Table of contents
2. Introduction
2.1 Problem context
Pesticides are a topic of considerable policy interest across environmental, agricultural and human health legislation. There is widespread interest in pesticides from regulators, farmers and the public owing to potential risks they present for both the environment and public health. Under the Water Framework Directive, pesticides are second only to nitrates in causing most failures of good chemical status in groundwater (European Commission, 2019).
For a topic of such interest, at a European level we know surprisingly little about the actual levels of pesticides in surface and ground waters. The sorts of reasons impacting on our knowledge include:
- Countries monitor a number of different pesticides, but the reported data on pesticide concentrations in waters are very different in quality and quantity and therefore difficult to harmonise to obtain an established European overview.
- Pesticide use depends on the crop type, season, weather and equipment availability. Some estimates of pesticides in the environment are based on sales data, but this gives very little indication of actual use or concentrations and toxicity of pesticides in water.
- Monitoring and assessment of pesticides in surface waters is mostly done routinely, but pesticide peaks in surface waters can only be identified by event-based monitoring, such as following heavy rainfall.
- Pesticide pollution from point sources could also be attributable to substances used in biocide products (e.g. household products, facade paint, gardening), which enters the water cycle mainly through discharges from urban waste water treatment plants (UWWTP), storm overflow or urban run-off. There is limited understanding of the significance of such contributions relative to those from agriculture.
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Chemical interactions and transformations between the active substances of pesticides as well as their synergism, enhancement and antagonism mechanisms are little known. Thus, the final product of these interactions may not be detected in monitoring.
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UBA-IV1.3: An additional aspect might be added: the role of pesticide metabolites. Particularly those of no or unknown toxicological relevance (non-relevant metabolites) might be underestimated in their impact, i.e. for water supplying companies and with regard to water processing or mixtures in the field. Despite of frequent detections of particular metabolites in relatively high concentrations, the monitoring data basis is scarce and heterogeneous.
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In addition, the main entry route of pesticide in surface waters depends on the application type, the physico-chemical characteristics of the substance (mobility, persistence, volatility), and on soil features (e.g. organic carbon content) and on the weather conditions at and after the application.
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Some authors argue that, despite a considerably lower application, the loads of urban pesticides and biocides are in the same range as agricultural pesticides. See for example:
Blanchoud H, Moreau-Guigon E, Farrugia F, Chevreuil M, Mouchel JM: Contribution by urban and agricultural pesticide uses to water contamination at the scale of the Marne watershed. Sci Total Environ 2007, 375:168-179.Wittmer IK, Scheidegger R, Bader H-P, Singer H, Stamm C: Loss rates of urban biocides can exceed those of agricultural pesticides. Sci Total Environ 2011, 409:920-932..
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"...interest in pesticides from regulators..." should also mention the benefits they bring in regard to food security.
There are industry data bases for a large number of pesticides submitted as part of the EU approval process, which complement Member State monitoring - this gives good complementary data and a good view on concentrations in surface and particularly groundwater. It is not correct to say that "we know surprisingly little".
The toxicity of pesticides in water is determined in a significant number of different tests, according to the requirements of the relevant Regulations under Regulation (EC) No. 1107/2009 and Regulation (EU) 528/2012. These tests cover different taxa and the complete food chain. All these tests are done in a dose/response design which enables the accurate determination of toxicity and no effect levels. Therefore, it should not be stated that the toxicity of pesticides is somehow unclear.
Point sources of PPP (excl. biocides) as possible entry sources such as farmyard runoff, spill overs, accidents, illegal disposal of spray liquid remnants or cans, are not explicitly mentioned but could be excluded for clarity.
Alongside these specific issues, there is also concern about the role pesticides may play in mixture toxicity. Existing environmental quality standards apply to single substances but in the environment, organisms are exposed to chemical mixtures. We know little about the combined effects of such mixtures but there is a risk that chemicals could combine to reach harmful levels (EFSA, 2019; EEA, 2018a; Busch, 2016; Kortenkamp, et al., 2009b). Given the uncertainty but the knowledge that pesticides are harmful to at least part of an ecosystem, application of the precautionary approach would seem appropriate.
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Maybe to reshape last sentence to be clearer.
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Regarding this paragraf maybe to conclude that since we know little about impact of mixtures, they are not in scope of this report. Or to add in chapter 2.2 - last sentence: "Other chemicals and mixtures which may be present in the water are out of scope of this technical report".
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the last sentence of this paragraph is out of the scope of this report, which shoudl be factual and refer to results.
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Last sentence: EQS are already precautionary with high safety values. These are able to cover any mixture effects.
2.2 Aim and scope of the report
The aim of this technical report is to provide an overview of information available on pesticides in surface and groundwater, based on reported information. This report includes descriptions and assessments of available data from different data and information sources with a focus on the European level.
The focus of this report is on active pesticide ingredients in agricultural activities (see section 2.3 for definition). It needs to be mentioned, that once a substance reached the environment, it is not usually possible to ascertain the original source or use of it. Organisms experiencing the resultant mixture do not discriminate by source, though such information is helpful in identification of appropriate prevention measures. Other chemicals which may be present in the water are out of scope of this technical report.
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Active pesticide ingredients - better to use the term active substances in line with Reg 1107/2009 and Biocides Regulation.
Metabolites appear in many of the tables in the report, so should be included here.
Why focus on agriculture only? Many of the actives found were widely used on railways, forestry etc. e.g. atrazine
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UBA-IV1.3: Regarding aim and scope of the report, the role of non-relevant metabolites might be clarified: Were they actively excluded or was data too scarce to include them?
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More emphasis should be put on the presence of a vast quantity of non-pesticidal chemicals - at least as context setting. Leaving them out without more context may result in the usual singling-out of pesticides as the main source of concern.
Besides, although this report is meant to cover pesticides active ingredients, there is also mention of some metabolites without sufficient context.
2.3 Definition and classification of pesticides
According to FAO (2002), pesticides are defined as follows:
“Any substance or mixture of substances intended for preventing, destroying, or controlling any pest, including vectors of human or animal disease, unwanted species of plants or animals, causing harm during or otherwise interfering with the production, processing, storage, transport, or marketing of food, agricultural commodities, wood and wood products or animal feedstuffs, or substances that may be administered to animals for the control of insects, arachnids, or other pests in or on their bodies. The term includes substances intended for use as a plant growth regulator, defoliant, desiccant, or agent for thinning fruit or preventing the premature fall of fruit. Also used as substances applied to crops either before or after harvest to protect the commodity from deterioration during storage and transport” (FAO 2002).
EU legislation divides pesticides into plant protection products and biocides. The term ‘pesticide’ is often used interchangeably with ‘plant protection product (PPP)’, however, pesticide is a broader term that also covers non plant/crop uses, for example biocides [1]. These PPPs are products including ‘pesticide substances’ that protect crops or desirable or useful plants. They are primarily used in the agricultural sector but also in forestry, horticulture, amenity areas and in gardens. The products contain at least one active substance and have one of the following functions:
- protect plants or plant products against pests/diseases, before or after harvest;
- influence the life processes of plants (such as influencing their growth, excluding nutrients);
- preserve plant products;
- destroy or prevent growth of undesired plants or parts of plants.
EU countries authorize plant protection products on their territory and ensure compliance with EU rules (see section 2.5).
[1] Source: https://www.efsa.europa.eu/en/topics/topic/pesticides
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Revise the last sentence to state " Active substances used in both PPPs and biocides are approved at an EU level and EU countries can then authorise PPPs and biocides containing these active substances........
Overall, pesticides are grouped in different ways depending on the defining interest group, usage or others. Main classifications are usually based on a biological, chemical or technical basis. Whereas the biological goal seems to be very relevant e.g. the pests they control or the target organisms they kill, inhibit or destroy in one way or another, other important definitions derive from their chemical structure (e.g. organophosphate insecticides or neonicotinoids, organochlorine etc.) or their method of application. The definitions between these groups are rather fluid but most often the classification might clearly define all of the four main pesticide classes: “an insecticidal acetyl-choline esterase inhibiting fumigant pesticide of the organophosphate substance class” (Lewis, et al., 2016).
Based on the given definitions, grouping of pesticides within this report were based on their usage and their mode of action (MoA). This grouping is in a way comparable to the EFSA (European Food Safety Authority) based “Cumulative Assessment Group or CAG” [1].
According to their usage, the report focusses on the three groups (i) herbicides, (ii) insecticides and (iii) fungicides. The herbicides should control unwanted plants, insecticides are used to prevent unwanted insect infestation, and fungicides to kill parasitic fungi or their spores.
The classification according to the MoA of pesticides is oriented towards their effects in the non-human organisms. Table 2.1 lists the different MoA, which were assigned to the pesticides available under Waterbase – Water Quality in the time period 2007 – 2017 (see Annex 5).
[1] Source: http://www.efsa.europa.eu/en/consultations/call/180508-0
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the classification of pesticides given in Regulation 1185/2009 (statistics of pesticides) should be considered in this report, for consistency. Also because under this Regulation data on sales and use of PPP at MS level are collected.
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The mode of action reported in draft EFSA SR is based uniquely on effects on nervous system, which is of course extremely partial when the focus is on the environment and not on humans only. The classification under table 2.1 is indeed more appropriate, but I wouldn't consider it comparable to the one from the draft EFSA SR.
Table 2.1 Groups of pesticides according to mode of action (MoA) and their effects to organisms
Note: Based on the used methods, data availability and data selection, only photosynthesis inhibition and neurotoxic MoA were assessed (see section 4.1.1.1)
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HU:
We practically do not have any substantial comment on this chapter, all the included classification of pesticides, sources and uses are agreed.
2.4 Sources, uses and sales of pesticides
Pesticides are substances contained as active ingredients in plant protection products and biocides. They must selectively act against specific pest organisms, but it is impossible to achieve absolute selectivity (i.e. where effects are limited to only the target species). Furthermore, some pesticides being toxic to humans and/ or harming the environment by contaminating soil, surface and ground water. Pesticide contamination of both surface and groundwaters can affect aquatic fauna and flora, as well as human health when pesticide polluted water is used for public consumption. Aquatic organisms are directly exposed to pesticides resulting from agricultural production or indirectly through trophic chains (Maksymiv, 2015).
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I suggest re-word sentence 1 as follows "Pesticides, which comprise plant protection products and biocides, contain active substances with pesticidal properties"
"impossible to achieve absolute selectivity" - I would revise to state "very difficcult"
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Third sentence: this sentence is incomplete and therefore does not make sense - this statement is not appropriate and should be dropped.
Pesticides are approved only if their toxicity to humans is excluded according to their use pattern.
The classification of pesticides to be toxic or harmful is based on its intrinsic properties. However, a risk to humans or the envirement only occurs where the exposure level exceeds the critical safety level. This is a key element in the discussion and should be mentioned here for the sake of transparency and clarity.
The pesticide pollution from agricultural activities of surface waters or groundwater may have different sources: a) Diffuse losses, e.g. spray drift due to pesticide application, b) point sources from waste water treatment plants (run-off from farmyards connected to sewer systems), c) surface run-off from farmyards during cleaning of application techniques, and d) leaching to field drains or to shallow groundwater (Sandin, 2017; Aktar, et al., 2009). In addition to agricultural activities, other relevant sources for pesticides include forestry, municipial use (e.g. on roadside), grasslands (e.g. golf courses) and uses in gardens. Once pesticides reach streams, they can be widely dispersed into other streams, rivers, lakes, reservoirs, and oceans (USGS, 1997).
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This paragraph seems to infer that points c and d do not belong to either diffuse or point sources, but in fact they do. In general, entry routes are either point sources, or diffused (nonpoint-source) ones which are due to transport processes such as soil surface runoff, drainage, preferential flow, leaching, atmospheric deposition and spray drift.
Population growth, increase in food consumption, and export of agricultural products (crops as well as meat) result in enhanced agriculture production, which mostly relies on extensive use of pesticides (FAO & IWMI, 2017). In Europe, the volume of pesticide sales has remained about constant since 2011 (Figure 2.1). The groups with the highest sales are fungicides, bactericides and herbicides (some 80% of the total pesticide sale). France, Italy, Spain and Germany sold together over 65 % of the total volumes reported in the EU (Agri-environmental indicator - consumption of pesticides - Statistics Explained 2019). However, the share of tonnes of pesticide sales does not allow any statement about the risk to human health and the environment.
Figure 2.1 Sales of pesticides, EU-28, 2011-2017
Note : This figure does not take into account confidential values. They represent < 3% of the total of sales over the entire time series.
Source : Eurostat (online data code : aei_fm_salpest09). https://ec.europa.eu/eurostat/statistics-explained/images/1/18/Sales_of_pesticides%2C_EU-28%2C_2011-2017_%28tonnes%29.png
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Bactericides are mentioned as having very high sales, but receive no further mention in the report. Some explaination would be useful as to why this is the case.
Based on sales data, EEA developed the ‘Total sales of pesticides’ indicator under the 7th Environment Action Programme within priority objective 3 to safeguard the Union’s citizens from environment-related pressures and risks to health and well-being (EEA, 2018a). It indicates no trends of pesticide sales (grouped by their usage) from 2011 to 2016. It is also stated, that: “This indicator does not allow, at present, for a full evaluation of progress towards the 2020 objective as pesticide sales are not synonymous with the risk of harmful effects on humans and the environment” (EEA, 2018a).
Beside the sales of pesticide information, EU developed the Harmonised Risk Indicator (HRI) to support the goals of the Sustainable use of pesticides Directive (EU, 2009). The HRI, published in 2019, considers the quantities of active substances placed on the market in plant protection products, and shows a decreasing trend from 2011 to 2017 of some 20% (Figure 2.2). This caused surprise among some [1].
Figure 2.2 Harmonised Risk Indicator 1
Note: A baseline of the average of three years 2011-2013 is used as the starting point against which subsequent values are compared.
Source: https://ec.europa.eu/food/plant/pesticides/sustainable_use_pesticides/harmonised-risk-indicators/trends-hri-eu_en
[1] Source: https://www.endseurope.com/article/1666559/commission-pesticides-data-draws-scepticism
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Suggested text "The European Commission developed Harmonised risk indicator 1 (HRI 1) .......
Suggested text "HRI 1 is based on the quantities of active substances placed on the market in PPPs, with a weighting applied to reflect the hazardous properties of the active substances. HRI 1 shows a 20% decrease in the risks associated with PPPs in the 2011-2017 period. "
This is an important distinction - HRI 1 does not measure quantities sold. It measures risk.
I would leave out "This caused surprise by some". HRI 1 was supported and welcomed by a wide range of stakeholders including Pesticide Action Network.
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(Austria): There should be a brief explanation of the HRI 1 and also about its interpretation/message.
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HRI index should be explained in detail in terms of how it is calculated and what it represents. Also, are there any suggestions on why the HRI trend has been declining?
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Last sentence - "this caused surprise among some": we suggest to drop this sentence as it is perceived one-sided. This seems more like a personal comment by one of the authors. The cited reference links to an online article about the concern of environmental campaigners. No scientific reason for pros and cons regarding the HRI are given.
Individual EU Member State sales indeed demonstrate that a decline is real.
There is a need for the development of a management tool such as an indicator which would combine the information on concentrations in water with the ecotoxicological knowledge of the specific pesticide product or its active components. This way regulators and politicians would be able to search, detect, identify the most important (i.e. most toxic and in highest concentrations) pesticide in their region of interest and prioritise management actions.
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Suggested text "There is a need to develop a management tool......."
2.5 Legislation and broader regulation on pesticides
The European Union tackles water pollution since the 1970s, e.g. Council Directive on pollution caused by certain dangerous substances discharged into the aquatic environment (EU, 1976), the Urban Waste Water Treatment Directive – UWWTD (EC, 1991), the Drinking Water Directive – DWD (EU 1998) or the Nitrates Directive (EU, 1991). Since 2000, the Water Framework Directive became the central instrument of water management and protection of EU waters (EC 2000). For substances (including pesticides), two daughter directives added quality standards to be achieved.
For source control, Directives and Regulations were set on substance level for a standardized registration including risk assessment or, for example, the usage of specific substances in agriculture as pesticides.
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Given text first mentions about two daughter directives of WFD setting quality objectives for pesticides. Further in the text, Drinking Water Directive (EU 1998) is also given among the directives setting quality standards for pesticides in water.
The following list of Directives and Regulations distinguishes between water policy and source control legislations including pesticide substances:
Water policy
- The Water Framework Directive (WFD) (EC 2000) sets a scheme for water management at river basin level. With regular six yearly planning and programmes of measures a good status of surface and groundwater is to be achieved.
- The WFD daughter Directives on Environmental quality standards in water policy - EQSD (EU, 2008) and on groundwater (EU, 2006a) set quality objectives and targets for pesticides in surface and groundwater.
- The Drinking water directive (EU 1998) sets quality objectives for pesticides at the tap.
Register and source control legislation according to pesticide substances
- Regulation on the European Pollutant Release and Transfer Register (E-PRTR) (EU, 2006b), which is the Europe-wide register that provides accessible key environmental data from industrial facilities in European countries including substances used as pesticides or biocides.
- The REACH Regulation (EC, 2006) aims to improve the protection of human health and the environment through identification and risk assessment of chemical substances, and to register the information in a central database.
- The Directive on the sustainable use of pesticides (EU, 2009) aims at reducing the risks and impacts of pesticide use on human health and the environment, and promoting the use of integrated pest management and alternatives such as non-chemical approaches.
- The Plants Protection Products Regulation (EC, 2009b) set out rules for the authorisation of plant protection products and their marketing, use and control. Based on this Regulation, the Seventh Environment Action Programme (EU, 2013) set the objective that, by 2020, the use of plant protection products should not have any harmful effects on human health or unacceptable influence on the environment, and that such products should be used sustainably.
- The Biocide Regulation (EU, 2012) focusses on the marketing and use of biocide products.
The UN Stockholm Convention recommends the ban of specific substances, inter allia pesticides, to protect human health and the environment from persistent organic pollutants (UNEP 2018) [1].
[1] List of persistent organic pollutants: http://chm.pops.int/TheConvention/ThePOPs/AllPOPs/tabid/2509/Default.aspx
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....the marketing and use of biocidal products.
The absence of European data on the sales of biocides, so that their relative importance as a source of pollution is not known
The absence of useful European data on the use of PPPs and biocides, which could help to identify areas of intensve use, the relative importance of agricultural and non-agricultural use etc.