Environmental risk assessment in agro-ecosystems: Revisiting the concept of receiving environment after the EFSA guidance document

The environmental risk assessment (ERA) for genetically modified plants (GMPs) is a prerequisite for commercial approval of these new varieties according to regulatory systems worldwide. The first country to regulate GM crops was the USA and the issue of possible environmental impacts was based on the principles used in risk assessment of pesticides. Two main pillars of this approach are the use of surrogate species for testing effects on non-target organisms using a tiered assessment with clear thresholds to indicate the need to move between tiers. The latest EFSA guidance document on ERA of Genetically Modified Organisms considers specifically the receiving environment in preparation of ERA for commercial cultivation of GMPs. According to existing guidelines in the EU, the receiving environment is defined by three mutually interacting components: the characteristics of the environmental stressor (i.e. the GM plant), the bio-geographical regions where the commercial release of the crop is expected and the agricultural systems therein. Difference in agronomic and ecological conditions (e.g. use of different varieties, vegetation of adjacent areas, non-target species assemblages, sensitivity of local species to the stressors) suggests that explicit considerations of the receiving environments are necessary. Results from field experiments indicate that differences in cultivation practices, e.g. the herbicide regime used on herbicide-tolerant GM crops, may induce direct and indirect effects on wild plant distribution and abundance, with consequent repercussions on food webs based on these plants. Moreover, ecological literature indicates that the concept of surrogate species has clear limitations if applied broadly to any ERA. Starting from case studies regarding GMPs, this paper discusses some ecological and agronomic characteristics of agro-ecosystems, which have implications in the elaboration of both hazard and exposure analyses during ERA. The species selection approach indicated in the EFSA Guidance Document and the consideration of the area(s) of the expected release of the new variety may provide the basis to an ecologically sound ERA for a range of environmental stressors. The quality of the data that become available for risk managers with this approach may support a more transparent and dependable ERA and risk management for GMPs as well as for other potential environmental stressors in agro-ecosystems.