With the release of the SETAC EMAG-Pest GW group’s recommendations, there is now comprehensive guidance on the design and conduct of groundwater monitoring of pesticide active substances and their metabolites in the context of Regulation (EC) 1107/2009. The guidance draws on authors from regulatory authorities as well as industry and academia.
Groundwater monitoring studies can provide more realistic assessments of potential impact on groundwater if the inherently conservative Tier 1 FOCUS modelling predicts levels of active substances or metabolites in excess of the 0.1 µg/L trigger value. Such studies potentiallytherefore provide potential for an acceptable exposure assessment for substances failing a Tier 1 assessment. The guidance is designed to work within the FOCUS tiered approach to groundwater. Monitoring of groundwater (with appropriate reality checking) is seen by FOCUS as the highest tier since the actual concentrations in groundwater are directly measured rather than being estimated by modelling approaches or approximated from small-scale field studies.
FOCUS notes that the EFSA PPR panel opinion expressed reservations on whether current hydrogeological knowledge is sufficient to use monitoring data to conclude that a representative “safe use” exists at EU level. However, the results of the leaching assessment at the EU level could be used to assist local assessments of leaching at the Member State level.
ERM’s hydrogeologists have comprehensive experience of designing and conducting groundwater monitoring projects in the field. In addition, our teams of regulatory scientists have many years’ experience of the pesticide regulatory framework. ERM is therefore uniquely placed to offer support, in conjunction with Member State input, on the regulatory and practical aspects of your groundwater monitoring studies.
For advice on groundwater monitoring and further information on the registration of plant protection products, biocides or general chemicals, or any other regulatory issues, please contact ERM on +44 (0)1423 520245, firstname.lastname@example.org.
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