kota and Thompson 2004). The committee acknowledges the utility of a qualitative assessment and discussion between risk assessors and decision-makers at both Step 2 and Step 3 of the ESA risk-assessment process. A decision-maker will then be adequately informed about the estimated probability of an adverse effect and can make a decision about whether the proposed action is “likely to adversely affect” or can be “reasonably expected” to result in jeopardy. Decisions about the acceptable level of risk and how to manage the risk are policy decisions that are not part of the scientific analysis.

The committee recognizes that decision-makers will need to understand how to interpret and use the information on uncertainty in their decision-making. There is a great body of literature on risk management and decision-making under uncertainty that can help to guide and guard against misuses of uncertainty in decision-making (see, for example, Cropper et al. 1992, Morgan and Henrion 1992, EPA 2010, and IOM 2013).

BEST DATA AVAILABLE

As discussed in Chapter 1, the Services have a mandate to use the “best scientific and commercial data available” in their assessments. There is little guidance on what constitutes “best data available,” and the agencies do not appear to have formal protocols that define “best data available.” However, the following sections describe the agencies’ approaches to data collection and evaluation, and the committee provides some guidance on important data characteristics.

Scope of Data Collection and Selection

EPA (1998) indicated that a search for all available data is conducted at the start of each risk assessment and iteratively throughout the assessment to support and guide each step of the process. EPA’s primary repository for peer-reviewed toxicity studies that are publicly available is ECOTOXicology (ECOTOX; EPA 2012a). The Services and EPA agreed to use ECOTOX as the common source for data on ecotoxic effects of pesticides (EPA 2011).

Data used by EPA in pesticide risk assessments are typically derived from detailed reports of standardized studies required for pesticide registration under FIFRA; studies in peer-reviewed journals or other publications, such as reference books; and government reports and surveys. Repository databases are used if they meet data-quality standards. The Services also include anecdotal or oral information and other unpublished materials from such sources as state natural-resources agencies and natural-heritage programs, tribal governments, other federal agencies, consulting firms, contractors, and persons associated with professional organizations and institutions of higher education (59 Fed. Reg. 34275 [1994]). Accordingly, the scope of data collection by the Services appears



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