licensing and registration under the mandate "not to cause unreasonable adverse effects" on the environment, ESA obligations include ensuring that registration actions "are not likely to jeopardize" the continued existence of an endangered species, and require consultation with the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS) if the registration action "may affect" an ESA-listed species. Over the years, EPA has modified data requirements, developed ecological risk assessment methodologies, and proposed several successive field implementation plans, including county bulletins, to ensure protection of endangered species in pesticide regulatory decision-making. Industry has also been active in generating supporting data, and a significant outcome has been development of a task force-sponsored species location system. During the past 35 years, EPA has developed a conservative, screening-level ecological risk assessment approach designed to provide a high degree of protection for ecosystems, including endemic endangered species. However, limited success has been experienced in forging a collaborative process between EPA and the Services (USFWS, NMFS) with respect to ESA consultation activities. A variety of operational and technical issues has impeded progress in effectively meshing FIFRA and ESA obligations. At present, efforts to make a fresh start on ESA-related consultations via the EPA Registration Review program are making slow progress, and a spate of ESA-related lawsuits unrelated to Registration Review has clogged the system and exacerbated unresolved issues. This chapter reviews historical developments related to implementation of ESA obligations for pesticide regulation, examines the current state of affairs with respect to Registration Review and litigation, and highlights a movement toward process and science improvements described in succeeding chapters of this book. © 2012 American Chemical Society.


McGaughey B.D.,Compliance Services International | Hall A.T.,Bayer AG | Racke K.D.,Dow AgroSciences
ACS Symposium Series | Year: 2012

It is clear, from the wealth of information and diverse methods discussed by the contributors of chapters in this book, that good science abounds with respect to endangered species assessment. However, definition of whose scientific approach is the "right one" and how a regulatory process should incorporate that science is only now emerging after more than 30 years of uneven and incomplete policy development. This final chapter explores ways in which the "nexus that perplexes" - the complicated intersection of the Federal Insecticide, Fungicide and Rodenticide Act and the Endangered Species Act - might be best improved within the processes that define the current framework of consultation under the Endangered Species Act. Ideas presented by the chapter authors for this volume relate to many lessons learned and this collective wisdom can be applied to clarify a common vision for what successful consultation may look like in the future. A first step toward practical improvement may be for all parties to step back from differences in perspectives, favored methods, and intensity of scientific scrutiny and ask the simple question, "Just what is it we really need to do to cooperatively develop and successfully advance this vision?" This chapter looks back on the contributions made by all authors and distills that wealth of thought to a platform of recommendations for process improvement. Recommendations are made for three main initiatives: (1) establish trust and a cooperative process between agencies; (2) provide resources, or leverage existing resources, to establish priorities for accomplishing the task at hand; and (3) improve communication with and early involvement of stakeholders. © 2012 American Chemical Society.


Maund S.J.,Syngenta | Campbell P.J.,Hill International | Giddings J.M.,Compliance Services International | Hamer M.J.,Hill International | And 4 more authors.
Topics in Current Chemistry | Year: 2012

In this chapter we review the ecotoxicology of the synthetic pyrethroids (SPs). SPs are potent, broad-spectrum insecticides. Their effects on a wide range of nontarget species have been broadly studied, and there is an extensive database available to evaluate their effects. SPs are highly toxic to fish and aquatic invertebrates in the laboratory, but effects in the field are mitigated by rapid dissipation and degradation. Due to their highly lipophilic nature, SPs partition extensively into sediments. Recent studies have shown that toxicity in sediment can be predicted on the basis of equilibrium partitioning, and whilst other factors can influence this, organic carbon content is a key determining variable. At present for SPs, there is no clear evidence for adverse population-relevant effects with an underlying endocrine mode of action. SPs have been studied intensively in aquatic field studies, and their effects under field conditions are mitigated from those measured in the laboratory by their rapid dissipation and degradation. Studies with a range of test systems have shown consistent aquatic field endpoints across a variety of geographies and trophic states. SPs are also highly toxic to bees and other nontarget arthropods in the laboratory. These effects are mitigated in the field through repellency and dissipation of residues, and recovery from any adverse effects tends to be rapid. © 2011 Springer-Verlag Berlin Heidelberg.


Frank A.R.,Compliance Services International | McGaughey B.D.,Compliance Services International | Cummings J.,FMC Corporation | Longacre S.,FMC Corporation | Mitchell G.,FMC Corporation
ACS Symposium Series | Year: 2012

As directed by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 3(g), and mandated by the Food Quality Protection Act, the U.S. Environmental Protection Agency (EPA) established a program, referred to as Registration Review, to review all pesticide registrations every 15 years. The program is intended to ensure that registered pesticides do not cause unreasonable risk to human health or the environment. The active ingredient clomazone was one of the first conventional pesticides reviewed under this program to have a national-level federally listed species assessment conducted by the EPA, and independently, data to support this assessment submitted by the registrant, FMC Corporation. EPA conducted the clomazone assessment as a pilot to explore methods to identify federally listed species that may be affected by the pesticide's uses. The U.S EPA's endangered species effects determination for clomazone conducted under the Registration Review program is reviewed and supportive data submitted by the registrant is discussed. Recommendations on how the endangered species assessment process in Registration Review can be further enhanced through reliance on data of this nature are also presented. © 2012 American Chemical Society.


Giddings J.,Compliance Services International | Gagne J.,Compliance Services International | Sharp J.,MGK
Environmental Toxicology and Chemistry | Year: 2016

A series of acute toxicity tests with the amphipod Hyalella azteca was performed to quantify the synergistic effect of piperonyl butoxide (PBO) on pyrethrin toxicity. Concentrations of PBO <4 µg/L caused no toxicity enhancement, whereas toxicity increased with PBO concentrations between 4 µg/L and 15 µg/L. Additive toxicity calculations showed that true synergism accounted for an increase in pyrethrin toxicity (decrease in median lethal concentration) of 1.4-fold to 1.6-fold and varied only slightly between 4 µg/L and 15 µg/L PBO, whereas direct toxicity of PBO accounted for an additional increase in mixture toxicity (up to 3.2-fold) that was proportional to PBO concentration. The results can be used to assess the risk of measured or predicted co-occurring concentrations of PBO and pyrethrins in surface waters. Environ Toxicol Chem 2016;35:2111–2116. © 2016 SETAC. © 2016 SETAC


Ma Q.,Exponent, Inc. | Reiss R.,Exponent, Inc. | Habig C.,Compliance Services International | Whatling P.,Cheminova
ACS Symposium Series | Year: 2012

The joint probability distribution analysis (JPDA) utilizes the full exposure distribution and the dose-response curve to determine the probability of an adverse effect occurring and the magnitude of the effect. It accounts for uncertainty from variations in exposure concentrations and species sensitivities and can better address the probability of risks of pesticides than the standard, Environmental Protection Agency regulatory risk quotient (RQ) method. In this application, the concern is for effects of dimethoate on salmonid prey which have differing sensitivities. Thus, accounting for variability in response is important. While use of the RQ method indicated potential risks to aquatic invertebrates, results of JPDA showed minimal risks, despite using an exposure model that likely significantly overestimates water concentrations. This paper demonstrates the application of the JPDA methodology to refine an ecological risk assessment and develop more accurate risk estimates. © 2012 American Chemical Society.


Hall A.T.,Bayer AG | McGaughey B.D.,Compliance Services International | Gagne J.A.,Compliance Services International
ACS Symposium Series | Year: 2012

Risk assessment procedures used by the U.S. Environmental Protection Agency (EPA) for pesticides have been worked out over a period of years and are now well-established and well-known by the regulated community. Similarly, the nature of the database needed to support a standard EPA risk assessment for a pesticide is well-established and well-known. These procedures and data are used to make assessments for endpoints that are deemed relevant to the questions at hand for a particular pesticide. In contrast, no instructional guidelines for evaluating data reliability or relevance for the purpose of endangered species assessments for pesticides are in place. This circumstance has resulted in considerable confusion and uncertainty in the overall consultation process. In this paper, we begin with an overview of some methods used to ensure that high quality data are selected for a risk assessment and we then examine what criteria might be applied to whether data are in fact relevant for a given assessment. Finally, we provide examples of how improperly selected data can strongly influence the conclusions of an assessment, if such data are not of high quality or solid relevance. But we also provide guidance on how to decide which studies beyond guideline studies may (and should) be incorporated into the risk assessment. This paper concludes that no instructional guidelines for evaluating relevancy and reliability are in place, and shows that peer review does not always serve that purpose. Consequently, the risk assessor must use due diligence to consider risk assessment and protection goals in light of data reliability and relevance. Suggestions provided here on how a risk assessor might weigh data for use in a given risk assessment hopefully enhance the assessor's ability to utilize or question data and give it the proper role in the given risk assessment exercise. © 2012 American Chemical Society.

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