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Box 4.4: Where are the pesticides in 2nd RBMPs?
Pesticides do not appear as a significant cause for failure to achieve good (chemical) status of water bodies, despite expert views that pesticides – substances designed to eliminate part of an ecosystem - should be of concern. Why don’t we see this in the data?
Fig B3.4 shows numbers of water bodies where pesticides cause failure to achieve good status, in surface and groundwaters
Numbers in parentheses are the number of Member States reporting failures owing to that substance.
Why do we see this? Possibly because…
· Restrictions and changed practice have been enacted on many of the substances measured, these controls have been effective and releases to water are reduced;
· Restrictions mean that the monitored substances do not reflect the pesticides actually in use, so the monitoring misses important information;
· Monitoring frequency (typically up to 12 times per year) misses the limited period for which a pesticide is typically in use;
· WFD monitoring takes place in larger waterbodies, rather than small streams;
· Averaging concentrations over the year means threshold standards for chronic exposure are not exceeded;
· Differences in uses of pesticides across the EU mean that for any particular pesticide, there are relatively few records, which means that apparent significance at EU-scale is smaller than for other substances.
· National EQS or threshold values vary so difficult to get comparable picture.
From the RBMP assessments, we could conclude:
Reporting is correct – concerns about pesticides are over-stated. Measures have been effective.
Reporting is correct on reported substances, but we lack information on many other pesticides.
Reporting of status is inaccurate, owing to monitoring not reflecting situation during peak periods of pesticide use.
But, from the reporting, we cannot be sure which of these apply.
Notes
1) Shown are where at least 50 surface water bodies failing for pesticide https://tableau.discomap.eea.europa.eu/#/site/Wateronline/views/WISE_SOW_PrioritySubstance/SWB_SWPrioritySubstance_Europe?:iid=2
2) Shown are where at least 50 surface water bodies failing for pesticide https://tableau.discomap.eea.europa.eu/#/site/Wateronline/views/WISE_SOW_FailingRBSP/SWB_FailingRBSP?:iid=1
3) Shown are where at least 25000 km2 groundwater bodies failing for pesticide https://tableau.discomap.eea.europa.eu/#/site/Wateronline/views/WISE_SOW_gwPollutant/GWB_gwPollutant?:iid=1
4) EU pesticides database http://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/public/?event=activesubstance.selection&language=EN
5) Tributyltin is a biocide which was mainly used to combat marine biofouling.
6) Imidacloprid is approved but use severely restricted since 2013 https://ec.europa.eu/food/plant/pesticides/approval_active_substances/approval_renewal/neonicotinoids_en
7) Active substances in pesticides, including metabolites, where the concentration of any individual exceeds 0.1 ug/l or the sum of total measured exceeds 0.5ug/l
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DE-UBA IV 1.2:
legend of box 4.4:
a) Why are some substances beginning with an uppercase and others not?
b) Isoproturon is still under review in the biocides legislation. This means that this substance can be used as material preservative in biocidal products at least until a final decision about the approval is made.
c) Diuron is still under review in the biocides legislation. This means that this substance can also be used as material preservative in biocidal products at least until a final decision about the approval is made.
d) Imidacloprid is approved under the biocides legislation until 07/2023. This means that this substance can also be used as insecticide in biocidal products at least until 07/2023.
e) Cypermethrin is also approved under the biocides legislation.
f) 'Possibly because...' Monitoring frequency:
Please consider PPP are mainly used in spring, summer and autumn. Biocides can be emitted to surface waters also in winter. Therefore, a monitoring of about 12 months is regarded as neccessary.
DE-UBA IV 1.2:
conclusions box 4.4
What does this list mean? The first possible conclusion contradicts the second possible conclusion is that not all pesticides are covered within the acutal monitoring program.
In this list they are both indicated as possible conclusions with the same right to be drawn. In our opinion, the concerns about pesticides are underestimated and that should be made clear.
DE-UBA IV1.3:
a) With a view to the conclusions in Box 4.4, some practical problems existing especially for some inseciticides could be substantiated here. For example meeting the very low limits of quantification and the importance of measuring non persistent but very potent substances within their period of use.
b) Please give also information about the registration/use of the substances as biocides.
c) in the legend it is not clear what the numnbers in the paranthesis [ e.g. RBSP (2)] means, possibly the footnotes are ment? Please then indicate as footnote properly.
d) 'WFD monitoring takes place in larger waterbodies, rather than small streams'
Please add : ..., for example adjacent to agricultural areas.
e) Footnote 7 should be augmented: "Unspecifierd active substances or metabolite, where the concentration of any individual exceeds 0.1 ug/l or the sum of total measured exceeds 0.5 ug/l." to also be valid for ground water treshold exceedance. Perhaps in addition an explanation could be given in the text.
DE-UBA:
in the text it is referred to the box as: 'way that water and pesticides legislation affects reporting at the European level (Box 3.4).'
Please verífy whether the box should be labelled 3.4 instead of 4.4.
DE-UBA:
'Why do we see this? Possibly because'
We would welcome, if 'this' could be further specified here.(Meant is the relatively low failure rate due to pesticides)
The first assessment of monitoring data for the watch list can contribute to the info seen in the 2nd RBMPs and also to the questions raised. https://ec.europa.eu/jrc/en/publication/review-1st-watch-list-under-water-framework-directive-and-recommendations-2nd-watch-list
Imidacloprid as an example: According to box 4.4 only 2 MS report failure of status due to imidacloprid. However, a majority of MS report monitoring data exceeding the PNEC for the watch list. Thus, the RBMPs do probably not reflect actual risks. This could be due to varying interpretations regarding what “significant quantities” mean, lack of info regarding pressures, different EQSs used (last assessments under PPP and BD published 2014 and 2015, it is thus likely that new data just recently became available), but also that the substance is on the watch list and that MS due to that do not consider the substance as a RBSP awaiting potential status as PS.
Figure B3.4
According to the EU Regulation – active substances atrazine, alachlor, metolachlor, mecoprop, hexachlorobenzene, endosulfan, HCH, isoproturon, tributyltin are not approved. Therefore additionally evaluation would be important – to check why substances are still occurring in waters (besides the properties and behaviour, approval in biocides...).
Instead of Pesticides” to use active substances
There in the figure are mixed 2 different kind of information: classification of substances (Priority substances, RBSPs) and number of failing water bodies. We suggest to split the figure for surface water and groundwater (there were no a case, when priority substance was a reason of failing in SW body and also in GW body parallel?
Atrazine was not detected in failed SW bodies ?) Based on information from the EEA Report: European waters – assessment of status and pressures 2018, there in the figure B3.4 is missing information e.g. – Atrazine was a reason of failure to achieve good status in 9 surface water bodies (4 countries) (should be marked with dark- blue colour), alachlor was a reason of failure to achieve good status in 5 surface waterbodies (3 countries) (and also should be marked with dark- blue colour) please harmonize results with EEA status assessment.
Notes should be moved below figure.
There is also information about number of failed water bodies for RBSPs – whose assessment is based on national criteria, that can be set with great differences. This is an example how only statistical presentation could be incomparable.
There in the figure could be also added information how many countries are influenced by failure to achieve good status in surface water bodies (also in brackets e.g. SW: Atrazine (9, 4).