Feedback reference
F7730
Submitted by
Giorgio Rkl
User type
Non-governmental organisation (NGO)
Organisation
Pesticide Action Network (PAN) Europe
Organisation size
Micro (1 to 9 employees)
Transparency register number
Country of origin
Belgium

Taking into account the scope of this fitness check, that will look at “the relevance, effectiveness, efficiency, coherence and EU added value of the Water Framework Directive”, which represents “the most comprehensive instrument of EU water policy…with the aim of achieving good status of EU waters”, it seems quite reductive and biased to have as purpose “a quantitative assessment of actual costs and benefits including impacts on business” and “an assessment of the potential for regulatory simplification and burden reduction”. Indeed, the scope of this evaluation cannot be just an analysis from an economic and regulatory point of view, but it should include also the social, public health and environmental aspects.
The WFD and its “daughters-directives” aim to establish guidelines and standards in order to achieve a good ecological status in all european water bodies, which includes the aquatic contamination matter. From this point of view, it’s important to point out that the list of the main pollutants present in the WFD includes substances “which have been proved to possess carcinogenic or mutagenic properties or properties which may affect steroidogenic, thyroid, reproduction or other endocrine-related functions in or via the aquatic environment.” In fact, several man-made chemicals present in the aquatic environment may influence the reproductive capabilities of both vertebrates and invertebrates by adversely affecting the function of the endocrine (hormonal) system, thus resulting in several adverse health outcomes including reduced fertility and fecundity, spontaneous abortion, male and female reproductive abnormalities, precocious puberty, neurobehavioural disorders, impaired immune function and a wide variety of cancers among other effects. In the aquatic environment, several well-documented studies have described the impact of these compounds, termed endocrine disruptors, in wildlife. Many chemical pesticides have showed these properties, as they are designed to have a a toxic action to living organisms mostly by affecting enzymatic activities with key role in the regulation of the endocrine system, thus representing the largest group of EDs. A few of these endocrine disrupting pesticides (EDPs) have been already banned, though they are still present at environmentally relevant dosis, and others are in the market yet. A complementary table is provided together with this feedback, focusing on some exemplary EDPs and their toxic effects on aquatic species.
Pesticide pollution is an important element of the WFD. Here it’s important to point out that traditional approaches to determining safe exposure levels (for example, chemical risk assessments) do not work with EDCs, as a central feature of endocrine disruption is that may cause detrimental effects on organisms at very low chemical concentrations Thus, while wildlife is particularly vulnerable to the endocrine disrupting effects of pesticides at the environmental level, with effects noted in invertebrates, reptiles, fish, birds and mammals, it is often difficult to duplicate these precise effects in laboratory animals.
At this stage therefore we call for a better implementation of the WFD before requiring any changes. We fully support the Commission’s feedback that “we still have a long way to go before the quality of all EU waters is good enough, due to decades of previous degradation and persisting ineffective management” (Communication from the EU Commission 9.3.2015 COM(2015)120 final, p. 3). Our focus right now should be directed to implement the protection targets, and helping Member States to reach these goals.

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