Abstract

Read-across approaches are considered key in moving away from in vivo animal testing towards addressing data-gaps using new approach methods (NAMs). Ample successful examples are still required to substantiate this strategy. Here we present and discuss the learnings from two OECD IATA endorsed read-across case studies. They involve two classes of pesticides – rotenoids and strobilurins – each having a defined mode-of-action that is assessed for its neurological hazard by means of an AOP-based testing strategy coupled to toxicokinetic simulations of human tissue concentrations. The endpoint in question is potential mitochondrial respiratory chain mediated neurotoxicity, specifically through inhibition of complex I or III. An AOP linking inhibition of mitochondrial respiratory chain complex I to the degeneration of dopaminergic neurons formed the basis for both cases but was deployed in two different regulatory contexts. The two cases also exemplify several different read-across concepts: analogue versus category approach, consolidated versus putative AOP, positive versus negative prediction (i.e., neurotoxicity versus low potential for neurotoxicity), and structural versus biological similarity. We applied a range of NAMs to explore the toxicodynamic properties of the compounds, e.g., in silico docking as well as in vitro assays and readouts – including transcriptomics – in various cell systems, all anchored to the relevant AOPs. Interestingly, although some of the data addressing certain elements of the read-across were associated with high uncertainty, their impact on the overall read-across conclusion remained limited. Coupled to the elaborate regulatory review that the two cases underwent, we propose some generic learnings of AOP-based testing strategies supporting read-across.

Highlights

  • Plant protection products (PPPs), often referred to as pesticides, are used to protect crops against pests, diseases, or competing plants with the aim of optimising food production in conventional or organic farming

  • While the evaluation has found a number of weaknesses, some of which are divisive among different stakeholders, stakeholders from across the spectrum agree that the current legislation sets an adequate framework of pre-market approval of active substances and authorisation of plant protection products and are not calling for fundamental changes of the PPP Regulation, while views were more divergent as regards the MRL Regulation

  • The number of active substances decreased already by more than 50 % under Directive 91/414/EEC, the predecessor to the PPP Regulation, which led to the withdrawal of the market of many substances that would not have met the requirements of the Directive

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Summary

INTRODUCTION

Plant protection products (PPPs), often referred to as pesticides, are used to protect crops against pests, diseases, or competing plants with the aim of optimising food production in conventional or organic farming. Implementation of the Regulations is the joint responsibility of the Member States and the Commission, as Member States have key roles for the scientific assessment of active substances and maximum residue levels, where they cooperate closely with the European Food Safety Authority (EFSA). While the evaluation has found a number of weaknesses, some of which are divisive among different stakeholders, stakeholders from across the spectrum agree that the current legislation sets an adequate framework of pre-market approval of active substances and authorisation of plant protection products and are not calling for fundamental changes of the PPP Regulation, while views were more divergent as regards the MRL Regulation. The report identifies sixteen areas where implementation can be improved in the short and medium term

STRENGTHENED PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Better implementation – addressing delays and increasing transparency
COMPETITIVENESS AND THE INTERNAL MARKET
EMERGENCY AUTHORISATIONS
TESTING ON VERTEBRATE ANIMALS
SUSTAINABILITY OF PLANT PROTECTION AND LOW-RISK PRODUCTS
ENFORCEMENT
FASTER RESPONSES IN THE CONTEXT OF THE MRL REGULATION TO EMERGING
INTERNATIONAL TRADE
INTERNAL COHERENCE AND CONSISTENCY WITH OTHER EU LEGISLATION
CONCLUSION
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