1. International Office for Water Prioritisation of substances under the WFD: Compilation of the comments WG E (4), Brussels, 15-16/10/2008

2. 2 Community-wide relevance UK: cut-off-criterion based on a higher number of MS (i.e. >4 MS) SE: to consider national specific pollutants that are shared by several MS How many? Not necessarily only monitored substances: “safety net procedure” (DE, DK, FI, SE, UK, CEFIC, Eurometaux) taking into account marine waters (DE) (see modelling-based methodology from JRC)

3. 3 Choice of the prioritisation parameters DE, UK : persistence to be considered UK : bioaccumulation to be considered See modelling-based methodology from JRC Further time needed to collect experimental data CEFIC : drinking water standards not to be considered

4. 4 Definition and calculation of PECs Arithmetic mean 1 90 th percentile station 2 station 1 Raw data station 3 Arithmetic mean 3 Arithmetic mean 2 PEC CEFIC: Data sets with very limited number of sampling points should not be used Discard stations with <10 records  discard 140 substances CEFIC: Median should be calculated instead of arithmetic mean Calculation of PEC is based on what has been done for COMMPS (1999) For compliance checking, AA-EQS are to be compared to arithmetic means CEFIC: Median should be calculated instead of 90 th percentile Calculation of PEC is based on what has been done for COMMPS (1999) DK: MEC (“Measured Environmental Concentrations”) instead of PEC (“Predicted Environmental Concentrations”)

5. 5 PNECs Substances-specific comments on PNEC values for: UK: Tecnazene Dow AgroSciences: Fluroxypyr, Triclopyr, Chlorpyrifos-methyl, 1,3-Dichloropropene, Clopyralid, Metal Industry: Cobalt, Aluminium, Copper, Arsenic, Iron, Antimony, Molybdenum, Zinc, Boron, Vanadium, PNEC values to be reviewed by EG-EQS Any additional information is welcomed Values in biota: ECPA: keep PNECoral (secondary poisoning for predators) and values from ADI/TDI (for human health) separated Data sources: ECPA: EU risk assessment. Other sources only if EU RA not available DK: EU RA + OECD + WHO UK: if available use EQS values from daughter directive on PS (e.g. for DDT, PAHs)

6. 6 Use of mesocosm studies? ECPA: mesocosm studies should be considered Related to the methodology for setting EQS. To be discussed with EG-EQS

7. 7 Metabolites ECPA: PNEC values and prioritisation to be based on the environmentally relevant form of the compounds FI: substances and their relevant degradation products should be considered together (e.g. diphenyltin and triphenyltin) Related to the methodology for setting EQS. To be discussed with EG-EQS

8. 8 Sediment & EqP approach DK, UK, ECPA: EqP approach can be acceptable if experimental data are lacking SK: EqP approach too generalising and too simplifying CEFIC: sediment information only as complementary Eurometaux: prioritisation should only focus on water

9. 9 For metals: PEC/bkg vs PEC/PNEC CEFIC, Metal Industry: “strongly reject” the PEC/bkg approach Metal Industry: PEC/PNEC should account for bkg (added risk approach) Metal Industry: bioavailability to be taken into account DE: PEC to be calculated on a case-by-case basis Metadata required Site-specific bkg required

10. 10 Dissolved vs total Eurometaux: - PNEC for metals should be compared to dissolved concentrations. - It is not possible that dissolved concentrations > total concentration - Total concentration should be translated to dissolved concentration using EqP approach Reliability? Problem identified in the dataset

11. 11 Historical pollutants DE, SE: support inclusion of substances which are already strictly regulated when monitoring data indicate that contamination still exists

12. 12 Group of substances E.g. PAHs, PCBs, dioxins, DDT, etc. SE: does not support TEF approach for PAHs (see EFSA report 2008) SE: dioxin-like PCBs and non dioxin-like PCBs should be differentiated Then, data are not sufficient to derive congener-specific ADI/TDI