EPA publishes draft on insecticides for endangered species

The U.S. Environmental Protection Agency (EPA) has released its draft insecticide strategy for public comment as it relates to endangered species that are federally threatened.

The draft strategy, released on July 25, identifies protections that EPA will consider when approving a new insecticide or re-evaluating an existing insecticide. In developing the draft strategy, EPA identified protections to address potential impacts on more than 850 species listed by the U.S. Fish and Wildlife Service.

The draft is part of EPA's ongoing effort to develop a more efficient, effective and protective multi-chemical, multi-species approach to meet its obligations under the Endangered Species Act, according to a press release. EPA focused the draft strategy on conventional insecticides used in agriculture in the lower 48 states, where about 34 million pounds of insecticides are used each year. The draft identifies protective measures earlier in the pesticide review process and believes this represents a far more efficient approach to assessing and protecting FWS-listed species that live near these agricultural areas.

This draft strategy also incorporates lessons learned from EPA's draft herbicide strategy, which the agency released last year to minimize the impacts of agricultural herbicides on listed species. For example, based on feedback on the draft herbicide strategy, EPA designed the mitigation measures in the draft insecticide strategy to provide farmers and other pesticide applicators with as many options as possible.

These mitigation options also consider farmers who already take measures to reduce pesticide runoff, as well as those who live in areas where pesticide runoff is less likely, such as lowland areas and regions with less rainfall to wash pesticides off fields. These measures include practices of the U.S. Department of Agriculture's Natural Resources Conservation Service, as well as government or private efforts to effectively reduce pesticide runoff.

Similar to the herbicide strategy, the draft insecticide strategy uses the most current information and procedures to determine whether an insecticide has an impact on a listed species and identifies protective actions to address any impacts. To determine impacts, the draft strategy considers where a species lives, what it needs to reproduce (e.g., food or pollinators), where the pesticide ends up in the environment, and what impacts the pesticide might have if it reaches the species. These refinements greatly reduce the need for pesticide restrictions in situations that do not benefit species.

Concerns raised

A coalition of farmers, retailers, cooperatives, crop protection consultants, researchers, manufacturers and government regulators are concerned that insecticide policy may not achieve the results EPA seeks. In its July 22 letter to EPA, the coalition stated, “The current methods EPA uses to assess these risks are extremely conservative. They often rely on immature models and very conservative assumptions rather than taking into account available relevant and reliable scientific and commercial data. As a result, these assessments can significantly overstate risks to species and conclude that pesticide applicators must implement more costly and stringent restrictions that are truly necessary to protect listed species.”

Organizations calling for a more intense dialogue include the American Farm Bureau Federation, the American Soybean Association, the National Association of Wheat Growers, the National Corn Growers Association, the National Cotton Council, the National Sorghum Producers, the National Sunflower Association and the Fertilizer Institute. Many state organizations, as well as these associations and other commodity groups, also signed the letter.

Herbicide page

One organization that has been tracking the herbicide proposal, the Weed Science Society of America, continues to urge EPA to add drift reduction aids to the agency's approved mitigation options for compliance with the Endangered Species Act. EPA is currently working on its herbicide strategy to meet ESA obligations and expects to release it before September. However, DRAs were not among the mitigation options in a draft herbicide strategy that EPA released for public comment in April.

“Drift reduction adjuvants are among the most practical, cost-effective and efficient methods to prevent the spread of off-target pesticides and can therefore contribute significantly to protecting endangered species,” said Greg Dahl, president of WSSA. “Pesticide applicators already use DRAs on over 100 million acres annually in the United States, and their performance and environmental benefits have been well demonstrated, documented and implemented.”

To achieve the best results from pesticide regulation, voluntary compliance is important, Dahl said.

“Adding DRAs to spray mixtures is convenient, inexpensive and already widely used,” he said. “Many pesticide distributors, crop protection advisors, farmers and applicators are familiar with these products. This would provide them with a method to recognize the actions they are taking to protect endangered species. It could also encourage them to take additional actions that EPA might recommend.”

How to comment on an insecticide