Table of contents
1. Executive summary
A stable and reliable food supply in Europe has over recent decades become normal. This has been achieved in many cases by the use of pesticides to control pests, weeds, and diseases, plus fertilisers to supply additional nutrients. Pesticides play an essential role in the food production process, maintaining or enhancing crop yields in conventional arable farming. However, they can also lead to harmful effects in the environment, including aquatic ecosystems and risks to human health. There is now widespread concern about the addition of a substance to the environment designed to be toxic to some part of the ecosystem.
European policies aimed at reducing the potential risk from pesticides mainly lie under the Plants Protection Products Regulation (EC, 2009b), the Sustainable Use of Pesticides Directive (EU, 2009) and the Biocidal Products Regulation (EU, 2012). The Water Framework Directive (WFD) (EC 2000) and its daughter directives add legislation to protect water quality. There is however, little evidence to show whether this legislation has been effective, mainly because of a lack of data to demonstrate the actual risk of pesticides in surface waters and groundwater at the European level (EEA, 2018a). Addressing this gap is of high interest for policy, practitioners, and the public owing to potential risks pesticides present to both the environment and public health.
-
- stable food supply is also partly caused by imports of food into the EU.
- may be good to be more precise when talkign about pesticides. The PPP legislation in the EU also covers microorgsnisms (wider scope than chemical pesticides), but the report concerns chemical pesticides.
-
Suggest to also mention organic farming for completeness.
"However, they can also lead to harmful effects in the enrivonment..." Investigation of possible adverse side effects on non-target organisms and the environment are part of the approval process of pesticides. In case a pesticide is not safe for the environment, it will not be approved. Therefore, this statement is misleading and biased.
Although the report is meant to assess pesticide effects in particular it would be good to also mention the risk of chemicals of various origins to set the right context.
This technical report provides an overview of the information available on pesticide concentrations in surface and groundwaters in EEA countries.
EEA’s Waterbase – Water Quality database contains the most reliable data available from across Europe. For the assessment, 180 pesticide substances were selected and characterised according to their usage, their Mode of Action (MoA), their chemical grouping, and their environmental quality standards (EQS) under consideration of the reported analytical limits of quantification (LOQ). The methods for the quality assurance of data, selection criteria and extraction, as well as the assignment of targets and calculation of exceedance rates under consideration of LOQ resulted in a unique database, and can be seen as a starting point on how to assess pesticide risk in surface waters and groundwater in Europe. EQS are based on European standards where available, and then on national EQS values (using the lowest value as a precautionary approach). The data suggest that for the period 2013 – 2017 for surface waters, 5 – 15 % of monitoring stations could be affected by herbicides and 3 – 8 % by insecticides. For groundwater the shares are about 7 % for herbicides and below 1 % for insecticides. Fungicides seem to be of lower importance.
-
For groundwater, the "affection" is only related to the concentration exceedance of the drinking water limit of 0.1 µg/L
-
In our opinion this approach is scientifically incorrect.
It suggests that everything but the lowest EQS is not safe enough and only the lowest EQS is correct. It therefore undermines the authority of those institutions in member states that have set a higher EQS.
Furthermore this approach potentially generates misleading information as it will result in higher EQS exceedances than reported on the national level.
EQS exceedances should be calculated by considering the respective national EQS values.It sholud be made clear what "affected" means in this context. Does it mean EQS exceedance? Does it mean exceedance of 0,1 µg/L for groundwater? Or does it mean "detected"?
This analysis contrasts with the results of status assessment of the 2nd River Basin Management plan 2016 under the WFD, which show 0.5% of all surface water bodies failing good chemical status because of pesticides, and 15% of groundwater bodies (EEA 2018).
The report also lists a number of other data sources for pesticides, especially scientific research and emissons data. They are diverse and often have limited spatial coverage, which make such data less representative for a European status assessment.
The aim of this work is to provide a baseline for what we know of measured concentrations of pesticides in water at the European level.
-
Perhaps explain the reason for this discrepany in paragraph 1
-
(Austria) If not anyhow foreseen, please provide a list of abbreviations.
-
Did the 2018 report use national EQS or the lowest available EQS to calculate chemical status?
In general, initiatives/actions of industry (e.g. product stewardship programs, e.g. for S-metolachlor, bentazone, chlorpyrifos) to farmer and advisory services, TOPPS Prowadis, Round Table Initiatives in DE and AT) to reduce/avoid entries of PPP in surface and groundwater are not mentioned
in this report.There are numerous recommendations to improve water monitoring – generally considering the need for intensification, diversification and implementation of strategies for improving focus of monitoring, we note that these recommendations are more easily made and less easily resourced…
In our view improvements in monitoring focussing simply upon expansion of surveillance in the diverse databases discussed in the report without ability to obtain further information to place detections or exceedances into context is not necessarily a meaningful advancement
To address this there should be a companion emphasis on greater transparency (besides the analytical strategy issues which are considered in the report we would add the need for more transparency on aspects such as sampling strategy, location and temporal context) so that follow up efforts may be supported to better understand and address detections/exceedances. This is a frequent limitation and does not get the attention that it deserves in this report
There is also discussion about adjustment of focus of monitoring to consider metabolites more frequently – we would again, return to the need for greater transparency regarding context as discussed above and, in particular, the need for coherence with monitoring of parent substance(s) noting that some common metabolites arise from diverse individual active substances. When focussing upon metabolites there is an even greater need for background context.
There is some discussion about management of chemicals through “measures” schemes designed to reduce or eliminate occurrences or detections. We recommend that blunt and simplistic index measures are avoided and suggest the promotion of greater need for intensive interpretation of high quality monitoring datasets focussing on better understanding the issues arising in individual catchment and how these may support or adjust action to be taken – at a minimum for validation purposes
There is some discussion of schemes like this – a supporting discussion on how monitoring was used to validate these schemes would have been an appropriate and helpful addition in the context of these discussions.
It is noted that there is need for a companion discussion on funding mechanisms to promote or implement these measures. This is a commonly encountered issue with risk management – any discussions on implementation of measures must factor in farmer motivation. This is often side-stepped but is, in fairness, noted very briefly in this report with suggestion that this could be addressed as a component of revision of CAP. Further national case studies showcasing successful farmer support frameworks for action could be presented to support further discussions.
"maintaining or enhancing crop yields and protecting quality in both conventional and organic arable farming"