Assessing the need for chronic fish studies on formulated pesticides

The ecotoxicity testing of pesticide active ingredients and formulated plant protection products (PPPs) prior to their commercial use is required by authorities around the world, to fulfil the data requirements for regulations such as the European and US PPP regulations (EC Regulation 1107/2009 and US Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)). However it has been shown that the toxicity of a formulated product can be reliably predicted based on the toxicity of the active substances and their respective content within the formulated product. Furthermore, chronic exposure to the formulated product rarely occurs in the environment.

In 2009, supported by a Working Group of experts from industry and academia, we carried out a survey across European pesticide companies on the scientific and regulatory drivers for chronic toxicity testing of formulated PPPs in fish. This revealed that current practice in deciding on the need for chronic fish toxicity testing of formulated PPPs varies substantially between companies. Analysis of the responses led to the conclusion that chronic formulation testing is rarely if ever scientifically justified. As a result, we published a cross-company consensus paper which recommended that scientific justification must be provided for conducting the chronic fish toxicity test with formulated PPPs.

Creton S, Douglas M, Wheeler JR, Hutchinson TH (2010). Challenging the requirement for chronic fish toxicity studies on formulated plant protection products. Toxicol Lett. 199(2):111-4. doi: 10.1016/j.toxlet.2010.08.019

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