Review of the list of priority substances (Decision 2455/2001/EC)

1. Review of the list of priority substances (Decision 2455/2001/EC) How comments received were taken into account in the final monitoring-based ranking report (version Sept. 2009)or within the mandate of the EG-R?

2. Presentation based on 2 documents “Prioritisation process : monitoring-based ranking (September 2009) (James et al., 2009) “Prioritisation process : compilation of comments and corresponding answers (June-August 2009) (James et al., 2009)

3. Scope of the presentationFocus on some comments only • Comments not taken into account in the final monitoring-based ranking report are not addressed here • Most issues extensively discussed within WG E • Answers can be find in the so-called “Compilation of comments”

4. Scope of the presentation • Comments not taken into account in the final monitoring-based ranking report but taken on board by the Expert Group on Review of WFD PS list • Comments taken into account in the final monitoring-based ranking report and how

5. Comments taken on board by theExpert Group on Review of WFD PS list • Underestimation of CMR substances (PNECoral) • Use of equilibrium partitioning approach to calculate PNECsed

6. Underestimation of CMR substances (PNECoral) • COM consultant answer: • as regards CMR substances underestimated, discussions on vinyl chloride and 1,2-dibromoethane to follow within EG on review of WFD PS list. • DK comment : • risk underestimated for some CMR substances for which no human health reference toxicological value were available (e.g. vinyl chloride, 1,2-dibromoethane)

7. Use of equilibrium partitioning approach to calculate PNECsed • Joint CEFIC, ECPA and Eurochlor comment: • EqP = acknowledged method to relate PNECwater and PNECsed • risk to and via sediment needs to be checked in more detail for the highly ranked substances during the expert review, e.g. for: • sediment assessment only useful for compounds with actual tendency to distribute to the sediment (e.g. log KOW > 3; log KOC > 3) • PNECsed calculated from PNECwater • not appropriate when PNECwater refers to a species living exclusively in water (e.g. case of a herbicide) • With utmost care if PNECwater based on acute data. • COM consultant answer: • such analysis should be made in the context of the Expert Group on Review

8. Comments taken into account in thefinal monitoring-based ranking report and how • False negatives : issue on monitoring peak concentrations • Use of biota monitoring data for risk-ranking • PNEC values status issues • PNECoral terminology issue • Water intended for human consumption

9. False negatives : issue on monitoring peak concentrations • COM consultant arguments: • true methodology may underestimate the risk of substances with discontinuous emission patterns • no outcome in re-calculating PECs (no peak measurement database) • outcome in comparing PECs with MAC values but not possible with the allocated time and resource • NL and MODELKEY coordination comments : • monitoring-based prioritisation approach relevant for compounds with chronic exposure but poor relevancy for chemicals with peak exposure pattern (e.g. pesticides) • PECs calculations use arithmetic means of all measurements • comparison between PECs and PNECs vs PECs and MAC values

10. False negatives : issue on monitoring peak concentrations “It is recognised that the methodology used may have underestimated the ranking of some pesticides or other organic chemicals with a seasonal emission pattern. Such characteristics could be taken on board for next prioritisation step, for instance by comparing MAC-EQS with peak measurements.” In the final report VIII. Conclusions and wayforward(last but one §)

11. Use of biota monitoring data for risk ranking • Eurometaux comment : • for essential elements, metal concentrations will vary depending on many factors, i.e. the species, the life stage and the season “It has to be stressed as well that concentrations of essential metal in biota will vary depending on the species (e.g.hemoglobinevshaemocyanin organisms), the life stage and the season and that this should be taken on board to further assess risk for top predators using biota monitoring data.” In the final report IV. Step 3 : Relevant parameters for risk evaluation – IV.4. Metals

12. PNEC values status issues • Eurometaux comment : • still of the opinion that a report on describing the quality and relevancy evaluation and PNEC derivation would be useful and that an agreement on the PNECs for some metals has not been reached. • but PNECs suggested in the report no longer be revised in the context of this exercise (final stages). “The reader of this report should be aware that, except from values extracted from draft or finalized European Union Risk Assessment Report and Directive 2008/105/EC, PNECs suggested in this annex have been derived in the only purpose of prioritisation and these values shouldn’t be used directly as environmental quality standards without any further review.” In the final report PNEC values – Annex VII. and Annex XV.

13. PNECoral terminology issue • DK comment : • error in the applied terminology for ADI/PNECoral • PNECbiota derivation section completely revised In the final report IV. Step 3 : Relevant parameters for risk evaluation – IV.2.3.b. PNECoralderivation

14. PNECoral terminology issue In the final report IV. Step 3 : Relevant parameters for risk evaluation – IV.2.3.b. PNECoralderivation

15. Water intended for human consumption • European Glyphosate Association comment : • Table in chapter VII.4. (table 18) lists the compounds “for which a high treatment efficiency may be necessary to comply with the drinking water standards” it implies that the listed compounds are likely to exceed the drinking water standard • may not be true in practice, as some of the listed compounds might be easily and efficiently removed by standard drinking water treatment process • Joint CEFIC – ECPA – Euro Chlor comment : • Not convinced that all the compounds in the table cause a widespread problem for drinking water producers

16. Water intended for human consumption “The purpose of presenting drinking water standards is to identify those substances for which the ratio between the PEC and the drinking water standards is high, i.e. to identify substances for which high treatment removal efficiency would be necessary, and thus may cause a failure of the drinking water standard at the tap.” In the final report VII.4. Water intended for human consumption “Please, note that this priority setting algorithm refers to risk of failure of the drinking water standards.” In the final report Annex VIII. Indicative risk ratios for drinking water

17. Thank you for your attention