HERA at XXXI CED Kay Fox Human & Environmental Risk Assessment Environmental Risk Assessment under HERA: Challenges and Solutions Kay Fox Chair of the HERA Environmental Task Force

HERA at XXXI CED Kay Fox C. Poelloth, C. Arregui, J. Backmann - AISE I. Lopez Petresa C. Stevens Dow Corning G. Boeije P&G R. van Egmond Unilever H. Certa SASOL R. van Wijk Akzo Nobel R. Elsmore McBride T. Wind Henkel K. Fox Unilever A. Aarts Solutia P. Masscheleyn P&G A. Berends Solvay P. Richner CIBA D. Calcinai Condea Augusta W. Schul BASF E. Cerbelaud Rhodia J. Steber Henkel V. Koch Clariant R. Toy Shell Chemicals Environment Task Force

HERA at XXXI CED Kay Fox Intended for application in EUROPE HERA Environmental Risk Assessment based on Technical Guidance Document for New and Existing substances EUSES

HERA at XXXI CED Kay Fox Focus on chemical substances used primarily in Household detergent and cleaning products Primary Focus on the use and disposal of these substances Sewer Transport River Domestic Emission On-Site Treatment Sewage Treatment

HERA at XXXI CED Kay Fox Detergent exposure scenario for EUSES Begin with EUSES –Environment Local Regional –Predators exposed via the environment –Man exposed via the environment TGD

HERA at XXXI CED Kay Fox Detergent exposure scenario for EUSES Wide dispersive use, Detergents (5, 9) 100% of chemical to sewer (Local Use model) HERA Effectively in HERA

HERA at XXXI CED Kay Fox Detergent exposure scenario for EUSES Production Formulation Use Contributions to Regional Environment from Local sources TGD Default HERA 0.3% 0.3%(1.003) % 0.8% 0 0 max max 99% 99% 100% 100% Bottom line - 100%, within volume determination error

HERA at XXXI CED Kay Fox Detergent exposure scenario for EUSES To cover a “reasonable worst case”, TGD and EUSES assume 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 default assumptions with HERA default values based on measured product consumption and environmental monitoring data - the HERA Detergent Scenario.

HERA at XXXI CED Kay Fox Detergent exposure scenario for EUSES Tiered Methodology –Begin with the HERA Detergent scenario –Accept all other EUSES Defaults –Replace selected defaults if necessary Removal values in STP Measured Kd values Biodegradation rates in rivers, soil, etc.  Often need Chronic ecotoxicity data

HERA at XXXI CED Kay Fox Production Formulation Use Regional Environmental Concentration 20 million people 10% of EU Production Standard EU Region 200 km Release is based on Production Volume

HERA at XXXI CED Kay Fox STD. EU Region Local treatment plants Input to local treatment plant is based on the regional production volume.

HERA at XXXI CED Kay Fox Production Formulation Use Detergent Release scenario Release is based on population density HERA Region 200 km ~100% of release Kg/person/year

HERA at XXXI CED Kay Fox The standard EU region has 10% of the EU detergent consumption - for 5.4% of the EU population.

HERA at XXXI CED Kay Fox Detergent consumption per person in eighteen European countries

HERA at XXXI CED Kay Fox

The maximum regional release for detergent ingredients is found in the UK region containing London This is 5.5% of total usage, rather than 10%, as in the TGD Thus the HERA Detergent release scenario should have 5.5% of the total volume released to the region.

HERA at XXXI CED Kay Fox STD. EU Region Local treatment plants Input to local treatment plant is based on the regional use volume. In EUSES,

HERA at XXXI CED Kay Fox HERA must give the correct local loading for sewage treatment plants in countries with highest detergent use. Italy and Spain have 1.25 times the average EU detergent consumption, per person. HERA ensures correct representation of the LOCAL treatment plant, which EUSES derives from the regional consumption, by raising the overall regional background to.055 X 1.25 = 0.07 times the European use volume Regional detergent Scenario HERA uses 7%, not 10%, for regional input EUSES

HERA at XXXI CED Kay Fox Product use and substance use data are expected to be similar, for most widely used detergent 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 at XXXI CED Kay Fox 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

HERA at XXXI CED Kay Fox GREAT-ER GIS model which predicts chemical concentrations of household chemicals in rivers. Boron used as a conservative tracer, to validate the model. 6 STP influents and effluents Monthly river water and effluent samples UK data

HERA at XXXI CED Kay Fox Measured effluent boron agreed with load calculated from consumer sales volumes (1996, 28 daily composite samples from 6 treatment plants) 0.22 g/person/day Boron in effluents: 50 treatment plants –NL 7 –Germany 6 –Italy 3 –UK 34 plants

HERA at XXXI CED Kay Fox UK Boron data from 804 grab samples from 34 plants. Measured to calculated boron : Mean = %ile < 1.5 Reasonable worst case (90%ile) is 1.5 times the regional average input, not 4 times as in the TGD default scenario.

HERA at XXXI CED Kay Fox Boron concentrations in Italy, Germany, and the Netherlands also agreed with the concentrations calculated for the country and year of emission, with the 90%ile of the measured to calculated boron distribution being less than 1.5. Thus data from 50 sewage plants, in 4 countries, show that for detergent ingredients in wide general use, such as perborate, a reasonable worst case (90%ile) is 1.5 times the regional average input. Paper on the 1.5 factor submitted to Chemosphere. ECETOC submission to TGD revision resulted in change to “up to a factor of 4” in the revised TGD.

HERA at XXXI CED Kay Fox Each HERA Substance team will consider any areas of high local usage for their substance, and will modify the HERA default for the reasonable worst case sewage treatment plant if appropriate.

HERA at XXXI CED Kay Fox STD. EU Region Summary - HERA Defaults Detergent scenario Region - 7%, not 10% of ingredient used 1.5 Local sewage treatment is worst case, not %, not 99%, of ingredient used goes to the local treatment facility

HERA at XXXI CED Kay Fox Modified Exposure Scenario - HERA TGD - Worst case (4) (Local STW) times worst case (~2) (10% production tonnage) gives almost 8 times the average ingredient loading to a local sewage treatment plant. HERA Detergent Scenario - Data backed “worst case” (1.5) for local STW times “worst case” (~1.7) regional release based upon product use shows two times the average ingredient loading to a local sewage treatment plant. HERA will check that the substance use patterns are suitable before using the HERA defaults.

HERA at XXXI CED Kay Fox 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 EA and Yorkshire Water employees who collected the samples in all weathers! To you for listening!