John Wiley & Sons, Ltd.

An evaluation of fish early life stage tests for predicting reproductive and longer term toxicity from plant protection product active substances

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The chronic toxicity of chemicals to fish is routinely assessed by using fish early life stage (ELS) test results. Fish full lifecycle (FLC) tests are generally only required when toxicity, bioaccumulation, and persistence triggers are met, or when there is a suspicion of potential endocrine disrupting properties. This regulatory approach is based on a relationship between the results of fish ELS and FLC studies first established over 35 years ago. Recently this relationship has been challenged by some regulatory authorities and it has been recommended that more substances should undergo full fish lifecycle testing. A project proposal has also been submitted to the Organisation for Economic Cooperation and Development (OECD) to develop a fish partial lifecycle (PLC) test including a reproductive assessment. Both FLC and PLC tests are animal‐ and resource‐intensive, technically challenging, and should therefore only be undertaken if there is clear evidence that they are necessary for coming to a regulatory decision. In this paper we report on an analysis of a database of paired fish ELS and FLC endpoints for plant protection product active substances from EU Draft Assessment Reports and the USEPA Office of Pesticide Programs Pesticide Ecotoxicity Database. Analysis of this database shows a clear relationship between ELS and FLC responses, with similar median sensitivity across substances when No Observed Effect Concentrations (NOECs) are compared. There was also no indication that classification of a substance as a mammalian reproductive toxicant leads to more sensitive effects in fish FLC tests than in ELS tests. Indeed, the response of the ELS tests was generally more sensitive than the most sensitive reproduction NOEC from a FLC test. This analysis indicates that current testing strategies and guidelines are fit for purpose and that there is no need for fish full or partial lifecycle tests for most plant protection product active substances. Environ Toxicol Chem © 2014 SETAC

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