Weeds in the treated field - a realistic scenario for pollinator risk assessment?

In July 2013 the European Food Safety Authority (EFSA) released its final guidance on the risk assessment of plant protection products (PPPs) to bees1. One objective of the guidance was to produce a simple and cost effective first tier risk assessment scheme to ensure that the appropriate level of protection is achieved. However, recent impact analyses have indicated that the first tier of this risk assessment does not act effectively as a screen for compounds of low risk to bees. For example substances showing no toxicity to bees often fail the tier 1 risk assessment based on a worst-case exposure to flowering weeds inside the treated field. If realistic farming practices (e.g. tillage and herbicide applications) are considered, weeds are not usually prevalent in arable fields. It is therefore suggested that the scenarios in the guidance could be considered overly conservative and in some instances unrealistic. The EFSA guidance states that if <10% of the area of use is flowering weeds then the exposure route is not relevant in the 90th %ile case, and thus does not need to be considered. However, despite this, the option to generate data or refine assessments based on available data is questioned as no guidance for the assessment of the abundance of weeds is available. As part of an industry-led initiative we present and discuss the use of empirical evidence (i.e. occurrence and growth stage of weeds in control plots from herbicide efficacy field trials conducted for regulatory submission) to illustrate that the scenarios in the guidance document could be modified using currently available data to create a more effective tier 1 risk assessment and still ensure that the appropriate level of protection is achieved. We have demonstrated here that less than 2% of all weeds recorded in arable crop trials (represented here by wheat, oilseed rape, sugar beet, sunflower, potatoes, maize, peas and beans) are at a flowering growth stage; therefore in arable crops the flowering weeds scenario is not applicable for the 90th %ile exposure. For permanent crop trials (represented here by orchards and vines) 37% of weeds were recorded at a flowering growth stage. When the attractiveness and density data are considered, the percentage of attractive, flowering weeds which cover >10% of the ground area is only 12.3%, indicating that for permanent crops further investigation may be required as to whether this scenario is relevant.