Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?

Abstract Background The reliance on traditional acute fish toxicity testing in the environmental risk assessment (ERA) of plant protection products (PPPs) raises ethical and scientific concerns, particularly considering the EU’s commitment to the 3Rs principle (replacement, reduction, refinement) an...

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Main Authors: Elena Adams, Sarah Hartmann, Daniel Faber, Yvonne Wolf, Markus Ebeling, Eric Bruns
Format: Article
Language:English
Published: SpringerOpen 2025-07-01
Series:Environmental Sciences Europe
Subjects:
Online Access:https://doi.org/10.1186/s12302-025-01170-1
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author Elena Adams
Sarah Hartmann
Daniel Faber
Yvonne Wolf
Markus Ebeling
Eric Bruns
author_facet Elena Adams
Sarah Hartmann
Daniel Faber
Yvonne Wolf
Markus Ebeling
Eric Bruns
author_sort Elena Adams
collection DOAJ
description Abstract Background The reliance on traditional acute fish toxicity testing in the environmental risk assessment (ERA) of plant protection products (PPPs) raises ethical and scientific concerns, particularly considering the EU’s commitment to the 3Rs principle (replacement, reduction, refinement) and animal welfare legislation. This study assesses the contribution of acute fish toxicity tests to ERAs for 224 pesticidal active substances (a.s.) approved for use in PPPs in the EU. We analyzed regulatory acceptable concentrations (RACs) across various aquatic organisms, including fish, invertebrates, sediment-dwelling organisms, algae, and macrophytes using data from publicly available European Food Safety Authority (EFSA) conclusions. Results Our tiered assessment revealed that only 22 a.s. (approximately 9.8% of the total) were driven by acute fish toxicity in a first-tier assessment. The risk for 20 out of these 22 a.s. was covered considering higher tiers such as geomean RAC calculations, EFSA adaptations of the assessment factor and similar RACs within a factor of 3. For only 2 out of 224 a.s. (0.89%), acute fish toxicity remained the driver in ERA. However, for one substance no chronic fish toxicity test was available. Furthermore, both substances degrade rapidly in water under environmental conditions. As the acute fish toxicity tests were performed under constant exposure, the real acute hazard to fish is substantially lower than indicated by the available data. Conclusions The findings advocate for a paradigm shift in regulatory ecotoxicology towards the integration of new approach methodologies, thereby reducing the reliance on vertebrate testing while maintaining environmental protection with regard to acute fish toxicity. This research underscores the potential for regulatory frameworks to minimize animal testing without compromising safety and calls for further investigation into alternative testing methods for specific modes of action.
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spelling doaj-art-770491cf863b47c5b2bd77cd96e219892025-08-20T03:45:52ZengSpringerOpenEnvironmental Sciences Europe2190-47152025-07-0137111310.1186/s12302-025-01170-1Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?Elena Adams0Sarah Hartmann1Daniel Faber2Yvonne Wolf3Markus Ebeling4Eric Bruns5Bayer AG, R&D, Crop Science Division, Environmental SafetyBayer AG, R&D, Crop Science Division, Environmental SafetyBayer AG, R&D, Crop Science Division, Environmental SafetyBayer AG, R&D, Crop Science Division, Environmental SafetyBayer AG, R&D, Crop Science Division, Environmental SafetyBayer AG, R&D, Crop Science Division, Environmental SafetyAbstract Background The reliance on traditional acute fish toxicity testing in the environmental risk assessment (ERA) of plant protection products (PPPs) raises ethical and scientific concerns, particularly considering the EU’s commitment to the 3Rs principle (replacement, reduction, refinement) and animal welfare legislation. This study assesses the contribution of acute fish toxicity tests to ERAs for 224 pesticidal active substances (a.s.) approved for use in PPPs in the EU. We analyzed regulatory acceptable concentrations (RACs) across various aquatic organisms, including fish, invertebrates, sediment-dwelling organisms, algae, and macrophytes using data from publicly available European Food Safety Authority (EFSA) conclusions. Results Our tiered assessment revealed that only 22 a.s. (approximately 9.8% of the total) were driven by acute fish toxicity in a first-tier assessment. The risk for 20 out of these 22 a.s. was covered considering higher tiers such as geomean RAC calculations, EFSA adaptations of the assessment factor and similar RACs within a factor of 3. For only 2 out of 224 a.s. (0.89%), acute fish toxicity remained the driver in ERA. However, for one substance no chronic fish toxicity test was available. Furthermore, both substances degrade rapidly in water under environmental conditions. As the acute fish toxicity tests were performed under constant exposure, the real acute hazard to fish is substantially lower than indicated by the available data. Conclusions The findings advocate for a paradigm shift in regulatory ecotoxicology towards the integration of new approach methodologies, thereby reducing the reliance on vertebrate testing while maintaining environmental protection with regard to acute fish toxicity. This research underscores the potential for regulatory frameworks to minimize animal testing without compromising safety and calls for further investigation into alternative testing methods for specific modes of action.https://doi.org/10.1186/s12302-025-01170-1EcotoxicologyEnvironmental risk assessmentAnimal welfarePesticidesPlant protection products
spellingShingle Elena Adams
Sarah Hartmann
Daniel Faber
Yvonne Wolf
Markus Ebeling
Eric Bruns
Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
Environmental Sciences Europe
Ecotoxicology
Environmental risk assessment
Animal welfare
Pesticides
Plant protection products
title Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
title_full Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
title_fullStr Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
title_full_unstemmed Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
title_short Acute fish toxicity testing in pesticide risk assessment: still a necessary requirement for the future?
title_sort acute fish toxicity testing in pesticide risk assessment still a necessary requirement for the future
topic Ecotoxicology
Environmental risk assessment
Animal welfare
Pesticides
Plant protection products
url https://doi.org/10.1186/s12302-025-01170-1
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