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4) Possible use of Regulatory Acceptable Concentrations (RAC) as effects threshold for pesticides in surface waters
Exceedances in surface waters were calculated using EU-wide or nationally-regulated thresholds (Environmental Quality Standards – EQS). We could not find EQS for about a third of the pesticides reported to WISE-6, which means these substances could not be included in the assessment of threshold exceedance.
Under Regulation 1107/2009 (PPP Regulation), RACs are required for pesticides to prevent harm to aquatic organisms. We investigated the possibility of using RACs as an alternative threshold to EQS, as all pesticides should have RAC values. However, we found that RACs and EQS could not be used interchangeably, as they consider different protection goals, apply to different spatial scales and are based on different valuation methods.
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I find this argument a bit weak, especially the one on the spatial scale. While this is conceptually true, the practice is that most EQS and all tier-1 RAC are derived from a laboratory ecotoxicological endpoint (the lowest available) divided by an assessment factor. Hence, the consideration of the spatial scale is not really impactful.
I find also a bit odd that tier-1 RAC were considered too different compared to EQS, but the use of maximum acceptable detection limits from the watchlist – something whose relation with toxicity is not so straightforward – was considered OK as ‘an indicator of the likely order of magnitude’.
A direct alignment of the RAC and the EQS for a particular pesticide (or metabolite) is not expected, as they consider different protection goals and apply to different types of water bodies.
Nevertheless, the comprehensive ecotoxicological data produced for pesticide authorization purposes under Regulation 1107/2009 can be and is used to derive robust EQS values according to the respective European Commission Common Implementation Strategy Guidance (EC 2018).
We therefore propose to derive “missing” EQS values based on the available ecotoxicological data compiled under Regulation 1107/2009 according to WFD CIS guidance in a transparent and participative way (EU-level process led e.g., by EEA), including EU registration holders of pesticides as stakeholders in this process.
Comment from UBA Germany, Unit Pesticides:
For 34 pesticides we have compared the highest-tier Regulatory Acceptable Concentration (RAC) used in our monitoring of small streams in the agricultural landscape in Germany with the MAC-EQS values used for the pesticide indicator (with the addition of some own MAC-EQS derivations). The result was: RAC values could be used for the assessment of short term peaks, if no MAC-EQS is available (see attached file displaying RAC/MAC ratios). In contrast, a relatively high discrepancy exists between the RAC and AA-EQS values for the same compound, since the various RAC-values are based on either acute, chronic or even mesocosm data with respective assessment factors (AF) and hence, were often much higher than AA-EQS that are based on chronic data only.