ENVIRONMENTAL

MONITORING

PLAN

For Applications of MALATHION 

 

BOLL WEEVIL ERADICATION PROGRAM

Arkansas, Louisiana, Missouri, and Tennessee 

2009 

 

United States 

Department of

Agriculture 

Animal and 

Plant Health 

Inspection 

Service 

Plant Protection 

and Quarantine 

Prepared by the 

Environmental 

Compliance Team

Human Health 

& 

Endangered and 

Threatened Species

 March 2009
2009 Environmental Monitoring Plan, Southeastern U.S. 1 

Table of Contents 

HUMAN HEALTH ........................................................................................................................ 2 

Objectives ................................................................................................................................... 2 

Methods....................................................................................................................................... 2 

Drinking Water Monitoring .................................................................................................... 2 

Sensitive Site Monitoring ....................................................................................................... 3 

Sensitive Site Inventory .......................................................................................................... 3 

Dye Card Sampling................................................................................................................. 4 

Communication of Negative Information................................................................................ 5 

Occupational Health Monitoring............................................................................................ 5 

Monitoring for Incidents or Complaints................................................................................. 5 

Monitoring for Malathion Spills............................................................................................. 6 

Quality Assurance and Quality Control (QA/QC) Monitoring............................................... 6 

ENDANGERED, THREATENED and PROTECTED SPECIES ................................................. 7 

Objectives ................................................................................................................................... 7 

Methods....................................................................................................................................... 7 

Inventory of Endangered and Threatened Species ................................................................. 7 

Monitoring for Drift................................................................................................................ 9 

Monitoring for Run-off............................................................................................................ 9 

Monitoring Water.................................................................................................................... 9 

Monitoring by Observation and Field Notes........................................................................ 10 

GENERAL MONITORING ISSUES........................................................................................... 10 

Discretionary Monitoring.......................................................................................................... 10 

Documentation.......................................................................................................................... 10 

Shipping of Samples ................................................................................................................. 11 

Supplies..................................................................................................................................... 11 

RESPONSIBILITIES ................................................................................................................... 11 

2009 Operational Procedures/Mitigation Measures Checklist ................................................... A-1 

Operational Procedures and Mitigation Measures...................................................................... A-3 

Protection Measures.................................................................................................................... B-1 

ENVIRONMENTAL MONITORING SUPPLIES CHECKLIST ............................................. C-1 

The methods and procedures described in the 2009 Environmental Monitoring Plan are designed 

to ensure compliance with the National Environmental Policy Act, the Endangered Species Act, 

Federal Insecticide Fungicide and Rodenticide Act, and APHIS policy. Each program 

organizational unit (e.g. work unit, zone, region, etc.) should fully implement this plan during the 

2009 boll weevil eradication season. 
2009 Environmental Monitoring Plan, Southeastern U.S. 2 

HUMAN HEALTH

OBJECTIVES

Monitoring for potential human exposure is designed to: 

1. demonstrate the effectiveness of Boll Weevil Eradication Program (the Program) operational 

procedures in excluding or minimizing exposure of the public to Program-applied 

malathion; 

2. collect data which can be used to evaluate whether the assumptions used in the Environmental 

Assessments are valid estimates of potential exposure of the public to Program-applied 

malathion by: 

a. monitoring for aerial spray drift to investigate the overall potential for exposure; 

b. testing crops and water bodies that might be used for human consumption to 

investigate the potential for exposure to malathion through ingestion; 

3. ensure that quality assurance and quality control procedures were followed; and, 

4. conduct additional monitoring to investigate any Program-related complaints or reports of 

adverse effects on public health, worker safety, environmental quality, or non-target 

species. 

METHODS

Drinking Water Monitoring 

Monitoring will be conducted during all treatments where surface water bodies used for human 

consumption lie within 500 feet of cotton fields. Make a list of the reservoirs, cisterns, or other 

water bodies used for human consumption that are within 500 feet of a cotton field within your 

program area. Before Program treatments begin, provide the Environmental Compliance Team 

(ECT) with a description of each site and its relation to nearby cotton fields. If there are no such 

sites, inform the ECT in Riverdale, MD. 

Collect two water samples from each water body at least one week before the first Program 

application of malathion to any nearby field (do not combine these into a single sample). These 

are pre-program samples. Collect them whether or not treatments are expected at the nearby 

fields. Refer to Standard Operating Procedure (SOP) EM-03, Collection of Water Samples. If 

you do not have a copy of this or any other SOP mentioned in this monitoring plan, contact 

Robert Baca of the ECT at (301) 734-7592 or 734-8247. 

When a treatment is scheduled for a cotton field within 500 feet of a water body that is used for 

human consumption, collect two pre-treatment water samples from different locations at the 

edge of the water (do not combine these into a single sample) within 24 hours of each application 

to the field. These are a separate set of pre-treatment samples from those described in the 

previous paragraph. Collect two post-treatment samples from different locations 2 to 4 hours 

after each application of malathion (do not combine these into a single sample). Monitor these 

water bodies with pre- and post-treatment samples during every application of malathion within 

500 feet of the water body. Ship the samples as described below. 
2009 Environmental Monitoring Plan, Southeastern U.S. 3 

Sensitive Site Monitoring 

Monitoring will be conducted where sensitive sites are within 500 feet of a Program-treated 

cotton field. Sensitive sites are defined as areas where people congregate such as residences, 

public buildings, hospitals, day care centers, inpatient clinics, nursing homes, parks, churches, 

and schools. For those programs that do not monitor all of the sensitive sites in their jurisdiction, 

monitor a minimum of three sites per work unit/district/program each week that malathion is 

applied to fields. Monitor these sites by using dye cards to measure potential drift. 

Vegetation samples will not be required as a part of routine monitoring. However, collection of 

vegetation samples is recommended for other program areas at sites where landowners express 

concern over possible contamination of vegetation. In such situations, it is recommended that 

pre- and post-treatment vegetation samples be collected. For details, refer to SOP EM-07, 

Collection of Vegetation Samples. 

If you will only be monitoring a subset of all sensitive sites, identify the most critical sensitive 

sites for monitoring (for guidance, you may use SOP EM-22, Selection of Sensitive Sites). Give 

priority to sites that are the most sensitive; for example, closest to the fields, near areas occupied 

by children or medically compromised individuals, etc. 

Sensitive Site Inventory 

Each work unit, district, or program will make a list of sensitive sites that are within 500 feet of 

cotton fields. You may list all sensitive sites within 500 feet of cotton or list sites according to 

the following criteria: 

1. All sensitive sites within 100 feet of cotton fields will be listed. 

2. Sensitive sites 100-300 feet from cotton fields that are a priority for the Program will be 

listed. These sites may include locations of previous complaints, chemically sensitive 

individuals, organic farms, etc. 

3. Sensitive sites 300-500 feet from cotton fields that are of particular interest to the 

Program, but not necessarily priorities, will be listed. Exposure at these sites should be 

negligible at best, but the Program may wish to list the sites based on public concerns. 

4. All sensitive sites within 500 feet of cotton fields where children are likely to be found 

will be listed. These sites include schools, daycare, playgrounds, etc. This is to address a 

potential concern of the Environmental Protection Agency with regard to possible 

exposure of children to malathion on outdoor surfaces. 

The sensitive site lists that are reported to the ECT need only list the type of sensitive site and the 

cotton field identification number associated with that site. It is preferred that these lists be 

submitted in an electronic form, but they may also be submitted as a printed hard copy. The 

additional information previously reported (distance and direction to cotton field, etc.) is to be 

maintained in the local Program office (although it can be included in the site lists). Those work 

units that provided exhaustive lists of sensitive sites in a previous year only need to submit 

updates to that list for 2008 (though please specify whether your list is a complete one or only an 

update). If there are no additions, deletions, or changes in field numbers, please send a brief 
2009 Environmental Monitoring Plan, Southeastern U.S. 4 

communication to the ECT noting the lack of changes. Prior to the start of malathion 

applications, provide the list of sensitive sites to the ECT at the following address: 

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04b, 

Riverdale, MD 20737 or via email to robert.m.baca@aphis.usda.gov 

Sensitive site lists will not be required in weevil-free areas. Since any potential treatment in 

these areas would be limited, sensitive sites can be easily identified on an ad hoc basis. Should a 

treatment be required in a weevil-free area, all sensitive sites within 500 feet of the cotton 

field(s) to be treated will be identified and a list provided to the ECT. This list need not be 

provided to the ECT prior to treatment, and may simply be submitted as part of monitoring 

documentation at the site. Residents within 500 feet of the cotton field(s) will be notified in 

advance of the treatment, and environmental monitoring with dye cards will be conducted. 

Additional sampling is not required but may be conducted at the discretion of the Program, in 

order to address particular concerns of residents or the Program. 

Dye Card Sampling 

Dye cards are used to monitor potential drift. Before leaving for the field to set-up dye cards, 

hang a clean dye card from the rear-view mirror of the Program vehicle used during sampling 

(SOP EM-10, Preparation of Control Samples and Collection of Pesticide Samples). This is a 

control card and should remain in place throughout the day. Send this dye card to the USDAAPHIS Analytical and Natural Products Chemistry Laboratory (ANPCL) for analysis along with 

an APHIS 2060 Environmental Monitoring Form for the control dye card, whether the card is 

spotted or not. If your program monitors all sensitive sites with dye cards throughout the season, 

send a representative sample of all control dye cards to the lab for analysis. However, the 

control dye card does not need to be submitted for analysis if all of the non-control cards for the 

day are unspotted, but document the control card on the APHIS 2060 Environmental Monitoring 

Form, and send it to the ECT to report the unspotted non-control dye cards. 

Before treatment begins, place three dye cards between the cotton field and the sensitive site, at 

the edge of the sensitive site (not the edge of the cotton field), and with approximately 30 feet 

between cards (see SOP EM-01, Collection of Dye Card Samples). Draw a diagram (either on 

the APHIS 2060 form or on a separate sheet) of the card positions relative to the field and the 

sensitive site, indicating the distance and direction of the dye cards and sensitive site from the 

cotton field. Each card should be identified and labeled individually on the diagram. The 

location of each dye card should be selected so that surrounding vegetation does not create an 

obstruction that could interfere with the deposition of malathion on the dye cards. It is 

acceptable to place the cards under a tree or other cover if this situation is representative of the 

area between the treatment site and the sensitive site. Two hours after the treatment is 

completed, collect the dye cards. Label each sample according to its location on the diagram. 

DO NOT write on the dye card, but rather on the plastic bag in which the dye card was shipped. 

Writing on the dye card will ruin it for analysis. 
2009 Environmental Monitoring Plan, Southeastern U.S. 5 

Check each dye card for any visible spotting. 

 If none of the dye cards has a visible spot, then record this information on a single 

APHIS 2060 form, filling out all of the other information on the sheet as well. Make a 

note of the total number of dye cards without spots. Send the yellow copy of the form 

and all diagrams, maps, etc. to the ECT. Do not send these cards to the laboratory for 

analysis, but keep them in your files. Occasionally submit for laboratory analysis for 

quality control purposes, a set of unspotted dye cards (including the control dye card) 

used during monitoring within your work unit, district, or program area. 

 If any of the dye cards in a set has visible spotting, then submit all of the cards 

(even those without spots and the control dye card) to ANPCL for analysis. Complete a 

separate APHIS 2060 form for each individual dye card (i.e. four forms and four dye 

cards will be submitted to ANPCL.) Fill out all of the information on each APHIS 2060 

form, being sure to record if that particular dye card was spotted or not. Ship the 

samples as described below. Submit the yellow copy of the APHIS 2060 forms and 

supporting documents to the ECT. 

Communication of Negative Information 

Any organizational unit identified as being an active eradication program, but that does not have 

treatments requiring monitoring is expected to convey this information to the ECT. If pesticide 

applications are made to cotton fields, but there are no treatments that require monitoring in a 

given week, a letter or email must be sent to the ECT noting that treatments were conducted but 

were beyond the distances from sensitive sites that would have required monitoring. 

Occupational Health Monitoring 

Field personnel who might be exposed to malathion should be monitored for serum acetyl 

cholinesterase (AChE) activity. Monitoring should include pre-Program baseline blood samples 

collected before exposure to malathion, followed by samples collected periodically throughout 

the season. At termination of employment or several weeks after all malathion applications have 

ended, a post-Program blood sample should also be collected. 

Specifics for serum AChE monitoring can be found in the APHIS Safety and Health Manual. 

The manual is available online at www.aphis.usda.gov/mrpbs/ safety_health_wellness.html. 

Blood test results should be reviewed by a licensed health care professional and appropriate 

action taken should a significant inhibition of serum AChE be detected or if clinical signs and 

symptoms of pesticide exposure appear. At the end of the treatment season, results of the serum 

AChE monitoring program should be sent to the ECT in such a way that the anonymity of the 

employees is preserved. 

Monitoring for Incidents or Complaints 

Priority sampling will be conducted to investigate incidents of unknown origin involving 

mortality of non-target species (fish, bees, etc.) or other unintended environmental or human 

health impacts possibly associated with Program-applied malathion. Information about priority 
2009 Environmental Monitoring Plan, Southeastern U.S. 6 

samples can be found in SOP EM-09, Priority (Emergency) Sampling. Collect priority samples 

as soon as possible after the complaint, request, or problem is reported. Contact the ECT at 

(301) 734-7592 or 734-8247 to collaborate on a sampling plan, sampling methods, and types of 

samples to collect in order to optimize the investigation. If the incident occurs on a weekend, 

commence your investigation and sampling without delay, and contact the ECT as soon as 

possible on Monday. 

Proper documentation of the incident, investigation, and samples is extremely important. When 

responding to priority incidents, send to the ECT all GPS maps showing the site, location where 

you collected samples, the cotton field, and spray lines of recent malathion applications. Be sure 

to completely fill out all information on the APHIS 2060 forms with each sample. Be sure to 

provide an incident/complaint report to the ECT, along with any other information that you feel 

will be helpful in resolving the incident (i.e. photos, observations at the site, etc.). 

Monitoring for Malathion Spills 

Malathion spills (whether accidental, improper disposal, or aircraft crashes) should be monitored, 

depending on the nature of the incident, contractual arrangements, Program guidelines or local, 

state and federal procedures. Call ECT personnel immediately, so that proper procedures and 

samples may be taken, if necessary. Sampling usually occurs as for priority incidents described 

above, but personnel must be aware that they may be sampling materials contaminated with 

nearly pure malathion, and appropriate safety measures should be taken. 

Samples containing malathion from spills or accidents can contain enough malathion to ruin 

shipping containers and analytical equipment. Contact ANPCL for information on shipping 

these samples. Note on each sample and accompanying APHIS 2060 form that this is a "possible 

spill sample," so that ANPCL personnel may properly process the sample. 

Quality Assurance and Quality Control (QA/QC) Monitoring 

A QA/QC checklist can be found on pages A1-2. The checklist describes all of the QA/QC 

measures to be conducted by each program organizational unit to assure adherence to Program 

operating procedures, protection measures, and mitigations. At the end of the treatment 

season, the checklist must be signed by the State Program Manager, State EMS, or other 

appropriate personnel indicating that all of the QA/QC activities were followed. Record any 

deviations along with an explanation and any corrective actions taken. Attach this information to 

the checklist. After the conclusion of Program operations for the season, promptly submit the 

signed checklist to the ECT. 

To determine purity of malathion, designated APHIS or Program personnel will collect neat 

(undiluted) malathion samples throughout the growing season from the distribution warehouses, 

airfield or other storage areas. Collection of purity samples must be coordinated with 

appropriate APHIS personnel, so as not to duplicate sampling. Program personnel may sample 

neat malathion that they suspect may have a problem, such as contamination, outside of regular 

purity sampling. Instructions for how to collect, handle, and ship the sample will be provided by 
2009 Environmental Monitoring Plan, Southeastern U.S. 7 

ANPCL (228-863-8124), along with the necessary equipment. Further details can be found in 

SOP EM-10, Preparation of Control Samples and Collection of Pesticide Samples. 

ENDANGERED, THREATENED AND PROTECTED SPECIES

OBJECTIVES

Monitoring near endangered and threatened (E&T) and protected species habitat is designed to 

provide data which can be used to evaluate the effectiveness of protection measures established 

for E&T species and critical habitat. Each year, zones, districts, or programs must reassess the 

presence of E&T species and their habitats. Should a species be found in the jurisdiction of a 

Program area that is not addressed in this document or the current Biological Assessment, the 

ECT must be contacted immediately at (301) 734-7592. Appropriate action will be taken to 

implement the proper protection measures and monitoring to assure that Program operations do 

not disturb the species or critical habitat in question. This monitoring plan lists all protected and 

proposed species known to occur in Arkansas, Louisiana, Missouri, and Tennessee as of the 

writing of this document and their associated protection measures on pages B1-7. Listed species 

and their protection measures for 2009 are similar to 2008 (changes are shaded in grey below). 

The U.S. Fish and Wildlife Service concurrence with these protection measures is pending, 

although few, if any, changes are expected. We will notify appropriate personnel once the 

consultation process is complete and if any changes are made to the protection measures. 

METHODS

Inventory of Endangered and Threatened Species 

A complete inventory of all E&T sites near cotton fields is needed to fully evaluate the 

Program’s ability to protect E&T species. Before the first treatments are made, each zone, 

district, and program staff shall contact the local FWS office concerning listed E&T species and 

the location of their habitats in all counties that may receive treatments during 2009 before the 

first treatments are made. Note that proposed species are also shown on pages B1-7 for 

information purposes only. No monitoring is required with these proposed species, but if they 

become listed as threatened or endangered, it is likely that protection measures will come into 

effect. If proposed species are in an area under your jurisdiction, it is strongly advised that the 

listed protection measures be implemented. Failure to implement these protection measures 

could possibly harm the species, potentially resulting in additional and highly restrictive future 

protection measures. 

Even if you do not expect to treat any fields this year or are in a weevil-free area, it is 

recommended that you contact FWS for the location of protected species that may be near cotton 

fields. Should any fields require treatments, such treatments cannot begin until protected species 

locations are known. Since it can take some time for FWS to respond with the location of the 

protected species, it is in the Program’s best interest to identify those locations ahead of time 

rather than potentially delay possible unexpected treatments. 

Submit to the ECT a report that documents your program’s annual contact with local FWS 

personnel and the location of E&T species and critical habitats near areas expected to be treated 
2009 Environmental Monitoring Plan, Southeastern U.S. 8 

by your Program. In your report, include the names and affiliations of those consulted, a list of 

E&T species and critical habitats in Program counties, a list of fields by field number where 

treatments would require protection measures for E&T species, and any other details regarding 

specific protection measures to be implemented. Use page B-8 (the “Endangered and Threatened 

Species Site Reporting Form”) to document the presence and location of each E&T species. Use 

additional paper if needed. 

Your list should also include any proposed species found near cotton and whether or not the 

protection measures for them will be implemented. If protected species exist beyond distances 

from cotton fields required to implement the protection measures, those species should also be 

listed on the form with a note in the comments section stating that the species are beyond the 

given limits requiring protection measures. Return the completed form to the ECT before 

treatments begin for the year. Send the completed form to: 

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04b, 

Riverdale, MD 20737 or via email to robert.m.baca@aphis.usda.gov 

Listed protection measures include buffer zones, observational monitoring, dye card monitoring, 

water monitoring, and run-off monitoring. If a protected species is located near cotton, the listed 

protection measures must be fully implemented. Note that many species are excluded from 

monitoring since it was determined that the Program will have no effect on the species. These 

species are listed on pages B1-7 with an “NE” (for “no effect”) under the protection measures. 

Several protection measures do not require sampling. For example, the measures for the Ozark 

big-eared bat state, “No aerial use within 1⁄4 mile, no ground use within 300 feet of identified 

habitat.” There are no sampling requirements for this species, but the buffer zones must be 

implemented and documented in writing on the “Endangered and Threatened Species Site 

Reporting Form.” 

When monitoring is required, the type of monitoring is specified in the protection measures. 

Descriptions of the types of monitoring are found below. The distance from a cotton field to a 

protected habitat that triggers required monitoring is listed in the protection measures. For 

example, if a protection measure states, “No use within 60 feet of identified aquatic habitat. 

Monitor for run-off,” then run-off monitoring would be required for any cotton field within 60 

feet of the habitat. In this example, if any portion of a cotton field extended into the 60-foot notreatment buffer area, monitoring would be required even though no malathion would be applied 

within the buffer area. 

Bald Eagle Protections 

 In 2007, the bald eagle was removed from protection under the Endangered Species Act, but 

remains federally protected under the Bald and Golden Eagle Protection Act. As a result, 

protection measures for the eagle must still be implemented. There should be no aerial 

applications within 1,000 feet of eagle nests, no ground applications within 660 feet of nests, and 

no use within 60 feet of large water bodies (25 feet across) within a 1 mile radius of the nest site. 
2009 Environmental Monitoring Plan, Southeastern U.S. 9 

Monitoring for Drift 

When a protection measure notes to “Monitor for drift”, dye cards are to be used. Dye cards 

should be placed at the edge of the habitat of the species. Do not place the dye cards next to the 

cotton field, but rather adjacent to the protected habitat. Placing dye cards next to the cotton 

field will not show that the species are being protected. Use the methods described in the Human 

Health section above. 

Monitoring for Run-off 

When a protection measure notes to “Monitor for run-off”, Automatic Runoff Sampling 

Equipment (ARSE) is to be used. When a cotton field is close enough to a protected habitat that 

it requires run-off monitoring, chances are that the cotton field will drain into that habitat at some 

location. Find the location where the field drains into the protected habitat. Refer to SOP EM04, Collection of Run-off Water Samples. Place a cluster of six ARSEs in the bottom of the 

runoff channel just beyond the edge of the field. Be sure the ARSEs are not in a turn-row where 

they might be run over. This cluster of six ARSEs will be combined into a single sample for the 

“near field” sample. From the location where the ARSEs were placed at the field edge, follow 

the same runoff channel towards the protected aquatic habitat. At a point in the runoff channel 

close to the water’s edge, place another cluster of six ARSEs. These six ARSEs will be 

combined into a second single sample for the “away from field” sample. The goal of these two 

samples is to show that any malathion that might run off of a field will decrease in concentration 

down the runoff channel before it enters the aquatic habitat. 

Periodically check on all the ARSEs, and replace any that have been damaged, buried, or 

removed. Provide a detailed description of the drainage including slope, soil type, and ground 

cover. Illustrate your description with an annotated map, aerial photograph, or sketch, and 

include photographs if available. Monitor weather and cancel treatments if rain appears 

imminent (within 8 hours). If it rains at one of the fields being monitored within five days after 

it was last treated, then collect the ARSE samples within 12 hours of when the rain begins. Each 

cluster of six ARSE samples is pooled to make one composite sample. So, there will be two 

samples from each site, one at the field edge (“near field”) and one near the receiving water body 

or drainage point (“away from field”). 

Whenever run-off water samples are collected, also collect a sample of the water body receiving 

the runoff. Directions for collecting water samples are detailed in SOP EM-03, Collection of 

Water Samples. This sample is used to show how malathion that might be detected in the 

ARSEs is diluted upon entry into the water body. 

Monitoring Water 

A few species require water sampling as a protection measure, but these species have not been in 

Program treatment areas in the recent past. If one of these species is found near a treatment area 

this year, contact the ECT for information on the appropriate method to protect and sample the 

water body in question. Methods vary depending on if the water body is flowing or stationary. 
2009 Environmental Monitoring Plan, Southeastern U.S. 10 

For reference, SOP EM-03, Collection of Water Samples can be reviewed, but this does not 

currently cover the sampling of flowing water. 

Monitoring by Observation and Field Notes 

Note-taking is required for most monitoring. Most often a sentence regarding general procedure 

is sufficient (for example: “nothing unusual noted during or after treatment”). In addition, note 

the time of treatment, and any wildlife activity in or around the field at E&T species sites. Refer 

to SOP EM-12 Using a Field Log Book. Submit photocopies of field log books, or make notes 

directly into the “remarks” section of the APHIS 2060 form. In the case of monitoring eagle 

nests, see note-taking recommendations in SOP EM-18 Observing Bald Eagles at Nest Sites. 

Document your observations as required by the protection measures, and submit these notes to 

the ECT. 

GENERAL MONITORING ISSUES

DISCRETIONARY MONITORING

At the discretion of program managers or staff, additional monitoring samples can be collected. 

Although the monitoring outlined in this plan should be adequate to generate the data needed to 

meet the objectives, additional sampling may be necessary around particular sensitive sites. 

Examples might include sites where there have been problems or complaints in previous years, 

sites that are highly visible to the public or are politically sensitive, sites where environmental 

monitoring might help prevent future concerns, and sites of proposed protected species. 

To assure that sampling equipment is not accidentally exposed to malathion, work units or 

program areas may periodically submit an unused dye card, distilled/deionized water in Program 

containers, or gauze wipes of sampling equipment in storage for analysis of malathion. Submit 

an individual APHIS 2060 form with these samples, as you would with any other sample you 

submit for analysis. 

To independently verify the analyses of ANPCL, work units or program areas may periodically 

follow procedures for taking, documenting, and submitting split samples for analysis. Split 

sampling involves taking a single sample and dividing it in half, with each half analyzed for 

malathion by a different laboratory. If you choose to take split samples of any type, contact the 

ECT at 301-734-7592 to discuss the proper procedures. 

DOCUMENTATION

Draw a clear diagram of the sensitive site and where each sample is collected, either on a 

Geographic Information System (GIS) map, on a separate piece of paper, or on the APHIS 2060 

forms associated with the samples. If you are collecting a series of samples from the same site, 

submit the map and diagram only once, as long as the site and each sample are clearly indicated 

on the map and in the appropriate sections of each APHIS 2060 form. 

Complete a separate APHIS 2060 form for each sample collected. Instructions for completing 

the APHIS 2060 forms may be found on the back of each form. For each sample, submit the 
2009 Environmental Monitoring Plan, Southeastern U.S. 11 

blue copy of the APHIS 2060 form to ANPCL with the sample, the white copy of the form to 

ANPCL in the sample shipping container but separate from the sample, and the yellow copy of 

the form (and any maps, photos, etc.) to the ECT. For any samples that are not sent to the 

laboratory for analysis (i.e. unspotted dye cards), send the APHIS 2060 form directly to the ECT. 

Keep the pink copy of each form you submit as a record in your local office. 

Properly identify each sample as “routine” or “priority.” An incorrect identification regarding 

the nature of the sample creates confusion for those who must interpret the data, and delays the 

processing of samples that are incorrectly marked. Mark samples as “priority” only for instances 

where a fast turnaround of samples is required. This applies to all complaint investigations, spill 

incidents, potential human health issues, and other samples considered to be of very high 

importance. Otherwise, mark the sample as “routine.” 

SHIPPING OF SAMPLES

Ship all samples, including dye cards, by using some form of overnight delivery. See SOP EM17, Packaging and Shipping of Samples for details. This applies to all samples, whether they are 

priority or routine. Do not ship samples using USPS Priority Mail or standard ground service 

with other carriers. Overnight delivery allows the sample to stay frozen or at least cold. 

Shipping any other way will take several days and can ruin the sample. 

With the exception of neat (pure) chemical, be sure that all samples are frozen, shipped in a 

cooler box (not a regular cardboard box), and kept cold during shipment. To keep samples cold, 

use dry ice, since it does not turn to liquid when warmed and will therefore not ruin any forms or 

samples. However, if water samples are shipped, do not use dry ice, since it will cause the 

sample containers to crack or break. Since dry ice may not be available in all areas, regular ice 

can be used for shipping any samples, but only if the ice is placed in a separate sealed container. 

Either use “blue ice” containers (the reusable plastic containers with the blue liquid/gel inside) or 

contained regular ice (i.e., sealed in zip-loc bags). Unsealed ice will melt and leak during 

shipment, causing unnecessary concern when received at the laboratory. 

SUPPLIES

As in the past, supplies for monitoring are ordered through the APHIS Analytical and Natural 

Products Chemistry Laboratory (ANPCL). A checklist for ordering supplies is located on pages 

C1-2. ANPCL prefers that supply orders be faxed to them using the numbers listed on the 

checklist rather then leaving a voice message for orders. 

RESPONSIBILITIES

USDA-APHIS Environmental Compliance Team 

In addition to preparing this Monitoring Plan, ECT personnel in Riverdale, MD, will: 

1. Review and interpret field and pesticide residue data from the sample collectors and the 

laboratory. Contact the sample collector for clarification as soon as possible if any field 

data is incomplete or unclear. Notify the Program Director and Manager immediately if 

any residue data indicates the possibility of excessive exposure to malathion. 

2. Provide training, clarification, and interpretation on how to implement the Monitoring Plan. 
2009 Environmental Monitoring Plan, Southeastern U.S. 12 

3. Submit a comprehensive interpretive report to the Program Director and the National 

Coordinator, within 60 working days of receiving all of the Program’s field data and all 

residue data. Following review of the information, the ECT will provide a copy of the 

report to the Environmental Protection Agency and U.S. Fish & Wildlife Service. 

USDA-APHIS Analytical and Natural Products Chemistry Laboratory 

Personnel at the ANPCL in Gulfport, MS, will: 

1. Prepare and ship sampling containers and other material required for collection, stabilization, 

and shipping of environmental monitoring samples. 

2. Provide training on methods for collecting, handling, preserving, and shipping samples. 

3. Respond to requests for additional information by field personnel when special sampling 

requirements occur. 

4. Analyze monitoring samples according to standard operating procedures for malathion. 

5. Complete analyses and report results on the following schedule: 

a. Within 23 working days after receipt, complete analyses of all routine samples and 

send results to the ECT. 

b. Within 5 working days after receipt, complete analyses of all priority/emergency 

samples and send results to the ECT. 

c. Contact ECT if the projected completion schedules need to be extended due to sample 

load or instrument problems on site. 

6. Forward copies of all environmental monitoring forms and any attached documentation to the 

ECT each week via overnight mail. 

Program/Foundation/Organization Employees, PPQ Field Service Personnel or 

Cooperators, Under the Direction of the Program Director 

Personnel in work unit, district, and program areas will: 

1. Ensure that sufficient resources from the Program are allocated for completing the monitoring 

activities described in the Environmental Monitoring Plan (EMP). 

2. Coordinate with Federal and local wildlife officials to identify E&T species and habitats near 

or within areas that may be affected by Program activities, inform the ECT of these 

species and locations, and implement the required protection measures. 

3. Identify all sensitive sites near cotton fields as described in the EMP. 

4. Select sufficient monitoring sites for the collection of samples. Follow instructions in the 

EMP and referenced SOPs to develop a plan for sample collection and documentation, 

including: 

a. Collection of the type and number of samples recommended in the EMP. 

b. Completion of a separate APHIS 2060 form for each sample that is collected. 

c. Providing all the information necessary (as described above) to document the 

samples. Following each treatment, send all supporting documentation, including a 

copy of the appropriate APHIS 2060 forms to the ECT. Send all samples and 

appropriate APHIS 2060 forms to ANPCL. Ship all samples and supporting 

documentation as soon as possible after collection. 

d. Notification of ANPCL prior to shipping any priority, spill, or unusual (i.e. other than 

water, dye card, soil, or vegetation) samples. 
A-1 

2009 OPERATIONAL PROCEDURES/MITIGATION MEASURES CHECKLIST

(Modify as needed for each work unit, district, or program area) 

______ Retain a copy of all the pesticide certifications for Program personnel who are applying or supervising the 

application of pesticides. Certificates were reviewed twice per year. 

______ Contractors’ pesticide application certificates were available and recorded prior to the initial pesticide 

application. 

______ Copies of all APHIS Form 2060’s submitted to the USDA analytical laboratory were retained at the work 

unit, district, or program area as documentation of the environmental monitoring program. 

______ A printout, or electronic file, of all trapped cotton fields, and the dates traps were checked and fields were 

treated, was retained as documentation for meeting all trapping and treatment criteria. 

______ Operational Procedures and Recommended Mitigation Measures for using malathion, as defined in the 

National Boll Weevil Cooperative Control Program, Environmental Impact Statement, Tables 2-1 and 2-2 

(attached), were reviewed with all appropriate Program personnel and copies were distributed as 

appropriate. (Measures for chemicals not used by the program may be ignored.) 

______ Sensitive areas as defined in Table 2-1 in the Environmental Impact Statement (attached) were identified in 

each field unit. Appropriate Program supervisory personnel are familiar with all sites and have applied 

appropriate protective measures to avoid negative impact. Program personnel have reviewed these areas 

with field unit supervisors each spring prior to pesticide application, assessed the sites for environmental 

monitoring sampling, and provided appropriate seasonal review. 

______ The following was issued to each employee as appropriate and serve as instructions for operational 

procedures: 

 _____ a. Trapper Guide and Trapper Agreement _____ d. Airplane Observer Duties 

 _____ b. Mist-Blower Operational Guide _____ e. Airport Recorder Duties 

 _____ c. Hi-Boy Operational Guide _____ f. BWEP Safety Manual 

 

______ Mist-blower and hi-boy operator training was conducted. Each employee signed a statement that they have 

received appropriate operational and safety training. This statement is retained in their personnel folder. 

______ Each employee involved with pesticide use was tested for blood acetyl cholinesterase levels as necessary. 

Copies of all cholinesterase tests were retained in each employee's folder. 

______ Global positioning systems (GPS) were required on all aerial application aircraft and generated a record of 

pesticide application. Two-way radio contact was maintained to allow communication between pilots and 

ground observers, to enhance safety and the effectiveness of each treatment. 

______ Wind and weather conditions were recorded to document meteorological conditions during treatments. 

______ Airplane check-in procedures certified nozzle type, size and number, spray system pressure, nozzle 

orientation, etc. This check-in list and subsequent seasonal inspections were retained in the work unit, 

district, or program area office for each aircraft used in the Program. 

______ Correct operational and safety procedures for mist-blowers and hi-boys were monitored weekly by Program 

supervisory personnel and documented in the mist-blower log. Program supervisory personnel checked at 

least one mist-blower operator or hi-boy operator each week during the control season. 
A-2 

______ A minimum of one aerial application operation was monitored by Program supervisory personnel each 

week for each contractor. This monitoring procedure was noted on flight records. 

______ Pesticide labels were carried in the vehicle of all persons involved with application, i.e. mist-blower 

operators, hi-boy operators, airplane observers, field supervisors, and Program supervisory personnel. 

______ Dye cards were labeled as to field numbers, date, and time of application. These cards were inspected by 

Program supervisory personnel and retained in the work unit or program area office or sent to the USDA 

laboratory for analysis as described in the Environmental Monitoring Plan. 

______ Initiation of Program operations was preceded by a notification to the following agencies: 

 _____ a. State Department of Agriculture or similar agency; 

 _____ b. State Conservation and National Resources Agency or similar agency; 

 _____ c. State Forestry Commission or similar agency; 

 _____ d. State Department of the Environment or similar agency; and 

 _____ e. Local governmental and county agencies. (Provide listings below.) 

______ Included in the notification letters was a request for assistance in identification of potential sensitive sites 

near cotton fields. 

______ A safety equipment check-off list was signed by each employee involved in pesticide application. This was 

retained in the employee’s personnel folder. 

______ Safety procedures dealing with exposure to pesticides were inserted into the Program safety manual and 

made available to all employees handling pesticides. 

______ Empty pesticide containers were returned to the distributor. 

______ All complaints were documented, thoroughly investigated, and resolved. Those involving alleged pesticide 

misuse were referred to the appropriate state authority. Copies of complaints and actions taken were 

maintained on file. Copies of any state investigative reports were retained in the work unit or program area 

and copies submitted to the USDA-APHIS Environmental Compliance Team. 

______ Local contacts with U.S. Fish and Wildlife Service concerning endangered and threatened species habitat 

and mitigation measures were documented. 

The above procedures and measures were performed in the __________________________________ work unit, 

district, or program area during the 2009 season. Any minor deviations in such were corrected when observed. 

Deviations and/or pesticide incidents and corrective actions taken have been documented and are described as 

follows: 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________

_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

______________________________________ _____________________ 

Signature Date
A-3 

Operational Procedures and Mitigation Measures 

National Boll Weevil Cooperative Control Program 

These operational procedures and mitigation measures have been adopted for, and are an integral part of, the 

cooperative Boll Weevil Eradication Program. They were printed originally in the programmatic Environmental 

Impact Statement, and were revised as necessary in 2005. 

Table 2-1 Operational Procedures

All Methods of Control 

1. All applicable Federal, State, and local environmental laws and regulations will be followed during boll 

weevil control operations. 

2. Sensitive areas (water bodies; parks; and occupied dwellings, such as homes, schools, churches, hospitals, 

and recreation areas) that may be adjacent to cotton fields will be identified. The program will be 

adjusted accordingly to ensure that these areas are not negatively affected. 

3. Environmental monitoring of the program will be in accordance with the current environmental monitoring 

plan. 

4. All cotton fields will be trapped. During the initial diapause year of the program, all fields will be treated 

from “ten percent cracked boll” until there is no hostable material remaining. In subsequent years, only 

hostable fields from which boll weevils have been caught will be treated. 

5. All program personnel involved in chemical applications will be instructed on the safe use of malathion, the 

safe use of equipment, and on operational procedures. Field supervisors will train Field Technicians, 

mist-blower operators and high-clearance sprayer operators on operational procedures, and monitor their 

conduct during working hours. 

Aerial Applications 

1. All materials will be applied in strict accordance with EPA- and State-approved label instructions. 

2. Aircraft, spray equipment, and pilots that do not meet all contract requirements will not be allowed to 

operate. 

3. All USDA, APHIS, Plant Protection and Quarantine employees who plan, supervise, recommend or perform 

pesticide treatments must be certified under the APHIS pesticide certification plan. They are also 

required to meet any additional requirements of the State where they perform duties involving pesticide 

use. All Foundation personnel involved in pesticide application must maintain State pesticide applicator 

certification as required by State law. 

4. Upon notification by program personnel, growers will advise workers of the re-entry period following 

treatment. 

5. Two-way radios or aircraft radio frequencies will be provided to program personnel who direct, coordinate, 

or observe pesticide applications, to facilitate communication with the pilot. 

6. All APHIS field personnel will have baseline cholinesterase tests before the first application and each spring 

and fall thereafter. It is recommended that contract, State, and private personnel also participate in this 

testing program. 

7. Only certified aerial applicators who have been familiarized with local conditions will be used by the 

program. 

8. To minimize drift and volatilization, applications will not be made when any of the following conditions 

exist in the treatment area: wind velocity exceeds 10 miles per hour (or less if required by State law); 

prevailing wind is blowing toward a nearby residence or other sensitive site; rain is falling or is 

imminent; fog is present, or air is turbulent enough to seriously affect the normal spray pattern; or 

temperature inversions exist that could lead to offsite movement of applied material. 

9. Nozzle types and sizes, spray system pressure, and nozzle orientation will be specified in the program’s 

aerial application contract or as otherwise directed by program personnel. 
A-4 

Ground Applications 

1. Mist-Blowers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with certified 

applicators. 

 • Units will be operated from closed truck cabs with operators using re-circulated air. 

2. High-Clearance Sprayers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with certified 

applicators. 

 • Spray operations will be conducted from closed cabs using re-circulated air. 

Table 2-2. Recommended Mitigation Measures 

All required State and local authorities will be notified upon initiation of the program. The notification will 

advise State and local authorities of the need for any assistance in identifying sensitive areas in proposed 

treatment areas. 

Protection of Workers 

All program personnel will be instructed on emergency procedures to follow in the event of insecticide 

exposure. Equipment necessary for immediate washing procedures must be available for application personnel. 

Aerial Applications 

1. Pilots, loaders, and other personnel handling insecticides will be advised to wear safety equipment and 

protective clothing. 

2. Program personnel observing applications of malathion are required to wear protective clothing or remain 

inside a closed vehicle with re-circulating air, depending on the circumstances of the application. 

3. Application operations will be postponed in fields in which people are working. These fields will not be 

treated when workers are present. 

4. GPS systems are required on all contract aircraft. They will be used for pilot guidance, mapping fields to be 

treated, and assistance in locating fields and marking swaths. 

Ground Applications 

1. Mist-Blowers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with certified 

applicators. 

 • Operators will wear appropriate safety equipment when loading or servicing the unit, and will be 

specially trained by program personnel. 

 • Mist-blower units will be operated from closed truck cabs with operators using re-circulated air. 

2. High-Clearance Sprayers 

 • Operators will be certified applicators, or will be in constant radio or cell phone contact with certified 

applicators. 

 • Operators will wear appropriate safety equipment and protective clothing when loading or servicing 

the unit. 

 • High-clearance sprayers will be operated from closed cabs with operators using re-circulated air. 

Pesticide Handling Precautions 

1. Insecticides will be delivered and stored in sealed totes (mini-bulk tanks) or drums and then pumped directly 

into the spraying equipment. 

2. All insecticides will be stored in accordance with Federal, State, and local regulations and label instructions. 
A-5 

3. All loading and unloading of insecticides will be within a containment area where an accidental spill will not 

contaminate a stream or other body of water. 

4. In the event of an accidental spill, procedures set forth in the PPQ Treatment Manual, chapter 7, pages 7-3-1 

through 7-3-18, entitled, “Guidelines for Managing Pesticide Spills” will be followed. 

5. All empty insecticide totes (mini-bulk tanks) and drums will be returned to the distributor for reconditioning. 

Protection of the Public 

1. Application aircraft shall avoid direct spraying of residences, garden plots and adjacent crops at all times. 

2. Program personnel shall immediately cease spraying operations if members of the public are observed within 

100 feet of a cotton field being sprayed with malathion. 

Protection of Bees 

Before beginning treatment with malathion, program personnel shall notify all registered apiarists in or near the 

treatment area of the date and approximate time of chemical treatment. 

Protection of Wildlife 

1. All control operations will be conducted with appropriate concern for their potential impact on endangered, 

threatened, proposed and protected species identified in this document. 

APHIS has prepared a biological assessment for federally listed endangered, threatened, proposed and protected 

species found within all U.S. cotton-producing counties from species information provided by the U.S. 

Department of the Interior, Fish and Wildlife Service (FWS) and State wildlife agencies. 

Adequate protection measures are developed for federally listed endangered, threatened, proposed and protected 

species through the Endangered Species Act, section 7, formal and informal consultations with FWS. 

Specific biological and distributional data for species is gathered in discussions between APHIS, Plant 

Protection and Quarantine, local FWS offices, State wildlife agencies and the Foundation before 

operations begin. 

Species and habitats protected by State laws are addressed in site-specific assessments as needed. 

2. Oil-sensitive dye cards are used to regularly monitor application efficacy. Spray deposition in the target area 

and droplet size are critical concerns.
Protection measures for endangered & threatened species - 2009 B-1 

Protection Measures for Endangered, Threatened, and Proposed Species in 

Arkansas, Louisiana, Missouri, and Tennessee for 2009

KEY

STATUS: E=Endangered, ECH =Endangered w/Critical Habitat, T=Threatened, TCH=Threatened w/Critical Habitat, PE=Proposed 

Endangered, PT=Proposed Threatened, XN=Experimental Population 

Gray shading = updates from 2008 

NE = APHIS determines that the Boll Weevil Program will have No Effect on populations of this species. 

Common Name Scientific Name Status Protection Measures

MAMMALS

Bat, gray Myotis grisescens E No aerial use within 1⁄4 mile or ground use within 300 feet of 

a cave roost or known maternity site. No treatment within 

60 feet around permanent water bodies within 10 miles of a 

cave roost or known maternity site. 

Bat, Indiana Myotis sodalis E,CH No aerial use within 1⁄4 mile or ground use within 300 feet of 

a cave roost or known maternity site. No treatment within 

60 feet around permanent water bodies within 10 miles of a 

cave roost or known maternity site. 

Bat, Ozark big-eared Plecotus townsendii 

ingens

E No aerial use within 1⁄4 mile or ground use within 300 feet of 

identified habitat. 

Bear, Louisiana black Ursus americanus 

luteolus

T, CH NE – Excluded by habitat 

Panther, Florida Felis concolor coryi E NE – Excluded by habitat 

Puma (=cougar), eastern Felis concolor couguar E NE – Excluded by rarity/habitat 

Squirrel, Carolina northern 

flying 

Glaucomys sabrinus 

coloratus

E NE – Excluded by rarity 

Wolf, gray, lower 48 States Canis lupus E,XN,CH NE – Excluded by rarity 

BIRDS

Crane, whooping Grus americana E,CH,XN Trained observer at site prior to each treatment. If crane is 

present, postpone treatment. 

Curlew, Eskimo Numenius borealis E NE – Excluded by rarity 

Eagle, bald 

(Protection measures remain as 

part of Bald and Golden eagle 

Protection Act) 

Haliaeetus leucocephalus Delisted No use within 1,500 feet of occupied nest until July 1. 

Thereafter no use within 300 feet of occupied nest; no use 

within 60 feet of large water bodies (>25 feet across) within 

a 1-mile radius of the nest site. Eagle (adults, nestlings, or 

fledglings) presence or absence will be documented for each 

treatment by an observer at the nest site. 

Pelican, brown Pelecanus occidentalis E NE – Excluded by habitat 
Protection measures for endangered & threatened species - 2009 B-2 

Common Name Scientific Name Status Protection Measures

Plover, piping Charadrius melodus E,T,CH NE – Migratory and excluded by habitat 

Tern, least (Interior population) Sterna antillarum E No aerial or ground use within 300 feet of a colony and no 

use within 60 feet of the water’s edge for 2.5-mile radius 

around the colony. Monitor for run-off. For colonies 

located on or along the Mississippi River: No use within 300 

feet of a colony and no use within 60 feet of the water’s 

edge for 2.5 miles upstream and downstream of the colony 

site. Monitor for run-off. 

Vireo, black-capped Vireo atricapillus E NE – Due to location (not in LA) and habitat (if present: 

aerial application is prohibited within 100 feet of habitat, 

and ground applications are prohibited within 60 feet of 

habitat.) 

Woodpecker, ivory-billed Campephilus principalis E No aerial use within 250 feet or ground use within 60 feet of 

habitat edge. Use wind to avoid deposition in habitat. 

Monitor for drift. 

Woodpecker, red-cockaded Picoides(=Dendrocopos) 

borealis

E No aerial use within 100 feet or ground use within 60 feet of 

habitat edge. Monitor for drift. 

REPTILES

Sea turtle, green Chelonia mydas E,T,CH NE – Excluded by habitat 

Sea turtle, hawksbill Eretmochelys imbricata E,CH NE – Excluded by habitat 

Sea turtle, Kemp's ridley Lepidochelys kempii E NE – Excluded by habitat 

Sea turtle, leatherback Dermochelys coriacea E,CH NE – Excluded by habitat 

Sea turtle, loggerhead Caretta caretta T NE – Excluded by habitat 

Tortoise, gopher Gopherus polyphemus T No aerial use within 300 feet of occupied habitat. Monitor 

for drift. 

Turtle, ringed map Graptemys oculifera T No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

AMPHIBIANS

Frog, Mississippi gopher Rana capito sevosa E NE – Due to underground habitat 

FISH

Cavefish, Ozark Amblyopsis rosae T No use within 60 feet of any drainage points within the 

recharge area of the cave. Monitor for run-off. 

Chub, slender Erimystax cahni T,CH No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

Chub, spotfin Cyprinella monacha T,CH Same as previous species 

Dace, blackside Phoxinus 

cumberlandensis

T Same as previous species 
Protection measures for endangered & threatened species - 2009 B-3 

Common Name Scientific Name Status Protection Measures

Darter, amber Percina antesella E,CH Same as previous species 

Darter, bluemask (=jewel) Etheostoma sp. E Same as previous species 

Darter, boulder (=Elk River) Etheostoma wapiti E Same as previous species 

Darter, duskytail Etheostoma sp. E Same as previous species 

Darter, leopard Percina pantherina T,CH Same as previous species 

Darter, Niangua Etheostoma nianguae T,CH Same as previous species 

Darter, slackwater Etheostoma boschungi T,CH Same as previous species 

Darter, snail Percina tanasi T Same as previous species 

Logperch, Conasauga Percina jenkinsi E,CH Same as previous species 

Madtom, Neosho Noturus placidus T Same as previous species 

Madtom, pygmy Noturus stanauli E Same as previous species 

Madtom, smoky Noturus baileyi E,CH, 

XN 

Same as previous species 

Madtom, yellowfin Noturus flavipinnis T,CH Same as previous species 

Shiner, Arkansas River Notropis girardi E,CH NE – Excluded by rarity 

Shiner, blue Cyprinella caerulea T No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

Shiner, Palezone Notropis sp. E Same as previous species 

Shiner, Topeka Notropis topeka. E,CH Same as previous species 

Sturgeon, gulf Acipenser oxyrhynchus 

desotoi

T,CH Same as previous species 

Sturgeon, pallid Scaphirhynchus albus E Same as previous species 

CLAMS

Acornshell, southern Epioblasma 

othcaloogensis

E,CH No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

Bean, Cumberland 

(pearlymussel) 

Villosa trabalis E,XN Same as previous species 

Bean, purple Villosa perpurpurea E,CH Same as previous species 

Blossom, green (pearlymussel) Epioblasma torulosa 

gubernaculum

E Same as previous species 

Blossom, tubercled 

(pearlymussel) 

Epioblasma torulosa 

torulosa

E,XN Same as previous species 

Blossom, turgid (pearlymussel) Epioblasma turgidula E,XN Same as previous species 
Protection measures for endangered & threatened species - 2009 B-4 

Common Name Scientific Name Status Protection Measures

Blossom, yellow 

(pearlymussel) 

Epioblasma florentina 

florentina

E,XN Same as previous species 

Catspaw (=purple cat’s paw 

pearlymussel) 

Epioblasma obliquata 

obliquata

E,XN Same as previous species 

Clubshell Pleurobema clava E Same as previous species 

Clubshell, ovate Pleurobema perovatum E,CH Same as previous species 

Clubshell, southern Pleurobema decisum E,CH Same as previous species 

Combshell, Cumberlandian Epioblasma brevidens E,CH,XN Same as previous species 

Combshell, upland Epioblasma metastriata E,CH Same as previous species 

Elktoe, Appalachian Alasmidonta raveneliana E,CH Same as previous species 

Elktoe, Cumberland Alasmidonta 

atropurpurea

E,CH Same as previous species 

Fanshell Cyprogenia stegaria E Same as previous species 

Fatmucket, Arkansas Lampsilis powelli T Same as previous species 

Heelsplitter, Alabama 

(inflated) 

Potamilus inflatus T Same as previous species 

Eye, Higgins (pearlymussel) Lampsilis higginsi E Same as previous species 

Kidneyshell, triangular Ptychobranchus greeni E,CH Same as previous species 

Lampmussel, Alabama Lampsilis virescens E Same as previous species 

Lilliput, pale (pearlymussel) Toxolasma 

(=Carunculina) 

cylindrellus

E Same as previous species 

Mapleleaf, winged (mussel) Quadrula fragosa E Same as previous species 

Moccasinshell, Coosa Medionidus parvulus E,CH Same as previous species 

Monkeyface, Appalachian 

(pearlymussel) 

Quadrula sparsa E Same as previous species 

Monkeyface, Cumberland 

(pearlymussel) 

Quadrula intermedia E,XN Same as previous species 

Mucket, pink (pearlymussel) Lampsilis abrupta E Same as previous species 

Mussel, oyster Epioblasma capsaeformis E,CH,XN Same as previous species 

Mussel, scaleshell Leptodea leptodon E Same as previous species 

Pearlshell, Louisiana Margaritifera hembeli T Same as previous species 

Pearlymussel, birdwing Conradilla caeleta E Same as previous species 
Protection measures for endangered & threatened species - 2009 B-5 

Common Name Scientific Name Status Protection Measures

Pearlymussel, cracking Hemistena lata E Same as previous species 

Pearlymussel, Curtis Epioblasma florentina 

curtisi

E Same as previous species 

Pearlymussel, dromedary Dromus dromas E Same as previous species 

Pearlymussel, littlewing Pegias fabula E Same as previous species 

Pigtoe, Cumberland Pleurobema gibberum E Same as previous species 

Pigtoe, finerayed Fusconaia cuneolus E,XN Same as previous species 

Pigtoe, rough Pleurobema plenum E Same as previous species 

Pigtoe, shiny Fusconaia cor E,XN Same as previous species 

Pigtoe, southern Pleurobema georgianum E,CH Same as previous species 

Pimpleback, orangefoot 

(pearlymussel) 

Plethobasus cooperianus E Same as previous species 

Pink, ring (mussel) Obovaria retusa E Same as previous species 

Pocketbook, fat Potamilus capax E Same as previous species 

Pocketbook, finelined Lampsilis altilis T,CH Same as previous species 

Pocketbook, Ouachita rock Arkansia wheeleri E Same as previous species 

Pocketbook, speckled Lampsilis streckeri E Same as previous species 

Rabbitsfoot, rough Quadrula cylindrica 

strigillata

E,CH Same as previous species 

Riffleshell, tan Epioblasma walkeri E Same as previous species 

Wartyback, white 

(pearlymussel) 

Plethobasus cicatricisus E Same as previous species 

SNAILS

Cavesnail, Tumbling Creek Antrobia culveri E NE – Excluded by habitat. 

Marstonia, royal (snail) Pyrgulopsis ogmorphe E No use within 60 feet of identified aquatic habitat and 

recharge areas of spring. Monitor for run-off. 

Riversnail, Anthony's Athaernia anthonyi E,XN No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

Shagreen, Magazine Mountain Mesodon magazinensis T NE – Excluded by habitat 

Snail, painted snake coiled 

forest 

Anguispira picta T NE – Excluded by habitat 
Protection measures for endangered & threatened species - 2009 B-6 

Common Name Scientific Name Status Protection Measures

INSECTS

Beetle, American burying Nicrophorus americanus E Avoid drift into potential habitat of beetle (=non-cultivated 

land) at the edge of fields in counties with species. Aerial 

swaths parallel to edge of beetle habitat. When possible, 

spray field edges near potential beetle habitat during mid 

morning to late afternoon from March to November. 

Dragonfly, Hine’s emerald Somatochlora hineana T,CH No use within 60 feet of identified habitat. Monitor for runoff. (CH is not in the program area) 

ARACHNIDS

Spider, spruce-fir moss Microhexura montivaga E,CH NE – Excluded by habitat 

CRUSTACEANS

Crayfish, cave Cambarus aculabrum E No use within 60 feet of drainage points within the recharge 

area for the cave. Monitor for run-off. 

Crayfish, cave Cambarus zophonastes E No use within 60 feet of drainage points within the recharge 

area for the cave. Monitor for run-off. 

Crayfish, Nashville Orconectes shoupi E No use within 60 feet of identified aquatic habitat. Monitor 

for run-off. 

PLANTS

Potato-bean, Price’s Apios priceana T NE – Excluded by habitat 

Rock-cress, Braun’s Arabis perstellata E,CH NE – Excluded by habitat, pollinators unknown 

Sandwort, Cumberland Arenaria 

cumberlandensis

E NE – Excluded by habitat 

Milkweed, Mead’s Asclepias meadii T NE – Excluded by location, habitat; not insect pollinated 

Fern, American hart’s-tongue Asplenium (=Phyllitis) 

scolopendrium 

(=japomica) var. 

americanum

T NE – Not insect pollinated 

Ground-plum, Pyne’s 

(=Guthrie’s) 

Astragalus bibillatus E NE – Excluded by habitat 

Aster, decurrent false Boltonia decurrens T NE – Excluded by habitat 

Rosemary, Cumberland Conradina verticillata T NE – Pollinated by honeybees and bumblebees 

Prairie-clover, leafy Dalea foliosa E NE – Pollinated primarily by bumblebees 

Coneflower, Tennessee purple Echinacea tennesseensis E NE – Excluded by habitat 

Geocarpon minimum Geocarpon minimum T NE – Excluded by habitat 

Avens, spreading Geum radiatum E NE – Excluded by habitat, many insects visit, pollinators 

unknown 
Protection measures for endangered & threatened species - 2009 B-7 

Common Name Scientific Name Status Protection Measures

Lichen, rock gnome Gymnoderma lineare E NE – Not insect pollinated 

Bluet, Roan Mountain Hedyotis purpurea 

montana

E NE – Excluded by habitat, pollinators include beetles, 

bumbelbees, flies, ants 

Sneezeweed, Virginia Helenium virginicum T NE – Excluded by location/habitat, pollinators include bees, 

wasps, butterflies, and hoverflies 

Quillwort, Louisiana Isoetes louisianensis E NE – Not insect pollinated 

Pogonia, small whorled Isotria medeoloides T NE – Self pollinated 

Bladderpod, Missouri Lesquerella filiformis E NE – Excluded by location-southwestern MO only 

Bladderpod, Spring Creek Lesquerella perforata E NE – Flowers early 

Pondberry Lindera melissifolia E NE – Pollination complete by spraying time 

Aster, Ruth's golden Pityopsis ruthii E NE – Vegetative reproduction in the wild 

Orchids, prairie fringed 

 Eastern and western 

Platanthera leucophaea 

Platanthera praeclara

T NE – Pollination occurs at night 

Harperella Ptilimnium nodosum E NE – Excluded by habitat 

Pitcher-plant, green Sarracenia oreophila T NE – Excluded by location, only in AL & GA; not insect 

pollinated 

Chaffseed, American Schwalbea americana E NE – Excluded by habitat 

Skullcap, large-flowered Scutellaria montana E NE – Excluded by habitat 

Goldenrod, Blue Ridge Solidago spithamaea T NE – Excluded by habitat, pollinators not identified 

Spiraea, Virginia Spiraea virginiana T NE – Vegetative reproduction 

Clover, running buffalo Trifolium stoloniferum E NE – Excluded by location 

Grass, Tennessee yellow-eyed Xyris tennesseensis E NE – Excluded by habitat 
Endangered and Threatened Species Site Reporting Form - 2009 

Use additional copies as needed. Prior to the start of applications of malathion, return the completed form to: Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04.b, Riverdale, MD 20737 Work unit/District/Zone/Program:_____________________________________________Sta

Species Field Number(s) Acres GPS Coordinates Distance to Field Comments 
 C-1 

ENVIRONMENTAL MONITORING SUPPLIES CHECKLIST 

SUPPLIES TO BRING EACH TIME YOU GO TO A SAMPLING SITE

Monitoring plan/SOP’s 

Obtain from 

ECT Thermometer 

Field log notebook Ice chest/wet or blue ice 

Obtain 

locally 

Compass Baby wipes 

Wind gauge 2060 monitoring forms 

Indelible marker Packing/strapping tape 

A.R.S.E. (Run-off Sampling) Dye Cards

Plexiglas cover Oil sensitive dye cards 

8"x 8" mesh screen Water sensitive dye cards 

Tent pegs/nails 5' bamboo poles/stakes 

Funnels attached to caps Paper/binder clips 

500 ml bottles Tacks 

4" PVC pipe, 14" long 4" x 4" plastic bags 

Post hole digger 12" x 12" plastic bags 

Pea gravel Tweezers/forceps 

Large rocks/bricks disposable gloves 

Bamboo pole/flagging tape Water Samples

collapsible cubitainer Dissolved oxygen kit 

Sodium sulfate (small vials) collapsible cubitainer 

pH paper/pH meter Sodium sulfate (small vials) 

Sulfuric acid (squeeze bottle) pH paper/pH meter 

Styrofoam “coffin” Sulfuric acid (squeeze bottle) 

Vegetation/Fish Samples Sediment Samples

Pruning sheers/scissors Dredge tied to strong rope

Aluminum foil envelopes 3 gallon galvanized pail

Strapping tape Hand trowel

3" mesh screen

 Aluminum foil envelopes 
 C-2 

Soil Samples Swab/Wipe Samples

Soil core sampler 3” x 3” sterile cotton pads 

with resealable plastic bag 

3 gallon galvanized pail Metric ruler 

Hand trowel Pencil 

3" mesh screen Disposable gloves 

Aluminum foil envelopes Isopropyl alcohol Obtain 

locally

Baby wipes 

Neat (Pure) Chemical Formulations Miscellaneous Supplies

Amber glass bottle Labels 

Parafilm Styrofoam coolers/mailers 

Small mailing tubes Freezer 

Obtain 

locally

Cat litter/packing material Dry ice 

Obtain 

locally 

Disposable pipette Resealable plastic bags: 

Pipetting bulb 4" x 4" 

Disposable gloves 6" x 6" 

Protective eyewear 8" x 8" 

 12" x 12" 

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

To order supplies, indicate the quantity of each items needed. Fax a copy of this form to ANPCL at 

228-822-3209 or 228-822-3137. If fax machines are not working, leave a message with the ANPCL supplies 

manager at 228-822-3106. Please realize that it may be difficult to completely fill order for large quantities of 

materials. 

Note: This is not an exhaustive supply list...items that are not listed here may be available through ANPCL.