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Ecological Risk Assessment Under FIFRA and ESA

Completed

A committee of the National Research Council (NRC) will examine scientific and technical issues related to the methods and assumptions used by the U.S. Environmental Protection Agency (EPA), the U.S. Fish and Wildlife Service (FWS), and the National Oceanic and Atmospheric Administration (NOAA) to conduct scientific assessments of ecological risks from pesticides registered by EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to species listed under the Endangered Species Act (ESA). The range of scientific studies needed to make such assessments will be considered, including ecological, agricultural, hydrological, toxicological, and exposure studies.

Description

A committee of the National Research Council (NRC) will examine scientific and technical issues related to the methods and assumptions used by the U.S. Environmental Protection Agency (EPA), the U.S. Fish and Wildlife Service (FWS), and the National Oceanic and Atmospheric Administration (NOAA) to conduct scientific assessments of ecological risks from pesticides registered by EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to species listed under the Endangered Species Act (ESA). The range of scientific studies needed to make such assessments will be considered, including ecological, agricultural, hydrological, toxicological, and exposure studies. The committee will develop conclusions reflecting the use of scientific principles and to facilitate a more holistic approach to assessing risks across the agencies, considering the intent of the ESA and of FIFRA. The expectation is that the NRC's conclusions would also be applied to the methods and assumptions used for scientific assessment of federal actions under the Clean Water Act to species listed under the ESA. Policy issues related to decision making will not be addressed. Specific topics that the committee will consider to the extent practicable include the following:

· Best available scientific data and information. The Services and EPA approach the identification of “best available scientific information” using a variety of differing protocols pertaining to the type and character of scientific information that may be appropriate for these evaluations. Some of these approaches pertain to the character of the information as consensus information, peer-reviewed information, regulatory studies supporting pesticide registrations, or other published and unpublished information. The NRC will evaluate those protocols with respect to validity, availability, consistency, clarity, and utility.

· Sub-lethal, indirect, and cumulative effects. The ESA requires the consideration of direct, indirect, and cumulative effects on listed species and habitats in the consultation process. The Services and EPA have used differing approaches on how to characterize indirect, sub-lethal, and cumulative effects. The NRC will review the best available scientific methods for projecting these types of effects and consider options for the development of any additional methods that are likely to be helpful.

· Mixtures and Inerts. Assessing the effects of the use of chemical mixtures, either in formulated products or as used at the field level, remains a complex and difficult challenge, as is assessing the effects of mixtures of pesticides and other environmental contaminants. Projecting the effects of inert ingredients such as adjuvants, surfactants, and other pesticide product additives is also an area of continuing challenge. The NRC will consider the scientific information available to assess the potential effects of mixtures and inert ingredients.

· Models. There is a range of approaches to the development and use of modeling to assist in analyzing the effects of actions such as using pesticides or alternatives to that use, and active issues remain about the use of unpublished models or the assumptions used in the choice of the available models for any particular analysis of effects. The NRC will assess the protocols governing the development of assumptions associated with model inputs, the use of certain models (e.g., spray drift), and the use of sensitivity analyses to evaluate the impact of multiple assumptions on the interpretation of model results.

· Interpretation of Uncertainty. There are a variety of methods for documenting and interpreting uncertainties and evaluating the extent to which uncertainties impact confidence in the scientific conclusions associated with a jeopardy decision. In particular, the NRC will consider the selection and use of uncertainty factors to account for lack of data on formulation toxicity, synergy, additivity, etc., and how the choice of those factors affects the estimates of uncertainty.

· Geospatial Information and Datasets. Location of the habitat is an important component of successfully protecting the impacted species. Much variability in datasets, geospatial layers, and scale contributes to uncertainty. The NRC will consider what constitutes authoritative geospatial information, including spatial and temporal scale, that most appropriately delineates habitat of the species and the duration of potential effects.

In its deliberations, the NRC will focus on the scientific and technical methods and approaches the agencies use in determining risks to endangered and threatened species associated with the use of pesticides. The NRC will provide conclusions as appropriate about techniques the agencies might apply or use to improve those methods and approaches using scientific principles to support their decision-making.

As examples, the NRC will consider three recent consultations between NOAA and EPA on the effects of EPA’s proposed FIFRA actions on Pacific salmonids as reference points for its work. The NRC will use the consultations as examples of the various agencies’ scientific approaches and methods, but will not evaluate the consultations themselves, or the decisions resulting from them, and it will not limit its considerations strictly to aquatic species.

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Committee Membership Roster Comments

10/4/2011: Usha Varanasi was provisionally appointed to the committee but will not be serving

2/6/2012: Committee membership changed with the resignation of Peter M. Kareiva

6/8/2012: Committee membership changed with the resignation of Jim Cowles

9/14/2012: Committee membership changed with the resignation of Scott McMurry

11/30/2012: The National Research Council has been informed that Daniel Goodman is deceased as of 11/15/2012

Sponsors

EPA

Staff

David Policansky

Lead

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