The Role of Multiple Species and Crop 

Attributes in Better Understanding the 

Potential for Pesticide Exposure

Assessing Risks to Endangered and Threatened Species 

from Pesticides – 3rd Interagency Workshop on Joint 

Interim Approaches to NAS Recommendations 

October 6, 2014 

FIFRA Endangered Species Task Force

Bernalyn D. McGaughey

Project Manager, FESTF

President, Compliance Services International
Simple Concept – Big Challenge
FESTF Aggregated Data . . .

. . . To FWS regional offices . . .

A Data Exchange Method . . .

. . . To EPA for use in pesticide 

risk assessment
At the 

national 

level, we 

use this . . .

. . . But this aerial 

image from which 

national 

summary data 

are extracted has 

10,000 times 

more information

Are there other Opportunities to Leverage 

Knowledge and Resources. . . ?

USDA NAIP Image

USDA NLCD Extract
Approaches for Ensuring Data Quality: 

Reliability of Available Data

5

From: Data Quality, Reliability, and Relevance Standards for Ecological Risk Assessment: Recommendations for improvements to 

pesticide regulation in compliance with the Endangered Species Act, A. T. Hall, B. D. McGaughey, and J. A. Gagne
No Relevance

Some 

Relevance

Highly 

Relevant

Reducing Uncertainty: Relevant Data in 

the Right Context

6

Information on the ecology 

of a listed species obtained 

recently from in or near the 

action area

In vitro tissue toxicity tests 

that bypass metabolic 

processes

Cold climate degradation 

data applied to warm 

climate habitat 

Controlled, well 

documented testing on a 

closely related surrogate 

species
Find the “Sweet Spot” for a Sound Decision 

and Build on the Knowledge Base

7

C

o

n

f

u

sio

n

Information

Step 1

Step 2

Step 3
FESTF: Contributing to the Knowledge Base

• FESTF aggregated data are a result of exploration, 

applied application and data gathering that 

started when the LLC was incorporated almost 20 

years ago, in 1996

• The task force of 19 companies grew from 5 

companies that had conditions on their 

registrations for “proximity data”

• While EPA was instructional on addressing data 

needs from about 1996 to 2003, no real further 

Agency investment in exploring the FESTF data 

until recently

8
FESTF: Contributing to the Knowledge Base (2)

• Aggregated data on

– Species locations

– Crop or pesticide use locations

– Species biology, local data and conditions

• An information management system to

– Collect and compare the data

– Document species assessments conducted on individual 

active ingredients

– Recall and build upon collected data over time

• Emphasis on data quality and identification of known 

data gaps

9

WoE:

Systematic Collection 

of Data

Systematic 

Documentation

of data

Minimize Uncertainty
FESTF Tools: Species Data

FESTF’s species location dataset, delivered through the FESTF MJD or the FESTF IMS

Licensed 

multi-jurisdictional 

database (FESTF MJD) 

provides sub-county 

locational data . . .

County-level presence 

and Critical Habitat 

locations are also 

important

FESTF MJD

FESTF IMS

10

but not all species or 

all occurrences have 

specific locational 

data, therefore

. . . so those data are 

stored in the 
To the Species Location Data, 

FESTF Tools Add

Multiple lines of evidence fully documented, accumulated to refine exposure 

conditions – and reusable, if appropriate, for subsequent investigations

11

Crop county and subcounty locations from 

USDA NASS

Species attributes or 

habitat requirements 

mined from FESTF MJD 

textual data

Additional authoritative 

species, habitat, crop 

and agronomic data 

Relevant proprietary 

crop, use or species data

Expert opinions

Species reports and 

notices
Systematic Methods for Implementing “Weight of 

Evidence” Analysis that Consider both Quantitative 

and Qualitative Data

12

Federal 

Lands

Special 4(d) Rule: Mazama 

Pocket Gopher

Lines of Evidence Relevant Condition Circumstance OK

Diet 

and/or 

Size

Cold 

Tolerance

Soil Type

Elevation

Carrion Feeder

Grows on Shale Outcrops

Cannot Survive <45F

Only in stream reaches at 

elevations >6,000 FT
Applying Multiple Lines of Evidence:

Example 1: Black-Spored Quillwort

13

All EO’s 

> 450 FT

Conditions 

Preclude 

Exposure

Granitic 

Outcrops

Result: Some or all counties can be removed from being of concern for 

exposure, even when there is no sub-county location (proximity) data

Data re-characterized to protect confidential information

Includes FESTF aggregated data, public and member data

Line 1: Proximity

Line 2: Soil Type

Line 3: Condition

6 counties with 1 circumstance

16 counties with 2 circumstances

4 counties with 3 circumstances
Applying Multiple Lines of Evidence:

Example 2: Bliss Rapids Snail

14

% EO’s on federal lands

100%

63% 100%

No sub-county 

data

No sub-county 

data

% EO’s >500 FT from use site

Use site is at an elevation 

incompatible with habitat

FWS species expert opinion: species is extirpated 

from this county

37%

Data re-characterized to protect confidential information

Includes FESTF aggregated data, public and member data
• Proximity data alone do not address whether a species 

has the potential to be impacted

• Aggregated location, biology, habitat and land 

characteristics can be portrayed in a visual or spatial 

manner to concisely explain circumstances important to 

risk assessment 

• The parameters to be included in “Step 1” will greatly 

impact the work remaining in “Step 2” and “Step 3”

These Examples Show

15
Thank you for this opportunity to

share our data

Bernalyn D. McGaughey

President/CEO, Compliance Services International

Project Manager, FIFRA Endangered Species Task Force

7501 Bridgeport Way West – Lakewood, WA 98499 

253-473-9007 – BMcGaughey@ComplianceServices.com

FIFRA Endangered Species Task Force