Transcript No Slide Title

Wildlife and Aquatic Species
Hazard Analysis
Data from the same sources as
human health data
Wildlife data bases
Data includes a mix of species
representing a variety of
habitats and feeding niches
There are significant data
gaps
especially in chronic and
subchronic toxicity data
Available Toxicity Data
Presented alphabetically
By chemical name
Within topics of discussion
Toxicity Data
(acute, subchronic and chronic)
CP/P -- FEIS -- P. 6-8/9
Wildlife Toxicity Data
Numbers the same as for human
health - 4,320 mg/kg...
A few additional data points
available for deer and other test
animals
Glyphosate Toxicity Data
(by formulation – relevant to wildlife)
CP/P -- FEIS -- P. 6-24/25
Glyphosate Toxicity Data
(by formulation – tabular form)
CP/P -- FEIS -- P. 6-26/28
All 3 pgs
Toxicity to Aquatic Organisms
Significant difference between
Roundup versus Accord and
Rodeo
Surfactant in Roundup poses
significant inhalation risk to fish
Wildlife and Aquatic Species
Exposure Analysis
Representative Species are
Used in the Analysis
Animal Exposures
Direct spray (dermal)
Preening (ingestion)
Foodstuffs (ingestion)
Breathing (inhalation)
(relevant for fish)
Other Exposure
Considerations
Body size
Food consumed (amount)
Respiration rate
Feeding range of the species
(both size of range and variety of foodstuffs in the range)
Wildlife and Aquatic
Species Risk Analysis
EPA Standards
Non-T&E Species
Terrestrial species
Dose must be < 1/5 LD50
Aquatic species
Dose must be < 1/10 LC50
EPA Standards
T&E Species
Terrestrial species
Dose must be < 1/10 LD50
Aquatic species
Dose must be < 1/20 LC50
1/5 LD50 Criterion Table
CP/P -- FEIS -- P. 8-11
Application of the 1/5 Rule
No animal species is at risk when
the EPA 1/5 LD50 standard is
applied to modeled potential
glyphosate doses
This is true of both the realistic
and the extreme scenarios
Accident Scenarios
CP/P -- FEIS -- P. 8-32/33
Some Conclusions
Concerning Wildlife
from the Risk Assessment
Typical application rates result
in doses of
1/5 LD50 to wildlife
Primary Concern for non-T&E
Species
resulting from habitat alteration
Aquatic Species
Are often at risk from accidents
T&E Species
Some risk under the EPA standards
Completing Appendix A
Glossary
References cited
Subject index
First Pages
Table of Contents
List of Figures
List of Tables
Front – Table of Contents
Back – Subject Index
Scope & Issues
Affected Environment
Environmental
Consequences
Summarizes
Expected effects on
a variety of environmental
elements
Including
Human health and safety
Vegetation
Wildlife
T&E Species
Soil
Water quality
Air quality
Visual quality
Cultural resources
and
Socioeconomic conditions
Human Health and Safety
Chapter IV
Reviews risk assessment
methodology
Documents incomplete or
unavailable data
Presents a readable summary of
the risk assessment
Projects MOS data
Public Risk
Typical Scenario
CP/P -- FEIS -- P. IV-15
Public Risk
Maximum Scenario
CP/P -- FEIS -- P. IV-16
Worker Risk
Typical Scenario
CP/P -- FEIS -- P. IV-17
Worker Risk
Maximum Scenario
CP/P -- FEIS -- P. IV-18
Human Risk
Accident Scenario
CP/P -- FEIS -- P. IV-19
Lifetime Cancer Risk
CP/P -- FEIS -- P. IV-21
Summary of Accidents
(Region 8’s CA-1 Record; 3 yrs)
CP/P -- FEIS -- P. IV-26-30
MOST
FULL
PAGES
Vegetation Section
Chapter IV
Presents a generalized summary
of herbicidal effects on plants
(target and non-target)
Wildlife Section
Chapter IV
Summarizes the assessment of tools
Summarizes incomplete and unavailable wildlife data
Summarizes wildlife risk assessment data
Discusses toxicity information – relating it to the EPA’s
standards
Indicates that data beyond that used in the human
health analysis is limited
Terrestrial Accident Risk
(5 gal spill in a farm pond)
CP/P -- FEIS -- P. IV-63
Aquatic Accident Risk
(100 gal. spill into a reservoir)
CP/P -- FEIS -- P. IV-65
Wildlife / Herbicide
Toxicity Conclusions
2,4-D, 2,4-DP or triclopyr
can cause negative effects on some species
An accidental spill of herbicide can cause risk
to most species
Diesel oil and kerosene pose a risk to nesting
birds
All P.E.T.S. plants are at some risk from
herbicide use
Discusses
Habitat effects
-- food, water, cover and their
arrangement as a function of method,
intensity and frequency of pesticide
application --
Habitat Alteration Comments
Change affects different species in
different ways
Mitigating measures will generally
be necessary
Selective application methods
pose less risk than broadcast
ones
Perform Site-specific Analysis
Set your objectives before analysis
(include the desired future condition as the target of the analysis)
Review specific tools, methods and chemicals
available for the task
Consider habitat alteration and other
secondary effects
Develop and document mitigations
Site Preparation Habitat
Effects
Reduces forage
(selective treatment causes less reduction)
Can benefit cavity nesters
Release
Habitat Effects
Broadcast methods reduce hard mast and
suppress soft mast
Effect varies with the herbicide used
Selective methods are very good for
enhancing the hardwood component
This is often the critical step in moving
towards the desired future condition
STAND IMPROVEMENT
HABITAT EFFECTS
Herbicides can be used to reduce or
increase the hardmast component
They can improve the stand for wildlife
In some areas they can be used to protect or
enhance specific plants such as grapevines
RIGHT-OF-WAY
HABITAT EFFECTS
Herbicides are a viable alternative to mowing
Selective treatments can be used to improve
deer and bird habitat (create linear wildlife
openings)
T&E Species Section of
Chapter IV
General discussion
Much of it relates back to the wildlife section
T&E Toxicity Effects
Discussion
Level of concern is very restrictive
It is based on the EPA standard for acute
toxic effects
(Terrestrial <1/10 LD50 and
Aquatic <1/20 LC50)
Allows only ½ the dose allowed for the
general wildlife population
T&E Toxicity Effects
Discussion
Typical herbicide application rates are
generally acceptable under the EPA standard
Extreme rates of application commonly
exceed the standard
T&E Habitat Effects
Herbicides are valuable tools for wildlife
habitat maintenance or improvement
Care must be taken to remain within low-risk
parameters
Spills generally present high risk to T&E
species
T&E Habitat Project Planning
In Appendix D
Use tables D-1, D-3, D-5 and D-6 to assist
with planning actions in T&E habitat
Prepare both a B.E. and an E.A. when T&E’S
are present
Soil, Water, and Air
Discussion in Chapter IV
Discloses the potential effect of herbicide
application separately and cumulatively
Chapter IV
Finishes with discussions of the potential
effects on Visual quality
Cultural resources
Socioeconomics
Alternatives
Discusses
The formulation of the alternatives
The 9 alternatives evaluated
The 11 herbicides evaluated
The 3 additives evaluated
The application tools considered
The potential patterns of application
The mitigation measures developed
(both general and method specific)
Displays a Comparison
Of the expected effects of the 9 alternatives
Sources of Mitigation
Measures
F.S. Manual
F.S. Health and Safety Code
Forest management plans
Some new ones developed to counter
problems identified in the risk assessment
Mitigation Measures
A classification of herbicides
by effects on
health and the environment
was developed and is presented
Class A Herbicides
Pose no risk requiring mitigation beyond that
specified in Chapter II (at E.2.c)
Class B Herbicides
Pose health or environmental risk which can
be mitigated with additional measures
(beyond those discussed in Chapter II)
Class C Herbicides
Pose health and environmental risk which
can be mitigated with additional measures
(beyond those discussed in Chapter II)
Class D Herbicides
Pose health or environmental risk which can
not be reasonably mitigated
Herbicide Classification
Developed in the EIS
CP/P -- FEIS -- P. II-42
Mitigation Measures
Herbicides
May not be used
at greater than
“Typical Rate”
Without further analysis
Typical Rates
CP/P -- FEIS -- P. II-59
Weather Mitigations
Wind speed limits
Temperature maxima
Humidity ranges
Weather Parameters
CP/P -- FEIS -- P. II-60
Aerial Mitigation Mitigations
Buffer size
Weather parameters
Personnel requirements
Aerial Mitigations
CP/P -- FEIS -- P. II-60/64
Scattered
throughout
Mitigations
(Toxic Effects)
Minimum protective clothing is
required
Mitigations
(Toxic Effects)
Herbicide use is permitted only at
the lowest effective rate
Use the most selective application
method which will accomplish the
task
Mitigations
(Toxic Effects)
Restrict application near water
Be careful when handling the
formulated products
Mitigations
(Toxic Effects)
Also,
To protect the general public and
private lands
To protect target vegetation
To protect PETS
Mitigations
(Toxic Effects)
And,
Defining response in the case of
an accident
Mitigations
(Habitat)
Perform a site specific analysis
(Mandatory B.E. and E.A. if T&E species are involved)
Protect selected habitat groups
Favor selective treatments
Protect non-target vegetation
Minimize drift
List of Preparers
References
Glossary
Subject Index
Public Comment
Front – Table of Contents
Back – Subject Index
Human health – Section 3
Wildlife health – Section 6
Readable summary - Chapter IV
Human health – Section 4
Wildlife health – Section 7
Readable summary - Chapter IV
Human health – Section 5
Wildlife health – Section 8
Readable summary - Chapter IV
Mitigation measures - Chapter II
Coastal Plain / Piedmont
Final Preferred
Appalachian Mountains
Final Preferred
Ozark / Ouachita Mountains
Final Preferred
All R.O.D.s permit all of the
application methods evaluated
to be used with the single
exception that the O/O R.O.D.
denies permission to use
aerial applications
All R.O.D.s require
implementation of all of the
mitigation measures required
in Chapter II as a minimum
standard
However, forest plans are
permitted to include
mitigations which are more
restrictive than those required
by the R.O.D.
Permits the use only of class A
herbicides without the
Regional Forester’s signature
And restricts
all use of
2,4-D and of tebuthiuron, and
the backpack foliar application
of 2,4-DP
Exhibit A in the R.O.D.
Lists all of the mitigation measures
required by the Regional Forester’s
decision
Exhibit B+ in the R.O.D.
Reproduce the forest plan amendments
which incorporate the VMFEIS mitigation
measures into the plans, Forest by Forest
Summary
Effect of the vegetation management
EISs
On the use of herbicides in Region 8
EIS reviewed only a small
number of the herbicides
available for use in forestry
and right-of-way work
Assessed
Herbicides
Of the 11 herbicides reviewed,
3 are virtually eliminated from
our program
Herbicides Evaluated
2,4-D
2,4-DP
Glyphosate
Hexazinone
Imazapyr
Picloram
Sulfometuron methyl
Tebuthiuron
Triclopyr
3 Dropped
8 Retained
In most cases the allowable rate of use
is restricted below that allowed by the
label
Allowed Rates
Disallowed Rates
Mitigations are added which further
decrease risk to applicators and the
public
Not permitted!
O.K.
Taken together this results in a very
small, low-risk window for herbicide
use
You may work here
E.I.S. for the
Suppression of southern pine
beetle
In the Southern Region
Suppression Strategies
Cut-and-Leave
Cut, Pile and Burn
Cut-and-Remove
Cut-and-Spray
Note: The difference in the
four methods comes after
trees are cut
Cut-and-Spray
Chemicals
Dursban
(Chlorpyrifos)
Lindane
At Present
Only chlorpyrifos is available
commercially (as Cyren 4E) and
that registration is in serious
jeopardy
Spray Approved for use in
General forest areas
and
RCW colonies
(felled trees only)
1934-1987
1910
1860
1934
1957
1974
1987
Applicable to
Suppression
and
Eradication
Projects
Approved Treatments
are either
Chemical
or
Biological
Pheromones
Attractant or anti-aggregant chemicals
which mimic natural behavioral chemicals
Biological Insecticides
NPV (nuclear polyhedrosis virus)
Bt (Bacillus thuringiensis)
Chemical Insecticides
Sevin (Carbaryl))
Orthene (Acephate)
Dylox (Trichlorfon)
Dimlin (Diflubenzuron)
Lest you feel
specially picked
on..
Here are a few
other N.E.P.A.
products to
consider
History
Region 8
Region 4
Region 5
Region 6
Region 6 &
the B.L.M.
The D.E.A.
New risk assessments are being
developed for the pesticides in
general F.S. use (and a few not in
general use)
New Risk Assessments
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Use RfD rather than MOS
Have computed HQs (hazard quotients)
Are better grounded in science
Are difficult to use in their current form
Are being adapted in a set of
computerized worksheets to aid use
New Risk Assessments at:
http://www.fs.fed.us/foresthealth/pesticide/risk
.htm
Here’s what has been
developed since the EIS
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Borax (fungic; R-6)
Clopyralid
2,4-D
Dicamba (Vanquish)
Dyes
Glyphosate
Hexazinone
Imazameth
Imazapyr
MCH (ins.)
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Metsulfuron methyl
Mimic (ins.)
Picloram
Sethoxydim
Sulfometuron methyl
Tebuthiuron
TM Biocontrol (ins.)
Triclopyr
Verbenone (ins.)