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4.1.1.2. Pesticides in groundwater
Table 4.2 shows in analogy to the results of pesticide substances in surface waters (section 4.1.1.1), the number of substances and their exceedance rate for groundwater.
The total number of records within the group of herbicides in the time period 2007 – 2017 is some 1,400,000, and the substances with the most exceedance rate are Deisopropyldeethylatrazine (4.9%), Desethylatrazine (3.49%) and 2,6-dichlorobenzamide (3.10%). Only five substances show exceedance rate >1% (out of 75).
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Different naming is used i.e. Deisopropyldeethylatrazine vs. Desethylatrazine either use desethyl or deethyl
General comment: Monitoring reports of EU Member States (and summary reports thereof at EU level) usually do not carry an appropriate description of possible quality deficiencies of monitoring results, more specifically concerning their probability and frequency of occurrence.
This is surprising: for years it is common practice in EU MS that applicants do provide to authorities assessments of exceedances in GW and their possible causality. However, this is not reflected in the monitoring reports.
In this context it is common that faulty monitoring stations are identified by the manufacturer of an active substance and reported to the responsible authorities as requested. Such compromised monitoring stations often do not even meet the standards of the competent environmental or water agencies or those stipulated by national authorities for such a monitoring. Experience of the plant protection industry shows that faulty monitoring stations may continue to be used and therefore false-positive exceedances are still reported. Some examples are: a) monitoring stations (or their nearest up-gradient vicinity) are visibly permeable and open to above-ground contamination, b) some monitoring stations are located at inner-city locations, away from any agricultural use, c) some stations are clearly exposed to sewage water influence.
These problems are well known in EU Member States but not mentioned in monitoring reports. In absence of a description of known deficiencies in monitoring quality it is often postulated that the regulatory approval process is not suitable to manage contamination and therefore requires further tightening.
We recommend that monitoring results are reported from appropriate monitoring stations only and available assessments of deficiencies are part of MS reporting and faults of stations are being taken seriously.
2nd paragraph: it should be made clear when talking about degradation products to clearly distinguish them from active substances.