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Enhanced monitoring and further harmonisation of data collection would be beneficial for more specific management to protect water quality. Together with agricultural area usage, one would be able to compare the relative contribution and thus toxic pressure of pesticide usage types (e.g. corn herbicides, wheat insecticides) for a specific region, as a basis for management. Additional analysis of spatial and temporal distribution would increase understanding of the risks and management options. Pesticide metabolites (transformation products) should be considered, as these substances not only hint to their ‘mother’ substance, but many of these still have toxic potential (assigned to an EQS) and therefore increase the overall toxicity to organisms.
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Together with agricultural area usage
suggest to change to
Together with detailed EU-wide data on the sale and use of both PPPs and biocides
as these substances not only hint to their ‘mother’ substance, but many of these still have toxic potential (assigned to an EQS) and therefore increase the overall toxicity to organisms.
suggest to change to
as these substances are derived from ‘mother’ substances, and many of them have toxic potential (assigned to an EQS) and therefore increase the overall toxicity to organisms.
UBA-IV1.3: We suggest to add further aspects on pesticide metabolites here or in other sections of the report:
- As mentioned above, the role of non-relevant metabolites might be underestimated. In Germany, some of these have been measured in high concentrations and cause problems for water supplying companies and in water processing (LAWA, 2019; NLWKN, 2016; LfU, 2019; Schmidt and Brauch, 2008 - references included in <a href="http://www.uba.de/empfehlungsliste" rel="nofollow">www.uba.de/empfehlungsliste</a>). As far as we know, the data basis is scarce and heterogeneous among substances, regions and member states.
- In our view it is important to extent monitoring data with regard to metabolites. UBA published a list of metabolites recommended for groundwater monitoring and prioritised on formation rate, leaching behaviour and sales rates of the active substance. The list addresses public authorities responsible for groundwater monitoring, but also water supplying companies, health agencies and other stakeholders.
The respective document is published online: <a href="http://www.uba.de/empfehlungsliste" rel="nofollow">www.uba.de/empfehlungsliste</a> (German). It describes the choice and priorisation process and contains the recommendation list with further information on each metabolite and the respective active substance. Please consider adding the link to the report.
- For some metabolites it is particularly challenging to link their detects to sources, because the same metabolite might derive from different active substances or other chemicals. For instance, 1,2,4-triazole is a metabolite of certain fungicides and also a byproduct of fertilizers. Triflouracetate (TFA) is a metabolite from various pesticides, but also from pharmaceuticals, cooling agents and other chemicals.
- The issue of non-relevant metabolites might be included in potential remediation measures: Pesticides shall be preferred that do not form or form less persistent and mobile metabolites to reduce groundwater leaching. In Germany, "round tables" between agriculture and water supply discuss this issue and pay farmers for pesticide substitution and reduction.
I find it striking that, in the entire report, there is no mention of modelling tools.
There is a large body of literature demonstrating that the processes driving pesticide contamination of surface and groundwater are more or less understood and they could be modelled effectively.
These models could help a lot in both providing a better overall picture and, more importantly, to optimize any monitoring strategy in terms of balancing efforts over time and space.
"Additional analysis of epatial and temporal distribution..." clearly speaking against event-driven monitoring which would result in biased simplification.
Clear distinction between non-relevant and relevant metabolites needs to be made based on their difference to meet relevant threshold values.