Appendix G

Integrated Pest

Management Program

© Erin Rowland

Appendix A

Appropriate Use Findings 

Appendix B

Compatibility Determinations

Appendix C

Implementation

Appendix D

Wilderness Review

Appendix E

Biological Resources of Concern

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary

Appendix I

Contributors

Appendix J

Acquisition History

Appendix K

Public Involvement

Appendix L

Hydrological Modeling

Appendix M

References

Appendix N

List of Refuge Species

Appendix O

Wildland Fire Management Plan

Appendix P

Maps
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-1 

Appendix G. Integrated Pest Management Program 

G.1 Background 

Integrated pest management (IPM) is an interdisciplinary approach using methods to prevent, 

eliminate, contain, and/or control pest and invasive species (herein collectively referred to as pests) 

in concert with other management activities on refuge lands and waters to achieve wildlife and 

habitat management goals and objectives. IPM is a scientific adaptive management process where 

available scientific information and best professional judgment of the refuge staff and other resource 

experts will be used to identify and implement appropriate management strategies that can be 

modified and/or changed over time to ensure effective, site-specific management of pest species to 

achieve desired outcomes. In accordance with 43 Code of Federal Regulations (CFR) 46.145, 

adaptive management would be particularly relevant where long-term impacts may be uncertain, and 

future monitoring would be needed to make adjustments in subsequent implementation decisions. 

After a tolerable pest population (threshold) is determined considering achievement of refuge 

resource objectives and the ecology of pest species, one or more methods, or combinations thereof, 

will be selected that are feasible, efficacious, and most protective of nontarget resources, including 

native species (fish, wildlife, and plants) and U.S. Fish and Wildlife Service (Service) personnel, 

Service-authorized agents, volunteers, and the public. Staff time and available funding will be 

considered when determining feasibility/practicality of various treatments. 

IPM techniques to address pests are presented as comprehensive conservation plan (CCP) strategies 

(see Chapter 2 of this CCP) in an adaptive management context to achieve resource objectives of the 

Tualatin River National Wildlife Refuge (the refuge). To satisfy requirements for IPM planning as 

identified in the Service director’s memo (dated September 9, 2004) titled Integrated Pest 

Management Plans and Pesticide Use Proposals: Updates, Guidance, and an Online Database, the 

following elements of an IPM program have been incorporated into this CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to 

indicate the need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives 

including pest thresholds. 

Where pesticides would be necessary to address pests, this appendix provides a structured procedure 

to evaluate potential effects of proposed uses involving ground-based applications to refuge 

biological resources and environmental quality in accordance with effects analyses presented in 

Chapter 6 (Environmental Consequences) of the draft CCP/EA. Only pesticide uses that likely would 

cause minor, temporary, or localized effects to refuge biological resources and environmental quality 

with appropriate best management practices (BMPs), where necessary, will be allowed for use on the 

refuge. 

This appendix does not describe the more detailed process of evaluating potential effects associated 

with aerial applications of pesticides. However, the basic framework to assess potential effects to 

refuge biological resources and environmental quality from aerial application of pesticides would be 

similar to the process described in this appendix for ground-based treatments of other pesticides. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-2 Appendix G. Integrated Pest Management Program 

G.2 Pest Management Laws and Policies 

In accordance with Service policy 569 FW 1 (Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System (Refuge System) can be controlled 

to ensure balanced wildlife and fish populations in support of refuge-specific wildlife and habitat 

management objectives. Pest control on Federal (refuge) lands and waters also is authorized under 

the following legal mandates: 

 National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S. Code 

[U.S.C.] 668dd-668ee); 

 Plant Protection Act of 2000 (7 U.S.C. 7701 et seq.); 

 Noxious Weed Control and Eradication Act of 2004 (7 U.S.C. 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) of 1996 (7 U.S.C. 136-136y); 

 National Invasive Species Act of 1996 (16 U.S.C. 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 U.S.C. 4701); 

 Food Quality Protection Act of 1996 (7 U.S.C. 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 U.S.C. 426-426c, 46 Stat. 1468). 

Pests are defined as “... living organisms that may interfere with the site-specific purposes, 

operations, or management objectives or that jeopardize human health or safety” according to 

Department Policy 517 DM 1 (Integrated Pest Management Policy), published by the U.S. 

Department of the Interior. Similarly, 569 FW 1 defines pests as “ ... invasive plants and introduced 

or native organisms, that may interfere with achieving our management goals and objectives on or 

off our lands, or that jeopardize human health or safety.” 517 DM 1 also defines an invasive species 

as “a species that is non-native to the ecosystem under consideration and whose introduction causes 

or is likely to cause economic or environmental harm or harm to human health.” Throughout the 

remainder of this CCP, the terms pest and invasive species are used interchangeably because both 

can prevent/impede achievement of refuge wildlife and habitat objectives and/or degrade 

environmental quality. 

In general, control of pests on the refuge would conserve and protect the nation’s fish, wildlife, and 

plant resources as well as maintain environmental quality. From 569 FW 1, animal or plant species 

that are considered pests may be managed if the following criteria are met: 

 There is threat to human health and well being or private property, the acceptable level of 

damage by the pest has been exceeded, or state or local government has designated the pest 

as noxious; 

 It is detrimental to resource objectives as specified in a refuge resource management plan 

(e.g., CCP, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purposes for which 

the refuge was established. 

The specific justifications for pest management activities on the refuge are the following: 

 Protect human health and well being; 

 Prevent substantial damage to important refuge resources; 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-3 

 Protect newly introduced or reestablished native species; 

 Control nonnative (exotic) species to support existence of populations of native species; 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the refuge: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or 

carrying out actions that are likely to cause or promote the introduction or spread of invasive 

species in the United States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize 

unacceptable change to ecosystem structure and function and prevent new and expanded 

infestations of invasive species. Conduct refuge habitat management activities to prevent, 

control, or eradicate invasive species ....” 

Animal species damaging/destroying Federal property and/or detrimental to the management 

program of a refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control 

Operations). For example, the incidental removal of beaver damaging refuge infrastructure (e.g., 

clogging with subsequent damaging of water control structures) and/or negatively affecting habitats 

(e.g., removing woody species from existing or restored riparian areas) managed on refuge lands may 

be conducted without a pest control proposal. We recognize beavers are a native species and most of 

their activities on refuge lands represent a natural process beneficial for maintaining wetland habitats. 

Exotic nutria, whose denning and burrowing activities in wetland dikes causes cave-ins and breaches, 

can also be controlled using the most effective techniques considering site-specific factors without a 

pest control proposal. Along with the loss of quality wetland habitats associated with breaching of 

impoundments, the safety of refuge staff, volunteers, contractors, and public driving on structurally 

compromised levees and dikes can be threatened by sudden and unexpected cave-ins. Disposed 

wildlife specimens may be donated or loaned to public institutions. Donation or loans of resident 

wildlife species would only be made after securing state approval (50 CFR 31.11 [Donation and 

Loan of Wildlife Specimens]). Surplus wildlife specimens may be sold alive or butchered, dressed, 

and processed subject to Federal and state laws and regulations (50 CFR 31.12 [Sale of Wildlife 

Specimens]). 

Trespass and feral animals also may be controlled on refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and 

observed in the act of killing, injuring, harassing, or molesting humans or wildlife may be disposed 

of in the interest of public safety and protection of wildlife. Feral animals should be disposed of by 

the most humane method available and in accordance with relevant Service directives. 

G.3 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would 

be carefully considered on the refuge for each pest species: 

 Prevention. This would be the most effective and least expensive long-term management 

option for pests. It encompasses methods to prevent new introductions or the spread of the 

established pests to uninfested areas. It requires identifying potential routes of invasion to 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-4 Appendix G. Integrated Pest Management Program 

reduce the likelihood of infestation. Hazard Analysis and Critical Control Points (HACCP) 

planning can be used to determine if current management activities on a refuge may 

introduce and/or spread invasive species in order to identify appropriate BMPs for 

prevention. See http://www.haccp-nrm.org/ for more information about HACCP planning. 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill, 

exclusion methods (e.g., barriers), and/or sanitation methods (e.g., wash stations) to prevent 

reintroductions by various mechanisms including vehicles and personnel. Because invasive 

species are frequently the first to establish newly disturbed sites, prevention would require a 

reporting mechanism for early detection of new pest occurrences with quick response to 

eliminate any new pest populations. Prevention would require consideration of the scale and 

scope of land management activities that may promote pest establishment within uninfested 

areas or promote reproduction and spread of existing populations. Along with preventing 

initial introduction, prevention would involve halting the spread of existing infestations to 

new sites (Mullin et al. 2000). The primary reason for prevention would be to keep pest-free 

lands or waters from becoming infested. Executive Order 11312 emphasizes the priority for 

prevention with respect to managing pests. 

The following would be methods to prevent the introduction and/or spread of pests on refuge 

lands: 

o Before beginning ground-disturbing activities (e.g., discing, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge 

staff would identify pest species on-site or within reasonably expected potential 

invasion vicinity. Where possible, the refuge staff would begin project activities in 

uninfested areas before working in pest-infested areas. 

o Refuge staff would locate and use pest-free project staging areas. They would avoid 

or minimize travel through pest-infested areas, or restrict travel to those periods when 

the spread of seed or propagules of invasive plants would be least likely. 

o Refuge staff would determine the need for, and when appropriate identify, sanitation 

sites where equipment can be cleaned of pests. Where possible, refuge staff would 

clean equipment before entering lands at on-refuge approved cleaning site(s). This 

practice does not pertain to vehicles traveling frequently in and out of the project area 

that would remain on roadways. Refuge staff would remove mud, dirt, and plant parts 

from project equipment before moving it into a project area. 

o Refuge staff would clean all equipment before leaving the project site, if operating in 

areas infested with pests. Refuge staff would determine the need for, and when 

appropriate identify, sanitation sites where equipment can be cleaned. 

o Refuge staff, their authorized agents, and refuge volunteers would, where possible, 

inspect, remove, and properly dispose of seed and parts of invasive plants found on 

their clothing and equipment. Proper disposal means bagging the seeds and plant 

parts and then properly disposing of them. 

o Refuge staff would evaluate options, including closure, to restrict traffic on sites with 

ongoing restoration of desired vegetation. Refuge staff would revegetate disturbed 

soil (except travelways on surfaced projects) to optimize native plant establishment 

for each specific site. Revegetation may include topsoil replacement, planting, 

seeding, fertilization, and weed-free mulching as necessary. The refuge staff would 

use native material where appropriate and feasible. They would also use certified 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-5 

weed-free or weed-seed-free hay or straw where certified materials are reasonably 

available. 

o Refuge staff would provide information, training, and appropriate pest identification 

materials to permit holders and recreational visitors. They would educate them about 

pest identification, biology, impacts, and effective prevention measures. 

o Refuge staff would require grazing permittees to use preventative measures for their 

livestock while on refuge lands. 

o Refuge staff would inspect borrow material for invasive plants prior to use and 

transport onto and/or within refuge lands. 

o Refuge staff would consider invasive plants in planning for road maintenance 

activities. 

The following methods would be used to prevent the introduction and/or spread of pests into 

refuge waters: 

o Refuge staff would inspect boats, trailers, other boating equipment, and waders or 

boots. Where possible, refuge staff would remove any visible plants, animals, or mud 

before leaving any waters or boat launching facilities. Where possible, refuge staff 

would drain water from motor, live well, bilge, and transom wells while on land 

before leaving the site. If possible, the refuge staff would wash and dry boats, 

anchors, nets, floors of boats, propellers, axles, trailers, and other boating equipment 

to kill pests not visible at the boat launch. Waders and boots would be cleaned and 

disinfected as necessary. 

o Where feasible, refuge staff would maintain a l00-foot buffer of aquatic pest-free 

clearance around boat launches and docks or quarantine areas when cleaning around 

culverts, canals, or irrigation sites. Where possible, refuge staff would inspect and 

clean equipment before moving to new sites or from one project area to another. 

 Mechanical/Physical Methods. These methods would remove and destroy, disrupt the 

growth of, or interfere with the reproduction of pest species. For plants species, these 

treatments can be accomplished by hand, hand tools (manual), or power tools (mechanical) 

and include pulling, grubbing, digging, tilling/discing, cutting, swathing, grinding, shearing, 

girdling, mowing, and mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use 

mechanical/physical methods (including trapping) to control pests as a refuge management 

activity. Based upon 50 CFR 31.2, trapping can be used on a refuge to reduce surplus wildlife 

populations for a “balanced conservation program” in accordance with Federal or state laws 

and regulations. In some cases, non-lethally trapped animals would be relocated to off-refuge 

sites with prior approval from the state. 

Each of these tools would be efficacious to some degree and applicable to specific situations. 

In general, mechanical controls can effectively control annual and biennial pest plants. 

However, to control perennial plants, the root system has to be destroyed or it would resprout 

and continue to grow and develop. Mechanical controls are typically not capable of 

destroying a perennial plant’s root system. Although some mechanical tools (e.g., discing, 

plowing) may damage root systems, they may also stimulate regrowth producing a denser 

plant population that may aid in the spread depending upon the target species (e.g., Canada 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-6 Appendix G. Integrated Pest Management Program 

thistle). In addition, steep terrain and soil conditions would be major factors that can limit the 

use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be very effective at controlling perennial species. For example, mowing 

perennial plants followed sequentially by treating the plant regrowth with a systemic 

herbicide often would improve the efficacy of the herbicide compared to herbicide treatment 

alone. 

 Cultural Methods. These methods would involve manipulating habitat to increase pest 

mortality by reducing its suitability to the pest. Cultural methods would include water-level 

manipulation, mulching, planting winter cover crops, changing planting dates to minimize 

pest impact, prescribed burning (which facilitates revegetation, increases herbicide efficacy, 

and removes litter to assist in emergence of desirable species), flaming with propane torches, 

trap crops, crop rotations that include nonsusceptible crops, moisture management, addition 

of beneficial insect habitat, reducing clutter, proper trash disposal, planting or seeding 

desirable species to shade or outcompete invasive plants, applying fertilizer to enhance 

desirable vegetation, prescriptive grazing, and other habitat alterations. 

 Biological Control Agents. Classical biological control would involve the deliberate 

introduction and management of natural enemies (parasites, predators, or pathogens) to 

reduce pest populations. Many of the most ecologically or economically damaging pest 

species in the United States originated in foreign countries. These newly introduced pests, 

which are free from natural enemies found in their country or region of origin, may have a 

competitive advantage over cultivated and native species. This competitive advantage often 

allows introduced species to flourish, and they may cause widespread economic damage to 

crops or outcompete and displace native vegetation. Once the introduced pest species 

population reaches a certain level, traditional methods of pest management may be costprohibitive or impractical. Biological controls typically are used when these pest populations 

have become so widespread that eradication or effective control would be difficult or no 

longer practical. 

Biological control has advantages as well as disadvantages. Benefits include reducing 

pesticide use, host specificity for target pests, long-term self-perpetuating control, low cost 

per acre, capacity for searching and locating hosts, synchronizing biological control agents to 

hosts’ life cycles, and the unlikelihood that hosts would develop resistance to agents. 

Disadvantages include limited availability of agents from their native lands, the dependence 

of control on target species’ density, the slow rate at which control occurs, biotype matching, 

the difficulty and expense of conflicts over control of the target pest, and host specificity 

when host populations are low. 

A reduction in target species populations from biological controls is typically a slow process, 

and efficacy can be highly variable. It may not work well in a particular area although it does 

work well in other areas. Biological control agents would require specific environmental 

conditions to survive over time. Some of these conditions are understood, whereas others are 

only partially understood or not understood at all. 

Biological control agents would not eradicate a target pest. When using biological control 

agents, residual levels of the target pest typically are expected; the agent’s population level or 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-7 

survival would be dependent upon the density of its host. After the pest population decreases, 

the population of the biological control agent would decrease correspondingly. This is a 

natural cycle. Some pest populations (e.g., invasive plants) tend to persist for several years 

after a biological control agent becomes established due to seed reserves in the soil, 

inefficiencies in the agent’s search behavior, and the natural lag in population buildup of the 

agent. 

The full range of pest groups potentially found on refuge lands and waters includes diseases, 

invertebrates (insects, mollusks), vertebrates, and invasive plants (the most common group). 

Often it is assumed that biological control would address many if not most of these pest 

problems. There are several well-documented success stories of biological control of invasive 

weed species in the Pacific Northwest including Mediterranean sage, St. John’s wort 

(Klamath weed), and tansy ragwort. Emerging success stories include Dalmatian toadflax, 

diffuse knapweed, leafy spurge, purple loosestrife, and yellow star thistle. However, 

historically, each new introduction of a biological control agent in the United States has only 

about a 30 percent success rate (Coombs et al. 2004). 

Introduced species without desirable close relatives in the United States would generally be 

selected as biological controls. Natural enemies that are restricted to one or a few closely 

related plants in their country of origin are targeted as biological controls (Center et al. 1997; 

Hasan and Ayres 1990). 

Refuge staff would ensure introduced agents are approved by applicable authorities. Except 

for a small number of formulated biological control products registered by the U.S. 

Environmental Protection Agency (EPA) under FIFRA, most biological control agents are 

regulated by the U.S. Department of Agriculture (USDA)-Animal Plant Health Inspection 

Service, Plant Protection and Quarantine (APHIS-PPQ). State departments of agriculture and, 

in some cases, county agricultural commissioners or weed districts have additional approval 

authority.

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrol agents 

from another state. Form 526 may be obtained through the Internet at: 

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html. 

The Service strongly supports the development and legal and responsible use of appropriate, 

safe, and effective biological control agents for nuisance and nonindigenous or pest species. 

State and county agriculture departments may also be sources for biological control agents or 

they may have information about where biological control agents may be obtained. 

Commercial sources should have an Application and Permit to Move Live Plant Pests and 

Noxious Weeds to release specific biological control agents in a state and/or county. 

Furthermore, certification regarding the biological control agent’s identity (genus, specific 

epithet, subspecies, and variety) and purity (e.g., parasite-free, pathogen-free, and biotic and 

abiotic contaminants) should be specified in purchase orders. 

Biological control agents are subject to 7 Refuge Manual (RM) 8 (Exotic Species 

Introduction and Management). In addition, refuge staff would follow the International Code 

of Best Practice for Classical Biological Control of Weeds 

(http://invasives.wsu.edu/Code.htm) as ratified by delegates to the Tenth International 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-8 Appendix G. Integrated Pest Management Program 

Symposium on Biological Control of Weeds in Bozeman, Montana, on July 9, 1999. This 

code states the following: 

o Release only approved biological control agents, 

o Use the most effective agents, 

o Document releases, and 

o Monitor for impact to the target pest, non-target species, and the environment. 

Biological control agents formulated as pesticide products and registered by the EPA (e.g., 

Bacillus thuringiensis var. israelensis [B.t.i.]) are also subject to pesticide use proposal 

(PUP) review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental 

conditions of the release site(s); the identity, quantity, and condition of the biological control 

agents released; and other relevant data and comments such as weather conditions. 

Systematic monitoring to determine the establishment and effectiveness of the release is also 

recommended. 

National Environmental Policy Act (NEPA) documents regarding biological and other 

environmental effects of biological control agents prepared by another Federal agency, where 

the scope is relevant to evaluation of releases on refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents include the Bureau of Land Management, U.S. 

Forest Service (USFS), the National Park Service, the USDA-APHIS, and the military 

services. It might be appropriate to incorporate by reference parts or all of existing 

document(s) from the review. Incorporating by reference (43 CFR 46.135) is a technique 

used to avoid redundancies in analysis. It also can reduce the bulk of a Service NEPA 

document, which only must identify the documents that are incorporated by reference. In 

addition, relevant portions must be summarized in the Service NEPA document to the extent 

necessary to provide the decision maker and public with an understanding of the relevance of 

the referenced material to the current analysis. 

 Pesticides. The selective use of pesticides would be based upon pest ecology (including 

mode of reproduction), the size and distribution of pest populations, site-specific conditions 

(e.g., soils, topography), known efficacy under similar site conditions, and the capability to 

use BMPs to reduce/eliminate potential effects to nontarget species and sensitive habitats, 

and prevent contamination of surface and groundwater. All pesticide use (pesticide, target 

species, application rate, and method of application) would comply with the applicable 

Federal (FIFRA) and state regulations pertaining to pesticide use, safety, storage, disposal, 

and reporting. Before pesticides can be used to eradicate, control, or contain pests on refuge 

lands and waters, PUPs would be prepared and approved in accordance with 569 FW 1. PUP 

records would provide a detailed, time-, site-, and target-specific description of the proposed 

use of pesticides on the refuge. All PUPs would be created, approved or disapproved, and 

stored in the Pesticide Use Proposal System (PUPS), which is a centralized database only 

accessible on the Service’s intranet (https://systems.fws.gov/pups). Only Service employees 

would be authorized to access PUP records for a refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests 

while minimizing/eliminating direct or indirect (e.g., drift) exposure to non-target areas and 

degradation of surface and groundwater quality. Where possible, target-specific equipment 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-9 

(e.g., backpack sprayer, roller, wiper) would be used to treat target pests. Other targetspecific equipment used to apply pesticides include soaked wicks or paint brushes for wiping 

vegetation and lances, hatchets, or syringes for direct injection into stems. Granular 

pesticides may be applied using seeders or other specialized dispensers. In contrast, aerial 

spraying (e.g., fixed-wing or helicopter) would only be used where access is difficult (due to 

remoteness) and/or the size and distribution of infestations precludes practical use of groundbased methods.

Because repeated use of one pesticide may allow resistant organisms to survive and 

reproduce, multiple pesticides with variable modes of action would be considered for 

treatments on refuge lands and waters. This is especially important if multiple applications 

within years and/or over a growing season likely would be necessary for habitat maintenance 

and restoration activities to achieve resource objectives. Integrated chemical and nonchemical controls also are highly effective, where practical, because pesticide-resistant 

organisms can be removed from the site.

Cost may not be the primary factor in selecting a pesticide for use on a refuge. If the least 

expensive pesticide would potentially harm natural resources or people, then a different 

product would be selected, if available. The most efficacious pesticide available with the 

least potential to degrade environmental quality (soils, surface water, and groundwater) as 

well as the least potential effect to native species and communities of fish, wildlife, plants, 

and their habitats would be acceptable for use on refuge lands in the context of an IPM 

approach. 

 Habitat Restoration/Maintenance. Restoration and/or proper maintenance of refuge 

habitats associated with achieving wildlife and habitat objectives would be essential for longterm prevention, eradication, or control (at or below threshold levels) of pests. Promoting 

desirable plant communities through the manipulation of species composition, plant density, 

and growth rate is an essential component of invasive plant management (Brooks et al. 2004; 

Masters et al. 1996; Masters and Sheley 2001). The following three components of 

succession could be manipulated through habitat maintenance and restoration: site 

availability, species availability, and species performance (Cox and Anderson 2004). 

Although a single method (e.g., herbicide treatment) may eliminate or suppress pest species 

in the short term, the resulting gaps and bare soil create niches that are conducive to further 

invasion by the species and/or other invasive plants. On degraded sites where desirable 

species are absent or in low abundance, revegetation with native/desirable grasses, forbs, and 

legumes may be necessary to direct and accelerate plant community recovery, and achieve 

site-specific objectives in a reasonable time frame. The selection of appropriate species for 

revegetation would be dependent on a number of factors including resource objectives and 

site-specific, abiotic factors (e.g., soil texture, precipitation/temperature regimes, and shade 

conditions). Seed availability and cost, ease of establishment, seed production, and 

competitive ability also would be important considerations. 

G.4 Priorities for Treatments 

For many refuges, the magnitude (number, distribution, and sizes of infestations) of pest problems is 

too extensive and beyond the available capital resources to effectively address during any single field 

season. To manage pests on a refuge, it is essential to prioritize treatment of infestations. Highest 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-10 Appendix G. Integrated Pest Management Program 

priority treatments are focused on early detection and rapid response to eliminate infestations of new 

pests, if possible. This is especially important for aggressive pests potentially impacting species, 

species groups, communities, and/or habitats associated with the refuge purpose(s), Refuge System 

resources of concern (federally listed species, migratory birds, and interjurisdictional fish), and native 

species important for maintaining/restoring biological integrity, diversity, and environmental health. 

The next priority would be treating established pests that appear in one or more previously uninfested 

areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of 

invasive plants eventually would infest an area larger than the established source population. They 

also found that control efforts focusing on the large, main infestation rather than the new, small 

satellites reduced the chances of overall success. 

The lowest priority would be treating large infestations (sometimes monotypic stands) of wellestablished pests. In this case, initial efforts would focus upon containment of the perimeter followed 

by work to control/eradicate the established infested area. If containment and/or control of a large 

infestation is not effective, then efforts would focus upon halting pest reproduction or managing 

source populations. Maxwell et al. (2009) found that treating fewer populations that are sources 

represents an effective long-term strategy to reduce total number of invasive populations and 

decreasing population growth rates. 

Although state-listed noxious weeds would always be of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, reed 

canarygrass may not be listed by a state as noxious, but it can greatly alter wetland plant composition 

by forming monotypic stands. Pest control would likely require a multiyear commitment from refuge 

staff. Essential to the long-term success of pest management would be pretreatment and 

posttreatment monitoring, assessment of the successes and failures of treatments, and development of 

new approaches when proposed methods do not achieve desired outcomes. 

G.5 Best Management Practices 

BMPs can minimize or eliminate possible effects associated with pesticide usage to non-target 

species and/or sensitive habitats as well as degradation of water quality from drift, surface runoff, or 

leaching. Based upon the Department of Interior Pesticide Use Policy (517 DM 1) and the Service 

Pest Management Policy and Responsibilities (30 AM 12), the use of applicable BMPs also would 

likely ensure that pesticide uses do not adversely affect federally listed species and/or their critical 

habitats through determinations made using the process described in 50 CFR 402. 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and used, where feasible, based upon target- and 

site-specific factors and time-specific environmental conditions. 

G.5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple-rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be 

used as part of the make-up water in the sprayer tank and applied to treatment areas. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-11 

 The refuge staff would triple-rinse and recycle (where feasible) pesticide containers. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health and fish and wildlife, 

and preventing soil and water contamination. 

 Refuge staff would consider the water quality parameters (e.g., pH, hardness) that are 

important to ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in the refuge 

spill response plan. 

G.5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service 

personnel and non-Service applicators with the appropriate state certification to safely and 

effectively conduct these activities on refuge lands and waters. 

 Refuge staff would comply with all Federal, state, and local pesticide use laws and 

regulations as well as Departmental, Service, and Refuge System pesticide-related policies. 

 Before each treatment season and prior to mixing or applying any product for the first time 

each season, all applicators would review the labels, material safety data sheets (MSDS), and 

PUPs for each pesticide, determining the target pest, appropriate mix rate(s), required 

personal protective equipment (PPE), and other requirements listed on the pesticide label. 

 Low-impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, 

Thinvert system applications) would be used rather than broadcast foliar applications (e.g., 

boom sprayer, other larger tank, wand applications), where practical. 

 Low-volume rather than high-volume foliar applications would be used where low-impact 

methods described above are not feasible or practical, to maximize herbicide effectiveness 

and ensure correct and uniform application rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum 

with optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average <7 miles per hour [mph] and 

preferably 3 to 5 mph) and consistent direction wind conditions with moderate temperatures 

(typically <80°F). 

 Where possible, applicators would avoid spraying during inversion conditions (often 

associated with calm and very low wind conditions), which can cause large-scale herbicide 

drift to nontarget areas. 

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied 

to the target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom 

treatments) would typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30 percent forecast for rain within 

6 hours, except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to 

minimize/eliminate potential runoff. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-12 Appendix G. Integrated Pest Management Program 

 Where possible, applicators would use drift retardant adjuvants during spray applications, 

especially adjacent to sensitive areas. 

 Where possible, applicators would use a non-toxic dye to aid in identifying target area treated 

as well as potential overspray or drift. A dye can also aid in detecting equipment leaks. If a 

leak is discovered, the application would be stopped until repairs can be made to the sprayer. 

 For pesticide uses associated with cropland and facilities management, buffers, as 

appropriate, would be used to protect sensitive habitats, especially wetlands and other aquatic 

habitats. 

 When drift cannot be sufficiently reduced through altering equipment setup and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of 

applications. Refuge staff would only apply pesticide adjacent to sensitive areas when the 

wind is blowing in the opposite direction. 

 Refuge staff would consider timing of application so native plants are protected (e.g., 

senescence) while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or 

applied to an appropriate pest plant infestation. 

 Application equipment (e.g., sprayer, all-terrain vehicle [ATV], tractor) would be thoroughly 

cleaned and PPE would be removed/disposed of on-site by applicators after treatments to 

eliminate the potential spread of pests to uninfested areas. 

G.6. Safety 

G.6.1 Personal Protective Equipment 

All applicators would wear the specific PPE identified on the pesticide label. The appropriate PPE 

would be worn at all times during handling, mixing, and application. PPE can include the following: 

disposable (e.g., Tyvek) or laundered coveralls; gloves (latex, rubber, or nitrile); rubber boots; and/or 

a National Institute for Occupational Safety and Health (NIOSH)-approved respirator. Because 

exposure to concentrated product is usually greatest during mixing, extra care should be taken while 

preparing pesticide solutions. Persons mixing these solutions can be best protected if they wear long 

gloves, an apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately 

from other laundry items. Transporting, storing, handling, mixing, and disposing of pesticide 

containers would be consistent with label requirements, EPA and Occupational Safety and Health 

Administration (OSHA) requirements, and Service policy. 

If a respirator is necessary for a pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical examination 

(including pulmonary function and blood work for contaminants), and proper storage of the 

respirator. 

G.6.2 Notification 

The restricted entry interval (REI) is the time period required after application after which someone 

may safely enter a treated area without PPE. Refuge staff, authorized management agents of the 

Service, volunteers, and members of the public who could be in or near a pesticide-treated area 

within the stated re-entry time period on the label would be notified about treatment areas. Posting 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-13 

would occur at any site where individuals might inadvertently become exposed to a pesticide during 

other activities on the refuge. Where required by the label and/or state-specific regulations, signs 

would also be posted on the perimeter of treatment areas and at other likely locations of entry. 

Refuge staff would also notify appropriate private property owners of an intended application, 

including any private individuals who have requested notification. Special efforts would be made to 

contact nearby individuals who are beekeepers or who have expressed chemical sensitivities. 

G.6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, 

apply, and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical 

Surveillance]). In accordance with 242 FW 7.12A, Service personnel would be medically monitored 

if one or more of the following criteria is met: exposed or may be exposed to concentrations at or 

above the published permissible exposure limits or threshold limit values (see 242 FW 4); pesticide 

use is considered “frequent pesticide use”; or pesticide use requires a respirator (see 242 FW 14 for 

respirator use requirements). According to 242 FW 7.7A, “frequent pesticide use means when a 

person applying pesticide handles, mixes, or applies pesticides, with a Health Hazard rating of 3 or 

higher, for 8 or more hours in any week or 16 or more hours in any 30-day period.” Under some 

circumstances, individuals who use pesticides infrequently, experience an acute exposure (sudden, 

short term), or use pesticides with a health hazard ranking of 1 or 2 may also be medically monitored. 

This decision would consider the individual’s health and fitness level, the pesticide’s specific health 

risks, and the potential risks from other pesticide-related activities. Refuge cooperators (e.g., 

cooperative farmers) and other authorized agents (e.g., state and county employees) would be 

responsible for their own medical monitoring needs and costs. 

Standard examinations (at refuge expense) of appropriate refuge staff would be provided by the 

nearest certified occupational health and safety physician as determined by Federal Occupational 

Health. 

G.6.4 Certification and Supervision of Pesticide Applicators 

Appropriate refuge staff or approved volunteers handling, mixing, and/or applying, or directly 

supervising others engaged in pesticide use activities, would be trained and state or federally licensed 

to apply pesticides to refuge lands or waters. In accordance with 242 FW 7.18A and 569 FW 1.10B, 

certification is required to apply restricted use pesticides based upon EPA regulations. For safety 

reasons, all individuals participating in pest management activities with general use pesticides also 

are encouraged to attend appropriate training or acquire pesticide applicator certification. New staff 

unfamiliar with proper procedures for storing, mixing, handling, applying, and disposing of 

pesticides and containers would receive orientation and training before handling or using any 

products. Documentation of training would be kept in the files at the refuge office. 

G.6.5 Record Keeping 

G.6.5.1 Labels and Material Safety Data Sheets 

Pesticide labels and MSDSs would be maintained at the refuge shop. A written reference (e.g., note 

pad, chalk board, dry erase board) for each tank to be mixed would be kept in the mixing area for 

quick reference while mixing is in progress. In addition, approved PUPs stored in the PUPS database 

typically contain website links to pesticide labels and MSDSs. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-14 Appendix G. Integrated Pest Management Program 

G.6.5.2 Pesticide Use Proposals 

A PUP would be prepared for each proposed pesticide use associated with annual pest management 

on refuge lands and waters. A PUP would include specific information about the proposed pesticide 

use including the common and chemical names of the pesticide(s), target pest species, size and 

location of treatment site(s), application rate(s) and method(s), and federally listed species 

determinations, where applicable.

In accordance with Service guidelines (Service Director’s memo [December 12, 2007]), refuge staff 

may receive up to 5-year approvals for Service Washington Office and field-reviewed proposed 

pesticide uses based upon meeting identified criteria including an approved IPM plan, where 

necessary (see http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan 

(requirements described herein) can be completed independently or in association with a CCP or a 

habitat management plant (HMP) if IPM strategies and potential environmental effects are 

adequately addressed within appropriate NEPA documentation. 

G.6.5.3 Pesticide Use 

In accordance with 569 FW 1, the refuge project leader would be required to maintain records of all 

pesticides annually applied on lands or waters under refuge jurisdiction. This would encompass 

pesticides applied by other Federal agencies, state and county governments, and nongovernment 

applicators including cooperators and their pest management service providers with Service 

permission. For clarification, pesticide means all insecticides, insect and plant growth regulators, 

desiccants, herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and 

piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s) 

 Active ingredient(s) 

 Total acres treated 

 Total amount of pesticides used (lbs or gallons) 

 Total amount of active ingredient(s) used (lbs) 

 Target pest(s) 

 Efficacy (% control) 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target 

pest) and achieving resource objectives, habitat and/or wildlife response would be monitored both 

pretreatment and posttreatment, where possible. Considering available annual funding and staffing, 

appropriate monitoring data regarding characteristics (attributes) of pest infestations (e.g., area, 

perimeter, degree of infestation density, percent cover, density) as well as habitat and/or wildlife 

response to treatments may be collected and stored in a relational database (e.g., Refuge Habitat 

Management Database), preferably a georeferenced data management system (e.g., Refuge Lands 

Geographic Information System [GIS]) to facilitate data analyses and subsequent reporting. In 

accordance with adaptive management, data analysis and interpretation would allow treatments to be 

modified or changed over time, as necessary, to achieve resource objectives considering site-specific 

conditions in conjunction with habitat and/or wildlife responses. Monitoring could also identify 

short- and long-term impacts to natural resources and environmental quality associated with IPM 

treatments in accordance with adaptive management principles identified in 43 CFR 46.145. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-15 

G.7 Evaluating Pesticide Use Proposals 

Pesticides would only be used on refuge lands for habitat management and croplands/facilities 

maintenance after approval of a PUP. In general, proposed pesticide uses on refuge lands would only 

be approved where there would likely be minor, temporary, or localized effects to fish and wildlife 

species as well as minimal potential to degrade environmental quality. Potential effects to listed and 

nonlisted species would be evaluated with quantitative ecological risk assessments and other 

screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments and characteristics 

of environmental fate and potential of pesticides to degrade environmental quality would be 

documented in chemical profiles (see Section G.7.6). These profiles would include threshold values 

for quantitative measures of ecological risk assessments and screening tools for environmental fate 

that represent minimal potential effects to species and environmental quality. In general, only 

pesticide uses with appropriate BMPs (see Section G.5) for habitat management and 

cropland/facilities maintenance on refuge lands that would potentially have minor, temporary, or 

localized effects on refuge biological and environmental quality (threshold values not exceeded) 

would be approved. 

G.7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to 

biological resources as a result of a pesticide proposed for use on refuge lands. It is an established 

quantitative and qualitative methodology for comparing and prioritizing risks of pesticides and 

conveying an estimate of the potential risk for an adverse effect. This quantitative methodology 

provides an efficient mechanism to integrate best available scientific information regarding hazards, 

patterns of use (exposure), and dose-response relationships in a manner that is useful for ecological 

risk decision making. It would provide an effective way to evaluate potential effects where there is 

missing or unavailable scientific information (data gaps) to address reasonable, foreseeable adverse 

effects in the field as required under 40 CFR 1502.22. Protocols for ecological risk assessment of 

pesticide uses on the refuge were developed through research and established by the EPA (2004). 

The toxicological data used in ecological risk assessments are typically results of standardized 

laboratory studies provided by pesticide registrants to the EPA to meet regulatory requirements under 

FIFRA. These studies assess the acute (lethality) and chronic (reproductive) effects associated with 

short- and long-term exposure to pesticides on representative species of birds, mammals, freshwater 

fish, aquatic invertebrates, and terrestrial and aquatic plants. Other effects data publicly available 

would also be used for risk assessment protocols described herein. Toxicity endpoint and 

environmental fate data are available from a variety of resources. Some of the more useful resources 

can be found in Section G.7.6. 

G.7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the refuge to cause direct adverse effects to fish and wildlife 

would be evaluated using the EPA’s ecological risk assessment process (EPA 2004). This 

deterministic approach, which is based upon a two-phase process involving estimation of 

environmental concentrations and then characterization of risk, would be used for ecological risk 

assessments. This method integrates exposure estimates (estimated environmental concentration 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-16 Appendix G. Integrated Pest Management Program 

[EEC] and toxicological endpoints [e.g., LC50 and oral LD50]) to evaluate the potential for adverse 

effects to species groups (birds, mammals, and fish) representative of legal mandates relevant for 

managing units of the Refuge System. This integration is achieved through risk quotients (RQs) 

calculated by dividing the EEC by acute and chronic toxicity values selected from standardized 

toxicological endpoints or published effects (Table G-1). 

RQ = EEC/Toxicological Endpoint 

Table G-1. Ecotoxicity Tests Used to Evaluate Potential Effects to Birds, Fish, and 

Mammals to Establish Toxicity Endpoints for Risk Quotient Calculations 

Species Group Exposure Measurement Endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1 

Fish 

Acute LC50 

Chronic NOEC or NOAEC2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic NOEC or NOAEC3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of eggs, 

number of offspring, eggshell thickness, and number of cracked eggs). 

2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time to 

hatch, growth, and time to swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental anomalies, 

evidence of mutagenicity or genotoxicity, and interference with cellular mechanisms such as DNA 

synthesis and DNA repair. 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by the EPA (1998b) (Table G2). The LOC represents a quantitative threshold value for screening potential adverse effects to fish 

and wildlife resources associated with pesticide use. The following are four exposure-species group 

scenarios that would be used to characterize ecological risk to fish and wildlife on the refuge: acutelisted species, acute-nonlisted species, chronic-listed species, and chronic-nonlisted species. 

Table G-2. Presumption of Unacceptable Risk for Birds, Fish, and Mammals (EPA 1998b) 

Risk Presumption Level of Concern 

Listed Species Nonlisted Species 

Acute 

Birds 0.1 0.5 

Fish 0.5 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-17 

Table G-2. Presumption of Unacceptable Risk for Birds, Fish, and Mammals (EPA 1998b) 

Risk Presumption Level of Concern 

Listed Species Nonlisted Species 

 Fish 1.0 1.0 

 Mammals 1.0 1.0 

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from 

LC50 and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, 

chronic risks would indicate the potential for adverse effects associated with long-term dietary 

exposure to pesticides from a single application or multiple applications over time (within a season 

and over years). For characterization of chronic risks, the no observed adverse effect concentration 

(NOAEC) or no observed effect concentration (NOEC) for reproduction would be used as 

toxicological endpoints for RQ calculations. Where available, the NOAEC would be preferred over a 

NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance 

with the Endangered Species Act of 1973. For listed species, potential adverse effects would be 

assessed at the individual level because loss of individuals from a population could detrimentally 

impact a species. In contrast, risks to nonlisted species would consider effects at the population level. 

A RQ<LOC would indicate the proposed pesticide use “may affect, not likely to adversely affect” 

individuals (listed species) and it would not pose an unacceptable risk for adverse effects to 

populations (nonlisted species) for each taxonomic group (Table G-2). In contrast, an RQ>LOC 

would indicate a “may affect, likely to adversely affect” for listed species, and it would also pose 

unacceptable ecological risk for adverse effects to nonlisted species. 

G.7.2.1 Environmental Exposure 

Following release into the environment through application, pesticides would experience several 

different routes of environmental fate. Pesticides that would be sprayed can move through the air 

(e.g., particle or vapor drift) and may eventually end up in other parts of the environment such as 

nontarget vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil 

into nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower 

soil layers and groundwater (Baker and Miller 1999; Butler et al. 1998; Extension Toxicology 

Network [EXTOXNET] 1993; Pope et al. 1999; Ramsay et al. 1995). Pesticides that would be 

injected into the soil may also be subject to the latter two fates. The aforementioned possibilities are 

by no means complete, but do indicate that movement of pesticides in the environment is very 

complex, with transfers occurring continually among different environmental compartments. In some 

cases, these exchanges occur not only between areas that are close together, but may also involve 

transportation of pesticides over long distances (Barry 2004; Woods 2004). 

G.7.2.1.1 Terrestrial Exposure 

The ECC for exposure to terrestrial wildlife would be quantified using an EPA screening-level 

approach (EPA 2004). This screening-level approach is not affected by product formulation because 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-18 Appendix G. Integrated Pest Management Program 

it evaluates pesticide active ingredient (a.i.). This approach would vary depending upon the proposed 

pesticide application method: spray or granular. 

G.7.2.1.1.1 Terrestrial—spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (EPA 

2004, 2005a; Pfleeger et al. 1996) through the EPA’s Terrestrial Residue Exposure model (T-REX) 

version 1.2.3 (EPA 2005b). To estimate the maximum (initial) pesticide residue on short grass (<20 

centimeter [cm] tall) as a general food item category for terrestrial vertebrate species, T-REX input 

variables would include the following from the pesticide label: maximum pesticide application rate 

(pounds a.i. [acid equivalent]/acre) and pesticide half-life (days) in soil. Although there are other 

food item categories (tall grasses; broadleaf plants and small insects; and fruits, pods, seeds and large 

insects), short grass was selected because it would yield maximum EECs (240 parts per million 

[ppm] per lb a.i./acre) for worst-case risk assessments. Short grass is not representative of forage for 

carnivorous species (e.g., raptors), but it would characterize the maximum potential exposure through 

the diet of avian and mammalian prey items. Consequently, this approach would provide a 

conservative screening tool for pesticides that do not biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et al. 1996). Body weights of bobwhite quail and mallard are included in TREX by default, but body weights of other organisms (Table G-3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 

would be used as a default. Alternatively, zero would be entered if it is known that body weight does 

not influence toxicity of pesticide(s) being assessed. The upper bound estimate output from the TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would yield 

a conservative estimate of ecological risk. 

Table G-3. Average Body Weight of Selected Terrestrial Wildlife 

Species Frequently used in Research to Establish Toxicological 

Endpoints (Dunning 1984) 

Species Body Weight (kilogram [kg]) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Rock dove (aka pigeon) 0.542 

Mammal (1,000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-19 

G.7.2.1.1.2 Terrestrial—granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units, which birds or mammals 

might ingest accidentally with food items or intentionally as in the case of some bird species that 

actively seek and pick up gravel or grit to aid digestion or seed as a food source. Granules may also 

be consumed by wildlife foraging on earthworms, slugs, or other soft-bodied soil organisms to which 

the granules may adhere. 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing 

the maximum milligrams of a.i. exposed (e.g., EEC) on the surface of an area equal to 1 square foot 

by the appropriate LD50 value multiplied by the surrogate’s body weight (Table G-3). An adjustment 

to surface area calculations would be made for broadcast, banded, and in-furrow applications. An 

adjustment also would be made for applications with and without incorporation of the granules. 

Without incorporation, it would be assumed that 100 percent of the granules remain on the soil 

surface available to foraging birds and mammals. Press wheels push granules flat with the soil 

surface, but the granules are not incorporated into the soil. If granules are incorporated in the soil 

during band or T-band applications or after broadcast applications, it would be assumed only 15 

percent of the applied granules remain available to wildlife. It would be assumed that only 1 percent 

of the granules are available on the soil surface following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined 

considering potential ingestion rates of avian or mammalian species (e.g., 10-30% body weight/day). 

This would provide an estimate of maximum exposure that may occur as a result of granule or seed 

treatment spills such as those that commonly occur at end rows during application and planting. The 

availability of granules and seed treatments to terrestrial vertebrates would also be considered by 

calculating the loading per unit area (LD50/feet2

)for comparison to the EPA LOC (EPA 1998b). The 

T-REX version 1.2.3 (EPA 2005b) contains a submodel that automates Kanaga exposure calculations 

for granular pesticides and treated seed. 

The following formulas would be used to calculate EECs depending upon the type of granular 

pesticide application: 

 In-furrow applications assume a typical value of 1 percent granules, bait, or seed remain 

unincorporated. 

mg a.i./feet

2 

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 

feet

2

/acre)/(row spacing (feet))] / (row spacing (feet)} 

or 

mg a.i./feet

2 

= [(lbs product/1,000 foot row)(% a.i.)(1,000 foot row)(453,580 mg/lb.)(1% exposed) 

EEC = [(mg a.i./feet

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume that 15 percent of granules, bait, and seeds are 

unincorporated. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-20 Appendix G. Integrated Pest Management Program 

mg a.i./feet

2 

= [(lbs. product/1,000 row feet)(% a.i.)(453,580 mg/lb.)(1 − % incorporated)]/(1,000 

feet)(band width (feet)) 

EEC = [(mg a.i./feet

2

)(% of pesticide biologically available)] 

 Broadcast treatment without incorporation assumes 100 percent of granules, bait, and seeds 

are unincorporated. 

mg a.i./feet

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)]/(43,560 feet

2

/acre) 

EEC = [(mg a.i./feet

2

)(% of pesticide biologically available)] 

Where: 

 % of pesticide biologically available = 100 percent without species-specific ingestion rates 

 Conversion for calculating mg a.i./feet

2 

using ounces: 453,580 mg/lb./16 = 28,349 mg/oz. 

The following equation would be used to calculate an RQ based on the EEC calculated by one of the 

above equations. The EEC would be divided by the surrogate LD50 toxicological endpoint multiplied 

by the body weight (Table G-3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, an RQ>LOC would be a presumption of unacceptable ecological 

risk. An RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or 

localized effects to species. 

G.7.2.1.2 Aquatic Exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) 

would be evaluated separately for ground-based pesticide treatments of habitats managed for fish and 

wildlife compared with cropland/facilities maintenance. The primary exposure pathway for aquatic 

organisms from any ground-based treatments likely would be particle drift during the pesticide 

application. However, different exposure scenarios would be necessary as a result of contrasting 

application equipment and techniques as well as pesticides used to control pests on agricultural lands 

(especially those cultivated by cooperative farmers for economic return from crop yields) and 

facilities maintenance (e.g., roadsides, parking lots, trails) compared with other managed habitats on 

the refuge. In addition, pesticide applications may be done <25 feet of the high water mark of aquatic 

habitats for habitat management treatments, whereas no-spray buffers (≥25 feet) would be used for 

croplands/facilities maintenance treatments. 

G.7.2.1.2.1 Habitat treatments 

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table G-4) would be 

derived from Urban and Cook (1986), which assumes an intentional overspray to an entire, nontarget water body (1 foot depth) from a treatment <25 feet from the high water mark using the 

maximum application rate (acid basis). However, use of BMPs for applying pesticides (see Section 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-21 

G.5.2) would likely minimize/eliminate potential drift to non-target aquatic habitats during actual 

treatments. If there would be unacceptable (acute or chronic) risk to fish and wildlife with the 

simulated 100 percent overspray (RQ>LOC), then the proposed pesticide use may be disapproved or 

the PUP may be approved at a lower application rate to minimize/eliminate unacceptable risk to 

aquatic organisms (RQ = LOC). 

Table G-4. Estimated Environmental Concentrations of 

Pesticides in Aquatic Habitats (1 foot depth) Immediately after 

Direct Application (Urban and Cook 1986) 

Lbs/acre EEC (parts per billion (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 

2.25 827.6 

2.50 919.4 

3.00 1,103.5 

4.00 1,471.4 

5.00 1,839 

6.00 2,207 

7.00 2,575 

8.00 2,943 

9.00 3,311 

10.00 3,678 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-22 Appendix G. Integrated Pest Management Program 

G.7.2.1.2.2 Cropland/facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force (SDTF), which is a joint project of 

several agricultural chemical businesses, were used to develop a generic spray drift database. From 

this database, the AgDRIFT computer model was created to satisfy EPA pesticide registration spray 

drift data requirements and as a scientific basis to evaluate off-target movement of pesticides from 

particle drift and assess potential effects of exposure to wildlife. The SDTF AgDRIFT model version 

2.01 (AgDRIFT 2001; SDTF 2003) would be used to derive EECs resulting from drift of pesticides 

to refuge aquatic resources from ground-based pesticide applications >25 feet from the high water 

mark. The SDTF AgDRIFT model is publicly available at http://www.agdrift.com. At this website, 

click “AgDRIFT 2.0,” followed by “Download Now,” and follow the instructions to obtain the 

computer model. 

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used 

to assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with 

AgDRIFT using the following input variables: maximum application rate (acid basis), low boom (20 

inches), fine to medium droplet size, EPA-defined wetland, and a ≥25-foot distance (buffer) from 

treated area to water. 

G.7.2.2 Use of Information on Effects of Biological Control Agents, Pesticides, 

Degradates, and Adjuvants 

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another Federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents include the Bureau of Land Management, USFS, 

National Park Service, USDA-APHIS, and the military services. It might be appropriate to 

incorporate by reference parts or all of existing document(s). Incorporating by reference (40 CFR 

1502.21) is a technique used to avoid redundancies in analysis. It also would reduce the bulk of a 

Service NEPA document, which only would identify the documents that are incorporated by 

reference. In addition, relevant portions would be summarized in the Service NEPA document to the 

extent necessary to provide the decision maker and public with an understanding of relevance of the 

referenced material to the current analysis. 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the USFS 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlantEIS.htm) and Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). 

These risk assessments and associated documentation also are available in total with the 

administrative record for the final environmental impact statement titled Pacific Northwest Region 

Invasive Plant Program – Preventing and Managing Invasive Plants (USFS 2005) and Vegetation 

Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States 

Programmatic EIS (PEIS) (Bureau of Land Management 2007). In accordance with 43 CFR 

46.120(d), use of existing NEPA documents by supplementing, tiering to, incorporating by reference, 

or adopting previous NEPA environmental analyses would avoid redundancy and unnecessary 

paperwork. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-23 

As a basis for completing chemical profiles for approving or disapproving refuge PUPs, ecological 

risk assessments for the following herbicide and adjuvant uses prepared by the USFS would be 

incorporated by reference: 

 2,4-D 

 Chlorosulfuron 

 Clopyralid 

 Dicamba 

 Glyphosate 

 Imazapic 

 Imazapyr 

 Metsulfuron methyl 

 Picloram 

 Sethoxydim 

 Sulfometuron methyl 

 Triclopyr 

 Nonylphenol polyethoxylate (NPE)-based surfactants 

As a basis for completing chemical profiles for approving or disapproving refuge PUPs, ecological 

risk assessments for the following herbicide uses as well as evaluation of risks associated with 

pesticide degradates and adjuvants prepared by the Bureau of Land Management would be 

incorporated by reference: 

 Bromacil 

 Chlorosulfuron 

 Diflufenzopyr 

 Diquat 

 Diuron 

 Fluridone 

 Imazapic 

 Overdrive (diflufenzopyr and dicamba) 

 Sulfometuron methyl 

 Tebuthiuron 

 Pesticide degradates and adjuvants 

G.7.2.3 Assumptions for Ecological Risk Assessments 

There are a number of assumptions involved with the ecological risk assessment process for 

terrestrial and aquatic organisms associated with use of the EPA’s (2004) process. These assumptions 

may be risk neutral or may lead to an over- or under-estimation of risk from pesticide exposure 

depending upon site-specific conditions. The following describes these assumptions, their application 

to the conditions typically encountered, and whether they may lead to recommendations that are risk 

neutral, or that underestimate or overestimate ecological risk from potential pesticide exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include 

the mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-24 Appendix G. Integrated Pest Management Program 

small mammals), reductions in the availability of prey items, and disturbance associated with 

pesticide application activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar 

or substantially different compared to only the active ingredient. Nontarget organisms may be 

exposed directly to the pesticide formulation or only various constituents of the formulation 

as they dissipate and partition in the environment. If toxicological information for both the 

active ingredient and formulated product are available, then data representing the greatest 

potential toxicity would be selected for use in the risk assessment process (EPA 2004). As a 

result, this conservative approach may lead to an overestimation of risk characterization from 

pesticide exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not 

available, data for surrogate species would be most often used for risk assessments. 

Specifically, bobwhite quail and mallard duck are the most frequently used surrogates for 

evaluating potential toxicity to federally listed avian species. Bluegill sunfish, rainbow trout, 

and fathead minnow are the most common surrogates for evaluating toxicity for freshwater 

fishes. Sheep’s head minnow can be an appropriate surrogate marine species for coastal 

environments. Rats and mice are the most common surrogates for evaluating toxicity to 

mammals. Interspecies sensitivity is a major source of uncertainty in pesticide assessments. 

As a result of this uncertainty, data are selected for the most sensitive species tested within a 

taxonomic group (birds, fish, and mammals) given the quality of the data is acceptable. If 

additional toxicity data for more species of organisms in a particular group are available, the 

selected data would not be limited to the species previously listed as common surrogates. 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an 

average daily concentration over a specified interval of time, which is referred to as a timeweighted-average (TWA). The maximum EEC would be selected as the exposure input for 

both acute and chronic risk assessments in the screening-level evaluations. The initial or 

maximum EEC derived from the Kanaga nomogram represents the maximum expected 

instantaneous or acute exposure to a pesticide. Acute toxicity endpoints are determined using 

a single exposure to a known pesticide concentration typically for 48 to 96 hours. This value 

is assumed to represent ecological risk from acute exposure to a pesticide. On the other hand, 

chronic risk to pesticide exposure is a function of pesticide concentration and duration of 

exposure to the pesticide. An organism’s response to chronic pesticide exposure may result 

from either the concentration of the pesticide or the length of exposure, or some combination 

of both factors. Standardized tests for chronic toxicity typically involve exposing an 

organism to several different pesticide concentrations for a specified length of time (days, 

weeks, months, years, or generations). For example, avian reproduction tests include a 10-

week exposure phase. Because a single length of time is used in the test, time response data 

are usually not available for inclusion in risk assessments. Without time response data it is 

difficult to determine the concentration that elicits a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimation of risk, 

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of 

exposure that is primarily responsible for the observed adverse effect. The maximum EEC 

would be used for chronic risk assessments although it may result in an overestimation of 

risk. TWAs may be used for chronic risk assessments, but they would be applied judiciously 

considering the potential for underestimation or overestimation of risk. For example, the 

number of days exposure exceeds an LOC may influence the suitability of a pesticide use. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-25 

The greater the number of days the EEC exceeds the LOC, the greater the ecological risk. 

This is a qualitative assessment, and is subject to reviewers’ expertise in ecological risk 

assessment and tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates, and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to 

avian reproductive studies designed to establish a steady-state concentration for 

bioaccumulative compounds. However, this does not necessarily define the true exposure 

duration needed to elicit a toxicological response. Pesticides that do not bioaccumulate may 

achieve a steady-state concentration earlier than 21 weeks. The duration of time for 

calculating TWAs would require justification and would not exceed the duration of exposure 

in the chronic toxicity test (approximately 70 days for the standard avian reproduction study). 

An alternative to using the duration of the chronic toxicity study is to base the TWA on the 

application interval. In this case, increasing the application interval would suppress both the 

estimated peak pesticide concentration and the TWA. Another alternative to using TWAs 

would be to consider the number of days that a chemical is predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as biphasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, 

these data are often not available and can be misleading, particularly if the compound is 

prone to “wash-off.” Soil half-life is the most common degradation data available. 

Dissipation or degradation data that would reflect the environmental conditions typical of 

refuge lands would be used, if available. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area, or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would 

likely lead to an overestimation of exposure for species that do not permanently and 

exclusively occupy the treated area (EPA 2004). 

 Exposure through incidental ingestion of pesticide-contaminated soil is not considered in the 

EPA risk assessment protocols. Research suggests <15 percent of the diet can consist of 

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). 

An assessment of pesticide concentrations in soil compared to food item categories in the 

Kanaga nomogram indicates incidental soil ingestion would not likely increase dietary 

exposure to pesticides. Inclusion of soil into the diet would effectively reduce the overall 

dietary concentration compared to the present assumption that the entire diet consists of a 

contaminated food source (Fletcher et al. 1994). An exception to this may be soil-applied 

pesticides in which exposure from incidental ingestion of soil may increase. Potential for 

pesticide exposure under this assumption may be underestimated for soil-applied pesticides 

and overestimated for foliar-applied pesticides. The concentration of a pesticide in soil would 

likely be less than predicted on food items. 

 Exposure through inhalation of pesticides is not considered in the EPA risk assessment 

protocols. Such exposure may occur through three potential sources: spray material in droplet 

form at time of application, vapor phase with the pesticide volatilizing from treated surfaces, 

and airborne particulates (soil, vegetative matter, and pesticide dusts). The EPA (1990) 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-26 Appendix G. Integrated Pest Management Program 

reported exposure from inhaling spray droplets at the time of application is not an appreciable 

route of exposure for birds. According to research on mallards and bobwhite quail, respirable 

particle size (particles reaching the lung) in birds is limited to maximum diameter of 2 to 5 

microns. The spray droplet spectra covering the majority of pesticide application scenarios 

indicate that less than 1 percent of the applied material is within the respirable particle size. 

This route of exposure is further limited because the permissible spray drop size distribution 

for ground pesticide applications is restricted to American Society of Agricultural Engineers 

(ASAE) medium or coarser drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some 

pesticides under certain conditions. This mechanism of exposure to pesticides occurs postapplication, and it would pertain to those pesticides with a high vapor pressure. The EPA is 

currently evaluating protocols for modeling inhalation exposure from pesticides including 

near-field and near-ground air concentrations based upon equilibrium and kinetics-based 

models. Risk characterization for exposure with this mechanism is unavailable. 

 The effect from exposure to dust contaminated with the pesticide cannot be assessed 

generically as partitioning issues related to application site soils and chemical properties of 

the applied pesticides render the exposure potential from this route highly situation-specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray 

and incidental contact with treated substrates may pose risk to avian wildlife (Driver et al. 

1991). However, available research related to wildlife dermal contact with pesticides is 

extremely limited, with the exception of dermal toxicity values for some mammals used as 

human surrogates (rats and mice), which are common. The EPA is currently evaluating 

protocols for modeling dermal exposure. Risk characterization may be underestimated for 

this route of exposure, particularly with high-risk pesticides such as some organophosphates 

or carbamate insecticides. If protocols are established by the EPA for assessing dermal 

exposure to pesticides, they would be considered for incorporation into pesticide assessment 

protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew, or other water on 

treated surfaces. Water-soluble pesticides have the potential to dissolve in surface runoff, and 

puddles in a treated area may contain pesticide residues. Similarly, pesticides with lower 

organic carbon partitioning characteristics and higher solubility in water have a greater 

potential to dissolve in dew and other water associated with plant surfaces. Estimating the 

extent to which such pesticide loadings to drinking water occurs is complex and would 

depend upon the partitioning characteristics of the active ingredient, soil types in the 

treatment area, and the meteorology of the treatment area. In addition, the use of various 

water sources by wildlife is highly species-specific. Currently, risk characterization for this 

exposure mechanism is not available. The EPA is actively developing protocols to quantify 

drinking water exposure from puddles and dew. If and when protocols are formally 

established by the EPA for assessing exposure to pesticides through drinking water, these 

protocols would be incorporated into pesticide risk assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be 

subject to pesticide application at the rates specified on the label. In most cases, there is 

potential for uneven application of pesticides through such plausible incidents such as 

changes in calibration of application equipment, spillage, and localized releases at specific 

areas in or near the treated field that are associated with mixing and handling and application 

equipment as well as applicator skill. Inappropriate use of pesticides and the occurrence of 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-27 

spills represent a potential underestimation of risk. It is likely not an important factor for risk 

characterization. All pesticide applicators are required to be certified by the state in which 

they apply pesticides. Certification training includes the safe storage, transport, handling, and 

mixing of pesticides; equipment calibration; and proper application with annual continuing 

education. 

 The EPA relies on Fletcher et al. (1994) for setting the assumed pesticide residues in wildlife 

dietary items. The EPA (2004) “believes that these residue assumptions reflect a realistic 

upper-bound residue estimate, although the degree to which this assumption reflects a 

specific percentile estimate is difficult to quantify.” Fletcher et al.’s (1994) research suggests 

that the pesticide active ingredient residue assumptions used by the EPA represent a ninetyfifth percentile estimate. However, research conducted by Pfleeger et al. (1996) indicates 

EPA residue assumptions for short grass were not exceeded. Baehr and Habig (2000) 

compared the EPA residue assumptions with distributions of measured pesticide residues for 

the EPA’s Uptake, Translocation, Accumulation, and Biotransformation (UTAB) database. 

Overall residue selection levels would tend to overestimate risk characterization. This is 

particularly evident when wildlife individuals are likely to have selected a variety of food 

items acquired from multiple locations. Some food items may be contaminated with pesticide 

residues whereas others are not contaminated. However, it is important to recognize 

differences in species feeding behavior. Some species may consume whole aboveground 

plant material, but others preferentially select different plant structures. Also, species may 

preferentially select a food item although multiple food items may be present. Without 

species-specific knowledge regarding foraging behavior, characterizing ecological risk other 

than in general terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with 

LC50 or NOEC values expressed as concentrations of pesticides in laboratory feed. These 

comparisons assume that ingestion of food items in the field occurs at rates commensurate 

with those in the laboratory. Although the screening assessment process adjusts dry-weight 

estimates of food intake to reflect the increased mass in fresh-weight wildlife food intake 

estimates, it does not allow for gross energy and assimilative efficiency differences between 

wildlife food items and laboratory feed. Differences in assimilative efficiency between 

laboratory and wild diets suggest that current screening assessment methods are not 

accounting for a potentially important aspect of food requirements. 

 There are several other assumptions that can affect non-target species not considered in the 

risk assessment process. These include possible additive or synergistic effects from applying 

two or more pesticides or additives in a single application, co-location of pesticides in the 

environment, cumulative effects from pesticides with the same mode of action, effects of 

multiple stressors (e.g., combination of pesticide exposure and adverse abiotic and biotic 

factors), and behavioral changes induced by exposure to a pesticide. These factors may exist 

at some level contributing to adverse effects to non-target species, but they are usually 

characterized in the published literature in only a general manner, limiting their value in the 

risk assessment process.

 It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no 

habitat use considerations specific for any species would place the organisms in closer 

proximity to pesticide use sites. This assumption produces a maximum estimate of exposure 

or risk characterization. It would likely be realistic for many aquatic species that may be 

found in aquatic habitats within or in close proximity to treated terrestrial habitats. However, 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-28 Appendix G. Integrated Pest Management Program 

the spatial distribution of wildlife is usually not random because wildlife distributions are 

often related to habitat requirements of species. Clumped distributions of wildlife may result 

in an underestimation or overestimation of risk depending upon where the initial pesticide 

concentration occurs relative to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. Additional chemical exposure from materials associated with suspended solids or 

food items is not considered because partitioning onto sediments likely is minimal. 

Adsorption and bioconcentration occur at lower levels for many newer pesticides compared 

with older, more persistent bioaccumulative compounds. For pesticides with RQs close to the 

listed species LOC, the potential for additional exposure from these routes may be a 

limitation of risk assessments, where potential pesticide exposure or risk may be 

underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, 

degradation, and sediment partitioning) would not be considered for ecological risk 

assessment. The water body would be assumed to capture all pesticide active ingredients 

entering as runoff, drift, and adsorbed to eroded soil particles. It would also be assumed that 

pesticide active ingredient is not lost from the water body by overtopping or flow-through, 

nor is concentration reduced by dilution. In total, these assumptions would lead to a near 

maximum possible water-borne concentration. However, this assumption would not account 

for the potential to concentrate pesticide through evaporative loss. This limitation may have 

the greatest impact on water bodies with high surface-to-volume ratios such as ephemeral 

wetlands, where evaporative losses are accentuated and applied pesticides have low rates of 

degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration 

to elicit acute effects comparable to those observed over more protracted exposure periods 

(typically 48 to 96 hours) tested in the laboratory. In the absence of data regarding time-totoxic event and analyses and latent responses to instantaneous exposure, risk would likely be 

overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of the invertebrate life cycle or fish early life stage tests 

(e.g., 21-28 days and 56-60 days, respectively). Response profiles (time to effect and latency 

of effect) to pesticides likely vary widely with mode of action and species and should be 

evaluated on a case-by-case basis as available data allow. Nevertheless, because the EPA 

relies on chronic exposure, and toxicity endpoints based on a finding of no observed effect, 

the potential for any latent toxicity effects or averaging time assumptions to alter the results 

of an acceptable chronic risk assessment prediction is limited. The extent to which duration 

of exposure from water-borne concentrations overestimate or underestimate actual exposure 

depends on several factors. These include the following: localized meteorological conditions, 

runoff characteristics of the watershed (e.g., soils, topography), the hydrological 

characteristics of receiving waters, environmental fate of the pesticide active ingredient, and 

the method of pesticide application. It should also be understood that chronic effects studies 

are performed using a method that holds water concentration in a steady state. This method is 

not likely to reflect conditions associated with pesticide runoff. Pesticide concentrations in 

the field increase and decrease in surface water on a cycle influenced by rainfall, pesticide 

use patterns, and degradation rates. As a result of the dependency of this assumption on 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-29 

several undefined variables, risk associated with chronic exposure may in some situations be 

overestimated or underestimated. 

 The EPA is required by the Food Quality Protection Act to assess the cumulative risks of 

pesticides that share common mechanisms of toxicity, or act the same way within an 

organism. Currently, the EPA has identified four groups of pesticides that have a common 

mechanism of toxicity requiring cumulative risk assessments. These four groups are: the 

organophosphate insecticides, N-methyl carbamate insecticides, triazine herbicides, and 

chloroacetanilide herbicides. 

G.7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or a plant regulator, defoliant, 

desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must be 

identified by name(s) on the pesticide label along with its relative composition expressed in 

percentage(s) by weight. In contrast, inert ingredient(s) are not intended to affect a target pest. Their 

role in the pesticide formulation is to act as a solvent (keep the active ingredient is a liquid phase), an 

emulsifying or suspending agent (keep the active ingredient from separating out of solution), or a 

carrier (such as clay in which the active ingredient is impregnated on the clay particle in dry 

formulations). For example, if isopropyl alcohol is used as a solvent in a pesticide formulation, then 

it would be considered an inert ingredient. FIFRA only requires that inert ingredients identified as 

hazardous and associated percent composition, and the total percentage of all inert ingredients, must 

be declared on a product label. Inert ingredients that are not classified as hazardous are not required 

to be identified. 

The EPA (September 1997) issued Pesticide Regulation Notice 97-6, which encouraged 

manufacturers, formulators, producers, and registrants of pesticide products to voluntarily substitute 

the term “other ingredients” for “inert ingredients” in the ingredient statement. This change 

recognized that all components in a pesticide formulation potentially could elicit or contribute to an 

adverse effect on non-target organisms and, therefore, are not necessarily inert. Whether referred to 

as “inerts” or “other ingredients,” these constituents within a pesticide product have the potential to 

affect species or environmental quality. The USEPA categorizes regulated inert ingredients into the 

following four lists (EPA 2012): 

 List 1 – Inert Ingredients of Toxicological Concern 

 List 2 – Potentially Toxic Inert Ingredients 

 List 3 – Inerts of Unknown Toxicity 

 List 4 – Inerts of Minimal Toxicity 

Several of the List 4 compounds are naturally occurring earthen materials (e.g., clay materials, 

simple salts) that would not elicit toxicological response at applied concentrations. However, some of 

the inerts (particularly the List 3 compounds and unlisted compounds) may have moderate to high 

potential toxicity to aquatic species based on MSDS or published data. 

Comprehensively assessing potential effects to non-target fish, wildlife, plants, and/or their habitats 

from pesticide use is a complex task. It would be preferable to assess the cumulative effects from 

exposure to the active ingredient, its degradates, and inert ingredients as well as other active 

ingredients in the spray mixture. However, it would only be feasible to conduct deterministic risk 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-30 Appendix G. Integrated Pest Management Program 

assessments for each component in the spray mixture singly. Limited scientific information is 

available regarding ecological effects (additive or synergistic) from chemical mixtures that typically 

rely upon broadly encompassing assumptions. For example, the USFS (2005) found that mixtures of 

pesticides used in forest management likely would not cause additive or synergistic effects to 

nontarget species based upon a review of scientific literature regarding toxicological effects and 

interactions of agricultural chemicals (Agency for Toxic Substances and Disease Registry [ATSDR] 

2004). Moreover, information on inert ingredients, adjuvants, and degradates is often limited by the 

availability of and access to reliable toxicological data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

 Toxicology, Occupational Medicine, and Environmental Series (TOMES) (a proprietary 

toxicological database including EPA’s Integrated Risk Information System (IRIS), the 

Hazardous Substance Data Bank, the Registry of Toxic Effects of Chemical Substances 

[RTECS]) 

 EPA’s Ecotoxicology (ECOTOX) database, which includes Aquatic Information Retrieval 

(AQUIRE) (a database containing scientific papers published on the toxic effects of 

chemicals to aquatic organisms) 

 TOXLINE (a literature searching tool) 

 MSDSs from pesticide suppliers 

 Other sources such as the Farm Chemicals Handbook 

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the 

pesticide spray mixture, and it would be assumed that negligible effects would be expected to result 

from inert ingredients. 

Although the potential effects of degradates should be considered when selecting a pesticide, it is 

beyond the scope of this assessment process to consider all possible breakdown chemicals of the 

various product formulations containing an active ingredient. Degradates may be more or less mobile 

and more or less hazardous in the environment than their parent pesticides (Battaglin et al. 2003). 

Differences in environmental behavior (e.g., mobility) and toxicity between parent pesticides and 

degradates would make assessing potential degradate effects extremely difficult. For example, a less 

toxic and more mobile, bioaccumulative, or persistent degradate may have potentially greater effects 

on species and/or degrade environmental quality. The lack of data on the toxicity of degradates for 

many pesticides represents a source of uncertainty for assessing risk.

An EPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action is 

common among the chemicals and receptors. Moreover, the composition of and exposure to mixtures 

would be highly site- and/or time-specific and, therefore, it would be nearly impossible to assess 

potential effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides 

as a mixture, the use would be conducted in accordance with the labeling requirements. Labels for 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-31 

two or more pesticides applied as a mixture should be completely reviewed, and products with the 

least potential for negative effects would be selected for use on the refuge. This is especially relevant 

when a mixture would be applied in a manner that may already have the potential for an effect(s) 

associated with an individual pesticide. Use of a tank mix under these conditions would increase the 

level of uncertainty in terms of risk to species or potential to degrade environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial 

herbicides, adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally 

applies to surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, 

compatibility agents, stickers, and spreaders. Adjuvants are not under the same registration 

requirements as pesticides, and the EPA does not register or approve the labeling of spray adjuvants. 

Individual pesticide labels identify types of adjuvants approved for use with it. In general, adjuvants 

compose a relatively small portion of the volume of pesticides applied. Selection of adjuvants with 

limited toxicity and low volumes would be recommended to reduce the potential for the adjuvant to 

influence the toxicity of the pesticide. 

G.7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

refuge lands. A pesticide can only affect water quality through movement away from the treatment 

site. After application, pesticide mobilization can be characterized by one or more of the following 

(Kerle et al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from runoff or wind; 

 Dissolve in water that can be subjected to runoff or leaching. 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the 

following: persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50 percent 

of the deposited pesticide to degrade (completely or partially). Persistence in the soil can be 

categorized as the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days (Kerle et al. 1996). Half-life data are usually available for aquatic and terrestrial 

environments. 

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required 

for 50 percent of the deposited pesticide to degrade and move from a treated site, whereas half-life 

describes the rate for degradation only. As with half-life, units of dissipation time are usually 

expressed in days. Field or foliar dissipation times are the preferred data for use to estimate pesticide 

concentrations in the environment. However, soil half-lives are the most common persistence data 

cited in published literature. If field or foliar dissipation data are not available, soil half-life data may 

be used. The average or representative half-life value of most important degradation mechanism 

would be selected for quantitative analysis for both terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic 

matter, its solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to 

soil particles, relatively insoluble in water, and not environmentally persistent would be less likely to 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-32 Appendix G. Integrated Pest Management Program 

move across the soil surface into surface waters or to leach through the soil profile and contaminate 

groundwater. Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water 

soluble, and are persistent in the environment would have greater potential to move from the 

application site (off-site movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et al. 1996) is expressed 

as the soil adsorption coefficient. The Koc is measured as micrograms of pesticide per gram of soil 

(μg/g), which can range from near zero to the thousands. Pesticides with higher Koc values are 

strongly sorbed to soil and, therefore, would be less subject to movement. 

Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. 

The water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water 

(mg/L) or ppm. As pesticide solubility increases, there would be greater potential for off-site 

movement. 

The GUS is a quantitative screening tool to estimate a pesticide’s potential to move in the 

environment. It uses soil persistence and adsorption coefficients in the following formula. 

GUS = log10(t1⁄2) × [4 − log10 (Koc)] 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS 

<0.1 would be considered to have an extremely low potential to move toward groundwater. Values of 

1.0 to 2.0 would have low potential, 2.0 to 3.0 would have moderate potential, 3.0 to 4.0 would have 

high potential, and >4.0 would have a very high potential to move toward groundwater. 

GUS, water solubility, half-life, and Koc values are available for selected pesticides from the Oregon 

State University (OSU) Extension Pesticide Properties Database at http://npic.orst.edu/ppdmove.htm. 

Many of the values in this database were derived from the Soil Conservation Service/Agricultural 

Research Service/Cooperative Extension Service (SCS/ARS/CES) Pesticide Properties Database for 

Environmental Decision Making (Wauchope et al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by 

leaching (vertical movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse-textured soils (e.g., high sand content) have a larger pore size 

and are generally more permeable than fine-textured soils (i.e., high clay content). The more 

permeable soils would have a greater potential for pesticides to move vertically down 

through the soil profile. Soil permeability rates (inches/hour) are usually available in county 

soil survey reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller pore size would lower the likelihood and rate that water would move 

through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils 

with high clay content would adsorb more pesticide than soils with relatively low clay 

content. In contrast, sandy soils with coarser texture and lower water-holding capacity would 

have a greater potential for water to leach through them. 

 Soil structure describes soil aggregation. Soils with a well-developed soil structure have 

looser, more aggregated structures that would be less likely to be compacted. Both 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-33 

characteristics would allow for less restricted flow of water through the soil profile, resulting 

in greater infiltration.

 Organic matter would be the single most important factor affecting pesticide adsorption in 

soils. Many pesticides are adsorbed to organic matter, which would reduce their rate of 

downward movement through the soil profile. Also, soils high in organic matter would tend 

to hold more water, which may make less water available for leaching. 

 Soil moisture affects how fast water would move through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would result in runoff rather than 

infiltrate into the soil profile. Soil moisture also would influence microbial and chemical 

activity in soil, which effects pesticide degradation. 

 Soil pH influences chemical reactions that occur in the soil, which in turn determines whether 

a pesticide would degrade, the rate of degradation, and, in some instances, which degradation 

products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination 

would be sandy soils with low organic matter. In contrast, the least vulnerable soils would be welldrained clayey soils with high organic matter. Consequently, pesticides with the lowest potential for 

movement in conjunction with appropriate BMPs (see below) would be used in an IPM framework to 

treat pests while minimizing effects to non-target biota and protecting environmental quality. 

Along with soil properties, the potential for a pesticide to affect water quality through runoff and 

leaching would consider site-specific environmental and abiotic conditions including rainfall, water 

table conditions, and topography (Huddleston 1996). 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. 

Pesticides that are soluble move easily with runoff water. Pesticide-laden soil particles can be 

dislodged and transported from the application site in runoff. The concentration of pesticides 

in the surface runoff would be greatest for the first runoff event following treatment. The 

rainfall intensity and route of water infiltration into soil, to a large extent, determine pesticide 

concentrations and losses in surface runoff. The timing of the rainfall after application also 

would have an effect. Rainfall interacts with pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), 

which is called the mixing zone (Baker and Miller 1999). The pesticide/water mixture in the 

mixing zone would tend to leach down into the soil or runoff depending upon how quickly 

the soil surface becomes saturated and how rapidly water can infiltrate into the soil. Leaching 

would decrease the amount of pesticide available near the soil surface (mixing zone) to 

runoff during the initial rainfall event following application and subsequent rainfall events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that 

are relatively flat would have little potential for runoff, except during intense rainfall events. 

In addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to 

leach into groundwater. If the distance from the soil surface to the top of the water table is 

shallow, pesticides would have less distance to travel to reach groundwater. Shallower water 

tables that persist for longer periods would be more likely to experience groundwater 

contamination. Soil survey reports are available for individual counties. These reports 

provide data in tabular format regarding the water table depths and the months during which 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-34 Appendix G. Integrated Pest Management Program 

they persist. In some situations, a hard pan exists above the water table that would prevent 

pesticide contamination from leaching. 

G.7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the 

atmosphere. The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure, 

which would be affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these numbers easier to compare, vapor 

pressure may be expressed in exponent form (I × 10-7), where I represents a vapor pressure index. In 

general, pesticides with I<10 would have a low potential to volatilize, whereas pesticides with 

I>1,000 would have a high potential to volatilize (OSU 1996). Vapor pressure values for pesticides 

are usually available in the pesticide product MSDS or the USDA Agricultural Research Service 

(ARS) pesticide database. 

G.7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete chemical profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled 

with the EPA. All information fields under each category (e.g., toxicological endpoints, 

environmental fate) would be completed for a chemical profile. If no information is available for a 

specific field, then “No data is available in references” would be recorded in the profile. Available 

scientific information would be used to complete chemical profiles. Each entry of scientific 

information would be shown with applicable references. 

Completed chemical profiles would provide a structured decision-making process using quantitative 

assessment/screening tools with threshold values (where appropriate) that would be used to evaluate 

potential biological and other environmental effects to refuge resources. For ecological risk 

assessments presented in these profiles, the “worst-case scenario” would be evaluated to determine 

whether a pesticide could be approved for use considering the maximum single application rate 

specified on pesticide labels for habitat management and croplands/facilities maintenance treatments 

pertaining to refuges. Where the worst-case scenario likely would only result in minor, temporary, 

and localized effects to listed and non-listed species with appropriate BMPs (see Section G.5), the 

proposed pesticide’s use in a PUP would have a scientific basis for approval under any application 

rate specified on the label that is at or below rates evaluated in a chemical profile. In some cases, the 

chemical profile would include a lower application rate than the maximum labeled rate in order to 

protect refuge resources. As necessary, chemical profiles would be periodically updated with new 

scientific information or as pesticides with the same active ingredient are proposed for use on the 

refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and 

environmental effects) would be clearly identified for specific information presented in a completed 

chemical profile. Comparison with these threshold values provides an explicit scientific basis to 

approve or disapprove PUPs for habitat management and cropland/facilities maintenance on refuge 

lands. In general, PUPs would be approved for pesticides with chemical profiles where there would 

be no exceedances of threshold values. However, BMPs are identified for some screening tools that 

would minimize/eliminate potential effects (exceedance of the threshold value) as a basis for 

approving PUPs. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-35 

Date: Service personnel would record the date when the chemical profile is completed or updated. 

Chemical profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed 

and updated as necessary. The most recent review date would be recorded on a profile to document 

when it was last updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from 

the pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, 

I, II or 64). The suffix often distinguishes a specific product from among several pesticides with the 

same active ingredient. Service personnel would record a trade name for each pesticide product with 

the same active ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the 

pesticide label or MSDS for an active ingredient. The common name of a pesticide is listed as the 

active ingredient on the title page of the product label immediately following the trade name, and the 

MSDS Section 2: Composition/Information on Ingredients. A chemical profile is completed for each 

active ingredient. 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, desiccant, fungicide, fumigant, growth regulator, insecticide, piscicide, or 

rodenticide. 

EPA Registration Number(s): The EPA Reg. No. appears on the title page of the label and MSDS 

Section 1: Chemical Product and Company Description. It is not the EPA Establishment Number, 

which is usually located near it. Service personnel would record the EPA Reg. No. for each trade 

name product with an active ingredient based upon PUPs. 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components usually 

contains this number immediately prior to or following the percent composition. 

Other Ingredients: From the most recent MSDS for the proposed pesticide product(s), Service 

personnel would include any chemicals in the pesticide formulation that are not listed as active 

ingredients but are described as toxic or hazardous, or are regulated under the Superfund 

Amendments and Reauthorization Act (SARA), Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), Toxic Substances Control Act (TSCA), OSHA, State 

Right-to-Know, or other listed authorities. These are usually found in MSDS sections titled 

“Hazardous Identifications,” “Exposure Control/Personal Protection,” and “Regulatory Information.” 

If concentrations of other ingredients are available for any compounds identified as toxic or 

hazardous, then Service personnel would record this information in the chemical profile by trade 

name. MSDSs may be obtained from the manufacturer, manufacturer’s website or from an online 

database maintained by Crop Data Management Systems, Inc. (see list below). 

G.7.6.1 Toxicological Endpoints

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and 

fish. Data would be recorded for species available in the scientific literature. If no data are found for 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-36 Appendix G. Integrated Pest Management Program 

a particular taxonomic group, then “No data available is references” would be recorded as the data 

entry. Throughout the chemical profile, references (including toxicological endpoint data) would be 

cited using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record 

available data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. The most common 

test species in scientific literature are the rat and mouse. The lowest LD50 value found for a rat would 

be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals 

(see Table G-1 in Section G.7.2). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record 

available data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). The 

most common test species in scientific literature are the rat and mouse. The lowest LC50 value found 

for a rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk 

(see Table G-1 in Section G.7.2). 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel 

would record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed 

Effect Level [LOEL], No Observed Adverse Effect Level [NOAEL], NOAEC) in mg/kg-bw or 

mg/kg-diet for reproductive test procedure(s) (e.g., generational studies [preferred], fertility, newborn 

weight). The most common test species available in scientific literature are rats and mice. The lowest 

NOEC, NOAEC, LOEL, or NOAEL test results found for a rat would be used as a toxicological 

endpoint for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.2). 

Avian LD50: For test species available in the scientific literature, Service personnel would record 

values for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. The most common test species available 

in scientific literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian 

species would be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk 

(see Table G-1 in Section G.7.2). 

Avian LC50: For test species available in the scientific literature, Service personnel would record 

values for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). The most 

common test species available in scientific literature are the bobwhite quail and mallard. The lowest 

LC50 value found for an avian species would be used as a toxicological endpoint for dietary-based 

RQ calculations to assess acute risk (see Table G-1 in Section G.7.2). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). The most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, 

LOEL, or NOAEL test results found for an avian species would be used as a toxicological endpoint 

for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.2). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel 

would record a LC50 in ppm or mg/L. The most common test species available in the scientific 

literature are the bluegill, rainbow trout, and fathead minnow (marine). Test results for many game 

species may also be available. The lowest LC50 value found for a freshwater fish species would be 

used as a toxicological endpoint for RQ calculations to assess acute risk (see Table G-1 in Section 

G.7.2). 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-37 

Fish Early Life Stage/Life Cycle: For test freshwater or marine species available in the scientific 

literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, lowest 

observed adverse effect concentration [LOAEC]) in ppm for test procedure(s) (e.g., early life cycle, 

life cycle). The most common test species available in the scientific literature are bluegill, rainbow 

trout, and fathead minnow. Test results for other game species may also be available. The lowest test 

value found for a fish species (preferably freshwater) would be used as a toxicological endpoint for 

RQ calculations to assess chronic risk (see Table G-1 in Section G.7.2). 

Other: For test invertebrate and nonvascular and vascular plant species available in the scientific 

literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or EC50 

(environmental concentration) values in ppm or mg/L. The most common test invertebrate species 

available in scientific literature is the honey bee. Green algae and pondweed are frequently available 

test species for aquatic non-vascular and vascular plants, respectively. 

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be 

exposed to these chemical(s). When exposure is high relative to the toxicity of the pesticides, wildlife 

may be killed or visibly harmed (incapacitated). Such events are called ecological incidents. The 

EPA maintains a database (Ecological Incident Information System) of ecological incidents. This 

database stores information extracted from incident reports submitted by various Federal and state 

agencies and non-government organizations. Information included in an incident report is date and 

location of the incident, type and magnitude of effects observed in various species, use(s) of 

pesticides known or suspected of contributing to the incident, and results of any chemical residue and 

cholinesterase activity analyses conducted during the investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

G.7.6.2 Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes 

the amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). 

Pesticide Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately 

soluble = 100 to 1,000 ppm, highly soluble >10,000 ppm (U.S. Geological Survey 2000). As 

pesticide Sw increases, there would be greater potential to degrade water quality through runoff and 

leaching. 

Sw would be used to evaluate potential for bioaccumulation in aquatic species (see Octanol-Water 

Partition Coefficient (Kow) below). 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical’s mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a 

pesticide may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see

Potential to Move to Groundwater below).
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-38 Appendix G. Integrated Pest Management Program 

Soil Persistence: Service personnel would record values for soil half-life, which represents the 

length of time (days) required for 50 percent of the deposited pesticide to degrade (completely or 

partially) in the soil. Based upon the half-life value, soil persistence would be categorized as one of 

the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days (Kerle et al. 1996). 

Threshold for approving PUPs: 

If soil half-life ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil half-life >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the “Specific 

Best Management Practices (BMPs)” section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the groundwater table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil half-life values would be used in evaluating the potential to degrade groundwater 

by leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Field dissipation time would be the preferred data for use to estimate pesticide 

concentrations in the environment because it is based upon field studies, unlike soil half-life, which is 

derived in a laboratory. However, soil half-life is the most common persistence data available in the 

published literature. If field dissipation data are not available, soil half-life data would be used in a 

chemical profile. The average or representative half-life value of most important degradation 

mechanism would be selected for quantitative analysis for both terrestrial and aquatic environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of 

the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days. 

Threshold for approving PUPs: 

If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the “Specific 

Best Management Practices (BMPs)” section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the groundwater table is <10 feet and average 

annual precipitation >12 inches. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-39 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil DT50 values (preferred over soil half-life) would be used in evaluating the 

potential to degrade groundwater by leaching (see Potential to Move to Groundwater below), if 

available. 

Aquatic Persistence: Service personnel would record values for aquatic half-life, which represents 

the length of time required for 50 percent of the deposited pesticide to degrade (completely or 

partially) in water. Based upon the aquatic half-life value, aquatic persistence would be categorized 

as one of the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days (Kerle et al. 1996). 

Threshold for approving PUPs: 

If aquatic half-life ≤100 days, then a PUP would be approved without additional BMPs to protect 

water quality. 

If aquatic half-life >100 days, then a PUP would only be approved with additional BMPs specifically 

to protect water quality. One or more BMPs such as the following would be included in the “Specific 

Best Management Practices (BMPs)” section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the groundwater table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50 percent of the 

deposited pesticide to degrade or move (dissipate), whereas, aquatic half-life describes the rate for 

degradation only. As with aquatic half-life, units of dissipation time are usually expressed in days. 

Based upon the DT50 value, environmental persistence in aquatic habitats also would be categorized 

as one of the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days. 

Threshold for approving PUPs: 

If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the “Specific 

Best Management Practices (BMPs)” section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the groundwater table is <10 feet and average 

annual precipitation >12 inches. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-40 Appendix G. Integrated Pest Management Program 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Potential to Move to Groundwater: GUS = log10(soil t1⁄2) × [4 − log10(Koc)]. If a DT50 value is 

available, it would be used rather than a t1⁄2 value to calculate a GUS score. Based upon the GUS

value, the potential to move toward groundwater would be recorded as one of the following 

categories: extremely low potential <1.0, low potential 1.0 to 2.0, moderate potential 2.0 to 3.0, high 

potential 3.0 to 4.0, and very high potential >4.0. 

Threshold for approving PUPs: 

If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water quality. 

If GUS >4.0, then a PUP would only be approved with additional BMPs specifically to protect water 

quality. One or more BMPs such as the following would be included in the “Specific Best 

Management Practices (BMPs)” section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the groundwater table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Threshold for approving PUPs: 

If I ≤1,000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality. 

If I >1,000, then a PUP would only be approved with additional BMPs specifically to minimize drift 

and protect air quality. One or more BMPs such as the following would be included in the “Specific 

Best Management Practices (BMPs)” section to reduce volatilization and potential to drift and 

degrade air quality: 

 Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion 

conditions. 

 Apply large-diameter droplets possible for spray treatments. 

 Avoid spraying when air temperatures >85°F. 

 Use the lowest spray height possible above target canopy. 

 Where identified on the pesticide label, soil should incorporate pesticide as soon as possible 

during or after application. 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1,000 or Sw<1 mg/L and soil t1⁄2>30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (U.S. Geological Survey 2000). 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-41 

Threshold for approving PUPs: 

If the potential for a pesticide to bioaccumulate is not high in aquatic species, then the PUP would be 

approved. 

If there is a high potential to bioaccumulate in aquatic species (Kow>1,000 or Sw<1 mg/L and soil 

t1⁄2>30 days), then the PUP would not be approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: Bioaccumulation is the physiological process where pesticide 

concentrations in tissue increase in biota because they are taken and stored at a faster rate than they 

are metabolized or excreted. The potential for bioaccumulation would be evaluated through 

bioaccumulation factors (BAFs) or bioconcentration factors (BCFs). Based upon BAF or BCF 

values, the potential to bioaccumulate would be recorded as one of the following: low = 0 to 300, 

moderate = 300 to 1,000, or high >1,000 (Calabrese and Baldwin 1993). 

Threshold for approving PUPs: 

If BAF or BCF ≤1,000, then a PUP would be approved without additional BMPs. 

If BAF or BCF >1,000, then a PUP would not be approved, except under unusual circumstances 

where approval would only be granted by the Washington Office. 

Worst-Case Ecological Risk Assessment 

Maximum Application Rates (acid equivalent [ae]): Service personnel would record the highest 

application rate of an active ingredient (ae basis) for habitat management and cropland/facilities 

maintenance treatments in this data field of a chemical profile. These rates can be found in Table 

CP.1 under the column heading “Max Product Rate – Single Application (lbs/acre – AI on acid equiv 

basis).” This table would be prepared for a chemical profile from information specified in labels for 

trade name products identified in PUPs. If these data are not available in pesticide labels, then write 

“NS” for “not specified on label” in this table. 

EECs: An estimated EEC represents potential exposure to fish and wildlife (birds and mammals) 

from using a pesticide. EECs would be derived by Service personnel using an EPA screening-level 

approach (EPA 2004). For each maximum application rate (see previous paragraph), Service 

personnel would record two EEC values in a chemical profile; these would represent the worst-case 

terrestrial and aquatic exposures for habitat management and croplands/facilities maintenance 

treatments. For terrestrial and aquatic EEC calculations, see the description for data entry under 

Presumption of Unacceptable Risk/Risk Quotients, the next field in a chemical profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic RQs for birds, mammals, and fish using the provided tabular formats for habitat 

management and/or cropland/facilities maintenance treatments. RQs recorded in a chemical profile 

would represent the worst-case assessment for ecological risk. See Section G.7.2 for a discussion 

regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be 

based upon selected acute and chronic toxicological endpoints for fish, and the EEC would be 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-42 Appendix G. Integrated Pest Management Program 

derived from Urban and Cook (1986) assuming 100 percent overspray to an entire 1-foot-deep water 

body using the maximum application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints 

for fish, and an EEC would be derived from the aquatic assessment in AgDRIFTmodel version 2.01 

under Tier I ground-based application with the following input variables: max application rate (ae 

basis [see above]), low boom (20 inches), fine to medium/coarse droplet size, 20 swaths, EPAdefined wetland, and 25-foot distance (buffer) from treated area to water. 

See Section G.7.2.1.2 for more details regarding the calculation of EECs for aquatic habitats for 

habitat management and cropland/facilities maintenance treatments. 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service 

personnel based upon dietary exposure, where the “short grass” food item category would represent 

the worst-case scenario. For terrestrial spray applications associated with habitat management and 

cropland/facilities maintenance treatments, exposure (EECs and RQs) would be determined using the 

Kanaga nomogram method through the EPA’s T-REX version 1.2.3. T-REX input variables would 

include the following: max application rate (ae basis [see above]) and pesticide half-life (days) in soil 

to estimate the initial, maximum pesticide residue concentration on general food items for terrestrial 

vertebrate species in short (<20 cm tall) grass. 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section G.7.2.1.1.2 for the procedure that would be 

used to calculate RQs. 

All calculated RQs in both tables would be compared with LOCs established by the EPA (see Table 

G-2 in Section G.7.2). If a calculated RQ exceeds an established LOC value (in brackets inside the 

table), then there would be a potential for an acute or chronic effect (unacceptable risk) to federally 

listed (threatened or endangered) species and non-listed species. See Section G.7.2 for detailed 

descriptions of acute and chronic RQ calculations and comparison to LOCs to assess risk. 

Threshold for approving PUPs: 

If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to minimize 

exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the 

following would be included in the “Specific Best Management Practices (BMPs)” section to reduce 

potential risk to nonlisted or listed species: 

 Lower application rate and/or fewer number of applications so RQs≤LOCs. 

 For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the 

buffer distance beyond 25 feet so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reason for using the pesticide based on 

control of specific pests or groups of pests. In most cases, the pesticide label would provide the 

appropriate information regarding control of pests to describe in the section. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-43 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs 

necessary to minimize or eliminate potential effects to non-target species and/or degradation of 

environmental quality from drift, surface runoff, or leaching. These BMPs would be based upon 

scientific information documented in previous data fields of a chemical profile. Where necessary and 

feasible, these specific practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to refuge resources and/or degradation of environmental quality are outweighed by 

the overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See 

Section G.5 of this document for a complete list of BMPs associated with mixing and applying 

pesticides appropriate for all PUPs with ground-based treatments that would be additive to any 

necessary, chemical-specific BMPs. 

References: Service personnel would record scientific resources used to provide data/information for 

a chemical profile. They would use the number sequence to uniquely reference data in a chemical 

profile. 

The following online data resources are readily available for toxicological endpoint and 

environmental fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California Environmental 

Protection Agency. (http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 

2. ECOTOX database. Office of Pesticide Programs, EPA, Washington, D.C. 

(http://cfpub.epa.gov/ecotox/) 

3. EXTOXNET Pesticide Information Profiles. Cooperative effort of University of California-Davis, 

Oregon State University, Michigan State University, Cornell University, and University of Idaho 

through Oregon State University, Corvallis, Oregon. (http://extoxnet.orst.edu/pips/ghindex.html) 

4. Food and Agriculture Organization (FAO) specifications and evaluations for plant protection 

products. Pesticide Management Unit, Plant Protection Services, FAO, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, USFS, USDA. (http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land Management, 

Bonneville Power Administration, U.S. Department of Energy, and USFS, USDA. 

(http://infoventures.com/e-hlth/pesticide/pest-fac.html) 

8. Pesticide fact sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide fate database. EPA, Washington, D.C. (http://cfpub.epa.gov/pfate/home.cfm). 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-44 Appendix G. Integrated Pest Management Program 

 10. Pesticide product labels and MSDSs. Crop Data Management Systems, Inc. 

(http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by agrichemical 

companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and amphibian toxicology literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet—New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. EPA, Washington, D.C. (http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The Invasive 

Species Initiative. The Nature Conservancy. (http://tnsweeds.ucdavis.edu/handbook.html) 

16. Wildlife contaminants online. U.S. Geological Survey, Department of Interior, Washington, D.C. 

(http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. EPA Office of Pesticide Programs, Washington, D.C. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-45 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical Name(s): 

Pesticide Type: EPA Registration Number: 

Pesticide Class: CAS Number: 

Other Ingredients: 

Toxicological Endpoints

Mammalian LD50: 

Mammalian LC50: 

Mammalian Reproduction: 

Avian LD50: 

Avian LC50: 

Avian Reproduction: 

Fish LC50: 

Fish ELS/Life Cycle: 

Other: 

Ecological Incident Reports 

Environmental Fate 

Water solubility (Sw): 

Soil Mobility (Koc): 

Soil Persistence (t1⁄2): 

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2): 

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score): 

Volatilization (mm Hg): 

Octanol-Water Partition Coefficient (Kow): 

Bioaccumulation/Biocentration: BAF:` 

BCF: 

Worst Case Ecological Risk Assessment

Max Application Rate 

(ai lbs/acre – ae basis) 

Habitat Management: 

Croplands/Facilities Maintenance: 

EECs Terrestrial (Habitat Management): 

Terrestrial (Croplands/Facilities Maintenance): 

Aquatic (Habitat Management): 

Aquatic (Croplands/Facilities Maintenance): 

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Non-listed Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-46 Appendix G. Integrated Pest Management Program 

Mammals [1] [1] 

Fish [1] [1] 

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Non-listed Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Justification for Use: 

Specific Best Management 

Practices (BMPs): 

References: 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program G-47 Table CP.1 Pesticide Name 

Trade Namea Treatment Typeb Max Product Rate – Single Application (lbs/acre or gal/acre) Max Product Rate - Single Application (lbs/acre - AI on acid equiv basis) Max Number of Applications Per Season Max Product Rate Per Season (lbs/acre/season or gal/acre/season) Minimum Time Between Applications (Days) 

a From each label for a pesticide identified in PUPs, Service personnel would record application information associated with possible/known uses on Service 

lands.

b Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is labeled for both types of treatments (uses), then record 

separate data for H and CF applications. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-48 Appendix G. Integrated Pest Management Program 

G.8. References 

AgDrift 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray drift of 

pesticides. Spray Drift Task Force. Macon, MO. 

ATSDR (Agency for Toxic Substances and Disease Registry). 2004. Guidance manual for the 

assessment of joint toxic action of chemical mixtures. U.S. Department of Health and Human 

Services, Public Health Service, ATSDR, Division of Toxicology. 62 pp + appendices. 

Baehr, C.H. and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. Tenth Symposium on Environmental Toxicology and 

Risk Assessment, American Society of Testing and Materials. West Conshohocken, PA. 358 

pp. 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication 

PM 1495, Iowa State University Extension. Ames, IA. 6 pp. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns 

in the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide 

Application for Drift Management. Waikoloa, HI. 15 pp. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and transformation 

products in surface waters of the midwestern United States. Journal of the American Water 

Resources Association (JAWRA) 39(4):743-756. 

Beyer, W.N., E.E. Connor, S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

BLM (Bureau of Land Management). 2007. Vegetation treatments using herbicides on Bureau of 

Land Management Lands in 17 western states Programmatic EIS (PEIS). Bureau of Land 

Management. Reno NV. 

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. 

Hobbs, M. Pellant, and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. 

BioScience 54:77-88. 

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to 

ground water. Extension Publication PI-2, University of Florida, Cooperative Extension 

Service. Gainesville, FL. 4 pp. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing ecological risk assessments. Chelsea, MI: Lewis 

Publishers. 

 Center, T.D., J.H. Frank, and F.A., Dray, Jr. 1997. Biological control. Pages 245-263 in: Strangers in 

paradise: impact and management of nonindigenous species in Florida. Washington D.C.: 

Island Press. 

Coombs, E.M., J.K Clark, G.L. Piper, and A.F. Cofrancesco, Jr. 2004. Biological control of invasive 

plants in the United States. Corvallis, OR: Oregon State University Press. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program 49 

Cox, R.D. and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated rangeland 

through assisted succession. Journal of Range Management 57:203-210. 

Driver, C.J., M.W. Ligotke, P. Van Voris, B.D. McVeety, B.J. Greenspan, and D.B. Brown. 1991. 

Routes of uptake and their relative contribution to the toxicologic response of northern 

bobwhite (Colinus virginianus) to an organophosphate pesticide. Environmental Toxicology 

and Chemistry 10:21-33. 

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird Banding 

Association. Monograph No. 1. West Lafayette, ID. 

EPA (U.S. Environmental Protection Agency). 1990. Laboratory test methods of exposure to 

microbial pest control agents by the respiratory route to nontarget avian species. EPA/600/3-

90/070. Environmental Research Laboratory, Corvallis, OR. 

EPA. 1998b. A comparative analysis of ecological risks from pesticides and their uses: background, 

methodology and case study. Environmental Fate & Effects Division, Office of Pesticide 

Programs, Washington, D.C. 105 pp. 

EPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide Programs, 

U.S EPA. Endangered and threatened species effects determinations. Office of Pesticide 

Programs. Washington, D.C. 101 pp. 

EPA. 2005a. Technical overview of ecological risk assessment. Analysis phase: exposure 

characterization; approaches for evaluating exposure; granular, bait, and treated seed 

applications. Office of Pesticide Programs. Washington, D.C. Available at: 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. Accessed June 2012. 

EPA. 2005b. User’s guide TREX v1.2.3. Office of Pesticide Programs, EPA. Washington, D.C. 22 

pp. Available at: http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

Accessed June 2012. 

EPA. 2012. Pesticide inert ingredients. Available at: http://www.epa.gov/opprd001/inerts/index.html. 

Accessed June 2012. 

EXTOXNET (The Extension Toxicology Network). 1993. Movement of pesticides in the 

environment. Pesticide Information Project of Cooperative Extension Offices of Cornell 

University, Oregon State University, University of Idaho, University of California-Davis, and 

the Institute for Environmental Toxicology, Michigan State University. 4 pp. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA 

food-chain (Kanaga) nomogram, and instrument for estimating pesticide residue on plants. 

Environmental Toxicology and Chemistry 13:1381-1391. 

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and prospects. 

Tansley Review 23:201-222. 

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide 

contamination. EM 8559. Oregon State University Extension Service. 4 pp. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-50 Appendix G. Integrated Pest Management Program 

Kerle, E.A., J.J. Jenkins, and P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension 

Service. 8 pp. 

Masters, R.A, and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Management 54:502-517. 

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996. Imidazolinone 

herbicides improve restoration of Great Plains grasslands. Weed Technology 10:392-403. 

Maxwell, B.D., E. Lehnhoff, and L.J. Rew. 2009. The rationale for monitoring invasive plant 

populations as a crucial step for management. Invasive Plant Science and Management 2:1-9. 

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies 

extrapolation to acute toxicity in birds. Regulatory Toxicology and Pharmacology 24:24-29. 

Moody, M.E. and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance of 

nascent foci. Journal of Applied Ecology 25:1009-1021. 

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive plant 

species. Issue Paper (13):1-18. 

OSU (Oregon State University). 1996. EXTOXNET-Extension Toxicology Network, pesticide 

information profiles. Oregon State University, Corvallis, OR. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, and C. Wickliff. 1996. Field evaluation of the EPA 

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on 

plants. Environmental Toxicology and Chemistry 15:535-543. 

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. 

Extension Publication PAT 36, Iowa State University Extension, Ames, Iowa and Iowa 

Department of Agriculture and Land Stewardship, Des Moines, IA. 6 pp. 

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington: protecting 

groundwater from pesticide contamination. Extension Publication EB1644, Washington State 

University Extension. Pullman, WA. 12 pp. 

SDTF (Spray Drift Task Force). 2003. A summary of chemigation application studies. Spray Drift 

Task Force. Macon, MO. 

Urban, D.J and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. Office of Pesticide 

Programs, EPA. Washington D.C. 94 pp. 

U.S. Geological Survey. 2000. Pesticides in stream sediment and aquatic biota: current understanding 

of distribution and major influences. USGS Fact Sheet 092-00. Sacramento, CA. 4 pp. 

USFS (U.S. Forest Service). 2005. Pacific Northwest Region invasive plant program: preventing and 

managing invasive plants. Final environmental impact statement. Portland, OR. 359 pp. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Program 51 

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992. The 

SCS/ARS/CES pesticide properties database for environmental decision making. Reviews of 

Environmental Contamination and Toxicology 123:1-155. 

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the 

International Conference on Pesticide Application for Drift Management. Waikoloa, HI. 8 

pp. 
Tualatin River National Wildlife Refuge Comprehensive Conservation Plan 

G-52 Appendix G. Integrated Pest Management Program 

Document continues on the following page.