LAUSR

Wild birds and mammals that feed in agricultural habitats are potentially exposed to pesticides through various routes. The European Food Safety Authority (EFSA) recently published a statement which concluded that the current EFSA risk assessment scheme for birds and mammals does not adequately cover bats (Chiroptera). In the present study, we take a more detailed look at the EFSA statement and assumptions made regarding direct (dermal) and indirect (dietary) exposure of bats to pesticides in terms of their realism and the potential implications for risk assessment outcomes. Regarding dietary exposure, errors in the residue per unit dose (RUD) values for flying insects (bat food), proposed in the EFSA bat statement, were identified and corrected. Lower RUD values based on a much broader data base are proposed. Using these more realistic RUD values, together with current assumptions regarding toxicity and exposure, the acute and long‐term risk to bats appears to be within the range of those calculated for birds and ground‐dwelling mammals under the current risk assessment scheme. Depending on the assumptions made, some uncertainties may remain and should be investigated further. According to the EFSA bat statement, dermal exposure of bats is the most significant route of exposure, resulting in the highest predicted daily doses. We demonstrated that the dermal exposure models in the EFSA bat statement predict much higher residues for bats than those measured for other flying organisms that have larger surface area to volume ratios, and thus would be expected to have the reverse relationship. We also illustrated that the amounts of spray liquid required to achieve the predicted dermal exposures of bats are implausibly high, with bats carrying an amount of spray liquid that exceeds their body weight many fold. It is recommended that a bat risk assessment framework should be based on realistic, sound science, allowing resources to be focused on those scenarios that are not already covered by the existing bird and mammal framework. Therefore, a quantitative risk assessment scheme should not be implemented until the many scientific uncertainties within the EFSA bat statement are addressed. Environ Toxicol Chem 2022;41:2595–2602. © 2022 Cambridge Environmental Assessments. Environmental Toxicology and Chemistry published by Wiley Periodicals LLC on behalf of SETAC.