Pesticide Consultations with EPA
Joint Stakeholder Workshops
ESA-Listed Salmonids Map:
28 Evolutionarily Significant Units
The Environmental Protection Agency, U.S. Department of Agriculture, U.S. Fish and Wildlife Service, and NOAA Fisheries held a Workshop to provide feedback on Assessing Risks to Endangered and Threatened Species from Pesticides in October 2014. We also held a stakeholder workshop in November 2013 to discuss and take comment on interim scientific approaches to address National Academy of Sciences (NAS) recommendations for assessing risks from pesticides to endangered and threatened species.
As part of a court settlement with the plaintiff, Northwest Coalition for Alternatives to Pesticides (NCAP) [pdf], we agreed to complete biological opinions for the 37 active ingredients, with final deadlines specified for different batches of pesticides (see schedule).
NMFS has completed six opinions addressing 27 active ingredients. Three opinions (1-3) consider organophosphate (OP) and carbamate insecticides. The fourth opinion (4) considers 4 herbicides and 2 fungicides. The fifth opinion (5) considers 3 herbicides. The sixth (6) opinion considers thiobencarb. A summary of the opinions is available on our website.
- EPA posts to their docket NOAA Fisheries' draft Endangered Species Act Section 7 Consultation Conference and Biological Opinion on the registration of three insecticides: Diflubenzuron, Fenbutatin Oxide, and Propargite
On July 2, 2012, NMFS issued a final biological opinion concluding that EPA’s registration of herbicide thiobencarb is not likely to jeopardize the continued existence of three listed Pacific salmonid Evolutionary Significant Units/Distinct Population Segments or adversely modify their designated critical habitat.
We analyzed EPA’s registration of thiobencarb based on its authorized use on rice. California is the only state within the range of listed Pacific salmonids that has approved the use of thiobencarb, and use is only approved for rice. As a result, this biological opinion focuses on three listed Pacific salmon Evolutionary Significant Units/Distinct Population Segments located in California’s Central Valley where rice is grown. Re-initiation of this consultation will be necessary if thiobencarb is approved for use by other states with listed Pacific salmonids, or if thiobencarb use expands to any other parts of California within the range of listed Pacific salmonids.
- Oryzalin, pendimethalin, and Trifluralin
On May 31, 2012, NMFS issued a final biological Opinion addressing the effects of dinitroanaline herbicides on listed Pacific salmonids.
NMFS concluded that oryzalin, pendimethalin, and trifluralin are likely to jeopardize the continued existence of some listed Pacific salmonids, and adversely modify designated critical habitat of some listed salmonids.
- Captan, chlorothalonil, 2,4-D, diuron, linuron, and triclopyr BEE
On June 30, 2011, NMFS issued a final biological opinion addressing the effects of four herbicides (2,4-D, triclopyr BEE, diuron, linuron) and two fungicides (captan, chlorothalonil) on listed Pacfic salmonids. NMFS's conclusions are that:
- pesticide products containing 2,4-D are likely to jeopardize the continued existence of all ESUs/DPSs of listed Pacific salmonids and adversely modify designated critical habitat for some ESUs/DPSs
- pesticide products containing chlorothalonil or diuron adversely modify designated critical habitat for some some ESUs/DPSs
- pesticide products containing captan, linuron, or triclopyr BEE do not jeopardize the continued existence of any ESUs/DPSs of listed Pacific salmonids or adversely modify designated critical habitat
- Azinphos-methyl, Dimethoate, Disulfoton, Ethoprop, Fenamiphos, Methamidophos, Methidathion, Methyl parathion, Naled, Phorate, Phosmet, Bensulide [pdf]
NMFS concluded that pesticide products containing Azinphos methyl, disulfoton,fenamiphos, methamidophos, or methyl parathion are not likely to jeopardize the continuing existence of any listed Pacific Salmon or destroy or adversely modify designated critical habitat.
NMFS also concluded that the effects of products containing bensulide, dimethoate, ethoprop, methidathion, naled, phorate, or phosmet are likely to jeopardize the continued existence of some listed Pacific Salmonids and to destroy or adversely modify designated habitat of some listed salmonids.
- Carbaryl, Carbofuran, and Methomyl [pdf]
NMFS concluded that pesticide products containing carbaryl, carbofuran, and methomyl are likely to jeopardize many populations of ESA-listed Pacific salmonids and destroy or adversely modify designated critical habitat. Response to the Opinion:
- Chlorpyrifos, Diazinon, and Malathion [pdf]
These three chemicals are components of insecticides used in both agricultural and urban settings. The opinion concluded that these chemicals are likely to jeopardize 27 populations of salmon on the West Coast listed under the Endangered Species Act. Response to the Opinion: Litigation:
Correspondence Related to Pesticide Consultations Conducted Under this Settlement Agreement
- Letter Exchange Between Dan Newhouse of Washington State Department of Agriculture and Jim Balsiger of NMFS - February 5, 2009
- Letter Exchange Between Heather Hansen of Washington Friends of Farms & Forests and Jim Balsiger of NMFS - October 15, 2009
- Letter Exchange Between Dan Newhouse of Washington State Department of Agriculture and Gary Locke of Dept of Commerce - November 12, 2009
- U.S District Court (Western District of Washington at Seattle) extended the deadlines for completing the Batch 3 and Batch 4 opinions [pdf] - February 2010
Other Pesticide Consultations Activities
- Atrazine Nonconcurrence Letter to EPA: May 29, 2007 [pdf]
- Atrazine Technical Appendix [pdf]
- Racemic Metolachlor Nonconcurrence Letter to EPA: July 13, 2007 [pdf]
- Racemic Metolachlor Technical Appendix [pdf]
- Clomazone Nonconcurrence letter to EPA: May 22, 2009 [pdf]
- Fomesafen Nonconcurrence letter to EPA: May 22, 2009 [pdf]
Status of Efforts to Implement the Recommendations of the NAS Report on Ecological Risk Assessment for Endangered and Threatened Species under FIFRA and ESA
In April 2013, the National Academy of Sciences' National Research Council released their recommendations for assessing risks from pesticides to listed species under the Endangered Species Act and the Federal Insecticide, Fungicide, and Rodenticide Act.
The Environmental Protection Agency, U.S. Department of Agriculture, U.S. Fish and Wildlife Service, and NOAA Fisheries are working collaboratively and expeditiously to review the report and identify improvements in the current scientific procedures used in evaluating the potential impacts of pesticides to endangered and threatened species. The Federal agencies will develop an implementation plan to provide a timeline and approach for responding to the panel's recommendations and implementing the appropriate revisions to these procedures and approaches. The plan will be available to the public.
More Information on Pacific Salmonids
- Chinook salmon
- Chum salmon
- Coho salmon
- Sockeye salmon
- Steelhead trout
- Salmon Recovery in the Pacific Northwest
More Information on Pesticide Effects on Pacific Salmonids
- Copper Effects to Salmon Sensory System [pdf]
- EPA's Endangered Species Protection Program
- Indirect Effects in Endangered Species Assessments for Pesticides [pdf]
- Indirect Effect of Pesticides to ESA-Listed Species [pdf]
- Integrating Ecological Risk Assessment with the Endangered Species Act [pdf]
- Population Models Used in NMFS' Biological Opinions with Pesticides [pdf]
Updated: November 26, 2014