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Current methods would allow reasonable predictions of long-term effects of pesticide application if three changes were instituted. First, more population-based laboratory studies should be applied in predictive pesticide risk assessment. Second, ERA should include as much effort on collating and integrating ecological knowledge into the assessment in Tier 1 as is currently expended on gathering chemical and toxicological information on exposure and effects. Production of a formal conceptual ecological risk assessment model for each product or active substance for which authorization is sought would provide an appropriate framework for integrating and applying such knowledge. Third, in acknowledgment of the uncertainties in the predictive risk assessment process, more postauthorization monitoring should be done.

The application of Occam’s razor to pesticide risk assessment makes good sense, as it does in any other field of science. However, we must take care that simplicity in risk assessment process does not lead to oversimplification:

SAs, a structurally related group of antibiotics containing a similar 4-aminobenzene sulfonamide backbone, are used in agriculture, aquaculture, animal husbandry, and also as human medicines. Competing with -aminobenzoic acid in the enzymatic synthesis of dihydrofolic acid, SAs inhibit the growth and reproduction of bacteria. Once released to the environment, SAs distribute themselves among different environmental compartments, along with their degradation products, and are transported to surface water and groundwater. The physicochemical properties, the dosage applied and the nature of the environmental components with which they interact, govern the whole process. SAs, as a class, are less sorptive, impersistent, and leachable. They cannot be characterized as readily biodegradable. Their adsorption to soil increases with the aromaticity and electronegativity of functional groups attached to the sulfonyl phenyl amine core. Preferential flow in clay soils has been identified as a mechanism responsible for surface water contamination by SAs.

Faced with the need to evaluate under what conditions chemicals can be used with “reasonable certainty of no harm” to workers and consumers, industry and government agencies have embraced quantitative risk analysis as a science-based approach for product development, regulatory evaluations, and associated risk management decision making. Beginning in the 1990s, a variety of industry-sponsored task forces have been formed to develop exposure-related data to support safety evaluations for pesticide chemicals used in agricultural, industrial, institutional, residential, and other settings. Human exposure assessment and the underlying data (e.g., personal exposure and biological monitoring measurements, media-specific residue measurements, product use, and time—activity information) represent a critical component of the risk assessment process and a rapidly advancing science. While task forces have been created to develop databases for supporting the continued safe use of products, the development of these databases has served to advance general understanding of the basic principles underlying exposure assessment methodology and thereby provide the basis for improved science-based risk management by both industry and government. Given that developing chemical-specific data for every product use pattern and associated worker or consumer exposure scenario (e.g., professional mixer, loader and applicator activities associated with the use of a low-pressure sprayer, consumer residential lawn application via a ready-to-use hose-end sprayer product) is prohibitively expensive and time consuming, alternative approaches have been developed based upon meta-analyses and generalizations derived from databases of exposure monitoring studies for multiple chemicals, sorted by significant exposure covariates such as formulation type, method of application, amount of active ingredient applied, site of application, protective equipment and clothing, and task or activity. These generalizations can be used for predictive exposure analyses and have clearly demonstrated the value of “generic databases.” Although data in these databases and associated generalizations are subject to interpretation, e.g., during the regulatory decision-making processes, and may be used in conjunction with additional considerations or assessment methods that result in conservative biases, the role of generic databases for risk management decision making, and advancing the science of applied exposure analysis continues to be realized.

SAs, a structurally related group of antibiotics containing a similar 4-aminobenzene sulfonamide backbone, are used in agriculture, aquaculture, animal husbandry, and also as human medicines. Competing with -aminobenzoic acid in the enzymatic synthesis of dihydrofolic acid, SAs inhibit the growth and reproduction of bacteria. Once released to the environment, SAs distribute themselves among different environmental compartments, along with their degradation products, and are transported to surface water and groundwater. The physicochemical properties, the dosage applied and the nature of the environmental components with which they interact, govern the whole process. SAs, as a class, are less sorptive, impersistent, and leachable. They cannot be characterized as readily biodegradable. Their adsorption to soil increases with the aromaticity and electronegativity of functional groups attached to the sulfonyl phenyl amine core. Preferential flow in clay soils has been identified as a mechanism responsible for surface water contamination by SAs.