Improving pesticide regulation by use of impact analyses: A case study for bees

When changes to regulatory guidance for risk assessment are proposed it is necessary to undertake an impact analysis to assess whether they bring the desired improvement to a risk assessment and reliability of the outcomes to inform decision making. In particular impact analyses should estimate the chances of getting both false negative (concluding low risk where more research is needed) and false positive outcomes (concluding high risks where the product is of low risk). Such analyses are also used to inform on future product development costs and workload for regulatory authorities. In this paper, we present the findings from an impact analysis conducted on the proposed EFSA bee guidance document (2013) and discuss whether the proposed guidance would provide for a cost effective and tiered approach toward the protection of bees due to the potential risks posed by the use of plant protection products. Following on from this a second impact assessment is presented based on new data generated by ECPA member companies regarding the assessment of chronic risk to bees. Critical areas are discussed and suggestions for the improvement of assess the risk assessment for plant protection products (PPP) to bees are presented.