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

the uncertainties related to experimental design, dose-response slopes, and confidence estimates
of the data, but we did not receive summaries of this information from EPA when preparing this
Opinion. However, even if the DER data were submitted, other aspects of EPA’s assessment
endpoints (survival, reproduction, and growth) were not presented. When this missing
information is combined with the absence of information presented on other non-assessed
endpoints such as AChE inhibition in fish and invertebrates, swimming behaviors, and olfactorymediated
impairments, an incomplete picture emerges on the potential effects of EPA’s action to
listed salmonid and habitat endpoints.
Toxicity information presented in the BEs (EPA 2003c, EPA 2004a, and EPA 2003a) lacks
details NMFS requires for analyses in support of this consultation. More complete information
is presented in the Science Chapters for carbaryl (EPA 2003c) and carbofuran (EPA 2005), yet
the information was not applied by EPA in its characterization of risk to listed salmonids or
salmonid habitats. Specific data gaps identified include the following, although not all gaps
apply to all three carbamates.
• Reported LC50s not accompanied by slopes, experimental design (number of treatments
and replicates, life stage of organism, concentrations tested), measures of variability such
as confidence intervals or standard deviations/errors;
• No analysis of the degree or magnitude of inhibition of acetylcholinesterase by the three
carbamates and expected response by listed salmonids or aquatic, salmonid prey
communities;
• Summary and discussion of fish sublethal data absent from BEs including effects to
swimming and chemoreception;
• Limited or no toxicity data on current formulations,
• Limited or no toxicity data presented for identified surface water degradates of the three
carbamates;
• Sensitivity of surrogate lab strains compared to wild, listed fish, particularly comparisons
between warm and cold water fish species used in chronic guideline tests;
• No data summarized for mixture toxicity including tank mixtures and environmental
mixtures to assessment endpoints;
• No toxicity data presented on “inert” or other ingredients present in formulations
containing each of the a.i.s;
• No analysis of influence of environmental factors (pH, temperature) on exposure and
toxicity.
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