1. HERA European Stakeholders Workshop: Brussels, Oct 20011 Environmental Risk Assessment Progress and Lessons Learned Kay Fox Chair of the HERA Environmental Task Force Human & Environmental Risk Assessment

2. HERA European Stakeholders Workshop: Brussels, Oct 20012 K. Fox Unilever (Chair) A. Aarts Solutia I. Lopez Petresa C. Arregui HERA P. Masscheleyn P&G J. Backmann HERA C. Poelloth HERA A. Berends Solvay P. Richner CIBA G. Boeije P&G W. Schul BASF D. Calcinai Sasol J. Steber Henkel E. Cerbelaud Rhodia C. Stevens Dow Corning H. Certa Sasol R. Toy Shell Chemicals R. Elsmore McBride R. van Wijk Akzo Nobel V. Koch Clariant T. Wind Henkel HERA Environment Task Force

3. HERA European Stakeholders Workshop: Brussels, Oct 20013 1a. To develop a methodology, based on the TGD, which is specifically tailored to household detergent and cleaning products –Transparent –Good science –Rapid and easy to use 1b. To carry out risk assessments, and to use them to improve the methodology HERA Environment Goals Speed Quality

4. HERA European Stakeholders Workshop: Brussels, Oct 20014 HERA Environmental Risk Assessment starts with EU Technical Guidance Document for New and Existing substances EUSES HERA Environment Conclusions specific for  European Usage  AISE product categories

5. HERA European Stakeholders Workshop: Brussels, Oct 20015 Main focus on chemical substances used primarily in Household detergent and cleaning products Focus on the use and disposal of these substances Sewer Transport Sewage Treatment HERA

6. HERA European Stakeholders Workshop: Brussels, Oct 20016 Detergent exposure scenario for EUSES Begin with EUSES –Environment Local Regional –Predators exposed via the environment –Man exposed via the environment TGD

7. HERA European Stakeholders Workshop: Brussels, Oct 20017 Detergent exposure scenario for EUSES Tiered Methodology –Begin with EUSES –Include the HERA Detergent Scenario –Replace selected EUSES values if appropriate Removal values in Sewage Treatment Plant Often need Chronic ecotoxicity data –Use all other EUSES initial values HERA

8. HERA European Stakeholders Workshop: Brussels, Oct 20018 Detergent exposure scenario for EUSES EUSES assumes that –the local wastewater treatment plant receives 4 times the average ingredient input –the Standard EU region receives 10% of the total European product consumption HERA replaces these assumptions with measured values based on laundry detergent product consumption and environmental monitoring data - the HERA Detergent Scenario. product consumption and environmental monitoring data - the HERA Detergent Scenario.

9. HERA European Stakeholders Workshop: Brussels, Oct 20019 Regional Environmental Concentration Standard EU Region Production Formulation Use 20 million people 10% of EU Production 200 km Release is based on Production

10. HERA European Stakeholders Workshop: Brussels, Oct 200110 Detergent Release scenario Production Formulation Use HERA Region 200 km ~100% of release Kg/person/year HERA Release is based on population density

11. HERA European Stakeholders Workshop: Brussels, Oct 200111 The HERA Detergent Scenario takes the highest population density in Europe HERA

12. HERA European Stakeholders Workshop: Brussels, Oct 200112 And the highest laundry detergent usage

13. HERA European Stakeholders Workshop: Brussels, Oct 200113 To generate the maximum regional release for household laundry products This is 7% of the European consumption volume 200 km

14. HERA European Stakeholders Workshop: Brussels, Oct 200114 Product use and substance use data are expected to be similar, for most widely used household detergent and cleaning ingredients. Each HERA Substance Team will consider any areas of high regional usage for their substance, and will modify the HERA regional default if appropriate. Fragrance F HERA

15. HERA European Stakeholders Workshop: Brussels, Oct 200115 STD. EU Region Local treatment plants 4 TGD - Local plant Release from LOCAL sewage treatment facility A reasonable worst case treatment plant receives 4 times the average load EUSES

16. HERA European Stakeholders Workshop: Brussels, Oct 200116 Experimental data HERA Boron in effluents: 50 treatment plants NL 7 Germany 6 Italy 3 UK 34 plants Comparison with sales shows 90% of sewage plants receive less than 1.5 times the boron sold in laundry detergent

17. HERA European Stakeholders Workshop: Brussels, Oct 200117 HERA uses 1.5 times, not 4 times the average per capita consumption to determine a realistic worst case for the sewage treatment plant input. Each HERA Substance team will consider any areas of high local use and will modify this HERA value if appropriate.

18. HERA European Stakeholders Workshop: Brussels, Oct 200118 STD. EU Region Summary - HERA Detergent Scenario Region - 7%, not 10% of ingredient 1.5 Local sewage treatment - 1.5 is worst case, not 4. 100%, not 99%, of ingredient used goes to the local treatment facility

19. HERA European Stakeholders Workshop: Brussels, Oct 200119 So - How well does it work? As well as for boron and some surfactants, monitoring data are available for FWA-5 –might be subject to local usage patterns FWA-5 data shows Hera Detergent Scenario is still conservative - i.e. predicts a higher environmental concentration than found experimentally. 

20. HERA European Stakeholders Workshop: Brussels, Oct 200120 Lessons learned - Environment The HERA detergent scenario, based on measured data for boron in laundry detergent, works - as shown by FWA -5 Production and Use data –HERA is identifying the data locations within companies/organisations –HERA is building the network to deliver the data we need HERA

21. HERA European Stakeholders Workshop: Brussels, Oct 200121 Lessons learned - Environment Hazard data needs are often “higher tier” –Chronic or higher “non-SIDS” data Environmental exposure - more realistic data often needed –Sewage treatment plant removal data –Environmental monitoring data very helpful HERA HERA sponsor companies are aware

22. HERA European Stakeholders Workshop: Brussels, Oct 200122 Conclusions - Environment HERA is building a focussed Risk Assessment method –based on the EU TGD –applicable to “HERA” products HERA is assembling the Network to deliver focussed risk assessments –good science –transparency –comparatively rapid, and easy to use HERA

23. HERA European Stakeholders Workshop: Brussels, Oct 200123 Thanks! To HERA for providing the Challenges! To the HERA Environment task force for help with the Solutions To ERASM and the Environment Agency for England and Wales for funding the boron monitoring work To the monitoring staff who collected the samples in all weathers! To you for listening!