German Environment Agency Calls for Criteria for 'Mobile Chemicals'

Germany's federal environment agency (UBA) is urging member states and Echa to back its proposals to allow substances that are 'persistent, mobile and toxic (PMTs)' or which are 'persistent and mobile (PMs)' to qualify for inclusion on the REACH candidate list.

The agency defines mobile chemicals as those that can move through the water cycle and reach drinking water sources, because they do not bind to solid substances, such as sand or activated carbon. They break through natural barriers like shore zones of rivers and lakes and cannot be removed by artificial filters in waterworks.

Under REACH, the current assessment of substances for their persistent, bioaccumulative and toxic (PBT) properties is limited, UBA says, as it only covers chemicals that are bioaccumulative and which can be absorbed from food.

REACH guidance should be revised, says the agency, to allow PMTs and PMs to qualify as substances of very high concern (SVHCs) under Article 57(f) of REACH. This says substances for which there is an 'equivalent level of concern' to those listed elsewhere in Article 57, which as CMRs and PBTs, can be designated as SVHCs.

The agency presented its proposal at its REACH workshop in Berlin on 4 May. And it wants to discuss the proposal with other member states and Echa as soon as possible, says scientific officer Michael Neumann.

It has not yet identified substances fulfilling the proposed PM and PMT criteria, but it is conducting research and should have more information this summer, he adds.

The agency plans to publish an impact assessment on how many substances under REACH would fulfil the proposed criteria by end of this year.

PBT concerns

Echa welcomed the UBA's proposal, noting that in SVHC identification and restriction there are no specific stipulations or criteria related to mobility in the REACH legal text or guidance.

However, mobility is "implicitly included" in the approaches on Echa guidance on chemical safety assessment as part of fate assessment in quantitative risk assessment, it says. "This means that if a substance is very mobile, that influences exposure concentrations in the environment, including groundwater and drinking water concentrations."

Michael Warhurst, executive director of NGO CHEM Trust, said it would be "an important step forward" if REACH could start identifying and acting on persistent and mobile chemicals, as they spread widely in the environment and it is not possible to reverse this contamination if they are later found to be hazardous.

One of the main chemicals groups of concern for these properties, he said, is per- and polyfluorinated chemicals (PFCs). CHEM Trust would like to see such chemicals being identified as of 'equivalent concern' in REACH.

ChemSec's Anna Lennquist said bioaccumulative identification has been "problematic". It has already been "partly reworked" once in order to include substances which accumulate in tissues, although they are not qualified as bioaccumulative in a standard test, such as for PFCs.

Other problematic substances, such as the phosphate flame retardant TDCPP, can, she said, escape regulatory scrutiny if they are deemed to be persistent and toxic, but not bioaccumulative.