quantitatively to modify risk assessments that focus on exposure to one or more active ingredients. NMFS (2011, p. 442) notes that “given the complexity and scale of this action, we are unable to accurately define exposure distributions for the chemical stressors.” Essentially the same language is included elsewhere (NMFS 2008, p. 259; 2009, p. 309; 2010, pp. 449-450).

The qualitative discussions of exposures to environmental mixtures in Bi-Ops by the Services and the focus of EPA on single chemicals are not fundamentally different. EPA’s basic agreement with the position taken by NMFS is clearly illustrated in its response to questions posed by the committee (EPA 2012i, p. 5), which included the following:

The highly variable nature of the background exposure to other chemical stressors represents a significant impediment to combined effects analysis. Much of the empirical data for multiple chemical stressor evaluation involves small suites of chemicals, in discrete concentration combinations that are not highly representative of in-field conditions across complex landscapes at the national scale of pesticide use that EPA must assess. In addition, predicting the frequency and pattern of environmental mixtures at the temporal scales used in acute and chronic risk assessment (hours to a few weeks) is beyond the capabilities of the best available nationwide data sets that look at combined chemical analysis.

The statements by EPA and NMFS above are functionally identical with respect to the qualitative rather than quantitative treatment of environmental mixtures.

The Services (see, for example, NMFS 2008, 2009, 2010, 2011) and other analysts (for example, Hoogeweg et al. 2011) often discuss or assess the potential co-occurrence of various pesticides (that is, pesticide active ingredients) with populations of listed species, but quantitative analyses of the co-occurrence of multiple pesticides have not been encountered in EPA assessments. As discussed in Gilliom et al. (2007, p.81), an analysis of the co-occurrence of pesticides might be useful in identifying environmental mixtures that have the greatest probability of adversely affecting listed species, and these investigators provide a preliminary assessment of the most commonly occurring mixtures of two to seven pesticides (Belden et al. 2007). More detailed analyses of the frequency of the co-occurrence of pesticides have been used in human health risk assessments (e.g., Stackelberg et al. 2009; Tornero-Velez et al. 2012). The preliminary analyses by Belden et al. (2007) on pesticides associated with corn and soybean production suggest that factoring the occurrence of environmental mixtures into assessments will increase the risk estimates but not substantially (by a factor of about 2). Although some BiOps (NMFS 2008, 2009, 2010) cite the analysis by Belden et al. (2007), they do not attempt to model exposures to multiple pesticides in a single watershed.



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