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Carbaryl, Carbofuran, and Methomyl - National Marine Fisheries ...

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potential ingredients in tank mixtures were not addressed in EPA’s BEs <strong>and</strong> remain a significant<br />

source of uncertainty.<br />

Environmental Mixtures<br />

As described in the Approach to the Assessment, we analyze the status of listed species, in<br />

conjuction with the Environmental Baseline in evaluating the likelihood that action stressors will<br />

reduce the viability of populations of listed salmonids. This involves considering interactions<br />

between the stressors of the action <strong>and</strong> the Environmental Baseline. For example, we consider<br />

that listed salmonids may be exposed to the wide array of chemical stressors that occur in the<br />

various marine, estuarine, <strong>and</strong> freshwater habitats they occupy throughout their life cycle.<br />

Exposure to multiple pesticide ingredients is most likely in freshwater habitats <strong>and</strong> nearshore<br />

environments adjacent to areas where pesticides are used. As of 1997, about 900 a.i.s were<br />

registered in the U.S. for use in more than 20,000 different pesticide products (Aspelin <strong>and</strong><br />

Grube 1999). Typically 10 to 20 new a.i.s are registered each year (Aspelin <strong>and</strong> Grube 1999). In<br />

a typical year in the U.S., pesticides are applied at a rate of approximately five billion lbs of a.i.<br />

per year (Kiely, Donaldson et al. 2004). Pesticide contamination in the nation’s freshwater<br />

habitats is ubiquitous <strong>and</strong> pesticides usually occur in the environment as mixtures (Gilliom,<br />

Barbash et al. 2006). “More than 90% of the time, water from streams with agricultural, urban,<br />

or mixed-l<strong>and</strong>-use watersheds had detections of two or more pesticides or degradates, <strong>and</strong> about<br />

20% of the time they had detections of 10 or more (Gilliom, Barbash et al. 2006).” The<br />

likelihood of exposure to multiple pesticides throughout a listed salmonids’ lifetime is great<br />

considering their migration routes <strong>and</strong> habitats occupied for spawning <strong>and</strong> rearing. In a threeyear<br />

monitoring study conducted by the Washington DOE, pesticide mixtures were found to be<br />

common in both urban <strong>and</strong> agricultural watersheds (Burke, Anderson et al. 2006). An average of<br />

three pesticides was found in each sample collected on urban sampling sites with as many as nine<br />

pesticides found in a single sample. Agricultural sites averaged three to five pesticides per<br />

sample with as many as 14 pesticides being detected in a single sample (Burke, Anderson et al.<br />

2006). Mixtures of chemicals that share a common mode or mechanism of action are of<br />

particular concern. Six to 11 million lbs of cholinesterase-inhibiting insecticides are used<br />

annually in California (CDPR 2007). One a.i., thiodicarb, degrades into methomyl. Potential<br />

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