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Proposal for a protective and workable regulatory European bee risk assessment scheme based on the EFSA bee guidance and other new data and available approaches


The crop protection industry recognizes the need to review the bee pollinator risk
assessment based on scientific progress. However, the EFSA Bee Guidance Document
issued in 2013 is not a realistically feasible way forward. It is based on extremely
conservative assumptions, its study requirements lack clarity and are not workable and
guidelines for a number of studies are unavailable or not validated. Industry therefore
believes that a revision of the assessment scheme for use by regulatory authorities is
needed. Building on an analysis of the proposed developments in the EFSA Bee
Guidance Document, we suggest a proactive and practical approach.
This new approach is summarized in the following overview. It provides a comparable
level of protection to the EFSA approach and is based on the current scientific state of
the art for bee pollinator risk assessment. Key features of this approach are the focus
on honey bees as a representative species, the definition of core data packages,
concentration on main exposure routes and the proposal of more realistic assumptions
for the risk assessment process.
Industry believes that this Practical Approach is both a realistic and protective way
forward for bee risk assessment and would welcome the opportunity to engage in a
technical discussion with Member States experts and EFSA on this topic in order to
help establish a workable and protective solution as soon as possible.