Reflections on bird and mammal risk assessment for plant protection products in the European Union: Past, present, and future

Predicted Dermal and Dietary Exposure of Bats to Pesticides

Wild birds and mammals that feed in agricultural habitats are potentially exposed to pesticides through various routes. The European Food Safety Authority (EFSA) recently published a statement which concluded that the current EFSA risk assessment scheme for birds and mammals does not adequately cover bats (Chiroptera). In the present study, we take a more detailed look at the EFSA statement and assumptions made regarding direct (dermal) and indirect (dietary) exposure of bats to pesticides in terms of their realism and the potential implications for risk assessment outcomes. Regarding dietary exposure, errors in the residue per unit dose (RUD) values for flying insects (bat food), proposed in the EFSA bat statement, were identified and corrected. Lower RUD values based on a much broader data base are proposed. Using these more realistic RUD values, together with current assumptions regarding toxicity and exposure, the acute and long-term risk to bats appears to be within the range of those calculated for birds and ground-dwelling mammals under the current risk assessment scheme. Depending on the assumptions made, some uncertainties may remain and should be investigated further. According to the EFSA bat statement, dermal exposure of bats is the most significant route of exposure, resulting in the highest predicted daily doses. We demonstrated that the dermal exposure models in the EFSA bat statement predict much higher residues for bats than those measured for other flying organisms that have larger surface area to volume ratios, and thus would be expected to have the reverse relationship. We also illustrated that the amounts of spray liquid required to achieve the predicted dermal exposures of bats are implausibly high, with bats carrying an amount of spray liquid that exceeds their body weight many fold. It is recommended that a bat risk assessment framework should be based on realistic, sound science, allowing resources to be focused on those scenarios that are not already covered by the existing bird and mammal framework. Therefore, a quantitative risk assessment scheme should not be implemented until the many scientific uncertainties within the EFSA bat statement are addressed. Environ Toxicol Chem 2022;41:2595-2602. © 2022 Cambridge Environmental Assessments. Environmental Toxicology and Chemistry published by Wiley Periodicals LLC on behalf of SETAC.

Assessing the Risks to Bats from Plant Protection Products: A Review of the Recent European Food Safety Authority Statement Regarding Toxicity and Exposure Routes

Wild birds and mammals that feed in agricultural habitats are potentially exposed to pesticides through various routes. Until recently, it has been implicitly assumed that the existing European Union risk assessment scheme for birds and mammals also covered bats (Chiroptera). However, recent publications raised concerns and, in 2019, a scientific statement was published by the European Food Safety Authority (EFSA) that concluded that bats were not adequately covered by the current risk assessment scheme. We review the evidence presented and assumptions made in the EFSA bat statement relating to toxicity, bioaccumulation, and exposure pathways (oral, dermal, and inhalation), in terms of their relevance for bats potentially foraging in agricultural areas in the European Union; we highlight where uncertainties remain and how these could be addressed. Based on our review, it is clear that there is still much uncertainty with regard to the appropriateness of the assumptions made in the EFSA bat statement. Significantly more information needs to be gathered to answer fundamental questions regarding bat behavior in agricultural landscapes, together with the relative sensitivity of bats to pesticide exposure. Given the current critical information gaps, it is recommended that quantitative risk assessments for bats not be performed for pesticides until more robust, reliable, and relevant data are available. The risk to bats can then be compared with that for birds and ground-dwelling mammals, to determine the protectiveness of the existing scheme and thus whether a bat scenario is indeed required and under what circumstances. Environ Toxicol Chem 2021;40:2978-2989. © 2021 Cambridge Environmental Assessments, part of RSK ADAS Ltd. Environmental Toxicology and Chemistry published by Wiley Periodicals LLC on behalf of SETAC.

Residue Levels of Pesticides on Fruits for Use in Wildlife Risk Assessments

The guidance document on risk assessment for birds and mammals (GD) provides generic residue values of pesticides on potential diet items for use in wildlife risk assessments. For most diet items, these values are based on a large number of residue studies. However, the default residues per unit dose (RUD; standardized for application of 1 kg substance per hectare) values for fruits were taken from a few literature trials of unclear relevance for regulatory purposes. These trials were conducted according to neither current European Union (EU) agricultural practice nor to recommendations given in the GD about how to conduct wildlife-relevant residue studies. Therefore, field study data on fruit residue levels from applications of pesticides in fruiting crops were compiled and evaluated. Corresponding studies had been conducted during the last 26 y in the EU. In the final data set, 291 studies provided 1002 residue values in different fruits, including grapes, berries (currants, raspberries, gooseberries), fruits from orchards (apple, peach, pear, lemon, mandarin, orange, apricot, cherry, plum), gourds (pumpkins, cucumbers, squash, melons), and strawberries. This data set provides a basis for revising registration-relevant RUD values for fruits as potential diet items for birds and mammals in environmental wildlife risk assessments. The objective of this study was to estimate the resulting residue levels in different fruits determined under field conditions following the application of pesticides across their growing areas within the EU in diverse climatic areas that can be used directly in wildlife risk assessments. The large data set of usually about more than 100 residue values per "fruit group," all evaluated at EU member state level, revealed significantly lower RUDs compared to the current default RUDs presented in the GD. These new RUD values for fruits should be considered for use as default values in future bird and mammal risk assessments and in respective guidance documents. Integr Environ Assess Manag 2021;17:552-561. © 2020 The Authors. Integrated Environmental Assessment and Management published by Wiley Periodicals LLC on behalf of Society of Environmental Toxicology   Chemistry (SETAC).

Common Vole as a Focal Small Mammal Species in Orchards of the Northern Zone

In 2018–2020, we performed a country-wide study of small mammals in commercial orchards and berry plantations with the aim of determining whether the common vole (Microtus arvalis) is a more suitable focal species than the field vole (M. agrestis) in the risk assessment of plant protection products in Lithuania (country of the Northern Zone). Common vole was present in 75% of orchards and in 80% of control habitats, accounting for 30% of all trapped individuals. The proportion of this species was stable between years and seasons. The pattern was in agreement with the intermediate disturbance hypothesis, i.e., highest in medium-aged crops, while lowest in habitats with high intensities of agricultural practices. The average relative abundance of common vole in autumn, 2.65 ± 0.52 individuals per 100 trap days, was three times higher than that in summer, with no differences recorded between crops and control habitats. Field vole was present in 30% of locations, only accounting for 2.1% of all trapped individuals. In central and eastern European countries, common vole is more widespread and abundant than field vole. In Lithuania, common vole dominates in orchards and natural habitats and is, therefore, the most relevant small mammal species for higher tier risk assessment.