Compliance Services International (CSI) Presentations at SciCon2, the SETAC North America 41st Annual Meeting (Virtual) from 15-19 November 2020

SciCon2 – the Society of Environmental Toxicology and Chemistry (SETAC) North America 41st Annual Meeting (Virtual) is just around the corner 15-19 November 2020, and Compliance Services International (CSI) consultants Bernalyn McGaughey, Larry Brewer, Cliff Habig, Jeff Wirtz, Ashlea Frank, Leah Duzy, Jennifer Stafford, and David Campana will be in attendance with multiple staff presentations to be presented. #SETACSciCon2

CSI is a proud SETAC North America Sustaining Member


SETAC – SciCon2: CSI Staff Presentations

5.04.18  Evaluation of the Potential Effects of Pesticide Registrations on Listed Species: A Case Study With Methomyl and a Federally Listed Threatened Species.

Bernalyn McGaughey, Ashlea Frank, Jennifer Stafford, Larry Brewer, Leah Duzy, Twyla Blickley, Patrick Havens

Live Session Discussion (50 Min.) – Time:  2:00 PM (CST).

Abstract: The U.S. Environmental Protection Agency (EPA) recently issued a Revised Method for National Level Listed Species Biological Evaluations of Conventional Pesticides (“revised method,” March 2020). Concurrent with publication of the revised method, EPA issued two Biological Evaluations (“BE’s”). EPA found 1,114 ESA-listed species “likely to be adversely affected” (“LAA”) by the use of methomyl. With 1,114 species determined as “LAA,” the final BE and forthcoming Services Biological Opinion, based on the BE, will only be realistic and reflective of effects reasonably certain to occur if: (1) risk assessment is refined for every species defined as “LAA” to better capture the actual relationship between exposure and hazard (a daunting task for this number of species and Agency resources); (2) the prediction of risk is put into context with respect to the status, recovery goals and conservation needs of the species; and/or (3) an efficient means is established to balance species assessment to the holistic needs of the species. We use methomyl and the listed terrestrial invertebrate Dakota skipper as a case study, in the spirit of the definition of “case study”: “Case studies are based on an in-depth investigation of a single individual . . . ” and “are analyses of . . . policies, institutions or other systems that are studied holistically by one or more methods.” We conducted additional analyses incorporating additional information on methomyl properties and use, and agronomic and conservation practices to illuminate possible pathways to understanding the environmental baseline for the species in the context of effects and activities that are reasonably certain to occur.

5.04.12   Refined Methodology for a National Level Listed Species Assessment for a Modern Herbicide.

Larry Brewer, Leah Duzy, Jennifer Stafford, Cliff Habig, Ashlea Frank, David Campana, Chad Jones, Jeffrey Giddings, Jeffrey Wirtz, Richard Kemman, Bernalyn McGaughey, Dwayne Moore, Patrick Havens, T. Michelle Blickley

Live Session Discussion (50 Min.) – Time:  2:00 PM (CST)

Abstract: The US Environmental Protection Agency (EPA) issued a Revised Method for National Level Listed Species Biological Evaluations (“revised method”) in March 2020 that provided guidance for conducting pesticide evaluations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). The revised methods are intended to be used to evaluate currently registered pesticides, many of which are older chemistries. In utilizing the revised methods for the carbaryl and methomyl draft Biological Evaluations (BEs), EPA acknowledged that many assumptions were made, and that considerable uncertainties remain. The availability of new herbicide chemistries that are effective at low rates are becoming more important in light of the growing need for tools with a good fit in weed resistance management programs, while exhibiting minimal potential for undesirable environmental impacts. In many cases, such herbicides are difficult to assess in the context of EPA’s revised method. This presents opportunities to develop many aspects of an ESA-listed species assessment not yet fully realized by EPA. This work explored various approaches and refinements including the application of spatial data to estimate the proximity of species’ range and designated critical habitat to a representative herbicide’s action areas (use sites plus off-site transport zone), developing crop groups and use sites that are more reflective of agronomic practices and labeled uses, and developing more realistic estimates of listed plant exposure in the off-site transport zone by incorporating NOAA wind speed data into drift and drift effects modeling. This presentation discusses the overall approach and methodology ,the unique challenges that a modern herbicide presents, and how scientifically sound data reflective of on-the-ground conditions all inform our understanding of risk and effects.

5.04.03 Towards the Best Available Information for FIFRA/ESA Assessments.

Ashlea Frank, David Campana, Tilghman Hall, Robin Charlton

Poster Presentation – Time:  2:00 PM (CST)

Abstract: For over 20 years, the FIFRA Endangered Species Task Force (FESTF) has contributed to the aggregation of data involved in the evaluation of pesticides under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The use of current and consistent data on species is important to the evaluation of pesticide impact on species listed under the Endangered Species Act (ESA), as conducted by the US Environmental Protection Agency (EPA). These evaluations are subject to subsequent consultation by the US Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) depending on the species under their management. As we have reported previously, FESTF’s ongoing efforts have included the aggregation of the best available information to inform species range maps and species attribute information, produced while working under the direction and supervision of FWS. The data products produced by these aggregation efforts are housed in an information management system, Gopher, used to store and deliver FESTF’s work products. In the aggregation process, Hawaiian species presented the biggest challenge because there are a high number of listed species in the Hawaiian Islands and the federal and state resources to deal with them are limited. As such, the effort to compile data for Hawaiian listed species provides a good model for the data access and aggregation process in a situation where data are widely scattered: although data may be plentiful, access to it and consistent use of it present a challenge when there is no strong central source for housing it and keeping it current. This presentation will review FESTF’s development of range maps and attribute data for species in the Hawaiian Islands, focusing on the means taken to ensure accurate and authoritative sources are those captured for aggregation. We also explain the subsequent steps taken to incorporate these work products into the FIFRA/ESA assessment and consultation process.

5.04.17 Using Historical Wind Speed Data to Refine Estimates of Offsite Pesticide Deposition.

David Campana, Chad Jones, Leah Duzy, Larry Brewer, Michelle Blickley

Poster Presentation – Time:  2:00 PM (CST)

Abstract: The US Environmental Protection Agency (EPA) released a finalized method for conducting national-level biological evaluations of species listed under the Endangered Species Act (ESA) in March 2020. Part of this method involves the assumption that the action area includes drift deposition of the applied pest control product 792 m (2600 ft.) beyond the boundary of the use site in all directions. The depositional drift curve, typically modeled using the AgDRIFT model, is used to find a critical threshold distance beyond which deposition would be of negligible concern for a determined toxicity threshold of a given species. Our analysis uses publicly available historical wind rose data from approximately 2,500 weather stations to examine different approaches to calculating localized wind speed during pesticide application for use as an input in AgDRIFT, to inform the estimation of chemical deposition in the offsite transportation zone. Results are demonstrated using a case study, quantified and qualified using the same metrics used in EPA’s finalized method. The relative benefits and limitations of the different approaches to calculating local wind speed and the value of applying different approaches for different stages of an ESA risk assessment are discussed.

5.04.20 A Tool to Rapidly Sequence ESA-Listed Species for FIFRA/ESA Processes.

Leah Duzy, Ashlea Frank, Tony Burd, Dan Campbell, Lula Ghebremichael, Ya-Wei Li

Poster Presentation – Time:  2:00 PM (CST)

Abstract: Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the registration of a pesticide requires compliance with the Endangered Species Act (ESA) which includes evaluating the potential risk of the use of the pesticide on ESA-listed species and designated critical habitats. For the agencies responsible for registration and consultation, this can be an extensive exercise involving many complex datasets and processes. For the pesticide registrant seeking registration, this can present an opportunity to explore ways to adequately protect ESA-listed species while also considering what is feasible for the end-user. We developed a tool that indexes factors that are important to the analysis of risk, as well as imperilment and conservation needs of each ESA-listed species. With these factors, the Rapid Species Assessment Tool (RSAT) sequences species so that the registrant and agencies can have informed discussions about conservation measures that may be the most appropriate for each species in the FIFRA/ESA assessment and consultation process.

5.04.15 Refinements to EPA’s TerrPlant Non-Target Plant Assessment Model.

Clifford Habig

Poster Presentation – Time:  2:00 PM (CST)

Abstract: EPA currently uses a Tier I screening level model, TerrPlant, to evaluate potential effects on non-target terrestrial plants from labeled agricultural pesticide applications. This conservative model is used to assess potential pesticide effects on both endangered and non-endangered terrestrial plants through three distinct modules. One module estimates effects of runoff and drift from the treated field (1 acre; A) to a nearby untreated terrestrial habitat, the second module estimates effects of runoff and drift from a larger treated area (10 A) to a nearby low-lying wetland or bog area, and the third module estimates the effect of spray drift only to a nearby untreated area. The model has no temporal component. Many aspects of the model are based on conservative hard-wired defaults and assumptions. Estimated exposures (EECs) are compared to endpoints from EPA’s standard non-target plant tests using small, vulnerable-stage species, with endpoints most commonly based on sub-lethal effects. Currently, EPA does not refine the results of this Tier I model if results indicate possible adverse effects; rather the default conclusion is that adverse effects from a pesticide use are likely. Refinements to both the runoff component and the drift component result in more relevant estimates of exposure through both pathways. Runoff is currently estimated by the pesticide’s water solubility, and can be refined by using the soil adsorption coefficient (Kd/Koc), soil incorporation, as well as including a temporal component that accounts for degradation after application. Currently available, higher tier modeling can be conducted to estimate the runoff contribution over time. Drift can be refined using various drift models as well as available field data that indicate far less drift, particularly with respect to drift distance by considering different droplet size distributions, less than maximum assumed wind speed, and seasonal directional considerations during application. Effects can also be refined through more detailed evaluation of the results on individual test species rather than relying on the default most sensitive species. These refinements can drastically change conclusions concerning potential effects on non-target plants. Examples of these refinements will be presented.


If you are attending and would like to have a conversation regarding CSI’s global scientific, regulatory, and technical consulting services pertaining to Crop Protection, Biocides, Chemicals, Consumer Product Sectors in the US, EU. Latin America, China, or Taiwan please contact one of us during the meeting, or email info@complianceservices.com.


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