(FWS) and the National Marine Fisheries Service (NMFS)—collectively referred to as the Services—to make jeopardy determinations (Step 3, Figure 2-1).

SUBLETHAL, INDIRECT, AND CUMULATIVE EFFECTS

Pesticides can kill organisms that are closely or distantly related to their intended targets, and they can cause sublethal changes that can affect reproduction, shorten lifespans, or make the organisms unable to compete. The following sections discuss how to incorporate sublethal effects into ecological risk assessments, how effects on one organism might indirectly affect others, and how pesticide effects might be modified by exposure to other environmental stressors.

Sublethal Effects

Pesticides can have sublethal effects at multiple levels of biological organization: molecular, cellular, tissue, organism, population, and community. Only when compensatory or adaptive mechanisms at one level of biological organization begin to fail do deleterious effects become apparent at higher levels. The committee considered how to assess objectively the degree to which observed effects of pesticides on organisms are adverse. Defining that concept is essential for ecological risk assessment because even if an effect is reliably observed, that alone might not be sufficient to conclude that the effect is adverse. The committee concluded that the only reasonable way to determine whether an effect is adverse and how adverse it might be is to assess the degree to which it affects the organism’s survival and reproductive success. It then is possible to extrapolate from changes in an individual organism’s survival or reproductive success to estimate population effects. If an adverse effect is large enough, it might lead to extinction of the species. EPA reached a similar conclusion in its overview of the ecological risk-assessment process (EPA 2004, p. 31): “If the effects on the survival and reproduction of individuals are limited, it is assumed that the risk at the population level from such effects will be of minor consequence. However, as the risk of reductions in survival and/or reproduction rates increase, the greater the potential risk to populations.”

EPA and the Services agree on the inclusion of sublethal effects in the risk-assessment process but disagree on the extent to which such effects should be included. For example, in its responses to committee questions, EPA explained that its focus is “on how to relate the relevance of sublethal data to an assessment of the risks to fitness of listed species,” with fitness defined as “an individual’s ability to survive and reproduce” (EPA 2012a, p. 2). Furthermore, EPA considers that incorporation of sublethal effects into an ecological risk assessment must be accompanied by an explicit relationship that defines the contribution of the sublethal effect to an individual organism’s fitness in terms of the end points of “survival, growth and reproduction” (EPA 2012a, p. 20). EPA



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