PPP-30
An Introduction to Testing, Registration, and Risk Management
Fred
Whitford, Coordinator, Purdue Pesticide Programs
Brian Miller, Wildlife Specialist, Purdue University Cooperative Extension Service
Richard Bennett, Research Ecologist, U.S. Environmental Protection Agency
Margaret Jones, Endangered Species Specialist, U.S. EPA Region 5
Larry Bledsoe, Field Crops Pest Management Specialist, Purdue University Cooperative
Extension Service
Edited by
Arlene Blessing, Purdue Pesticide Programs
Diana Doyle, Purdue University Agricultural Communication Service
PURDUE UNIVERSITY COOPERATIVE EXTENSION SERVICE
WEST LAFAYETTE, IN 47907
The diversity of wildlife habitats throughout our country is surprising. In rural areas fence rows, fields, pastures, ponds, wetlands, and woodlands comprise important habitats for many species of wildlife. Wild species also inhabit urban landscapes, finding food and shelter in lawns, cemeteries, golf courses, parks, etc. Collectively, these habitatsurban, rural, public forest, and pristine areasprovide resources to support plants (flora) and animals (fauna) that are important and necessary.
Lands that provide habitat for wildlife also may bring them into contact with human activities. Wildlife species living adjacent to farmlands may benefit from the crops grown but may be inadvertently exposed to pesticides used to reduce insect, weed, and disease pests of those crops. Urban expansion for new housing, manufacturing facilities, and other activities not only consumes valuable habitat but also may bring wildlife into contact with pesticides used on turf, ornamental and landscape plantings, gardens, highway rights-of-way, parks, and rodent and mosquito abatement programs. Pesticides and Wildlife introduces its readers to the potential effects of pesticides on wildlife and aquatic organisms; to the process by which ecological safety assessments are made for registered pesticides; and to pesticide use recommendations to protect wildlife.
Watching wildlife in natural settings appeals to persons of all ages and all ethnic, educational, and social backgrounds. Eighty-five percent of Americans participate in some wildlife observation activity (e.g., whale, bird, and butterfly watching). Ecotourism has become a lucrative market; many businesses and communities actively advertise and attract tourists to observe wildlife.
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| Endangered species: Mitchell's Satyr (Euptychia mitchellii) |
Wildlife viewing tours organized by professional wildlife biologists are in demand, and tourism is supported by a cadre of jobs related to lodging, meals, transportation, art, equipment, and the media. Taxes dedicated from the sale of hunting and fishing licenses and certain outdoor equipment provide revenue to purchase, maintain, and restore wildlife habitats while monetary support from some government agencies is dwindling. These user-based taxes also help finance scientific research on wildlife communities. It is important that we as a society do all we can to maintain and preserve the natural world and benefit from its existence.
Fewer than 20 plant species are responsible for feeding most of the world's population. However, it is estimated that 80,000 species of edible plants may have potential as new food sources; and wild plant and animal species may become sources of new genetic material with agricultural or medical applications. For example, the purple cone flower (a native prairie plant) has an oilseed content greater than that of commercially grown sunflowers; and the South American corn variety Zea diploperennis has been used to breed resistance to northern corn leaf blight into North American corn hybrids, thereby curtailing the likelihood of a major blight outbreak which might impact grain markets. Plants (e.g., Pacific Yew, which produces taxol) and animals also have been shown to harbor an array of pharmaceutical chemicals whose medicinal properties may be used to combat disease. Wildlife also play a role as natural enemies of pest species (e.g., birds eat mosquitoes; snakes consume rodents).
Many of these relationships are known, but many are yet to be discovered. It is for this reason that we must ensure that the vast array of plants and animals on our planet is maintained for future generations. It is likely that important connections exist between species diversity, environmental quality, and the long-term sustainability-and profitability-of farming operations.
The term wildlife as used here shall include insects, spiders, mammals, birds, fish, amphibians, reptiles, and plants. Each species fills a certain niche which includes its specific food, cover, water, space, and breeding site preferences. The location where a species can meet all of its living requirements becomes that species' habitat. Wildlife habitats are not just the Grand Canyon, ancient forests of the Pacific Northwest, or rich coastal marshes off of the eastern seaboard; they exist across the American landscape. Wildlife habitats-large and small, native and man-made-exist in urban settings, in agricultural fields, and in the wilderness.
Wildlife ecologists and natural resource managers study the needs and habits of wildlife. An important goal of wildlife research is to discover and understand the critical factors that affect survival and sustainability of viable populations. Most wildlife will adapt and flourish, given sufficient quantity of quality habitat, even in the presence of people. While ecological studies may pinpoint very specific requirements for individual species, the lives of plants and animals and their habitats can be integrated collectively into a matrix (ecosystem).
Knowledge of the biological and ecological relationships of any given plant or animal and the role that species plays in the ecosystem is required to evaluate the potential impact of a specific pesticide on a specific species. The impact of a specific pesticide may be negative, neutral, or positive to a species or its habitat as the chemical's residues move through the soil, water, food, or air. The interaction of wildlife, its habitat, and pesticides is evaluated by scientists trained in wildlife ecology, population dynamics, physiology, and environmental chemistry.
Pesticides are applied in many forms via various delivery methods to forests, rangeland, aquatic habitats, farmland, rights-of-way, urban turf, and gardens. Their widespread use makes contact with pesticide residues inevitable for some wildlife. Pesticide poisonings to wildlife may result from acute or chronic exposure. Additionally, pesticides may impact wildlife via secondary exposure or through indirect effects to the animal or its habitat.
Short exposures to some pesticides may kill or sicken wildlife. Examples of acute wildlife poisoning include fish kills that are caused by pesticide residues carried to ponds, streams, or rivers by surface runoff or spray drift, and bird die-offs caused by foraging on pesticide-treated vegetation or insects, or by consumption of pesticide-treated granules, baits, or seeds. These types of poisonings generally can be substantiated by analyzing tissues of affected animals for the suspected pesticide or by investigating impacts on biochemical processes (e.g., cholinesterase levels in blood and brain tissue). In general, acute poisoning to wildlife takes place over a relatively short time, impacts a very localized geographical area, and is linked to a single pesticide.
Exposure of wildlife over an extended period of time to pesticide levels not immediately lethal may result in chronic poisoning. The most well-known example of a chronic effect in wildlife is that of the organochlorine insecticide DDT (via the metabolite DDE) on reproduction in certain birds of prey. DDT and other organochlorine pesticides such as dieldrin, endrin, and chlordane have been implicated in bird mortality resulting from chronic exposure. The reduction of these compounds in the 1970s and early 1980s has resulted in decreased organochlorine residues in most areas, and reproduction in birds such as the bald eagle has greatly improved. Organochlorine pesticides used in some foreign countries may pose risk to migratory birds which overwinter there.
Pesticides may impact wildlife through secondary poisoning when an animal consumes prey species that contain pesticide residues. Examples of secondary poisoning are (1) birds of prey becoming sick after feeding on an animal that is dead or dying from acute exposure to a pesticide, and (2) the accumulation and movement of persistent chemicals in wildlife food chains.
A pesticide may affect wildlife in ways other than direct or secondary poisoning. Pesticides may impact wildlife indirectly when a part of its habitat or food supply is modified. For instance, herbicides may reduce food, cover, and nesting sites needed by insect, bird, and mammal populations; insecticides may diminish insect populations fed on by bird or fish species; insect pollinators may be reduced, thereby affecting plant pollination. The study of indirect effects is an emerging area and one that may be difficult to investigate.
Not all pesticides have detrimental effects on all wildlife, nor do pesticide residues necessarily lead to serious consequences for wildlife. The potential impact must be evaluated by simultaneously considering the availability of the pesticide or its degradation product(s), the toxicological properties of the pesticide, and the ecological characteristics of the exposure. Due to the complexity of these issues, many scientific disciplines must play a role in both the studies and the interpretation of results. The results from scientific studies aid numerous federal and state natural resource agencies to assess and manage the effects of pesticides on wildlife, including endangered species.
The degree of direct impact a pesticide has on wildlife is determined by the sensitivity of a species to the chemical and the degree to which the species is exposed. Just how safe are pesticides to wildlife? The following questions help to summarize the complexity that biologists and toxicologists face when attempting to evaluate pesticidal effects on wildlife.
What level of a pesticide residue or
its
breakdown product (metabolite) is introduced into a wildlife
habitat through direct application or via the transportation
of residues in air, water, food, or soil?
How long does the pesticide remain in
the environment?
Is the animal or plant exposed to the
pesticide
by mechanisms including dermal contact, inhalation,
or consumption of contaminated food or water?
Is the pesticide capable of producing biochemical
effects, illness, or death through either single or multiple exposures?
Ultimately, in making decisions and adopting attitudes about pesticides, one should consider both the potential benefits and the potential risks of their use. Pesticides contribute many positives to our society: reduction of insect-vectored and waterborne diseases; production of an abundant food supply that takes only 10 percent of our disposable income; a positive impact on our balance of trade; nourishment for the world; and reduction of soil erosion in conservation tillage programs. Pesticides facilitate the production of grains, meats, and fibers by less than two percent of our population, freeing the rest of us to pursue other vocations. With the world's human population steadily increasing (to 8 billion by the year 2025), and with limits on the amount of "new" land that can be converted into production, it is likely that pesticides will continue to play an important role in meeting our demands for food and fiber.
Though chemical technology has great potential to benefit humankind, we should act carefully. The benefits need to be evaluated continually so that the balance sheet clearly favors the benefit quotients. In order to prevent the use of pesticides that might cause unacceptable adverse effects, testing requirements and review processes are implemented to identify problem chemicals and allow development of precautions and instructions for proper use.
Pesticide registration is a process that is mandated by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The details of implementation are described in the Code of Federal Regulations Section 40. Both FIFRA and the regulations outline the basic framework for registration, rules of conduct, implementation mechanisms, and decision-making guidelines.
Congress delegates the U.S. Environmental Protection Agency (EPA) to assume regulatory responsibilities and decision-making authority to administer the federal pesticide registration process. The registration process is complex and takes considerable time, resources, and expertise on the part of EPA, the pesticide manufacturing industry, and various public interest groups. This process is ever-evolving to answer new questions and meet challenges posed by the use of pesticides. An expanding series of tests is required in response to public concern and improved technology that provides more precise pesticide residue detections and toxicological assessments. In addition, improved methods for hazard predictions, novel approaches to hazard reduction measures, and incorporation of the broadening scope of relevant scientific knowledge into industry and government policy decisions contribute to changes and improvements in the pesticide registration process.
The basic pathway for pesticide registration is: (1) research conducted by the manufacturer prior to its decision to pursue registration; (2) data submission report by the manufacturer to EPA; (3) EPA review; and (4) a decision by EPA either to register the pesticide based on the merits of the data submitted, or to deny registration. The congressional mandate that guides EPA decisions to register a pesticide hinges on a benefit-to-risk analysis of the data. Evaluation of available registration data must provide EPA with an assurance that the pesticide will perform its intended function without unreasonable adverse effects on people, wildlife, and the environment.
The EPA registration process for a single chemical requires the manufacturer (registrant) to conduct, analyze, and pay for 142 different scientific tests. These tests define product chemistry, risks to humans and domestic animals, the environmental fate of the pesticide, and the pesticide's impact on nontarget wildlife. Generation of such data for a single compound may take 6-10 years and cost millions of dollars.
The following table illustrates the scientific information required
by EPA when considering the registration of a pesticide.
It is impossible, inadvisable, and illegal to test every speciesabundant, threatened, or endangeredwith each pesticide. In the regulatory testing process, the test species selected are intended to broadly represent nontarget organisms. Chosen wildlife species typically satisfy the following criteria: ecologically significant; abundant and broadly distributed geographically; susceptible to chemical exposure; commercially available for testing; and easy to handle in the laboratory. For life cycle tests, the species must have a relatively short life span. When possible, species that are aesthetically, recreationally, or commercially important are studied. These indicator species provide the research scientist and the regulatory decision-maker with an information base for assessing potential risks to a broad range of nontarget birds, mammals, fish, aquatic invertebrates, predatory insects, insect pollinators, and plants. The following table lists typical indicator species.
Toxicological testing and scientific measurements are conducted under stringent guidelines, approved methodologies, and specified reporting requirements. Exacting standards are necessary for consistency in evaluations of pesticide safety and for comparisons among chemicals. EPA's pesticide assessment guidelines stipulate the following general practices which must be adhered to when conducting the various tests required for registration:
Toxicological or phytotoxicological
testing
normally is not performed on endangered or
threatened species.
Only EPA-recommended wildlife and
aquatic organisms should be used for laboratory
testing purposes.
The test organisms should be uniform in
weight, size, and age.
Control groups-those not exposed to
pesticides-should be maintained in a manner similar
to that of the test groups.
The substance to be tested-the
technical
grade of the active ingredient, or the end-use
product-is clearly specified. If the test substance is diluted
or dissolved for administration, the carrier should
not interfere with adsorption, distribution, or metabolism
of the test material; alter the chemical properties of
the substance; enhance or reduce the toxic
characteristics of the test substance; affect food and water
consumption; or impact the physiological processes of the
test organism.
Detailed descriptions of the nature,
incidence, time of occurrence, severity, and duration of all
observed toxic effects should be recorded.
All data generated must be in
accordance
with established Good Laboratory Practices for
handling and care of test organisms.
Final reports should include all
information necessary to provide a complete and accurate
description of test procedures and evaluation of the
test results.
Responsible parties must confirm by
signature that appropriate quality assurance and quality
control methods were followed.
Test species are exposed to measured amounts of pesticide to establish acute and chronic responses to varying concentrations. A dose can be delivered to the test organisms by various means, depending on the test: mixed with water in aquarium tanks stocked with fish or invertebrates; given as a single oral dose to mammals and birds; applied topically to honey bees; or incorporated into the diet. Typically, in every short-term test ten organisms each are exposed at four to five dose levels to determine mortality or other end point effects.
In addition to short-term mortality studies, the effects of long-term (chronic) pesticide exposures on reproduction, survival, and behavior are measured. If laboratory studies indicate that the pesticide has a potential for adverse effects on wildlife, the research may be expanded beyond laboratory settings to include studying and monitoring impacts under actual use conditions.
Northern bobwhites (upland game species) and mallards (waterfowl) are used to conduct a series of toxicological tests to quantify the short- and long-term impacts of pesticides on avian wildlife. These species generally are obtained from pen-reared stock and maintained under temperature, humidity, lighting, and pen size that conform to good husbandry practices and protocols established by EPA.
The purpose of this test is to determine the chemical's acute oral toxicity, expressed as a single dose of material (milligrams per kilogram of body weight) that will result in 50 percent mortality among test birds. The test provides a measure of a species' sensitivity to a toxic substance. Birds tested must be in good health, from the same source, and preferably from the same hatch. Birds must be at least 16 weeks old at test initiation and must have been preconditioned to the test facilities for at least 15 days prior to experimentation. The standard study uses ten birds for each of five dose levels. The test material is administered orally to each bird by direct injection into the stomach or crop, or through the use of capsules. Birds are observed for a minimum of 14 days, and any mortality or signs of intoxication are recorded. In addition, an internal examination is made to determine the condition of major organs.
The purpose of this test is to determine a chemical's toxicity to birds, expressed as a concentration of the pesticide in the diet (parts per million) that will produce 50 percent mortality among test birds. Birds selected for experimentation must be in good health and preferably from the same source and hatch. Bobwhites should be from 10 to 14 days old at the beginning of the test. Birds are preconditioned from hatch on a standard commercial game bird diet. Three to five days prior to testing, bobwhites or mallards are randomly segregated into six groups, ten birds per group. Five groups are given unrestricted access to feed containing known concentrations of the pesticide; one group serves as a control and receives standard commercial feed that contains no pesticide. Birds are allowed to feed on the test diets for five days and observed for an additional three days. During the study period, mortality and all signs of intoxication, such as immobility and any abnormal behavior, are recorded daily.
The most commonly used test for chronic pesticide effects on terrestrial wildlife is the avian reproduction test. The objectives of the study are to determine pesticidal effects on the health and reproductive performance of egg-laying adults, on embryo viability, and on the survival of hatchlings. One control and three pesticide-treated dietary concentrations (selected to bracket environmental exposures) are fed to four test groups of first year breeders. Exposures begin 10 weeks prior to egg laying and continue during 10 weeks of egg laying. Eggs are collected daily, artificially incubated, and checked periodically for embryonic development; hatchlings are grown on untreated feed for two weeks to check their viability and growth. This test is now conducted for virtually all pesticides.
From 1987 to 1992, EPA's Office of Pesticide Programs increasingly required ecotoxicological field studies both for new chemical registrations and as part of the ongoing reregistration process for older pesticides. Two major documents, Guidance for Conducting Terrestrial Field Studies and Guidance for Conducting Aquatic Mesocosm Studies, were issued to provide detailed recommendations on the implementation of these tests. The former document was concerned primarily with field monitoring of pesticidal impact on birds under actual use conditions; the latter concerned the use of test systems composed of constructed ponds (0.1 to 0.25 acre surface area) treated with pesticides at rates approximating chemical contamination that might result from runoff and spray drift following agricultural applications.
After approximately five years of ecotoxicological field testing under these guidance documents, more than 45 avian field studies and 10 aquatic mesocosm studies were conducted. But the results did not add sufficient information to agency risk assessments to justify the time and resources necessary to support the testing, so EPA discontinued it. In the absence of such field testing, EPA is evaluating the risks of pesticides based largely on laboratory test results, estimation of environmental exposures through the use of computer models and literature sources, measured pesticide residues, and pesticide incident data. When such analyses indicate a potential for adverse environmental effects, EPA requires pesticide registrants to implement changes in product use recommendations to lessen that potential. Under this new testing approach, EPA may still require field testing in special circumstances or may require field monitoring to determine if pesticide use changes have adequately reduced exposures or effects.
The first tier of testing consists of short-term, acute toxicity tests that determine lethal dosages and the general responses of the test animal to the pesticide. These tests include the single-dose oral test for birds, the 8-day dietary subacute test for birds, a 96-hour LC50 test for fish, and a 48-hour test for aquatic invertebrates. A fundamental end point of these tests is to determine the lethal dose (LD) or lethal concentration (LC) required to kill 50 percent of the test organisms.
This value is calculated statistically and expressed as an LD50 value (single oral dose) or LC50 value (dietary exposure or concentration in water). The LD50 values are expressed in milligrams of a pesticide per kilogram of animal body weight (mg/kg). The LC50 values are expressed in milligrams of a pesticide per kilogram of feed (mg/kg) or per liter of water (mg/l). The metric units are normally converted to parts per million (ppm) to aid in comparison to environmental residue data.
An initial interpretation of these statistical laboratory values concerns their magnitude: the lower the LD50 or LC50 value, the less chemical is required to kill test organisms. Toxicologists have developed rating scales for interpretation of the potency of pesticides, as follows:
| FOR AVIAN DIETARY LC50 | |
| LC50 < 50 ppm | very highly toxic pesticide |
| LC50 = 50-500 ppm | highly toxic pesticide |
| LC50 = 501-1000 ppm | moderately toxic pesticide |
| LC50 = 1001-5000 ppm | slightly toxic pesticide |
| LC50 > 5000 ppm | practically non-toxic pesticide |
| FOR AVIAN ACUTE ORAL LD50 | |
| LD50 < 10 ppm | very highly toxic pesticide |
| LD50 = 10-50 ppm | highly toxic pesticide |
| LD50 = 51-500 ppm | moderately toxic pesticide |
| LD50 = 501-2000 ppm | slightly toxic pesticide |
| LD50 > 2000 ppm | practically non-toxic pesticide |
| FOR MAMMAL ACUTE ORAL LD50 | |
| LD50 < 10 ppm | very highly toxic pesticide |
| LD50 = 10-50 ppm | highly toxic pesticide |
| LD50 = 51-500 ppm | moderately toxic pesticide |
| LD50 = 501-2000 ppm | slightly toxic pesticide |
| LD50 > 2000 ppm | practically non-toxic pesticide |
| FOR FISH OR AQUATIC INVERTEBRATE LC50 | |
| LC50 < 0.1 ppm | very highly toxic pesticide |
| LC50 = 0.1-1 ppm | highly toxic pesticide |
| LC50 = 1-10 ppm | moderately toxic pesticide |
| LC50 = 11-100 ppm | slightly toxic pesticide |
| LC50 = > 100 ppm | practically non-toxic pesticide |
Tests in the second tier evaluate longer-term impacts that might occur. These tests evaluate survival, growth, reproduction, body weight, physiological abnormalities, and other effects that may be chemically induced. An important statistical end point of these studies is the highest concentration producing no observed effect: the No Observed Effect Level (NOEL).
Understanding the short- and long-term toxicological effects from exposure is the first step for measuring hazards, but pesticide toxicity is only a partial indication of relative risks to wildlife. Potential exposures have to be evaluated in order to assess risks accurately. An estimation of the exposure of wildlife to pesticide residue in the environment must be determined. It is called the Estimated Environmental Concentration (EEC). The EEC for birds and mammals is the concentration of the pesticide in or on foods that they might consume. This may be determined in special field studies but is most often estimated from various published sources. The EEC for aquatic organisms may be a range of concentrations representing typical and worst-case exposures (caused by runoff or spray drift) that may occur in bodies of water adjacent to treated fields. Aquatic EECs usually are calculated, often with the aid of computer models, but also may be derived from field studies. Field monitoring of exposure and ecological effects still may be required on a case-by-case basis to assess the effectiveness of risk reduction measures.
Cumulative evaluation of laboratory toxicity studies, chemical fate analyses, and (when appropriate) evaluations under actual use conditions provides the manufacturer and EPA with data necessary to evaluate and estimate the direct risks to wildlife from the use of a pesticide. Hazard analysis is a comparison between toxicity information and the estimated environmental concentrations. If the EEC is significantly less than levels found to pose acute or chronic problems, the assumption is that the pesticide will not have a significant adverse impact on wildlife. Conversely, if the EEC exceeds levels known to produce problems, the pesticide residues being evaluated may be expected to produce harm. If the data indicate a high likelihood of hazard to wildlife, the EPA may require additional or more refined testing, mandate specific label language, classify the pesticide for restricted use, or recommend against registration.
Each pesticide must receive an EPA registration before it can be sold, distributed, or used in the United States. EPA's Office of Pesticide Programs grants registration of a product only at the conclusion of a thorough evaluation process wherein toxicological, environmental, and product use information is examined. The EPA's review of the data and the issuance of a registration complies with the agency's mandate by the Federal Insecticide, Fungicide, and Rodenticide Act that the potential benefits of use outweigh any potential risks: that use according to label directions will not cause unreasonable adverse effects on humans, wildlife, or the environment.
A pesticide's label is its primary communication to users. It reflects the numerous scientific studies and regulatory reviews generated by the registration process. The law requires pesticide users to read and follow label specifications. Through specific and general language, the label addresses potential and actual risks to wildlife (e.g., a label might state that drift and runoff from treated areas may be hazardous to aquatic organisms in neighboring areas).
The Environmental Hazards Statement forewarns the user of potential adverse effects on wildlife and/or the environment which might result from the use of the product. This section of the pesticide label also identifies precautions to reduce or prevent exposure of wildlife and contamination of the environment. Much of the label language is determined by the reaction of the indicator species during laboratory toxicity testing or as a result of actual cases of wildlife poisoning attributed to the pesticide. For example:
| If the toxicological data indicates... | Then the label must give the |
| following instructions: | |
| ...Mammalian acute oral LD50 of 100 ppm or less | This pesticide is toxic to wildlife. |
| ...Fish acute LC50 of 1 ppm or less | This pesticide is toxic to fish. |
| ...Avian acute oral LD50 of 100 ppm or less | This pesticide is toxic to wildlife |
| ...Avian dietary LC50 of 500 ppm or less | This pesticide is toxic to wildlife. |
| ...Bee acute toxicity of 2 micrograms or less | This pesticide is highly toxic to bees |
| ...Field studies or investigatiions indicate | This pesticide is extremely toxic to |
| that the use of the pesticide may result | wildlife or fish. |
| in fatality to birds, fish, or mammals. |
The following advisory statement must appear in the environmental hazard statement if the product is intended for outdoor use other than aquatic applications:
For terrestrial uses, do not apply
directly to
water, or to areas where surface water is present, or
to intertidal areas below the mean high water mark.
Do not contaminate water by the cleaning of equipment
or disposal of wastes.
Where a hazard to a nontarget organism (excluding humans and domestic animals) exists, statements describing the nature of the hazard and the appropriate precautions to avoid potential accident, injury, or damage are required. These hazard statements are prescribed according to toxicological data (LD50 or LC50 values) and field testing.
This pesticide is extremely toxic to
fish
and wildlife. Birds and wild mammals utilizing treated
areas may be killed. Do not apply directly to water or to
areas where surface water is present.
This product is highly toxic to bees
exposed
to direct treatment or residues on crops or
blooming weeds. Do not apply this product or allow it to drift
to blooming crops or weeds if bees are visiting the
areas to be treated.
Information designed to protect valuable resources and potential habitats may be indicated in the environmental hazards statement of the label by the listing of these advisories.
Pesticide X is a chemical which can
travel
(seep or leach) through soil and contaminate ground
water. Users are advised not to apply pesticide X where
the water table (ground water) is close to the surface
and where the soils are very permeable.
Do not apply when weather conditions
favor
drift from target areas.
This product may not be mixed or loaded
within 50 feet of intermittent streams and rivers, or natural
or impounded lakes and reservoirs.
Pesticide registration does not end the oversight process by EPA or the responsibility of the manufacturer. Employees of manufacturers are required under penalty of fine and/or imprisonment to report any adverse pesticidal effects not previously submitted to EPA. Manufacturers may become cognizant of new information as a result of continued laboratory testing or learn of incidents where field use of a product harmed wildlife or contaminated the environment. EPA, in cooperation with the pesticide manufacturer, may review labels as new information becomes available to ensure that the language is specific enough to protect wildlife. In addition, EPA may undertake a special review to determine whether their prior registration decisions continue to provide adequate environmental protection.
The special review process (40 CFR Part 154.7) allows EPA legal recourse to reconsider all data, wildlife incidents, and regulatory decisions relevant to a prior registration of a pesticide. Four of the six criteria listed for special review specifically mention nontarget effects, effects on endangered species, habitat destruction, and the environment. Wildlife considerations, therefore, are important to decisions on the continued registration of pesticides.
A special review can be initiated anytime there is evidence that the use of a pesticide will cause unreasonable adverse effects on wildlife. Typically, a special review goes beyond the comparison of estimated environmental concentration to toxicity values and includes evaluations of field studies or field incidents. Following a comprehensive reevaluation of the pesticide, EPA may 1) take no action, 2) alter the pesticide label language to further minimize risk, 3) classify the pesticide for restricted use, 4) eliminate specific uses, or 5) cancel or suspend the registration.
Often there is more than one product or management practice available to control a particular pest. But, ideally, the decision to purchase a pesticide should be based on more than a comparison of cost and performance among product choices. An important consideration is a review of the various pesticide labels for hazards to wildlife; users should select a product that is efficacious and presents the least potential for hazard to nontarget wildlife in the area to be treated.
The decision to protect wildlife and practice pesticide stewardship goes hand and glove with any purchasing decision. For wildlife protection and product stewardship to occur simultaneously, special attention has to be given to the biological and environmental uniqueness of the application site and to any adjoining wildlife habitats. The decision to use a pesticide implies that the user is willing to follow precisely all instructional and precautionary language and accepts the label as a legal document; yet the label cannot predict and give precise advice for every situation where that pesticide may be applied. The pesticide user should exercise common sense and be alert to wildlife that inhabits the application site and surrounding areas.
Users also can supplement label directions with additional measures beyond label guidelines to protect the integrity of a habitat and its corresponding wildlife populations.
Seek the advice of wildlife, conservation, and pesticide professionals at universities, state and federal agencies, and private foundations for strategies to improve wildlife habitat and for advice on the use of pesticides and alternative pest control strategies. Implementation of the management suggestions that follow will benefit wildlife and simultaneously allow for control of damaging insect, weed, and disease pests. Remember, with all of these suggestions the user must be consistent with the pesticide label.
All wildlife need natural areas in
which to
feed, rest, reproduce, raise young, and take shelter.
Create wildlife habitat by encouraging and promoting
the growth of native vegetation. This also reduces
mowing costs and saves time.
Select disease and insect resistant
trees
and shrubs to plant on your property, thereby reducing
the need for pesticide use.
Prevent wildlife poisonings by storing
pesticides and wildlife feed separately.
Do not feed wildlife near pesticide
storage
and mixing areas.
Keep wildlife habitats in mind when
reading labels.
Compare labels and select highly
specific
products which pose reduced risks to nontarget
species. Read the label carefully and use the lowest
effective rate.
Calibrate equipment carefully to assure
that
the pesticide is applied at labeled rates.
Ask the retail outlet for the
Endangered
Species Bulletin when indicated by the label, or contact
federal and state agricultural and conservation agencies
for bulletins.
Take heed of the label. The
environmental
and wildlife precautions on labels are based on
scientific and regulatory actions. They must be followed. It's
the law, good business, and the right thing to do!
Consult state agricultural
agency and Cooperative Extension Service educators for additional assistance
on label clarification or to determine potential pesticidal impacts on wildlife.
Also, consult state natural resource agencies, natural heritage programs, and
the Nature Conservancy for additional information about wildlife, native vegetation,
and endangered species.
If you can identify areas that are
frequented
by wildlifeespecially flocks of birdsavoid spraying
near those areas or, if possible, reduce the application rates.
Homeowners should search for bird and
mammal nests prior to spraying fruit trees, shrubs, or
lawns, then avoid spraying near those areas.
Investigate the use of alternative pest
control tacticsmechanical, cultural, biologicalwhen available and practical
(e.g., tillage, crop rotation, pest resistant plants, natural predators, trapping).
Scouting and pest identification are
critical
components of wise pesticide use. To save money
and reduce impacts on wildlife, apply pesticides
only when pests are present at unacceptable levels. Your
Cooperative Extension educator can provide guidelines.
Remember, it is important to guard
against pesticide drift and runoff. Apply pesticides under
low, directional wind conditions; and use adjuvants
when appropriate. Use buffer zones of unsprayed crops
or grass strips adjacent to important habitats to
help protect wildlife.
Adjust application schedules to reduce
likelihood of runoff. Do not make pesticide applications when
rain is imminent. Surface runoff may move some
pesticides into ponds, streams, and wetlands inhabited by
wildlife. In urban areas, such runoff may flow into storm
drains leading directly to streams and rivers, without
treatment. Moreover, pesticide that is washed off is
money lost.
Multiple pesticide applications may
have
cumulative effects, especially during breeding
seasons. Reduce frequency of applications, when possible,
and target each application to the specific site of the
pest instead of making broad applications over entire
fields or lawns.
Control weeds and insects in home lawns
and gardens by spot treating to reduce the amount
of pesticide applied.
Where practical, eliminate the use of
pesticides
in and around field edges and corners, fence rows,
set-aside acreage, nesting sites, vegetation near
streams and wetlands, and areas that are dedicated to
wildlife (except for spot treatment to control state listed
noxious weeds). Especially important are sensitive areas
such as endangered species habitats, native plant
communities, and sinkholes.
Check the label for instructions on
incorporating pesticide granules into the soil or watering them
into turf: The product reaches the target pests
more readily, and foraging birds are less likely to
ingest granules.
Never spray leftover pesticides or wash
off equipment near wetlands, rivers, streams, creeks, potholes, ponds, marshes,
sinkholes, other wildlife habitats, or drains leading to these areas. Dispose
of leftover pesticide in an approved manner as specified by the label.
The Endangered Species Act (ESA) of 1973 and its subsequent amendments comprise the major federal legislation that protects not only threatened or endangered wild plants and animals, but also critical habitats and ecosystems that support those and many other species. Referring to endangered or threatened plants and animals, ESA states in the preamble that "these species of fish, wildlife, and plants are of aesthetic, ecological, educational, historical, recreational, and scientific value to the nation and its people."
The U.S. Fish and Wildlife Service and the National Marine Fisheries Service are responsible for identifying candidate species for federal endangered species protection. Species proposed for listing are made public through a notice of review in the Federal Register. This notice of review is the process whereby these two federal agencies ask all interested persons and organizations for biological and ecological information on each species on the proposed list. Currently 3,600 species or subspecies of plants and animals have been identified as candidates for listing.
In the United States, information sufficient to move approximately 600 species from candidate status to the United States List of Endangered and Threatened Wildlife and Plants has been gathered. Federally listed species are given full federal protection: No one shall "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct." All federal agencies (e.g., Environmental Protection Agency and U.S. Army Corps of Engineers) must comply with ESA by ensuring that their activities will not jeopardize the continued existence of a listed species.
ESA mandates that federal agencies shall not undertake activities or make decisions whose consequences will adversely impact the existence of federally threatened or endangered species or their habitats. EPA must comply with the provisions of ESA in assuring that a pesticide registration does not create the potential for exposure of, or otherwise jeopardize, a federally listed species. The scope of this program covers all outdoor uses of pesticides, including home and garden uses.
The Endangered Species Protection Program has two phases: consultation and implementation. The EPA's "may affect" determination takes place prior to formal consultation with the United States Fish and Wildlife Service (FWS) and is the key to initiating consultation. Following are the fundamental steps in the process:
Species which potentially could be
impacted
by the use of pesticides are identified. EPA, the
United States Department of Agriculture, and FWS
have collaboratively ranked approximately 93 species
for pesticide vulnerability.
Pesticides that may impact any of
these
species are identified. EPA identifies the pesticides
registered for use in areas within the range of a protected
species and issues what is known as "may affect"
determination.
EPA may eliminate a "may
affect"
determination. EPA may remove a "may affect" determination
through pesticide use limitations that are sufficient to achieve
a "no effect" determination.
Environmental Protection Agency
consults
with the Fish and Wildlife Service on the remaining
"may effect" determinations. EPA requests a formal
consultation with the Fish and Wildlife Service. A
thorough review of the species allows FWS to develop a
Biological Opinion, which indicates if harm is likely to
result from pesticide exposure to a specific organism in
a specific habitat. This Biological Opinion will
specify reasonable and prudent measures, such as
specific pesticide use limitations, that EPA must implement
to protect the species.
Habitat maps are
developed. Where there is potential for impact, EPA develops species
habitat maps within an Endangered Species Bulletin.
The bulletin identifies pesticides that may harm the
species and describes use limitations necessary to
protect them.
Pesticide users must read
labels. Pesticide labels alert the pesticide user to refer to county
Endangered Species Bulletins. If the area in which the user will
be making an application is included in the bulletin,
the user must comply with all of the provisions.
The bulletin becomes a part of the labeling and
therefore carries the full force of law if not properly followed.
Program implementation includes several components, depending on the approach to protection selected by state pesticide regulatory agencies. Currently, there is an EPA interim program in which some pilot states are conducting activities to protect endangered species from pesticides. The federal approach to protection is through labels, bulletins, and fact sheets. The label refers the user to a bulletin and a toll-free endangered species hotline number to call for information about endangered species, such as whether there is a bulletin available for the county. The user must comply with use restrictions in the bulletin, which contains a map, a list of pesticides, and use limitations such as buffer zones or limitations on application methods.
About one-fourth of the states manage or are developing their own programs to protect federally listed species from pesticide injury as an alternative to, or in addition to, the EPA labeling program. In many cases, protection is accomplished by providing information and education on endangered species and pesticides directly to affected landowners, land managers, operators, applicators, and dealers. Pesticide management plans are negotiated jointly with users for lands near these species. Some states are involved in mapping, developing protection guidelines, or in other ways providing protection from potential harm from pesticides. State plans need the approval of FWS and EPA and can substitute for EPA bulletins and fact sheets. Some excellent brochures have been developed by state programs.
States have considerable responsibility in protecting wildlife. State biologists are actively creating species inventories from which a better understanding of distribution and abundance can be obtained. Using the guidelines established by the Minnesota Department of Natural Resources, most states adopt similar strategies to help protect wildlife and habitat.
Identification of Species and
Habitats and
Setting Priorities for Conservation. A comprehensive
biological inventory of the state's endangered species and
natural habitats is the first step toward their protection.
Without this information, responsible management
decisions cannot be made concerning the fauna and flora of
an area.
Protection by Saving the Best and
the
Rarest. After identification, ecologically significant lands
are protected by acquisition, conservation easement, or landowner
registry. Creative
partnerships among public agencies, private conservation organizations,
and private
landowners are the key to protecting all the major types
of wildlife habitat.
Stewardship by Managing
Endangered Species and Unique Habitats. The
protection of threatened natural lands is critical in
the conservation process. Active management, including monitoring and
restoration, often
is required to maintain the ecological conditions necessary for
long-term survival of
endangered species and their habitats.
Promoting Public Awareness Through Education.
Educational programs enhance public awareness of the loss of natural habitat
and the potential jeopardy to endangered species will result in increased public
support for conservation initiatives.
The certification process was established to provide technical knowledge for those using restricted-use pesticidesthose pesticides that pose the greatest risk of harm to people, wildlife, and the environment if handled improperly. The certification process generally involves educational training and examinations that cover pest biology, human health and safety, environmental issues (e.g., water quality and endangered species), regulatory updates, label interpretation, and other job-specific information. Nationally, there are approximately one million applicators certified to purchase and apply restricted-use pesticides. Certified applicators are generally required to retest periodically or attend pesticide education programs to maintain their certification.
The handling of listed species requires a federal endangered species permit except for employees or agents of a state or federal conservation agency who are acting in an official capacity. If you discover injured or dead wildlife, do not handle it. Call a wildlife law enforcement agent with either your state conservation agency or the U.S. Fish and Wildlife Service for information and instructions; both should be listed in your telephone directory under government agencies.
The primary objective for sick or injured wildlife is effective treatment and care; for carcasses, the objective is preservation for proper diagnosis of the cause of death. If pesticides are suspected or known to be the cause-whether the species is endangered or notinformation on pesticides known to have been used in the area will be useful: product name, EPA registration number, date of application, conditions before and after application, etc.
Among the goals of society is our ambition to provide citizens with meaningful employment, appropriate food, good health, decent housing, a safe environment, and quality education. Government, industry, and the general public must approach economic productivity in a manner that is ecologically and environmentally sound. Most wildlife species do not have the luxury of moving to new habitats when exposed to pesticides. Wildlife species must adapt to changes in their habitator cease to exist.
A diverse, healthy flora and fauna are indicators of a healthy ecosystem. It behooves each of us to take our environmental responsibilities seriously and to take all reasonable steps necessary to protect wildlife from hazards posed by pesticides.
The responsibility for ensuring that wildlife is protected from potential adverse pesticidal effects can be viewed as a triangle of wildlife protection: manufacturers, government, and the pesticide user. The manufacturer must develop products, supported by sound scientific studies, that allow for the maximum benefits of use with minimal risk to wildlife and its habitat. Local, state, and federal government must establish standards for pesticide use and promote research addressing wildlife contaminant issues. The pesticide userfarmer, homeowner, and professional applicatormust follow pesticide label instructions and strive to apply pesticides as carefully as possible, with wildlife protection in mind. Protection and sustainability of our environmental heritage is a task requiring the support of all.
Purdue University |
| West Lafayette, Indiana |
| Cooperative Extension Service, (765) 494-4566 |
| ~ For pesticide applicator education and public outreach |
|
|
| (765) 494-3591 |
| ~ For wildlife management education |
| (765) 494-1492 |
| ~ For pesticide applicator certification and licensing; pesticide registration; enforcement |
Indiana Department of Natural Resources |
| 402 West Washington Street, Room W296 |
| Indianapolis, Indiana 46204 |
| ~ For forest management assistance |
| ~ For wildlife management assistance |
U.S. Department of Agriculture |
| National Program Leader, Cooperative Extension Service |
| South Ag Building |
| 1400 Independence Avenue, SW |
| Washington, DC 20450-0900 |
| ~ Liaison between federal government and state pesticide educators |
| ~ Liaison between federal government and state IPM specialists |
| ~ Liaison between federal government and state wildlife specialist |
U.S. Department of the Interior |
| 1849 C Street, NW |
| Washington, DC 20240 |
| ~ For wildlife managementresearch, technical assistance, and enforcement |
| Laurel, Maryland 20708 |
| ~ For wildlife researchpesticide and contaminant effects on wildlife |
| Fort Snelling Federal Building |
| Twin Cities, Minnesota 55111 |
| ~ For fisheries researchpesticide hazards to aquatic organisms |
| Route 2, 4200 New Haven Road |
| Columbia, Missouri 65201 |
| ~ Fisheries researchpesticide hazards to aquatic organisms |
U.S. Environemntal Protection Agency |
| 401 M Street |
| Washington, DC 20406 |
| ~For pesticide registration, environmental risk assessment, and evaluation of environmental and wildlife data for registration |
| ~ Atlanta (404) 562-9900 |
| ~ Boston (617) 918-1111 |
| ~ Chicago (312) 353-2000 |
| ~ Dallas (214) 665-2000 |
| ~ Denver (303) 312-6312 |
| ~ Kansas City, KS (913) 551-7003 |
| ~ New York (212) 637-3000 |
| ~ Philadelphia (214) 814-5000 |
| ~ San Francisco (415) 744-1305 |
| ~ Seattle (206) 553-1200 |
U.S. Code |
Title |
Intent |
Fine/Penalty |
| 16 U.S.C. 688-668C | Eagle Protection | Prohibits import, export, taking of | Civil: $5,000 |
| Act 1940 | bald and golden eagles. | Criminal: $100,000/one year, | |
| $250,000/two years (second | |||
| offense) | |||
| 16 U.S.C. 703-712 | fMigratory Bird | Prohibits hunting, taking, possession, | Criminal: $25,000/six months, |
| Treaty Act 1918 | etc., of migratory birds. | $250,000/two years (felony | |
| sale) | |||
| 16 U.S.C. 718 | Migratory Bird hunting, | Requires hunting stamps prior to | Criminal: $25.000/six months |
| and Conservation Stamp | taking migratory waterfowl. | ||
| Act 1934 | |||
| 18 U.S.C. 42; | Lacey Act 1981 | Ensures humane treatment for wildlife | Civil: $10,000 |
| 16 U.S.C. 3371-3378 | shipped to U.S. Controls smuggling/ | Criminal: $100,000/one year | |
| trade in illegally taken fish and | $250,000/five years | ||
| wildlife. | (felony sale/purchase) | ||
| 16 U.S.C. 1361-1407 | Marine Mammal Protection | Moratorium on taking and importation | Civil: $10,000 |
| Act 1972 | of marine mammals. Defines federal | Ciminal: $100,000/one year | |
| responsibility for conservation of | |||
| marine mammals. | |||
| 16 U.S.C. 742j-1 | The Airborne Hunting Act | Prohibits taking wildlife from aircraft | Criminal: $100,000/one year. |
| 1956 | except when protecting wildlife, | Allows forfeiture of guns, | |
| livestock, or human health. | aircraft, and equipment. | ||
| 16 U.S.C. 668dd-668ee | National Wildlife Refuge | Guidelines and directives for mange- | Criminal: $100,000/one year |
| System Administration Act | ment of wildlife refuges and areas | ||
| 1966 | for protection of fish, wildlife, etc. | ||
| 16 U.S.C. 1521-1453 | Endangered Species Act | Prohibits importation, taking, etc., of | Civil: $25,000 |
| 1973 | fish, wildlife, and plants that are listed | Criminal: $100,000/one year | |
| as threatened and endangered. Also | (knowing violation) | ||
| implements the convention or | |||
| international trade in endangered | |||
| species of wild fauna and flora | |||
| (CITES). | |||
| 16 U.S.C. 721-731 | Upper Mississippi Refuge | Guidelines for the upper Mississippi | Criminal: $25,000/six months. |
| National Wildlife and Fish Refuge. | Forfeiture of fish, wildlife, | ||
| guns, fishing equipment, and | |||
| boats used contrary to the | |||
| statute. | |||
| 16 U.S.C. 4901 et seq. | Wild Bird Conservation | Moratorium on all imports of exotic | Civil: $25,000 |
| Act 1992 | birds except for scientific research, | Criminal: 2 years | |
| breeding, personally owned pets. | |||
| 7 ;U.S.C. 121-136y | Federal Insecticide, | Registration of pesticides; risk/benefit | Civil: $5,000 (companies |
| Fungicide, and Rodenticide | standard; data requirements. | and commercial), $1,000 | |
| Act 1947* | (farmer). Criminal: $50,000/ | ||
| one year (companies), | |||
| $25,000/one year (applicator), | |||
| $1,000/30 days (farmer). | |||
| 33 U.S.C. 2401-2410 | Organotin Antifouling | Prohibits use of antifouling paints on | Civil: $5,000 |
| Paint Control Act 1988 | ships <25 meters; toxicity to shellfish. | Criminal: $25,000/one year. | |
| 16 U.S.C. 4701-4751 | Aquatic Nuisance | Research into environmental effects | Civil: $25,000/day |
| Prevention and Control | of ballast; zebra mussel demonstration | Criminal: $250,000 (indiv.) or | |
| Act 1990 | project; prevention and control of | 2 x value of the loss or damage | |
| aquatic nuisance species. | $500,000 (corp.) or 2 x the | ||
| value of the loss or pecuniary | |||
| gain/0-25 years |
*The first legislation regulating pesticide use was the Insecticide Act of 1910.
Bryan, G. and J. Pease. 1992. Agricultural Pesticides and Wildlife: A Balancing Act. Iowa State University Cooperative Extension Service.
Edge, W. and L. Ketchum. 1992. Endangered Species and Pesticides: Balancing Protection and Production. Oregon State University Cooperative Extension Service. VTP 006.
Environmental Protection Agency. 1988. Pesticide Assessment Guidelines Subdivision E Hazard Evaluations: Wildlife and Aquatic Organisms. U.S. Environmental Protection Agency.
Environmental Protection Agency. 1992. Framework for Ecological Rish Assessment. U.S. Environmental Protection Agency. EPA 630/R-92/001.
Environmental Protection Agency. 1993. A Review of Ecological Assessment Case Studies from a Risk Assessment Perspective. U.S. Environmental Protection Agency. EPA 630/R-92/005.
Environmental Protection Agency. 1994. Status of Pesticides in Reregistration and Special Review. U.S. Environmental Protection Agency. EPA 738/R-94/008.
Fish and Wildlife Service. 1991. Why Save Endangered Species? United States Department of the Interior.
Fish and Wildlife Service. 1991. Placing Animals and Plants on the List of Endangered and Threatened Species. United States Department of the Interior.
Fish and Wildlife Service. 1993. National Survey of Fishing, Hunting, and Wildlife-Associated Recreation. United States Department of the Interior.
Fite, E., L. Turner, N. Cook and C. Stunkard. 1988. Guidance Document for Conducting Terrestrial Field Studies. U.S. Environmental Protection Agency. EPA 540/09-88-109.
Hamilton, S. and J. Pease. 1993. Agricultural Pesticide Impacts on Prairie Wetlands. Iowa State University Cooperative Extension Service.
Hill, E. and D. Hoffman. 1984. Avian Models for Toxicity Testing. Journal of the American College of Toxicology, Vol. 3:357-76.
Hudson, R., R. Tucker and M. Haegele. 1984. Handbook of Toxicity of Pesticides To Wildlife. United States Department of the Interior Fish and Wildlife Service. Resource Publication 153.
Martin, A., F. Whitford, J. Becovitz and C. Rew. 1993. Pesticides and Applicator Certification. Purdue University Cooperative Extension Service. PPP-25.
Messmer, T. and G. Dahl. 1991. Wildlife and Pesticides: A Practical Guide to Reducing the Risk. North Dakota State University Extension Service. WL-1017.
Miller, B. 1993. Hoosier Farmland Wildlife Notes: Fostering Wildlife in Agriculture. Purdue University Cooperative Extension Service.
Miller, J. 1991. National Program Guidance Statement Extension Wildlife and Recreational Fisheries. Cooperative Extension Service. U.S. Department of Agriculture.
Miller, B. and J. Seifert. 1992. Forestry and Wildlife Management Assistance Available to Indiana Landowners. Purdue University Cooperative Extension Service. FNR-87.
Miller, B., V. Stiles and S. Wilds. 1990. Managing Forest and Wildlife Resources: An Integrated Approach. Purdue University Cooperative Extension Service, FNR-125.
Palmer, W. and P. Bromley. 1992. Pesticides and Wildlife. North Carolina Cooperative Extension Service. Ag-463-1 through AG-463-7.
Palmer, W. and P. Bromley. 1992. Wildlife and Agricultural Pesticide Use. North Carolina State Cooperative Extension Service. AG-475.
Smith, G. 1987. Pesticide Use and Toxicology in Relation to Wildlife: Organophosphorus and Carbamate Compounds. Fish and Wildlife Service. U.S. Department of the Interior. Resource Publication 170.
Stinson, E. and P. Bromley. 1991. Pesticides and Wildlife: A Guide to Reducing Impacts on Animals and Their Habitat. Virginia Department of Game and Inland Fisheries. Pub. 420-004.
Touart, L. 1988. Technical Guidance Document for Aquatic Mesocosm Tests to Support Pesticide Registrations. U.S. Environmental Protection Agency.
Urban, D. and N. Cook. 1986. Ecological Risk Assessment. U. S. Environmental Protection Agency. EPA 540/9-85-001.
Whitford, F. 1993. Pesticide Facts and Perceptions: Communicating with Producers and Consumers. Journal of Extension. Vol. 31: 9-11.
Whitford, F., D. Barber, E. Scott, C. Edwards and J. Caravetta. 1993. Pesticides and the Label. Purdue University Cooperative Extension Service. PPP-24.
Whitford, F., R. Corrigan, G. Ruhl, B. Lerner, Z. Reicher and T. Gibb. 1994. Pesticides and the Home, Lawn, and Garden. Purdue University Cooperative Extension Service. PPP-29.
Whitford, F., J. Neu, B. Brousseau, T. Hardy, J. Impson and D. Rider. 1991. State Departments of Agriculture: Pesticide and Environmental Specialists of the 1990's. American Entomologist. Vol. 37: 27-34.
Partial funding for this publication was made available from the U.S. Environmental Protection Agency, Region 5. Support also was provided by the Branch of Extension and Publications, Office of Training and Education, U.S. Fish and Wildlife Service.
The senior author is extremely grateful to Richard Balcomb, Ciba Plant Protection, for his expertise and technical assistance; to Stephen Adduci for his original illustrations; and to Gene White, Eugene White Photography, and Jim Rathert, Missouri Conservation Department, for their wildlife photographs. The authors are very grateful to to the following reviewers for comments and suggestions that greatly improved the breadth and scope of Pesticides and Wildlife.
Robert Bielarski, Certification and Training Branch, U.S. Environmental Protection Agency
Peter Bromley, Extension Wildlife Specialist, North Carolina Cooperative Extension Service
Richard Brown, Manager, Environmental Fate & Effects Section, Zeneca
David Deegan, Certification and Training Branch, U.S. Environmental Protection Agency
David Fischer, Terrestrial Group Leader, Miles Inc.
Julie Fry, Certification and Training Branch, U.S. Environmental Protection Agency
Thomas Hampton, Purdue University Cooperative Extension Service County Educator
Woody Hill, Wildlife Toxicologist, U.S. Fish and Wildlife Services Patuxent Wildlife Research Center
Ron Johnson, Extension Wildlife Specialist, Nebraska Cooperative Extension Service
Linda Lyon, Fish and Wildlife Biologist, U.S. Fish and Wildlife Service
Terry Messmer, Extension Wildlife Specialist, Utah State University
Ellen Mihaich, Environmental Toxicologist, Rhone-Poulenc
Jim Miller, National Program LeaderFish and Wildlife Natural Resources and Rural Development, U.S. Department of Agriculture Extension Service
Lisa Mueller, Endangered Species Protection Program, Minnesota Department of Agriculture
Ursula Petersen, Endangered Species Specialist, Wisconsin Department of Agriculture, Trade and Consumer Protection
Ann Stavola, Supervisory Biologist, Ecological Effects Branch, U.S. Environmental Protection Agency
Larry Turner, Project Manager, EPA Endangered Species Protection Program, U.S. Environmental Protection Agency
Barry Wilson, Department of Avian Sciences, University of California at Davis
It is the policy of the Purdue University Cooperative Extension Service, David
C. Petritz, Director, that all persons shall have equal
opportunity and access to the programs and facilities without regard to race,
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