Water Res. Vol. 16, pp. 1371 to 1372. 1982 Printed in Great Britain
0093-1354 82 081371-02503.00 0 Pergamon Press Ltd
LETTER TO THE EDITOR BIOLOGICAL MONITORING. PART VI--FUTURE NEEDS Dear Sir,
I don't know one person who thinks so narrowly as to rely solely on acute toxicity tests nor do I know of anyone who thinks that system level tests are unnecessary.-C0nversely, it is widely recognized that data generated in single species tests are but one tiny group of inputs needed for hazard evaluation. It was the opinion of the majority of 41 leading biologists, ecologists, and chemists from the U.S., Canada, and England, that system level tests are essential to validate predictive accuracy, according to a poll I recently conducted. The review paper does not go "so far beyond the present practices" nor is it in any way "visionary". It merely reflects, with the exception of the implication that most of us consider single species tests all that is necessary for hazard evaluation, the state-of-the-art of ecotoxicology.
I read and enjoyed John Cairns Jr's review paper "Biological Monitoring. Part VI--Future Needs" (Water Research 15, 941-952, 1981). His statement in the first paragraph about the most important future needs of biological assessment of pollution--predictive capability development and validation of prediction accuracy--is correct, in my opinion, as is his last sentence about priorities. In between, however, there were some things which bothered me. I do not think that it was the intent of Dr Cairns to do harm to the process of hazard evaluation, but I think he did so by inaccurately portraying the prevailing attitude among ecotoxicologists. Dr Cairns advocates " . . . abandoning the practice of placing sole reliance on single species testing" and accuses some people who conduct such tests as believing that " . . . no system level tests are necessary to protect ecosystems." As a participant in two of the three symposia to which Dr Cairns expresses indebtedness for influencing his thoughts on future needs, and as an active member in the aquatic toxicologist community,
Consultant in Aquatic Toxicology 8330 Wilde Lake Road Pensacola, FL 32506, U.S.A.
Yours faithfully ROD PARRISH
A REPLY Dear Sir, Parrish's conclusion that there is strong support for going beyond single species testing was based on: (1) " . . . the opinion of 41 leading biologists, ecologists, and chemists... "(in a poll he conducted) and (2) participation in symposia on hazard evaluation to which I expressed indebtedness (again to leaders in the field). If my conclusions were based entirely on this select group, I would agree entirely with Parrish. If Parrish is correct, how does one explain the following? 1. There are no formally endorsed (e.g. the American Society for Testing and Materials) standard methods for system level or even community or multispecies tests. At the recent annual meeting of the Society for Environmental Toxicology and Chemistry (attended by over 500 professionals), I asked (Cairns, 1981) from the platform at a plenary session if anyone knew of a formally endorsed system level test and no one did. 2. None of the draft criterion documents prepared
by the U.S. Environmental Protection Agency in response to the consent decree (Federal Register, 1978a,b, 1979a,b, 1980) had substantive evidence on system level testing. 3. The preface of a National Research Council Report (1981) states "Recognizing that most current assessments rely primarily on data generated by single-species tests, the Council on Environmental Quality (CEQ) and the U.S. Environmental Protection Agency (EPA) initiated a review of available laboratory test systems and data evaluation schemes for predicting effects of chemicals on ecosystems". If awareness to go beyond single species testing is as widespread as Parrish suggests, it is curious that the National Research Council (the principal operating agency of the National Academy of Sciences and the National Academy of Engineering) was requested to conduct the review just mentioned: The position that our practices (i.e. primary reliance on single species testing) do not match our beliefs (i.e. that system level tests are needed for sound hazard evaluation)
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