GRACE: no place for doubts? An endorsement for communicating uncertainty in scientific assessments
However, this group of stakeholders is essentially relying on a comprehensive uncertainty analysis accompanying disseminated conclusions and recommendations for an informed decision making. Only if this provision is met, risk managers, policy makers, and decision makers are able to fulfill their tasks and duties responsibly. Uncertainty comprises all types of limitations in the knowledge available to assessors at the time an assessment is conducted and within the time and resources available for the assessment (EFSA Scientific Committee 2016) EFSA recommends that "assessments must say clearly and unambiguously what uncertainties have been identified and what is their impact on the overall assessment outcome." This information is missing in the respective booklet. EFSA has recognized uncertainty analysis as a core element of transparency for all assessments and is of the opinion that ".as a general principle assessors are responsible for characterising uncertainty, while decision makers are responsible for resolving the impact of uncertainty on decisions. Resolving the impact on decisions means deciding whether and in what way decision making should take account of the uncertainty. Therefore, assessors need to inform decisionmakers about scientific uncertainty when providing their advice" (EFSA Scientific Committee 2016) We are in line with EFSA in this respect. In the present case, the GRACE consortium and/or its representatives take on the role as assessors and therefore are appealed for addressing uncertainties which inherently affect their analyses in their final "Conclusions and Recommendations," in the same booklet. This would substantially increase also the validity of and the confidence in the proposed "recommendations." Additionally, we miss a clearly structured description of the "strengths and limitations" of 90 day feeding trials in rodents and alternative studies as announced in the introductory section of the final "Conclusions and Recommendations" Over the past few years, Archives of Toxicology has provided excellent editorial coverage of the GRACE project and has issued in accordance with the coordinators of the project an invitation to an open scientific discussion on project related subjects at several occasions (Hengstler 2015) We are now taking the opportunity to enter the forum by providing a comment in response to the final "Conclusions and Recommendations" published online by the GRACE consortium (GRACE Consortium 2015) The amount of data collected by the project team and the efforts proficiently undertaken to solve the posed research questions are impressive and undisputedly acknowledged. However, it is astonishing that in this final report, the GRACE consortium appears to have refrained from communicating uncertainties which intrinsically affect any scientific analysis and subsequently the quality and validity of the drawn conclusions. This observation is of special relevance when considering the envisioned primary target group of these final "Conclusions and Recommendations" In contrast to peerreviewed publications of the GRACE consortium and as vaguely connoted in the heading of their booklet, this contribution appears to be primarily tailored to address risk managers, policy makers, and decision makers.
Archives of Toxicology