We comment on Zaida Lentini's summary of Session V (titled “Estimating Likelihood and Exposure”) of the 9th International Symposium on the Biosafety of Genetically Modified Organisms. We provide an explanation of the drawbacks of using empirical pollen dispersion models, based largely on the general representativeness of the data used to generate the empirical models. We exemplify the drawbacks by highlighting the limited data used to develop the empirical model of Gustafson (presented in the same Symposium session). We provide a discussion of the meaning of “worst-case” assessments for pollen dispersion, how “worst-case” assumptions are commonly used in environmental impact assessments and how regulators will view worst-case impact assessments differently from the regulated (biotech) community. Finally, we clarify the advantages and disadvantages of mechanistic models and explain why they are often used in preference to empirical models in environmental impact assessments.
