A Risk Assessment Process for Establishing Negligible Risk Earlier in National-Scale Endangered Species Assessments

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1 CLA & Rise Spring Conference April 2016 A Risk Assessment Process for Establishing Negligible Risk Earlier in National-Scale Endangered Species Assessments Matt Kern (Ecotoxicology & Risk Assessment) Katherine Kapo (Ecotoxicology & Risk Assessment) Nathan Snyder (Exposure & Risk Assessment) Josh Amos (Geospatial Analysis) Megan Sebasky (Geospatial Analysis) Dan Perkins (Exposure & Risk Assessment) Gregg Hancock (Ecotoxicology & Risk Assessment) Amelie Schmolke (Population Modeling & Risk Assessment) 1 1

2 National-scale challenges in pesticide risk assessment for listed species Effective screening and lower-tier assessment phases are critical to identify and prioritize species for further assessment 1592 Species USFWS Environmental Conservation Online (ECOS) April 10, 2016 Screening that is not ecologicallyinformed can result in unnecessarily high numbers of species requiring advanced assessment Result can be a misuse of resources and a disservice to the overall goal of species protection

3 High Level Assumptions? Protection of listed species is important to all of us Action (potential stressor) is important.scientifically and/or legally Assessment goal is not to prioritize and help direct resources to stressors of greatest concern to species Use best available information and science to make logical risk management decisions (reliable and relevant) Complete understanding of species locations and life histories Assume the chemical applied to all potential use sites in the US (100% market share view) Initial Risk Assessment Mindset 1) Some chemical proximity: assume risk, benefit of the doubt to the species, risk cannot be precluded 2) Some chemical proximity: evaluate causality, probability.optimize risk management decision making

4 Optimal listed species risk assessment process FIFRA Assessments Scientific Meetings Inter-Agency Interim Guidance Past Biological Opinions Legal Decisions Current Biological Evaluations Ongoing Scientific Learnings

5 Starting a risk assessment-what we know? Product indications (herbicides, fungicides and insecticides) are designed to be efficacious to a select group of pest organisms Entirely logical that there will be a range of sensitivities between non-target species taxon but also within more sensitive groups We typically will have a FIFRA assessment to provide a beginning site picture The point: we are not starting from scratch as we begin an ESA

6 Parallel or prioritized efforts early on Toxicity data (low sensitivity taxa) Highest exposure scenario EECs Species (groups) Negligible direct risk conclusions (deterministic) Use patterns (e.g. county-level) Species locations (e.g. county-level) Examples: Examples: Birds: LD50>2000 mg/kg-bw, Lack of county level overlap LC50> 5000 mg/kg, NOEC=1000 ppm Species location (plus conservative drift buffer) Fish: LC50>100 ppm, NOEC=10 ppm Plants: NOEC/EC25 > highest on field use rate Improved spatial detail

7 Views on toxicity thresholds Acute EC50 (ppb) 1/20 EC50 (0.05 LOC) 1 in 1 million 1 in 100,000 1 in 10,000 1 in 1,000 1 in in

8 Example Insecticide-Potential Direct Risk Taxonomic Group Fish & Amphibians Birds & Reptiles Early Finding Result Listed Species 1 Exposure significantly < toxic response Negligible Risk 197 Exposure significantly < toxic response Negligible Risk 142 Wild Mammals Exposure significantly < toxic response Negligible Risk 98 Plants Exposure significantly < toxic response Negligible Risk 898 Terrestrial & Aquatic Invertebrates Some exposures > toxic response Evaluate further 257 Total= USFWS Environmental Conservation Online (ECOS) April 10, 2016

9 Evaluating Invertebrates Species Group Listed Species Variables Arachnids 12 Clams 88 Corals 6 Crustaceans 26 Insects 75 Between & Within Groups Range in sensitivities Range in habitats Range in distributions Range of exposures Snails 50 Assumed additional analysis is needed assumed risk

10 Grouping species for effective analysis Toxicity data Species life history Screening effects thresholds Species surrogacy (groups) Grouping & Analysis of Species Direct/Indirect negligible risk conclusions (deterministic) Screening models Species life history Screening exposure scenario EECs Species scenarios (groups) Grouping & Analysis of Species

11 Grouping Species for Effective Analysis Goal: Use available species data for delineation of habitat/life history groups Quantitative multi-variate cluster analysis of habitat and life history information (habitat preferences, tropic level/diet, phenology etc.) Information informs assignment of toxicity values to species (taxonomy), exposure scenarios and ecological modeling development

12 Grouping Species for Effective Analysis

13 Grouping species for effective analysis Grouping by habitat (bins) Grouping terrestrial species for evaluation Thousands of bin x use pattern x endpoint combinations Database exercise prioritizing most difficult Improved species detail

14 Grouping Species for Effective Analysis Group 1 (listed crayfish) Toxicity surrogate: crayfish Relevant use patterns, rates, intervals etc. Established exposure scenarios (habitats) Regional model inputs Urban and residential Group 2 (listed beetles) Toxicity surrogate: rove beetle Relevant use patterns, rates, intervals etc. Established spray drift distances of interest (Field to distance x ) Urban and residential Group 3 (cave species) Conditional attributes that might mitigate risk

15 Analysis of Aquatic Species

16 Analysis of Aquatic Species

17 Terrestrial Analysis

18 Terrestrial Analysis Improved spatial detail Year Grassland/ Pasture/Hay/ Forage/Range Labeled Crop Percent Area (within 300m) Non- Natural Labeled Vegetation Crop Urban Developed Water/ Wetlands % 0.09% 59.26% 0.05% 8.39% 30.14% % 0.01% 60.23% 0.03% 9.39% 29.11% % 0.05% 64.07% 0.01% 9.39% 24.73% % 0.04% 62.74% 0.01% 9.40% 24.46% % 0.02% 18.80% 0.00% 10.02% 68.29%

19 Prioritizing Addition Assessment Bay Checkerspot Butterfly Habitat Example of representation of species habitat by land use composition for a listed species

20 Insensitive groups 1592 Species Negligible risk to terrestrial vertebrates No co-occurrence Negligible risk to plants Negligible risk to 27 invert. species Negligible risk to Aquatic Vertebrates 230 Invertebrate Species Group species based on toxicity surrogate & exposure scenarios Group 1: 8 species Group 2: 15 species Groups Species Group 11: 47 species Group 12: 13 species Negligible risk 8 species Negligible risk to 7 species Negligible risk to 67 species Negligible risk 20 species Negligible risk 6 species 122 Species for Additional Assessment

21 Advancing assessment

22 Prioritizing Addition Assessment-Dashboard View

23 Advancement Opportunities. Decision Gaps

24 Advancement Opportunities. Decision Gaps Example Invertebrate SSD Improved species detail

25 Conclusions Early assumptions may matter the most Wealth of information from product registrations Wealth of species detail needs to be organized and used Range of group (species) sensitivities Range of habitats and thus exposure potential Needing to continue with assessment risk Advancement in decision criteria and prioritization is essential for protection of species 12

26 Thank you! For more information contact : Matt Kern (kernm@waterborne-env.com) Nathan Snyder (snydern@waterborne-env.com) Josh Amos (amosj@waterborne-env.com) Amelie Schmolke (schmolkea@waterborne-env.com)