Environmental Risk Assessment of Pesticides: What Do Consultants Think?
The consultant voice should be heard loud and clear. We are the group that listen to lots of different companies and also listen to lots of different regulators. We include some of the most thoughtful, pragmatic, realistic and scientific people working in pesticide risk ssessment. In
the summer of 2016, the author was asked by the European Food Safety Authority (EFSA) if he could talk on what consultants think of about the methods for environmental risk assessment of pesticides. They were planning a conference1 to celebrate the 25 years since the introduction of Directive
91/414 and to look forward to the next 25 years. The author could not, on his own, hope to be a representative voice, but he figured that he could ask around and see what thoughtful, pragmatic, realistic and scientific responses he could elicit from his 'community'. The population of consultants
in pesticide risk assessment is not huge. The author does not know exactly how many consultancies there are working in this area in Europe: he would guess 100 or so, ranging from individual people working from home to multinational corporations with large regulatory teams. He made no attempt
to be systematic in approaching people to respond to the survey: he simply approached people where he already had some connection. Here are the statistics: 31 consultants invited to participate; 26 responses covering 25 consultancies. So, this was not a huge survey, but with a response rate
of 84%, we can be confident that the results reflect widely-held opinions. Was there any bias in who actually responded? The author tried to measure this by asking how long people had been working in this area. The results showed a good spread of recent arrivals and long-timers (some from
before 1991, when the regulations changed). There are some who started consulting in the mid 1990s right through to people who started in the last year or two. Not everybody knows about everything. We cannot really expect a bee expert to be authoritative on surface water fate. Did the author
get people with a range of experience? He thinks he did. The respondents offer services across a good spread of domains from ground water to non-target plants. The responses are split roughly 50:50 between people answering for themselves and people answering on behalf of their organisation.
The survey covered: The nature of the assessments (e.g. conservatism, realism). The process of conducting the assessments Sources of data Interacting with the system. Parts of the survey were numerical and parts gave the opportunity for comments. Many of the participants included very insightful
comments and the author has included here his pick of the best.
Keywords: CONSULTANTS; ENVIRONMENTAL RISK ASSESSMENT; METHODS; PESTICIDES; PROGRESS
Document Type: Research Article
Publication date: 01 June 2017
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