- Risk assessments using real data confirm that the chronic risk for adults is the key driver of honey bee risk according to the EFSA Bee GD as stated in the original
impact analysis . In contrast the majority of fungicides and herbicides passed the Tier 1 RA for larvae  and even pass rates for insecticides were not even worse.
- A more selective risk assessment can be achieved by applying the standard EPPO 2010 approach based on the use of NOEDD endpoints and more realistic exposure
- The EFSA 2013 approach can be significantly improved by taking into account the type of endpoint (NOEDD or LDD50) and the dose-response relationship in order to
meet the proposed protection goal more accurately.
- Using HB endpoints for BB and SB screening and Tier 1 RA will lead to failed BB and SB chronic RA for almost all active substances and their products, as valid
laboratory methods will not be available in the next future.
- The industry is committed to pursue dialog with regulatory authorities and EFSA to share our experience and data to help develop a workable way forward.