The National Marine Fisheries Service has been studying the effects of chemical pesticides on threatened and endangered salmon species, and I have to say that I’m impressed with the thorough approach to this scientific challenge.
Not everyone is so impressed, however, and pesticide manufacturers have filed a federal lawsuit to block implementation of protection measures proposed by NMFS, but more about that in a moment.
Risk analysis is always a tricky subject, but it appears that the NMFS researchers have taken a step-by-step approach, turning over every stone.
The latest “biological opinion” (PDF 11.7 mb) is a 600-page report covering pesticides containing carbaryl, carbofuran and methomyl. Like the previous biological opinion (PDF 11 mb) on diazinon, chlorpyrifos and malathion, the agency has determined that the pesticides pose a significant risk of extinction for listed salmon and outline further restrictions on their use.
Read my story in Wednesday’s Kitsap Sun and a well-written piece by Associated Press reporter Phuong Le.
NMFS scientists have been looking at how much of each pesticide can get into a stream under various kinds of applications. In the water, these neurotoxins can affect a fish directly — if not by killing them, by impairing their response to predators, their ability to get food, their ability to find their natal streams or their ability to connect with a mate.
Even if a fish is not harmed directly, these insecticides can affect fish simply by doing their job very well — killing off all or a significant portion of the insects that a fish needs to eat, grow and survive.
As if measuring all these effects are not enough, now we learn that chemicals may exhibit synergistic effects — making it necessary to look not just at the effects of a single chemical but how multiple chemicals in the water work together.
The biological opinion outlines measures for reducing the risk of harm, including no-spray buffer zones, which vary by the amount of pesticide used among other things.
Of the scientists I’ve talked to, everyone is in agreement that the NMFS approach to the pesticide problem is clearly superior to previous analyses by the Environmental Protection Agency.
But pesticide manufacturers assert that assumptions that went into NMFS’ probability models are over-reaching and that agency officials failed to consider existing studies with contrary results. Manufacturers have filed a lawsuit to block the proposed restrictions from going into effect. See news release from Washington Friends of Farms & Forests or download the lawsuit (PDF 324 kb).
While these NMFS reviews are open to debate under federal law, they never would have occurred at all without a requirement for consultation under the Endangered Species Act and a lawsuit filed by environmental groups.
As attorney Joshua Osborne-Klein points out in a news release from Earthjustice:
NMFS has now determined that current uses of all six of the pesticides it has reviewed so far are jeopardizing the existence of West Coast salmon and steelhead. The Environmental Protection Agency — the federal agency charged with regulating pesticide use — had earlier determined that many salmon runs were not at risk from these six pesticides.
NMFS’s review found serious flaws with EPA’s analytical methods and conclusions, and determined that EPA underestimated the risk that the pesticides pose to salmon.
“Today’s findings are an example of why it’s so important for the fish and wildlife scientists at NMFS to provide an independent check on other agencies’ findings about endangered species,” said Earthjustice’s Osborne-Klein.
But in the final days of the Bush administration, the federal government significantly weakened the protections provided by the consultation process between EPA and NMFS that produced today’s decision.
“The Bush administration’s warped interpretation of the law removed the voices of scientific experts responsible for protecting salmon,” continued Osborne-Klein.
President Obama is well aware of the problem. In a memo issued March 3, he called on all agency heads to “exercise their discretion, under the new regulation, to follow the prior longstanding consultation and concurrence practices,” until the rule can be reconsidered and possibly reversed.
Thirty-one more pesticides are scheduled for review by the National Marine Fisheries Service over the next three years.
For additional information, see press release from the Northwest Coalition for Alternatives to Pesticides (PDF 76 kb) and a previous entry in Water Ways.
