4. Strategies to reduce chemical pollution of water

4.1 Introduction

A range of legislation exists to protect water from chemical pollution (section 1.3). At EU level, the legislation both:

protects against pollution in one country being transferred downstream to another; and
ensures that similar, minimum standards apply in Member States, avoiding unfair competition where weak standards give advantage to polluters compared to others meeting more stringent standards.

The EU’s 7th Environment Action Programme (EU, 2013a) mandated the European Commission to develop "a Union strategy for a non-toxic environment that is conducive to innovation and the development of sustainable substitutes including non-chemical solutions."

Alongside this, the EU action plan for a circular economy contains measures covering the whole product cycle: from production and consumption to waste management and the market for secondary raw materials (COM, 2015). Seen in this light, harmful chemicals used in products can present a barrier for materials to be recycled. Finding new ways to deliver the desired benefit represents opportunity for innovation (box 4.1).

Radically rethinking our existing approach to chemicals has followed. From an environmental perspective, given the thousands of chemicals in daily use, it is not sustainable to regulate a chemical, then measure it in the environment and assess whether it is causing harm. However, managing the current situation into the next few decades requires dealing with chemicals already in use (Box 4.2). The following sections describe some EU and national approaches to limiting the harm presented by chemical pollution.

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Box 4.1 Chemical innovation for sustainability

Sweden has recently established a Chemical Substitution Centre at the state-owned RISE Research, to help smaller companies replace hazardous chemicals. The Centre aims both to stimulate the development of sustainable chemical products, production processes, articles and non-chemical methods, and to build capacity in the public and private sector. This will contribute to developing greener products and a circular economy. 

One example is to find and implement better alternatives for the problematic, highly fluorinated compounds such as PFAS in consumer goods such as textiles, cosmetics and food-packaging.

  • sommelin (Linda Sommer) 26 Sep 2018 11:19:19

    DE-UBA IV 1.1:

    A further example for a box could be:

    The International Sustainable Chemistry Collaborative Centre ISC3 acts with an even broader approach: initiated by the German Environment Ministry (BMU) and Environment Agency (UBA), launched in 2017, the ISC3 promotes and develops sustainable chemistry solutions worldwide. Located in the UN City Bonn, with hubs for innovation, for research and education, and regional hubs in other UN regions, the Centre is a globally acting institution, multi-stakeholder platform and think tank. It manages a knowledge platform and a network of experts, offers training and support for implementation especially for developing countries, carries out innovation scouting activities to discover new technologies, processes and business models. The ISC3 is a partner for industry and politics as well as for the civil society and research, and it connects stakeholders to jointly develop new solutions e.g. for climate protection, energy generation, mobility and food supply.

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Box 4.2 – Chemicals for a sustainable future

A recent EEA Scientific Committee concluded:

Regulation of chemicals is entering a new phase as we better understand the diversity and persistence of substances in the environment. Key issues are :

Chemical production is increasing and poses risks to ecosystems and human health.

European legislation has reduced acute pollution, but chronic, less apparent effects persist.

Environmental and societal megatrends are changing exposure patterns.

Chemical risks are traditionally underestimated by science.

A focus on critical parameters is more important than gathering more general data.

Monitoring for a wider variety of chemicals can provide earlier warnings.

Policy approaches need to be further integrated in support of sustainability objectives.

Avoiding upstream use of persistent and hazardous chemicals is key.

A less toxic environment requires visionary and inclusive stakeholder approaches.


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4.2         EU strategic approach to pharmaceuticals in the environment

The 2013 Priority Substances Directive required the European Commission to develop a strategic approach to pollution of water by pharmaceutical substances, with expectation that the strategy would be developed by 2015. (The strategic approach was scheduled for adoption by the Commission in 2018, but at the time of writing no date for adoption has been set.) Cutting across health and environment legislative policies, pharmaceuticals in the environment is a “headline grabbing” topic where balancing the needs of different stakeholders is challenging and essential. Building understanding and developing effective, proportionate actions across different areas requires resources and high level commitment. While the EU level approach is being developed, Member States continue to develop actions relevant to their competence.

4.2.1.     The issue
Pharmaceuticals are used to improve the health of both humans and animals. Once taken, the medicine and its breakdown products (“metabolites”) are excreted in urine and fæces. Where there is urban waste water treatment, sewage is treated and the medicine and its breakdown products may be broken down further. Substances remaining may then be discharged into the environment, in effluent or as sewage sludge applied to land. 

EU medical products regulation (EC, 2004) requires environmental risk assessment for veterinary medicines, but that is not currently required for human medicines.  This in part reflects the tensions in priorities between the benefits of health care and risks to drinking water resources and ecosystems. As understanding of the potential effects of very low levels of pollutants has increased, so has concern about release of biologically active molecules into the environment.

4.2.2.     Member State responses
There was collaboration between Member States and the Commission well in advance of the Priority Substances Directive (EU, 2013b). Two-way communication – advising of concerns and learning about them – is part of a well-functioning, high level process. Possible EQS values were prepared, and although these did not become legally binding, they are used to indicate whether there may be concentrations of concern.

To differing extents, Member States were investigating concentrations of medicines in their surface waters. For example, further to investigations into effects of a contraceptive pill ingredient, EE2, on fish, work in the UK considered waste water treatment and socioeconomic impacts of pharmaceuticals in the environment (Environment Agency, 2008; Gardner et al, 2013; Defra, 2015). In Germany, between 2013–2015, concentrations of several pharmaceuticals were compared with possible EQS, revealing isolated cases where EQS were exceeded for carbamazepine (an anti-epileptic), clarithromycin, the contraceptives E2 and EE2, and more frequently in the cases of diclofenac and ibuprofen (Figure 3.2).

Figure 4.2      Pharmaceuticals in German Surface Waters: Comparison of annual concentration means at surveillance monitoring sites with possible  environmental quality standards


 Source: Waters in Germany – Status and Assessment. Federal Environment Agency, 2017. https://www.umweltbundesamt.de/sites/default/files/medien/377/publikationen/171018_uba_gewasserdtl_engl_bf.pdf

  • sommelin (Linda Sommer) 26 Sep 2018 11:33:28

    DE-UBA IV 2.2:

    Last paragraph:

    Please emphasise the need for a european strategy in the last paragraph, by e.g.

    'While the EU level approach is being developed and urgently needed,…'


  • sommelin (Linda Sommer) 26 Sep 2018 11:37:38

    DE-UBA IV 2.2:

    “ EU medical products regulation (EC, 2004) requires environmental risk assessment for veterinary medicines, but that is not currently required for human medicines.'

    This statement is not correct. Could it be that the envrironmental risk assessment (which ist required for both veterinary and human) was confused with the Risk-Benefits-Analysis?

    Please change to:“EU medical products regulation (EC,2004) requires environmental risk assessment for human and veterinary medicines. However, environmental risks are only taken into account within the risk-benefit-analyses for veterinary medicines.”

  • sommelin (Linda Sommer) 26 Sep 2018 11:38:28


    Figure 4.2:

    - figure legend is in German

    - figure title it should be proposed instead of possible


  • Bertrand Vallet (invited by Caroline Whalley) 28 Sep 2018 11:36:38


    "This in part reflects the tensions in priorities between the benefits of health care and risks to drinking water resources and ecosystems"

    Risks are not only for drinking water resources but for water resources in general. The effects of pharmaceutical through drinking water are a research topic and should not be claimed as such in the report.

    We ask that the word "drinking" is removed, not to focus the attention only on drinking water.

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4.3.         National Action Plans to reduce risks from pesticides[1]

EU legislation can require Member States to derive national approaches where that is appropriate. For example, the "Sustainable Pesticide Use Directive" (EC, 2009b) required that Member States introduce National Action Plans, setting objectives, measures and timelines to reduce risks for human health and the environment by the end of 2012.

- training of users, advisors and distributors
- inspection of pesticide application equipment
- the prohibition of aerial spraying
- the protection of the aquatic environment and drinking water
- limitation of pesticide use in sensitive areas
- information and awareness raising about pesticide risks
- systems for gathering information on pesticide acute poisoning incidents, as well as chronic poisoning developments, where available.


  • sommelin (Linda Sommer) 27 Sep 2018 09:29:52

    DE-UBA IV 1.3:

    We would welcome an example (perhaps a box) of how actions within the national action plans contribute help to gain knowledge abut the risk from pesticides and derive measures to reduce them. The German representative monitoring for the pollution of small water bodies in the agricultural landscape (pilot study, KGM) would be such an example.

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4.3.         National action programs for combating risks from micro-pollutants

To protect their citizens and the environment, some Member States have initiated national programmes and strategies to reduce the risks posed by substances harmful at low concentrations (“micropollutants”). Examples of such programmes are:

The Swedish MistraPharma Project 2008-15 worked to identify human pharmaceuticals that are likely to be of concern to aquatic ecosystems, and addressed the risk for antibiotic resistance promotion in the environment[2]. It also proposed risk management strategies, in particular improved regulatory test requirements and waste water treatment technologies.

In France, a comprehensive monitoring program was established on micropollutants, the “National plan against micro-pollutants 2016- 2021”[3]. It aims to reduce micro-pollutant emissions in order to protect water quality and biodiversity to preserve water quality and biodiversity.

In Britain, United Kingdom Water Industry Research (UKWIR) collaborate upon the “Chemicals Investigation Programme” (CIP), as a response to current and emerging legislation on trace substances in the water environment, bringing together water and waste water companies in England and Wales with regulators (Gardner et al, 2012, 2014). CIP phase 1, 2010-14, obtained a comprehensive view of concentrations in effluents for over 70 contaminants, finding that the principal source of many trace contaminants is domestic. The second phase, comprises sampling of 74 substances at over 600 sewage treatment plants. Substances of interest include metals, industrial chemicals such as fire retardants and biocides, hydrocarbons, pharmaceuticals, hormones and personal care products. The research program has examined several novel waste water treatment techniques that can be used to supplement existing processes.

The Pharmaceutical Chain Approach is a Dutch strategy, which considered the life cycle of pharmaceuticals from development, authorisation, prescription, use and wastewater treatment. End of pipe measures, e.g. wastewater treatment are seen as complementary to measures in the health sector. With a focus on pharmaceuticals a set of programs was started in the Netherlands. These are inter alia the programs: medicines out of water’s, public communication strategies on the reduction of antibiotic use and substitution of certain drugs by others that are less harmful to the environment (Grinten, et al., 2016)[4].

  • sommelin (Linda Sommer) 26 Sep 2018 10:31:51


    Please add the German "Spurenstoff-Dialog" (Micropollutant-Dialogue)

  • sommelin (Linda Sommer) 26 Sep 2018 11:51:40

    DE-UBA II 2.2:

    We strongly suggest to add the German Trace Substance Strategy:

    The German Trace Substance Strategy is being developed on the basis of a multi-stakeholder dialogue, with stakeholders from industry, environmental NGOs, associations of municipal companies, drinking water suppliers, operators of wastewater treatment plants, federal government departments, public authorities and Federal States representatives. The strategy’s purpose is to prevent and reduce inputs of trace substances from biocides, human and veterinary pharmaceuticals, plant protectants, industrial chemicals, detergents and personal care products to the aquatic environment. Guided by the precautionary principle and the polluter-pays-principle, both of which are enshrined in EU and in German law, the stakeholders have developed recommendations for measures at the source, on the user side and at the end of pipe1. These recommendations are now further concretised in a follow-on phase.

    1 German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (June 2017): Policy Paper - Recommendations from the multi-stakeholder dialogue on the trace substance strategy of the German federal government: To policy makers on options to reduce trace substance inputs to the aquatic environment. http://www.bmu.de/fileadmin/Daten_BMU/Download_PDF/Binnengewaesser/spurenstoffstrategie_policy_paper_en_bf.pdf

  • sommelin (Linda Sommer) 26 Sep 2018 13:38:10

    DE-UBA II 2.2:

    We suggest to delete the reference to Grinten, 2016 in the paragraph about the Dutch Pharmaceutical Chain Approach. 

  • hatfisim (Simon Hatfield) 05 Oct 2018 11:15:59

    P63, 3rd bullet: The CIP programme was also run in Scotland, and CIP2 is on-going in England, Wales and Scotland with plans afoot for a third CIP from 2020 to 2025.

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4.5         Summary

Regulation to protect water quality is core to protecting public health and the environment. Many approaches are possible: the challenge now is perhaps to ensure that there is coherence between different activities. While the WFD greatly facilitates coherence in water management, activities around chemicals may not be so well aligned. For instance, efforts to reduce air pollution may lead to discharges to water when pollutants are filtered out of gaseous emissions. 

It should be understood that the cycling of chemicals “from cradle to grave” can lead to water pollution if not adequately managed. Long term strategies towards a circular economy and a non-toxic environment hold the promise of ceasing chemical pollution in future. However, for the medium term, practical approaches to preventing pollution by existing products and substances continue to be required.

[1]https://www.nap-pflanzenschutz.de/en/about-the-national-action-plan/regulations/european-regulations/directive-2009128ec/ accessed 25/03/2018)
[2] http://www.mistrapharma.se/ (accessed 26/03/2018)
[3]https://www.ecologique-solidaire.gouv.fr/sites/default/files/National%20plan%20against%20micropollutants%202016-2021%20to%20preserve%20water%20quality%20and%20biodiversity.pdf  accessed 29/08/2018
[4] https://www.daarwordtiedereenbetervan.nl/ (26th March 2018)

https://jamdots.nl/view/239/Medicijnresten-uit-water (26th March 2018)

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