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Published on 17 June 2013 by authority of the House of Commons London: The Stationery Office Limited

House of Commons

Science and Technology Committee

Water quality: priority substances

First Report of Session 2013–14

Volume III

Additional written evidence

Ordered by the House of Commons to be published 5 June 2013

Science and Technology Committee

The Science and Technology Committee is appointed by the House of Commons to examine the expenditure, administration and policy of the Government Office for Science and associated public bodies.

Current membership

Andrew Miller (Labour, Ellesmere Port and Neston) (Chair) Jim Dowd (Labour, Lewisham West and Penge) Stephen Metcalfe (Conservative, South Basildon and East Thurrock) David Morris (Conservative, Morecambe and Lunesdale) Stephen Mosley (Conservative, City of Chester) Pamela Nash (Labour, Airdrie and Shotts) Sarah Newton (Conservative, Truro and Falmouth) Graham Stringer (Labour, Blackley and Broughton) David Tredinnick (Conservative, Bosworth) Hywel Williams (Plaid Cymru, Arfon) Roger Williams (Liberal Democrat, Brecon and Radnorshire) The following members were also members of the committee during the parliament: Gavin Barwell (Conservative, Croydon Central) Caroline Dinenage (Conservative, Gosport) Gareth Johnson (Conservative, Dartford) Gregg McClymont (Labour, Cumbernauld, Kilsyth and Kirkintilloch East) Stephen McPartland (Conservative, Stevenage) Jonathan Reynolds (Labour/Co-operative, Stalybridge and Hyde)

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The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the Internet at http://www.parliament.uk/science. A list of reports from the Committee in this Parliament is included at the back of this volume. The Reports of the Committee, the formal minutes relating to that report, oral evidence taken and some or all written evidence are available in printed volume(s). Additional written evidence may be published on the internet only.

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The current staff of the Committee are: Dr Stephen McGinness (Clerk); Jessica Montgomery (Second Clerk); Xameerah Malik (Senior Committee Specialist); Victoria Charlton (Committee Specialist); Darren Hackett (Senior Committee Assistant); Julie Storey (Committee Assistant); Henry Ayi-Hyde (Committee Office Assistant); and Nick Davies (Media Officer).

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All correspondence should be addressed to the Clerk of the Science and Technology Committee, Committee Office, 7 Millbank, London SW1P 3JA. The telephone number for general inquiries is: 020 7219 2793; the Committee’s e-mail address is: [email protected].

List of additional written evidence

1 Water UK (WQ 01) Ev w1

2 Cancer Prevention and Education Society (CPES) (WQ 03) Ev w3

3 Chemical Industries Association (WQ 04) Ev w6

4 National Farmers Union (WQ 05) Ev w7

5 Royal Society of Chemistry (WQ 08) Ev w9

6 Marine Conservation Society (WQ 09) Ev w13

7 Severn Trent Plc (WQ 11) Ev w13

8 British Generic Manufacturers Association (WQ 12) Ev w16

9 Geological Society (WQ 13) Ev w18

10 Professor Richard C Thompson (WQ 17) Ev w20

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Science and Technology Committee: Evidence Ev w1

Written evidence

Written evidence submitted by Water UK (WQ01)

Declaration of Interest

Water UK represents all major UK water and wastewater service suppliers at national and European level.We provide a positive framework for the water industry to engage with government, regulators, stakeholderorganisations and the public.

The UK water industry already faces huge costs to meet the full implications of the existing WFD legislation.The addition of further substances (in particular pharmaceuticals) to the priority list presents a number oftechnical challenges and raises this potential expenditure to an unprecedented level.

General Background

1. The Water Framework Directive (WFD) is a very far sighted and innovative legislative mechanism thathas provided an excellent means to improve water quality across the European Union and we strongly supportits robust implementation, but would point out that it is not without fault.

2. The key plank in the WFD philosophy is the achievement of “good” status. Good surface water statusrequires both the ecological and the chemical quality of a water body to be at least “good”.

3. Good ecological status is defined on the basis of a number of normative definitions that are set out inAnnex V of the directive. In summary these definitions accept that there will be a slight deterioration frompristine conditions. As there are a number of these definitions, the metrics used have been the subject of anextensive pan-European “intercalibration” process as part of the EU Common Implementation Strategy.

4. The mechanism that provides the basis of Good Chemical Status is based upon consideration of eco-toxicity data for the individual pollutants listed as priority or priority hazardous substances (PS/PHS) in thedirective and its daughters. This mechanism has not been subjected to a similar intercalibration process.

Good Chemical Status requires the concentrations of all priority and priority hazardous substances found ina water body to be less than their Environmental Quality Standard (EQS) values on a one out all out basis.This means if one sample fails against one individual EQS value that water body cannot achieve good status.This means that the EQS value agreed is extremely important.

5. EQS values are calculated using a Technical Guidance Document developed as part of the CommonImplementation Strategy. The core elements of the approach are summarized in Annex V (1.2.6) of thedirective. This approach adopts the precautionary principle and utilises ecotoxicity data obtained fromlaboratory experiments to estimate a safe concentration (measured in water, sediment or biota) for the substanceconcerned. EQS values are usually derived from a so-called predicted no-effect concentration (PNEC), as thebasis of the standard. Unfortunately reliable eco-toxicity data may not always be readily available. This is oftenthe case when considering newly emerging problem substances, and to account for these uncertainties, a systemof safety or assessment factors is used to modify the PNEC when calculating an EQS value. These factors areapplied as a denominator to the PNEC and range from 1–10,000 dependent upon the extent of our scientificknowledge—the larger the factor the poorer our understanding. Thus, where our knowledge is limited, thestandard is effectively very much tighter with a higher safety or assessment factor applied to account for theuncertainty. Some standards may therefore be vanishingly small numbers that are both difficult to apply andchallenging to detect in the environment.

6. This methodology was not originally developed as a means to set environmental quality standards but forthe EU Risk Assessment process, used under the Existing Substances Regulations (793/93) which now fallsunder REACH. In this mechanism the assessment factors were used as a feedback loop—a flag to indicate thatmore data was required to qualify the level of risk presented. Unfortunately when adapted for EQS derivationan equivalent feedback loop was not included. Thus it may be asserted that, in cases where high uncertaintyfactors are applied, the standard is more indicative of “high” status than the good/moderate boundary that thenormative definition demands.

7. If one compares the core philosophy applied to ecological as opposed to chemical status there is a clearpotential mis-match between the terms in the equation used. A predicted no-effect concentration modified byan appropriate factor does not reflect a slight deterioration from pristine conditions especially if a large factoris applied.

It is therefore vital that EQS standards are robust, with low levels of uncertainty if we are to avoidexceptionally high levels of expenditure to achieve compliance that may not be justified or necessary in thefirst place. This matter is of particular concern as, to date, the European Commission has been reluctant torelax standards where more recent scientific data has indicated that such a stringent standard is not now justified.

8. Thus the prioritisation and standard setting system for listed substances has a pivotal impact on theachievement of good status across the EU but also may lead to much higher bills for water consumers acrossEurope

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Ev w2 Science and Technology Committee: Evidence

What chemicals should be controlled in water discharges, what should the acceptable thresholds be and howare these chemicals currently controlled?

9. The water industry is committed to the supply and distribution of good quality drinking water to all itscustomers and thus wholeheartedly supports the improvement of water quality in the environment. Under theWFD and its related daughters, controlled waters must not contain concentrations of substances (listed aspriority or priority hazardous substances) above the EQS values set out in the respective directives. Memberstates are also required to set domestic EQS values for specific pollutants that have been identified as beingdischarged in significant quantities to individual river basins. This means that there are already two tiers ofcontrol that dictate effluent quality standards that water companies must meet for their wastewater treatmentplant discharges under existing permit and consent arrangements.

10. The existing mechanism for setting EQS standards works well if there is a thorough understanding ofthe toxicological impacts of the pollutant concerned in the environment but not where there are high levels ofuncertainty as is often the case with newly emerging pollutants and where fate and behaviour studies have notbeen conducted. There should be an opportunity to either set interim standards in such cases or to delay theirintroduction until a better level of understanding is reached.

11. Water companies are empowered to control the quality of trade effluent discharges made to the publicfoul sewerage system but they do not enjoy any equivalent mechanism to control the amounts of pharmaceuticaland steroid oestrogens discharged from domestic dwellings to the foul sewerage system.

This means that the water industry has no mechanism to restrict the concentrations of such substancesdischarged to wastewater treatment plants and this almost inevitably means sophisticated end of pipe treatmentwill be required. Data from the Chemical Investigation Programme shows that many substances on the list thatare found in sewage primarily arise from domestic sources.

What are the roles of the public, industry, regulators and Government in ensuring chemicals that pose a riskare effectively controlled?

12. We believe that each has an active role to play in this area. Industry, regulators and Government alreadywork closely to deal with identified risks but it must remembered that these relationships are primarily dictatedby European legislation which effectively sets the agenda and the timeframe for action. The public are the leastinvolved in the process and although they could choose to reject the use of certain drugs we believe that to bemost unlikely.

Should pharmaceuticals in water discharges be better controlled and if so, how could this be achieved?

13. To answer this question we believe it is first necessary to consider the driver for such control. If theconcern is a health issue then it is surely preferable to manage the primary usage of the substance moreeffectively rather than attempt to deal with the problem as a water quality issue.

14. Brominated diphenyl ethers (BDEs) are fire retardants, found principally in fire-proofed foams in olderhousehold furniture. The proposed standard for BDEs (4.9 10–8 g/l) has been set at a level that the greatmajority of rivers receiving sewage discharges would fail to comply. Critically, there is no clear evidence thatBDEs are currently harming the aquatic environment, with healthy levels of fish and invertebrates found inrivers with concentrations orders of magnitude higher than the proposed standard.

The proposed standard is so low that no technology exists to measure their presence at the level beingsuggested (the lowest detectable level is 12 times below average levels in treated effluent). Additionally thereare currently no wastewater treatment techniques that are likely to be able to achieve compliance. Given thatBDEs have already been banned in the manufacture of furniture, due to their toxicity in far higher doses thanfound in the water environment, the opportunity to remove them via source-control is also diminished, makingthe delivery of the proposed standard an exclusively end-of-pipe concern.

15. The adoption of certain pharmaceuticals as potential priority substances presents a real challenge to thewater industry because, to achieve the demanding quality standards required, the only practical option is thewholesale treatment of wastewaters using techniques normally confined to the most advance level of potablewater treatment. Such treatment is costly to deliver and will have a huge impact on the industry’s carbonfootprint.

To what extent is innovation in water treatment supported in the UK? How successfully is innovation sharedacross the UK and the EU?

16. The UK water industry has a long history of introducing innovative methods of water treatment to dealwith quality problems dating back to the 1970s. This approach was found necessary to address legacy issuescaused by malpractices in the manufacturing and engineering sectors which for example had led to groundwatercontamination in large areas of the midlands. Indeed the adoption of techniques such as granulated activatedcarbon filtration was often the only viable mechanism to enable to continued use of such sources.

17. The UK water industry now works closely with its counterparts in other countries through EUREAU todevelop and improve innovative solutions to common problems.

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Has European Commission taken an evidence-based approach to the designation of chemicals that present asignificant risk to/via the aquatic environment under the Water Framework Directive?

18. While the Commission has continued to request water quality monitoring data from all Member Statesupon which to base its decision there are clear disparities across the EU. The core of larger states is reasonablywell prepared and has provided analytical data. Apart from the UK the countries that include the Rhine andDanube basins are among the best prepared but even they do not all have analytical methods and capabilitiesfor all the substances proposed. This means that too often decisions are being taken on the basis of partialdatasets. Elsewhere the level of awareness over the extent of current risk to water quality presented by manysubstances is not yet fully understood. In plain terms most of the newer member states do not have the technicalcapability to monitor and analyse for the proposed substances. They may also be incapable of affording thenecessary levels of wastewater treatment. Affordability concerns are also a significant consideration for olderand larger member states.

19. The proposed EU watch list was clearly aimed at trying to provide an evidence based approach but thereis an intrinsic conundrum here that will frustrate progress. Any newly proposed substance will not be commonlymonitored except where there is a known problem. Furthermore an analytical method of sufficient sensitivitywill not usually be available. These often take years to develop and accredit.

What likely impacts could the Commission’s proposals have in the UK? How could any adverse effects bemitigated?

20. The inclusion of pharmaceutical and steroid estrogens as potential priority substances presents a hugechallenge to all member states. These substances are widely prescribed by GPs to a large proportion of theadult population and pass unchanged through the human body into the sewerage system. Removal at source isnot therefore possible. Indeed recent research suggests that pharmaceuticals and estrogenic substances areubiquitous in sewage effluents and thus there may be little option but to adopt end of pipe treatment regimes.

21. The type of wastewater treatment required is much more sophisticated than any in current routine use inthe UK and would normally only be used in advanced potable water supply regimes (eg granulated activatedcarbon filtration or reverse osmosis). As we have an integrated commercial water industry in the UK we haveexperience in the use of such technology but it must be remembered that such techniques present considerablechallenges when used in wastewater applications and bring a huge energy and carbon footprint to reach thelevels of quality required.

22. In addition, if the Environmental Quality Standard (EQS) values adopted by the EU are not robust, ahigh safety factor may be applied using the precautionary principle that underpins the EQS standard settingregime such that high levels of purity are required but, in truth, these may not be justified. Unfortunately, onceset at a European level, it has proved almost impossible to relax such standards once a better understanding ofthe toxicological impact is gained.

23. So, while the effective control of toxic and polluting substances can have benefits for the potable supplyarm of the industry and indeed the general public, these benefits must be offset against the huge potentialtreatment costs that will be encountered in the wastewater arm of the industry. The scale of the benefits forpotable side will also be limited by the presence of other substances in the water environment that will stillneed high levels of water treatment, particularly pesticides.

24. Mitigation of these proposals will not be easily effected without a fundamental review of these clinicalpractices to include a broader understanding of the environmental consequences of their use.

February 2013

Written evidence submitted by Cancer Prevention and Education Society (CPES) (WQ03)


1. We are already seeing effects in the environment related to chemical exposure, in particular EDCs. UKEnvironment Agency data from 2004 already showed serious problems, with intersex wild roach found at 44of 51 sites sampled (Gross-Sorokin et al, 2006). It is unacceptable that levels of ethanylestradiol and estradiolshould exceed PNECs, especially when mixtures of estradiols have been shown to have effects below individualNOEC concentrations, showing how inadequate the PNECs are likely to be for preventing harm to the aquaticenvironment. The UK’s resistance to improved water quality standards means the situation is unlikely tochange; given the UK is home to some world-leading research in the area of water quality, this is a contradictoryattitude verging on the shameful and paints a general picture of an absence of anything approaching sufficientcontrols on UK water quality.

2. There will soon be a basic legal obligation to control the current list of 33 Priority Substances as identifiedin the Water Framework Directive, targeted for cessation or phase-out by 2020. However, it is the opinion ofCPES that this list does not go far enough, with many other pollutants besides those for which there isunequivocal evidence undoubtedly contributing to poor water quality, such as PFOA, BPA, triclosan and



ibuprofen (it should be noted that the introduction of “fracking” is likely to introduce a further range ofpotential risks to underground aquifers). Additionally, there is the ongoing failure to address the issue ofmixture effects, already long identified by the UK’s own Environment Agency as presenting serious challengesto current thresholds for allowable levels of pollutants in waterways.

3. There should be monitoring for a full range of important water contaminants. Since monitoring for allpossible contaminants is unrealistic, continuous monitoring (five samples per year) using markers of overallwater quality should be used (indicator species health and a watch-list of specific chemicals indicative ofoverall water quality), with periodic detailed analyses undertaken to look for any potential problem chemicalsas they either currently are, or might be in future, identified as posing a threat to the aquatic environment.


4. The government has primary responsibility in ensuring high water quality standards are set and met.Responsibilities could otherwise break down as follows.

5. Government: A range of measures can be implemented to reduce the emission of hazardous substances towater, encompassing product substitution, marketing and use restrictions, industrial permits being granted onon demonstration of best available production/pollution mitigation techniques, fiscal instruments such as taxesand levies on polluting practices or products; the setting of emissions and environmental quality standards; andaction to raise public awareness. Specific ideas include:

(a) Introducing triggers for action and a timetable for control measures to reduce emissions ofpriority substances and to eliminate the presence of priority hazardous substances in water.

(b) Strengthening the principle for recovery of costs in accordance with the polluter pays principle.

(c) Joined-up environmental thinking, with effective coordination between the various elements ofGovernment with a stake in water quality.

(d) Supporting innovation in water treatment.

(e) Promoting more sustainable consumption and production of chemicals and invest in greenchemistry.

6. Public: Taking care not to dispose of pharmaceuticals and chemical products down the drain (accompaniedby a Government and industry role in providing take-back schemes and education, incentives to achieve this).

7. Industry: Investment in green chemistry, limiting pollution from point sources, phasing-out chemicalproducts and practices which result in diffuse water pollution; ending practice of externalising costs associatedwith polluting practices.


8. A lot of taxpayer money has been spent on research, but very little action has been taken to address theissues this research investment has revealed. Not even measures as simple as effective pharmaceutical take-back schemes have been implemented across the UK. Meetings between CPES and the Environment Agencyrevealed very little interest or enthusiasm for addressing a problem which, previously, the EA had been integralto uncovering.

9. At the very least, pharmaceutical take-back schemes should be uniformly implemented across the UK.The bigger issue of pharmaceutical contamination from user excretion is more difficult to address, but levelsof pharmaceuticals in UK waterways are more than sufficient to cause concern.

10. Hospital outflows can be filtered to prevent healthcare facilities contributing to water contaminationissues, but this is currently unrealistic for domestic context. The issue can probably only be addressed byimproved water treatment practices. There are obvious cost concerns around the expense of methods such asactivated charcoal, but rather than simply write off the possibility of improving water quality, the UKgovernment should be encouraging the development of more realistically-priced alternatives, such as enzymecatalysts, and be setting a target date for a low-cost treatment option.

To what extent is innovation in water treatment supported in the UK?

11. Not enough, given that the UK government has consistently opposed the introduction of tighter waterquality standards in the EU, and the current lack of interest CPES has observed at the EA. If governmentpositions as communicated through the media are anything to go by, there is no reason to suppose that theGovernment has any intention of supporting innovation in this area. Instead, the focus seems to be on writingoff technologies for water purification as too expensive, and dealing with water quality issues by loweringstandards to accommodate UK’s poor water quality, rather than looking at innovative ways of treating waterwhich are economical.



Has the European Commission taken an evidence-based approach to the designation of chemicals thatpresent a significant risk to/via the aquatic environment under the Water Framework Directive?

12. Presumably the intent of this strangely-worded question is to ask whether or not the Commission hascorrectly chosen which chemicals for prioritization in the WFD. This bears several comments.

13. Firstly, yes it has. The selection of 15 Priority Hazardous Substances followed a risk-based approach,screening over 2000 chemicals and incorporating monitoring data from the EU as well as hazard data. Scientificexperts from Member States were closely involved in the selection and for the 15 selected chemicals there isoverwhelming evidence that these pose a high risk to the aquatic environment.

14. Secondly, there is insufficient research into the environmental toxicity of chemicals, so any decision isinevitably going to be controversial; that does not change the facts that water should not be contaminated withchemicals which are either known to be hazardous, or with chemicals of unknown hazard profile.

15. Thirdly, the Commission has been slow to act on a number of chemicals of concern; any suggestion thatsomehow they proposals could be going too far would be peculiar, and if anything one could argue theproposals do not go far enough.

16. The main issue here is that chemicals have been allowed to contaminate waterways before it has had tobe proven they are environmentally safe; without that evidence it is always possible to dispute how “evidence-based” the Commission’s approach is.

17. Overall, CPES supports the Commission’s designation of chemicals of harm as a minimum requirement,and would overall argue that controls on chemicals in waterways should in fact be much tighter. In the absenceof proof of safety, no chemical should be released into the environment. This is an evidence-based approachrequiring proof of safety before environmental release; to demand evidence of harm before restriction is alsoevidence-based but flouts obligations to observe the precautionary principle.


18. It is probably expensive and in the current climate cost is no doubt the UK’s chief concern (regardlessof the costs of poor quality water). Adverse effects could be mitigated with schemes which ensure neither theGovernment nor taxpayer do not foot the bill for pollutants in the environment as a result of commercial orindustrial activity—the principle of “polluter pays”.

19. The UK could utilise its expertise in green chemistry to facilitate the development of low-cost butefficient techniques for removing contaminants from water. If UK companies developed technologies whichbecame widely adopted (which they should be, if the EU is driving higher water quality standards and allcountries face budgetary difficulties in adapting water treatment systems for ensuring these are met), it couldbe a boost for the UK economy rather than just a burden.

Declaration of Interests

Paul Whaley was paid for writing this document as part of his role as Scientific Advisor to CPES.

Paid work by Paul Whaley over the last five years relevant to this document: ChemSec (researcher); CancerPrevention and Education Society (retained as Scientific Advisor and editor/producer of Health &Environment); Standardisation Network for Sustainability (Technical Committee Expert Representative); Centrefor Sustainable Healthcare (researcher, writer); BetterValueHealthcare (web developer, writer); New Harbour(researcher); Health Care Without Harm (employee); Reseau Environnement Sante (researcher, projectmanager).

Relevant Grants: PW is currently a recipient of a research and education grant from the EuropeanEnvironment & Health Initiative and Fondation Pour Une Terre Humaine, concerned with exploring weight-of-evidence protocols for evaluating environmental health and safety profiles of endocrine disrupting chemicals,with the grant administered by French environment charity Reseau Environnement Sante.

PW has no investments or other financial interests to declare, and no Board memberships.

February 2013



Written evidence submitted by the Chemical Industries Association (WQ04)

1. Introduction

The Chemical Industries Association (CIA) is the largest industry association for the chemical and alliedindustries, representing around 250 businesses whose products underpin many UK manufacturing sectors. Werecognise the need for sustainable water legislation and have supported the implementation of the variousaspects of the Water Framework Directive and its Daughter Directives in the UK. However, we express somereservations on the move to increasingly low and precautionary water quality thresholds. We are working withDefra and the Environment Agency to resolve the current uncertainties around the regulatory requirements onthe chemical industry (around the practical expectations of WFD compliance) but are also aware of the potentialimpact of non-regulatory arrangements with Water treatment companies for releases to sewer.

We have responded to your specific questions, where they relate to the chemical industry, below.

2. Questions

2.1 What chemicals should be controlled in water discharges, what should the acceptable thresholds be andhow are these chemicals currently controlled?

Response:

The current 33 chemicals followed a methodology based on pbt criteria. Thresholds were again set by ascientific technical committee, but I think it is widely recognised that these are based on precautionary values(with significant extra protection factors built in). It is also suggested that for those sites for which the particulartest species is not applicable, neither should be the threshold.

WFD classifications can give a pessimistic view of water quality—they aren’t able to show all theimprovements made in recent years… and the fact that often these improvements are continuing. It is arguablethat the significant further reductions in threshold levels being seen in recent priority substance reviews, arenot needed as water quality continues to improve.

Chemical sites may release certain materials under permit (EPR) which also sets allowable release limits—usually as threshold concentrations, but these can also include load thresholds. These have in the past beenbased on environmental impact assessments for significance, with an understanding of the costs of any furtherinvestments needed for further control.

Sites may also have releases to sewer, which in this case are subject of a commercial agreement, not regulatedby the environmental agencies. However, the controls needed for the WWTP and the impact of the industrialeffluent as part of their overall inputs, will influence the release limits (thresholds and/or loads) placed withinthis commercial permit. It is a current concern to industry that WTPs can set their own release thresholds forindustrial effluents, and may do so as a means of meeting their own regulatory compliance targets, which maymake no reference to the technology in place (BAT), or and (disproportionate) costs of compliance at thereleasing site. This raises the issue, which is currently under UK discussion, of where investment costs shouldbe incurred—at a Water Treatment company, or at (potentially several) contributing sites.

2.2 What are the roles of the public, industry, regulators and Government in ensuring chemicals that pose arisk are effectively controlled?

See above for industry and regulators. The role of the water treatment company is also integral to this debate.

2.3 Should pharmaceuticals in water discharges be better controlled and if so, how could this be achieved?

No comment.

2.4 To what extent is innovation in water treatment supported in the UK? How successfully is innovationshared across the UK and the EU?

No comment.

2.5 Has European Commission taken an evidence-based approach to the designation of chemicals thatpresent a significant risk to/via the aquatic environment under the Water Framework Directive?

The initial round of designation of chemicals considered the scientific evidence around a defined list ofsubstances, which had been shortlisted on the basis of both substance properties, and monitoring evidence oftheir widespread existence in the environment. We believe the inclusion of a monitoring programme is essentialto improve the quality of the data, and ensure that substances are included in future lists due to theirenvironmental impacts.

We did have concerns however about the process within the EU committees, as it appeared that severalmember states did not fully contribute—either in attendance or with the required level of technical knowledge(this is a difficulty, as much of the technical discussions require real specialists, which are not alwaysavailable)—and this ensuing lack of technical challenge was exacerbated by the technical documents for review,



being available only at short notice before the meetings. This led to the concern that some substances, or theirwater standards, were being accepted with insufficient or robust challenge.

2.6 What likely impacts could the Commission’s proposals have in the UK? How could any adverse effects bemitigated?

We have welcomed the Environment Agency’s risk-based approach to regulation, where the environmentalimpacts have been balanced at site level, against the implementation of BAT, and any (disproportionate) costsof additional controls. As additional substances appear in the list, and/or reduction of threshold levels, thisapproach is particularly welcomed, as it can be very costly to upgrade existing plant and where theenvironmental benefits can be unquantifiable, or at best uncertain.

February 2013

Written evidence submitted by the NFU (WQ05)

The NFU represents more than 55,000 farming and growing members and in addition some 40,000countryside members with an interest in the countryside and rural affairs. The NFU welcomes the opportunityto make a submission to the Science and Technology Committee inquiry on water quality (Priority Substances).

Executive Summary

— The NFU aims to base its policy on sound scientific evidence and supports a risk-based approachto regulation.

— The list of proposed priority substances contains three plant protection products: Bifenox,Cypermethrin and Quinoxyfen. Glyphosate is also proposed for inclusion on a watch list.

— Pesticides are regulated under directive 1107/2009 which offers stringent environmental controls.

— Pesticide actives used in the EU have fallen by over 70% since 1993 resulting in increased use of areduced number of actives.

— Pesticides proposed as priority substances tend to be high volume products but represent a low risk.Risk from pesticides identified in the aquatic environment should be managed under regulation 1107/2009 not by the Water framework directives.

— UK pesticide stewardship sets a very high standard as a result of the Voluntary Initiative on pesticidesand has gone a long way to manage aquatic risks from pesticides.

— UK regulators need to provide greater support in terms of data and information to inform localdecision making on pesticide stewardship.

— The Commission proposal for a watch list of chemicals lacks clear criteria for inclusion, it isimportant that any proposed list is based on clear criteria.

— Loss/restriction of Cypermethrin and Quinoxyfen would have a considerable impact on specialistcrops in the soft fruit and vegetable sector. This sector is economically important and alreadystruggles with a lack of suitable pesticides.

— Inclusion of Glyphosate on a list for monitoring without a clear basis of concern sets a dangerousprecedent for further decision making implementing a precautionary approach to pesticide regulation.

Introductory Comments

1. Under the EU Water Framework Directive (WFD), discharges of substances deemed to “present asignificant risk to or via the aquatic environment” must be progressively reduced to a safe level. This list ofchemicals contains a number of plant protection products (ppp) commonly referred to as Pesticides. Currentproposal for adding new chemicals to the list of EU chemicals considered a risk in water courses includeCypermethrin and Bifenox to be listed as Priority Substances (PS) and Quinoxyfen as a Priority Hazardoussubstance (PHS). Glyphosate is also proposed for inclusion on a PS watch list.

Pesticide Regulation and what Chemicals should be Controlled as PS

2. Pesticide active ingredients are closely regulated under the plant protection regulation 1107/2009. Theregulation lays down extensive criteria to protect the aquatic environment; any significant environmental risksidentified under ppp registration assessments would prevent the active substances being registered for use. Theregulation 1107/2009 was recently implemented and has more stringent criteria for environmental and humanprotection than the previous ppp regulation 91/414, including hazard cut off criteria which lower the thresholdof tolerance for active toxicity making it unlikely that toxic substances which bio-accumulate will be registeredfor use in the EU.

3. Currently low toxicity products that have passed safety criteria under 1107/2009 but that have a highvolume usage or are used during wet periods (such as autumn sowing) are being identified as risks in water



courses under the WFD (eg Glyphosate) and become targets for regulatory restriction. Effectively producing asecond layer of regulatory control that is not based on risk but is more reflective of levels of usage.

4. Thresholds setting and further regulation of active substance including whether an active should be phasedout of the market (eg Quinoxyfen) should be considered and reviewed under pesticide regulation 1107/2009which is designed to identify and manage chemical risks, not under the WFD to ensure consistency withregulatory process. At any time, the Regulation 1107/2009 can revise the authorisation of a specific activesubstance, if it is considered dangerous restricting use, setting up new mitigation measures or the revoking useof the active.

5. The number and range of pesticide active ingredients available to farmers and growers has alreadydecreased significantly in recent years, the number of active ingredients available for use in the EU hasfallen1 from c. 900 actives in 1993 to c. 230 actives in 2009. There are two main implications; firstly themore toxic substances are generally no longer available, and secondly the range of pesticides available tocontrol each pest or disease has reduced significantly, as a result growers often rely on one or two ppp’s ascontrol options for common pest problems such as slugs or weed control, as a result the levels of usage ofthese products rises because of a lack of alternatives. Then because of high usage they are detected in watercourses and potentially listed as specific pollutants and potential priority substances thus creating a closedloop problem which is only likely to intensify with reducing product availability and the resultant reliance onsingle ppp actives.

Industries Role in Managing Pesticide

6. Industry plays a clear UK role in minimising the risk to the aquatic environment, the NFU believes thatthe standards of agricultural practice in the use of pesticides in the UK are among the highest in Europe, asevidenced by the high professional standards identified in the recent DEFRA Pesticide Forum report2 andidentified by ministerial comments concerning the achievement of the industry Voluntary Initiative since itsinception in 2001 in raising pesticide stewardship standards3. Following the success of the VoluntaryInitiative, improved pesticide stewardship has been encouraged by a range of chemical company initiatives andalso by fresh produce and arable assurance schemes

7. The basis of this achievement is the Voluntary Initiative on pesticides, which has looked to improve thestandards of operators, agronomists and application equipment on an on-going voluntary basis with schemesthat in all cases continue to exceed the requirements of the newly implemented EU Sustainable Use Directive.The Voluntary Initiative reports progress to Defra ministers annually. On a voluntary basis 20,359 sprayoperators are involved in on-going Continuing Professional Development via the National Register of SprayOperators, run by City and Guilds. Of the total sprayed area in the UK, 86.8% was sprayed using sprayequipment tested annually under the National Sprayer Testing Scheme. The inclusion of these measurers inassured produce schemes, like the Red Tractor, which have very high levels of uptake by farmers and growers,have further improved standards of pesticide stewardship in the UK, with reduction in water courses a keytarget.

8. Growers in the fresh produce and arable sectors are supported by experts in the agronomic advice industry,many of whom have received additional training beyond expected industry standards; 847 agronomists holdthe Biodiversity Environmental Training Award (BETA), designed to improve the standards of environmentalstewardship and encourage best practice.

Public and Regulatory Responsibility to Manage PS

9. In some cases products like Glyphosate are commonly used by amateurs, the implications of such usageis that care and attention is likely to be lower with amateur users, but all uses add to cumulative presence ofactive substances in water courses. Opportunities to improve standards in amateur and amenity use requireconsiderable development as identified in the Draft National Action Plan on Pesticides.4

10. Regulators such as Environment Agency and Chemical Regulation Department (HSE) are heavilyinvolved in the work of the Voluntary Initiative and further support to industry is provided through theCatchment sensitive farming (CSF) initiative run by Natural England.

The recent report by CSF indicated the success of work with the VI in reducing pesticide presence in watercourses,5 however further support is needed to facilitate change. It has proved difficult to source local dataon exceedance’s to inform farmers of local risks from their fields, or to provide information to farmers on whatriver catchment there land is in. Greater support is required from the Environment Agency to provide localinformation that can better inform on farm practice. Data ownership issues between government agencies haveoften been identified as a reason for failing to provide local/detailed information. Government can play agreater role in ensure that issues of data ownership are managed to ensure that such issues do not compromise1 http://www.bcpc.org/_assets/files/43_WILLIAMS.pdf2 http://www.pesticides.gov.uk/guidance/industries/pesticides/advisory-groups/pesticides-forum3 http://www.voluntaryinitiative.org.uk/4 http://www.defra.gov.uk/consult/2012/07/30/uknap-pesticides/5 Pesticides in Catchment Sensitive Farming catchments 2006–2012, CSF report



attempts by Industry and Regulators to improve stewardship standards and reduce contamination of watercourses.

Identification of PS, PHS and Watch List Chemicals

11. The watch list of potential emerging substances as proposed by the European Commission lacks clearcriteria for inclusion. Substances should be identified based on a clear set of criteria however the inclusion inthe watch list of some substances (eg Glyphosate, AMPA) with a low toxicity level, whose monitoring dataare well under the Environmental Quality Standard threshold, seems to suggest a lack of coherent strategy.This approach sets up a dangerous principle at EU level based on a precautionary approach which will lead toa continuous erosion of active substances on the European market. Inclusion of the active substances shouldbe based on scientific evidence of quantifiable risk and a cost/benefit analysis of any restriction.

Likely Impact of Commission Proposal on PS, PHS and Watch List Chemicals

12. Direct impact of this round of PS reviews will be greatest for the specialist crop sector. Listing ofQuinoxyfen as a PHS will probably result in the loss of a critical fungicide for controlling powdery mildew inthe soft fruit sector for crops such as strawberries. Cypermethrin proposal as a PS is of great importance tovegetable growers as control for range of pests including aphids and stem weevils. It is also important as acontrol in apples and pears against a range of sucking pests. The availability of suitable pesticides in specialistcrops is an area of great concern due to limited number of actives registered for use and the loss of anyproducts to these sectors reduces the control options and increases the potential pressure for resistance todevelop. It is therefore important that any restrictions are based on clear evidence of risk under ppp regulation1107/2009 and take account of possible mitigation measures and cost benefit analysis.

13. Inclusion of Glyphosate on a potential watch list could result in future restriction on one of the widestused and most important pesticides in modern agricultural practice. Glyphosate offer growers establishedbenefits, on yield, increased harvest efficiency and reduced soil erosion due to its use in most minimum tillagesystems6. Loss of significant restriction would result in the use of selective and residual herbicides which arepotentially more toxic to the environment than Glyphosate, and would in effect create a greater environmentalthreat than any current concerns over the relatively benign Glyphosate.

February 2013

Written evidence submitted by The Royal Society of Chemistry (RSC) (WQ08)

1. The RSC is the largest organisation in Europe for advancing the chemical sciences. Supported by anetwork of 47,000 members worldwide and an internationally acclaimed publishing business, its activities spaneducation and training, conferences and science policy, and the promotion of the chemical sciences to thepublic. This document represents the views of the RSC. The RSC has a duty under its Royal Charter “to servethe public interest” by acting in an independent advisory capacity, and it is in this spirit that this submissionis made.

2. The RSC believes that chemicals for control in water discharges must be identified through a thoroughenvironmental risk assessment process. The development of legislation to control such chemicals must beproduced with appropriate scientific advice to ensure that it is based upon sound scientific evidence. Wherenecessary a cost-benefit analysis of options for control should be applied. In advance of taking measures tocontrol specific substances, it is important to consider the following questions:

— What is the extent of the problem? If more substances are identified for control, thenunderstanding how widespread these substances are will be important in determining a solution.

— If further treatment is required, does the cost-benefit analysis suggest that this is the best option?

— What is the fate of chemicals that are removed by treatment? Are they broken down intoharmless “daughter” products or do the daughter products represent a separate hazard?

— In the case of pharmaceuticals, what would be the impact of the withdrawal of the medicinesin which the specific substances are used?

— Much more research is need into the list of proposed substances before adopting a treatmentbased solution.


3. Chemicals to be Controlled:

Chemicals to be controlled in water discharges cannot be listed in an arbitrary fashion. They needto be identified by a thorough environmental risk assessment process that takes account of the toxicityto the aquatic environment, human toxicity and persistence. This needs to be achieved within a

6 Monsanto (2010). The agronomic benefits of glyphosate in Europe-review of the benefits of glyphosate per market use—Review,p1–82.



risk framework that takes account of any potential synergistic or antagonistic effects of hazardoussubstances.7 Both spatial and temporal consequences must be considered. Effects from long-term,low dose, exposure must be examined, as well as short-term exposure to higher doses. The fate andtransportation of such substances must also be investigated. If the substances in question can bebroken down into other products, these “daughter” products must also be taken into consideration.Such assessments are currently applied to understand the risk that various substances or processespose throughout the environment, in air, water and on land.

4. The process of environmental risk assessment must consider both the hazard and risk of the substance.8

The differentiation between these two terms is important. Hazard is the inherent potential for something tocause harm, whilst risk is the likelihood that harm will actually be done by the realisation of the hazard.Chemicals should not be selected for control on the basis of hazard alone. In other words, it should beemphasised that it is the overall risk from substances that is the key parameter in deciding what chemicalsshould be controlled in water discharges. The overall risk takes into account not just the intrinsic hazard ofsubstances but also, crucially, the likelihood of a significant exposure to these substances in water.

5. Acceptable Thresholds and Current Controls:

Acceptable thresholds for chemicals that need to be controlled are currently derived from theEnvironmental Quality Standard (EQS) for that substance, alongside consideration of theenvironmental sensitivity of the receiving water (eg are there any protected species present?) and thedownstream use of the source (eg public supply, irrigation of crops). Limits should be set withspecific parameters, based on the best available scientific data and an understanding of currentdetection techniques.


6. The government must produce appropriate legislation to ensure that substances which pose a risk to theenvironment and/or human health are identified and controlled. This legislation must be developed withappropriate scientific advice to ensure that it is based upon sound evidence. This can include advice from thenetwork of Chief Scientific Advisers, as well as specialist committees. Committees such as the UK ChemicalStakeholder Forum9 and the Hazardous Substances Advisory Committee10 are important mechanisms inproviding scientific advice in relation to the management of chemicals in the environment.

7. In general, the role of regulatory agencies includes identifying issues in the discharge of controlledchemicals, proposing limits, providing advice, ensuring monitoring is undertaken and enforcing regulations.As part of their role in constructing and enforcing regulation, they have a role in providing input on the efficacyof such regulations.

8. Industry can take a lead in eliminating the use of particularly hazardous chemicals by identifying ways toreduce, replace or substitute these. A 2010 workshop on Pharmaceuticals in the Environment by the EuropeanEnvironment Agency identified “green pharmacy” as one way of reducing the environmental impact ofpharmaceuticals.11 Green pharmacy is defined as the design of pharmaceutical products and processes thateliminate or reduce the use and generation of hazardous substances. The report suggests that incentivisinggreen pharmacy (eg extending patents for such products) could help to reduce the environmental impact ofpharmaceuticals. Industry is also required to comply with national regulations and European directives.

9. The general public have a limited role in the control of chemical risks, but they can be encouraged tominimise the use and discharge of hazardous chemicals (see paragraph 11).


10. A better understanding of the scale and effects of pharmaceuticals in water discharges is needed beforedetermining control measures. The term “pharmaceuticals” covers a multitude of widely differing chemicals.Each pose a different level of potential risk to the environment, and consequently need to be individuallyassessed. The discharge of pharmaceuticals occurs via three main routes; manufacture of pharmaceuticals,human health use and veterinary health use, which need to be considered separately.

11. A wide range of pharmaceutical products, particularly antimicrobials, is administered to livestock andthen can pass directly into the aquatic environment via run-off from fields, bypassing wastewater treatmentplants. Before investing money in upgrading wastewater treatment processes to remove pharmaceuticals, itmay be prudent to examine the relative contribution from domestic and industrial wastewater of human originand that coming directly from livestock. Encouraging the correct disposal of unused pharmaceuticals by the7 Environment, Health and Safety Committee Note on: Pragmatic Approaches to Assessing the Toxicity of Chemical Mixtures,

Environment, Health and Safety Committee of the RSC, May 20128 Environment, Health and Safety Committee Note on: Environmental Risk Assessment, Environment, Health and Safety

Committee of the RSC, April 20089 http://www.defra.gov.uk/chemicals-forum/10 http://www.defra.gov.uk/hsac/11 Pharmaceuticals in the Environment, Results of an EEA workshop, EEA Technical Report, No1/2010



public is important. One option would be to include a prominent warning on pharmaceutical packaging thatunused items must be returned to the pharmacy for safe disposal.

12. There is a particular concern over the discharge of antimicrobial agents that has less to do with theecotoxicity of these substances and more to do with the propensity of bacteria exposed to such agents todevelop and then exchange antibiotic resistance genes. Assessing the levels of antimicrobial agents already inthe aquatic environment and their effect on antibiotic resistance is an area of research that needs to be givensome priority. Moreover, it has been shown that the over-prescription of antibiotics is a significant factor indecreasing the effective treatment of bacterial infections in humans and also detrimental effects in the aqueousenvironment with respect to antibiotic resistance of wild-type bacteria.12

13. Industrial discharges in relation to the manufacture of pharmaceuticals are another area where controlcan be exercised and there are already mechanisms by which to achieve this. The EU directive on IntegratedPollution Prevention and Control is included as part of UK environmental permitting regulations for allindustrial activities, including the manufacture of pharmaceuticals. The inclusion of ecotoxicity and biotaimpact limits for industrial discharges can also assist with controlling discharges relating to pharmaceuticalmanufacture.

14. Clearer monitoring standards within EU directives could lead to more consistent controls for thedischarge of hazardous substances. The 2008 EU directive 2008/105/EC on environmental quality standards inthe field of water policy allows member states a choice of matrix when monitoring some substances, takinginto account that different measurement techniques are available in different member states.13 These are thebiota standard (measurement in organisms) and the water environmental quality standard (measurement in thebody of water). However, this can lead to the same environmental situation giving rise to different assessments.For example, if a substance is liable to bioaccumulation, then using a biota standard may result in a badenvironmental assessment, whilst applying the water environmental quality standard will result in a goodenvironmental assessment. There is a need to strike a balance between considering best available techniquesand setting clear and transparent standards. It may be appropriate to set the matrix for selected substanceswhere such discrepancies occur.

To what extent is innovation in water treatment supported in the UK? How successfully is innovation sharedacross the UK and the EU?

15. Currently, there is significant activity within the UK water industry to encourage innovation. Mostcompanies have a research and development budget and a good level of cooperation with academia. Nationalorganisations such as UK Water Industry Research aim for a strategy that is innovation-led. However, the lackof a national testing facility for new water treatment technologies is a critical barrier, as even when innovativetechnology is developed, it cannot be demonstrated. An additional hurdle in the early adoption of innovativetechnology from small and medium enterprises (SMEs) is the financial regulatory framework. This currentlyrequires companies to define significant capital expenditure five years in advance, which can hinder the uptakeof new technology.

16. There are a number of other potential obstacles to the adoption of new technology, including thevariability in water (eg upland, surface, river or groundwater), wastewater types (eg domestic, industrial ormixed waste), the regulatory framework and variability in upstream treatment processes. Due to the lack of anational testing facility, once a new technology has passed proving and pilot stages, it must be assessed in realscenarios. This requires incorporation into working water treatment systems, which can carry regulatory,operational and public health risks, which must be managed.

17. Non-technological innovations can help achieve sustainability objectives and protect water quality. Forexample, land management practices to reduce diffuse pollution and flooding have been adopted successfullyacross some parts of the UK.14,15 These catchment based approaches often have synergistic environmental,economic, societal and landscape benefits.

18. The European Commission is addressing the link between water research and innovation by setting upan European Innovation Partnership (EIP) on water.16 The aim is to bring together stakeholders from research,industry, policy, finance, governance and other areas to generate innovative technologies and approaches thatsupport future EU policy in water and create jobs and growth.17 The Royal Society of Chemistry, via theEuropean Technology Platform for Sustainable Chemistry (SusChem) is involved in providing advice andscientific input to this EIP.18

12 Antibiotic Resistance: Contribution of Hospital Effluents to the spread of ATBR in environment, presentation by ProfessorChristophe Dagot, PILLS Project Final Conference, September 2012

13 Directive 2008/105/EC on environmental quality standards in the field of water policy, December 200814 Catchment management in Wales—Glas Tyr, Presentation by Ann Humble, Welsh Assembly Government at Protecting Water

Catchments from Diffuse Pollution—the Emerging Evidence, February 201215 Sustainable Land Management (SLM) for the Protection of Drinking Water Sources in Scotland, Presentation by Peter Brown,

Water Quality Regulation Manager, Scottish Water at Protecting Water Catchments from Diffuse Pollution—the EmergingEvidence, February 2012

16 http://ec.europa.eu/environment/water/innovationpartnership/index_en.htm17 Communication from the European Commission on the European Innovation Partnership on Water, May 201218 http://www.suschem.org/



Has European Commission taken an evidence-based approach to the designation of chemicals that present asignificant risk to/via the aquatic environment under the Water Framework Directive?

19. To an extent, the approach used by the EC has been evidence-based. The method used for assessing therisk of hazardous chemicals is defined in Article 16 of the WFD, which also lists the agencies consulted aspart of the process. The shortlist of substances has been selected on the basis of scientific evidence that theymay pose a significant risk to health.19

20. However, concerns have been raised regarding the data used to set the Environmental Quality Standards(EQS) for some of the substances that have been selected for control. For example, in a letter to RichardBenyon (the Parliamentary Under Secretary of State for Natural Environment and Fisheries), the chair of theHazardous Substances Advisory Committee, Professor Stephen Holgate, raised concerns over the data sets usedin the assessment of diclofenac.20 In setting the EQS for any substance, the full consideration of relevantscientific evidence is of paramount importance.

21. There are other concerns around the EQS for many of the substances identified. Firstly, each substanceappears to have been assessed individually, yet there may be synergistic effects that enhance or diminish theenvironmental impact and/or toxicity of a particular substance. Secondly, substance limits often take littleaccount of the technology available for compliance monitoring. An example is the directive recommendationof a standard of 4.9 x 10–8 micrograms per litre for brominated diphenyl ethers,21 but there is no analyticaltechnique available that can detect a concentration at this level. Specifying an EQS at a level that currentlycannot be measured, regardless of the perceived risk, is unhelpful. That said, setting such levels can providethe driver for technological innovation.

22. Similarly, setting a low EQS where member states may be unable to influence the environmentaldistribution of substances seems impractical. Referring again to brominated diphenyl ethers, these are largelybanned from use throughout the EU, but they are widespread and environmentally stable so concentrationswell above the EQS are likely to persist in many surface waters despite the source of input being eliminated.

23. Moreover, in reference to the three pharmaceutical substances that are listed, no assessment has beenmade of the impact on the availability of medicines in which they are a key constituent. Diclofenac is used totreat osteoarthritis; an illness that affects 2.5 million people in the UK.20 17 alpha-ethinylestradiol is used inmany brands of the contraceptive pill. No analysis has been carried out to understand the likely impacts ifthese medicines were no longer widely available. A cost-benefit analysis should be carried out for eachsubstance. This will need to consider the economic impact of installing new treatment technology, as well asthe impact on patients from the withdrawal of medicines.


24. EC standards should not be adopted without examination by UK experts, who should also consider ifsuch standards are appropriate to UK conditions. The main likely impact would be a need to minimise and/orremove the proposed substances from water discharges. To do this, more technologically advanced wastewatertreatment capacity will be required. Such technology has a large financial implication as the introduction to theinquiry acknowledges. The EC’s own impact assessment estimates that the monitoring of the threepharmaceutical substances on the shortlist could cost somewhere between €15–36 million per year across thewhole EU.22 As well as the significant financial impact of widespread installation of advanced treatmenttechnologies, there will be a consequent negative impact to the carbon footprint of EU member states, becausesuch technology is energy intensive.

25. In advance of the adoption of the proposals, it would be prudent to consider the following questions:

— What is the extent of the problem? This question has been answered in part for the current listof priority and priority hazardous substances as a result of the extensive UK wide ChemicalInvestigation Program carried out in 2011–12. If more hazardous chemicals are identified, thenfurther work will need to be carried out to understand the scale of the issue.

— What proportion of each hazardous chemical enters the environment via the sewer network andcan therefore be treated?

— What proportion of each hazardous chemical can be removed by the best available wastewatertreatment technology?

— If further treatment is required, does the cost-benefit analysis suggest that this is best option?

— In the case of pharmaceuticals, what would be the impact of the withdrawal of related medicinesfrom use?

— What is the fate of chemicals that are removed by treatment? Are they broken down intoharmless “daughter” products or do the daughter products represent a separate hazard?

19 http://ec.europa.eu/environment/water/water-dangersub/lib_pri_substances.htm#prop_2011_docs20 Minutes of the meeting of the Hazardous Substances Advisory Committee on 4th September 201221 http://ec.europa.eu/environment/water/water-dangersub/pdf/com_2011_876.pdf22 Executive Summary of the Impact Assessment accompanying the proposal—Commission Staff Working Paper SEC(2011)1546



— Are the chemicals only physically removed into the sewage sludge? Will they potentially findtheir way into the environment via other routes, eg agricultural spreading?

26. Answering the above questions will contribute to assessing the likely impacts of the legislation and helpto forecast the extent of adverse effects. Again, the issue of risk assessment for chemicals is the most importantaspect in targeting potential problem chemicals. Referring only to the hazard information of a substance doesnot consider the actual exposure and hence the risk of harm of the substance to biological systems in theenvironment and humans. Much more research is needed before adopting a treatment based solution.

February 2013

Written evidence submitted by Marine Conservation Society (MCS) (WQ09)

1. The Marine Conservation Society (“MCS”) is the UK charity dedicated to the protection of the UK’sseas, shores and wildlife. MCS campaigns for clean seas and beaches, sustainable fisheries, protection of marinelife and their habitats, and the sensitive use of our marine resources for future generations. MCS produces theannual Good Beach Guide, the Good Fish Guide on sustainable seafood, organises volunteer projects andsurveys such as Beachwatch, the Beachwatch Big Weekend and Basking Shark Watch and works closely withthe UK Government and devolved administrations on the development and implementation of marine lawsand policies.

2. MCS strongly believes that microplastics should be included in this inquiry due to their potential adverseeffects on marine wildlife and human health.

3. Microplastics (defined as plastic particles smaller than 5mm), consist of microbeads from the cosmeticsindustry, plastic pellets produced by chemical companies for use in the plastics manufacturing industry and thedegradation products of larger plastic items.

4. Microplastics in the marine environment can carry two types of organic micropollutants. Firstly,compounds incorporated into plastics during production as plasticizers and their degraded products such asnonylphenols (an endocrine disruptor), and secondly pollutants adsorbed from seawater such as Polychlorinatedbiphenyls (PCBs) and Dichlorodiphenyldichloroethylenes (DDEs).

5. Marine wildlife ingest these products and there is the potential risk that these toxins may bioaccumulateup the food chain, ultimately to ourselves as sea food consumers.

6. The plastic beads used in some cosmetic preparations, hand cleansers and industrial air blast cleaningmedia reach the marine environment through foul water and sewerage systems. Please see the attachment onthis subject by Dr. H Leslie of the Institute of Environmental Studies, Free University of Amsterdam.

7. Unilever has recently stated that there is no place for microplastic beads in their products and has agreedto remove microplastics from their products in the Netherlands by 2013, in Europe in 2014 and worldwide in2015, sooner if possible. Lush in the UK have also removed all plastic particles from their products.

8. MCS together with other environmental NGOs believe that the simplest way to stop the use ofmicroplastics in personal care products is by introducing a Europe wide ban and we are campaigning stronglyon this front. We believe the best way to implement such a ban may be through the Water Framework Directive.

Attached

1. Micro plastics in personal care products—Joint NGO Position Paper.23

2. MICROPLASTICS: an emerging pollutant in municipal wastewater treatment plants.24

February 2013

Written evidence submitted by Severn Trent plc (WQ11)

Our general position can be summarised as:

— It is right that public health should be a national priority and that there should be a continuedfocus on improving water quality standards still further.

— There needs to be a comprehensive cost/benefits analysis undertaken for each substance beforecustomers money is spent on removal. What are the potential health, environmental andfinancial costs of removing a substance balanced against the same costs of not removing asubstance?

— We are proud of the progress we have made with improving water standards in our region, butwe are also conscious of the need to keep our customers’ bills affordable.

23 Not printed. http://www.mcsuk.org/downloads/pollution/positionpaper-microplastics-august2012.pdf24 Not printed



— We would question whether the Commission is taking an over-cautious approach based ontheoretical, not practical, harm. Its’ assumptions should be tested vigorously against broadcriteria. Most of the substances covered by the directive have been present in the environmentover the long term—real evidence of existing harm should be the primary driver for remedialaction.

Our responses to the specific questions posed by the committee are set out below.


1.1 Acceptable thresholds should be set on the basis of demonstrable not theoretical harm, with clearreference to a comprehensive cost benefit assessment of removing or alleviating the source of harm. Thereneeds to be a clear detrimental impact upon river ecology before standards are imposed and these standardsshould be river catchment specific, not universal. Otherwise, our customers may be paying unnecessarily.

1.2 We are concerned that the EU review both the list of Hazardous Substances and their associated standardsevery four years. This does give rise to the real possibility that expensive treatment assets required to meet acurrent standard are rendered obsolete if the standards are subsequently tightened or new substances are addedto the list.


2.1 We would suggest that Government should take the lead in determining how these substances should becontrolled. There is a clear need to weigh up the alternative options of source control (including outright bans)versus removal from the aquatic environment through enhanced wastewater treatment. Whilst the water industryis able to quantify the cost of “end of pipe” treatment, it is not well placed to quantify the cost of usingalternative chemicals in industrial/commercial processes or quantifying the consequences of outright bans.

2.2 Greater emphasis also needs to be placed on understanding the public’s willingness to pay towardsmeeting the higher water quality standards being proposed. Ultimately, it is the general public who will haveto pay, be that through their water bill; via levies raised on the variety of products that contain the proscribedsubstances or (indirectly) for the cost of developing alternative products.

2.3 We firmly believe that the “polluter pays” principle needs to be fully implemented in respect ofHazardous Substances. This could be through a combination of amendments to the Mogden Formula (used todetermine charges for Trade Effluent discharges to sewers) and/or a levy raised directly upon the producers (orimporters) of the proscribed substances. Industrial producers of Hazardous Substances should bear the cost ofcontrolling their effect on the environment. In some respects, this would be consistent with the aims andobjectives of the WEEE (Waste Electrical and Electronic Equipment) Directive in that that the manufacturerretains certain responsibilities after point of sale.

2.4 It is important to note that the lists of Hazardous and Priority Hazardous Substances include a numberof metals (Cadmium, Mercury, Nickel, Copper, Zinc and Lead). It is not possible to eliminate elementalsubstances through wastewater treatment processes. All that can be achieved at a sewage works is to transferthese substances from the effluent discharged to watercourses into another waste stream—ie Biosolids (sewagesludge). All of our biosolids are ultimately recycled, following appropriate treatment and conditioning, toagricultural land. Effective control does need to carefully consider whether or not compliance with WFDrequirements has unintended consequences to the wider environment.

2.5 Historically, the role of the water industry in respect of wastewater treatment has been driven by theneed to protect public health and safeguard rivers from the effects of pollution from human (organic) wasteand our treatment processes are specific to these requirements. Whilst the sewer system has long been used forthe disposal of inorganic trade effluents, this has been as much about diluting these wastes as actually treatingthem. The standard waste water treatment processes are basically physical separation (solid from liquid) andbiological treatment. Many of the hazardous substances now being controlled are not readily amenable toseparation or treatment through conventional sewage treatment processes. Some removal may be achieved byexisting processes (though as much by accident as by design), although not to the levels required by the EUlimits. Taking on a lead role in the control of hazardous substances would be a significant extra responsibilityfor the water industry and procuring the additional treatment technology will come at substantial cost.


3.1 We do not believe that controls over the discharge of pharmaceuticals via sewage works dischargesshould be implemented, unless there is clear evidence of significant ecological damage. We do not believe thata “precautionary principle” approach is appropriate as the cost to the country of such an approach is likely tobe excessive and disproportionate. Where “end of pipe” treatment is genuinely required it does need to beclearly explained to customers what the benefits of this treatment will be the environment. They also need tobe made aware that this is a knock-on effect of the availability of modern medicines.



3.2 We also do not think that it would be appropriate to consider controlling the discharge of pharmaceuticalproducts through better source control on a widespread basis—the wider benefits to society of effectivemedication should take priority over fluvial ecology.

3.3 Whilst it may be possible to develop alternative formulations for certain medications, we are aware thatit can take years or even decades to bring new pharmaceutical products to market.

3.4 In respect of some of the more toxic pharmaceuticals (eg Chemotherapy drugs), that are onlyadministered within a hospital environment, consideration could be given to providing treatment of thewastewater stream prior to discharge into the sewer system where necessary.


4.1 The ongoing £25 million Chemical Investigation Programme highlights the extent of collaboration andinnovation across the water industry within the UK. This programme has carried out extensive work todetermine the prevalence of various Hazardous/Priority Hazardous Substances within wastewater effluents andalso to establish where they have originated from. Further work has been done to establish the effectiveness ofboth existing and new technologies for removing these substances from treated sewage effluent.

4.2 Each water and sewerage company has Research and Development (R&D) funding, which will beprioritised according to pressures on local ecology; opportunities for efficiency etc. Collaborative R&D projectsare run in the UK under the auspices of UKWIR, however collaboration at the wider EU level is less prevalent.

5.0 Has European Commission taken an evidence-based approach to the designation of chemicals thatpresent a significant risk to/via the aquatic environment under the Water Framework Directive?

5.1 Our impression is that the commission has adopted an excessively precautionary approach to thedesignation of chemicals and the setting of EQS standards. We would contend that “on the ground” ecologyassessments should drive the need for further chemical controls, not theoretical assessments of the potentialfor harm to occur. Assessments should be on a catchment by catchment basis, rather than a blanket “one sizefits all” approach.

5.2 We would also question the benefit of adopting the “one out, all out” approach to assessing compliancewith WFD chemical status, especially as compliance is judged on a straight “Pass/Fail” basis. This ultimatelymeans that there is no compliance benefit of making improvements, unless every chemical that is contributingto failure is addressed.

5.3 We remain concerned that the Commission views the Water Framework Directive in isolation from thewider environment. Full implementation of the proposals will inevitably have wider environmentalconsequences, not least in terms of carbon emissions. We don’t see much evidence that a balance is beingstruck (or even attempted) between WFD and the wider environment. As a case in point, the phasing out ofincandescent light bulbs in favour of mercury containing florescent bulbs would not appear to be consistentwith Mercury being on the Priority Hazardous Substance list, with a requirement to phase out emissionsby 2020.


6.1 The new EQS for the Priority Hazardous Substance PBDE (PolyBrominated Diphenyl Ethers—incommon use as flame retardants) being proposed by the EU of 0.000000049ug/l is several orders of magnitudebelow the levels achievable by even the most advanced form of treatment currently available. Initial estimatesfrom the Water Industry led Chemicals Investigation Programme suggest that over 5000 sewage works wouldbecome a cause of WFD chemical failure for this substance. Widespread adoption of Reverse Osmosis to treatfor this substance would cost of the order of £110 billion and would still fail to achieve compliance by at leasttwo orders of magnitude.

6.2 Compliance with many of the proposed new standards will require substantial deployment of energyintensive wastewater treatment processes (unless really significant emphasis is placed upon phasing out thesesubstances at source). This would potentially be incompatible with the country’s carbon commitments, unlesssufficient investment in non-fossil fuel power generation is made to offset this.

6.3 The £27 billion over 20 years being quoted by the Environment Agency for installing the advancedwaste water treatment equipment needed just to treat the pharmaceuticals being proposed as new prioritysubstances is marginally higher than the £25 billion total capital investment being made by the whole industryin AMP5 to meet all of our existing obligations. This equates to a 25% uplift on the industry’s capitalinvestment programme from 2020 to 2040. In addition there would be a significant further upward pressure oncustomer bills to cover the ongoing running costs.

6.4 Some of the chemicals on the Hazardous/Priority Hazardous Substances lists are of industrial rather thandomestic origin (in terms of where they enter the sewerage system). The possibility exists that application ofthe “Polluter Pays” principle to the setting of trade effluent discharge consents (for discharges to the sewerage



system) could act as a disincentive for certain industrial activities to locate to (or remain within) the country.Some consideration does need to be given (by government) to the possibility that the costs associated with theCommissions’ proposals prompt some businesses to relocate production to countries with less stringentregulation.

6.5 We understand that it falls to DEFRA to determine what would constitute a “disproportionate cost” ofdelivering WFD compliance. We would urge that this assessment be progressed as a matter of some urgencyas it will be difficult for the Water Industry to take significant steps in the absence of national guidance onwhat may constitute “disproportionate”. The potential levels of investment that could be required (assumingthat “end of pipe” treatment is the country’s preferred approach), will be substantial and will take a number ofyears to procure. Given this, the potential for infraction proceedings on grounds of a perceived lack of progressdoes exist.

February 2013

Written evidence submitted by British Generic Manufacturers Association (BGMA) (WQ12)

1. Summary

1.1 BGMA believes the only substances which should be subject to control to entering the water systemshould be those where scientifically based investigations show a consistent level of their detection in watercourses in Member States, to a level which can be shown to present harm to the environment or, via theenvironment, to human health.

1.2 The Commission proposes through the Water Framework Directive to apply controls to threepharmaceutical compounds despite the extremely low trace level of pharmaceutical residues found in water.Reports including from the UK Drinking Water Inspectorate and, most recently, from the World HealthOrganisation, have all come to the same conclusion that it is very unlikely that exposure to the very low levelsof pharmaceuticals in drinking-water would result in appreciable adverse risks to human health.

1.3 In addition, and crucially, BGMA believes that when decisions are being considered as to whethercontrols should be applied to pharmaceutical compounds within certain medicinal products, it is necessary toweigh up the potential societal costs of applying such controls on public access to medicines. The EuropeanCommission’s plans have the potential to entail the commitment of resources in excess of £25 billion in theUK alone to meet the requirements proposed in order to address a problem that current evidence suggests doesnot exist.

1.4 As such, BGMA believes that a wholesale review of the scientific basis on which the EuropeanCommission made its proposals is necessary.

2. Introduction

2.1. The British Generic Manufacturers Association (BGMA) welcomes the opportunity to respond to theHouse of Commons Science & Technology Select Committee Inquiry into Water Quality.

3. Our Response

3.1. In responding to the inquiry we have set out our views on the individual questions posed by theCommittee specifically as they relate to pharmaceutical substances although the general scientific principlesunderlying our comments on those specific compounds are generally applicable.

Answers to the Specific Questions Posed by the Committee


3.2.1 The Water Framework Directive (WFD) is the current European legislation for identifying whichchemicals should be subject to control of emissions to the aqueous environment (water system). This it doesby designation of certain substances as “priority substances” and the setting of limits on their concentration inthe aqueous environment. The WFD defines priority substances as substances which “present a significant riskto or via the aquatic environment” and the Directive sets out a number of ways by which significant risk maybe identified.

3.2.2 It is our view that substances should only be designated as priority substances if there are robust datato indicate a consistent level of detection in water courses in Member States, above levels which scientificallybased investigations show to present harm to the environment or, via the environment, to human health. Wherecontrol of the levels of substances in the environment involves restrictions on use, any environmental benefitsfrom restricted use should be weighed against the benefits of use of that substance—this is particularly so inrelation to medicines.




3.3.1 Regulators have the role of identifying those chemicals that pose a potential risk to the environmentand/or human health and, on the basis of sound scientific evaluation, making appropriate proposals for theircontrol.

3.3.2 Government has the responsibility to consider any such proposals in the light of a number of otherconsiderations such as weighing the potential loss of societal benefit of such chemicals against any risks theymay pose and the costs and benefits of applying such controls.

3.3.3 Industry has a responsibility to seek to minimise the impact of its products and operations on theenvironment. In relation to manufacturing, this means controlling emissions to water in accordance withregulatory requirements and industry good practices.

3.3.4 The public has the role of following guidance on proper use, storage and disposal provided withmedicines. There need to be appropriate processes available for patients to dispose of unused medicines.


3.4.1 As mentioned above, the WFD defines priority substances as substances presenting a significant riskto or via the aquatic environment. A proposal from the European Commission to designate three pharmaceuticalsubstances (ethinyloestradiol (used in oral contraceptives), oestradiol (used in hormone replacement therapy)and diclofenac (an anti-inflammatory)) as priority substances is currently the subject of consideration by theEuropean Parliament and the Council of The European Union.

3.4.2 While a number of laboratory studies have claimed a potential risk to the environment forpharmaceutical substances, there is no evidence in actual use of any harm accruing to the environment or tohuman health from the extremely low trace levels of pharmaceutical residues found in water. Specifically, asregards human health, a number of reports including from the UK Drinking Water Inspectorate and, mostrecently, from the World Health Organisation have all come to the same conclusion that it is very unlikely thatexposure to the very low levels of pharmaceuticals in drinking-water would result in appreciable adverse risksto human health. The BGMA view is that the current proposal to include the three pharmaceuticals as prioritysubstances under the WFD is not substantiated and could necessitate significant, costly and unwarrantedintervention by water utility companies.

3.4.3 Notwithstanding our comments above, industry accepts that there is a scientific and societal need toseek to understand as fully as possible the significance of pharmaceutical residues in water. To this end industryhas consistently engaged collaboratively with other stakeholders to improve the knowledge base in this areaand will continue to do so.


3.5.1 In some cases, in-plant treatments, such as granular activated carbon, acid/alkaline hydrolysis andozonation, have been utilised to treat specific substances to meet either local regulations or meet specific waterquality objectives/targets identified by environmental risk assessments when regulatory reference treatment isnot sufficient. In many cases, treatment technology information is shared in the development of Best AvailableTechnique (BAT) Reference Documents to set minimum manufacturing treatment standards across the EU.

3.6 Has the European Commission taken an evidence-based approach to the designation of chemicals thatpresent a significant risk to/via the aquatic environment under the Water Framework Directive?

3.6.1 It is the BGMA view that in relation to the proposal to designate ethinlyoestradiol, oestradiol anddiclofenac as priority substances under the WFD, the approach taken by the European Commission lacked thedegree of scientific rigour that we believe is necessary for designating substances as priority substances.

3.6.2 Existing scientific data on potential impact on the environment posed by the medicinal use of thesesubstances is limited and inconclusive. The Environmental Quality Standards (EQS) set by the Commission inits legislative proposal are based on incomplete data, or on information from published literature that describesstudies that in a number of cases have not been performed according to accepted national and internationalstandards of good laboratory practice. This lack of evidence seems to be confirmed by the EuropeanParliament’s proposal to delete the EQSs initially set. However, we would also question the process establishedto select these three substances for inclusion in the priority substances list in the first place.

3.6.3 If there are no robust data to indicate a consistent level of detection in Member States, above levelswhich scientifically robust investigations show to present a harm to the environment, then the substances shouldnot be included in the priority list. Additionally, leaving the substances on the priority substances list is notthe appropriate tool to obtain monitoring data in order to provide information on potential risk related tochemical substances.



3.6.4 We are well aware that some pharmaceuticals are, by their very nature, potent; but a rigorous scientificapproach to assessing the risk that their use poses should be taken rather than one looking solely at the intrinsichazards of any substance, as we believe has been the case in the current proposal.

3.6.5 Furthermore, we believe that the Impact Assessment performed by the European Commission waslacking in that it did not take account properly of the societal benefits associated with the pharmaceuticalcompounds in question. There is only a very superficial and, in our view, inadequate consideration of these.


3.7.1 As regards pharmaceutical compounds, the Commission’s proposals, as they were presented, wouldhave the potential to entail the commitment of significant resources (estimated at in excess of £25 billion inthe UK alone) to meet the EQSs proposed and to address a putative problem which the current evidencesuggests does not exist.

3.7.2 The Commission’s proposals ultimately would likely have the effect of increasing the NHS drugs billand access to medicines could be inappropriately limited.

3.7.3 The current compromise suggested by the European Parliament would effectively only postpone theimplementation of the Commission’s proposals and would not address the fundamental question of the lack ofrobust scientific evidence to support the proposal.

3.7.4 The adverse effects can only be mitigated by a wholesale review, as discussed above, of the scientificbasis upon which the Commission made it proposals.

4. About the BGMA and Generic Medicines

The British Generic Manufacturers Association (BGMA) represents the interests of UK-based manufacturersand suppliers of generic medicines and promotes the development and understanding of the generic medicinesindustry in the UK. Our 25 members account for around 90% of the UK generics market by volume. Genericmedicines are launched when the patent on a medicine produced by a research-based pharmaceutical (ororiginator) company expires. When a patent expires, generic manufacturers can produce equivalent versionsthat contain the same active ingredient. Generics are tested by the medicines regulator (MHRA) to the samestandards of safety and efficacy as the originator product. The high number of generic manufacturers helpsensure that generic medicine prices are much less than that of the originator version under patent protection.

Indeed, in 2011, the average cost to the NHS of a generic medicine was around £4.00, whilst the averagecost of an originator medicine was about £20. In 2011, if all medicines had been reimbursed at the averagebrand price (instead of the price for the generic version), the NHS drugs bill would have been £10.25 billionhigher. We calculate that a 1% increase in the use of generics would generate a further annual saving of £149million25 to the NHS.

Competition from generics also stimulates the research-based (branded) pharmaceutical industry to developnew medicines (as generics capture the bulk of the market after patent expiry). Furthermore, in keepingmedicines affordable for the Department of Health, this allows further investment in other healthcare priorities,and promotes innovation in the development of new medicines.

Written evidence submitted by the Geological Society of London (WQ13)

1. The Geological Society is the UK’s learned and professional body for Geoscience, with more than 10,500Fellows (members) worldwide. The Fellowship encompasses those working in industry, academia andgovernment with a broad range of perspectives on policy-relevant science, and the Society is a leadingcommunicator of this science to government bodies and other non-specialist audiences.

2. We have not attempted to answer all the questions raised in the Terms of Reference for the inquiry, manyof which are outside our area of competence. We have focused on relevant geoscientific considerations whichwe believe the Committee may find helpful in its deliberations. The main points raised below are:

(i) The importance of an integrated and holistic approach to water quality and remediation.

(ii) The benefits of a catchment based approach in line with the EU’s Water Framework Directive.

(iii) The importance of a joined up approach to water remediation innovation and technologysharing.

(iv) The importance of water quality protection in safeguarding drinking water for the future andpreparing for likely water scarcity challenges.

25 Based on 2001—2011 Prescription Data, published by the NHS Information Centre (July 2012)



What should the acceptable thresholds be and how are these chemicals currently controlled?

3. The monitoring of toxic chemicals in the environment and establishing of thresholds is essential forimproving the ecological status of our waterways in line with the European Water Framework Directive. Thebasis for establishing acceptable thresholds is clearly open to debate. The geoscience community is not directlyinvolved in setting such thresholds, but has an important role offering advice on aspects of complex andvariable water systems at a national and EU level.

4. Surface water exists as part of a wider system encompassing groundwater, oceans, water in the atmosphereand water stored in ice. These sub-systems are pervious to water and the chemicals contained within them, sothe impact of a contaminant should be considered for the whole system when defining threshold limits. It isimportant to consider the impact and behaviour of contaminants in the sub-surface and in the shallow sea forthe provision of clean drinking water and ecosystem services. An unchecked build up of these chemicals mayhave long term impacts on fisheries, sub-surface and coastal fauna and tourism, for instance.

5. Currently, limits are applied on a national or international (EU) basis. In line with the EU’s river basin-based approach to water management, we suggest that because of the geochemistry of water systems and theirinteractions with the environment, the application of blanket thresholds may not be the optimal way to managetoxic chemicals in the environment. Thresholds are usually set by taking a classical risk-based approach tocontamination that cannot always capture the variability of different systems. Local geochemistry may have aconsiderable impact on levels of risk or harm, as properties of water bodies such as pH, dissolved organiccarbon and particulates can have significant effects on concentrations of dissolved chemicals. The varyingresidence times of water in different parts of a system is also significant in considering behaviour ofcontaminants in that system. Changes caused by disequilibrium and external effects can significantly affect theamount of contaminant bioavailable (that is, the degree to which an organism has access to the chemical).Different water catchments are affected by different microclimates and geological heterogeneity, which giverise to distinct geochemical environments. This can significantly affect the behaviour of potentially toxicchemicals. The US Environmental Protection Agency, recognising the heterogeneity of water systems, hasdeveloped a policy of assigning of site-specific threshold limits due to the wide variability in behaviour ofcontaminants.

6. Parts of the UK rely heavily on groundwater for the provision of safe drinking water, so the quality ofthis water resource should not be overlooked. The potential for build up and extended residence times in sub-surface aquifers should be taken into consideration. As a result of environmental change and population growth,pressure on safe drinking water and water scarcity is set to increase in future, adding to the need to safeguardthese valuable resources.

To what extent is innovation in water treatment supported in the UK?

7. Water treatment technology development occurs in both the academic and industrial sector, but isprincipally developed in private sector companies seeking to design and sell economic materials andtechnologies. Whilst private sector development is important, reliance on this sector alone may reduceconsideration of the water system and environment as a whole, and of the long term environmental impacts ofremediation materials and technologies. A more joined up approach between government, academia andindustry would support the generation of technologies which address water quality more holistically.

What likely impacts could the Commission’s proposal have in the UK? How could any adverse effects bemitigated?

8. We welcome the Water Framework Directive’s approach to addressing river quality and management interms of catchment basins, as this functions as a better demarcator for considering ecological status. Such aholistic localised approach could reduce the need for excessively low blanket thresholds, which have beencriticised in the past and are likely to impose a greater financial cost on emitters.

9. Long term impact on delicate ecosystems and on ecosystem services such as fisheries should be consideredwhen setting limits. Insufficient or inappropriate control of new, perhaps poorly understood contaminants couldresult in unforeseen long term impacts on surface and groundwaters. Acting now will also help the futurechallenge of securing safe, clean drinking water in the coming years when water scarcity will be more keenlyfelt.

February 2013



Written evidence submitted by Professor Richard C. Thompson (WQ17)

Marine debris, and in particular plastic debris, is fragmenting in the environment. Much of the debriscollected during survey trawls consists of tiny particles or “microplastic” (Law et al. 2010; Thompson et al.2004). This material was first described by Thompson et al. in 2004 (Figure 1) who identified microscopicfragments on shorelines and in the water column. The definition has since been refined by NOAA in the USAto include pieces or fragments less than 5 mm in diameter(Arthur et al. 2009). The abundance of microplasticsis increasing in the oceans (Goldstein et al. 2012; Thompson et al. 2009a). A horizon scan of globalconservation issues identified microplastic as one of the top global emerging issues (Sutherland et al. 2010)and a recent review for the Convention on Biological Diversity has shown that around 10% of all reportedencounters between marine debris and marine organisms are with microplastics (GEF 2012).



Figure 1

(A) MARINE DEBRIS ON A STRANDLINE WHERE IT FRAGMENTS INTO SMALLER PIECES(B) A FRAGMENT OF MICROPLASTICS NEXT TO A GRAIN OF SAND FOUND ON A BEACH IN

CORNWALL, UK(C) SCANNING ELECTRON MICROSCOPE IMAGE OF MICROPLASTIC FRAGMENTS

Source: R C Thompson.

Microplastic is formed by the physical, chemical and biological fragmentation of larger items, or from thedirect release of small pieces of plastic. This includes, for example, industrial spillage of pre-production pelletsand powders, microscopic plastic particles that are used as abrasive scrubbers in domestic cleaning products(Fendall & Sewell 2009; Gouin et al, 2011) and industrial cleaning applications such as shot blasting of shipsand aircraft (Barnes et al, 2009). Plastic items fragment in the environment because of exposure to UV lightand abrasion, such that smaller and smaller particles form. Some plastics are even designed to fragment intosmall particles, but the resulting material does not necessarily biodegrade (Roy et al, 2011). Microplastics areknown to have accumulated in the water column, on coastal and estuarine shorelines and in subtidal sedimentsworldwide (Andrady 2011; Barnes et al, 2009; Thompson et al, 2004; Zarfl et al, 2011). However there islimited information on their abundance in freshwater habitats including lakes and rivers or from the terrestrialenvironment (Rillig 2012).

Microplastics have a relatively large surface area to volume ratio and are therefore have greater capacity tofacilitate the transport of contaminants. Fragments as small as 2 µm have been identified from marine habitats(Ng & Obbard 2006), but due to limitations in analytical methods, the abundance of smaller fragments isunknown. As a consequence of the fragmentation of larger items and the direct release of small particles, thequantity of fragments is expected to increase in the seas and oceans (Andrady 2011; Thompson et al, 2009). Itis therefore recognised that there are important questions that should be investigated regarding the emissions,transport and fate, physical effects, and chemical effects of microplastics (Zarfl et al, 2011).

Due to their small size moicroplastics have the potential to be ingested by a diverse range of organisms.Laboratory experiments have shown they are readily ingested by filter feeders, deposit feeding worms anddetritivores (Thompson et al, 2004). Work with the common mussel (Mytilus edulis) has shown that after asingle pulse exposure ingested microplastics can be retained for periods in excess of 48 days (Browne et al,2008). Microplastics have also been reported in natural populations of commercially important crustaceans(Murray & Cowie 2011) and fish (Lusher et al, 2012) as well as in sea birds (van Franeker et al, 2011). It hasbeen suggested that ingestion could lead to direct physical harm and may also facilitate the transport ofchemicals to organisms.



Plastics contain a variety of potentially toxic chemicals incorporated during manufacture (monomers andoligomers, bisphenol-A (BPA), phthalate plasticisers, flame retardants and antimicrobials) (Lithner et al, 2011),which can be released into the environment. These chemicals can be transferred to humans through, forexample, plastic containers used for food and drink, plastic used in medical applications, and plastic toys(Koch & Calafat 2009; Lang et al, 2008; Meeker et al, 2009; Talsness et al. 2009). Hence, a hazard could existif plastic fragments containing these chemicals are ingested by marine organisms (Oehlmann et al. 2009; Teutenet al, 2009). Research has shown that chemicals used in plastics, such as phthalates and flame retardants arepresent in fish, mammals, and molluscs, raising concerns about subsequent toxic effects (STAP 2011). Thereis limited evidence to confirm a direct link between the chemical characteristics of marine debris and adverseeffects on marine life (Besseling et al, 2013). However, experimental studies have shown that phthalates andBPA affect reproduction in all study species, impairing development in crustaceans and amphibians, andgenerally inducing genetic aberrations (Oehlmann et al, 2009). If these impacts were identified in the naturalenvironment it would pose a substantial problem, as no option exists for remediation due to the nature of theaccumulation of debris within the marine environment (GESAMP 2010; Thompson et al, 2009b). It is thereforeconcerning that concentrations of these substances in the marine environment have been found to match thoseidentified as harmful in laboratory studies, inferring that they could be impacting natural populations (Oehlmannet al, 2009).

In addition to the potential for release of additive chemicals, plastic debris can adsorb persistent,bioaccumulative and toxic substances, including persistent organic pollutants (POPs) that are present in theoceans from other sources. Within a few weeks these substances can become orders of magnitude moreconcentrated on the surface of plastic debris than in the surrounding water column (Hirai et al, 2011; Mato etal, 2001; Rios et al, 2010; Teuten et al, 2009). This presents a second mechanism that may facilitate thetransport of chemicals to biota upon ingestion. Laboratory studies have shown that very small quantities ofplastic (ppm) have the potential to increase the transport of sorbed contaminants to marine organisms. Howeverthe role of plastics as a vector is context dependant and is influenced by the availability of other particulates,in particular carbon. The potential for chemical transport varies according to the polymer type (eg PE >> PP> PVC) (Teuten et al, 2007). However, the influence of the surrounding physical environment for example theeffect of temperature, salinity and competition with other particulates is not clear (Bakir et al 2012). Henceour understanding of the extent to which plastic particles facilitate the transport of contaminants in the naturalenvironment is uncertain, and more work is required to establish the relative importance compared to otherpathways.

February 2013

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