EPA’s Vulnerable Species Action Plan may impact pesticide applicators in Michigan

Pesticide applicators may experience label changes aimed at protecting particularly vulnerable endangered species.

A rusty patched bumble bee on a white flower collecting pollen.
Rusty patched bumble bee, seen here, is one of the species listed in the Vulnerable Species Action Plan. Photo by Heather Holm.

The U.S. Environmental Protection Agency (EPA) has released the Vulnerable Species Action Plan (VSAP) as part of an effort to mitigate pesticide impacts on particularly vulnerable endangered species. Unlike the recent EPA herbicide and insecticide strategies that apply only to agricultural pesticide labels, this effort applies to non-residential outdoor conventional pesticides within the contiguous United States and may include agricultural and non-agricultural uses. The VSAP currently includes 20 listed species that have been identified as being particularly vulnerable. The list includes some listed species that may impact Michigan.

Within the VSAP, EPA identified 27 vulnerable species, defined as “a listed species that is particularly vulnerable to pesticides due to a combination of factors including a declining population trend, small number of individuals or small number of populations (e.g., groups of individuals or sub-populations), limited distribution (e.g., endemic, constrained and/or isolated populations), and occurrence in areas that may be exposed to pesticides. Species are included in the VSAP when potential pesticide impacts to a small number or group of individuals may have population level impacts to the species.”

To address concerns related to these particularly vulnerable species, EPA and partners will develop a strategy to identify and mitigate pesticide impacts for each species, which will be communicated via new pesticide label language as needed. These label changes will occur as products undergo standard registration or registration review. Impacted products will include a new section under the “Directions for Use” section of the label that directs users to visit the EPA Bulletins Live! Two website to check the intended application parameters (location, product and timing). Bulletins Live! Two will indicate if any additional use limitations are applicable.

EPA plans to add additional species to the VSAP over time and are still working to refine the use patterns that will require additional pesticide use limitations. EPA is also continuing to develop the associated mitigation measures and offsets that may increase the flexibility available to growers and applicators who need to make an application of impacted products within a pesticide use limitation area.

For more information on the Vulnerable Species Action Plan, refer to the September 2024 EPA press release, “EPA Finalizes Plant to Protect Vulnerable Species,” or go directly to the Vulnerable Species Action Plan.

For more information on Bulletins Live! Two, visit the Michigan State University Extension Bulletins Live! Two website.

 

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