1. Methods for Incorporating Aquatic Plant Effects into Community Level Benchmarks EPA Development Team Regional Stakeholder Meetings January 11-22, 2010

2. Outline Purpose and Scope Existing data requirements and approaches for estimating aquatic plant effects Key research questions/issues Evaluation of approaches

3. Purpose and Scope Consider existing approaches used by OW and OPP for characterizing plant aquatic ecological effects for incorporating plant effects into Describe the best integrated use of existing tools for incorporating plant effects into aquatic community-level benchmarks. Characterize the uncertainty and robustness of current data for aquatic plants

4. OPP’s Approach to Evaluate Aquatic Plant Effects Tier I (Limit test) Tier I (Limit test) Needed for all pesticides with outdoor uses Needed for all pesticides with outdoor uses 4 microalgae + Lemna: laboratory tests with Technical Grade Active Ingredient (TGAI) 4 microalgae + Lemna: laboratory tests with Technical Grade Active Ingredient (TGAI) If >50% effect, Tier II testing required If >50% effect, Tier II testing required Tier II (Dose-response test) Tier II (Dose-response test) Pesticides that are known phytotoxins also tested at Tier II Pesticides that are known phytotoxins also tested at Tier II 4 microalgae + Lemna: laboratory tests with TGAI 4 microalgae + Lemna: laboratory tests with TGAI If >50% effect, Tier III testing may be required If >50% effect, Tier III testing may be required Tier III (Field test) Tier III (Field test) 4 vascular plant families, 3 seedless vascular plant families, 10+ families of algae, 1 bryophyte family tested with typical end-use product to determine detrimental effects at critical growth stages 4 vascular plant families, 3 seedless vascular plant families, 10+ families of algae, 1 bryophyte family tested with typical end-use product to determine detrimental effects at critical growth stages Rarely required by the Agency Rarely required by the Agency

5. Typical Aquatic Plant Surrogates Used in US Regulatory Testing Pseudokirchneriella subcapitata Anabaena flos-aquae Skeletonema costatum Navicula pelliculosa Lemna gibba, a free-floating vascular macrophyte Non-vascular plants

6. OW’s Approach to Evaluate Aquatic Plant Effects Minimal plant data are required for the derivation of Water Quality Criteria (typically not used since less sensitive) Minimal plant data are required for the derivation of Water Quality Criteria (typically not used since less sensitive) “Results of tests with plants usually indicate that criteria which adequately protect aquatic animals and their uses will probably also protect aquatic plants and their uses.” “Results of tests with plants usually indicate that criteria which adequately protect aquatic animals and their uses will probably also protect aquatic plants and their uses.” May not be supported when addressing certain chemical classes (e.g., herbicides) May not be supported when addressing certain chemical classes (e.g., herbicides) Plant value based on a 96-hr test conducted with an alga or a chronic test conducted with an aquatic vascular plant Plant value based on a 96-hr test conducted with an alga or a chronic test conducted with an aquatic vascular plant Final Plant Value: lowest value from a test with an “important” plant species where test concentrations are measured, and endpoint is biologically “important”. Final Plant Value: lowest value from a test with an “important” plant species where test concentrations are measured, and endpoint is biologically “important”.

7. Approaches Used Internationally Canada Canada At least one vascular plant or alga to derive guidelines (if the compound is highly phytotoxic, 4 species are required) At least one vascular plant or alga to derive guidelines (if the compound is highly phytotoxic, 4 species are required) Safety factors Safety factors 10 applied for LOEC 10 applied for LOEC 100 for acute data on persistent chemicals 100 for acute data on persistent chemicals 20 for acute data on non-persistent chemicals 20 for acute data on non-persistent chemicals European Union European Union Requires a green algae test (for herbicides, tests on an alga and a vascular plant) Requires a green algae test (for herbicides, tests on an alga and a vascular plant) Safety factor of 10 to the lowest plant test value Safety factor of 10 to the lowest plant test value

8. State Approach (MN) Protect overall integrity of plant community from significant impacts; protect the most sensitive species Protect overall integrity of plant community from significant impacts; protect the most sensitive species For 2 herbicides: target 20 th percentile level of protection For 2 herbicides: target 20 th percentile level of protection Acute criterion derived using Great Lakes Initiative Tier II methodology with standard animal data Acute criterion derived using Great Lakes Initiative Tier II methodology with standard animal data Chronic criterion derived using distribution of plant data only Chronic criterion derived using distribution of plant data only Both EC 50 values and/or maximum acceptable toxic concentration (MATCs) were collected and put in separate distributions; distributions with most robust data set were used to derive criteria Both EC 50 values and/or maximum acceptable toxic concentration (MATCs) were collected and put in separate distributions; distributions with most robust data set were used to derive criteria 5 th percentile of EC 50 distribution 5 th percentile of EC 50 distribution 20 th percentile of MATC distribution 20 th percentile of MATC distribution

9. Key Issues Minimum/type of data requirements to document aquatic plant sensitivity Minimum/type of data requirements to document aquatic plant sensitivity aquatic plant grouping into subsets to draw better surrogates aquatic plant grouping into subsets to draw better surrogates representativeness of current microalgal species for non-vascular plants representativeness of current microalgal species for non-vascular plants representativeness of Lemna for aquatic macrophytes representativeness of Lemna for aquatic macrophytes Endpoint selection Endpoint selection The appropriateness of the current plant measurement end points (ECx versus NOAEC) The appropriateness of the current plant measurement end points (ECx versus NOAEC) Specific measurement endpoint-related questions Specific measurement endpoint-related questions Miscellaneous Miscellaneous

10. Key Issues 1. Types/Minimum Data to Document Sensitivity Do we need to group aquatic plants into new subsets to draw better surrogates Do we need to group aquatic plants into new subsets to draw better surrogates Non-vascular vs. vascular (currently used) Non-vascular vs. vascular (currently used) Habitat Habitat Life history patterns Life history patterns Physiology Physiology

11. Key Issues Are the sensitivities of current microalgal species representative of non-vascular plant sensitivities? Are the sensitivities of current microalgal species representative of non-vascular plant sensitivities? Limited information available for comparison of sensitivities of standard algal species to other non-vascular families such as mosses and liverworts Limited information available for comparison of sensitivities of standard algal species to other non-vascular families such as mosses and liverworts Many tests compared sensitivities of various freshwater microalgal species - great variation (2 to 10 orders of magnitude) between species for same toxicant Many tests compared sensitivities of various freshwater microalgal species - great variation (2 to 10 orders of magnitude) between species for same toxicant Sensitivities of freshwater vs. saltwater algae are not well understood Sensitivities of freshwater vs. saltwater algae are not well understood

12. Key Issues Is the sensitivity of Lemna representative of vascular plants sensitivity? Is the sensitivity of Lemna representative of vascular plants sensitivity? Lemna, a free floater, may not be a suitable surrogate to represent the diversity of types of aquatic vascular plants (emergent, submerged, rooted floating, and free floating) Lemna, a free floater, may not be a suitable surrogate to represent the diversity of types of aquatic vascular plants (emergent, submerged, rooted floating, and free floating) Many vascular plants are rooted in the sediment, which could provide another route of exposure Many vascular plants are rooted in the sediment, which could provide another route of exposure

13. Key Issues 2. Endpoint Selection Appropriateness of ECx vs. point estimates such as NOEC/MATC Appropriateness of ECx vs. point estimates such as NOEC/MATC Are plant endpoints acute or chronic? Are plant endpoints acute or chronic? Use of plant and animal data in the same SSD Use of plant and animal data in the same SSD Use of non-traditional endpoints Use of non-traditional endpoints Inclusion of reproduction-based endpoints Inclusion of reproduction-based endpoints Can endpoints from different test methods, test durations, and light intensities be combined? If so how? Can endpoints from different test methods, test durations, and light intensities be combined? If so how?

14. Key Issues 3. Miscellaneous How should plant recovery be incorporated? How should plant recovery be incorporated? Exponential growth over short periods vs. aquatic animal life cycle and reproductive strategies Exponential growth over short periods vs. aquatic animal life cycle and reproductive strategies Current frequency and duration for acute and chronic effects to aquatic animals is once in 3 years – appropriate for plants? Current frequency and duration for acute and chronic effects to aquatic animals is once in 3 years – appropriate for plants? How to address community level impacts How to address community level impacts Community shifts? Community shifts? Other measures? Other measures?

15. Strategy for Addressing Key Issues Toxicity data of at least 2 herbicides with “large” data sets will be utilized Toxicity data of at least 2 herbicides with “large” data sets will be utilized What approaches to take when only OPP data are available? What approaches to take when only OPP data are available? What approaches to take when more data are available? What approaches to take when more data are available? Application of safety factors? (as used by Canada, EU/Denmark etc.) – are there other factors that are more scientifically defensible? Application of safety factors? (as used by Canada, EU/Denmark etc.) – are there other factors that are more scientifically defensible?

16. Summary Aquatic plant testing needs are becoming more apparent. Aquatic plant testing needs are becoming more apparent. Key issues Key issues Representativeness of current tested species Representativeness of current tested species Determining minimum data set Determining minimum data set Potential use of safety factors Potential use of safety factors Use of non-traditional or reproductive endpoints Use of non-traditional or reproductive endpoints Issues discussed in white paper will need to be readdressed in the future. Issues discussed in white paper will need to be readdressed in the future.