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)