Why Prepare EIS’s?

Managers need current informationNew technology must be evaluated

The public demands that analysis be doneLaws, lawsuits and court proceedings will drive

the system if we don’t

Legal Purposes

Action ensuring device (the law was designed to insure analysis is done)Full and fair disclosure is required

of SIGNIFICANT environmental impactsto inform the decisionmaker & the public

Legal Requirements

Reasonable alternatives must be evaluated

to avoid or minimize adverse impactsOR

to enhance the quality of the environment

Interdisciplinary TeamFull Time

Team Leader

Editorial AssistantHydrologist

Plant PathologistProgram Assistant

Public Affairs PersonSilviculturist

The EIS Development Team?

Interdisciplinary TeamPart Time

EcologistEconomist

Forestry Program ManagerLandscape Architect

Pest Management SpecialistPesticide Specialist

SociologistSoil Scientist

Wildlife BiologistWriter-Editor

Development ofAlternatives

Range of methods

Range of intensities

Range of alternatives

Possible Vegetation Management Methods

Mechanical methodsManual methods

Herbicidal methodsPrescribed fire

Biological methods

The EIS evaluates

used within these methods

The EISDoes NOT Evaluate

Silvicultural systems (clearcutting, shelterwood, etc.)

Engineering activities (road building, mining, etc.)

Activities Evaluated

Site preparationStand management

(Release, Thinning, etc.)

Wildlife opening maintenanceCorridor (ROW) maintenance

Fuels treatment

V. M. EISsTwo Basic BooksIn Three Volumes

-- Body of the EIS

-- Science appendices

( -- [Chapter VI of Volume I] Public comment letters and team

responses)

Risk Assessmentfor the Use of HerbicidesIn the Southern RegionUSDA Forest Service

Effects of Prescribed Fireon Soil and Water in

Southern National Forests

Effects ofHerbicides

on Soil Productivityand Water Quality

A Biological Evaluation ofThe Effects of the Final

Preferred Alternativeon Threatened, Endangered,

Proposed and Sensitive Species

Lists of Threatened, Endangered, Proposed and Sensitive Species of the

Coastal Plain/Piedmont

Risk Assessment

Human and Wildlife Health Risks

Introduction

Current Vegetation Management Programs

Herbicide Application Methods Evaluated

Aerial methodsGround mechanical methods

Ground manual methods

The Risk Assessments Consider

the Use of Either or .

Formulations

What is Risk?

Human Health Analysis

Herbicides Evaluated

2,4-D2,4-DP

DicambaFosamine

GlyphosateHexazinone

ImazapyrPicloram

Sulfometuron methylTebuthiuron

Triclopyr.

Additives Evaluated

Light Fuel Oils-- Diesel Oil-- Kerosene

Mineral OilLimonene

(Later: Vegetable Oil).

Also Evaluated

Inert Ingredients

Data Sources

Laboratory testingReports in the scientific literature

E.P.A. files (F.O.I.A. request)Manufacturer’s data

Available Toxicity Datais presented

AlphabeticallyBy chemical name

Within toxicology categories

Hazard Analysis

Acute toxicitySubchronic toxicity

Chronic toxicityCancer potency

Mutagenicity

As we go through thedocument

will be used as the primary example

General Toxicity Data

CP/P -- FEIS -- P.3-21

Discussion of NNG - a known derivative of glyphosate

more NOELs...

some toxic effects reported...

no evidence of teratology...

Repro NOEL 10 mg/kg/day - mouse

NOEL - 750 mg/kg/day - mouse

LD50 - 4320 mg/kg - rat...

Glyphosate Toxicity

Oral LD50 of 4,320 mg/kg

Systemic NOEL = 1,000 mg/kg/day

Reproductive NOEL = 10 mg/kg/day

Glyphosate Toxicity

Monsanto has submitted a study establishing 5,600 mg/kg - EPA has not accepted it

1 yr. chronic feeding study - liver cell damage at the HDT (4,500 mg/kg)

Brief discussion of NNG a derivative / contaminant of glyphosate

Elimination Rates

CP/P -- FEIS -- P.3-28

Rabbit - 92% in 5 days

Rat - 94% in 5 days

Glyphosate Elimination

2 studies reported -- both 5 day elimination tests:

- 92% eliminated by rabbit in 5 days

- 94% eliminated by rat in 5 days

Mutagenicity Data Summary

CP/P -- FEIS -- P.3-29

7(-)

2(-)

1(-)

1(-)

1(-)

1(-)

Glyphosate Mutagenicity Summary (Tabular)

13 assays listed - all are negative for mutagenic effects

Glyphosate Mutagenicity Data (Full Text)

CP/P -- FEIS -- P.3-33

...nonmutagenic in bacterial assays...

Glyphosate Mutagenicity (Text)

There is no evidence to indicate it is mutagenic

Mutagenicity/Carcinogenicity

(Tabular Summary)

CP/P -- FEIS -- P.3-35

Mutagenicity

0/13

Oncogenicity

Possible weak effect 1/2 studies

Glyphosate Mutagenicity/Carcinogenicity

(Tabular Summary)

0/13 ASSAYS WERE POSITIVE

Oncogenicity Data(Full Text)

CP/P -- FEIS -- P.3-39/40

...no evidence of oncogenicity...

Glyphosate Oncogenicity Data(Full Text)

No cancer causation up to (HDT) 31 mg/kg/day

FAO & WHO - no evidence that it is carcinogenic

EPA S.A.P - Class D oncogen - but there is a problem study where test & controls developed

tumors

Experiment vs. Reality(Cancer Potency Curves)

CP/P -- FEIS -- P.3-43

Cancer Potency

CP/P -- FEIS -- P.3-44

Data insufficient to classify (Class D)

We went ahead and evaluated risk as if it had been demonstrated to be carcinogen

Glyphosate Cancer Potency

Uncertainty exists due to one study in which both test and control mice

developed tumors

For the sake of conservative analysis a cancer potency analysis was done

Cancer potency is 0.000026 / mg/kg/day

Inert Ingredient (%) Summary(Label Information)

CP/P -- FEIS -- P.3-46

Glyphosate Inert Ingredient Information(Label Data)

Roundup -- 59% inert ingredients (85% of it = water)

Rodeo -- 46.5% inert (100% water)

Accord -- 59% inert (100% water)

Inert IngredientToxicity Summary

CP/P -- FEIS -- P.3-49

Toxicity of the Inert Ingredients in Glyphosate

Polyethoxylated tallow amine is the inert in Roundup

It is more toxic (1200 vs. 4620 mg/kg) than glyphosate

No other significant toxicological concern

Data Gaps

Incompleteor

UnavailableData

All of this disclosure is not enough

to satisfy N.E.P.A.

So far…Registration data only

Registration data

requirements are found in F.I.F.R.A

Need to Know

So as to evaluate the potential effects of a product on

animals and their biological and physical environment

Only a limited number of studies exist

so…

is used to project effects

Human Exposure Analysis

Routes of Human Exposure

Dermal Oral

Inhalation

Applications EvaluatedAerial

(Liquid or granular formulations)

Mechanical (Liquid or granular formulations)

Manual (Liquid or granular formulations [Liquid formulations considered were:

Directed foliar; Basal bark or stem; Soil spot; and, Cut surface treatments])

Brown-and-Burn Treatments

Exposure Results from

Rate of applicationTime spent applying

Cleanliness of methodProtective equipment used

Rate Scenarios Evaluated

Exposure Analysis is Based on

Data Submitted by the Forest Pesticide

Coordinators(It was not speculative or made up in the Regional

Office)

Acres Treated / Year(Regional Typical & [Maximum] Values)

CP/P -- FEIS -- P.4-5

GlyphosatePatterns of Use

For this and subsequent tables note that “typical” values precede bracketed

“maximum” values

Values are presented only for labeled uses at the time of analysis

Acres / Treatment (Regional Typical & [Maximum] Values)

CP/P -- FEIS -- P.4-7

Hours Worked / Person Day(Regional Typical & [Maximum] Values)

CP/P -- FEIS -- P.4-9

Days / Year / Worker (Regional Typical & [Maximum] Values)

CP/P -- FEIS -- P.4-11

Worker Exposure (Hours per Year)

(Regional Typical & [Maximum] Values)

This number was found to have little value in projecting risk due to the rapid

and almost total excretion of internalized herbicide

There appeared to be no accumulation of chemical which would affect the toxicity of a subsequent dose of the

same or another pesticide

Pounds a.i. Applied / Acre (Regional Typical & [Maximum] Values)

CP/P -- FEIS -- P.4-13

Estimated ExposureDue to Drift

CP/P -- FEIS -- P.4-21

Aerial

Ground

Drift Curves

Evaluation of large droplet systems used for herbicide application

Aerial - virtually no deposition more than 100 meters off-line

Drift Curves

Ground (Fig 4-2)

Upper line = row crop application - high pressure - small droplet size - significant

drift potential

Lower line = forestry application - low pressure- large droplet size - insignificant

drift potential

Estimated Leaching Potential

CP/P -- FEIS -- P.4-27

Glyphosate Leaching Potential

Adsorption coefficient and retardation factor are each second highest on the list

Glyphosate binds tightly to available organic matter and soil movement is not

significant

Estimated Subsurface Dispersion of Pesticides

CP/P -- FEIS -- P.4-41

Hexazinone

Hexazinone is used for Example

Glyphosate was not analyzed due to its immobility in soil

Hexazinone modeling shows no subsurface movement

Some question here for hexazinone

Estimated Runoff

CP/P -- FEIS -- P.4-55 Hexazinone

Runoff Potential(Hexazinone)

Several soils analyzed (broad range of silt, sand and loam)

Different slopes considered

Significant variation found in potential movement in runoff

Estimated Exposure to Glyphosate

CP/P -- FEIS -- P.4-75

Exposure to Glyphosate(Typical Scenario)

Public exposure potential is extremely low, ranging from 0.00001 to 0.00090

mg/kg/day

Estimated worker exposure ranges from 0.00008 to 0.05144 mg/kg/day

Exposure to Glyphosate(Maximum Scenario)

Public exposure potential is still extremely low, ranging from .00003

to .04659 mg/kg/day

Estimated worker exposure ranges from .00261 to .98919 mg/kg/day

Exposure to Glyphosate(Accident Scenario)

Spills into water pose limited threat of exposure estimated to be between 0.0023 and 0.0276

mg/kg/day

Accidental spray of persons is higher risk - exposure is estimated to be 0.1668 mg/kg/day

Spill onto worker is serious - exposure can range to 180 mg/kg/day

Exposure is simplycontact with or proximity

to a pesticide

Dose requiresinternalization

of the pesticide

Internalization is…

Penetration through skin,stomach / intestines

or lungsinto the body properor the blood stream

Human Health RiskAnalysis

Measures of RiskNOEL

NOAELADITLVMOS

MOS = NOEL / Dose

For Forest Service ProjectsMOS Must Be Greater Than

10010 = Inter-species protection

factor10 = Intra-species protection

factor

10 X 10 = 100

Estimated MOSs for Glyphosate Use

CP/P -- FEIS -- P. 5-19

Summary of Projected MOSs for Glyphosate Use

Public MOSs in both systemic and reproductive typical scenarios all exceed

10,000In the maximum scenarios six do not

exceed 10,000 - and of those only 2 (sys. & repro. berry pickers) don’t exceed 1,000

All exceed the minimum 100 standard

Summary of Projected MOSs for Glyphosate Use

Worker MOSs in both systemic and reproductive typical scenarios all exceed the minimum standard of 100 (lowest is

194.4 - backpack applicator repro.)

In the maximum scenarios several MOSs do not achieve the minimum 100

Spills onto workers and accidental spray of persons all pose unacceptable risk

Lifetime Cancer Risk

CP/P -- FEIS -- P. 5-40

Lifetime Cancer Risk

Risks smaller than 1 x 10-6 are acceptable under the EPA

standard adopted

All of the glyphosate risks meet this criterion

Cancer Risk fromBrown-and-Burn Operations

(Estimated)

CP/P -- FEIS -- P. 5-42

Cancer Risk fromBrown-and-Burn Operations

Analysis assumed all applied herbicide was present at time of burning

Risks range between 2 x 10-8 and 8 x 10-15

Even so, cancer risk from B&B is negligible

Some conclusionsabout

human health riskfrom herbicide use

Highest Risk is to WorkersInvolved in

Mixing / loading pesticides (mixer / loaders)

Backpack spray operations

More Human Health Conclusions

Diesel oil and kerosene are barely acceptable based on published data

(further review indicates that they are unacceptable)

Cancer risk to workers & the public is low

Only 1 synergism disclosed

No bioaccumulation seen

Human Health Effectsfrom Brown-and-Burn

Treatments

Assumes a wildfire occurs immediately after application

Finds only an extremely low risk beyond that resulting from the fuels

Cancer risk posed by herbicides is negligible

Human Health RiskPosed to the Public

Negligible at typical application rates

Including the risk to berrypickers (highest public risk scenario)