the assessment will have sufficient specificity for decision-making. The analysis phase of the risk assessment should not begin until the decision-makers are satisfied that the risk assessor understands the questions that need to be addressed and understands how much confidence in the final risk estimate is needed. Problem formulation is also an excellent time to discuss how the risk estimate will be communicated at the conclusion of the assessment.
The committee views coordination among EPA and the Services as a collegial exchange of technical and scientific information for the purpose of producing a more complete and representative assessment of risk, including the types and depths of analyses to be conducted at each step in the process. Such coordination would allow EPA’s expertise in pesticides to be effectively combined with the Services’ expertise in life histories of listed species and in abiotic and biotic stressors of the species. Coordination discussions would include many of the issues discussed by the committee in the present report, such as datasets to use to delineate species’ habitats, the need for additional fate data, and new approaches for exposure and effects analysis. The agencies can use Steps 1-3 as a framework for such discussions but need not be constrained by them. It might be that technical working groups would form around various aspects of the assessment approach—such as fate and transport modeling, estimating species distributions and habitats, data-sharing, and uncertainty analysis—to discuss technical details and that others would discuss policy-based issues, such as which evolutionarily significant units to include in the analysis. The committee recommends that such collaboration meetings be formal, structured workshops that have stated goals and objectives, be led by professional facilitators, and have formal agendas agreed to by all parties. That approach would enhance productivity and allow expectations to be met. The periodicity of such discussions would necessarily be at the discretion of the agencies, but the committee recommends a frequency of at least once every 2 years to capture updates in risk-assessment and population-biology methods, newly listed species, new pesticide classes, and changing agricultural practices.
The committee concludes further that coordination during problem formulation regarding the ESA and ERA processes would be enhanced if a common outline, such as the one shown in Box 2-1, were adopted. The details of the outline would be adapted according to the step being conducted. However, the outline should incorporate specific elements of concern and interest to EPA and the Services. For example, examination of earlier EPA assessments has revealed a need for EPA to include and consider all available information about the life history of a listed species early in the process, ideally during planning and scoping (Item 1.1.4 in Box 2-1). Although assessment end points might ultimately involve only common surrogate or test species, the inclusion of natural life-history information on the listed species and critical habitat would at least enable a qualitative assessment of the similarities and differences between the listed species and the identified surrogates.