Representatives of the U.S. Department of Agriculture spoke at the first public NAS/NRC panel meeting on risk assessments for pesticides under the Endangered Species Act.  During their presentation, the USDA representatives asked the panel to “Seriously Consider the Following for ESA Consultations”:

●The consultation process MUST use the best available real world pesticide use and usage information (includes temporal & spatial patterns)

            –Authorized use rates on labels should not be the basis for use rate determination

            –Actual pesticide use data can be analyzed to map where and when toxicity exposure is greatest within a region (geographically depicted)

            –Timing of applications is important – most species are NOT present at the same life stage, year round and pesticides are not present at the same levels, year round

            –The ESA requires Federal agencies to use the best available scientific

and commercial data available when making determinations of

‘jeopardy’ or ‘adverse modification of critical habitat.’

●Practical outcomes of risk‐assessment practices:

            –MUST be tailored to reduce actual exposure using accurate

agricultural use rates and patterns

            –MUST be practical for farmers to implement

            –MUST be agronomically correct; requiring input by crop specialists

during the information gathering stage of the consultation process

●Models that estimate fate and transport of chemicals:

            –MUST consider direct and indirect pathways

            –MUST be vetted by modeling experts and,

            –MUST be transparent in how they are used; any non‐model risk

estimates must be explained

●For American farmers and foresters to remain productive and globally competitive, they MUST have a consultation system that is fair, felicitous, certain, & allows them to be responsive to market demands

The USDA power point presentation is attached below.