Wrapping it up: environmental risk assessment of pesticides, the consultants' view
We are coming to the end of our journey. We have discussed a lot of issues about the consultants' view of the changes in environmental risk assessment of pesticides. These issues were first presented at the EFSA meeting in November 2016 alongside the views of many other stakeholders. My presentation was different from the others because I didn't present my own views: I presented a spectrum of views from across the consulting industry.
I am indebted to the consultants who took part in this survey. There is much to discuss. Picking out the key themes is always tricky but here is my hotlist of important points. Lots of people included very articulate comments and I have included here my pick of the best.
I conducted a survey of 25 consultancies. That doesn't sound so many but it represented every area of environmental risk assessment and a response rate of 84%. So this survey makes a strong claim to be representative.
•Environmental risk assessment has become more conservative in both exposure and effects assessment.
"EFSA bird and mammal guidance significantly more conservative than previous assessments with the majority of assessments needing higher tier work."
•We are more realistic in some areas, less realistic in others.
"Now that other species are included in the suite of testing. the assessment is probably more realistic."
"Mechanistic exposure calculations using conservative assumptions significantly overestimate exposure leading to an overestimated risk."
•We are more dependent on expert knowledge, but expertise is in short supply.
"Numerical criteria are important for streamlined low-tier assessment, but it should be possible (at least in principle) to override them with well-reasoned arguments."
•Our procedures favour environmental protection over agricultural production more than they used to, but it is not clear if we have gone too far or not far enough.
"It's good that we are taking more care of environmental protection. This is the spirit in which the guidance documents are written. It's bad that the amount of detail and effort might not be resulting in a higher quality of decision-making."
•Guidance documents and assessment reports provide the greatest share of the information that we use. Discussions with regulators does not contribute a lot.
"Rarely any official does give a clear and 'final' answer; maybe the process is too complicated for everybody involved. "
•Guidance is improving: documents have become more comprehensive, more consistent but suffer from being too conservative at lower tiers, too complex and too restrictive at higher tiers
"When conducting exposure modelling, no matter how much you try to follow guidance and previous decisions by regulators, regulators will disagree with some aspect and ask for it to be re-done."
•It has become easier to understand data access but harder to challenge a decision.
"The availability of lists of studies has improved. The rules for data protection have been clarified."
"Challenging decisions is difficult - particularly with EFSA."
Summary of the summary
The population of consultants in pesticide risk assessment is characterised by thoughtfulness, care and inquisitiveness. We are committed to doing the right job in the right way. Overall we are very favourable towards anything that leads to improvements in environmental protection. However, we are suspicious of complexity when there is no obvious link to reality. We are grateful for the strides that have been made to improving the system, but regulators can be sure that any new approach will be scrutinised.
Regulators can expect criticism whenever we feel that they are adding burdens to the system without benefits to the environment.
That is my tenth and final post on this theme. I hope you enjoyed it. If you like the articles, please 'Like' them! Add your feedback to the box below. And don't forget to share your favourite articles with your network.
Best wishes,
James
I am indebted to the consultants who took part in this survey. There is much to discuss. Picking out the key themes is always tricky but here is my hotlist of important points. Lots of people included very articulate comments and I have included here my pick of the best.
I conducted a survey of 25 consultancies. That doesn't sound so many but it represented every area of environmental risk assessment and a response rate of 84%. So this survey makes a strong claim to be representative.
•Environmental risk assessment has become more conservative in both exposure and effects assessment.
"EFSA bird and mammal guidance significantly more conservative than previous assessments with the majority of assessments needing higher tier work."
•We are more realistic in some areas, less realistic in others.
"Now that other species are included in the suite of testing. the assessment is probably more realistic."
"Mechanistic exposure calculations using conservative assumptions significantly overestimate exposure leading to an overestimated risk."
•We are more dependent on expert knowledge, but expertise is in short supply.
"Numerical criteria are important for streamlined low-tier assessment, but it should be possible (at least in principle) to override them with well-reasoned arguments."
•Our procedures favour environmental protection over agricultural production more than they used to, but it is not clear if we have gone too far or not far enough.
"It's good that we are taking more care of environmental protection. This is the spirit in which the guidance documents are written. It's bad that the amount of detail and effort might not be resulting in a higher quality of decision-making."
•Guidance documents and assessment reports provide the greatest share of the information that we use. Discussions with regulators does not contribute a lot.
"Rarely any official does give a clear and 'final' answer; maybe the process is too complicated for everybody involved. "
•Guidance is improving: documents have become more comprehensive, more consistent but suffer from being too conservative at lower tiers, too complex and too restrictive at higher tiers
"When conducting exposure modelling, no matter how much you try to follow guidance and previous decisions by regulators, regulators will disagree with some aspect and ask for it to be re-done."
•It has become easier to understand data access but harder to challenge a decision.
"The availability of lists of studies has improved. The rules for data protection have been clarified."
"Challenging decisions is difficult - particularly with EFSA."
Summary of the summary
The population of consultants in pesticide risk assessment is characterised by thoughtfulness, care and inquisitiveness. We are committed to doing the right job in the right way. Overall we are very favourable towards anything that leads to improvements in environmental protection. However, we are suspicious of complexity when there is no obvious link to reality. We are grateful for the strides that have been made to improving the system, but regulators can be sure that any new approach will be scrutinised.
Regulators can expect criticism whenever we feel that they are adding burdens to the system without benefits to the environment.
That is my tenth and final post on this theme. I hope you enjoyed it. If you like the articles, please 'Like' them! Add your feedback to the box below. And don't forget to share your favourite articles with your network.
Best wishes,
James
