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SCB Recommends Improvements to EPA’s Endangered Species Risk Assessment Process for Pesticide Exposure

October 16, 2012. Synthetic pesticides are widely used throughout the United States in agriculture, forestry, pest-control, and for household use.  The Environmental Protection Agency (EPA) is responsible for approving and regulating the over 18,000 pesticide products that are commercially available within the United States.  As part of this responsibility, the EPA has a duty under the Endangered Species Act’s (ESA) consultation process to insure that its actions do not jeopardize any threatened or endangered species, and that the use of pesticides does not adversely modify or destroy any listed species’ critical habitat.

Unfortunately, the EPA has struggled to meet its obligations under the ESA to insure that its actions do not harm threatened and endangered species.   Because most pesticides are used across vast portions of the United States on a variety of crops at different times of the year, any particular pesticide could potentially impact dozens of threatened and endangered species.  As a result, consultations regarding the use of pesticides in the environment pose significant scientific challenges.

In August, the EPA proposed several procedural changes to its pesticide review process to increase and enhance opportunities for stakeholder input on endangered species consultations.  Some of the changes proposed by EPA could potentially make the ESA consultation process more transparent to the public.  However, the EPA proposal does not address several long-standing problems with the EPA’s risk assessment process for endangered species.  In its comments today, SCB has made the following recommendations:

  1. The EPA should allow all interested persons an equal opportunity to review draft Biological Opinions and the recommended conservation measures designed to protect endangered species at the same time in a transparent manner.
  2. While it is important to implement procedural improvements, it is more important for the EPA to address the substantive deficiencies in the current risk assessment process. The EPA must take into account the cumulative and synergistic effects of multiple pesticides interacting in the environment, and how those real-world interactions affect endangered species.
  3. Currently, the EPA focuses only on the acute harm that pesticide exposure may cause to listed species. The EPA must continue to do this, but it is equally important to evaluate the possibility that a pesticide could adversely modification or destroy critical habitat, thereby reducing a listed species’ ability to forage successfully or migrate.
  4. The EPA should consider each species’ current conservation status when evaluating the risk a pesticide would poset to that species’ survival and recovery.  Currently, the EPA uses a one-size-fits-all approach that allocates risk to threatened and endangered species, which ignores the real-world factors that may affect a threatened or endangered species’ ability to be protected and recovered under the ESA.

Read SCB’s comments HERE.

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