SILENT

SPRING
REVISITED

Pesticide Use and Endangered Species

Center for Biological Diversity

 Silent Spring Revisted:
Pesticide Use and Endangered Species

A Center for Biological Diversity Report

By Brian Litmans and Jeff Miller
Photo Editor, Design: Meredith Hartwell

Center for Biological Diversity

BECAUSE LIFE IS GOOD
P.O. Box 710
Tucson, AZ 85702
(520) 623-5252
www.biologicaldiversity.org

The Center for Biological Diversity protects endangered species and

wild places through science, policy, education, and environmental law.

These sprays, dusts, and aerosols are now applied almost universally to farms,
gardens, forests, and homes - nonselective chemicals that have the power
to kill every insect, the “good” and the “bad,” to still the song of
birds and the leaping of fish in the streams, to coat the leaves with a
deadly film, and to linger on in soil - all this though the intended target may be
only a few weeds or insects. Can anyone believe it is possible to lay down
such a barrage of poisons on the surface of the earth without making it
unfit for all life? They should not be called “insecticides,” but “biocides.”

~Rachel Carson, Silent Spring, 1962 ~

 TABLE OF CONTENTS

Executive Summary...................................................................................... i
A Background on Pesticide Use.................................................................. 1
Contaminated Waterways............................................................................... 2
Contaminated Soils, Contaminated Biota.................................................... 3
Pesticide Drift................................................................................................... 4
Pesticides and Aquatic Life Criteria.............................................................. 6
The Biological Effects of Pesticides: Endocrine Disruption,
Sexual Deformities and Other Reproductive Anomalies.......................... 10
Other Wildlife Impacts................................................................................. 16
Pesticide Use Threatens the Survival of Endangered Species.................. 18
Pacific Region Species..................................................................................... 19
Southwest Region Species...............................................................................30
Great Lakes-Big Rivers Region Species........................................................ 32
Southeast Region Species............................................................................... 35
Northeast Region Species............................................................................... 39
Mountain-Prairie Region Species................................................................... 40
Other Species Affected by Pesticides........................................................... 42
What is the EPA doing to Control the Use of Pesticides?......................... 45
The Registration Process................................................................................ 45
The EPA’s Responsibilities Under the Endangered Species Act.............. 49
The EPA’s So-Called “Endangered Species Protection Program”........... 51
The EPA and the Courts.............................................................................. 55
Discussion.................................................................................................... 58
Endnotes....................................................................................................... 61
 EXECUTIVE SUMMARY

More than two billion pounds of pesticides are sold The most recent example of the EPA’s unfortunate
each year in the United States for agricultural, obeisance to the industries it was intended to
commercial, and home uses. At present, the regulate was revealed in November 2003, when it
Environmental Protection Agency (EPA) has renewed its registration of the chemical atrazine.
registered more than 18,000 pesticides.The public Atrazine, an herbicide used heavily throughout the
assumes pesticide products are safe because they United States, is so dangerous to humans and
are registered for use by the EPA, but their faith is wildlife that it was recently banned by the European
misplaced. Union.

More than two billion pounds of pesticides are sold each year in
the United States for agricultural, commercial, and home uses.

As this report documents, the EPA’s regulatory Yet despite numerous studies linking atrazine to
oversight of the pesticide industry is abysmal. significant human and wildlife health concerns
When confronted with credible studies on the (including endocrine disruption), the EPA
adverse impacts of pesticides, the EPA has announced it would impose no new restrictions on
consistently responded by attempting to diminish its use. Rather, the EPA entered into a private deal
the findings in any way it can, even though it has with the manufacturers of atrazine, including the
admitted that “most pesticides pose some degree of giant chemical corporation Syngenta, in which the
risk because they are designed to have a negative corporations will monitor a mere 40 of the 1,172
effect on living organisms.”1 watersheds the EPA has recognized as being “at
risk” of contamination. This is just one example
While the Environmental Protection Agency is of how the EPA is placing humans and wildlife at
entrusted to protect public health and the risk to serve the agrochemical industry.
environment it has consistently attempted to ignore
mounting evidence demonstrating that even low What’s more, under the administration of George
doses of pesticides in wildlife and humans can have W. Bush, the EPA is attempting to further subvert
drastic consequences. By ignoring sound science, the public interest by changing the rules governing
disregarding U.S. Fish and Wildlife Service requests pesticide evaluations. Although the EPA by law is
to alter pesticide registrations because of adverse required to consult with the U.S. Fish and Wildlife
impacts to wildlife, and rushing to get pesticides Service on pesticide registration, it has failed to
on the market, the EPA’s Office of Pesticide complete a single consultation in the last ten years
Programs has proven it is not an independent entity. despite repeated formal requests from the wildlife
agency and the unambiguous requirements of the
Endangered Species Act.

i
 [EXECUTIVE SUMMARY]

The EPA has abrogated its responsibilities under The EPA’s policies of dereliction can be
federal laws intended to protect human health and reversed through diligent citizen action. By
imperiled wildlife, including the Federal insisting that federal agencies adhere to
Insecticide, Fungicide, and Rodenticide Act, the the laws protecting rare animals and plants,
Food Quality Protection Act, and the Endangered members of the public can curtail and reduce
Species Act. As a result, wildlife and humans their exposure to known carcinogens and
remain at risk. other substances that have a deleterious effect
on human health. By ensuring that our
Now, the EPA is introducing regulations that would government upholds its promise to protect the
undercut the Endangered Species Act and allow natural world, we can better protect ourselves.

Pesticides pollute significant areas of our air and water, threaten

endangered species, and continuously expose farm workers, women
of reproductive age and children to harmful levels of chemicals.

the agrochemical industry to control research on Humans are not immune from the ravishments we
the environmental impacts of its products. The unleash on nature. Our fate is ultimately
proposed regulations leave sole responsibility for entwined with that of natural ecosystems.
determining whether pesticides threaten
endangered species in the hands of the EPA, despite
its dismal track record. Further, the rule would cut
out the federal agencies that have expertise about
endangered species from the assessment process.

This report exposes the EPA’s failure to protect

people and wildlife from exposure to harmful
pesticides and highlights the agency’s on-going
refusal to reform pesticide use in accordance with Callippe silverspot butterfly
scientific findings. It reveals what the EPA ignores:
Pesticides pollute significant areas of our air and Found at only two sites, Callippe silverspot larvae is
water, threaten endangered species, and often killed by pesticides found in runoff (see p. 26).
continuously expose farm workers, women of
reproductive age and children to harmful levels of
chemicals.

Photo by Dr. Richard Arnold, Entomological Consulting Services

ii
 BACKGROUND ON PESTICIDE USE

Widespread use of synthetic pesticides began Home and commercial uses also contribute
after World War II when federal and local significant amounts of pesticides to our
governments sponsored large-scale spraying environment. The EPA estimates that 85% of all
programs using organochlorines, such as the households have at least one pesticide in storage.4
now-infamous DDT. Today, more than two billion Of those homes, an estimated 76% of residents
pounds of pesticides are used each year in the self-treat their abodes for pest and weed control.
United States to control weeds, insects and other10% of single-family households use a commercial
organisms.2 Although many of the organochlorines lawn service, while an additional 20% applied
have been phased out, they have been replaced with
lawn chemicals themselves.5 Insecticides, which
less persistent yet still dangerous chemicals such
are generally more toxic to aquatic life, are more
as organophosphates, carbamates and triazines. commonly used in urban areas. Yet the EPA is
doing little to assess the impacts of residential
Agriculture now accounts for 70% to 80% of and commercial pesticide use and is only
total pesticide use3 with few mandatory measures taking marginal steps to mitigate the use of
in place to protect human health and the agricultural and commercial uses to protect
environment. The bulk of the agricultural wildlife. It is little wonder that the U.S. Geological
pesticides are herbicides, which comprise Survey (USGS) found that “[a]lmost every sample
60% of agricultural use by weight. of water and fish from streams and major
rivers in all land use settings contained at least
one of the pesticides that we measured.
This means that, throughout the nation, almost
every time and place that you observe a
stream or river in a populated area you are
looking at water that contains pesticides,
inhabited by fish that contain pesticides.” 6

It is imperative that we better understand the

threats pesticides pose to wildlife and humans.
Potential impacts can best be assessed by
analyzing two key attributes of any environmental
contaminant: its biological effects (or toxicity)
and the degree to which it is contained or to
which it spreads. We will take up the latter attribute
first, since once a pesticide is introduced into
the environment, its persistence and movement
ultimately determine the degree of harm it
will cause “non-target” plants and animals.

Line drawing courtesy of the Canadian Wildlife Service 1

 [BACKGROUND ON PESTICIDE USE]

Contaminated Waterways

Water is one of the primary paths by which Yet the EPA continues to assess the risk of each
pesticides are transported away from their pesticide individually, and fails to consider
application areas - often through agricultural and cumulative and synergistic effects. Not surprisingly,
urban runoff.7 Movement of pesticides via runoff the USGS noted a direct correlation between the
can occur whether pesticides are dissolved in the amounts and types of pesticides used and their
water or bound to suspended sediments in the frequency in nearby surface waters. Pesticides were
water. Polluted runoff can pose both acute and found not simply in minute quantities, but at
chronic problems to plants and wildlife. concentrations established as levels of concern,
insofar as the EPA or other regulatory bodies
have set such levels. Although these studies
The USGS, after engaging in a series of water demonstrate the prevalence of pesticides in our
quality studies, released several reports that waters, they represent a mere snapshot of pesticides
documented the astounding ubiquity of in our environment, since the USGS did not assess
pesticides in our waterways.8 Streams and ground pesticide concentrations in our waters through daily
water in basins with significant agricultural or monitoring over the entire season or seasons the
urban development, or with a mix of these pesticides were used. With a limited sampling
land uses, almost invariably were found to size, the USGS studies most likely do not reflect
contain mixtures of nutrients and pesticides. the highest concentrations, and fail to measure the
At least one pesticide was found in almost duration pesticides persist in our waters.
every water and fish sample collected by the
USGS. Moreover, individual pesticides
seldom were found alone; almost every sample
from streams contained two or more pesticides.

Black skimmer killed by pesticides

Photo by Ted Below

2
 [BACKGROUND ON PESTICIDE USE]

Contaminated Soils, Contaminated Biota

Pesticide presence in the sediment of stream Concentrations in aquatic biota may be a better
bottoms also indicates that the pesticide is or was indicator of contamination than direct assay of
present in the water of that stream. 9 Sediment water or sediments. The USGS reports that 44%
serves as habitat for benthic biota at the bottom (41 of 93) of the pesticides they searched for in
of the food chain, such as clams and insects, many their national sediment survey were detected
of which become food for fish. Sediment can act as in sediment, whereas 64% (68 of 106) were detected
a reservoir for contaminants in the stream. in an aquatic biota study. 11
Pesticides can move into and out of stream
bottom sediments Herbicides in
through multiple current use, such as
processes: settling benfluralin, besulide,
of contaminated dacthal, ethafluralin,
suspended sediments; 2,4-DB, dicamba,
re-suspension and net diuron, triallate, and
export of sediments in trifluralin, as well
the water column; as the insecticides
adsorption onto and chlorpyrifos, dicofol,
release from mineral or endosulfan, esfenvalerate,
organic sediments fenthion, fenvelaerate,
depending on stream lindane, methoxychlor,
flow, acidity and permethrin, phorate,
California red-legged frogs
temperature, as well and propargite, were all
as from interactions detected in stream
with stream-bottom organisms; ingestion sediment or biota, raising questions about their
or surface absorption by organisms; or long-term impacts to wildlife and human health.
elimination of wastes and release from decaying
contaminated organisms. 10 Pesticides can
persist and accumulate in sediment and aquatic
biota through such processes even when pesticide
concentrations in water are too low to
be detected using conventional sampling
and analytical methods.

Photo by William Flaxington

3
 PESTICIDEDRIFT
PESTICIDE DRIFT

Runoff is not the only mechanism by which The USGS found concentrations of diazinon,
pesticides travel inadvertently. Pesticide drift is endosulfan, and chlorpyrifos at toxic levels in over
any airborne movement of pesticides away from half the frogs tested in one study – raising
the target site. Drift can result from aerial significant concerns about the transfer of pesticides
application, as well as from wind movement over and impacts of their use on non-target organisms
soils containing pesticides. Airborne vectors of living far away from the point of application. 2 0
pesticides include droplets, dusts, volatilized
vapor-phase pesticides, and pesticide-contaminated Recently, Californians for Pesticide Reform (CPR)
soil particles. Aerial pesticide applications typically released Secondhand Pesticides: Airborne
result in “considerable” off-site drift, according to Pesticide Drift in California,21 documenting the
the National Research Council .12 The quantity of adverse impacts of pesticide drift on humans and
pesticide drift can vary from 5% under optimal wildlife. The analysis found pesticides far from
low-wind conditions to as high as 60%.13 The
Congressional Office of Technology Assessment
estimates that about 40% of an aerial insecticide
application leaves the target area and that less than
1% actually reaches the intended pest.14 The typical
range for drift is 100 to 1,600 meters.15 However,
longer ranges have been documented. For example,
drift from orchard applications in Vermont
exceeded two miles.16 Application on wheat fields
in Colorado drifted between five and ten miles.17
Applications in California drifted four miles from
an oat field; while drift has been noted ten to 50
miles from applications in central Washington. 1 8

Impacts to wildlife from pesticide drift have been Helicopter spraying pesticides
documented. Studies have implicated pesticide
drift from the Central Valley of California in their application sites at concentrations significantly
disproportional declines of several native frog exceeding acute and chronic exposure levels
species in the Sierra Nevada. Even frogs collected deemed “safe” by the EPA. The study also noted
from high in the Sierra Nevada in areas with no that the “acceptable” levels of exposure are
direct pesticide use contain pesticides that appear unlikely to adequately protect humans because the
to be compromising their immune systems. 1 9 levels are determined by exposure to only
The victims include the California red-legged frog one pesticide in isolation from other toxicants.
(Rana aurora draytonii), foothill yellow-legged Failure to incorporate cumulative and synergistic
frog (Rana boylii ), mountain yellow-legged effects means the “acceptable” levels are
frog (Rana muscosa), and Yosemite toad under-protective. The EPA requirements also fail
(Bufo canorus ). Studies have found a close to adequately evaluate sub-lethal effects, such
correlation between the declining populations of as endocrine and developmental alterations.
amphibians and exposure to agricultural pesticides.

Photo courtesy of USFWS 4

 [PESTICIDE DRIFT]

The CPR study reported that pesticide drift causes To prevent spray drift, the EPA relies on applicators
acute human poisonings every year, with children following pesticide labels. However, the EPA itself
most at risk. However, the study noted that acknowledges that current labels are inadequate in
exposures to levels below those that result in preventing spray drift. 24 For example, in
poisoning symptoms are far more common. This a recently released Interim Re-registration
long-term low-level exposure can lead to chronic Eligibility Decision for the highly toxic
illness such as various types of cancer, asthma, pesticide atrazine, the EPA simply states the
respiratory ailments, neurological disorders, birth following under “Spray Drift Management”:
defects, miscarriages and sterility. Exposure early “The Agency is currently working with
in life can result in impaired growth and stakeholders to develop appropriate generic labels
development, cancers and lifelong disabilities. For to address spray drift risk. Once this process is
example, diazinon and chlorpyrifos, commonly completed atrazine labels will need to be
used pesticides that can be found throughout the revised to include this additional language.”2 5

The EPA’s voluntary standards to control spray

drift place humans and wildlife at risk.

waters of the United States, reduce development of Although the EPA published draft guidance for
neural connections and have been documented as label statements on August 22, 2001, it has yet to
endocrine disruptors. An endocrine disruptor is a finalize the label guidance for spray and dust drift,
synthetic chemical that when absorbed into the body and the agency notes “registrants (and applicants)
either mimics or blocks hormones and disrupts the may choose to use the statements proposed
body’s normal functions. The pesticide molinate, in the draft PR notice” [underlining added].2 6
used almost exclusively for rice and heavily used
in California, is linked to testicular damage and The EPA’s voluntary standards to control spray
developmental neurotoxicity. The CPR study drift place humans and wildlife at risk. The CPR
documented molinate many times above levels study notes that the current EPA pesticide label
considered hazardous to children for short-term language is inadequate to control spray drift. Until
exposures up to 75 feet from the application the EPA aggressively addresses spray drift, it
area. Molinate levels were many times above lev- will continue to abrogate its duties under the
els considered hazardous to children in towns Federal Insecticide, Fungicide, and Rodenticide
25 miles from the area of highest molinate use. Act (FIFRA) to protect humans and the
environment from unreasonable adverse effects.
This study’s findings are confirmed by the EPA. Furthermore, the EPA’s failure to control
The EPA notes that pesticide spray drift has been spray drift jeopardizes endangered species, in
and continues to be of concern. 22 The Agency violation of the Endangered Species Act (ESA).
receives thousands of reported complaints of
off-target spray drift each year. 23 Although
the EPA states that its policy is to prevent
drift from the target site, it acknowledges
that some degree of drift of spray particles
will occur from nearly all applications.

5
 PESTICIDES and AQUATIC LIFE CRITERIA

The USGS has noted that the health of aquatic lifeFurther concern for aquatic organisms is raised
may be more at risk than human health from by the fact that ALC have been established for
pesticide contamination in streams.27 It has been only a few pesticides. In the USGS study of our
known for several decades that aquatic life nation’s waters, the USGS refers to ALC
may concentrate or “bio-accumulate” certain established by three different bodies. The ALC
pesticides. In addition, aquatic organisms may established by the EPA were used for six of the
be so sensitive to the presence of pesticides target compounds,33 Canadian values were used
that they serve as more refined indicators for eleven compounds with no EPA-established
of pesticide contamination than chemical assays. values,34 and the ALC established by the Great
Lakes Water-Quality Objective were used for
“Aquatic life criteria” (ALC) have been developed diazinon.35 No ALC have been established for the
by the EPA and others to determine the remaining 28 compounds covered by the USGS
risk to aquatic life from water
contamination. ALC are developed
for specific pollutants to provide
guidance to states and tribes on
adopting water quality standards,
and are the basis for regulating
discharges or releases of pollutants.

USGS sampling found that aquatic

life criteria values were frequently
exceeded in U.S. streams.28 For
example, one or more ALC was
exceeded in 67% of the 58 sampling
sites.29 Almost every urban stream
sampled had concentrations of
insecticides that exceeded at least
one guideline, and most had Fish kill due to pesticide spray
concentrations that exceeded a
guideline in 10% to 40% of samples collected study. 36 Of the target herbicides in the USGS study,
throughout the year. 30 For herbicides, the study only 33% had an established ALC, and for the
found a seasonal pulse of elevated concentrations target insecticides, only 47% had an established
of pesticides following applications.31 Insecticides ALC. Of the pesticides that have an ALC, the
were found to persist above ALC for longer USGS study found that concentrations of one or
periods of time in both urban and agricultural sites.32 more compounds exceeded an ALC value in at
least one sample from 68% of the agricultural
sites, 91% of the urban sites, and 40% of the
integrator sites (mixed land use sites). At four of
these sites, six to eight compounds were
detected at concentrations greater than their ALC.

Photo courtesy of USFWS

6
 [PESTICIDES and AQUATIC LIFE CRITERIA]

The herbicides triallate, trifluralin, metolachlor, Several factors contribute to uncertainty regarding
atrazine, and cyanazine were all found in the potential effects of the presence of pesticides
levels exceeding their ALC. The ALC for in our waters, and likely indicate the impacts of
atrazine and cyanazine were exceeded more pesticides are much greater than the EPA’s ALC
frequently than the other target compounds. For would lead one to believe: (1) ALC do not address
the nine target insecticides that have an chronic exposure to pesticide amalgamations or
established ALC (carbofuran, dieldrin, a-HCH, mixtures, failing to take into account possible
lindane, parathion, azinphos-methyl, chlorpyrifos, additive or synergistic effects of more than
diazinon, and malathion), the study found that one pesticide or combinations of pesticides,
all of their criteria values were exceeded. much less pesticide transformation products; (2)
ALC do not address the prevalence or toxicity
of pesticide breakdown products; (3) ALC do
not address the strong seasonality of
concentration patterns (resulting in repeated
pulses of high concentrations); (4) ALC do not
evaluate some types of biological effects (e.g.
endocrine disruption); and, as noted, (5) the
EPA has established few ALC for the thousands
of registered pesticides. It can be seen from
these factors, acknowledged by the USGS
Dunlin, a migratory shorebird, but ignored by the EPA, that sole reliance
killed by exposure to pesticides
on whether an EPA-established ALC is
exceeded as an indicator of whether species
Despite the fact that aquatic life criteria are more may or may not be adversely affected would
commonly observed in the breach and, even be an exceedingly thin blanket of protection.
more common than that, in their complete absence
in the case of most pesticides, ALC most The USGS also reported that several pesticide
likely underestimate the impact to aquatic degradation products were commonly detected.
organisms. As such, the assessment of various These substances were found at higher levels and
pesticides’ impacts must regard occurrences can persist much longer than the parent
of excess ALC levels as an almost certain compounds. 37 For example, total herbicide
indication of severe deleterious effects. breakdown products were frequently found at more
than ten times the concentration of the parent
compounds over a two-year period. 38 Failure
to incorporate this pertinent fact into an analysis
of pesticide impacts on aquatic biota would
erroneously raise the acceptable concentrations of
pesticides for aquatic biota in our surface waters.

Photo by Ted Below

7
 [PESTICIDES and AQUATIC LIFE CRITERIA]

The mere fact that ALC do not address the About 15% of all stream samples
cumulative effects of the presence of multiple contained more than ten pesticides. With all
pesticides is enough to indicate that the recorded ALC exceedences, it is clear that
any determination of no adverse effects on organophosphates, carbamates, and triazines
aquatic biota, based solely on ALC exceedences, pose significant threats to aquatic species.
would be inadequate. The USGS reported
that the presence of multiple pesticides with With such a pervasive presence of multiple
concentrations greater than their ALC was pesticides, any determination of effects made on a
“widespread,” occurring at 29 sites. On average, single pesticide basis will clearly fall short of
about 20 of the target compounds were recognizing the real impact the pesticide is having,
detected at each site regardless of land-use in combination with other pesticides, on aquatic
setting and basin size, and an average of six listed species. The EPA does not test pesticides in
to seven of the target compounds
were detected in each
individual sample. The USGS
also noted that pesticides almost
always occur as mixtures. 3 9

For example, in the San Joaquin

River and the Willamette River
basins, concentrations of two or
more insecticides often exceeded
criteria values in the same sample
or during the same period. In
Oregon, concentrations of several
insecticides, including azinphos-
methyl, carbofuran, chlorpyrifos,
diazinon, and malathion, as well
as the herbicide atrazine, were San Joaquin River National Wildlife Refuge, California
higher than or near criteria values
at various times, often in the same samples. combination with other chemicals, although their
The presence of multiple pesticides can be found synergistic effects (the simultaneous action of
in urban streams as well. About 80% of separate pesticides which, together, have greater
samples from urban and mixed land use total effect than the sum of their individual effects)
streams contained more than four pesticides. may be amplified by as much as 1,000 times.

Photo courtesy of USFWS

8
 [PESTICIDES and AQUATIC LIFE CRITERIA]

For example, in April 1996 researchers Combinations of two or three pesticides, which are
at the Duke University Medical Center and the commonly found in the environment at low levels,
Texas Southwestern Medical School studying can be up to 1,600 times more powerful in their
Gulf War Syndrome in veterans reported in the impact on hormones than any of the pesticides
Journal of Toxicology and Environmental Health individually. Some chemicals, which individually
that the simultaneous exposure to topical do not disrupt hormones, greatly magnify the
insecticides (DEET and permethrin) and ability of other chemicals to disrupt hormones,
pyrido-stigmine bromide, a drug taken which is the case with the chemical chlordane.
prophylactically to counteract toxic gas warfare The Tulane study focused on endosulfan,
agents, causes nervous system damage in chlordane, oxaphene and dieldrin, all of
chickens and produces symptoms similar which impact a gene making estrogen in
to many of those of Gulf War veterans. animals. Estrogen controls the formation and
development of female organs and is strongly
associated with both breast cancer and
Researchers at Tulane University in June 1996
deformity of male sex organs. This research
proved that hormone-disrupting chemicals known
should prompt the EPA to no longer
to cause mild effects produce significantly dramatic
base ALC and regulations on studies of
hormonal effects when used in combination.4 0
individual chemicals and their individual
effects, but rather to regulate combinations
of chemicals in order
to assure appropriate
levels for public
safety and protection
of aquatic species.

California red-legged frog

Photo by Joyce Gross

9
 BIOLOGICAL EFFECTS OF PESTICIDES

Endocrine Disruption, Sexual Deformities

and other Reproductive Anomalies

Endocrine disruptors are synthetic chemicals Endocrine disruption can wreak particularly acute
that mimic natural hormones, disrupting natural havoc during critical developmental stages of an
processes by sending false messages, blocking organism’s life.42 Offspring of those affected by
real messages, preventing synthesis of endocrine disruptors may also suffer from lifelong
the body’s own hormones, and accelerating the health and reproductive abnormalities, including
breakdown and excretion of hormones. reduced fertility, altered sexual behavior, lowered
Endocrine disruption affects how an organism immunity, and cancer. 43 Over 60% of all
develops and functions. Reproductive disorders, agricultural herbicides applied in the United States
(measured by volume) have the potential to disrupt
endocrine and/or reproductive systems of humans
and wildlife, as numerous studies document.4 4

For example, red-spotted newts (Notopthalmus

viridescens) exposed in a series of experiments to
minute quantities of endosulfan, a commonly-used
pesticide, lost reproductive capability. 45 The study
noted that endosulfan disrupted the development
of glands that synthesize a pheromone used in
female communication, resulting in lowered mating
success. Especially worrisome, the study revealed
an impact at just five parts per billion (ppb), the
lowest concentration measured in the study and
well within the range of endosulfan contamination
Pesticides in a retail store
levels regularly encountered in our nation’s
waterways. The EPA’s recommendation for
immune system dysfunction, thyroid acceptable concentrations of endosulfan in surface
disorders, types of cancer, birth defects waters is 74 ppb, almost fifteen times higher than
and neurological effects have all been the level found to result in noticeable reproductive
linked to endocrine disruption. Several impacts. This study also identified a new
organophosphate and carbamate pesticides mechanism by which low-level contamination
are recognized as endocrine disruptors. 4 1 can cause adverse effects in wildlife populations
– interference with chemical information transfer.

10
 [BIOLOGICAL EFFECTS OF PESTICIDES]

Another study suggests that a new and growing The study noted that the pervasive nature of
class of herbicides (acetolactate synthase or atrazine at levels that can disrupt sexual
ALS herbicides) can affect non-target plants and development puts aquatic ecosystems at grave risk.
microorganisms at levels so low that they cannot The EPA’s newly drafted criterion for atrazine for
even be detected. 46 Still another recent study by the protection of aquatic life is 12 ppb. However,
the National Academy of Sciences found that exposure levels as low as 0.1 ppb result in frog
amphibians are likely to be far more sensitive to hermaphrodites. Since initial effects may go

In a recent University of California study, the herbicide atrazine

was found to disrupt sexual development of frogs at concentrations
30 times lower than levels allowed by the EPA.

pesticides in the natural world than traditional unnoticed by researchers because they are all
laboratory tests used to establish regulatory internal, exposures at even lower levels may be
standards would indicate.47 The study found that causing harm. Thus, “exposed populations could
low contamination levels of decline or go extinct without any recognition of
carbaryl cause significant mortality due to the the developmental effects on individuals.” 4 9
length of exposure. Long-term exposure to low
levels of carbaryl in combination with added
biological stressors, such as the presence of
predators, dramatically increased mortality.
The study suggests that the current regulatory
schemata rely on science that dramatically
underestimates the impacts of many pesticides.

In a recent University of California study, the

herbicide atrazine was found to disrupt the
sexual development of frogs at concentrations Tadpole deformities caused by pesticides
30 times lower than levels allowed by the
EPA. 48 Atrazine is the most commonly used The impact of pesticides on frogs also was analyzed
herbicide in the United States. This study exposed in a recent Canadian study. 50 The study found
frogs to low levels of atrazine, levels often found that frogs given trace amounts of DDT and
in the environment. Even at these “low” exposures, other pesticides experience a near-total collapse
male frogs’ masculine characteristics were in their immune systems. The researchers
prevented from fully forming, while in some cases, exposed northern leopard frogs (Rana pipiens)
male frogs developed eggs in their testes to small doses of DDT, dieldrin, or malathion.
(hermaphroditism). The impacts of these The study found that it took frogs 20 weeks
deformities are surely exacerbated in the natural of living in a pesticide-free environment for
environment because the highest atrazine levels their immune systems to return to normal.
coincide with the amphibian breeding season.

11
 [BIOLOGICAL EFFECTS OF PESTICIDES]

In a study focusing on the effect of methoxychlor, In yet another study, dieldrin reduced the number of
a substitute for DDT, scientists found that male water fleas (Galeata mendotae). 54 Since
its presence in pregnant mice changed aquatic arthropods serve as a food source for fish
the structure of the male offspring’s prostrate.51 and many other life forms, this study has
This study also utilized doses regularly implications for the entire chain of aquatic life.
encountered in non-laboratory settings.

A study on the impacts of pesticides on the expected sex ratio of

turtle eggs found that the sex ratio was altered by pesticides.

Endocrine disruptors have been found An in-situ (in the field) study of Northern leopard
to affect sexual development of salmon as well. 52 frogs and green frogs from eight breeding sites, four
Investigating the troubling phenomenon of which were situated in apple orchards, assessed
of sexual reversal in salmonids, this study found the impacts of pesticides on the reproductive system. 55
that the 84% of phenotypic females testing
positive for the male genetic marker (or more
plainly put, the feminization of developing
males) may be attributable to endocrine
disrupting compounds such as pesticides.

A study on the impacts of pesticides on the

expected sex ratio of turtle eggs found that the
sex ratio was altered by the pesticides
trans-nonachlor and chlordane.53 Specifically,
the study found that chlordane suppressed Western painted turtle
testosterone levels in hatchling males and
progesterone levels in hatchling females, Embryos and larvae were subjected to in-situ and
indicating that chlordane’s impact on sexual ambient pond water (laboratory) assays and to toxicity
ratio results from anti-androgenic activity. tests of pesticides used in orchards. The in-situ
Trans-nonachlor functions as an estrogen mimic, embryos and larvae suffered high mortality at
while chlordane suppressed testosterone some of the orchard sites, while high hatching
levels but not progesterone levels. The study success was found in the reference sites. The
concluded that different hormone disrupting common pesticide diazinon and the formulations
compounds can achieve similar end results via Dithane DG, Gunthion 50WP, and Thiodan 50WP,
seemingly unrelated biochemical mechanisms. all of which are known to cause mortality,
deformities, and/or growth inhibition in embryos
and tadpoles, were detected at the in-situ sites.

Photo courtesy of USFWS

12
 [BIOLOGICAL EFFECTS OF PESTICIDES]

Another study investigating hormone disruption A delay in puberty and reduction in the fertility of
in amphibians found that exposure to the rats was found as a result of exposure to the
breakdown products of methoprene “dramatically pesticide methoxychlor. 57 The same researchers
interfere with normal amphibian development.”5 6 documented anti-androgenic effects of other
Laboratory experiments with African clawed commonly used pesticides. The study found that
frogs (Xenopus laevis) showed that the exposure to these pesticides produced diverse
common pesticide S-methoprene itself posed little reproductive malformations in male rats, including
direct risks to toads at levels commonly undescended testes, birth defects in the urinary
encountered in the environment. However, tract opening, vaginal pouches and permanent
when toads were exposed to methoprene’s nipples. The study also documented reproductive
breakdown products, caused by its reaction with effects from exposure of low-levels of the fungicide
sunlight, water and microorganisms, normal vinclozilin, raising concern that some of the
amphibian development was severely disrupted. anti-androgen effects may have no threshold -
that they may be initiated through the slightest
increase in anti-androgenic pesticides.

In another study, the cumulative effects of multiple

pesticides were analyzed to determine if
synergistic effects were taking place despite
innocuous responses to each chemical in isolation. 58
The study exposed rodents to concentrations
of atrazine, aldicarb and nitrate at levels these
common pesticides are actually found in the
environment. Although no effects were noted to
rodents exposed to a single chemical, those
California tiger salamanders are particularly subjected to multiple contaminants were found to
susceptible to environmental contaminants. suffer endocrine, immune and behavioral changes.

This study also demonstrates that pesticide

breakdown products must be considered to
present a realistic picture of the risk to natural
populations. In some cases, important effects may
only be evident once the experiment focuses on
the breakdown products of the active ingredient.
But the EPA (as it readily acknowledges) only
examines a parent compound’s impacts
without investigating the deleterious impacts
the breakdown products may have on wildlife –
whether directly or through the myriad
tertiary impacts by which one species’ decline
precipitates further ecological degradation.

Photo by William Flaxington

13
 [BIOLOGICAL EFFECTS OF PESTICIDES]

Experts from a wide variety of disciplines are present in tissue at concentrations

convened in 1998 to jointly review evidence and previously not possible to measure with
assess hazards of endocrine disruption. 59 These conventional analytical methods, but at
meetings produced a series of “consensus concentrations that are biologically active.
statements” detailing their conclusions about the • Thyroid hormones are essential for
state of science regarding endocrine disruption. normal brain function throughout life.
Interference with thyroid hormone
The experts were certain of the following: function during development leads
to abnormalities in brain and
• Endocrine-disrupting chemicals can behavioral development. Similarly,
undermine neurological and behavioral exposure to man-made chemicals during
development and subsequent potential early development can impair motor
of individuals exposed in the womb or, in function, spatial perception, learning,
fish, amphibians, reptiles, and birds, memory, auditory development,
the egg. Widespread loss of this nature can fine motor coordination, balance, and
change the character of human societies attentional processes. In severe
or destabilize wildlife populations. cases, mental retardation may result.
• The developing brain exhibits specific
and often narrow windows during which
exposure to endocrine disruptors can
produce permanent changes in its structure
and function. A variety of chemical
challenges in humans and animals early in
life can lead to profound and
irreversible abnormalities in brain
Crop duster spraying pesticides
development at exposure levels that do not
produce permanent effects in adults.
• The seriousness of the problem is • Man-made chemicals that interfere with
exacerbated by the extremely low levels sex hormones have the potential to
of hormones produced naturally by disturb normal sexual development.
the endocrine system and needed to Wildlife studies of gulls, terns, fishes,
modulate and induce appropriate whales, porpoises, alligators, and
responses. In contrast, many endocrine- turtles link environmental contaminants
disrupting contaminants, even if less with disturbances in sex hormone
potent than the natural products, are production and/or action. These effects
present in living tissue at concentrations have been associated with pesticides.
millions of times higher than the • Commonalities across species in the
natural hormones. Wildlife, laboratory hormonal mechanisms controlling brain
animals, and humans exhibit adverse development and function mean that
health effects at contemporary adverse effects observed in wildlife and in
environmental concentrations of laboratory animals may also occur in
man-made chemicals that act as humans, although specific effects may
endocrine disruptors. New technology has differ from species to species.
revealed that some man-made chemicals
14
 [BIOLOGICAL EFFECTS OF PESTICIDES]

The scientists also expressed concern over the Exposures to pesticides at current environmental
following factors: levels have demonstrable adverse effects,
even though the study of endocrine disruption
• There may not be definable thresholds and developmental and behavioral effects
for responses to endocrine disruptors. (and their interaction with the environment) is
In addition, for naturally occurring in its early stages. Endocrine disruption is
hormones, too much can be as severe a not limited to interference with natural estrogen
problem as too little. Consequently, levels; it includes androgen blockers, progesterone
traditional dose-response curves for blockers, compounds that interfere with the
toxicity do not necessarily apply to thyroid, and others. The current information
the effects of endocrine disruptors. available on pesticides and their endocrine-
• Many pesticides affect thyroid disrupting effects raises significant and grave
function and therefore, may cause concerns regarding their chronic cumulative
neurological abnormalities. impact on humans and other animals, including
imperiled species supposed to be protected by law.

The endangered Atlantic salt marsh snake

may be threatened by pesticides.
(Listed in table on p. 44)

Photo courtesy of USFWS

15
 OTHER WILDLIFE IMPACTS

Beyond impacting wildlife through endocrine for the majority of bird kills in California,
and/or reproductive disruption, pesticides affecting songbirds, waterfowl, and raptors.
may adversely affect wildlife through Shockingly, as many as seventeen birds die
direct toxicity or indirectly by modifying for every five acres treated with carbofuran.
the availability of food or adequate habitat.

The American Bird Conservancy estimates that 672 million birds are
directly exposed to pesticides from agricultural uses alone each year
and that more than 67 million birds will die from the exposure.

Studying the impact of pesticides used for corn, Tragic consequences for birds and fish occur from
researchers with the North Carolina the legal application of pesticides each year. The
Cooperative Extension Service noted both direct American Bird Conservancy estimates that
and indirect effects. 60 Quail suffered direct 672 million birds are directly exposed to pesticides
impacts. A single aerial insecticide application from agricultural uses alone each year and that
sickened more than 30% of the quail tested. Once more than 67 million birds will die from the
sick, wild birds may neglect their young, exposure.62 Carbamate and organophosphate
abandon their nests, and become more (OP) pesticides have been linked with many
susceptible to predators and disease. Indirect bird kills (termed “incidents” by the EPA).
effects on birds included reduction in insect For example, carbofuran, a carbamate, is estimated
and plant food as a result of insecticides to kill one to two million birds annually in the U.S. 63
and herbicides, as well as reduction in needed Many of these organophosphates and
vegetative cover. Of course, many of carbamates have also resulted in massive fish kills.
these pesticides – such as carbofuran, chlorpyrifos,
ethoprop, methomyl, methyl parathion,
and terbufos – are highly toxic to birds.

In 1999, the Pesticide Action Network of North

America released a report, Disrupting the Balance:
Ecological Impacts of Pesticides in California,
which documented the impact of organophosphate
and carbamate pesticides on wildlife.61 The report
found that multiple pesticides are often found in
California waters and sediments at concentrations
that exceed levels lethal to zooplankton,
the primary food source for young fish.
The report also observed the routine occurrence of
toxic pulses of diazinon and chlorpyrifos in
California streams during critical stages in fish
development. Additionally, the report documents
that carbofuran and diazinon are responsible Bald Eagles at Reelfoot
National Wildlife Refuge, Tennessee

Photo courtesy of USFWS 16

 [OTHER WILDLIFE IMPACTS]

A stark, but unfortunately not unique, example was roles. It is unknown what tertiary impacts could
seen in Louisiana in 1991 where more than one result from the disappearance of these plants and
million fish, and a multitude of other wildlife animals. An unknown fraction of threatened and
including alligators, turtles, snakes, and birds, endangered plant species could be adversely
were killed during six legal azinphos-methyl affected or jeopardized by pesticide-caused
applications.64 Hundreds of these “incidents” occur reductions in their pollinators. Plants that are
annually, resulting in untold mortalities insect-pollinated are also potentially at risk,
and unknown indirect impacts to wildlife. because most insecticides are broad-spectrum.

According to the U.S. Department of Agriculture, we are facing an

“impending pollinator crisis,” in which both wild and managed
pollinators are disappearing at alarming rates.

The impact of pesticides on pollinators also raises Bees, including native solitary bees and
significant environmental concern. According to bumblebees, which are effective pollinators, are
the U.S. Department of Agriculture, we are facing known to be highly sensitive to many pesticides.
an “impending pollinator crisis,” in which both wild Bees are affected by pesticides, insecticides and
and managed pollinators are disappearing at herbicides used for agriculture, forestry and
alarming rates.65 This crisis commercial/urban purposes.
has been attributed, in part, Bees can be directly exposed
to pesticides. 66 Federally to pesticides through
endangered or threatened contamination while seeking
pollinators which may pollen in blooms, as well
be adversely affected by as through spray drift.
pesticides include the Contaminated bees may
Sanborn’s lesser long-nosed also introduce toxins into
bat, Mexican or big long- their hives, exposing bee
nosed bat, Kirtland’s warbler, larvae as well. Due to their
Golden-cheeked warbler, low fecundity rate, it may
five Hawaiian honeycreepers take three to four years for
(Nukupu’u, Hawaii Akepa, bumble bee populations to
Maui Akepa, Po’ouli, Swallowtail butterfly and bee on a thistle return to pre-pesticide
and O’u), Kauai Oo, Palila, application levels. Many
Maui parrotbill, Laysan finch, Niho finch, and oligolectic bees (narrowly specialized to visit
Hawaiian crow. 67 Although pesticides have been one or a few species of flower) have small
identified as a threat to these listed species, populations but are ‘below the radar screen’ of
the EPA has made no effort to change this. the federal listing process, and could be rendered
extinct without public awareness. Bumblebee
Further decline in these imperiled pollinator species populations are in very bad shape in cotton-growing
jeopardizes reproduction of specific plants that areas, where they are exposed to repeated
have evolved to take advantage of their unique applications of insecticides while foraging. 6 8

Photo courtesy of USFWS 17

 PESTICIDE USE THREATENS THE
SURVIVAL OF ENDANGERED SPECIES

Desert pupfish

Pesticide use is rampant in the United States. Investigations into the potential consequences lag
far behind. It is clear that pesticides are finding their way into ecosystems throughout the
nation and that many wildlife species are exposed to them in numerous ways. The impact to
species on the verge of extinction is sometimes difficult to ascertain. Yet, it is not difficult to
infer that pesticide presence at toxic levels in areas used by species listed under the Endangered
Species Act as threatened or endangered, potentially threatens their survival.

ENDANGERED SPECIES WHICH MAY BE AFFECTED BY PESTICIDES

There are currently 1,265 federally endangered or Unfortunately, the EPA has not taken
threatened species across the United States. 69 Pages this acknowledgment seriously and for many
19 through 44 detail some of the threatened and of these species has done nothing to limit or
endangered species that the U.S. Fish and Wildlife otherwise mitigate pesticide use in its process of
Service (FWS), National Marine Fisheries Service registering pesticides. By failing to consult
(NMFS), and/or the EPA acknowledge may with the FWS and NMFS, which have the
be affected by pesticides. Unfortunately, this is statutory authority and responsibility to cooperate
only a sampling of the many species that may with other agencies in assessing impacts of
be affected by pervasive use of pesticides across agency actions and authority on threatened
the country. It is evident from examination and endangered species, the EPA neglects
of Federal Register notices in which the FWS to comply with federal law or even develop
and NMFS list species, that the agenciesrecognize the information base for making the wise
that pesticides pose a threat to many listed fish, and cautious decisions the public e x p e c t s .
insects, aquatic invertebrates, mollusks,
crustaceans, mammals, birds, amphibians,
reptiles, and plants throughout the United States.

Photo by John Rinne

18
 PACIFIC REGION SPECIES

SAN JOAQUIN KIT FOX

Location: CA
The San Joaquin kit fox (Vulpes macrotis mutica), BUENA VISTA LAKE SHREW
the smallest member of the dog family in North Location: CA
America, inhabits grasslands in the San Joaquin
The tiny Buena Vista Lake shrew (Sorex ornatus
Valley of California. The area’s intensive agricultural
relictus) lives in the marshes and wetlands of the
use exposes foxes to a wide array of pesticides and
southern San Joaquin Valley and feeds primarily
rodenticides. The FWS has determined that the use
on insects. According to the FWS, the Buena Vista
of pesticides and rodenticides threatens the Lake shrew may be “directly exposed to lethal and
endangered San Joaquin kit fox. 70 Hundreds of kit
sublethal concentrations of pesticides from drift or
foxes were destroyed historically by strychnine
direct spraying of crops, canals and ditch banks,
poisoned bait put out for coyote control. Rodent
wetland or riparian edges, and roadsides where
poisoning programs that eliminated ground
shrews might exist,” 71 due to the close proximity
squirrels reduced the kit fox prey base. of shrew habitat to an otherwise agriculturally
dominated landscape. The FWS also noted that
Although the federal government began controlling
“[r]educed reproduction in Buena Vista Lake
use of rodenticides in 1972 and prohibited
Shrews could be directly caused by pesticides
above-ground application of strychnine within
through grooming [mammals exposed to pesticides
the range of the kit fox in 1988, two San Joaquin may ingest them through grooming as they try to
kit foxes died in 1992 on federal lands as a
clean their fur], and secondarily from feeding on
result of secondary poisoning from other
contaminated insects.”72 The listing notice for the
rodenticides. The EPA has recorded several
shrew acknowledged the endocrine-disrupting
instances where San Joaquin kit foxes have been
effects of carbamates and organophosphates, noting
killed recently by rat poison containing that “laboratory experiments have shown that
brodifacoum, a deadly rodenticide widely available
behavioral activities such as rearing, exploring for
to the public as an active ingredient in rat and
food, and sniffing can be depressed for up to six
mouse baits such as Talon, Havoc, and D-Con.
hours in the common shrew from
environmental and dietary exposure to
sublethal doses of a widely used
insecticide, dimethoate.” Such depression
in behavioral activities could make the
shrews more vulnerable to predation and
starvation. Furthermore, shrews may have
higher concentrations of pesticides in their
system than would normally be available
because they may feed heavily on toxic
arthropods after pesticide applications.
Finally, the FWS notes that Fresno,
Kern, and Tulare counties, where
the shrew lives, are the three
highest users of pesticides in California.
San Joaquin kit fox pups at night

Photo by Rawge at www.rawge.com 19

 [PACIFIC REGION]

HAWAIIAN HOARY BAT CALIFORNIA TIGER SALAMANDER

Location: HI Location: CA
Known locally as the ‘ope’ape’a, the Hawaiian
Hoary bat (Lasirus cinereus semotus) is the only
existing native terrestrial mammal known
to occur in the Hawaiian archipelago. The
hoary bat is today found on Hawai’i, Maui, O’ahu,
Kaua’i and Moloka’i with unconfirmed
observations from Kaho’olawe. The FWS notes
that pesticides may indirectly impact the bat.7 3
California tiger salamander

SOUTHWESTERN WILLOW FLYCATCHER The California tiger salamander (Ambystoma

Location: AZ, CA, CO, NV, NM, TX, UT californiense) is a colorful amphibian that breeds
in seasonal ponds or vernal pools and is particularly
The southwestern willow flycatcher (Empidonax susceptible to environmental contaminants. The
traillii extimus) is a small bird that catches insects FWS has noted that pesticides may affect both the
within and above dense riparian vegetation Santa Barbara County and the Sonoma County
along rivers, streams, and other wetlands. The populations of the California tiger salamander. 7 5
FWS noted that the proximity of Southwestern The State of California and USGS conducted
willow flycatcher habitat to agricultural areas studies in Santa Barbara County sampling well and
indicates a potential threat from pesticides. 7 4 ground water at 156 locations throughout the range
The FWS concluded that pesticides may of the tiger salamander. More than 2.2 million
potentially affect the flycatcher through direct pounds of agricultural chemicals were used in 1994
toxicity or effects on their insect food base. alone on the five major crop types grown on or
near tiger salamander sites in Santa Barbara County.
More than 3.1 million pounds were applied in
2000 in Sonoma County. Among those chemicals
thought to be harmful to tiger salamanders were
chlorpyrifos, acephate, fenamiphos, malathion,
methyl bromide, metam sodium, azinphos-methyl,
maneb, and endosulfan. However, the FWS noted
that the identified pesticides provide only a sample
of the actual and potential threats. The FWS
highlighted the presence of certain pesticides, such
as chlorpyrifos, because amphibians, with their
permeable skins, readily absorb the chemical –
especially when migrating through recently
treated fields. The FWS also noted that the use
of azinphos-methyl in the vicinity of the
tiger salamander could affect recruitment
Southwestern willow flycatcher and survival directly, or affect the food supply.

Flycatcher photo by Suzanne Langridge,USGS

Salamander photo by Gerald and Buff Corsi 20
 [PACIFIC REGION]

CALIFORNIA TIGER SALAMANDER, cont.

Finally, the FWS cited studies reporting severe Pesticides, often insoluble in water, tend to
toxicity to amphibians from exposure to concentrate on the surface, a place where mountain
endosulfan, including extensive paralysis, delayed yellow-legged frogs move through often,
metamorphosis and high death rates. The FWS heightening their risk. The species’ unique
noted that “[I]t is apparent that endosulfan is overwintering behavior also makes it particularly
extremely toxic at low concentrations to vulnerable to pollutants. Both adults and tadpoles
amphibians.” The FWS concluded that five of the overwinter on or in the sediments of lakes, ponds,
six metapopulations of California tiger salamanders and slow moving rivers. These sediments become
breeding sites in Santa Barbara County “may be repositories of concentrated organochlorides
directly or indirectly affected by toxic agricultural and other pollutants. Mountain yellow-legged
chemical contaminants because there is intensive frogs can be repeatedly exposed to these toxic
agriculture within their drainage basins,” and that sediments for up to nine months each year.
“all but one of the remaining documented
salamander breeding sitesin Sonoma County may
be directly or indirectly affected by toxic
landscaping chemicals.” Additionally, the FWS
stated that “[e]ven if toxic or detectable amounts
of pesticides are not found in the breeding ponds
or groundwater, salamanders may still be directly
affected, particularly when chemicals are applied
during the migration and dispersal seasons.”7 6

MOUNTAIN YELLOW-LEGGED FROG

Location: CA
Mountain yellow-legged frog
The mountain yellow-legged frog (Rana muscosa)
is thought to be declining in part due to pesticide Of great concern is the possibility that pesticide
drift from the Central Valley into the high Sierra pollutants act as environmental stressors, rendering
lakes and streams that harbor the species. The FWS mountain yellow-legged frogs more susceptible
has noted that airborne contaminants may affect to aquatic pathogens such as red-leg disease
the Southern California population of the mountain or the chytrid fungus. These aquatic pathogens
yellow-legged frog.77 Airborne pesticides from historically have been considered opportunistic,
the west side of the Sierra from Central Valley infecting only injured or immuno-suppressed
agriculture are thought to be at least partially amphibians, but not healthy individuals.
responsible for the decline of mountain Recent research indicates that sub-lethal levels
yellow-legged frogs in the Sierra Nevada.78 Since of organophosphate pesticides in combination
mountain yellow-legged frogs spend much of with normal background levels of red-leg
their life cycle in water, moving through the bacteria may result in fatal infections to
interface of water and air, and respire through their amphibians.79 More recent data from the Sierra
skin, they are at high risk from chemical pollutants. Nevada strongly implicates pesticide drift as a
factor for frog declines in general and also
specifically for yellow-legged frog declines.8 0

Photo by William Flaxington

21
 [PACIFIC REGION]

CALIFORNIA RED-LEGGED FROG ARROYO TOAD

Location: CA Location: CA
The California red-legged frog (Rana aurora The arroyo toad (Bufo californicus) is restricted to
draytonii) is California’s largest native frog, and is shallow gravel pools adjacent to sandy
exposed to pesticides in the wetlands, ponds, and terraces in rivers in southern California. The
streams in inhabits. The species has disappeared FWS noted that pesticide applications as well
from more than 70% of its historic range in as other long-term factors likely rendered
California. The FWS recognized the threat of habitat for the arroyo toad in agricultural
pesticides in its Draft Recovery Plan for the fields a “population sink” meaning death rates
Red-Legged Frog, noting that agricultural exceed birth rates, resulting in a local
practices are introducing pesticides into the population incapable of maintaining itself
red-legged frog’s range. In the Final Recovery Plan without immigration of replacement toads
for the California Red-Legged Frog, the FWS from other habitats.83 The FWS went on to state
concluded that exposure to wind-borne that the use of pesticides and herbicides
agrochemicals may be an important factor in the within or adjacent to arroyo toad habitat
decline of the species.81 FWS noted a strong may cause adverse impacts to the species.
relationship between increasing levels of upwind
agriculture and the percentage of extirpated
California red-legged frog sites; in the Sierra
Nevada-Central Valley region the percentage
of upwind land in agriculture for sites where
the species has disappeared was 6.5 times
greater than for sites where the species still lives.

The FWS noted that pesticide contamination may

result in deformities, abnormal immune
system functions, diseases, injury, and death.
Ranid tadpoles are likely to be killed or
paralyzed by some herbicides such as triclopyr,
and insecticides such as fenitrothion. 82 The Arroyo toad
FWS listed 150 pesticides or herbicides used
within the same one square mile section as
known California red-legged frog sites or their
habitat. The FWS pointed to 25 chemicals of
particular concern, including acephate,
azinphos-methyl, carbaryl, chlorpyrifos,
diazinon, difocol, disulfoton, endosulfan,
esfenvalerate, fenamiphos, glyphosate, malathion,
mancozeb, methamidophos, methoprene,
naled, paraquat, permethrin, phosmet,
pyrethrins, strychnine, triclopyr, and trifluralin.

Photo courtesy of SCV History in Pictures

22
 [PACIFIC REGION]

BLUNT-NOSED LEOPARD LIZARD GIANT GARTER SNAKE

Location: CA Location: CA

The giant garter snake (Thamnophis gigas) is one

of the largest garter snakes, endemic to wetlands
in the Sacramento and San Joaquin Valleys
of California. The FWS has acknowledged that
pesticides could adversely affect giant garter
snake populations by degrading water quality
and reducing prey populations. Heavy use of
pesticides is suspected as a contributing factor
in the decline of this once abundant species.8 5
Blunt-nosed leopard lizard

The blunt-nosed leopard lizard (Gambelia silus) is

a large, striped lizard found in grasslands and
alkali sinks in the San Joaquin Valley. The
lizard utilizes small mammal burrows and forages
on insects. FWS has noted that use of pesticides
may directly and indirectly affect blunt-nosed
leopard lizards. The insecticide malathion has been
used since 1969 to control the beet leafhopper
and its use may reduce insect prey populations.84
Aerial application of malathion may reduce
the availability of food for reproducing lizards
in the spring, and later for hatchlings when Giant garter snake
they should be storing fat to sustain themselves
during their first winter. The California Department
of Food and Agriculture treats areas on the
west side of the San Joaquin Valley with
malathion up to three times each year. Fumigants,
such as methyl bromide, are used to control
ground squirrels. Because leopard lizards
often inhabit ground squirrel burrows,
they may be inadvertently poisoned.

Garter snake photo courtesy of USFWS

Leopard lizard photo by John Sullivan/Ribbit Photography 23
 [PACIFIC REGION]

PACIFIC SALMON SPECIES

Location: CA, ID, OR, WA

Pacific salmon, including endangered and threat- documents that approved uses of at least 36
ened runs of coho salmon (Oncorhynchus kisutch), pesticides used in the Pacific Northwest are
chinook salmon (O. tshawytscha), sockeye salmon expected to have a negative impact on salmon.
(O. nerka), chum salmon (O. keta), and steelhead These include the organophosphate insecticides
trout (O. mykiss), depend on clean water during azinphos methyl, carbaryl, diazinon, and malathion;
the freshwater stages of their complex life cycles. and the herbicides 2,4-D, diuron, and trifluralin. 87
Many runs of Pacific salmon are threatened by Azinphos methyl has caused massive fish kills
pesticide pollution of rivers and streams within their throughout the U. S. 88 Studies show that exposure
range. The U. S. Geological Survey studied five to 2,4-D impairs trout swimming ability. 8 9
major river systems in Washington, Idaho, Oregon, Triluralin has been shown to cause bone
and California, states which contain most of the abnormalities.90 All of these pesticides are found
remaining range of anadromous fish outside of in harmful concentrations in Pacific northwest
Alaska, and found at least 35 pesticides in each waters within the range of listed salmon species.91
watershed. The USGS found sixteen pesticides in Diazinon has been found in northwest streams at
concentrations exceeding their ALC, threatening levels that reduce production of testosterone
salmonid growth, development, behavior, by male salmon, which may weaken the
and reproduction. Pesticides can also chances that salmon will successfully mate.9 2
impair swimming ability and avoidance
of predators, cause abnormal sexual
development, interfere with growth and
feeding, and disrupt the salmon’s
navigating abilities to return to its natal
stream to spawn. Pesticides can further
indirectly affect fish by changing the
aquatic environment, by reducing the
food supply, and by eliminating
vegetative cover used by young salmon.
Fishing and environmental groups recently
obtained a court order preventing the use
of more than 30 harmful pesticides
in no-spray buffers near salmon streams in
Pacific salmon drawing
California, Oregon, and Washington. Pesticides
have profound effects on Northwest salmon and
may be a significant factor in their decline. The
NMFS has noted that pesticides and herbicides also
contaminate numerous water bodies and destroy
aquatic life necessary for salmonid survival. 86 The
EPA itself acknowledged in pesticide registration

Drawing by Timothy Knepp,USFWS 24

 [PACIFIC REGION]

DELTA SMELT OHLONE TIGER BEETLE

Location: CA Location: CA

The delta smelt (Hypomesus transpacificus) is a The Ohlone tiger beetle (Cicindela ohlone) is a
nearly translucent steely-blue fish found only in brilliant green beetle found only on coastal prairie
the brackish waters of the Sacramento-San Joaquin terrace habitat in Santa Cruz County, California.
Delta estuary. The FWS Recovery Plan for The ESA listing designation for the species stated
the Sacramento/San Joaquin Delta Native that “pesticides could pose a threat to the Ohlone
Fishes noted that the estuary receives flushes tiger beetle.” 97 Specifically, the FWS noted
of high concentrations of agricultural pesticides, that the beetle could be killed from aerial drift or
such as carbofuran, chlorpyrifos, and diazinon. 93 runoff into Ohlone beetle habitat. The FWS
The California State Water Resources Control further stated that as development increases,
Board states that all the important water bodies in “negative impacts from pesticides may
the smelt’s range are impaired by one or more become more frequent,” and that although the
contaminants, commonly including pesticides significance of pesticide effects is unknown,
such as diazinon, chloropyrifos, malathion, “they are recognized as a substantial potential
chlordane, DDT and dieldrin. Recent research threat to the species.” The FWS concluded
indicates that toxicity of certain contaminants that along with other factors, pesticides “imperil
in smelt habitat is not constant but occurs the continued existence of this species.”
in episodes, often in runoff from rainstorms
following periods of use of the chemicals.
The FWS has noted that acutely toxic
pulses of pesticides move down the rivers
and through the estuary with “remarkable
persistence and relatively little dilution.” 9 4

Researchers report episodic toxicity in

winter associated with organophosphate pesticide
treatment of dormant orchards; carbofuran and
chlorpyrifos in the San Joaquin River and Delta in
spring, possibly associated with treatment of
alfalfa; rice pesticides in late spring and early
summer with release of rice field water; and a
Ohlone Tiger Beetle
variety of herbicides from irrigation tailwater
during the summer. 95 Peaks of numerous other
chemicals, including the herbicides trifluralin and
atrazine, have also been found. 96 It is unknown what
direct effect these toxins have on delta smelt, but
there is growing evidence that other fish species in
the Delta are suffering direct mortality or additional
stress from the presence of toxic substances. There
is also evidence that the plankton upon which the
smelt feed may be depleted by these highly
concentrated pulses of pesticides through the Delta.

Photo by Richard Arnold, Entomological Consulting Services

25
 [PACIFIC REGION]

SANTA ANA SUCKER

Location: CA

The Santa Ana sucker (Catostomus santaanae) is In designating critical habitat for the Bay checkerspot
designated as threatened in the Los Angeles River, San butterfly (Euphydryas editha bayensis), FWS noted that
Gabriel River, and Santa Ana River basins of application or drift of pesticides may affect its critical
California. The FWS noted that both point and habitat. 100 For the Carson wandering skipper
non-point source pollution (e.g. urban runoff) have (Pseudocopaeodes eunus obscurus), the FWS noted
significantly degraded the water quality in most of that pesticide drift from alfalfa fields into a
the native range of the Santa Ana sucker. 98 FWS also neighboring nectar sites could eliminate a large portion
noted that the use of pesticides on golf courses of its population. 101 The FWS identified the use of
frequently results in maximum contaminant level pesticides and biological control agents to control insect
exceedences for various pesticides. Consequently, pests, such as the gypsy moth, as a threat to the Fender’s
the Santa Ana sucker may be adversely affected blue butterfly (Icarica icarioides fenderi).102 The FWS
from pesticide runoff associated with urban uses noted that although the sensitivity of Fender’s blue
such as golf course and turf or lawn treatment. butterfly larvae to specific insecticides is not known,
the potential threat from the use of gypsy moth control
agents in Fender’s blue habitat should not be dismissed.
CALLIPPE SILVERSPOT BUTTERFLY , The FWS identified pesticide spraying as an activity
BEHREN’S SILVERSPOT BUTTERFLY that would likely be considered a violation of the ESA.
and
BAY CHECKERSPOTBUTTERFLY
Location: CA
CARSON WANDERING SKIPPER
Location: CA, NV
FENDER’S BLUE BUTTERFLY
Location: OR

The Callippe Silverspot butterfly (Speyeria callippe

callippe) is found at two sites on grasslands in the San
Francisco Bay Area and the Behren’s Silverspot
butterfly (S. zerene behrensii ) is found within
coastal terrace prairie at one site in southern Bay Checkerspot Butterfly
Mendocino County, California. According to the
FWS, the use of insecticides would threaten both
butterflies if use occurred in proximity to
occupied habitat.99 The FWS noted that silverspot
butterfly larvae are extremely sensitive to
pesticides and even the accumulation of runoff in the
soil after spraying has proven lethal to the larvae
of members of the genus Speyeria, the silverspots.

Photo by Dr. Richard Arnold, Entomological Consulting Services 26

 [PACIFIC REGION]

IDAHO SNAIL SPECIES VENTURA MARSH MILKVETCH

Location: ID and OTAY TARPLANT
Location: CA

Five rare Idaho freshwater snail species are

restricted to a few isolated free-flowing reaches
or spring alcove habitats in the middle Snake River.
Water contamination from pesticides has
been listed as a concern for the Idaho springsnail
(Fontelicella idahoensis), Utah valvata snail
(Valvata utahensis), Snake River physa snail
(Physa natricina), Banbury springs limpet (Lanx sp.),
and Bliss rapids snail (Taylorconcha serpenticola).103

KAUAI CAVE WOLF SPIDER and

KAUAI CAVE AMPHIPOD
Location: HI Otay Tarplant

The use of pesticides for golf courses was identified as A large number of Pacific coast plants are threatened
a threat to two Hawaiian cave species, the Kauai cave by herbicide and pesticide use. For example, the FWS
wolf spider (Adelocosa anops) and the Kauai cave noted that Ventura marsh milk-vetch (Astragalus
amphipod (Spelaeorchestia koloana).104 Golf courses pycnostachyus var. lanosissimus) and the Otay tarplant
exist on, or are proposed for, the land directly above (Deinandra conjugens) both have small fragmented
or adjacent to both populations of the spider and all ranges, making them especially vulnerable to
but one population of the amphipod. The FWS anthropogenic events such as nearby use of pesticides.105
identified at least 30 different pesticides that are used For the Ventura marsh milk-vetch, the FWS also noted
on golf courses in Hawaii. The FWS cited a study that future suburban and urban uses near the vetch’s
finding that predators, such as the Kauai cave wolf preserve can bring expected increases in uses of
spider, are generally more susceptible to insecticides herbicides and pesticides in proximity of the vetch
than the target pests. The FWS noted that chronic which could harm the milk-vetch directly, or alter the
effects, such as reduced fecundity, reduced pollinator or plant associations upon which it depends.
lifespan, slowed development rate, and impaired
mobility and feeding efficiency are all
associated with pesticides. Furthermore, the FWS
stated that pesticide use on residential property
also poses a “serious threat” to the species.

Photo courtesy of CalPhotos

27
 [PACIFIC REGION]

HOWELL’S SPECTACULAR THELYPODY ROUGH POPCORNFLOWER

Location: OR Location: OR

The FWS acknowledged that Howell’s spectacular

thelypody (Thelypodium howellii spectabilis)
is “particularly vulnerable to herbicide use”
as herbicides may impact pollinator
populations. 106 The likelihood of herbicide
use in Howell’s spectacular thelypody
habitat was supported by the known
invasion of noxious weeds into those habitats.

Rough Popcornflower

The FWS noted that pesticides and herbicides

have an indirect effect on rough popcornflower
(Plagiobothrys hirtus) because the plant relies
on pollinators to reproduce and these insect
pollinators are vulnerable to pesticides.107 The
FWS stated that pesticides have a direct effect on
the plant when sprayed in the spring
and summer by “reducing seed set, which
negatively affects populations of the species.”

Howell’s Spectacular Thelypody

Thelypody photo by Andrew Kratz

Popcornflower photo by Dr. Ivo Tosevski 28
 [PACIFIC REGION]

BAKER’S and YELLOW LARKSPUR SPALDING’S CATCHFLY

Location: CA Location: ID, MT, OR, WA

Baker’s larkspur (Delphinium bakeri), a perennial The Spalding’s catchfly (Silene spaldingii) is a
herb in the buttercup family, currently has one long-lived perennial herb whose grassland habitat
known population with about 35 individuals. The once was widespread in the region but has been
yellow larkspur (Delphinium luteum), is also highly reduced by more than 95 percent. Currently, there
endangered with only two known remaining are only 52 locations where the catchfly is found,
populations, with fewer than 50 individuals. containing a total of about 16,500 plants. The
FWS believes that pesticide applications in the range majority of remaining Spalding’s catchfly
of these plants are not likely to result in a violation populations are extremely small and isolated, often
of the ESA when such activity is conducted bordering agricultural fields or rangelands. The
in accordance with consultation under section 7 catchfly suffers from both direct and indirect
of the ESA.108 Unfortunately, the EPA has not impacts of pesticides. Reduced pollinator activity
consulted on the impacts of pesticides on these is associated with poor reproductive success,
endangered larkspurs so it is possible that pesticide particularly in small populations of the catchfly.
applications could result in harm to these species.

Agricultural fields do not provide suitable habitat

for pollinators of S. spaldingii, which requires
pollination by insects for maximum seed set and
population viability. Populations that occupy small
areas surrounded by land that does not support
bumblebee colonies (e.g. crop lands) are not likely
to persist over the long term. Beyond indirect
impacts of insecticides and herbicides on
pollinators, the catchfly may be directly affected
by herbicide applications in adjacent agricultural
fields.109 The FWS notes that the ESA consultation
process will address activities including herbicide
spraying, yet the EPA has never sought consultation
on pesticide impacts to the catchfly. 110

Baker’s larkspur

Photo by Doreeen Smith

29
 SOUTHWEST REGION SPECIES

CACTUS FERRUGINOUS PYGMY OWL BARTON SPRINGS SALAMANDER

Location: AZ Location: TX

The cactus ferruginous pygmy owl (Glaucidium The Barton Springs salamander (Eurycea sosorum)
brasilianum cactorum) is a small southwestern is a slender yellowish-cream color amphibian
raptor that nests in cavities in trees or in large only found in its namesake watershed, a
columnar cactus. Pesticides are considered a threat popular public swimming hole near Austin,
to the pygmy owl where it occurs in floodplains Texas. Barton Springs salamanders have been
that are now largely agricultural. 111 The FWS noted developing strange deformities and dying of
that more than 100 pesticides are used year-round bizarre maladies. Pesticides in Barton Springs
on agricultural crops throughout the lower were described by the FWS as a threat to the
Rio Grande Valley. Additionally, the FWS noted salamander because of amphibians’ recognized
that “[p]esticide contamination is described as sensitivity to contaminants. The FWS cited the
‘widespread’ throughout the inland waters of the exposure to certain cylcodienes (endosulfan,
lower Rio Grande Valley. The FWS concluded that endrin, toxaphene, and dieldrin) and
“[w]ithout appropriate precautions, these agents organophosphates (parathion, malathion, and
may potentially affect pygmy-owls through direct diazinon) as a threat to amphibians, noting that
toxicity or effects on their food base.” Despite the “since the salamander is fully aquatic, there is
acknowledged threat of pesticides, the EPA has not no possibility for escape from contamination.”114
consulted with the FWS on the impact to the The agency not only cited the threat of direct
pygmy owl of its action to register pesticides. exposure but also indirect effects of pesticides on
the quality and quantity of amphibian food.

In 2002, the FWS suggested that the EPA enter into

formal consultation regarding the impact of atrazine
on the Barton Springs salamander. 115 The FWS also
cited concern about other pesticides – specifically,
diazinon, atrazine, prometon, metolachlor, carbaryl,
and simazine – due to findings from the USGS
which found all of these pesticides in the Barton
Springs watershed. Although numerous scientific
studies link pesticide use with significant
Cactus ferruginous pygmy owl developmental, neurological and reproductive
effects to amphibians, the EPA has refused to
CHIRICAHUA LEOPARD FROG consult with the FWS regarding the impact of
Location: AZ, NM pesticides on the Barton Springs salamander.
The Chiricahua leopard frog (Rana chiricahuensis)
is a stocky leopard-spotted frog found in
springs, streams, ponds, and lakes in Arizona
and New Mexico. According to the FWS,
pesticides may be a contributing or causal
factor in the decline of the Chiricahua leopard
frog. 112 Pesticides have also been implicated in
the decline of other species of ranid frogs.113

Photo by Robin Silver

30
 [SOUTHWEST REGION]

KEMP’S RIDLEY SEA TURTLE TEXAS INVERTEBRATE SPECIES

Location: AL, CT, DE, FL, GA, LA, MD, MA, Location: TX
MS, NC, NJ, NY, RI, SC, TX, VA

The Kemp’s ridley sea turtle (Lepidochelys kempii) Water contamination from pesticides has been listed
nests on beaches in the Gulf of Mexico and as a concern for the Comal Springs riffle beetle
juvenile turtles frequent bays, coastal lagoons (Heterelmis comalensis ) and Comal Springs
and river mouths. The FWS and the EPA dryopid beetle (Stygoparnus comalensis), small
believe pesticides used near the Texas coast aquatic insects restricted in distribution to spring
might threaten the Kemp’s ridley sea turtle.116 sites in Comal and Hays Counties, Texas.118 Nine
The pesticide atrazine has been shown to cave-dwelling invertebrates found in Bexar County
disrupt the hormonal system in sea turtles, are also threatened by pesticides. Rhadine exilis
which can impact their reproductive success. (no common name), Rhadine infernalis (no
common name), Batrisodes venyivi (Helotes mold
beetle), Texella cokendolpheri (Robber Baron Cave
harvestman), Cicurina baronia (Robber Baron cave
spider), Cicurina madla (Madla’s cave spider),
Cicurina venii (no common name), Cicurina
vespera (Vesper cave spider), and Neoleptoneta
microps (Government Canyon cave spider) cave
habitat is susceptible to degradation from
pesticide runoff. 119 The FWS concluded that
pesticide applications in or near karst features that
contain any of the nine invertebrates, or areas
that drain into these karst features, could
Kemp’s ridley sea turtle potentially result in the violation of the ESA
prohibitions against harm to these species.

DESERT PUPFISH HOLMGREN and SHIVWITS MILK-VETCH

Location: AZ Location: AZ, UT
Desert pupfish (Cyprinodon macularius), which Holmgren milk-vetch
survive in only a few isolated Mojave Desert (Astragalus holmgreniorum)
springs, can tolerate water heated to 113 degrees and Shivwits milk-vetch
and twice as salty as the ocean. However, they (A. ampullarioides) are
cannot tolerate exposure to pesticides. Drift from endangered perennial herbs
aerial application of pesticides has contributed to found near the Arizona-Utah
the decline of pupfish in Quitobaquito Springs, border. The FWS recognized
Arizona.117 Aerial pesticide application is a common indirect effects of pesticides
practice near other natural populations in California on both plant species. 120 Shivwits milk-vetch
and Mexico, which may be similarly impacted. Pollination for these species
was identified as a long-term concern, as the
FWS acknowledged that increased pesticide
use may affect pollinators which in turn
would impact both milk-vetch species.
Milk-vetch photo by Renee Van Buren
Turtle photo courtesy of Texas Parks & Wildlife, Bill Reaves(c)2004 31
 GREAT LAKES–BIG RIVERS REGION SPECIES

BALD EAGLE Contaminants can affect the health, survival

Location: AL, AR, AZ, CA, CO, CT, DC, DE, and reproductive success of bald eagles, as
FL, GA, ID, IL, IN, IA, KS, KY, LA, MA, MD, well as the abundance and quality of
ME, MI, MN, MS, MO, MT, NC, ND, NE, prey. Although pesticides in recent times have
NH, NJ, NM, NV, NY, OH, OK, OR, PA, RI,
not impacted the bald eagle on a population
SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY
level, individual poisonings still occur from
carcasses baited with poison for coyotes,
through poisoned predatory animals eaten
by eagles, and crop insecticides taken up by
prey animals. 123 Long-term exposure to
contaminants is a much more extensive problem
than is direct mortality, since lifetime
exposure may limit an eagle’s reproductive
capabilities, alter their behavior and foraging
abilities, and increase their susceptibility to
diseases or other environmental stresses. 124

PALLID STURGEON
Location: AR, IL, IA, KS, KY, LA, MO, MI, MT,
Bald eagle ND, NE, SD, TN

Historical declines of the bald eagle (Haliaeetus The prehistoric-looking pallid sturgeon
leucocephalus) were attributed in large part to (Scaphirhynchus albus) is one of the largest
the widespread use of DDT before it was and rarest fish of the Missouri and Mississippi
banned in 1972. DDT and other organochlorine River basins. According to the FWS, pollution is
compounds accumulate in eagles causing likely a threat to the species. 125 Detectable
eggshell thinning and reproductive failure. concentrations of the pesticides dieldrin and
chlordane, which is very highly toxic to fresh water
The bald eagle continues to be threatened by the invertebrates and fish, have been found in pallid
use of several pesticides, including the sturgeon in the Missouri River. Pesticides may
organophosphate insecticides terbufos, fonofos, adversely affect developing eggs of sturgeon,
and phorate; warfarin, an anticoagulant development of embryos, or survival of fry,
rodenticide; and the insecticide carbofuran. thereby reducing reproductive success, due
The FWS has been urging the EPA to cancel to the long egg maturation cycle of the pallid
all forms of carbofuran since the early 1990s sturgeon combined with the tendency for certain
because of its extreme toxicity to wildlife. contaminants to be concentrated in eggs.
According to the FWS, illegal use of carbofuran
and other highly toxic chemicals for predator
control has killed a number of bald eagles.121 The
National Wildlife Health Research Center has
diagnosed over one hundred cases of pesticide
poisonings in bald eagles in the past fifteen years.122

Release of pallid sturgeon

Both photos courtesy of USFWS 32

 [GREAT LAKES–BIG RIVERS REGION]

HINE’S EMERALD DRAGONFLY

Location: AL, IL, IN, MI, MO, OH, WI

The Hine’s emerald dragonfly (Somatochlora pesticides are much higher than than acceptable
hineana) exhibits a unique mix of natural beauty limits and may be lethal to the species. Additionally,
and engineering, with its slender, metallic the FWS noted that groundwater contamination,
body with green, brown or black coloring and including pesticides, affects the amphipod’s habitat.
yellow lateral strips marking the thorax. The Illinois State Geological Survey (ISGS)
Due to the proximity of Hine’s emerald analyzed water samples from nine springs, one cave
dragonfly habitat to apple and cherry orchards, stream, and 33 wells. The study detected atrazine
pesticide drift and runoff was identified by and/or alachlor in 83% of the samples taken from
the FWS as a potential threat to the species.126 springs in the study area.128 Atrazine is one of the
most commonly used herbicides in Monroe County,
where the amphipod is found. The levels found
in these samples often exceeded the EPA
maximum contaminant levels of 2.0 ppb and
3.0 ppb, respectively, during and following
spring rainfalls. Atrazine concentrations in
spring samples were found as high as 98 ppb.
The maximum level found in the Illinois Caverns
was 1.38 ppb. However, studies have demonstrated
acute toxicity to amphipods from a 48-hour
exposure to atrazine at 2.4 parts per million (ppm).

Furthermore, the ISGS study reported reproductive

effects and impaired survival of offspring from
concentrations as low as 0.14 ppm. Another study,
Hine’s Emerald Dragonfly
by Mayer and Ellersieck (1986), reported that
Gammaridae were most sensitive to the insecticides
ILLINOIS CAVE AMPHIPOD carbaryl, DDT, endrin, malathion, and
Location: IL methoxychlor and postulated that pesticide pulses
characteristics of karst springs could have major
The Illinois cave amphipod (Gammarus impacts on biota such as amphipods. Malathion and
acherondytes) is a small cave-dependent species carbaryl were noted by the FWS to be among the
inhabiting the dark zone of cave streams. most commonly used insecticides in the
The amphipod is threatened primarily region. The FWS concluded that “[w]hile direct
by degraded groundwater caused by the mortality cannot be conclusively attributed to such
application of agricultural and residential agricultural chemicals as atrazine, carbaryl,
pesticides and other contaminants.127 Of particular DDT, or malathion…the presence of such
concern is runoff during spring and summer contaminants in the amphipod’s environment
rainstorms when demonstrated peak levels of constitutes strong circumstantial evidence that the
deterioration of water quality is the primary
cause of the decrease in the species’ range
and the number of extant populations.” 129

Photo by Paul Burton

33
 [GREAT LAKES–BIG RIVERS REGION]

HUNGERFORD’S NORTHERN WILD MONKSHOOD

CRAWLING WATER BEETLE Location: IA, NY, OH, WI
Location: MI

The Hungerford’s crawling water beetle (Brychius Northern wild monkshood (Aconitum
hungerfordi spangler) is a small water noveboracense) is a purple flower in the buttercup
beetle found in only five isolated locations family which grows only in moist soil pockets
in Michigan and Ontario, Canada. The four at the bottom of sandstone or limestone cliffs. In
Michigan sites are in the Cheboygan 1998 the EPA reported that application of
River watershed and may be affected by oxyfluorfen, an herbicide used to control roadside
agricultural and lawn pesticide pollution. 130 vegetation, had killed northern wild monkshood. 132

MITCHELL’S SATYR BUTTERFLY

Location: IN, MI

The Mitchell’s satyr butterfly (Neonnympha

mitchellii mitchellii) is one of the most
geographically restricted eastern butterflies.
Historically, the Mitchell’s satyr was found
in New Jersey, Ohio, Michigan, Indiana,
and possibly Maryland. Today it can only be
found in 13 locations in Michigan and two locations
in Indiana. Mitchell’s satyr is a wetland Northern wild monkshood
dependent species. FWS recognized contamination
of wetlands from pesticide runoff from adjacent
agriculture as a threat to its existence. 131
SCALESHELL MUSSEL
Location: AR, MO, OK, SD

The scaleshell mussel (Leptodea leptodon) is a filter

feeder that lives in the substrate of medium to
large-sized rivers within the Mississippi River
basin. Surface run-off of pesticides was noted by
the FWS as an apparent “contributing factor” in
the degradation of the Scaleshell mussel’s habitat.133
The FWS went on to state that “many of the
same threats that caused the extirpation of
historical populations of scaleshell mussels still
exist and continue to threaten extant
populations,” and that pesticide registration is a
Mitchell’s satyr butterfly federal activity that may impact the mussel.

Monkshood photo by J. Selby

Butterfly photo by Dr. Richard Arnold, Entomological Consulting Services 34
 SOUTHEAST REGION SPECIES

WOOD STORK
Location: AL, FL, GA, SC

The wood stork (Mycteria americana) is a large, The FWS notes that overuse of pesticides and
long-legged wading bird with a wingspan of pesticide poisoning has contributed to the gray
over five feet. Significant pesticide levels have bat’s decline.135 The core range of the gray bat
been reported in wood storks, with some eggshell encompasses the cave regions of Alabama, northern
thinning, but this has apparently not yet Arkansas, Kentucky, Missouri, and Tennessee.
adversely affected reproduction.134 The FWS Populations also occur in portions of Florida,
informed the EPA in 1989, when the EPA consulted Georgia, Kansas, Indiana, Illinois, Oklahoma,
on the re-registration of the insecticide Mississippi, Virginia, and possibly North Carolina.
endosulfan, that endosulfan use jeopardized
the continued existence of the wood stork.
The EPA ignored a FWS recommendation LOWER KEYS MARSH RABBIT
that the registration of endosulfan be cancelled. Location: FL

The Lower Keys marsh rabbit (Sylvilagus palustris

hefneri) builds mazes of runs, dens, and nests in
brackish coastal marshes or freshwater inland
marshes. This endangered rabbit may be exposed
to pesticides used in its marsh habitat and may also
come in contact with poisons used to control black
rats.136 These contaminants can either be ingested
while foraging on plants or drinking water.
In a 1993 Biological Opinion, the FWS investigated
the effects of vertebrate control agents on
endangered and threatened species and determined
that several chemicals, such as Pival, would
Wood stork jeopardize the continued existence of the
Lower Keys marsh rabbit. Pival is a rodenticide
used to kill rats and is lethal if ingested. The FWS
GRAY BAT
Location: AL, AR, GA, KS, KY, IN, IL, OK, also concluded that if development in the
Keys continues to increase, the potential for
MS, MO, NC, TN, VA
rabbits to come in contact with such chemicals
also increases, as does the potential for their
The gray bat (Myotis grisescens), 3 to 4 inches extinction. Based on these findings, the FWS
in length, is the largest species of Myotis concluded that use of such chemicals will
found in the eastern United States. result in deaths of Lower Keys marsh rabbits.

Photo by Dr. Lloyd Glenn Ingles 35

 [SOUTHEAST REGION]

MISSISSIPPI GOPHER FROG ATLANTIC COAST PIPING PLOVER

Location: MS Location: AL, CT, DE, FL, MA, MD, ME, NC,
NH, NJ, SC, VA
The Mississippi gopher frog (Rana capito sevosa)
is a stubby subterranean frog that utilizes gopher
tortoise and mammal burrows in the lower
coastal plain of the Mississippi River and Mobile
River Deltas. In designating the Mississippi
gopher frog as endangered, the FWS recognized
that pesticides may affect the species. 137
The FWS cited four separate peer-reviewed
studies in recognizing the multiple impacts
pesticides have on frogs throughout their life cycle.

ALABAMA CAVEFISH
Location: AL
The Alabama cavefish (Speoplatyrhinus poulsoni) Piping Plover
is a blind albino fish known only from
Key Cave, Lauderdale County, Alabama.
According to the FWS, application of pesticides The Atlantic Coast piping plover (Charadrius
to row crops on land immediately around and melodus) is a sand colored shorebird that breeds
above Key Cave may impact the cavefish.138 on coastal beaches from Newfoundland to
South Carolina. The EPA failed to reply to a request
from the FWS for consultation on the impacts
SPRUCE-FIR MOSS SPIDER of the pesticide fenthion and ignored the
Location: NC, TN FWS recommendation that its registration be
cancelled, despite the fact mortality of at least
The spruce-fir moss spider (Microhexura one plover was documented from fenthion
montivaga) is a tarantula-like spider found on use.140 The registration of fenthion was voluntarily
damp moss mats on boulders in high-elevation cancelled by the manufacturer in 2003.
fir and spruce forests. In designating critical
habitat for the Spruce-fir moss spider, the FWS
noted that the species is “extremely vulnerable to
extirpation from a single event or
activity such as … pesticide/herbicide
application.”139 The FWS also identified pesticide
applications as an activity that may also
jeopardize the continued existence of the species.

Photo by Sidney Maddock 36

 [SOUTHEAST REGION]

EASTERN INDIGO SNAKE

Location: AL, FL, GA, SC

The Eastern indigo snake (Drymarchon corais the species.144 In fact, pesticide runoff from urban
couperi) is a large, docile, non-poisonous, shiny use was responsible for at least one fish kill
bluish-black snake growing to a maximum incident, and that heavy pesticide runoff could
length of about eight feet. Pesticides that result in extirpation of the species given
bioaccumulate through the food chain may its limited distribution. The FWS also stated
present a potential hazard to the species. that pesticide registration was one of several
Pesticides used on crops or for silviculture federal activities that could impact the darter.
would pose a pulse effect to the indigo.

Secondary exposure to rodenticides used ARMORED SNAIL

to control black rats may also occur. 141 The FWS and SLENDER CAMPELOMA
has discouraged use of poison to control Location: AL
rats in areas inhabited by this species since
indirect poisoning of snakes may occur. 142 The
USGS also notes that agricultural insecticides The armored snail (Pyrgulopsis pachyta) and
are a contributing factor to its decline. 143 slender campeloma (Campeloma decampi) are
freshwater snail species restricted to a few isolated
sites in Alabama. The FWS identified pesticides
as a threat to both snail species because their habitat
is dominated by agricultural use.145 Specifically,
the FWS identified habitat for both species in three
drainages which are susceptible to pesticide
contamination because of the agricultural use in
those drainages. The FWS noted that pesticides
were found in two of the three drainages during a
site visit in 1997. However, despite a request from
Indigo Snake
the FWS to federal agencies (including the EPA)
that may have programs that might adversely affect
the species, the FWS did not receive any responses.
VERMILION DARTER It is startling that the EPA did not respond to the
Location: AL FWS request despite the fact that the FWS
highlighted pesticides as a threat to both species
The vermilion darter (Etheostoma chermocki) is a and found pesticides present in the species’ habitat.
freshwater fish with reddish-orange sides and belly,
and a bright red spot on the dorsal fin of males.
According to the FWS, pesticides from runoff that
washes into stream habitat for the vermillion darter
currently threaten the sole surviving population of

Photo by E.R. Degginger 37

 [SOUTHEAST REGION]

CAROLINA HEELSPLITTER SCHAUS SWALLOWTAIL BUTTERFLY

Location: NC, SC Location: FL
APPALACHIAN ELKTOE
Location: NC, TN

The FWS noted that pesticides threaten the

remaining populations of the Carolina
heelsplitter (Lasmigona decorata ) and the
Appalachian elktoe (Alasmidonta raveneliana),
two species of freshwater mollusks.146 The FWS
also specifically identified pesticide applications
as an activity that may destroy or adversely modify
critical habitat for both species. Additionally,
the FWS stated that the previously identified
activities (including pesticide applications) also
have the potential to jeopardize the existence Schaus swallowtail butterfly
of both species and that federal agencies are already
required to consult with the FWS on these type ofThe Schaus swallowtail butterfly (Heraclides
activities. Despite the FWS announcement that aristodemus ponceanus) is limited to tropical
pesticide application activities require consultation,
hardwood hammocks in the upper Florida Keys.
EPA has failed to initiate such consultation. Commercial pesticide and insecticide use
has contributed to the decline of the swallowtail.
Spraying for mosquito control still occurs
ALABAMA SNAIL SPECIES in swallowtail habitat in Monroe County, Florida,
Location: AL including the pesticides Dibrom, Baytex,
and Teknar, which are toxic to the related
Water contamination from pesticides has giant swallowtail in the laboratory. 148 Use of
been listed as a concern for the cylindrical these pesticides causes direct mortality of
lioplax snail (Lioplax cyclostomaformis), flat Schaus swallowtail butterflies and indirectly
pebble snail (Lepyrium showalteri ), painted affects the species by application to food
rocksnail (Leptoxis taeniata), plicate rocksnail sources and other components of the
(Leptoxis plicata), round rocksnail (Leptoxis habitat. The FWS believes it very likely that
ampla),and lacy elimia (Elimia crenatella).147 extensive mosquito control using these pesticides
has greatly reduced butterfly populations. 149

Photo by George Krizek,USFWS 38

 NORTHEAST REGION SPECIES

LOGGERHEAD SEA TURTLE ATLANTIC SALMON

Location: AL, CA, CT, DE, FL, GA, HI, LA, Location: ME
MD, MA, MS, NC, NJ, NY, OR, RI, SC, TX,
VA
Pesticides have been detected in sea turtles, Wild Atlantic salmon (Salmo salar) in Maine rivers
including in their eggs, but levels which result in are at an all-time low, with less than 50 adult fish
adverse effects have not been quantified. 150 returning to spawn in recent years, and face
Loggerhead sea turtles (Caretta caretta ) in a number of threats that could drive them to
Chesapeake Bay are exposed to harmful extinction. According to the FWS, chronic
concentrations of the herbicide atrazine. Atrazine exposure to insecticides, herbicides, fungicides,
may disrupt the hormonal system of sea turtles, and pesticides (in particular those used
impacting their reproductive success. According to to control spruce budworm) impact the Maine
the EPA, atrazine runoff in Chesapeake Bay also population of Atlantic salmon. 153 The FWS
destroys habitat and food sources for sea turtles.151 noted that pesticide application even in
compliance with label restrictions could result in
violations of section 9 prohibitions against take.

INDIANA BAT
Location: AL, AR, GA, IA, IL, IN, KS, KY,
MD, MI, MO, MS, NC, NJ, NY, OH, OK,
PA, SC, TN, VT, VA, WV

The FWS listed pesticides as a threat to the Indiana

bat (Myotis sodalis) and noted that pesticides have
been implicated in the declines of a number of
other insectivorous bats in North America.
Loggerhead sea turtle
Studies of the related little brown bat
(M. iucifugus) and the northern long-eared bat (M.
DWARF WEDGE MUSSEL septentrionalis) in northern Missouri suggested
Location: CT, MD, MA, NC, NH, NJ, NY, PA, that bats there may be exposed to significant
VT, VA amounts of organophosphate and/or carbamate
insecticides applied to agricultural crops,
Adventurous larvae of the dwarf wedge mussel
especially those applied to corn. 154 Further studies
(Alasmidonta heterodon) attach to a fish host,
of tissue and guano samples from five species of
suspected to be an anadromous fish which migrates
bats in Missouri documented their exposure to
from the ocean into freshwater to spawn. The dwarf
DDE, heptachlor epoxide, and dieldrin. 155
wedge mussel is now known from only a dozen
sites and one of the largest known populations,
where the Ashuelot River meanders through a golf
course, declined dramatically from 1985 to 1990.
In listing the species, the FWS attributed the decline
to fungicides, herbicides, insecticides; fertilizers
applied to the golf course as well as agricultural
runoff from abutting cornfields and pastures.152

Photo by John White 39

 MOUNTAIN-PRAIRIE REGION SPECIES

WYOMING TOAD TOPEKA SHINER

Location: WY Location: IA, KS, MO, MN, NE,SD
ARKANSAS SHINER
Location: AR, KS, NM, OK, TX

The Wyoming toad (Bufo baxteri) is extremely rare The Topeka shiner (Notropis topeka) is a small
– only one small population remains. The use of minnow that inhabits headwater prairie streams
the herbicide atrazine is known to decimate with good water quality and cool temperatures. The
populations of frogs of the genus Bufo (which FWS stated that due to a lack of riparian vegetation
includes the Wyoming toad) and can be introduced buffer strips, pesticide application for agricultural
into watersheds in sufficient levels to kill eggs purposes has the potential to impact the Topeka
or tadpoles.156 The FWS noted in the proposed shiner, particularly through runoff following
listing for the Wyoming toad that atrazine is heavy precipitation events.158 The FWS noted
widely available throughout the Laramie that “there are presently numerous areas
Basin, where the species occurs, and that along streams without buffers that may impact
other herbicides such as Tordon are also used. 157 the species.” For the Arkansas River shiner
(Notropis girardi), FWS referred to the
The FWS informed the EPA in 1989, when the EPA section 7 consultation process, mentioning that the
consulted on the re-registration of the insecticide EPA will consider the shiner in the registration
endosulfan, that endosulfan use jeopardized the of pesticides. However, EPA has yet to consider
continued existence of the Wyoming toad. The EPA the shiner in any pesticide registration. 159
ignored FWS recommendation that the
registration of endosulfan be cancelled.
The FWS noted that Weed and Pest
Districts commonly use herbicides for
noxious weed control in roadside ponds
and field edges typically used by the
Wyoming toad. Application of Fenthion
with diesel fuel for mosquito control began
in 1975 in the Laramie Basin. The FWS
believes that this mosquito control
technique, with very little control of spray
drift, may be highly toxic to bufonids, as
there is evidence that shows diesel fuel
alone is highly toxic to amphibians. Topeka shiner

Photo by Konrad Schmidt 40

 [MOUNTAIN-PRAIRIE REGION]

PREBLE’S MEADOW JUMPING MOUSE PAWNEE MONTANE SKIPPER

Location: CO, WY Location: CO

The Preble’s meadow jumping mouse The Pawnee montane skipper (Hesperia
(Zapus hudsonius preblei) has a long tail and leonardus montana) is a small brownish-yellow
long feet adapted for jumping. The FWS butterfly found on granite outcrops in
listing decision for the Preble’s meadow ponderosa pine habitat in the South Platte
jumping mouse noted that pesticide and River drainage. The FWS noted in the
herbicide use has undoubtedly increased across listing determination for the Pawnee mountain
the species’ range as human land use has skipper that use of insecticides for mountain
intensified. 160 According to the FWS these pine bark beetle or other pests within
chemicals could directly poison mice or be the range of the species could result in the
ingested through contaminated food or water. loss of individual butterflies or populations. 162

NEOSHO MADTOM
Location: KS, OK, MO

The Neosho madtom (Noturus placidus) is a

small catfish up to three inches long. When listing
the species, the the FWS explicitly alerted the EPA
that upon listing, the EPA will need to
reinitiate ESA consultation on the registration
and re-registration of pesticides.161 Despite the
request to initiate consultation, the EPA has
refused to comply, allowing pesticides to
continue to threaten the madtom’s existence.

Pawnee montane skipper

Photo courtesy of USFWS 41

 OTHER SPECIES AFFECTED BY PESTICIDES

The list of other species that may be affected by The EPA has abdicated its statutory responsibility
pesticide use is long but still incomplete (see pages to investigate and develop information on species
43 and 44). It includes numerous fish, amphibians, affected by pesticide use. When environmental
reptiles, birds, mammals, insects, aquatic groups identify a species that may be affected
invertebrates, clams, snails, and plants. by pesticide use, the EPA’s usual answer is
that there is not enough information to confirm
Pesticides are used extensively throughout the impacts. Instead of embracing the
the United States, jeopardizing aquatic and precautionary principle and restricting pesticide
terrestrial species. However, little is known use while more information is gathered, the
about the impacts occurring on the ground and EPA shifts the evidentiary burden to those
in the water. Lists are compiled for different seeking to protect species from pesticide impacts.
purposes by different organizations and there
is no single database that identifies
species at risk from pesticide use.
In California alone however, the
California Department of Pesticide
Regulation has compiled a list of species
whose habitat overlaps with pesticide
use at the section level (one square mile),
which totals 179 federally listed, proposed
and Category 1 candidate species. 163

The Audubon Society’s “watch list” is

composed of species facing population
declines and/or threats such as habitat loss
on their breeding and wintering grounds, Hawaiian coot
or with limited geographic ranges. The
watch list identifies pesticides as a risk to the
bay-breasted warbler, black rail, black swift,
McCown’s longspur, Lewis woodpecker,
white-throated swift, buff-breasted sandpiper,
calliope hummingbird, Gunnison sage-grouse,
Hawaiian coot (pictured), Allen’s hummingbird,
California thrasher, olive-sided flycatcher, Pacific
golden-plover, American golden-plover, Antillean
nighthawk,short-eared owl, wrentit, rufous
hummingbird, and short-billed dowitcher. 164

Photo courtesy of USFWS 42

 [OTHER SPECIES AFFECTED BY PESTICIDES]

Louisiana Black Bear Short-tailed Albatross Pecos Gambusia

Sonoran Pronghorn Whooping Crane San Marcos Gambusia
Bighorn Sheep Amber Darter Pygmy Madtom
Point Arena Mountain Beaver Bayou Darter Scioto Madtom
Riparian Brush Rabbit Bluemask (Jewel) Darter Smoky Madtom
Mount Graham Red Squirrel Boulder Darter Yellowfin Madtom
Northern Idaho Ground Squirrel Cherokee Darter Bonytail Chub
Amargosa Vole Duskytail Darter Borax Lake Chub
Hualapai Mexican Vole Etowah Darter Chihuahua Chub
Pacific Pocket Mouse Fountain Darter Cowhead Lake Tui Chub
Salt Marsh Harvest Mouse Goldline Darter Hutton Tui Chub
Southeastern Beach Mouse Leopard Darter Humpback Chub
Fresno Kangaroo Rat Maryland Darter Mohave Tui Chub
Giant Kangaroo Rat Niangua Darter Oregon Chub
Morro Bay Kangaroo Rat Okaloosa Darter Owen’s Tui Chub
San Bernardino Kangaroo Rat Relict Darter Pahranagat Roundtail Chub
Stephen’s Kangaroo Rat Slackwater Darter Slender Chub
Tipton Kangaroo Rat Snail Darter Sonora Chub
Riparian Woodrat Watercress Darter Spotfin Chub
Cape Sable Seaside Sparrow Ash Meadows Specked Dace Virgin River Chub
Dusky Seaside Sparrow Blackside Dace Yaqui Chub
Florida Grasshopper Sparrow Desert Dace Ash Meadows Amargoa Pupfish
San Clemente Sage Sparrow Foskett Speckled Dace Comanche Springs Pupfish
Indiana Bat Kendall Warm Springs Dace Devil’s Hole Pupfish
Lesser long-nosed Bat Moapa Dace Leon Springs Pupfish
Mexican long-nosed Bat Spike Dace Owen’s Pupfish
California Clapper Rail Big River Spinedace Warm Springs Pupfish
Light-footed Clapper Rail Little Colorado Spinedace June Sucker
Yuma Clapper Rail White River Spinedace Lost River Sucker
Laysan Finch Apache Trout Modoc Sucker
Niho Finch Coastal sea-run Cutthroat Trout Razorback Sucker
Mountain Plover Gila Trout Shortnose Sucker
Western Snowy Plover Greenback Cutthroat Trout Warner Sucker
California Least Tern Lahontan Cutthroat Trout Hiko White River Springfish
Interior Least Tern Little Kern Golden Trout Railroad Valley Springfish
Audubon’s Crested Caracara Paiute Cutthroat Trout White River Springfish
Brown Pelican Beautiful Shiner Gulf Sturgeon
California Condor Blue Shiner Shortnose Sturgeon
Coastal California Gnatcatcher Cahaba Shiner Conasauga Logperch
Eskimo Masked Bobwhite Cape Fear Shiner Roanoke Logperch
Everglade Snail Kite Palezone Shiner Chui-ui
Florida Scrub Jay Pecos Bluntnose Shiner Colorado Squawfish
Inyo California Towhee Devil’s River Minnow Ozark Cavefish
Least Bell’s Vireo Loach Minnow Pahrump Poolfish
Marble Murrelet Rio Grande Silvery Minnow Pygmy Sculpin
Northern Aplomado Falcon Gila (Yaqui) Topminnow Tidewater Goby
Northern Spotted Owl Big Bend Gambusia Unarmored Three Spine Stickleback
Red-cockaded Woodpecker Clear Creek Gambusia Waccamaw Silverside
San Clemente Loggerhead Shrike Woundfin

43
 [OTHER SPECIES AFFECTED BY PESTICIDES]

Yaqui Catfish Higgin’s Eye (Pearlymussel) Pecos Assminea

Alameda Whipsnake Orange-footed Pearlymussel Roswell Springsnail
Atlantic Salt Marsh Snake Little-wing Pearlymussel Royal Snail
New Mexico Ridge-nosed Pale Lilliput Pearlymussel Tulotoma Snail
Rattlesnake Purple Cat’s Paw Pearlymussel El Segundo Blue Butterfly
San Francisco Garter Snake Tubercled-blossom Pearlymussel Lange’s Metalmark Butterfly
Coachella Valley Fringe-toed Turgid-blossom Pearlymussel Lotis Blue Butterfly
Lizard White Cat’s Paw Pearlymussel Mission Blue Butterfly
Island Night Lizard White Wartyback Pearlymussel Myrtle’s Silverspot Butterfly
Bog Turtle Yellow-blossom Pearlymussel Oregon Silverspot Butterfly
Green Sea Turtle Cumberland Pigtoe Palos Verdes Blue Butterfly
Leatherback Sea Turtle Dark Pigtoe Quino Checkerspot Butterfly
Hawksbill Sea Turtle Fine-rayed Pigtoe Saint Francis’ Satyr
Yellow-Bloched Map Turtle Rough Pigtoe San Bruno Elfin Butterfly
Desert Tortoise Shiny Pigtoe Sacramento Mountains Checkerspot
Desert Slender Salamander Southern Pigtoe Butterfly
Flatwoods Salamander Fat Pocketbook Smith’s Blue Butterfly
San Marcos Salamander Finelined Pocketbook Blackburn’s Sphinx Moth
Santa Cruz long-toed Salamder Ouachita Rock-Pocketbook Kern Primrose Sphinx Moth
Sonora Tiger Salamander Speckled Pocketbook Ash Meadows Naucori
Texas Blind Salamander Arkansas Fat Mucket Delhi Sands Flower-loving Fly
Houston Toad Orange-nacre Mucket Laguna Mountains Skipper
Puerto Rican Crested Toad Pink Mucket Valley Elderberry Longhorn Beetle
Guajon Ovate Clubshell Zayante Band-Winged Grasshopper
Alabama Cave Shrimp Southern Clubshell
California Freshwater Shrimp Coosa Moccasinshell
Conservancy Fairy Shrimp Alabama Maccasinshell
Kentucky Cave Shrimp Jame’s Spinymussel
Longhorn Fairy Shrimp Tar River Spinymussel
Riverside Fairy Shrimp Cumberland Elktoe
San Diego Fairy Shrimp Cumberlandian Combshell
Vernal Pool Fairy Shrimp Fat Threeridge
Vernal Pool Tadpole Shrimp Inflated Heelsplitter
Hay’s Spring Amphipod Louisiana Pearlshell
Noel’s Amphipod Oyster Mussel
Lee County Cave Isopod Purple Bankclimber
Madison Cave Isopod Purple Bean
Nashville Isopod Rough Rabbitsfoot
Socorrro Isopod Shinyrayed Slabshell
Cave Crayfish Southern Acornshell
Shasta Crayfish Stirrup Shell
Alabama Lamp Pearlymussel Tan Riffle Shell
Appalachian Monkeyface Pearlymussel Triangular Kidneyshell
Birdwing Pearlymussel Upland Combshell
Cumberland Bean Pearlymussel Anthony’s Riversnail
Cumberland Monkeyface Pearlymussel Iowa Pleistocene Snail
Curtis’ Pearlymussel Koster’s Tryonia
Dromedary Pearlymussel Newcomb’s Snail
Green-blossom Pearlymussel Morro Shoulderband Snail

44
 WHAT IS THE EPA DOING TO CONTROL
THE USE OF PESTICIDES?

The Federal Insecticide, Fungicide, and Rodenticide Act

and the Food Quality Protection Act

The EPA is responsible for the oversight of pesticide The 1988 amendments established a comprehensive
sales and use in the United States. Specifically, re-registration program for all pesticides
the Federal Insecticide, Fungicide, and Rodenticide with active ingredients that were initially
Act (FIFRA) charges the EPA with reviewing registered before November 1, 1984, in
and registering chemicals for use as insecticides, recognition of rapid advancements in scientific
fungicides, rodenticides, and pesticides understanding of the effects of pesticides.
(collectively “pesticides”) in the United States.165
A pesticide generally may not be sold or The Registration Process
used in the United States unless the EPA has
registered it for that particular use.
The EPA may register a pesticide only after
History of Federal Pesticide Law making the following determinations: (1) the
labeling complies with FIFRA’s requirements; (2)
the composition claims are warranted; (3) the
FIFRA was enacted in 1947 to address the pesticide will perform its intended function; and
human health risks posed by pesticide products. (4) the pesticide will not cause unreasonable
In 1972, concerned about long- and short-term adverse effects on the environment. The
toxic effects of pesticide exposure to applicators, culmination of the registration process is the
wildlife, non-target insects and birds, EPA’s approval of a label for the particular
and food consumers, Congress amended the pesticide, which then may not be used in a
1947 version of FIFRA, with the Federal manner inconsistent with that label.
Environmental Pesticide Control
Act. The 1972 amendment The EPA must classify
shifted responsibility for pesticides for general or
administering pesticides from restricted use, depending
the U.S. Department of on their particular risks.
Agriculture to the Administrator Where necessary to guard
of the EPA, and established a against unreasonable adverse
program for controlling the environmental effects, the EPA
sale, distribution, and application must classify (or when the
of pesticides through an information becomes available,
administrative registration reclassify) a pesticide as
process. With Congressional “restricted.” Restricted use
General Accounting Office pesticides may only be applied
reports projecting that the process Pesticide warning sign by a certified applicator or under
would not be completed until the direct supervision of a
well into the twenty-first century, and frustrated by certified applicator and application must follow all
the EPA’s inability to re-register pesticides, limitations on the frequency, type, location
Congress again amended FIFRA in 1988. or protective measures associated with its use.

Photo by Gail Hansche

45
 [THE REGISTRATION PROCESS]

Even after registering a pesticide, the agency retains for testing because they broadly represent
discretionary involvement and in control over non-target organisms. Toxicology studies analyze
that registration. Furthermore, it must review each both acute (short-term) and chronic (long-term)
registration every fifteen years. The EPA impacts; impacts being mortality of plants and
also has the authority to compel registrants to animals as a result of exposure to the pesticide.
submit data on potentially unreasonable
adverse effects that may be necessary for a
re-registration review and can cancel pesticide
registrations whenever “a pesticide or its labeling
or other material required to be submitted does not
comply with the provisions of this Act or, when
used in accordance with widespread and commonly
recognized practice, generally causes unreasonable
adverse effects on the environment.” 166

The EPA’s re-registration decisions require a

determination of whether the pesticide causes
unreasonable adverse effects to people or the
environment when used according to product Mattiace Petrochemical pollution, Glen Cove, NY
labeling. This determination is presented in a To determine how the pesticide behaves in the
Re-registration Eligibility Decision (RED) environment, the EPA measures the interaction of
document. The RED comprises a human health the pesticide with soils, air, sunlight, surface water,
assessment and an environmental risk assessment. and ground water. Some of the basic questions
The FIFRA risk-benefit standard is not a safety that must be answered to determine the
standard, but rather a balancing standard under “environmental fate” of the pesticide include: how
which, in the EPA’s own words, workers can be fast and by what means does the pesticide
regularly exposed to “unacceptable risks.” The degrade; what are the breakdown chemicals; how
environmental assessment evaluates the likelihood much of the pesticide or its breakdown chemicals
that exposure to that pesticide may cause harmful will travel from the application site; and where
ecological effects. The effects can be direct (e.g. will the pesticide or its breakdown chemicals
fish die from a pesticide entering waterways), or accumulate in the environment. Environmental fate
indirect (e.g. birds become sick or do not reproduce analyses help develop estimates of pesticide
normally after ingesting contaminated fish). The concentrations in the environment. The EPA
studies conducted during the environmental establishes the risk assessment by comparing
assessment include: defining the chemical possible exposures to a pesticide, based on the
properties of the pesticide; determining how the environmental fate analyses, with resulting harmful
pesticide behaves in the environment; and effects on plants and animals. The result will
assessing its impact on plants and animals not indicate the likelihood of mortality to plants and
targeted by the pesticide (non-target organisms). animals from use of the pesticide. However, the
Toxicology studies are carried out on risk assessment does not incorporate sub-lethal
plants and animals that have been chosen impacts under its risk assessment evaluation.

Photo courtesy of NOAA 46

 [THE REGISTRATION PROCESS]

In determining the ecological risk posed by a LOCs address the following risk presumption
pesticide (risk characterization), the EPA integrates categories: (1) acute high – potential for acute risk
the results of the exposure and ecotoxicity data to is high and regulatory action may be warranted in
estimate the likelihood of adverse ecological addition to restricted use classification; (2) acute
effects. The means of integrating the results restricted use – the potential for acute risk is high,
of exposure and ecotoxicity data is called the but may be mitigated through restricted use
quotient method. For this method, risk classification; (3) acute endangered species –
quotients (RQs) are calculated by dividing endangered species may be adversely affected; and
exposure estimates (estimated environmental (4) chronic risk – the potential for chronic
concentrations or EECs) by ecotoxicity values risk is high and regulatory action may be
(toxicity endpoint values, such as the median warranted. In general, the higher the RQ,
lethal dose (LD 50 ) or the median lethal the greater the concern. Calculated risk quotients
concentration (LC50 ), both acute and chronic. RQs represent a screening level assessment.
are then compared to the EPA’s levels of concern
(LOCs). The LOCs are criteria used by the EPA to Risk characterization provides further information
indicate potential risk to non-target organisms. on the likelihood of adverse effects occuring by
considering the fate of the chemical in the
The criteria indicate that a pesticide used environment, geographic patterns of chemical
as directed has the potential to cause usage, communities and species potentially at
adverse effects on non-target organisms. risk, their spatial and temporal distributions
and the nature of the effects observed in the
laboratory and field studies. When the RQ exceeds
the LOC for a particular category, the EPA
presumes a risk of concern to that category.

The types of measures included in Re-registration

Eligibility Decisions (REDs) to reduce risks that
are of concern include: voluntary cancellation
of pesticide products or deletion of uses;
declaring certain uses ineligible or not yet
eligible (and then proceeding with follow-up
action to cancel the uses or require additional
Contaminated water supporting data); restricting use of products to
certified applicators; limiting the amount or
frequency of use; improving use directions and
precautions; adding more protective clothing and
equipment requirements; requiring special
packaging or engineering controls; requiring no-
treatment buffer zones; employing ground
water, surface water, or other environmental
and ecological safeguards; and other measures.

Photo courtesy of NOAA 47

 [THE REGISTRATION PROCESS]

The EPA also regulates the use of pesticides through The EPA also issues Reports on FQPA Tolerance
the Federal Food, Drug, and Cosmetic Act Reassessment Progress and Interim Risk
(FFDCA), which authorizes the EPA to set Management Decisions, known as TREDs, for
tolerance levels for pesticides used in or on foods pesticides that require tolerance reassessment
or animal feed. In 1996, Congress further amended decisions under the FQPA but do not require re-
FIFRA and the FFDCA with the Food Quality registration eligibility decisions at present because:
Protection Act (FQPA), which refined safety the pesticide was first registered after November
standards for pesticide residue in food. Under 1984; the EPA completed a RED for the pesticide
FQPA, the EPA must further determine with before the FQPA was enacted; or the pesticide is
“reasonable certainty that no harm” will come to not registered for use in the United States but
infants, children or other sensitive individuals tolerances are established that allow crops treated
exposed to pesticides from food, water, and home with the pesticide to be imported from other
and garden use. The FQPA also requires that countries. Like IREDs, some TREDs will not
the EPA consider the cumulative effects of become final until the EPA considers the cumulative
different pesticides in evaluating the safety of risks of all the pesticides in the cumulative group.
individual pesticides. However, the cumulative
effects consideration does not apply to
occupational exposure to pesticides. The EPA
satisfies FQPA’s requirements by reassessing all
existing “tolerances” (maximum limits for pesticide
residues in foods) and is using the re-registration
program as the vehicle for such analysis.

Interim REDs (IREDs) are issued for pesticides that

are undergoing de-registration, require a re-
registration eligibility decision, and also must be Halby Chemical pollution, Wilmington, DE
included in a cumulative assessment under FQPA
because they are part of a group of pesticides that The EPA has chosen organophosphate pesticides,
share a common mechanism of toxicity. The EPA a group of closely-related pesticides that affect the
is issuing IREDs for most organophosphate (OP) functioning of the nervous system as the first
pesticides, as OPs share common mechanisms of priority group of pesticides to be reviewed under
toxicity. An IRED is issued for each individual FQPA. Consequently, OPs are issued IREDs until
pesticide in the cumulative group when the EPA the cumulative risks of the OPs have been
has completed the pesticide’s risk assessment and considered. After the EPA has issued a RED and
risk management decision. An IRED may include declared a pesticide re-registration case eligible for
measures to reduce food, drinking water, re-registration, individual end-use products that
residential, occupational, and/or ecological risks, contain pesticide active ingredients included in the
to gain the benefit of these changes before the case still must be reregistered. This concluding
RED can be issued, following the EPA’s part of the re-registration process is referred to as
consideration of cumulative risks for the group. “product re-registration.” In issuing a completed
RED document, the EPA calls in any product-
specific data and revised labeling needed to make
final re-registration decisions for each of the
individual pesticide products covered by the RED.

Photo courtesy of NOAA 48

 THE EPA’S RESPONSIBILITIES UNDER THE ESA

When a species has been listed as threatened or fish species, and the National Marine Fisheries
endangered under the Endangered Species Act, Service for marine species) to determine
federal agencies have duties under that Act whether their actions will jeopardize the survival
to assess their programs and activities to or adversely modify the critical habitat
ensure they do not jeopardize the survival and of listed species and, if so, to identify ways to
recovery of the animal or plant in question. modify the action to avoid that result.
The Act prescribes the process to be followed to
ensure compliance with each set of duties. An agency must initiate consultation under Section
7 whenever it undertakes an action that “may affect”
Section 7(a)(2) of the ESA requires that “each a listed species or critical habitat. Conversely, an
federal agency shall, in consultation with and agency is relieved of the obligation to consult on
with the assistance of the [Interior] Secretary, its actions only when the action will have “no
insure that any action authorized, funded, or effect” on listed species or designated critical
carried out by such agency … is not likely habitat. Effects determinations are based on the
to jeopardize the continued existence of any direct, indirect, and cumulative effects of the action
endangered species or threatened species or when added to the environmental baseline and
result in the destruction or adverse other interrelated and interdependent actions.
modification of habitat of such species which
isdeterminedbytheSecretary...tobecritical167 .” Regulations implementing Section 7 broadly define
the scope of agency actions subject to
consultation to encompass “all activities or
programs of any kind authorized,
funded, or carried out, in whole or in part,
by Federal agencies,” including the
promulgation of regulations and the
granting of licenses. Agencies must
consult on ongoing agency actions over
which the federal agency retains, or is
authorized to exercise, discretionary
involvement or control. Agencies must also
consult on ongoing agency actions “if a
new species is listed … that may be
LPC Chemical and marsh affected by the identified action.” 168
The end product of formal consultation is
a biological opinion in which the FWS determines
The Act establishes an inter-agency consultation whether the action will jeopardize the survival
process to assist federal agencies in complying and recovery of listed species or will adversely
with this duty under Section 7. Federal agencies modify the species’ critical habitat. In order
must consult with the appropriate expert fish to make this determination, the FWS must review
and wildlife agency (the Fish and Wildlife all relevant information and provide a
Service for terrestrial species and non-oceanic detailed evaluation of the action’s effects, including
the cumulative effects of federal and nonfederal
activities in the area, on the listed species.

Photo courtesy of NOAA 49

 [THE EPA’S RESPONSIBILITIES UNDER THE ESA]

The FWS has a statutory duty to use the best An incidental take statement insulates the federal
available scientific information in an ESA agency from liability for take of a threatened or
consultation. If the FWS determines that the action endangered species, provided the agency complies
is likely to jeopardize the species, the biological with the statement’s terms and conditions. This
opinion must specify reasonable and prudent permission to take a species extends to any entity
alternatives that will avoid jeopardy. The FWS must receiving a federal permit, license, authorization,
also formulate discretionary conservation or funding subject to, and in compliance with, the
recommendations to reduce or minimize the action’s statement. Thus, the ESA provides that:
impacts on listed species or critical habitat. “[A]ny taking that is in compliance with the
terms and conditions specified in a written
Not only does a Section 7 consultation assist the statement provided under subsection (b)(4)(iv)
action agency in discharging its duty to avoid of this section shall not be considered to be
jeopardy, but the biological opinion also affects the a prohibited taking of the species concerned.”170
agency’s obligation to avoid the “take” of listed
species. Under Section 9 of the ESA, it is illegal
for any person -whether a private or governmental
entity – to “take” without authorization any
endangered species of fish or wildlife listed under
the ESA. By regulation, the FWS has made the
take prohibition applicable to all threatened
species. “Take” is defined to mean harass, harm,
pursue, hunt, shoot, wound, kill, trap, capture,
or collect, or attempt to engage in such
conduct. The FWS has defined “harm” to include
“significant habitat modification or degradation Sewer contamination
which actually kills or injures fish or
wildlife by significantly impairing essential Beyond Section 7 consultation duties, federal
behavioral patterns, including breeding, spawning, agencies must “utilize their authorities in
rearing, migrating, feeding or sheltering.” 169 furtherance of the purposes of this chapter by
carrying out programs for the conservation of
endangered species and threatened species
As part of a consultation, the FWS determines
listed” under the ESA. As defined under
whether to authorize the incidental take of listed
Section 3 of the ESA, the term “conservation”
species through the issuance of an incidental
means to use all necessary methods and procedures
take statement. An incidental take statement may
to bring an endangered or threatened species to
be issued only if the action can proceed without
the point at which the measures provided
causing jeopardy. An incidental take statement
pursuant to the ESA are no longer necessary.
must: (1) specify the impact of the incidental
As a federal action agency, the EPA must review
take on the listed species; (2) specify reasonable
the programs it administers and consult with
and prudent measures the FWS considers necessary
the expert fish and wildlife agencies to ensure
to minimize that impact; and if necessary
it utilizes its programs and authorities to
(3) set forth mandatory terms and conditions.
conserve listed species – especially in light of the
agency’s pesticide registration responsibilities.

Photo courtesy of NOAA

50
 THE EPA’S SO-CALLED “ENDANGERED
SPECIES PROTECTION PROGRAM”

The EPA displays a stunning lack of initiative in In 1989, the EPA reinitiated consultation on the
complying with the Endangered Species Act. pesticides reviewed in the clusters, focusing on
The agency has shown reckless disregard for the impacts to aquatic species. Additionally, in 1989,
impact of its Pesticide Regulation Program on the EPA released a proposed “Endangered Species
wildlife, and most importantly, on endangered Protection Program” (ESPP), 171 which would
species. The EPA has made occasional forays in establish how future consultations take place.
addressing pesticide registrations through ESA In 1993, the EPA found that the “cluster”
consultation, but each attempt has failed to fully approach was also problematic and adopted a
assess the impact of the pesticide program on species-based approach where they evaluated the
endangered species. More importantly, the EPA impacts of sixteen vertebrate control agents
has failed to implement an overarching s(i.e. rodenticides) on 56 species (mammals, birds,
program to address pesticide impacts to endangered reptiles, and insects). The EPA intended
species, abrogating its authorities to further to consult on another fifteen pesticides but the
conservation of threatened and endangered species biological opinion was never completed.
as required by Section 7(a)(1) of the ESA.

Since 1993, the EPA has continuously referred to

the non-finalized 1989 ESPP, deferring ESA
compliance until it was finalized. The EPA’s view
was that previous opinions proved ineffective in
assessing the impacts of pesticides and thus an
overarching framework was necessary.
Consequently, instead of complying with the ESA
as pesticides continued to be registered and
new species continued to be added to the federal
endangered species list, the EPA provided
generic statements that it would address
ESA issues when the ESPP was finalized.
Dredge discharge pipe

In 1972, the EPA assumed responsibility for Of course, each year the EPA claimed it
registration of pesticides from the U.S. Department expected the ESPP to be finalized soon.
of Agriculture. Congress passed the Endangered In the interim, the agency has relied on
Species Act in 1973 but the EPA did not begin voluntary measures to protect species that received
consultations with the FWS until 1981. consultation up to 1993. However, since 1993,
Consultations were conducted on a case-by-case except in the presence of litigation, the EPA has
basis where an individual pesticide was consulted not completed a single consultation for newly
on for specific uses. Recognizing that the listed species or addressed new scientific
case-by-case approach was inefficient, the information regarding previously consulted species.
EPA adopted a “cluster” approach, where
pesticides with similar use patterns were
considered together. This approach began in 1983
with a series of biological opinions covering
corn, grain, forest, mosquito, and rangeland uses.

Photo courtesy of USFWS 51

 [THE EPA’S SO-CALLED “ENDANGERED
SPECIES PROTECTION PROGRAM”]

In the interim, species remain in peril while the The bulletins also have not incorporated use
EPA fails to comply with the ESA. During its limitations for species listed since 1993, and are
consultation period with the EPA in used in only a select number of states
the mid 1980s to early 1990s, the FWS concluded across the country. Although the EPA never
that pesticides jeopardized birds, amphibians, updated the original set of county bulletins,
mammals, aquatic invertebrates, fish, created to implement the mitigation measures
and reptiles. The consultations found that deemed necessary by the FWS in the 1989
pesticides impacted over a hundred species, biological opinion, it states in the 2002
indicating that registered pesticides clearly proposed ESPP that county bulletins will
threaten the existence of listed species. be updated annually. Given the EPA’s
Yet the EPA has left species unprotected in inability to manage a very small number of
the interim, as it continuously defers any bulletins covering a limited number of
ESA consultation until the ESPP is finalized. species, it is difficult to believe that the EPA
However, inaction for over a decade indicates will be able to adequately protect endangered
that this is by no means an “interim” species through the use of county bulletins.
problem to be resolved in the “near future.”

The EPA also assumes that it can solve the

pesticide problem for endangered species
through the use of “county bulletins.”
Under the proposed program, generic
label statements would instruct pesticide
users to consult local county bulletins,
which would inform the user on how
to appropriately apply the pesticide
in proximity to endangered and threatened
species. Some county bulletins
were created after the 1989 consultation
to provide protections for species
covered in the 1989 biological opinion.
Pollution at Kanai Moose Range, AK
Specifically, the bulletins contained the 1989
biological opinion’s reasonable and prudent
alternatives to avoid jeopardy. However, the EPA
admits that these bulletins are totally outdated as
they only provide use instructions for a few species
listed prior to 1993. Furthermore, the use of county
bulletins is completely voluntary, allowing
applicants to use pesticides as they see fit.

Photo courtesy of USFWS 52

 [THE EPA’S SO-CALLED “ENDANGERED
SPECIES PROTECTION PROGRAM”]

Consequently, those species whose survival is EPA’s second proposed ESPP is lacking in several
jeopardized by pesticide use receive no real regards. First, the EPA misinterprets its overlapping
protections. In 2000 the Director of the FWS, Jamie duties between FIFRA and the ESA. The EPA
Rappaport Clark, informed the EPA that “[t]he contends that it must comply with the ESA while
nonjeopardy findings we rendered in our previous “considering the needs of agriculture and other
opinions were based on EPA implementing an pesticide users,” and that “moving forward with a
enforceable county bulletin program. Voluntary final program implementation scheme did not seem
compliance shifts the responsibility of enforcing feasible,” – though such loopholes are in no way
appropriate use limitations from EPA to the Fish built into the statutes. In fact, the Supreme Court
and Wildlife Service…. Unless EPA requires has highlighted that “Congress intended endangered
mandatory compliance with FIFRA-enforceable species to be afforded the highest of priorities,”
pesticide use limitations, there will be no certainty and made it clear that prevention of jeopardy is
that our consultations on pesticides will result above cost considerations.174 The agency’s proposal
in protective measures for threatened and to balance impacts to pesticide applicators with its
endangered species.”172 The EPA has yet to require mandatory duty to protect endangered species
mandatory compliance with the bulletins. undermines the purpose of the ESA and places
These species continue to decline listed species in greater peril.
towards extinction while the
EPA continues to find ways to Furthermore, the EPA has
avoid compliance with the ESA. revealed an institutional lack of
concern for listed species by
Although the EPA released a proposing that the agency itself,
second proposed ESPP in 2002, 173 not the Fish and Wildlife Service
it falls far short of the mandates or the National Marine Fisheries
of the ESA, demonstrating that the Service, should assess the risk of
EPA still has no real interest in pesticide registrations on
assessing the impacts of pesticides endangered species, and
on endangered species. In thirteen proposing the assessment be done
years, the EPA has made little outside of the consultation
progress on addressing pesticide process.175 The EPA is not fully
impacts to listed species. For qualified or equipped to assume
well over a decade the EPA has this role. Although EPA staff may
continuously referred to an ESPP Edison Insecticide dumping, have a strong understanding of
in the works – unfortunately, the pesticides, the agency does not
Edison, NJ
new ESPP proposed rule reveals have expertise about listed species
that the EPA was doing little in the interim and cannot, therefore, make requisite effect
to find a way to bring its pesticide registration determinations absent the FWS or the NMFS. In a
program into compliance with the ESA. Instead, nod to industry, this inadequate process would also
it is astonishingly obvious that the EPA was looking allow opportunities for pesticide manufacturers to
for ways to avoid its ESA obligations. contribute to the risk assessment while
limiting the opportunity of the expert agencies
(FWS and NMFS) to provide oversight.

Photo courtesy of NOAA 53

 [THE EPA’S SO-CALLED “ENDANGERED
SPECIES PROTECTION PROGRAM”]

The EPA’s risk assessment is also fundamentally One example of the EPA’s failure to regulate
flawed for numerous reasons. Problematically, pesticides harmful to endangered species is their
the risk assessment screenings are based on consultation with the FWS on re-registration of the
effects to organisms and not to habitat, ignoring insecticide endosulfan. A 2002 FWS letter to the
indirect and chronic effects. The risk EPA stated that “EPA’s discussion of the FWS’s
assessment only addresses active ingredients biological opinion on endosulfan use is inadequate.
of a pesticide, failing to take into account It fails to mention that jeopardy opinions were
degradate products. Moreover, the EPA’s models provided in 1989 on those pesticides used for 43
address one-time events on species, failing to assess species, including fish and mussel species, as well
the cumulative risk of multiple applications or the as the Santa Cruz long-toed salamander, Wyoming
use of multiple chemicals within a particular area. toad, Nashville crayfish, piping plover and wood
The models fail to incorporate site-specific stork. EPA failed to adopt 9 of the 13 reasonable
conditions such as water temperature, pH, changes and prudent actions to avoid jeopardy…EPA may
in precipitation, and climate. The assessment fails be in violation of the Endangered Species Act.”176
to address impacts of inert or other ingredients of The letter concludes: “the U.S. Fish and Wildlife
the pesticide. The EPA models also do not consider Service does not support the re-registration of
species distribution or density, endosulfan.” The FWS further
number of species actually informed the EPA that “we do
exposed, or the concentration not believe that EPA has
and duration of exposure. adequately evaluated or presented
the ecological risks of this
Of particular concern is how the pesticide...In the event that EPA
EPA estimates the toxicity levels proceeds with this registration, we
for species. Because their toxicity believe that sufficient information
levels are based on the median exists to assume this pesticide is
lethal concentration, the EPA’s likely to result in numerous
determination of allowable adverse effects to threatened
pesticide levels is based on and endangered species.”
mortality and not on potential
adverse impacts – while “may As of this writing there are 103
affect” is the relevant trigger for products with endosulfan for
consultations prescribed by general use and approximately
the ESA. Consequently, the EPA’s 60 special use registrations for
Cape May National Wildlife
ecological risk assessment Refuge contaminant area
endosulfan. As discussed in this
fails to adequately assess report endosulfan has been
sub-lethal effects which harm implicated in the decline of or is a
listed species. These failures, and a threat to numerous listed amphibians
misunderstanding of cause and effect, result in an such as the California red-legged frog, California
invalid and unlawful effects determination. tiger salamander, mountain yellow-legged
frog, and Barton Springs salamander.

Photo courtesy of NOAA 54

 THE EPA AND THE COURTS

Due to the EPA’s ongoing recalcitrance in complying with the ESA, many environmental
organizations have been forced to seek recourse in the courts. The following is a brief review of
resolved and pending lawsuits over the EPA’s neglect of endangered species.

Washington Toxics Coalition, et al. v. EPA Californians for Alternatives to Toxics,

et al. v. EPA
Concerned about the impacts pesticides pose to
endangered salmonid species in the Pacific In 2000, Californians for Alternatives to Toxics,
Northwest, the Northwest Coalition for Alternatives the Environmental Protection Information Center,
to Pesticides, Washington Toxics Coalition, Pacific and the Humboldt Watershed Council sued the EPA
Coast Federation of Fishermen’s Associations, and for failing to consult with the FWS and the NMFS
Institute for Fisheries Resources sued the EPA for before registering pesticides that may affect six
failing to conduct ESA Section 7 consultations with listed salmonids and 33 listed plant species or their
the NMFS. In July of 2002, the U.S. District Court critical habitats in California. The plaintiffs settled
in Seattle found that the EPA had failed to meet its the lawsuit with a Consent Decree, which
Section 7 obligations, noting that the EPA’s own establishes deadlines for the EPA to initiate
reports document the potentially-significant risks consultation on the potential effects of eighteen
posed by registered pesticides to salmonids. pesticides (acrolein, atrazine, bromacil, carbaryl,
Specifically, the Court found that the EPA failed chlorpyrifos, diazinon, diuron, glyphosate,
to consult on the potential impacts of 54 pesticides hexazinone, imazapyr, oxyfluorfen, 2,4-D-2
on salmon. The EPA was ordered to complete ethylhexyl ester, molinate, oryzalin, simizine,
effects determinations and initiate consultation by sulfometuron-methyl, triclopyr butoxyethyl
December 1, 2004. In January of 2004, the Court ester, and triclopyr triethylammonium). 178
also restricted the use of 38 pesticides near salmon
streams and required point-of-sale warnings on
products containing seven pesticides that have
polluted urban salmon streams. In May of 2004,
the pesticide industry group, CropLife America,
along with grower groups, requested a stay of the
January 2004 injunction while they appeal the
ruling to the Ninth Circuit Court of Appeals. The
District Court issued a strongly worded opinion
denying the industry request. Lambasting the EPA,
the Court stated that “if EPA had expended as
much effort in compliance with the ESA as it Frog deformities caused by pesticides
has expended in resisting this action, the
lawsuit might have been unnecessary.” 177

55
 [THE EPA AND THE COURTS]

Center for Biological Diversity v. Whitman Natural Resources Defense Council v. EPA

In April of 2002, the Center for Biological Diversity The Natural Resources Defense Council (NRDC)
sued the EPA for failing to consult on pesticides sued the EPA in August of 2003 for failing to
that may affect the California red-legged frog. The consult on the impact of the herbicide atrazine
suit identified 51 pesticides by name, and another on several listed species. The lawsuit focuses on
200 pesticides generally, that are used in habitat of the EPA’s failure to protect sea turtles in the
the red-legged frog. This suit is still pending. 179 Chesapeake Bay, salamanders in Texas, mussels
in Alabama, and sturgeons in Midwest
Center for Biological Diversity v. EPA waters from atrazine. Although atrazine is
banned in much of Europe, the EPA refuses to
Recognizing an ongoing recalcitrance from EPA ban the herbicide in the U.S. even though its
to address the serious problem pesticides pose to risk assessments acknowledge potential
numerous listed species, the Center for Biological harmful effects of atrazine – both directly and
Diversity filed a notice of intent to sue the EPA indirectly – on endangered fish, aquatic
in June of 2002 for violations of the ESA and invertebrates, terrestrial plants and aquatic plants.
for violations of the ESA and the Migratory
Bird Treaty Act (MBTA) for failure to consult or A recent University of California study
re-consult on the effects of 45 pesticides on over demonstrated that frog larvae exposed to extremely
300 listed species from Florida to Washington. low doses (0.01 ppb) of atrazine resulted in
the production of hermaphrodites.181 However,
Defenders of Wildlife, et al. v. EPA the EPA concluded that it is not possible to
ascertain the relationship of atrazine exposure
Defenders of Wildlife, the American Bird to developmental effects in amphibians.
Conservancy, and Florida Wildlife Federation filed The EPA’s independent Scientific Advisory
suit in October of 2002 against the EPA over the Panel (SAP) reviewed the literature on
registration of fenthion, a mosquitocide that is only developmental effects of atrazine on amphibians
used in three counties in Florida. Fenthion is and responded to the EPA’s conclusion.
extremely toxic to birds and has been linked to bird
kills, including the death of piping plovers, an
endangered species. Although the FWS advised
the EPA that fenthion poses “unreasonable adverse
effects” to the environment, particularly to species
protected under the ESA and the MBTA, and
suggested that the pesticide be cancelled, the EPA
refused to heed these warnings. In 2003, Bayer
Environmental Science voluntarily requested
that EPA cancel its registrations for all of
its products containing fenthion, stating that
the decision was based on the fact that
the market for the product was very limited. 180

56
 [THE EPA AND THE COURTS]

Natural Resources Defense Council v. EPA, Center for Biological Diversity v. EPA
cont.

The SAP noted that although it could not draw a In December of 2003, the Center for Biodiversity
conclusion regarding a concentration-response and the Save Our Springs Alliance brought another
relationship, it believes that the data support suit against the EPA for failing to consult on the
the hypothesis that the effect of atrazine on impact of six pesticides (including atrazine,
amphibian gonadal development occurs with a diazinon, metolachlor, prometon, and simazine) on
threshold concentration between 0.01 and 25 ppb. 182the Barton Springs salamander. All six pesticides
have been found in samples taken by the USGS
In a shocking move, the EPA has ignored the from Barton Springs, Texas. Additionally, the FWS
overwhelming scientific evidence on the harmful alerted the EPA that “it does not appear that
effects of atrazine, and in October 2003 approved EPA will be able to fulfill its legal responsibilities
the unrestricted use of this pesticide. Under a under Section 7(a)(2) of the [ESA] to ensure
court-approved consent decree with NRDC under that its proposed re-registration action [for
another atrazine suit focused on public health atrazine] is not likely to jeopardize the continued
concerns, the EPA was required to further assess existence of listed species or destroy or
the use of this dangerous chemical. 183 However, aversely modify designated critical habitat.”185
in a private agreement with Syngenta, the
primary producer of atrazine, the EPA required The FWS letter identified concern for the
Syngenta to monitor atrazine pollution from 2004 Barton Springs salamander given documented
to 2005 in only 3% of the 1,172 watersheds adverse affects to amphibians from atrazine
that are at high risk of atrazine contamination. exposure. Despite the FWS’s concerns, the
EPA has not initiated consultation for pesticide
The EPA has not required any measures to protect impacts to the Barton Springs salamander.
the public and wildlife from atrazine use in any of
these watersheds. The EPA also alarmingly
concluded that atrazine is not likely to cause
cancer in humans, despite the August 2003
report from the SAP, which found that atrazine
may cause cancer and that the EPA’s focus on
prostate cancer was potentially misleading.184

57
 DISCUSSION

Fortunately, much progress has been made by oversight. Section 7 regulations require FWS/
environmental and public health organizations in NMFS concurrence for agency determinations that
bringing attention to pesticide issues. As an action is not likely to adversely affect a listed
more scientific studies are released documenting species. If either FWS or NMFS does not concur
the adverse impacts common pesticides with the agency’s determination, the agency must
have on our environment and public health, enter into formal consultation. Under the EPA’s
education and awareness of these issues grows. proposed regulation this important check would be
eliminated, giving the EPA unilateral power in
However, the Bush Administration and the EPA determining whether a pesticide must be
continue to employ “avoid and delay” tactics to consulted on. This proposed rule is a clear attempt
protect the chemical industry. For more than by the Bush Administration to avoid litigation
thirteen years, the EPA has failed to consult forcing the EPA to consult on pesticide impacts to
under the ESA on the effects of pesticide species, and yet another chapter in the Bush
registrations, and delayed implementation of an Administration’s litany of corporate protectionism.
Endangered Species Protection Program, all the
while jeopardizing numerous listed species from Unsurprisingly, the proposed rule and the new
pesticide use. The EPA has shown a callous ESPP were strongly advocated for by the FIFRA
disregard for the scientific findings that Endangered Species Task Force (FESTF),
continue to document a committee composed of
adverse impacts to fourteen agro-chemical
wildlife and humans. companies. The EPA
is shifting the focus
The EPA has taken striking of FESTF, originally
and unnerving measures to formed to address data
avoid ESA conflicts with requirements, to making
pesticide use. In January of policy recommendations
2004, the EPA released its to weaken the ESA.
proposed Joint Counterpart Through FESTF the EPA
Endangered Species Act has provided for the
Section 7 Consultation agro-chemical industry to
Regulations.186 If finalized, lobby behind closed doors
this regulation will River system in Montana as an “advisory committee”
circumvent the ESA Section for weaker ESA protections.
7 consultation process altogether, not to mention Meanwhile, the public is left to participate
Congressional intent, allowing the EPA itself to in a rulemaking process dominated by a
decide whether pesticides are likely to adversely heavily financed agro-chemical and farm
affect listed species without any FWS or NMFS grower lobbying effort which already
has close contact with the rule makers.

Photo courtesy of USFWS 58

 [DISCUSSION]

Concerned about EPA’s efforts to avoid compliance Amphibians are a barometer of environmental
with the ESA through rule changes, 66 members health - adverse impacts to amphibians are a sign
of Congress recently sent a letter to the EPA, that our ecosystems are under stress. The EPA’s
Secretary Norton and Secretary Evans, “expressing attempt to ignore the documented and disturbing
serious concern….”187 The Representatives noted impacts of pesticides to amphibians by dismissing
that the proposed regulation “unilaterally eliminates the science will not alleviate this systemic problem.
expert review of the scientific evidence that serves Additionally, these problems are not limited to
as an independent check and safeguard…[,] would wildlife. Neurological and sexual developmental
allow flawed science to be the basis for dysfunctions also affect humans, and especially
determining whether and the extent to which children. 191 A recent study found that women who
endangered species must be protected from were infertile were 27 times more likely to have
pesticides…[and] would give the chemical industry mixed or applied herbicides in the two years prior
special participation rights that are not shared by to attempting conception than women who were
the public or the workers who are exposed to these fertile.192 Farmers, manufacturers and applicators
chemicals.”188 The letter of pesticides have an
concluded that “[t]hese increased risk of certain
proposed regulations types of malignancies,
are a step backward for especially lip, prostate,
both wildlife and farm or testicular cancer,
worker protections.”189 lymphoma, leukemia,
brain tumors, pancreatic
Pesticides are cancer, sarcoma and
contaminating our air multiple myeloma.193
and water while the EPA The EPA’s 1997
fails to adequately regulate Special Report on
their use to protect our Environmental Endocrine
environment. The USGS Disruption notes that
has documented the “possible human health
widespread contamination endpoints” affected by
of our nation’s water-ways Wetlands in Oregon endocrine-disrupting
and aquatic species. chemicals include
Pesticides have been identified as one of the fifteen breast cancer, endometriosis, testicular and
leading causes of impairment for streams on the Clean prostate cancers, abnormal sexual development,
Water Act’s section 303(d) list of impaired waters. 190 reduced male fertility, neurobehavioral
effects and immune system suppression. 194

Photo courtesy of USFWS 59

 [DISCUSSION]

The science is astounding: pesticides are in our Also available is use of “beneficial” insects
waterways, groundwater, air, and soils. They are including predators and parasitoids such as
also being absorbed daily by plants, wildlife, and lady beetles and various wasps, as well as
humans.The EPA, discouragingly, has shown more certain nematodes that are used for insect
interest in assisting the agro-chemical industry control. Organic agriculture and less harmful
than ensuring human and wildlife safety. In fact, alternatives to chemical pesticides such as organic
much of the studies and data supporting the pesticides and IPM are better in the long term for
registration documents are compiled by the the health of farmers, farm workers, America’s
registrants themselves. The EPA often dismisses communities and wildlife.It is a testament to
environmental concerns in the face of hard the success achieved by the environmental
science, and steadfastly refuses to adopt any community that pesticide use has become such
mandatory measures to limit pesticide use. This a hotly debated issue. However, there is
catering to the chemical industry must end much work to be done before the EPA actually
if the EPA is truly concerned about protecting functions as an environmental “protection” agency.
humans and wildlife from these toxins.

There are safe and The EPA pesticide

effective alternatives to registration process
most of the harmful is not adequately
pesticides registered for safeguarding human
use by the EPA. There health and wildlife
are numerous effective because the agro-chemical
organic pesticides industry is allowed to
such as botanicals, control the process
microbials, synthetics and the “science” of
and minerals. A strategy risk analysis. The
known as Integrated environmental and public
Pest Management health communities
(IPM) relies upon must continue to apply
information on the life Gulf of Mexico Refuge pressure on the EPA to
cycles of pests and their follow the laws created
interaction with the environment to manage pest to protect humans and wildlife from these
damage by the most economical means, and with dangerous chemicals. The Bush administration
the least possible hazard to people, property, and proposal to allow the EPA to self-consult on the
the envronment. IPM relies primarily on impacts of pesticides must be scrapped: with the
non-chemical means – such as controlling undue influence of the agrochemical industry this
climate, food sources, and building entry points - policy is the equivalent of the fox guarding the
to prevent and manage pest infestation. henhouse. The EPA’s pesticide registration
Chemical treatments are used only in a crisis program must be reformed to comply with
situation threatening rapid losses or when pests the Endangered Species Act and prevent
fail to succumb to more conservative methods. registration and use of harmful pesticides that
are causing jeopardy to humans and wildlife.

Photo courtesy of USFWS 60

 ENDNOTES

1 19
Environmental Protection Agency Office of Pesticide Sparling, D.W., G.M. Fellers, and L.L. McConnell,
Programs, FY 2002 Annual Report, Promoting Safety for 2001. Pesticides and Amphibian Population Declines in
America’s Future, p. 6. California, Environmental Toxicology and Chemistry,
2 Ibid. Vol.20, No.7, 1591-1595; see also Lenoir, J.S., et al.,
3 U.S. Geological Survey. 1999. Quality of Our Nation’s 1999, Summertime transport of current-use pesticides
Waters, Nutrients and Pesticides, USGS, Circ. 1225. from California’s Central Valley to the Sierra Nevada
4 Environmental Protection Agency, “National Home and Mountain Range, Environmental Toxicology and
Garden Pesticide Use,” Pesticide Industry Sales and Chemistry, 18:2715.
20 Sparling, et al. 2001.
Usage: 1990 and 1991 Market Estimates, Washington
21 Kegley, S., et. al., Secondhand Pesticides: Airborne
D.C., Fall 1992, 3.
5 Aspelin, A. L. 1997. Pesticides Industry Sales and Pesticide Drift in California, Californians for Pesticide
Usage: 1994 and 1995 Market Estimates, U.S. Reform, available at <<www.panna.org/resources/
Environmental Protection Agency, Office of Prevention, documents/secondhandDriftAvail.dv.html>>.
22 U.S. Environmental Protection Agency, Pesticide
Pesticides and Toxic Substances, Biological and
Economic Analysis Division, Washington D.C., August Registration Notice 2001-X (8/9/01) Draft (Spray and
1997, 2-3. Dust Drift Label Statements for Pesticide Products),
6 U.S. Geological Survey. 1999. Pesticide National available at <<http://www.epa.gov/oppmsd1/PR_Notices/
Synthesis Project, Pesticides in the Nation’s Water prdraft-spraydrift801.htm>>.
23 U.S. Environmental Protection Agency, Dec. 1999,
Resources—Water Environment Federation Briefing
Series, March 19, 1999, Capitol Building, Washington, Spray Drift of Pesticides, available at <<http://
D.C.. www.epa.gov/pesticides/factsheets/spraydrift.htm>>.
7 U.S. Geological Survey, 1999, Pesticides in Stream 24 Supra note 22.

25 Atrazine Interim Re-registration Eligibility Decision,

Sediment and Aquatic Biota, USGS Fact Sheet 092-00.
8 Larson, S.J. et al, Pesticides in Streams of the U.S.— Jan 31, 2003, available at <<http://www.epa.gov/oppsrrd1/
Initial Results from the National Water-Quality reregistration/atrazine/>>, p. 93.
26 See e.g. Chloropyrifos Interim Deregistration Eligibility
Assessment Program (“NWQA”), USGS Water-
Resources Investigation Report 98-4222, 1999. Decision, Sept. 28, 2001, available at <<http://
9 Supra note 7. www.epa.gov/oppsrrd1/op/chlorpyrifos.htm>>, p. 95-97
10 Ibid. (emphasis added).
11 Ibid. 27 Supra note 3.

12 Cox, C., 1995. Pesticide Drift-Indiscriminately from 28 Supra note 8.

29 Ibid.
the Skies, Journal of Pesticide Reform, Spring 1995,
30 Supra note 3.
Vol.15, No.1.
13 National Research Council, Board on Agriculture, 31 Supra note 8.

32 Ibid.
Committee on Long-Range Soil and Water
33 U.S. Environmental Protection Agency. 1991. Water-
Conservation. 1993. Soil and water quality: An agenda
for agriculture, Washington, D.C., National Academy quality criteria summary: U.S. EPA, Office of Water,
Press, 323-324. Office of Science and Technology, Health and Ecological
14 U.S. Congress, Office of Technology Assessment. Effects Division.
34 Canadian Council of Resource and Environment
1990. Beneath the bottom line: Agricultural approaches
to reduce agrichemical contamination of groundwater, Ministers. 1991. Canadian water quality guidelines:
Report No. OTA-4-418, Washington, D.C., U.S. GPO. Ottawa, Ontario, Environment Canada, Inland Waters
15 Supra note 12. Directorate, Water Quality Branch.
16 Ibid. 35 International Joint Commission. 1977. New and revised

17 Ibid. Great Lakes water quality objectives, International Joint

18 Ibid. Commission Canada and United States.
36 Supra note 8.

37 Larson, S.J. et al, U.S.G.S Pesticide National Synthesis

Project, Pesticides in the Nation’s Water Resources.

61
 [ENDNOTES]

38 50
Supra note 8, citing Goolsby et al, Persistence of Gilbertson, M. K., G. D. Hafner, K. G. Drouillard, A.
herbicides in selected reservoirs in the Midwestern United Albert, and B. Dixon. 2002. Immunosuppression in the
States, 1993; Kalkhoff et al., Degradation of Northern Leopard Frog (Rana Pipiens) Induced by
chloroacetanilide herbicides, Environmental Science and Pesticide Exposure. Environmental Toxicology and
Tech., v.32, no.11, 1998. Chemistry 22(1):101–110.
39 Supra note 8. 51 Welshons, W.V., et al. 1999. Low-dose bioactivity of

40 Arnold, S. F., et al. 1996. Synergistic Activation of xenoestrogens in animals: fetal exposure to low doses of
Estrogen Receptor with Combinations of Environmental methoxychlor and other estrogens increases adult prostrate
Chemicals. 272 Science 1489-1492 (June 7, 1996). size in mice, Toxicology and Industrial Health: An
41 See EPA Science Policy Council, Handbook for Non- International Journal, Jan-March 1999, Vol.15, Nos. 1&2,
Cancer Health Effects Valuation, available at <<http:// 12-25.
52 Nagler, J.J., et al. 2001. High Incidence of a Male-
www.epa.gov/osp/spc/Endoqs.htm>>.
42 Center for Bioenvironmental Research, Environmental Specific Genetic Marker in Phenotypic Female Chinook
Estrogens, Wildlife and Human Health Effects, available Salmon from the Columbia River, Environmental Health
at <http://www.som.tulane.edu/ecme/eehome/basics/ Perspectives 109:67-69.
53 Willingham, E.T., et al. 2000. Embryonic Treatment
eeeffects/>.
43 Ibid. with Xenobiotics Disrupts Steroid Hormone Profiles in
44 Short, P. and T. Colborn. 1999. Pesticide Use in the U.S. Hatchling Red-Eared Slider Turtles (Trachemys scripta
and Policy Implications: A Focus on Herbicides, elegans), Environmental Health Perspectives 108(4): 329-
Toxicology and Industrial Health: An International 332.
54 Dodson, S.I., et al. 1999. Dieldrin Reduces Male
Journal, Jan-March 1999, Vol.15, Nos. 1&2, 240-275.
45 Park, D., S.C. Hempleman, and C. R. Propper. 2001. Production and Sex Ratio in Daphnia (Galeata mendotae),
Endosulfan exposure disrupts pheremonal systems in the Toxicology and Industrial Health: An International
red-spotted newt: A mechanism for subtle effects of Journal, Jan-March 1999, Vol.15, Nos. 1&2, 192-199.
55 Harris, M., et al. Apple Orchard Insecticide and
environmental chemicals, Environmental Health
Perspectives 109:669-673. Fungicide Effects on Ranid Populations in Ontario,
46 Whitcomb, C.E. 1999. An Introduction to ALS- University of Guelph, Ontario, abstract found at
Inhibiting Herbicides, Toxicology and Industrial Health: <www.pmac.net/ranid.htm>.
56 La Clair, J.J., J.A. Bantle and J. Dumont. 1998.
An International Journal, Jan-March 1999, Vol.15, Nos.
1&2, 231-239. Photoproducts and metabolites of a common insect
47 Reylea, R.A. and N. Mills. 2001. Predator-induced growth regulator produce developmental deformities in
stress makes the pesticide carbaryl more deadly to gray Xenopus, Environmental Science and Technology, 32:
treefrog tadpoles, Hyla versicolor, Proceedings of the 1453-1461.
57 Gray, L.E., et al. 1999. The estrogenic and
National Academy of Sciences, USA, 98:2481-2496; see
also Reylea, R.A., 2004, The growth and survival of five antiandrogenic pesticide methoxychlor alters the
amphibian species exposed to combinations of pesticides, reproductive tract and behavior without affecting pituitary
Environ. Toxico. Chem., In Press; Reylea, R.A., 2004, size or LH and prolactin secretion in male rats, Toxicology
Synergistic impacts of malathion and predatory stress on and Industrial Health: An International Journal, Jan-March
six species of North American tadpoles, Environ. Toxicol. 1999, Vol.15, Nos. 1&2, 37-47.
58 Porter, W.P., et al. 1999. Endocrine, Immune, and
Chem. 23:1080-1084; Reylea, R.A., 2003, Predator cues
and pesticides: A double does of danger for amphibians, Behavioral Effects of Aldicarb (Carbamate), Atrazine
Ecol. Applic. 13:1515-1521. (Triazine) and Nitrate (Fertilizer) Mixtures at
48 Hayes, T.B., et al., 2002, Hermaphroditic, Groundwater Concentrations, Toxicology and Industrial
demasculinized frogs after exposure to the herbicide Health: An International Journal, Jan-March 1999, Vol.15,
atrazine at low ecologically relevant doses, Proc. Natl. Nos. 1&2, 133-150.
59 Colborn T, F. Vom Saal, and P. Short (eds.). 1998.
Acad. Sci., April 16, 2002, Vol.99, Issue 8, 5476-5480.
49 Ibid. Environment Endocrine-Disrupting Chemicals: Neural,
Endocrine, and Behavioral Effects, Princeton, N.J.:
Princeton Scientific Publishing, 1998; 1-9.

62
 [ENDNOTES]

60 75
Palmer, W.E. P.T. Bromely, and J.R. Anderson, Jr., Final Rule to List the Santa Barbara County Distinct
Wildlife and Pesticides—Corn, North Carolina Population Segment of the California Tiger Salamander as
Cooperative Extension Service AG-463-2. Endangered, 65 Fed. Reg. 57242, 57259 (Sept. 21, 2000);
61 Kegley, S, L. Neumeister, and T. Martin, Disrupting the Final Rule to List the Sonoma County Distinct Population
Balance: Ecological Impacts of Pesticides in California, Segment of the California Tiger Salamander as
available at <www.panna.org/panna/resources/documents/ Endangered, 68 Fed. Reg. 13497-13520 (March 19, 2003).
76 Final Rule to List the Sonoma County Distinct
disruptingSum.dv.html>.
62 American Bird Conservancy, <<http:// Population Segment of the California Tiger Salamander as
www.abcbirds.org/pesticides/pesticideindex.htm>>. Endangered, 68 FR 13497, 13520 (March 19, 2003).
63 Cox, Caroline. 1991, “Pesticides and birds: from DDT 77
Proposed Endangered Status for the Southern California
to today’s poisons” , Vol. 11, No. 4 , Winter 1991, pp.2-6, Distinct Vertebrate Population Segment of the Mountain
available at <<http://www.eap.mcgill.ca/magrack/jpr/ Yellow-Legged Frog, 64 Fed. Reg. 71714-71722 (Dec. 22,
jpr_14.htm>>. 1999).
64 Williams, Ted, 1993, Hard News on “Soft” Pesticides, 78
Cory, L., P. Fjeld, and W. Serat 1970. Distribution
Audubon Magazine, March-April 1993. patterns of DDT residues in the Sierra Nevada mountains.
65 Ingram, M., G.P. Nabhan, S. Buchmann, 1996, Our Pesticides Monitoring Journal 3(4): 204-211.
Forgotten Pollinators: Protecting the Birds and Bees, 79
Taylor, S.K., et al. 1999. Effects of malathion on disease
Global Pesticide Campaigner, Vol.6, No.4, Dec. 1996, susceptibility in Woodhouse’s toads. J. Wildlife Diseases
PANNA, <www.pmac.net/birdbee.htm>. 35(3):536-541.
66 Nabhan, G.P., 1996, Pollinator Redbook, Volume One: 80
Davidson, C., et al. 2001. Declines of the California red-
Global list of threatened vertebrate wildlife, wildlife legged frog: Climate, UV-B, habitat, and pesticides
species serving as pollinators for crops and wild plants, hypotheses. Ecological Applications 11:464-479;
<<www.desertmuseum.org/conservation/fp/ Davidson, C., et al. 2002. Spatial tests of the pesticide
redbook.html>>; Kearns, C.A., D.W. Inouye, and N.M. drift, habitat destruction, UV-B, and climate change
Waser, 1998, Endangered mutualisms: the conservation of hypotheses for California amphibian declines.
plant-pollinator interactions, Annu. Rev. Ecol. Syst., 29: Conservation Biology (6):1588-1601
83-112. 81
U.S. Fish and Wildlife Service, 2002, Recovery Plan for
67 Supra note 64. the California Red-Legged Frog (Rana aurora draytonii);
68 U.S. Fish and Wildlife Service, Division of see also U. S. Fish and Wildlife Service. 2000. Draft
Environmental Quality, Pollinator Fact Sheet, available at recovery plan for the California red-legged frog (Rana
<http://contaminants.fws.gov/Issues/Pollinators.cfm> aurora draytonii). Region 1 U. S. Fish and Wildlife
69 See <<http://endangered.fws.gov/ Service, Portland, Oregon.
wildlife.html#Species>>. 82
Berrill, M., et al. 1993. Effects of Low Concentrations
70 U. S. Fish and Wildlife Service. 1998. Recovery Plan for of Forest-Use Pesticides on Frog Embryos and Tadpoles.
Upland Species of the San Joaquin Valley, California. Environ. Toxicol. Chem. 13(4):657-664..
71 Endangered Status for the Buena Vista Lake Shrew, 67 83
Designation of Critical Habitat for the Arroyo Toad, 66
Fed. Reg. 10101-01 (March 6, 2002). Fed. Reg. 9414-9415 (Feb. 7, 2001).
72 Ibid. 84
U. S. Fish and Wildlife Service. 1998. Recovery Plan for
73 Pacific Islands U.S. Fish and Wildlife Service, Upland Species of the San Joaquin Valley, California.
Threatened and Endangered Animals in the Hawaiian 85
Determination of Threatened Status for the Giant Garter
Islands, available at <http://pacificislands.fws.gov/wesa/ Snake. 58 Fed. Reg. 54053-54066 (October 20, 1993).
hrybatindex.html>. 86
Factors for Decline, A Supplement to the Notice of
74 Final Rule Determining Endangered Status for the Determination for West Coast Steelhead Under the
Southwestern Willow Flycatcher, 60 Fed. Reg. 10694, Endangered Species Act, National Marine Fisheries
10713 (Feb. 27, 1995). Service, 1996.
87
U. S. EPA. 2004. Pesticide Threats to Endangered
Species: Case Studies, January 2004.
88
U. S. EPA. 2001. Interim Reregistration Eligibility
Decision for Azinphos methyl, October 30, 2001.

63
 [ENDNOTES]

89 Dodson, J. J. and C. I. Mayfield. 1979. The Dynamics of 100

Final Determination of Critical Habitat for the Bay
and Behavioral Toxicology of Aqua-Kleen (2,4-D Checkerspot Butterfly (Euphydryas editha bayensis), 66
Butoxyethanol Ester) as Revealed by the Modification of Fed. Reg. 21450 (April 30, 2001).
Rheotropism in Rainbow Trout. Transactions of the 101
Determination of Endangered Status for the Carson
American Fisheries Society 108:632-640. Wandering Skipper, 67 Fed. Reg. 51116 (Aug. 7, 2002);
90 Wells, D. E. and A. A Cowan. 1982. Vertebral Dysplasia and Emergency Rule to List the Carson Wandering
in Salmonids Cause by the Herbicide Truifluralin. Envir. Skipper as Endangered, 66 Fed. Reg. 59537 (Nov. 29,
Pollut. 29:249-260. 2001).
91 U. S. Geological Survey. 2004. National Water-Quality 102
Endangered Status for Willamette Daisy, Fender’s Blue
Assessment (NAWQA) Program, 1998-2000. Circulars Butterfly and Threatened Status for Kincaid’s Lupine, 65
1144, 1159, 1161, 1215, 1216, January 22, 2004. Fed. Reg. 3875 (Jan. 25, 2000).
92 Moore, A. and C. P. Waring. 1996. Sublethal Effects of 103
Endangered Status for Three Aquatic Snails, and
the Pesticide Diazinon on Olfactory Function in Mature Threatened Status for Three Aquatic Snails in the Mobil
Male Atlantic Salmon Parr. Journal of Fish Biology River Basin of Alabama, 63 Fed. Reg. 57610, 57616 (Oct.
48:758-775. 28, 1998).
93 Recovery Plan for the Sacramento/San Joaquin Delta 104
Final Rule to List Two Cave Animals from Kauai,
Native Fishes, U.S. Fish and Wildlife Service, Portland, Hawaii, 65 Fed. Reg. 2348, 2353 (Jan. 14, 2000).
Oregon, 1996. 105
Proposed Designation of Critical Habitat for Deinandra
94 Determination of Threatened Status for the Sacramento conjugens (Otay tarplant), 66 Fed. Reg. 32052, 32056
Splittail, 64 Fed. Reg. 5963, 5974-80 (Feb. 8, 1999). (June 13, 2001); Final Rule for Endangered Status for
95 Kuivila KM. 2000. Pesticides in the Sacramento-San Astragalus pycnostachyus var. lanosissimus (Ventura
Joaquin Delta: state of our knowledge. Presented at marsh milk-vetch), 66 Fed. Reg. 27901, 27904 (May 21,
CALFED Bay-Delta Program Science Conference, Oct. 3- 2001).
5, 2000, Sacramento, CA. Abstract (#66), summary, and 106
Threatened Status for the Plant Thelypodium howellii
notes available at <<http://www.iep.water.ca.gov/calfed/ ssp. spectabilis (Howell’s spectacular thelypody), 64 Fed.
sciconf/2000/publications/>>; see also Houston JR, Allen Reg. 28393, 28395 (May 26, 1999).
LA, Kuivila KM. 2000. Seasonal patterns and factors 108
Endangered Status for the Plant Plagiobothrys hirtus
controlling the occurrence of dissolved pesticides in the (Rough Popcornflower), 65 Fed. Reg. 3866, 3871 (Jan.
Sacramento-San Joaquin Delta. Presented at CALFED 25, 2000).
108 Determination of Endangered Status for Two Larkspurs
Bay-Delta Program Science Conference, Oct. 3-5, 2000,
Sacramento, CA. Abstract (#169), summary, and notes From Coastal Northern California, 65 Fed. Reg. 4156
available at <<http://www.iep.water.ca.gov/calfed/sciconf/ (Jan. 26, 2000).
109 Final Rule to List Silene spaldingii (Spalding’s
2000/publications/>>.
96 Moon GE, Kuivila KM, Orlando JL. 2000. Exposure of catchfly) as Threatened, 66 Fed. Reg. 51598 (Oct. 10,
delta smelt to dissolved pesticides during larval and 2001).
110 Spalding’s catchfly Factsheet, U.S. Fish and Wildlife
juvenile stages in 1998 and 1999. Presented at CALFED
Bay-Delta Program Science Conference, Oct. 3-5, 2000, Service, available at <http://idahoes.fws.gov/Fact/
Sacramento, CA. Abstract (#183), summary, and notes Spaldings.html>.
111 Determination of Endangered Status for the Cactus
available at <<http://www.iep.water.ca.gov/calfed/sciconf/
2000/publications/>>. Ferruginous Pygmy-Owl in Arizona, 62 Fed. Reg. 10730-
97
Endangered Status for the Ohlone Tiger Beetle, 66 Fed. 10744 (March 10, 1997).
112 Listing of the Chiricahua Leopard Frog (Rana
Reg. 50340, 50348 (Oct. 3, 2001).
98
Threatened Status for the Santa Ana Sucker, 65 Fed. chiricahuensis), 67 Fed. Reg. 40789 (June 13, 2002).
113 See supra note 81.
Reg. 26438 (2000).
114 Final Rule to List the Barton Springs Salamander as
99
Determination of Endangered Status for the Callippe
Silverspot Butterfly and the Behren’s Silverspot Butterfly Endangered, 62 Fed. Reg. 23377, 23386-91 (April 30,
and Threatened Status for Alameda Whipsnake, 62 Fed. 1997).
Reg. 64306, 64314 (Dec. 5, 1997).

64
 [ENDNOTES]

115 Letter from Everett Wilson, Chief, Division of 131

Fish and Wildlife Service Endangered Species
Environmental Quality, U.S. Fish and Wildlife Service to Factsheet for the Mitchell’s Satyr Butterfly, available at
Kimberly Nesci Lowe, Chemical Review Manager, EPA, <http://midwest.fws.gov/endangered/insects/
June 27, 2002 (on file with the Center for Biological mitchell.html>.
Diversity). 132
U. S. EPA. 1998. Pesticides and Endangered Species,
116 U. S. Fish and Wildlife Service. 1992. Recovery Plan September 1998; see also U.S. Fish and Wildlife Service
for the Kemp’s Ridley Sea Turtle, Lepidochelys kempii. Endangered Species Factsheet for the Northern
117 U. S. Fish and Wildlife Service. 1993. Desert Pupfish Monkshood, available at <http://midwest.fws.gov/
(Cyprinodon macularious) Recovery Plan. eco_serv/endangrd/ing_coll/plants/monkshoo.html>.
118 Final Rule to List Three Aquatic Invertebrates in Comal 133
Determination of Endangered Status for the Scaleshell
and Hays Counties, Texas, as Endangered, 62 Fed. Reg. Mussel, 66 Fed. Reg. 51322, 51334 (Oct. 9, 2001).
66295, 66300 (Dec. 18, 1997). 134
Ohlendorff, H. M., E. E. Klass, and T. E. Kaiser. 1978.
119 Final Rule to List Nine Bexar County, Texas Organochlorine Residues and Eggshell Thinning in Wood
Invertebrate Species, 65 Fed. Reg. 81419 (Dec. 26, 2000). Storks and Anhingas. Wilson Bulletin 90(4):606-618.
120 Determination of Endangered Status for Astragalus 135
U.S. Fish and Wildlife Service, Species Accounts – The
holmgreniorum (Holmgren milk-vetch) and Astragalus Gray Bat, available at <http://endangered.fws.gov/i/a/
ampullarioides (Shivwits milk-vetch), 66 Fed. Reg. saa4l.html>.
49560, 49564 (Sept. 28, 2001). 136
U. S. Fish and Wildlife Service. 1999. South Florida
121 Final Rule to Reclassify the Bald Eagle From Multi-Species Recovery Plan. U. S. Fish and Wildlife
Endangered to Threatened in All of the Lower 48 States, Service. 1999. South Florida Multi-Species Recovery
60 Fed. Reg. 35999 36010 (July 12, 1995). Plan.
122 National Wildlife Health Center Mortality Reports, 137
Final Rule to List the Mississippi Gopher Frog Distinct
available at <http://www.nwhc.usgs.gov/research/ Population Segment of the Dusky Gopher Frog as
mortality/mortality.html>. Endangered, 66 Fed. Reg. 62993-01 (Dec. 4, 2001).
123 See Elliott, J. E., L. K. Wilson, K. M. Langelier, P. 138
Reclassification of Alabama Cavefish from Threatened
Mineau, and P. H. Sinclair. 1997. Secondary poisoning of to Endangered, 53 FR 37968-37970 (September 28,
birds of prey by the organophosphorus insecticide, 1988).
phorate. Ecotoxicology, vol. 6, no. 4, pp. 219-231, Aug 139
Designation of Critical Habitat for the Spruce-fir Moss
1997; also Wilson, L., M. Harris, and J. Elliot. Impact of Spider, 66 Fed. Reg. 35547, 3550 (July 6, 2001).
agricultural pesticides on birds of prey in the lower Fraser 140
U. S. Fish and Wildlife Service letter to the
Valley. Pacific Wildlife Research Centre, Environment Environmental Protection Agency, July 5, 2002 (on file
Canada, Delta, B.C. with the Center for Biological Diversity).
124 Final Rule to Reclassify the Bald Eagle From 141
Speake, D.W. 1993. Indigo snake recovery plan
Endangered to Threatened in All of the Lower 48 States, revision. Final report to the U.S. Fish and Wildlife
July 12, 1995, 60 FR 35999 36010. Service; Jacksonville, Florida.
125 U. S. Fish and Wildlife Service. 1993. Recovery Plan 142
Supra note 136.
for the Pallid Sturgeon (Scaphirhynchus albus). 143
Patuxent Wildlife Research Center, Species Decline:
126 Determination of Endangered Status for the Hine’s Contaminants as a Contributing Factor, search results,
Emerald Dragonfly (Somatochlora hineana), 60 Fed. Reg. available at <http://www.pwrc.nbs.gov/pattee/
5267, 5270 (Jan. 26, 1995). herpsshortserch.cfm>.
127
Final Rule to List the Illinois Cave Amphipod as 144
Final Rule to List the Vermilion Darter as 66 Fed. Reg
Endangered, 63 Fed. Reg. 46900, 46903 (Sept. 3, 1998). 59367 (Nov. 28, 2001).
128
Ibid. 145
Endangered Status for the Armored Snail and Slender
129
Ibid. Campeloma, 65 Fed. Reg. 10033, 10036 (Feb. 25, 2000).
130
U.S. Fish & Wildlife Service, Endangered Species 146
Proposed Designation of Critical Habitat for the
Factsheet for the Hungerford’s Crawling Water Beetle, Carolina Heelsplitter, 66 Fed. Reg. 36229, 36230 (July 11,
available at <http://midwest.fws.gov/Endangered/insects/ 2001); Proposed Designation of Critical Habitat for the
hungerfo.html>.; see also Determination of Endangered Appalachian Elktoe, 66 Fed. Reg. 9540-9546 (Feb. 8,
Status for Hungerford’s Crawling Water Beetle, 59 Fed. 2001).
Reg. 10580 (March 7, 1994).
65
 [ENDNOTES]

164
147
Determination of Endangered Status or Threatened Audubon Society Watch List, available at <<http://
Status for Five Aquatic Snails in South Central Idaho, 57 www.audubon.org/bird/watchlist/index.html>>.
165 7 U.S.C §§ 136-136y.
Fed. Reg. 59244, 59252 (Dec. 14, 1992).
166 7 U.S.C. § 136d(b).
148
Emmel, T. C. 1986. Pesticide Effects on the Survival of
167 16 U.S.C. § 1536(a)(2).
the Schaus Swallowtail Butterfly. Final Report to
168 50 C.F.R. § 402.16 (reinitiation of consultation).
Elizabeth Ordway Dunn Foundation, Inc. University of
169 50 C.F.R. § 222.102.
Florida, Gainesville, Florida.
170 16 U.S.C. § 1536(o)(2).
149
Ibid.
171 54 Fed. Reg. 27984 (July 3, 1989).
150
U. S. Fish and Wildlife Service. 1993. Recovery Plan
172 Letter from Jamie Rappaport Clark, Director, Fish and
for U. S. Population of Loggerhead Turtle (Caretta
caretta). Wildlife Service to Susan Wayland, Acting Assistant
151
U. S. EPA. 2002. Atrazine, Registration Eligibility Administrator for Prevention, Pesticides and Toxic
Science Chapter, Environmental Fate and Effects Chapter, Substances, EPA (June 9, 2000) (on file with the Center
April 22, 2002. for Biological Diversity).
173 67 Fed. Reg. 71549 (Dec. 2, 2002).
152
Determination of Endangered Status for the Dwarf
174 Tennessee Valley Authority v. Hill, 437 U.S. 153, 174
Wedge Mussel, 55 Fed. Reg. 9447-9451 (March 14,
1990). (1978).
175 68 Fed. Reg. 3786 (Jan. 24, 2003) and 69 Fed. Reg.
153
Final Endangered Status for a Distinct Population
Segment of Anadromous Atlantic Salmon (Salmo salar) in 4465 (Jan. 30, 2004).
176 Letter from Jamie Rappaport Clark, Director, Fish and
the Gulf of Maine, 65 Fed. Reg. 69459-69483 (November
17, 2000). Wildlife Service to Susan Wayland, Acting Assistant
154
McFarland, C. A. 1998. Potential Agricultural Administrator for Prevention, Pesticides and Toxic
Insecticide Exposure of Indiana Bats (Myotis sodalist) in Substances, EPA (June 9, 2000) (on file with the Center
Missouri. Unpublished M. S. Thesis, University of for Biological Diversity).
177 See Earthjustice’s website for more information about
Missouri-Columbia. 256 pp.
155
BHE Environmental, Inc. 1999. 1998 Annual Report: the lawsuit and the court orders, <http://
Implementation of Reasonable and Prudent Measures & www.earthjustice.org/urgent/display.html?ID=46>.
178 See Californians for Alternatives to Toxics’ website for
Terms and Conditions in the Biological Opinion at Fort
Leonard Wood. Unpublished Report. 199 pp. more information about its work to protect endangered
156
Beebee, T. J. C. 1973. Observations Concerning the species and humans from pesticides <at http://
Decline of the British Amphibia. Biological Conservation www.alternatives2toxics.org/>.
179 See the Center for Biological Diversity’s website for
5:20-24.
157
Proposed Endangered Status for Bufo genuiogrts more information about this lawsuit at <http://
baxteri (Wyoming Toad), 48 Fed. Reg. 3794-3796 www.biologicaldiversity.org/swcbd/species/rlfrog/
(January 27, 1983). index.html>.
180 See Fenthion: Product Registrations Cancellation
158
Final Rule to List the Topeka Shiner as Endangered,
63 Fed. Reg. 69008, 69014 (Dec. 15, 1998). Order, 68 Fed. Reg. 55609-55611 (Sept. 26, 2003). EPA
159
Final Rule to List the Arkansas River Shiner as approved the request to cancel Bayer’s registrations for
Threatened, 63 Fed. Reg. 64772 (Nov. 23, 1998). fenthion in May of 2003. See 68 Fed. Reg. 32495-32497
160
Final Rule to List the Preble’s Meadow Jumping (May 30, 2003).
181 Supra note 48.
Mouse as a Threatened Species, 63 Fed. Reg. 26517-
182 SAP Report No. 2003-01, A Set of Scientific Issues
26530 (May 13, 1998).
161 Neosho Madtom Determined to be Threatened, 55 Fed. Being Considered by the Environmental Protection
Reg. 21148 (May 22, 1990). Agency Regarding: Potential Developmental Effects of
162 Threatened Status for Pawnee Montane Skipper, 51 Atrazine on Amphibians, Aug 4, 2003.
183 See NRDC’s website for more information regarding its
Fed. Reg. 34106-34109 (September 25, 1986).
163 California Department of Pesticide Regulation, Species work to ban atrazine at <http://www.nrdc.org/health/
by Pesticide Vol.1 by Richard Marovich and Steven pesticides/natrazine.asp>.
184 Ibid.
Kishaba, Aug. 5, 1997, available at <<http://
www.cdpr.ca.gov/docs/es/index.htm>>.
66
 [ENDNOTES]

185 Supra note 115.

186 69 Fed. Reg. 4465-4480 (Jan. 30, 2004).
187 Letter from Congressman Raul M. Grijalva and 65

other members of Congress to Secretary Norton, Secretary

Evans and Administrator Leavitt, June 14, 2004, available
at <http://www.house.gov/grijalva/>.
188 Ibid.

189 Ibid.

190 U.S. Fish and Wildlife Service, Division of

Environmental Quality, Pesticides and Wildlife, <http://

contaminants.fws.gov/Issues/Pesticides.cfm>.
191 See Elizabeth A. Guillette, María Mercedes Meza,

Maria Guadalupe Aquilar, Alma Delia Soto, and Idalia

Enedina Garcia. 1998. An Anthropological Approach to
the Evaluation of Preschool Children Exposed to
Pesticides in Mexico. Environmental Health Perspectives
106:347-353, available at <<http://
www.ourstolenfuture.org/NewScience/behavior/
yaqui.htm>>; see also Landrigan, P. et al., Assessing the
Effects of Endocrine Disruptors in the National Children’s
Study, Environmental Health Perspectives 111:1678-1682
(2003) available at <<http.dx.doi.org>>.
192 See Greenlee, AR, TE Arbuckle and P-H Chyou. 2003.

Risk factors for female infertility in an agricultural region.

Epidemilogy 14:429-436, available at <<http://
www.ourstolenfuture.org/NewScience/reproduction/2003/
2003-0904greenleeetal.htm>>; see also Castorina, R. et
al., Cumulative Organophosphate Pesticide Exposure and
Risk Assessment among Pregnant Women Living in an
Agricultural Community: A Case Study from the
CHAMACOS Cohort, Environmental Health Perspectives
111:1640-48 (2003) available at <<http://dx.doi.org/>>.
193 Environmental Illness Society Of Canada, Pesticides,

Their Multigenerational Cumulative Destructive Impact

on Health, Especially on the Physical, Emotional and
Mental Development of Children and of Future
Generations, Feb. 2000, available online at <<http://
www.eisc.ca/pesticide_moratorium.html>>; see also Blair,
A. and S.H. Zahm, “Agricultural exposures and cancer,”
Environmental Health Perspectives, 103 No 8, 1995.
194 U.S. EPA, Special Report on Environmental Endocrine

Disruption: an Effects Assessment and Analysis, EPA/630/

R-96/012 February 1997, available at <http://
www.epa.gov/ORD/WebPubs/endocrine/>.

67