U.S. EPA Office of Chemical Safety and Pollution Prevention Climate Adaptation Implementation Plan

Climate Adaptation
Implementation Plan

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Disclaimer

To the extent this document mentions or discusses statutory or regulatory authority, it does so
for informational purposes only. This document does not substitute for those statutes or
regulations, and readers should consult the statutes or regulations to learn what they require.
Neither this document, nor any part of it, is itself a rule or a regulation. Thus, it cannot change
or impose legally binding requirements on EPA, States, the public, or the regulated community.
Further, any expressed intention, suggestion or recommendation does not impose any legally
binding requirements on EPA, States, Tribes, the public, or the regulated community. Agency
decision makers remain free to exercise their discretion in choosing to implement the actions
described in this Plan. Such implementation is contingent upon availability of resources and is
subject to change.

EPA Publication Number 747B22001

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

SEP 12 2022

P arm ro

$ 2 DEPUTY ADMINISTRATOR

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Preface

Climate change is threatening communities across the nation. Millions of Americans feel the
destructive effects of climate change each year when the power goes down, rivers and lakes
go dry, homes are destroyed by wildfires and communities are flooded by hurricanes.
Underserved communities are especially vulnerable to the climate crisis and are more likely
to experience the negative health and environmental effects of extreme weather events.

The Biden-Harris Administration is actively confronting the climate crisis while also
advancing environmental justice. As part of a whole-of-government approach, the U.S.
Environmental Protection Agency is strongly committed to taking the actions necessary to
protect human health and the environment and to increase the resilience of the entire nation,
even as the climate changes.

The EPA's commitment to action is reflected in its FY 2022-2024 Strategic Plan and in the
2021 Climate Adaptation Action Plan. Both documents present priority actions the agency
will take to ensure that its programs, policies and operations remain effective under future
climate conditions while we work to support states, territories, tribes and communities in
increasing their own adaptive capacity and resilience to climate change impacts.

From flooding at Superfund sites, to wildfires causing air pollution, to sea-level rise affecting
water quality and infrastructure, the EPA will boldly address climate impacts in both its
programs and the communities it serves. We recognize the importance of tribal, state and
local government partnerships in efficient, effective and equitable implementation of climate
change adaptation strategies. Our plans were informed and improved by input we received in
listening sessions we held to engage these and other partners as we developed these plans.

To ensure we are addressing the climate crisis in a comprehensive way, each of our national
program and regional offices has developed individual Climate Adaptation Implementation
Plans that outline how the EPA will attain the agencywide goals described in the broader
Climate Adaptation Action Plan. These plans describe how programs and regions will
integrate climate adaptation into their programs, partnerships and operations. They also
describe how they will help partners build their resilience and capacity to adapt, while
delivering co-benefits, including curbing greenhouse-gas emissions and other pollution, and

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promoting public health, economic growth and climate justice. Of course, the EPA has a
major role to play on emissions reductions as well, though that is not the focus of these plans.
Indeed, we must focus on both climate adaptation and mitigation to ensure our nation and
communities thrive in an era of climate change.

As part of this effort, we will empower our staff and partners by increasing awareness of how
climate change may affect our collective ability to implement effective and resilient
programs. We will also provide them with the necessary training, tools, data, information and
technical support to make informed decisions and integrate climate adaptation into our work.

The EPA will work to modernize its financial assistance programs to encourage climate-
resilient investments across the nation. We will also focus on ensuring that investments
funded by the Bipartisan Infrastructure Law, the Inflation Reduction Act and other
government programs are resilient to the impacts of climate change. Finally, as our
knowledge advances and as impacts continue to develop, our response will likewise evolve.
We will work to share these developments to enhance the collective resilience of our nation.

The actions outlined in these implementation plans reflect the EPA's commitment to build
every community's capacity to anticipate, prepare for, adapt to and recover from the
increasingly destructive impacts of climate change. Together with our partners, we will work
to create a healthy and prosperous nation that is resilient to the ever-increasing impacts of
climate change — which is vital to the EPA's goal of protecting human health and the
environment and to ensuring the long-term success of our nation.

Janet G. McCabe

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Climate Change Adaptation Implementation Plan
The Office of Chemical Safety and Pollution Prevention (OCSPP)

Table of Contents

1. Background 6

2. OCSPP Role in Implementing Agency Strategic Goals 7

3. Senior Leadership and Staffing 8

4. Climate Vulnerability Assessment 9

5. Priority Actions 15

6. Training Plan for Climate Knowledge 23

7. Tribal and Environmental Justice Considerations 23

8. Science Needs 25

9. Operational Resiliency 26

10. Bipartisan Infrastructure Law 27

11. Adoption 27

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Climate Change Adaptation Implementation Plan
EPA Office of Chemical Safety and Pollution Prevention (OCSPP)

1. Background

On January 27, 2021, President Biden signed Executive Order (EO) 14008 on Tackling the
Climate Crisis at Home and Abroad.1 The EO builds on and reaffirms actions the administration
has taken to place the climate crisis at the forefront of the nation's policy including rejoining
the Paris Agreement, which occurred on January 20, 2021. As part of its continuing
commitment the administration will also host a leaders' climate summit, reconvene the major
economies forum on energy and climate, and establish a special presidential envoy for climate.
The EO also emphasizes taking a government-wide approach to the climate crisis. EPA
Administrator Regan has repeatedly stated the Agency's support for the EO in a variety of
settings.

OCSPP is one of EPA's national programs. The overall office is comprised of three distinct offices
that make up the chemical safety program: the Office of Pesticide Programs (OPP), the Office of
Pollution Prevention and Toxics (OPPT), and the Office of Program Support (OPS).2 For OCSPP,
development of this plan means integrating consideration of critical policy issues related to
climate change into routine processes including pesticide registration decisions under the
Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA), new chemicals assessment under
the Toxic Substances Control Act (TSCA), and the risk evaluation process under TSCA for existing
chemicals. OCSPP also is responsible for managing the Agency's pollution prevention programs
under the Pollution Prevention Act (PPA), which are designed to prevent pollution at the
source, promote the use of greener substances, and conserve natural resources. Under the EO,
national programs and regions are each required to develop a Climate Change Adaptation
Implementation Plan to integrate climate adaptation into their portfolios. This document and
other program/region specific plans will be integrated into an overall EPA plan that will be key
to meeting the policy directives outlined in the EO.

This document focuses on climate change adaptation and not how changes in climate patterns
occur from human-caused increased levels of atmospheric greenhouse gases (GHG). Climate
change adaptation means taking action to prepare for and adjust to both the current and
projected impacts of climate change.3 There may be instances where there are related GHG
impacts such as releases due to environmental degradation. These will be noted and
considered as appropriate.

1 E.O. 1/27/21 https://www.whitehQUse.gQv/briefing-rQQm/presidential-actions/2021/Ql/27/executive-order-on-tackling-the-climate-crisis-at-

ho m e-a n d-a b r oa d /

2 https://www.epa.gov/aboutepa/about-office-chemical-safetv-and-poHution-prevention-ocspp

3 https://www.epa.gov/climate-adaptation/climate-adaptation-and-epas-role

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Programs and regional offices were asked to include a variety of elements in their plan. These
include: programmatic vulnerabilities, priority actions, role in the Agency's strategic measures,
legal/enforcement, training/outreach, partnerships with stakeholders, impacts on vulnerable
populations/locations, operational resiliency, science needs, consideration of the Bipartisan
Infrastructure Law, and evaluation to inform the organization's efforts to integrate climate
adaptation into its activities. Each of these elements have been integrated as appropriate
herein.4

2. OCSPP Role in Implementing Agency Strategic Goals

Goal 1/Objective 1.2 Accelerate Resilience and Adaptation to Climate Change Impacts of the
EPA 2022-2026 Strategic Plan describes long-term performance goals and strategies for
addressing climate adaptation.5 The key long-term performance goals include implementing all
priority actions outlined in the EPA Climate Adaptation Action Plan6 and those contained in
each of the 19 National Program and Regional Climate Adaptation Implementation Plans - this
document is the National Program Climate Adaptation Implementation Plan for OCSPP. The
overall EPA Plan identified five priority actions: integration of climate adaptation into programs,
stakeholder interaction, EPA resilience, performance metrics, and identification of science
needs. The EPA Plan also provided strategies related to how these priorities are to be achieved.

The primary responsibility of OCSPP is to ensure the safety of chemicals as stipulated in EPA's
Strategic Plan Goal 7; Ensure Safety of Chemicals for People and the Environment.7 OCSPP has
developed this document to identify how and where climate adaptation will be incorporated
into its programs.

Chemicals used to make products, build homes, protect property and crops, and support our
way of life can potentially end up in the environment, cause risks (which are a function of
exposure and the toxicity of a chemical), and impact human and environmental health. A
changing climate and the associated effects of that process can impact risks to a wide range of
chemicals make communities more vulnerable. OCSPP's efforts to assess chemical safety and to
implement chemical management decisions and pollution prevention programs to
appropriately manage risks could be impacted by a changing climate related to extreme
weather events (e.g., increasing run off can increase pollution in nearby streams), changing
chemical use patterns (e.g., changing pest pressure can affect the use of agricultural chemicals),
as well as other factors. Decision making within OCSPP related to climate change issues will
consider such impacts within the bounds of the applicable statutes.

4 This document focuses on domestic climate adaptation considerations. OCSPP will support international activities as appropriate either solely
or in coordination with other aspects of EPA (e.g., collaboration via the United Nations Industrial Development Organization).

5 https://www.epa.gov/svstem/files/documents/2021-10/fv-2022-2026-epa-draft-strategic-plan.pdf &

https://www. epa.gov/svstem/files/dQcuments/2021-10/fy-2022-2026-epa-draft-strategic-p lan. pdf#page=14&zoom=100,69,82

6 https://www.epa.gov/svstem/files/documents/2021-09/epa-climate-adaptation-plan-pdf-version.pdf

7 https://www.epa.gov/svstem/files/documents/2021-10/fv-2022-2026-epa-draft-strategic-plan.pdf#page=69&zoom=100,69,82

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The specific statutes within the regulatory framework that OCSPP uses to ensure chemical
safety provide for risk-based decision making but this framework differs for pesticides and
industrial chemicals based on statutory requirements. Pesticides are regulated under the
Federal Fungicide, Insecticide and Rodenticide Act (FIFRA) and under the Federal Food, Drug,
and Cosmetic Act (FFDCA), EPA's implementation of which is managed by OPP. Industrial
chemicals are evaluated and regulated under the Toxic Substances Control Act (TSCA), which is
managed by OPPT. OPPT also administers the Pollution Prevention Act (PPA) through a series of
programs that identify and leverage opportunities to prevent pollution. The PPA expanded the
Toxics Release Inventory (TRI) Program, governed by the Emergency Planning and Community
Right-to-Know Act (EPCRA), to include the collection of information to track industry progress in
reducing waste generation and moving towards safer waste management alternatives. OPPT
manages EPA's TRI Program.

3. Senior Leadership and Staffing

EPA's Office of the Administrator (OA) coordinates climate change activities across the Agency
and represents the Agency in cross-governmental groups. To support EPA's efforts to address
the climate change issue, OCSPP along with each EPA national program office and regional
office must have a specific climate adaptation plan and designate associated leadership and
staffing roles. Those involved in addressing the climate change issue will:

• Represent the program in interactions with OA, other programs, and regions on issues
related to climate change.

• Be the primary point of contact and conduit of information for the national program,
including maintaining a list of subject matter experts on relevant issues.

• Coordinate directly with management across the national program.

• Ensure that the national program coordinates with impacted stakeholders as
appropriate.

The staffing plan of the OCSPP climate team (Table 1) is at the discretion of the Assistant
Administrator for OCSPP. Currently, the approach is to have the Science Advisor in the OCSPP
Immediate Office serve as the overall coordinator with the other science advisors serving as
alternates in this role and/or supporting this function. The broad nature of the climate issue
dictates engagement across the OCSPP organization. The office directors are included in this
plan to ensure continuity in the process of initiating and sustaining elements of the plan such as
directing staff and resources which will clearly be needed to address vulnerabilities through the
identified priority actions described below.

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Table 1: OCSPP Climate Staffing Plan

Positioi i/Title/Gi oup

Suh-Qi'^diii'tdlioii

Roie Jrsa iption

Assistant Administrator

Office of Chemical Safety and
Pollution Prevention

Michai Freedhoff

Senior Executive Sponsor

Deputy Assistant
Administrator for Pollution
Prevention

Office of Chemical Safety and
Pollution Prevention

Jennie Romer

Senior Executive Advisor

Science Policy Advisor

Office of Chemical Safety and
Pollution Prevention

Jeff Dawson

Staff Lead

Science Policy Advisor

Office of Chemical Safety and
Pollution Prevention

Stan Barone

Staff Lead

Science Policy Advisor

Office of Pesticide Programs

Vacant (Anna Lowit on detail
to OPPT)

Staff Lead

Science Policy Advisor

Office of Pollution Prevention and
Toxics

Anna Lowit (acting)

Staff Lead

Office Director

Office of Program Support

Hayley Hughes

Program Management Lead

Office Director

Office of Pesticide Programs

Ed Messina

Program Management Lead

Office Director

Office of Pollution Prevention and
Toxics

Denise Keehner

Program Management Lead

Note: Teams related to specific topics will be assembled and used as applicable for pertinent issues. These will be designated at the
discretion of the Staff Lead and Program Management Leads for each applicable office.

4. Climate Vulnerability Assessment

OCSPP identified vulnerabilities associated with climate change in its 2014 Climate Adaptation
Plan.8 Further efforts to identify vulnerabilities were completed during the interagency
development of the Fourth National Climate Assessment.9 The national assessment focused on
topics in which OCSPP may have equities including land use patterns, forests, ecosystems and
biodiversity, oceans and marine resources, agriculture, urban areas, air quality, human health,
and tribes/indigenous peoples.

The effects on the environment resulting from climate change pose challenges to EPA as it
strives to fulfill its mission of protecting human health and the environment. Challenges
resulting from a changing environment due to climate change that may inhibit the Agency's
ability to fulfill its mission are referred to as vulnerabilities. Vulnerabilities include physical
changes in the environment causing increased exposure to chemicals and their breakdown
products. Breakdown products may, in some cases, be more hazardous and thereby increase

8 https://www.epa.gov/sites/default/files/2015-08/documents/adaptationplans2014 508,pdf#page=110 & https://www,epa.gov/climate-

adaptation/2014-climate-adaptation-plans
9https://nc:a2018. globalchange.gov/

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risks. They may also relate to programmatic processes or tools that may need to be adapted as
a result of a changing environment. This section discusses potential vulnerabilities to OCSPP's
mission of ensuring chemical safety, tracking chemical releases, and otherwise preventing
pollution.

OCSPP has considered vulnerabilities related to climate change for several years. For example,
in 2010 to assist with the evaluation of potential programmatic vulnerabilities, OCSPP consulted
the FIFRA Scientific Advisory Panel (SAP)10 to seek advice on areas within pesticide assessment
processes that may be vulnerable to changing climatic conditions. The SAP concluded that
climate change would likely impact pest pressure which can impact how and where pesticides
are employed, and the quantity of pesticides used. The SAP agreed with the preliminary EPA
conclusions that since pesticide registrations are reevaluated at least every 15 years using
assessment methodologies that are conservative and protective of human health and the
environment, it is expected that the assessments, and decisions based on them, will remain
protective if they evolve and account for climate shifts (e.g., through updates to weather-based
inputs used for assessments).

Table 2 below presents the major vulnerabilities which have been identified currently for
OCSPP and its programs. It also describes:

• Relevant risks posed by climate change and potential impacts.

• Environmental Justice concerns including vulnerable populations potentially at risk due
to the climate threat.

• Actions already taken to address the risks, remaining vulnerabilities, and known barriers
to further actions.

EPA's chemical safety programs—particularly the assessment and management of chemical risks
to health and the environment, including risks to vulnerable subpopulations—will play an
important role in achieving the Biden-Harris Administration's goal to tackle the climate crisis as
set forth in Executive Order (EO) 14008: Tackling the Climate Crisis at Home and Abroad. Since
TSCA was amended in 2016, significantly increasing EPA's responsibilities under TSCA, the
resources appropriated for this work have remained essentially unchanged. EPA's ability to
implement the actions in this plan will depend on whether resources requested in the FY 2023
President's budget request are provided to the agency.

Overall, the vulnerabilities discussed below are unlikely to severely impede OCSPP's ability to
carry out its core mission of ensuring chemical safety and preventing pollution because many of
its programmatic processes can be adapted to address changing environmental conditions,
including those resulting from climate change which is discussed further below.

10 December 2010 Scientific Advisory Panel Meeting, EPA~HQ~OPP-2010~Q761

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Table 2: Major Vulnerabilities Related to Climate Change For OCSPP

Vulnerability: Key
Office11

Impact - Likelihood and Nature

Actions Already Being Taken

Known Barriers to Future
Actions

Vulnerable Populations

Pest Complex Changes:
OPP

Climate change can alter pest pressure (e.g., species,
population levels, potential resistance) or the location
where crops are grown, which in turn may affect the
rate, timing and/or frequency of chemical use (e.g.,
subtropical fruit production moving further north as
temperatures increase). Such events can alter pest
pressure because of several factors including but not
limited to differing indigenous pests in those areas or
pests moving with crop and climate changes. This
could impact chemical use due to the chemicals
needed, increases in the rate, timing and/or frequency
of chemical use. This could burden Section 24 and
Section 18 programs for local needs. These effects
could also pressure Agency resources should they
require modifications to labels and potentially
pesticide registration review schedules as more
frequent evaluations based on changing scientific
inputs could be needed. It may also burden producers
because of economic changes tied to factors such as
choice/availability of chemistries and impacts on crop
yields.

OCSPP has established lines of
communication with a strong network of
potentially impacted stakeholders. This
enables the organization to track trends
related to changing pest complexes and
the nature and location of where crops
are grown. Mechanisms are also in place
to allow for flexible scheduling and
focused use of available resources such as
employed during the COVID pandemic to
ensure timely consideration of necessary
regulatory actions. Opportunities for
education, training, and linkages with co-
regulators will be utilized to enhance
these efforts.

The are many potential barriers which
include unpredictable factors such as
the magnitude and breadth of a
particular event which could
potentially challenge available
information and resources (e.g.,
aftermath of a large hurricane or
major flooding). Additionally, training
and expertise of Agency staff may be
limited relative to possible issues
which may require outside counsel
and/or particular peer review activities
(e.g., establishing health criteria for a
new mode of action insecticide,
resources for implementation).

It is anticipated that this type of issue
will be largely geographical in nature.
This indicates that any possible
susceptible population within such
locales could be impacted and will be
considered. Demographic factors such
as economic disparities, race, and age
(e.g., children or the elderly) will be
included as well as whether tribes and
indigenous peoples are impacted.
Additionally, social and cultural
concerns will be considered along with
environmental factors as applicable.

Novel Disease Vectors
and Invasive Species:
OPP

The introduction of new disease vectors or invasive
species could increase the demand for evaluating and
making decisions regarding the safety of new
chemicals or new uses of existing products to address
public health threats. For example, invasive species
could displace native species and create new pest and
disease concerns.

OCSPP is actively engaged with partner
organizations (e.g., CDC and USDA) to stay
informed regarding potential disease
vectors and invasive species. OCSPP is also
active related to obtaining information on
new control measures such as novel
modes of action chemistries and existing
approaches such as those utilized in
Integrated Pest Management.

There are limited staff with applicable
knowledge of critical public health
topics so broader training may be
required. Also, resources are limited
and there is limited, focused research
and support for public health pesticide
development given costs and low
typical return for producers. This is
important because in many
circumstances there are limited
control measure options available
(e.g., only a couple modes of action
are available for mosquito
management).

It is anticipated that this type of issue
will be largely geographical in nature
(defined by pest of concern range) or
focused on certain agricultural sectors
(e.g., avian or swine flus). This
indicates that any possible susceptible
population within such locales could
be impacted and will be considered.
Demographic factors such as economic
disparities, race, and age (e.g., children
or the elderly) will be included as well
as whether tribes and indigenous
peoples are impacted. Additionally,
social and cultural concerns will be
considered along with environmental
factors as applicable.

11 The "Key Office" information is intended to elaborate the key elements within OCSPP to which each vulnerability applies.

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3

Changes in Chemical
Production Practices:

OPP& OPPT

Extreme weather events and impacts to energy
production and use are important considerations.
Limited availability of water and other natural
resources are changing the way manufacturers
produce products, driving them to look for new ways
to reduce and reuse water and other materials.
Increased demands on energy are pushing businesses
to streamline production processes and minimize
waste.

OCSPP will continue to use its authorities
to ensure the safest possible practices are
utilized in chemical production and use
activities. It will also use its existing
pollution prevention efforts to encourage
safer, climate friendly practices.
Additionally, existing reporting
requirements and the resulting data can
be used to identify and assess events
which are publicly available.

There are many potential barriers
which include unpredictable factors
such as the magnitude and breadth of
a particular event which could
potentially challenge available
information and resources.
Additionally, training and expertise of
Agency staff may be limited relative to
possible issues which may require
outside counsel and/or peer review
activities on particular issues (e.g.,
establishing health criteria for novel
material new chemical action).

It is anticipated that this type of issue
will be largely geographical in nature
as defined by the locale of the
production facility and could impact
exposure potential and other factors
such as social and cultural
considerations. This would indicate
that any possible susceptible
population within such locales could
be impacted and will be considered.
Demographic factors such as economic
disparities, race, and age (e.g., children
or the elderly) will be included as well
as whether tribes and indigenous
peoples are impacted.

Damage Due to
Extreme

Weather/Infrastructure
Failure: OPP & OPPT

Extreme changes in environmental conditions that
could impact chemical safety need to be considered.
For example, rising sea levels and more frequent
extreme weather events increase the vulnerability to
flooding and destruction of structures in low lying
areas due to the magnitude of an event and/or
infrastructure failure. Chemical production and storage
facilities located in low lying areas may have an
increased potential for chemical releases into the
environment as a result of major weather events.
Similarly, many farms, pesticide storage facilities, and
businesses are along major waterways because of
their proximity to growing areas, which could be
impacted. Industrial chemicals could also be stored in
low lying areas near ports along the seaboard, rivers,
and other waterways.

OCSPP maintains systems which can be
used to identify applicable information
should an event occur (e.g.,
environmental fate data/criteria and
water modeling tools could be used to
evaluate impacts of a flooded pesticide
storage facility). Also, chemical storage
criteria are included in pesticide user
training and associated directives. OCSPP
works to provide this information to
address topical events and to ensure
longer term preventative solutions
whenever feasible.

There are many potential barriers
which include unpredictable factors
such as the magnitude and breadth of
a particular event which could
challenge available information and
resources. Additionally, resources,
training and expertise of Agency staff
may be limited relative to possible
issues which may require outside
counsel and/or peer review activities
on particular issues (e.g., establishing
health criteria for novel material new
chemical action).

Infrastructure Supply
Chain Impacts: OPP &
OPPT

Increased demand due to shifting weather patterns
may require novel technologies and additional systems
related to housing and other human needs. This could
burden the new chemicals program for industrial
chemicals. It could also impact existing chemicals
reviews since production values, the numbers of
workers involved, and other factors could change
because of needs for chemicals (e.g., refrigerant
feedstocks). Changing climate can also induce disease
outbreaks which may necessitate higher than normal
levels of chemicals such as disinfectants and PPE which
could impact infrastructure operations (e.g., ensuring
safety at subway stations, airports and in mass transit
vehicles).

OCSPP has established lines of
communication with a strong network of
potentially impacted stakeholders. This
enables the organization to track trends
related to changing supply chain issues.
Mechanisms are also in place to allow for
flexible scheduling and focused use of
available resources to ensure timely
consideration of necessary regulatory
actions. OCSPP also collaborates closely
with EPA's OHS and ORD to ensure cutting
edge research information is utilized in a
timely way.

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6

Agricultural Practice
Adaptation: OPP

Changes in pest pressures, crop tolerance to weather,
use of greater quantities of pesticides, and other
factors might have unintended consequences related
to the increased use of fuels to achieve equal amounts
of agricultural yields because more applications of
pesticides or mechanical cultivation practices might be
required.

OCSPP is aware that this is an issue and is
considering how climate related factors
such as this can potentially be included in
regulatory decision making. Often in
critical decisions, alternatives analyses
indicate that additional pesticide use or
mechanical cultural practices are needed
to replace certain chemistries. Information
related to these will be utilized in such
processes.

The are many potential barriers which
could impact implementation of this
issue including statutory requirements
for regulatory decision making and
appropriate quantification of climate
related criteria as an input into such
decisions (e.g., determination of
climate load from additional
fuel/equipment use). Resources may
also be limited for evaluating this issue
and implementing updated
approaches.

The impacted populations from this
issue will be determined largely based
on geographical constraints but in this
case, locales will be determined based
on where crops are produced, and the
chemicals used for those crops.
Emphasis will be placed on
farmworkers as they experience more
routine exposures to pesticides.
Demographic factors such as economic
disparities, race, and age (e.g., children
or the elderly) will be included as well
as whether tribes and indigenous
peoples are impacted.

Institutional Use
Practice Adaptation:
OPP

Changes in pest pressures, pest tolerance to weather,
use of greater quantities of pesticides, and other
factors might have unintended consequences. These
could include higher uses of pesticides in institutional
settings such as hospitals, schools, public housing.
They may also require greater expenditures and
fuel/energy use with increased sealing of buildings.

OCSPP is aware that this is an issue and is
considering how climate related factors
such as this can potentially be included in
regulatory decision making. Often in
critical decisions, alternatives analyses
indicate that additional pesticide use or
changing management practices are
needed to replace certain chemistries.
Information related to these will be
utilized in such processes.

The are many potential barriers which
could impact implementation of this
issue including statutory requirements
for regulatory decision making and
appropriate quantification of climate
related criteria as an input into such
decisions (e.g., determination of
climate load from additional energy
use). Resources may also be limited for
evaluating this issue and implementing
updated approaches.

The impacted populations from this
issue will be determined largely based
on geographical constraints where
known institutional pest pressures
exist (e.g., termite presence in the
southeast). Demographic factors such
as economic disparities, race, and age
(e.g., children or the elderly) will be
included as well as whether tribes and
indigenous peoples are impacted.

Endangered Species &
Pollinator Impacts: OPP

Climate changes could have detrimental effects on
endangered species and pollinators due to changing
their habitat and ranges. This could impact pesticide
regulation as it would require updated analyses of the
impacts of chemicals on such species. As noted above
this could burden regulatory programs needed to
address local needs.

OCSPP considers the most up to date
information relative to endangered
species and pollinators including their
vulnerability, potential to be exposed to
and affected by chemicals, as well as their
biology, habitats, and ranges as provided
by the applicable U.S. Services. If climate
change impacts where endangered
species are located, then there may be
implications related to land use, pesticide
usage, and regulations in those areas,
which could include use of different
chemistries of pesticides or other factors
that would need to be evaluated relative
to the species. OCSPP also has active
pollinator protection programs which can
be leveraged to address these issues.

As the U.S. Services provide
information on species habitats and
ranges the schedule for updates may
not coincide with specific OCSPP
program needs related to specific
locales and events. Changes in habitats
and ranges for pollinators will also be
considered based on availability of
information, which could be limiting.
Resources may also be limited for
evaluating this issue and implementing
updated approaches.

It is anticipated that this type of issue
will be largely geographical in nature.
This indicates that any possible
susceptible population within such
locales could be impacted and will be
considered.

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9

Outdated tools and
methods: OPP & OPPT

This is a primary vulnerability which was identified
related to chemicals management programs. It is
critical to ensure that the tools and methodologies
OCSPP uses remain robust so that they reasonably
reflect environmental changes, including those
influenced by climate change.

OCSPP periodically updates its tools and
methods to account for changing
information. These updates are typically
defined by relevance noted by the user
communities and applicable subject
matter experts. Also, pesticides are
periodically reviewed in the registration
review process which ensures the most up
to date data and methods are employed.

Tools and methodologies often require
information technology input to
update tools such as an electronic
modeling system. Resources and
systems may be outdated which would
require extensive expenditures and
time which could delay development
and implementation. Resources may
also be limited for evaluating this issue
and implementing updated
approaches.

It is anticipated that this type of issue
will be specific in nature (e.g.,
geographic or life stage specific). This
indicates that any possible susceptible
population within such locales could
be impacted and will be considered.
Demographic factors such as economic
disparities, race, and age (e.g., children
or the elderly) will be included as well
as whether tribes and indigenous
peoples are impacted.

Outdated Critical Data:
OPP & OPPT

Existing data could be compromised under certain
circumstances related to changing climate and its
impact on agriculture. For example, changing climatic
zones could influence the relevance of crop field trial
data used in dietary exposure analysis given the
potential for more pesticide need due to extended
seasons and evolving pest pressures. Additionally,
stream flow information and other environmental fate
information (e.g., dissipation characteristics) could be
outdated given increasing drought and or severe
weather event conditions. This could impact pesticide
and industrial chemical environmental evaluations.

OCSPP periodically updates critical data
used for analysis. For example, the
pesticides program recently updated
weather information used for air modeling
predictions to more recent periods of time
in order to reflect more current
conditions. In cases such as with field trials
the Agency will monitor changes in factors
such as USDA growing regions which could
impact data applicability and will adjust
accordingly. This may include, but is not
limited to, using USDA Pesticide Data
Program (PDP) monitoring data in dietary
exposure analyses as well as current
pesticide usage data that may identify
changes in pesticide usage in many major
crops because of shifts in pest pressures
or cropping practices as well as current
pesticide usage data that may identify
changes in pesticide usage in many major
crops because of shifts in pest pressures
or cropping practices.

The ability to ask for additional
research to support needed future
data needs may be compromised
because of statutory limitations
related to requiring such information
from the regulated community.

Limited funding and/or internal
laboratory capacity could impact the
ability to have access to applicable
data in the future. Resources may also
be limited for evaluating this issue and
implementing updated approaches.

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5. Priority Actions

OCSPP has identified a series of priority adaptation actions which are in alignment with the May
2021 EPA Draft Climate Adaptation Action Plan and the May 2021 Policy Statement on Climate
Adaptation.12 These priority actions will be implemented to integrate climate adaptation into
OCSPP programs, policies, rules, financial programs, and operations (including procurement and
facilities). Additional consideration has been given to actions that also deliver co-benefits in
other areas including reductions in greenhouse gases and other pollution; public health
enhancements; economic growth and job creation; enhanced national security; and
environmental justice.

The EPA Climate Adaptation Plan has five following priorities. They include:

1) Integrate climate adaptation into EPA programs, policies, rulemaking processes, and
enforcement activities.

2) Consult and partner with states, tribes, territories, local governments, environmental
justice organizations, community groups, businesses, and other federal agencies to
strengthen adaptive capacity and increase the resilience of the nation, with a particular
focus on advancing environmental justice.

3) Implement measures to protect the agency's workforce, facilities, critical infrastructure,
supply chains and procurement processes from the risks posed by climate change.

4) Measure and evaluate performance.

5) Identify and address climate adaptation science needs.

Table 3 provides a summary of the OCSPP main priority action items for quick reference. The
table also provides higher level information associated with each item such as relevance to the
Agency goals as noted above. Additional, more detailed narratives are provided below based on
the data fields prescribed as part of the required content of this document for each action item.

12 https://www,epa.gov/climate-change

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Table 3: OCSPP Climate Adaptation Priority Action Items

OCSPP Priority
Action Item

Description

Co-Benefits

Applicable EPA
Climate Adaptation
Plan Priority 13

Lead Organization

Timeframe

Streamline Processes for
Bringing Climate Favorable
Chemistries to Market

Scientific Integrity,

Environmental

Justice

OPP, OPS, OPPT
depending upon
specific topic

Many not initiated, some
ongoing with general plans
in place by FY 2023

Training & Communication

Scientific Integrity,

Environmental

Justice

2, 3

OPP, OPS, OPPT
depending upon
specific topic

Many not initiated with
some ongoing with general
plans in place by FY 2023

Enhance Rulemaking and
Decision Processes

Scientific Integrity,

Environmental

Justice

1, 3, 5

OPP, OPS, OPPT
depending upon
specific topic

Many not initiated with
some ongoing with general
plans in place by FY 2023

Framework Development

Scientific Integrity,

Environmental

Justice

OPP, OPS, OPPT
depending upon
specific topic

Ongoing with general plans
in place by FY 2023

Detailed information related to each OSCPP Climate Adaption Priority Action Item and
supporting performance measures are provided below in Table 4.14 Each product developed as
a result of the priority actions undertaken as part of this plan will also include in associated
publications and communication materials a component that describes how climate adaptation
concerns have been integrated into the materials. Additionally, efforts will be made to include
climate adaptation considerations in other materials produced by OCSPP especially major policy
statements and decision related materials as appropriate.

13 Based on EPA Climate Adaptation Plan listed on previous page and more detailed table below.

14 Note there is a field in these tables "Key Partners and Stakeholders" which only provides information on external partners. Collaboration
within EPA is coordinated via an established workgroup focused on climate adaptation that is represented by all programs and regions.

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Table 4: OCSPP Climate Adaptation Priority Action Items

OCSPP Climate Adaptation Priority Action Item A: Increase the number of streamline processes for bringing climate favorable chemistries to the market.

Sub-priority A.l - Actions to directly support climate adaptation related to new chemistries and innovative technologies or other related processes

Co-Benefits

Scientific Integrity, Environmental Justice

Applicable Agency
Climate Adaptation
Plan Priorities

Lead Organizations

OPPT, OPS depending upon specific topic

Timeframe

Not initiated, plan in place by FY'22. Begin implementation in FY 2023.

Performance Metrics

Develop a strategy to directly support climate adaptation related to new chemistries, innovative technologies, and/or other related processes.

FY 2023 Target

Metric Details

Baseline: One strategy implemented for biofuels to directly support climate adaptation in FY 2022.

Data Source: Report out from OPPT/New Chemicals Division

Misc.: Strategy could include guidance and training. In FY 2023, EPA is exploring strategies in areas such as electric vehicle batteries, biotechnologies, and
hydrofluorocarbon replacements.

Resource Requirements

No specific resources have been allocated to this activity. Resource needs will vary based on the nature of the issue, the availability of pertinent information, the vetting
required of new information, and the integration of new information into existing tools and/or processes.

Accomplishments

This is a novel effort.

Key Partners &
Stakeholders

ECOS https://www.ecos.org/

American Chemistrv Council https://www.americanchemistrv.com/default.asDX

Green Chemistrv in Commerce Council (GC3) https://sreenchemistrvandcommerce.org/

Association for the Advancement of Alternatives Assessment https://www.saferalternatives.org/

American Chemical Society Green Chemistrv Institute https://www.acs.org/content/acs/en/greenchemistrv/about.html

Various NGOs - Natural Resources Defense Council (NRDC), Environmental Working Group (EWG), Environmental Protection Network (EPN), Union of Concerned
Scientists (UCS), People for the Ethical Treatment of Animals (PETA)

Co-regulators - State, local, tribal, and territorial programs

Other appropriate academic, regulated industry, and scientific organizations

Challenges/Barriers

The challenges are multifaceted and include maintaining the ability to properly identify the most current data and information which could have been refreshed based
on climate change criteria. They also include resource challenges associated with the surety of novel information and integration of such information into tools and
processes.

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Table 4: OCSPP Climate Adaptation Priority Action Items

Sub-priority A.2 - Consider impact of climate change and the resulting effects (e.g., on evolving pest complexes such as novel invasive and disease vectoring pests, shifting crop production patterns,
and risk management options)

Co-Benefits

Scientific Integrity, Environmental Justice, Public Health, Homeland Security

Applicable Agency
Climate Adaptation
Plan Priorities

Lead Organizations

OPP, OPS depending upon specific topic

Timeframe

Not initiated, plan in place by FY'22. Begin implementation in FY 2023.

Performance Metrics

Develop a strategy for evaluating the processes associated with Section 18s to determine potential efficiencies and/or process improvements.

FY 2023 Target

Metric Details

Baseline: Zero strategy for considering the impact of climate adaptation and the resulting effects in FY 2022.
Data Source: Report out from OPP/Registration Division
Misc.: Strategy could include accompanying guidance as well.

Resource Requirements

Accomplishments

Activities are ongoing related to this sub-priority, but the climate change adaptation component is a novel effort.

Key Partners &
Stakeholders

USDA-for a variety of ag related issues

CDC - because of climate impacts on disease vectors

Local mosquito control districts and state lead agencies (via program and regional contacts or AMCA https://www.mosquito.org/)

RISE https://www, pestfacts.org/

Crop Life America http://www.croplifeamerica.org/

Various NGOs - NRDC, EWG, EPN, UCS, United Farmworkers (UFW), PETA

Co-regulators - State, local, tribal, and territorial programs

Other appropriate academic, regulated industry, and scientific organizations

Challenges/Barriers

The challenges are multifaceted and include maintaining the ability to properly evaluate the current tools and processes which may need to be refreshed based on
climate change criteria. They also include resource challenges associated with the surety of novel information and integration of such information into tools and
processes.

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Table 4: OCSPP Climate Adaptation Priority Action Items

OCSPP Climate Adaptation Priority Action Item B: Establish and Implement training programs related to climate adaptation for OCSPP employees.

Co-Benefits

Scientific Integrity, Environmental Justice

Applicable Agency
Climate Adaptation
Plan Priorities

2 & 3

Lead Organizations

OPP, OPS depending upon specific topic

Timeframe

Not initiated. Scoping exercise to be completed in FY'22. Followed by content development and beginning implementation FY 2023

Performance Metrics

Complete training climate adaptation curriculum.

FY 2023 Target

100%

Metric Details

Baseline: Zero trainings on climate change topics relevant for risk evaluation and risk management in FY 2022.

Data Source: Report out from climate training workgroup.

Misc.: This activity will include forming a climate training workgroup, developing a curriculum, and testing the curriculum with a focus group. May be dependent upon
training delivery method.

Resource Requirements

No specific resources have been allocated for this activity. Resource needs will vary based on the nature of the issue, the availability of pertinent information, the
vetting required of new information, and the integration of new information into existing tools and/or processes.

Accomplishments

Activities are ongoing related to this sub-priority, but the climate change adaptation component is a novel effort.

Key Partners &
Stakeholders

USDA - for a variety of ag related issues

CDC - because of climate impacts on disease vectors

ECOS https://www.ecos.org/

Local mosquito control districts and state lead agencies (via program and regional contacts or AMCA https://www.mosquito.org/)

RISE https://www.pestfacts.org/

Crop Life America http://www.croplifeamerica.org/

American Chemistry Council https://www.americanchemistrv.com/default.aspx
Green Chemistrv in Commerce Council (GC3) https://greenchemistrvandcommerce.org/

Various NGOs - NRDC, EWG, EPN, UCS, UFW, PETA

Other appropriate academic, regulated industry, and scientific organizations (e.g., agricultural extension related to pesticide choices/considerations)

Co-regulators - State, local, tribal, and territorial programs

Other appropriate academic, regulated industry, and scientific organizations

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Table 4: OCSPP Climate Adaptation Priority Action Items

Challenges/Barriers

The challenges are multifaceted and include maintaining the ability to properly develop content relative to climate change criteria and its impacts on programs. They
also include resource challenges associated with broad implementation of content.

OCSPP Climate Adaptation Priority Action Item C: Increase the number of risk assessments and risk management decisions that incorporate climate adaptation.

Co-Benefits

Scientific Integrity, Environmental Justice

Applicable Agency
Climate Adaptation
Plan Priorities

1 & 5

Lead Organizations

OPP, OPPT, OPS depending upon specific topic

Timeframe

Not initiated. Initiate establishing baselines for current approaches and evaluate workflow by FY'22. Initiate process updates FY 2023

Performance Metrics

Develop criteria for incorporating climate adaptation into risk assessment and risk management documents.

OPP FY 2023 Target

100%

OPP Metric Details

Baseline: Zero criteria for considering the impact of climate adaptation and the resulting effects in FY 2022.
Data Source: Report out from OPP

Misc.: Criteria could include science approach, risk management approach, and accompanying guidance.

OPPT FY 2023 Target

100%

OPPT Metric Details

Baseline: Zero criteria for considering the impact of climate adaptation and the resulting effects in FY 2022.
Data Source: Report out from OPPT

Misc.: Criteria could include science approach, risk management approach, and accompanying guidance.

Resource Requirements

Accomplishments

Activities are ongoing related to this sub-priority, but the climate change adaptation component is a novel effort.

Key Partners &
Stakeholders

ECOS https://www.ecos.org/

American Chemistry Council https://www.americanchemistrv.com/default.aspx

Green Chemistrv in Commerce Council (GC3) https://sreenchemistrvandcommerce.ors/

Association for the Advancement of Alternatives Assessment https://www.saferalternatives.ors/

American Chemical Society Green Chemistrv Institute https://www.acs.ors/content/acs/en/sreenchemistrv/about.html

Various NGOs - NRDC, EWG, EPN, UCS, UFW, PETA

Co-regulators - State, local, tribal, and territorial programs

Other appropriate academic, regulated industry, and scientific organizations

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Table 4: OCSPP Climate Adaptation Priority Action Items

Challenges/Barriers

The challenges are multifaceted and include maintaining the ability to properly identify and track changes in materials science, building codes, etc. based on climate
change criteria. They also include resource challenges associated with the surety of specific ties to climate change.

OCSPP Climate Adaptation Priority Action Item D: Use the most up-to-date and appropriate tools and data related to climate change in risk assessments including for vulnerable populations.

Co-Benefits

Scientific Integrity, Environmental Justice

Applicable Agency
Climate Adaptation
Plan Priorities

Lead Organizations

OPP, OPPT, OPS depending upon specific topic

Timeframe

Begin inventory in FY'22 and with general plans in place by FY 2023

Performance Metrics

Develop framework for systematically ensuring latest tools and data are included into risk assessments to account for climate adaptation.

OPP FY 2023 Target

100%

OPP Metric Details

Baseline: Zero systematic look at data and tools related to considering the impact of climate adaptation and the resulting effects in FY 2022.
Data Source: Report out from OPP

Misc.: Criteria could include science approach, risk management approach, and accompanying guidance.

OPPT FY 2023 Target

100%

OPPT Metric Details

Baseline: Zero systematic look at data and tools related to considering the impact of climate adaptation and the resulting effects in FY 2022.
Data Source: Report out from OPPT

Misc.: Criteria could include science approach, risk management approach, and accompanying guidance.

Resource Requirements

Resource needs will vary based on the nature of the issue, the availability of pertinent information, the vetting required of new information, and the integration of new
information into existing tools and/or processes.

Accomplishments

Activities are ongoing related to this sub-priority, but the climate change adaptation component is a novel effort.

Key Partners &
Stakeholders

USDA - for a variety of ag related issues

CDC - because of climate impacts on disease vectors

ECOS https://www.ecos.org/

Local mosquito control districts and state lead agencies (via program and regional contacts or AMCA https://www.mosquito.org/)

RISE https://www.pestfacts.org/

Crop Life America http://www.croplifeamerica.org/

American Chemistry Council https://www.americanchemistrv.com/default.aspx

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Green Chemistry in Commerce Council (GC3) https://sreenchemistrvanckommerce.org/

Various NGOs - NRDC, EWG, EPN, UCS, UFW, PETA

Co-regulators - State, local, tribal, and territorial programs

Other appropriate academic, regulated industry, and scientific organizations

Challenges/Barriers

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6.

Training Plan for Climate Knowledge

OCSPP will utilize appropriate and available materials to develop approaches which will
enhance staff and management awareness of the importance of climate adaptation and the
need to integrate the concept into its programs. The exact nature of the materials is formative
at this point and will depend on available materials and information as well as how these
materials and thinking related to climate change implications for OCSPP evolve over time.

OCSPP will use approaches such as webinars available for all staff and orientation materials for
new entering staff to ensure appropriate information is conveyed. OCSPP is committed to
conducting at least one webinar per fiscal year. The timing of the first webinar will be within
one year of adoption of this plan to allow for time to prepare curriculum materials and ensure
their quality.

7. Tribal and Environmental Justice Considerations

Certain individuals and communities - such as communities of color, children, the elderly, those
with lower income, those with limited access to information, tribal communities, and
indigenous people - can be especially vulnerable to the impacts of a changing climate. As
climate change exacerbates existing pollution problems and environmental stressors,
overburdened and underserved communities and individuals are particularly susceptible to
impacts.

EPA's FY2022-2026 Strategic Plan prioritizes consideration of climate change and
environmental justice in Goal 1: Tackle the Climate Crisis and Goal 7: Ensuring Safety of
Chemicals for People and the Environment. Key objectives deliver targeted assistance to
increase the resilience of tribes, states, territories, and communities to the impacts of climate
change (Goal 1, Objective 1.2 and 1.3) and seek to protect the health of families, communities
and ecosystems from the risks posed by chemicals and pesticides (Goal 7). OCSPP is a
contributor to these overall objectives through outreach activities to partners such as tribes
and states. Examples include interactions with the Tribal Pesticide Program Council (TPPC) and
via the Pesticide Regulatory Education Program (PREP).

Under EPA's Strategic Plan, OCSPP has significant responsibilities for ensuring the safety of
chemicals and pesticides by addressing unreasonable risks to human health and the
environment. OCSPP will work to complete High Priority Substance TSCA risk evaluations,
initiate TSCA management actions, consider the protections of federally threatened and
endangered species and support Agricultural Worker Protection Standard (WPS) pesticide
safety training for farmworkers.

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Integrating climate adaptation into OCSPP's programs will take place over several years. As a
first step, OCSPP outlined major climate change vulnerabilities (Table 2) related to program
responsibilities, including environmental justice perspectives. These vulnerabilities include
several topics critical to the health of communities such as managing the potential increase of
pest population and activities; potential detrimental effects on endangered species and
pollinator habitats; and how to evaluate and make decisions regarding the safety of new
chemicals or new uses of existing products to address public health threats.

Actions within this plan (Table 4) focus on elements that examine the intersect of OCSPP's
programs with environmental and social impacts that can be used to improve climate
adaptation and resilience and reduce impacts from climate change. For example, OCSPP uses
the risk management process to ensure that chemicals meet statutory standards for protecting
human health and the environment, and effectively assess, manage, and mitigate risk based on
the best available science and policy, including feedback from stakeholders on environmental
justice concerns. This plan seeks to further include climate adaptation perspectives, as
appropriate, into risk management processes and decisions. Identifying risk associated with
climate change and managing them to reduce their impacts is essential and will foster risk-
based climate change vulnerability analysis.

Managing the consequences of climate variability at a national level requires the agency to
understand complex sociocultural interactions that contribute to societal adaptative activities
and capacity building at the local, community levels. OCSPP will focus on enhancing community
resilience by utilizing existing community networks to design strategies that are inclusive of
local and indigenous knowledge as well as western science perspectives. Critical to achieving
results, EPA seeks to proactively engage with tribes, communities, and other stakeholders to
discuss and potentially address disproportionate impacts of climate change in a meaningful
manner.

When working with our tribal partners, OCSPP seeks to uphold tribal treaty rights as well as
focus on understanding and considering the integration of Indigenous Tribal Ecological
Knowledge, as appropriate and permitted by the law and under the guidance of tribal partners,
into agency environmental science, policy, and decision-making processes. EPA also
acknowledges that unique situations and relationships may exist that promote the agency to
consider information on sacred sites, cultural resources, and other traditional knowledge for
federally recognized tribes and indigenous peoples. OCSPP will use a tribal-driven approach
with these matters as well as review EPA policies (e.g., EPA Policy on Environmental Justice for
Working with Federally Recognized Tribes and Indigenous Peoples) and newly anticipated
federal guidance currently in development by the White House Council on Native American
Affairs.

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8. Science Needs

Science needs will be identified in a timely manner that is consistent with the current
availability of resources and organizational priorities. These will also be incorporated as
appropriate into research planning activities with ORD. Additionally, OCSPP may utilize its
statutory authorities under FIFRA and TSCA to require data and leverage equities through other
sources such as regional capabilities, assistance agreements, and IPM Centers. The science
needs identified based on the current Priority Action Items noted above to date are
summarized in Table 5 below. OCSPP will work with Agency and outside partners to address
these needs in a manner consistent with priorities and allowable per statute. These efforts will
include consideration of Citizen Science activities and products as appropriate.

Table 5: Climate Adaptation Science Needs For OCSPP

No.

Description

Comments

Ensure that the most current data and
information in risk assessment and risk
management

Develop/obtain/maintain information related to changing environmental factors
which could alter behaviors of pesticides and industrial chemicals in the environment,
(e.g., water flow information, changing climate zones, etc.)

Utilize current tools and methods in risk
assessment and risk management

Develop/obtain/maintain information related to changing environmental factors
which could alter behaviors of pesticides and industrial chemicals in the environment,
(e.g., stream dilution models, geospatial methods, volatilization prediction tools.)

Enhance tracking/integration for changing
pest complexes, invasive species, and
disease vectors

Develop/obtain/maintain data to illustrate how climate change could alter pest
habitats (expansions and range reductions) and host species which could impact
chemical needs. Also, develop and maintain surveillance and countermeasures for
invasive species and disease vector species.

Enhance tracking/integration of changing
agricultural production practices

Develop/obtain/maintain data to illustrate how climate change could alter chemical
use/needs associated with modifications of agricultural practice changes such as
modified tillage and cultivation practices which may require more weed control or
more chemical use due to a higher presence of invasive pests.

Enhance tracking/integration of changing
practices related to industrial and
structural pest control

Develop/obtain/maintain data to illustrate how climate change could alter chemical
use/needs associated with modifications of industrial/structural pest control practice
changes such as modified application methods relative to novel pests and the
measures needed to manage them.

Enhance tracking/integration of changing
fundamentals surrounding endangered
species and pollinators

Obtain/maintain data to illustrate how climate change could alter chemical
use/needs associated with endangered species and pollinators due to factors such as
modified competition for resources in novel habitats and lower foraging
opportunities for pollinators. Will work with appropriate partners such as USDA
related to this topic.

Identify tools, data, and methods for
predicting future trends related to climate
change.

Develop/obtain/maintain data and information related to the prediction of future
climate change impacts which could include topics ranging from meteorology,
infrastructure preparedness, agricultural production needs, pest complex, and crop
production information.

Enhance tools, data, and methods for
protecting populations exposed to
chemicals as part of their employment
including agricultural and industrial
settings

Develop/obtain/maintain data and information related to the protection of those
exposures due to their employment status. This could include any number of topics
from heat stress, adaptation of employer needs, protective equipment and clothing
designs/materials, training, compliance initiatives, and availability.

-------
Collect, analyze, assess, and use data, as
appropriate, to evaluate potential chemical
and pesticide exposures associated with
vulnerable populations, including tribes
and agricultural workers.

Collect new data to evaluate and assess potential risks.

Consider potential impacts that may result in changed risk calculations and mitigation
approaches, data analysis, training and education, technical assistance, and overall
program perspectives.

Analyze data and information to better understand and incorporate, as appropriate,
social and behavioral aspects of climate change into program perspectives.

Expand work with partners to identify and discuss indicators and surrogate data to
inform climate vulnerabilities.

9. Operational Resiliency

Operational resiliency ensures that OCSPP can maintain its activities and ongoing processes
regardless of potential ongoing deleterious conditions including those associated with climate
adaptation concerns. Managing such events is complex and can be thought of in phases
including immediate needs followed by concerns over ensuring the continuing operations of
OCSPP in a manner that protects both its staff and facilities.

To address immediate needs and concerns, OCSPP will rely on guidance from EPA's Office of
Mission Support (OMS). It will also implement the Occupant Emergency Plan which has been
developed based on guidance established by the General Services Administration (GSA).15

Regarding continuing operations after immediate needs are addressed, it is important to
consider how to ensure ongoing operations continue. Significant lessons have been learned as a
result of the Covid 19 pandemic and it is likely much of the same approaches would be utilized
in any future event that would require this approach. OCSPP may also use the more intensive
activation of the Continuity of Operations plan. COOP plans including the one utilized by OCSPP
contain elements described in the Federal Emergency Management Agency (FEMA) guidance.16
Implementation of these types of activities would be coordinated with OMS. These combined
activities would protect the OCSPP workforce and ensure the resilience of its facilities and
operations.

15 https://www,Ksa,Kov/resources~for/citizens~consumers/child~care~services/for~providers~and~boards/emerKencv~mariaKement &
https://www.dhs.gOv/fps-guidanc:e-occupant-emergenc:y-planning

16 https://www.fema.gov/pdf/about/org/ncp/coop_brochure.pdf

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10. Bipartisan Infrastructure Law

OCSPP will take steps to ensure the outcomes of infrastructure investments using Infrastructure
Investment and Jobs Act (IIJA, or Bipartisan Infrastructure Law [BIL]) funds are resilient to the
impacts of climate change. OCSPP will explore opportunities to integrate climate change
considerations into its financial assistance programs in order to expand support for projects
that increase climate resilience while delivering co-benefits for public health, the mitigation of
greenhouse gases, and the reduction of other pollution. OCSPP will also provide technical
assistance to recipients of BIL funds to help them make climate smart infrastructure
investments.

11. Adoption

This OCSPP Climate Adaptation Plan is approved by:

Digitally signed by Michal Freedhoff, PhD on 07/22/2022

Michal Freedhoff, PhD
Assistant Administrator

U.S. EPA, Office of Chemical Safety and Pollution Prevention
1200 Pennsylvania Avenue, NW
Washington D.C. 20004

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