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Getting in control of persistent, mobile and toxic (PMT) and very persistent and very mobile (vPvM) substances to protect water resources: strategies from diverse perspectives

Getting in control of persistent, mobile and toxic (PMT) and very persistent and very mobile... Background: Safe and clean drinking water is essential for human life. Persistent, mobile and toxic (PMT ) sub‑ stances and/or very persistent and very mobile (vPvM) substances are an important group of substances for which additional measures to protect water resources may be needed to avoid negative environmental and human health effects. PMT/vPvM substances do not sufficiently biodegrade in the environment, they can travel long distances with water and are toxic (those that are PMT substances) to the environment and/or human health. PMT/vPvM substance research and regulation is arguably in its infancy and in order to get in control of these substances the following (non‑ exhaustive list of ) knowledge gaps should to be addressed: environmental occurrence; the suitability of cur‑ rently available analytical methods; the effectiveness and availability of treatment technologies; the ability of regional governance and industrial stewardship to contribute to safe drinking water while supporting innovation; the ways in which policies and regulations can be used most effectively to govern these substances; and, the identification of safe and sustainable alternatives. Methods: The work is the outcome of the third PMT workshop, held in March 2021, that brought together diverse scientists, regulators, NGOs, and representatives from the water sector and the chemical sector, all concerned with protecting the quality of our water resources. The online workshop was attended by over 700 people. The knowledge gaps above were discussed in the presentations given and the attendees were invited to provide their opinions about knowledge gaps related to PMT/vPvM substance research and regulation. Results: Strategies to closing the knowledge, technical and practical gaps to get in control of PMT/vPvM substances can be rooted in the Chemicals Strategy for Sustainability Towards a Toxic Free Environment from the European Commission, as well as recent advances in the research and industrial stewardship. Key to closing these gaps are: (i) advancing remediation and removal strategies for PMT/vPvM substances that are already in the environment, how‑ ever this is not an effective long‑term strategy; (ii) clear and harmonized definitions of PMT/vPvM substances across *Correspondence: sarah.hale@ngi.no Norwegian Geotechnical Institute (NGI), Ullevål Stadion, P.O. Box 3930, 0806 Oslo, Norway Full list of author information is available at the end of the article © The Author(s) 2022. Open Access This article is licensed under a Creative Commons Attribution 4.0 International License, which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons licence, and indicate if changes were made. The images or other third party material in this article are included in the article’s Creative Commons licence, unless indicated otherwise in a credit line to the material. If material is not included in the article’s Creative Commons licence and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder. To view a copy of this licence, visit http:// creat iveco mmons. org/ licen ses/ by/4. 0/. Hale et al. Environmental Sciences Europe (2022) 34:22 Page 2 of 24 diverse European and international legislations; (iii) ensuring wider availability of analytical methods and reference standards; (iv) addressing data gaps related to persistence, mobility and toxicity of chemical substances, particularly transformation products and those within complex substance mixtures; and (v) advancing monitoring and risk assess‑ ment tools for stewardship and regulatory compliance. The two most effective ways to get in control were identified to be source control through risk governance efforts, and enhancing market incentives for alternatives to PMT/vPvM substances by using safe and sustainable by design strategies. Keywords: Water protection, Regulation, Governance, Stewardship, Prevention, Remediation Introduction contamination if they are emitted in substantial quanti- PMT/vPvM substances as a threat to water security (H.P.H. ties. In the content of this paper, mobility of PMT/vPvM Arp, C. Castell‑Exner, S.E. Hale and X. Trier) substances refers to the fact that they can travel long Safe and clean drinking water is essential for human life. distances with water, even in the subsurface and thus The European Drinking Water Policy began in the 1980s are able to spread over large spatial and temporal scales. with the aim to ensure that water intended for human This means it may be difficult to relate the point of pollu - consumption is consumed safely on a life-long basis and tion release to the final point of contamination. Concur - as such guarantees a high level of health protection. In rently these substances can present a threat to planetary order to meet the set of legal requirements stipulated boundaries [5]. If continuously emitted into freshwa- by current policies, water suppliers must have access to ter systems, and not removed, concentrations of PMT/ adequate and reliable drinking water resources that are vPvM substances will gradually increase and they will be protected from chemical pollution and other threats. Ide- detected in more areas. As many PMT/vPvM substances ally, these drinking water resources should have a natural are extremely difficult to remove from water resources status or should only have to be treated using natural or especially when waste water is recycled for drinking conventional techniques, like sand filtration or aeration, water purposes, exposure will also increase with continu- to meet drinking water quality standards. In this way, ing emissions [6–8] unnecessary consumer costs are avoided while conserv- PMT/vPvM substance research and regulation is argu- ing water’s pristine qualities. ably in its infancy [9–13] and several gaps have already It is possible to manage the threat from chemical pol- been outlined [14]. In order to forward knowledge lution in such a way that harm to human health and the related to these substances the following (non-exhaustive ecosystem is minimized. This has been demonstrated list of ) gaps should be addressed: environmental occur- over recent decades in areas such as the Rhine River rence; the suitability of currently available analytical Basin [1]. However, as the chemical industry continu- methods; the effectiveness of treatment technologies; the ously innovates, currently developed tools for environ- ability of regional governance and industrial stewardship mental risk assessment struggle to keep up with the to contribute to safe drinking water and environmen- diversity of chemicals and their uses [2]. Pollution occurs tal protection while supporting innovation; the ways in across the whole life cycle of a product from its produc- which (new) policies and regulations can be used most tion until its final disposal, whilst regulation typically effectively to govern these substances; and, the iden - only addresses the point at which products are placed on tification of safe and sustainable alternatives. Many of the market, which is only a small part of that lifecycle [3]. these knowledge gaps were discussed at the "Third PMT The increasing amount and diversity of emerging chemi - Workshop: Getting control of PMT and vPvM substances cals on the EU market that can enter water resources, under REACH", which took place on the 25th and 26th means it is important to consider whether changes to of March 2021 (online) which was attended by over 700 chemical and water resources management need to be people. made in order to inexpensively safeguard water resources in their natural state. Structure of this paper Persistent, mobile and toxic (PMT) substances and/or This paper presents a summary of the state of play for very persistent and very mobile (vPvM) substances pre- PMT/vPvM substances from many of the workshop sent an important example where additional measures to presenters with diverse backgrounds, including chemi- protect water resources may be needed to avoid negative cal and water regulators, analytical and environmental environmental and/or human health effects [4]. Owing chemists, representatives from environment and health to their persistent nature, they do not sufficiently biode - non-government organisations, and industry represent- grade in the environment and this can result in pervasive atives from the chemical production and water services Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 3 of 24 sectors. Each section of the paper is written by a sub- PMT/vPvM substances in the spotlight set of coauthors, as indicated. The perspectives from The examples of PMT/vPvM substances below reflect this author group are bought together  to present new those discussed at the third PMT workshop. These are ideas of how PMT/vPvM substances can be brought by no means exhaustive and the reader is referred to under control in order to protect water resources, par- additional literature containing extensive lists of sub- ticularly for those substances registered under REACH stances identified as PMT/vPvM substances. [16]. (Regulation 1907/2006 on the registration, evalua- tion, authorisation and restriction of chemicals). The knowledge gaps and perspectives are presented below Trifluoroacetate (TFA) (K. Nödler and M. Scheurer) by drawing on the toxic free hierarchy presented in the In 2016, elevated concentrations (10–20  µg/L) of the recently published "Chemicals Strategy for Sustainabil- chemical trifluoroacetate (TFA) (or trifluoroacetic ity Towards a Toxic Free Environment" [15]. Figure  1 acid, TFAA) were detected in tap water samples from schematically illustrates the toxic free hierarchy for a major city in Baden-Württemberg, Germany. Waste- PMT/vPvM substances, where the preferred options water discharge from an industrial company was later in green and at the top of the hierarchy are to prevent identified as the source of the contamination to bank use of PMT/vPvM substances, followed by strategies to filtrate which was used to produce tap water. Extended minimize and control PMT/vPvM substances in orange monitoring showed a measurable impact on the drink- and in the middle and, finally, the least preferred solu - ing water supply along the lower River Rhine [17]. TFA tion is to remediate PMT/vPvM substances, illustrated does not have a significant degradation pathway and in red at the bottom. This article begins by introducing this results in accumulation in the aquatic environ- PMT/vPvM substances that are currently in the spot- ment. This persistence, combined with the mobility light, then outlines strategies that can be used to get in of TFA and a lack of suitable water treatment options, control of analytical and monitoring methods for PMT/ presents a highly relevant and complex problem to vPvM substances to set the stage, and this is followed solve in order to minimize and control exposure [17]. by discussing options upward through the toxic-free In addition to industrial emissions there are many hierarchy; remediation, minimisation and control and, other primary product and process sources that emit finally prevention strategies. To conclude the paper, TFA directly, as well as secondary sources which are survey results from the third PMT workshop are used synthetic substances that form TFA in the environ- to highlight opinion related to what the largest knowl- ment. For example, the photochemical degradation of edge gaps are that need to be closed to get in control of certain propellants, refrigerants and blowing agents PMT/vPvM substances. [18] as well as the (bio)degradation of various com- pounds from other substance classes (e.g. pesticides and pharmaceuticals), all result in TFA formation [17, 19, 20]. Current monitoring studies show that TFA is a common contaminant in tap water [17], food crops [21] as well as in beer and tea [22] and, consequently, TFA was recently detected in blood samples from the gen- eral population (Chinese adult men and women, detec- tion rate 97%, median 8.5 µg/L) [23]. In addition, recent studies investigating ice cores from the Arctic [24] and precipitation in Germany [25] have confirmed increas - ing TFA levels in the environment from the 1990s dem- onstrating the ubiquitous nature of this substance. The toxicity of TFA in animals and aquatic systems is rather low. However, the microalga Raphidocelis subcapitata (formerly known as Selenastrum capricornutum) was identified as the most sensitive species [26] and the Fig. 1 Ways to manage PMT/vPvM substances in the environment according to prevention, minimization and remediation strategies. NOEC of 0.12  mg/L was shown to be exceeded in a Inspiration is drawn from the toxic free hierarchy presented in surface water near a TFA discharging industrial facility the "Chemicals Strategy for Sustainability Towards a Toxic Free [17]. For terrestrial plants NOELs and NOECs > 1 mg/L Environment" [15] Hale et al. Environmental Sciences Europe (2022) 34:22 Page 4 of 24 were reported by several authors. A comprehensive (pH 7) value < 0. The other substances (i.e. 19%) were summary of toxicity data regarding TFA can be found mixtures and could not be classified or have log D ow in Seiber and Cahill [27]. (pH 7) values above 4. Of the 74, 72 and 62 substances above, 32, 17 and 4 substances, respectively, contained 1,4‑Dioxane (Ivo Schliebner) chlorine or bromine; and 1, 18 and 33 substances, 1,4-dioxane has been found in groundwater and surface respectively, contained amino/acidic groups. water in Germany [11, 28], Spain [29], Belgium [30], the Analytical techniques capable of simultaneously USA and Japan [31–33], as well as detected in drinking detecting such diverse substance classes over a broad water in these and other regions [31, 34–36]. 1,4-Diox-log D range are advantageous when screening for ow ane has a plethora of uses. 1,4-Dioxane is a known by- such a diversity of PMT/vPvM substances that are product during the synthesis of polyethoxylates and suspected to be present. However, these methods may polyesters. The widespread uses of polyethoxylates encounter challenges related to separation and detec- (and polyesters) containing residual concentrations tion of such substances [42]. Figure 2 illustrates today’s of 1,4-dioxane can result in emissions to the environ- chromatographic techniques and their capabilities. For ment, mainly to waste water. It is also a solvent used as example, super-critical fluid chromatography (SFC) an industrial processing aid, but this use is unlikely to and reversed-phase liquid chromatography (RPLC) result in substantial emissions. coupled to hydrophilic interaction liquid chromatog- There are several studies that have pointed to the fact raphy (HILIC) allows for the analytical determination that 1,4-dioxane can be attenuated naturally to varying of substances with log D from −  9 to + 9 [24–26]. ow degrees [35, 37, 38]. However, a recent study reported This range is much wider than when using the con- that 1,4-dioxane was only marginally removed during ventional and common reversed-phase chromatogra- subsurface passage via river bank filtration and that the phy, which is mostly used in commercial laboratories. removal of 1,4-dioxane using an activated carbon filter Due to increasing needs in PMT/vPvM substance does not occur in practice [39]. Based on this evidence analysis, more commercial laboratories are installing of high persistency and mobility in the aquatic envi- a polarity-extended chromatography. The techniques ronment, together with 1,4-dioxane’s classification as shown in Fig. 2 can be coupled using electrospray ioni- Carc. 1B, it is a priority substance for regulatory assess- zation with high-sensitivity, high-accuracy and high- ment. At the time of writing this paper 1,4-dioxane was resolution tandem mass spectrometry (HRMS/MS). identified as a substance of very high concern under With such HRMS/MS systems non-targeted screening REACH [40], based on its PMT/vPvM properties being (NTS) analysis of ‘unknown’ PMT/vPvM molecules considered an equivalent level of concern to persistent, can be conducted. There are several openly accessi- bioaccumulative and toxic substances (PBT), and very ble platforms such as XCMS [43], MZmine [44], FOR- persistent, very bioaccumulative (vPvB) substances IDENT [45] and patRoon [46], which cover parts of [10]. or the entire NTS data evaluation and prioritization Getting in control of analytical methods and monitoring of PMT/vPvM substances Advances in analytical methods for PMT/vPvM substances (J. Hollender and T. Letzel) There are many more persistent and mobile substances than TFA and 1,4-dioxane. The previous studies report - ing compilation lists of PMT/vPvM substances [11, 12] are dominated by organic molecules with varying polar, ionizable and ionic functional groups. Taking for instance a list of 260 REACH substances that fulfil the PMT/vPvM criteria proposed by the German Environ- Fig. 2 Polarity scheme for chromatographic (electrophoretic) mental Agency in 2019 [4, 41], and further classifying separation techniques (like reversed‑phase liquid chromatography them on the basis of ‘polarity’ according to their log (RPLC), hydrophilic interaction liquid chromatography (HILIC), ion D , 74 of the 260 substances (i.e. 29%) have a log D ow ow chromatography (IC), capillary electrophoresis (CE) and supercritical (pH 7) value between 2 and 4, 72 of the 260 substances fluid chromatography (SFC)) based on log D values (at several pH ow (i.e. 28%) have a log D (pH 7) value between 0 and 2, values) of separable molecules and molecule characteristics, [48] ow adapted with polarity extended chromatography [49] and 62 of the 260 substances (i.e. 24%) have a log D ow Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 5 of 24 process. Using polarity extended chromatography, develop customized methods. A combination of meth- HRMS, FOR-IDENT and compound databases, sev- ods might be needed to separate and detect a broad eral vPvM substances (in the log D range from −  9 range of PMT substances in a robust way as shown in ow to + 9) such as N,N′-ethylenedi(diacetamide) [12] or Schulze et al. [57] and Fig. 2. 4-hydroxy -2,2,6,6- te trame thylpip er idine-1-e thanol [47] could be identified in surface waters and other Monitoring PMT/vPvM substances in groundwater (H.P.H. aqueous samples [12, 40, 42–44]. By comparing physic- Arp, J. Hollender and M. de Jonge) ochemical properties of suspect substances with target Many PMT/vPvM substances have been identified substances, information can be gained as to whether through groundwater monitoring using the analytical the suspect substance can be found with a given ana- techniques described above. In many regions ground- lytical method. Additional file  1: Fig. S1 shows 1162 water is the major drinking water resource, providing PMT/vPvM suspect substances (NORMAN Suspect approximately 50% of domestic water supply worldwide; List S82, https:// www. norman- netwo rk. com/ nds/ in Switzerland this can reach 70 to 80% [58]. Groundwa- SLE/) compiled for the Swiss groundwater screening ter is considered better protected from contamination study described below, [50] where approximately 90% compared to surface water [58], reducing the need for have a predicted log D and molecular volume in the water treatment. Despite this, a broad variety of com- ow same range as almost 500 target compounds that can pounds used in households, industry and agriculture be detected with polar modified RPLC coupled to elec- have been reported in groundwater at concentrations in trospray ionization to HRMS. the ng/L to µg/L range [59]. Here two illustrative cases However, even when polarity-extended chromato- studies are presented, one from Netherlands and one graphic separations are used, there are still several from Switzerland. challenges in the analysis of PMT/vPvM substances. The Dutch groundwater survey investigated the pres - To detect them with sufficient sensitivity in monitor- ence of 778 organic substances in raw water samples ing campaigns, enrichment is often needed; however, taken from 110 groundwater well fields in 2020 [60]. very mobile substances are easily lost during conven- Most of these well fields are considered vulnerable to pol - tional enrichment techniques like solid phase extrac- lution in newly formed groundwater, with about 30% of tion (SPE). Vacuum-assisted evaporative enrichment them being influenced by the infiltration of polluted sur - of water samples [51, 52], using a combination of sev- face water. Travel times in these groundwater sampling eral SPE materials including anion and cation exchange sites range from two years to several hundreds of years. materials [53], polarity extended SPE (e.g. [49]) or Results from the monitoring showed concentrations of larger injection volumes (e.g. [54]) are all potential 134 of the 778 monitored organic substances above the ways to overcome this problem. In addition to the analytical detection limit. issue with enrichment, identification of unknown sub- The Swiss groundwater study was based on samples stances can be time consuming and reference stand- from 60 national monitoring sites in Switzerland, and ards are often needed for the final confirmation of the included NTS analysis [50]. The samples were classified PMT/vPvM substance in question. However, reference as having high or low urban or agricultural influence standards are often not available, especially for trans- based on the occurrence of 139 of approximately 500 formation products [55]. It would be very beneficial screened target substances associated with either urban for the process of detection and confirmation of new or agricultural sources at the sites. High intensity and contaminants that reference materials or at least sub- frequency of occurrence of unknown peaks associated stance characteristics such as mass spectra would be with potential urban or agricultural sources were investi- provided by industry, such as during the chemical reg- gated further with suspect and non-target screening (for istration process. Finally, prioritization of unknown more information see the section "Monitoring data" in signals for substance identification is often based on the Additional file  1). New substances, not yet reported intensity [56] which can be misleading, as the sub- in groundwater were identified, including the industrial stance in question might not be ionized sufficiently. substance 2,5-dichlorobenzenesulfonic acid (log D ow, pH7 In summary, to detect novel PMT/vPvM substances 0.0, 19 detections, up to 100 ng/L), phenylphosponic acid in the environment, suspect screening with appropri-(log D −  2.0, 10 detections, up to 50  ng/L), triiso- ow, pH7 ate suspect lists and broad-scope analytical meth- propanolamine borate (log D 1.5, 2 detections, up ow, pH7 ods can be applied successfully, as has been recently to 40 ng/L), a transformation product of the blood pres- demonstrated [42, 50]. In the context of regulatory sure regulator amlodipine (log D −  0.4, 17 detec- ow, pH7 monitoring it is beneficial to define the targeted tions), and another of the herbicide metolachlor (log D ow, PMT/vPvM substances as precisely as possible and Hale et al. Environmental Sciences Europe (2022) 34:22 Page 6 of 24 of these 57 are considered Potential P/vP (or Potential P/ −  1.7, 33 detections, estimated concentrations up to pH7 vP + +) because screening tests indicated they were not 100–500 ng/L). readily and/or inherently biodegradable, but they lacked PMT/vPvM criteria for REACH registered substances established half-lives to give a definitive P, vP or Not P have recently been proposed [4] and are currently being conclusion. There were 19 detected substances consid - discussed for adaptation or modification in a revision ered "Not P", because they were readily or inherently bio- to Regulation 1272/2008 on the classification, labelling degradable according to screening tests. The presence of and packaging of substances and mixtures (CLP), and "Not P" substances in groundwater could be due to half- the REACH regulation (EC No. 1907/2006), [15], as will lives in the environment being much longer than inferred be discussed more in the "Minimize and Control" sec- from readily biodegradable screening tests, substan- tion. Of the substances that were detected in either the tial local emissions, or both. Substantial local emissions Dutch or Swiss study, 127 were found to be registered are considered an important factor here, as 19 of the under REACH as of May 2019. It is therefore of inter- detected "not P" compounds were either BTEX compo- est to see how many of these substances would be con- nents associated with petroleum leakage (5 substances), sidered   as  PMT/vPvM substances  based on the 2019 high production volume phthalates (4 substances), criteria. By consulting a recently established database of organophosphates (3 substances), or other high-volume persistency data and experimental log K data (similar to oc commodity substances (p-cymene, bisphenol-a, phenol, Arp and Hale, 2019 [79]), 86 of the 127 substances could aniline, caffeine, tetrahydrofuran and adenosine) that be matched with an experimental log K within the data- oc may be emitted from urban areas or landfills [62] (see base. Figure  3 presents a box-plot of these substances, the Additional file  1: Table S1). In principle, the concen- comparing the log K with persistency evaluation (raw oc tration of these "Not P" substances could be minimized data can be found in section "Monitoring data used to through emission reduction, such as to a point where produce Fig. 3" in the Additional file 1). natural biodegradation would be sufficient for negligible As is evident from Fig.  3, most observed substances pollution levels (i.e. "natural attenuation"). had a log K < 3 (76 out of 86). In addition, for 57 out of oc the 86substances, a definitive P conclusion could not be made. For substances monitored in the environment it Remediation and removal is common that log K data are more commonly avail- oc Getting in control of treatment technologies for PMT/vPvM able than environmental half-lives [41]. For 8 substances substances (G. Sigmund) no experimental persistency data, such as readily biode- The removal of PMT/vPvM substances from water gradable screening tests were available at all; the other 49 remains an intense field of research, as no single solution for the removal of all PMT/vPvM substances exists. Their structural and functional diversity, as well as differences in emission sources, calls for a differentiated assessment of treatment technologies. One of the most widely used advanced water treat- ment technologies to remove organic contaminants from waters is adsorptive removal via activated carbon. Because of their high porosity, high specific surface area and graphene-like aromatic structures, activated car- bons are very good sorbents for aromatic compounds, such as polycyclic aromatic hydrocarbons, polychlorin- Fig. 3 Box plots of experimental log K values for REACH registered OC ated biphenyls and other “traditional” persistent organic substances reported in the Swiss or Dutch groundwater survey, pollutants (POP) [63], as well as polar and ionizable grouped according to their persistency classification. See the SI for aromatic compounds which generally sorb efficiently to more information about the monitoring data. Also shown is the these graphene-like surfaces [64–66]. Accordingly, acti- PMT/vPvM classification presented in 2019. Briefly, for persistent (P) and very persistent (vP) environmental half‑life criteria established vated carbon was recently found suitable for removing in REACH Annex XIII are used [61]; substances that meet the P or vP 15 pollutants known to be only partly removed in con- criterion can be considered "PM" if the minimum experimentally ventional waste water treatment plants, all of which con- measured log K is < 4.0 (and therefore a PMT substance if oc tained aromatic structures [67]. However, many PMT/ additionally found to be toxic), and vP substances can be considered vPvM substances are not aromatic (132 out of the 260 a vPvM substance if there is a minimum experimentally measured log K < 3.0 according to the currently proposed definition of PMT/ prioritized REACH PMT/vPvM substances are not aro- oc vPvM substances [4]. The thresholds of log K < 4.0 (red line) and log oc matic [41]), and/or are ionizable or ionic (148 out of K < 3.0 (dark red line) are presented oc 260 prioritized REACH PMT/vPvM substances), which Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 7 of 24 complicates their sorption behaviour, as additional elec- quantitatively removing organic micropollutants such as trostatic interactions can occur [66]. For non-aromatic HFPO-DA, TFA and melamine [71]. The removal of all and negatively charged substances, removal rates by acti- relevant PMT/vPvM substances needs an ever-increasing vated carbon are often low. A recent study considering combination of technologies. Further, the implementa- PFAS (where some of the individual substances are ani- tion of many technologies in Fig. 4 undermines the prin- onic), revealed generally unsatisfactory removal rates via ciple of limiting water treatment to natural processes activated carbon, and anion exchange resins have been [72]; and are best practiced at the site of initial emissions, suggested as alternative sorbents [68] before exposure to raw water. For substances where activated carbon or ion exchange resins do not remove them to a sufficient degree, reverse Minimize and control osmosis and nanofiltration can be effective technologies Getting in control of substance property assessments for water purification (Fig.  4). However, these techniques to identify PMT/vPvM substances (H.P.H. Arp, J. Hartmann, are energy intensive and produce brine (often 25% of the R.C.H.M. Hofman‑Caris, E. Rorije, E. Verbruggen) volume) which has to be disposed or remediated [69]. As Identification of a PMT/vPvM substance well before an example, TFA, described above, can only be removed it is emitted into the environment in large quantities, by reverse osmosis [17]. Advanced oxidation processes increases the chances for control. If a high-quality PMT/ including the use of Fenton’s reagent (H O + ferrous vPvM substance assessment could be carried out before 2 2 ion), photo catalysis (UV + TiO ) or supercritical water a substance is even produced in large volumes, risk man- oxidation are also proposed for the removal of substances agement efforts could be put in place to prevent contami - from water [70]. However, oxidation-based processes nation of ground and surface water; or safer alternative pose the risk of forming unwanted by-products which chemicals could be used instead. Persistence (P), mobility may need to be removed by activated carbon as a sub- (M) and toxicity (T) are all intrinsic substance properties sequent step. An overview of these treatment processes, related to if the chemical structure is resistant to naturally and substances they are most suitable for, is presented occurring biodegradation reactions (P), partitions pref- in Fig.  4. Each of these treatments have a limited imple- erably to water from environmental soils and sediments mentation window due to their costs, and none of them (M), and acts deleteriously with biology at the cellular or are wholly protective. Even these expensive, advanced ecological level at low levels of chemical activity (T). As P, drinking water treatments in Fig.  4 are not capable of M and T are all dependent on ambient and environmental Fig. 4 Water treatment technologies (left column) and the organic compound groups that cannot be removed by the respective method and/or can survive treatment (right column) Hale et al. Environmental Sciences Europe (2022) 34:22 Page 8 of 24 properties (e.g. temperature, nutrient levels, etc.), they are was then added to this pristine water and stored in the best quantified through standardized tests. dark at 13  °C. Aniline is used as a benchmarking sub- stance, as its biodegradation behaviour is well-known. At Persistence regular time intervals, bottles were removed for chemical When assessing persistence, Annex XIII of the REACH analysis to account for changes in concentration of the regulation ((EC) No. 1272/2008) sets half-life thresholds analytes, alongside adenosine triphosphate (ATP) analy- in water, sediment and soil at 12˚C. Substances with half- sis to account for microbial activity and to account for lives exceeding threshold values would meet the classifi - the possibility of a substance acting as a biocide. Results cation for P or vP. For mobile substances, the half-lives from the test showed that there was no degradation for in (marine) surface water are particularly relevant, as soil gabapentin, 1H-benzotriazole, diglyme, 1,4-dioxane and and sediment retain these substances only to a limited melamine while for DTPA and urotropine, slow degrada- extent and surface water is the compartment in which tion (with half-lives of 68 and over 128 days, respectively) these substances end up. Unfortunately high-quality occurred. The degradation half-live of the benchmark half-life data are quite rare, even for REACH registered substance aniline was 5  days. Based on these results, all compounds, due to their high cost and difficulty of meas - tested substances were determined to be very persistent urement [41, 73]. The PBT guideline makes several rec - according to REACH Annex XIII, having a half-life in ommendations to assess persistence, and particularly freshwater > 60  days. As the test was carried out with- non-persistence, in the absence of half-lives, such as the out the need for C-labelled compounds, the method is use of readily biodegradable or inherently biodegradable more accessible and by far cheaper than the OECD 309 screening tests like the OECD Test Guideline 301 and performed with radiolabelled test substances. This exam - 302 series [61]. Quantitative structure activity relation- ple shows that existing guidelines allow for generating ships (QSARs) can also be used to predict half-lives, but high-quality biodegradation data at reduced costs. More are generally too uncertain for a definitive P conclusion details about this test can be found in section "Additional and are best used for screening [41]. Therefore, simpler details about the persistency test" Additional file 1. approaches are needed to ascertain half-lives of sufficient quality. Mobility In the OECD Guideline 309 "Aerobic Mineralisation Mobility assessments are the only truly new part of in Surface Water—Simulation Biodegradation Test" [74] a PMT/vPvM substance assessment protocol, as the for assessing biodegradation half-lives, a time course of assessments of P and T follow the current PBT assess- aerobic primary and ultimate degradation in surface ment, with slight modifications. It is emphasized that water can be determined using kinetic rate expressions in the PMT/vPvM criteria under discussion in Europe for degradation, mostly performed using C-labelled for inclusion in the CLP and REACH regulations [15], compounds. However, it is very difficult to obtain C mobility assessments are only required for persistent labelled compounds, especially in cases where the com- substances [4]. This is largely based on the rationale pre - pounds are observed for the first time in the aqueous sented in the monitoring section that non-persistent sub- environment. This makes the procedure poorly acces - stances monitored in groundwater or drinking water, like sible and very expensive. The OECD 309 test may how - caffeine (Fig.  3), would disappear more readily from the ever, be performed with non-radiolabelled material as subsurface if emissions were suddenly reduced or elimi- well, with a validity criterion for the mass balance of nated. Gustafson et al. [76] first suggested the use of the 70–110%. This test with non-radiolabelled materials was organic-carbon partition coefficient, K , in combina- oc recently applied to the following potential PMT/vPvM tion with persistency in terms of soil half-lives, as a way substances: gabapentin, 1H-benzotriazole, diglyme, of assessing the potential for subsurface mobility. This DTPA, 1,4-dioxane, melamine and urotropine, identified combination of log K and soil half-lives has been used oc by Arp and Hale [41] that were at the time not subject to in the EU biocide regulations [77], and adapted to the any regulation [75]. For the test, a pure, pristine surface discussed PMT/vPvM criteria (with log K < 4.0 and < 3.0 oc water source from Schalterberg (NL) used for drinking as the cut-off for M and vM, respectively, for all P and vP water production was obtained and was tested to confirm substances, not just those persistent in soil). A current the following: i) it did not contain the test substances; ii) proposal from the European Commission for Classifica - it contained very little synthetic chemical contamination, tion and Labelling (CLP regulation) currently uses log and iii) it contained microbiological activity. The micro - K < 3.0 and < 2.0 as the cut-off for M and vM [78]. These oc organisms in this water had not previously been exposed proposals compared with classifications used in the ("adapted") anthropogenic micropollutants. A spiked GUS (Groundwater Ubiquity Score) index as proposed stock solution of the PMT/vPvM substances and aniline Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 9 of 24 for many ionic organic compounds, as soil organic car- bon has a substantial cationic exchange capacity [80]. The major shortcoming with organic carbon as the proxy phase for mobility is that data and models are lacking for ionic and zwitterionic species [81], partly because these ionic interactions could vary widely across types of organic carbon, as well as counterions in the porewa- ter. This is evidenced empirically as K measurements oc for ionic and ionizable substances are often quite vari- able [82], in part due to ionic interactions with soil min- erals that can further reduce mobility [83]. Therefore for mobility assessments of ionic substances, a recom- mended approach is to use the minimum empirical meas- ured log K from batch tests with actual soils (where the oc K value is corrected using the soil organic carbon con- tent), sediments or sludges as the basis [41]; however, it should be kept in mind for local risk assessments that Fig. 5 A groundwater ubiquity score (GUS) showing the thresholds for groundwater leachers (GUS > 2.8), non‑leachers (GUS < 1.8), and additional local factors are also important for subsurface regions that correspond to the UBA and EC commissions current mobility (e.g. flow rates, clay content, etc.) [84]. proposal (Sept 30, 2021) for very persistent, very mobile (vPvM) substances and persistent and mobile substances (PM) Toxicity Toxicity assessments generally follow those defined in REACH Annex XIII for PBT/vPvB assessments. These by Gustafson [76] are shown in Fig.  5. The GUS index is include the toxicity categories of carcinogenicity, muta- based on the equation below: genicity, reproductive toxicity, specific organ toxicity (repeated exposure), freshwater ecotoxicity and more GUS = log DT50 4− log K , (1) OC recently also endocrine disruption [15]. Other catego- ries can also play a role, including terrestrial ecotoxicity Where DT50 is the soil half-life (degradation time— [78], skin sensitization, and immunotoxicity. It must be 50%) in days. In this metric, a GUS > 2.8 is considered noted that for those endpoints based on effect concen - a groundwater leacher, a GUS < 1.8 a non-leacher, and trations in environmental media, the same effect caused those between 1.8 and 2.8 a transition zone where both within the organism should occur at a lower fugacity than are possible. For a half-life of 180  days in soil (the vP for PBT substances, because of the general lower bioac- criterion) this would mean a log K value of 2.76 as the oc cumulation from these environmental media for PMT upper value (rounded to 3 and thus in agreement with the substances. Although large amounts of toxicity data are current proposal [4]). With a soil half-life of 120 days (the available [16], it cannot always be assumed that such tox- P criterion) this would lead to a K value 3.13 to match oc icity data sets are complete or reliable. For certain persis- the boarder between "non-leachers" and the transition tent compounds that are widespread in the environment, zone. However, it was argued based on empirical data of long time scales of exposure were needed before the chemicals in drinking water, groundwater and breaking mechanisms of toxicity were elucidated [85]. This is part through bank filtrate that the M criteria should be a log of the justification for the establishment of the vPvM cri - K of 4 to be protective of the majority of detected sub- oc teria, which does not consider toxicity [4]. stances in these media [41]. The European Commission in consultation with the PBT expert group of ECHA has Screening and predictive approaches proposed to lower these cutoffs to log K of 2 and 3 for oc Due to the lack of empirical persistency, mobility and vM and M, respectively, because "a comparison of criteria toxicity data, it is currently only possible to conduct a provided in different legislations [and] guidance […] indi - high-quality PMT/vPvM substance assessment for a cate that log K of 4 would include also substances with oc relatively small number of substances [41]. To address great adsorption capacity and not likely to be mobile" this gap, screening and predictive models can be useful [78]. to prioritize where further testing is needed. For per- The advantage of using K is that organic carbon is oc sistency, this includes readily biodegradable tests (e.g. often a good "proxy phase" for soil and sediment sorp- OECD301A-F, OECD310). For mobility assessments, tion, as it is often dominating sorption phase in soils and octanol–water distribution coefficients D values, sediments for neutral organic compounds [79], and even ow Hale et al. Environmental Sciences Europe (2022) 34:22 Page 10 of 24 Getting in control of PMT/vPvM substances have been recommended as a screening parameter in through various types of chemical risk governance (H. the lack of K data, though there are concerns that D oc ow Timmer) does not account for ionic interactions with soil [4, 41]. The Dutch and Swiss monitoring studies discussed above For toxicity screening the Cramer Class III method has highlight that drinking water suppliers are faced with an been recommended [86]. A proposal for a more elabo- increasing number of known and unknown PMT/vPvM rate screening of potential (human health) toxicity by substances in their water sources. Strategies are there- including alert models for carcinogenicity, mutagenicity, fore needed to avoid detrimental effects of pollutants on reproductive toxicity (CMR) as well as potential endo- the quality of water bodies, aquatic life, natural areas and crine disruption (ED) is described in the supporting biodiversity. Stricter drinking water threshold concentra- information. A discussion of the performance of various tions are becoming more and more common; the revised quantitative structure activity relationship (QSAR) for version of the drinking water directive (98/83/EC) [90] predicting persistence and mobility properties has been is a prominent example. The revision includes several described in recent articles and reports [12, 41]. parameters for PFAS concentrations where threshold Two QSAR approaches to conduct a complete PMT values are in the ng/L range. The growing gap between assessment, requiring only the chemical structure as detected concentrations of certain PMT/vPvM sub- input, have been proposed. One was developed using a stances (in addition to other micropollutants) in drinking Danish QSAR database and was described by Holmberg water sources exceeding the acceptable concentrations in et  al., [87]. The other one was recently developed by the drinking water results in an increasing requirement for Dutch National Institute for Public Health and the Envi- purification treatment levels. This has been highlighted ronment (RIVM), presented in section "Additional details in a recent study [91] where a framework was developed about the RIVM QSAR" Additional file  1, which scores to evaluate the required purification treatment level. This substances on a scale from 0 to 1, from low to high PMT framework was applied to Amsterdam and its surround- substance potential. This screening approach also enables ings from an intake along the river Rhine, the major separate evaluation of persistence, mobility and toxicity Dutch river, at Nieuwegein. The results showed that the of a chemical structure making a score for P, M and T, treatment effort required to provide safe drinking water and aggregates them using the following function: actually increased between 2000 and 2018, despite the 0.4 0.4 PMT − score = P − score ∗ M − score ∗ ambitions of the water framework directive (WFD, (2) 0.2 2000/60/EC [72]) to reduce the level of purification treat - T (humanhealth) − score . ment required. When PMT/vPvM substances were con- The two approaches differ. The approach developed by sidered alone, as shown in Fig. 6 for the Nieuwegein river the Danish team only considers mobility for substances intake, the level of purification treatment was even higher that exceed a persistency threshold, and toxicity only for [92]. For this evaluation, water quality data for 1161 sub- those substances exceeding a persistency and mobility stances with P, M and/or T assessments from the Dutch threshold. The approach developed by RIVM considers PMT Working Group were used. In total, 626 substances persistency, mobility and toxicity simultaneously. The were detected, and 91 substances exceeded the target approaches also include different toxicity endpoints, but value in the European River Memorandum of 0.1 µg/l at both include QSARs predicting a substance’s carcino- least once between 2000 and 2019. This pollution affects genic, mutagenic, reprotoxic and endocrine disruptive about 3 million people that depend directly on Rhine potential. The RIVM approach also incorporates toxic - water (including lake IJssel) and a similar situation is ity screening based on Cramer Classes. Both approaches assumed at the Dutch Meuse water intakes. Both riv- consider some human health-related endpoints, while ers provide about 40% of Dutch drinking water, in areas ecotoxicity based on long-term toxicity to fish, daphnia where fresh groundwater is scarce. Extensive monitoring or algae is considered by the Danish team but not in the along the Rhine at the location Lobith identified that the RIVM approach. composition of these PMT/vPvM substances changed An inherent feature of all QSARs is that they work best over time, indicating that some substances were switched for substances that have similar structures to those in with other substances, due to regulatory or commercial their chemical calibration data set, which tend to be neu- forces (Additional file  1: Fig. S2). For example, efforts to tral substances [12, 88]. Despite this, if the uncertainty of identify and reduce the emissions of diglyme, MTBE/ predictions and application domains are taken into care- ETBE and pyrazole were effective, whilst the "hot" PMT/ ful consideration, QSAR-based screening approaches are vPvM substances such as 1,4-dioxane and TFA can be a valuable tool for the initial screening of potential PMT seen to have been introduced during the study period. substances [89]. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 11 of 24 Fig. 6 Removal Requirement Index for PMT substances at the intake of Nieuwegein (River Rhine), based on the methodology of Pronk et al. (2021) as described in https:// iwapo nline. com/ ws/ artic le/ 21/1/ 128/ 77954/A wat‑er‑ quali ty‑ index‑ for‑ the‑ remov al‑ requi rement. The Water Quality Removal Requirement Index is an indicator sum parameter that describes the gap between the standards in the Dutch drinking water act, and the quality of the source water. The gap increases when the concentrations of the pollutants increase, or when environmental quality standards are lowered There are many ambitious goals established via the the ambitions set. Reaching good ecological and chemi- WFD, the Urban Waste Water Treatment Directive cal status for water bodies covered by the WFD by 2027 (UWWTD, directive 91/271/EEC) and the Industrial seems increasingly unlikely [93, 94]. Similarly, results Emissions Directive (IED, directive 2010/75/EU) to pro- on the transparency of emissions is disappointing as tect surface and groundwater from the adverse effects of currently available information shows limited qual- discharges of urban and industrial waste water. In addi- ity, completeness, and homogeneity [95]. In contrast tion, both the Aarhus convention (1998) and the Kyiv to this, steps are being made forward in certain more Protocol (2003) provide a transparent ambition for the regional situations. For example, the Dutch system of registration of discharges and emissions. The Aarhus licensing industrial discharges was revised in 2019 to Convention details rights that organisations are entitled include a drinking water test as an additional require- to receive environmental information that is held by pub- ment to the existing regulatory WFD ecological and lic authorities. The Kyiv Protocol aims to enhance public chemical requirements. This ambitious approach is in access to information on industrial and WWTP emis- line with EU regulations and protects drinking water sions through the establishment of coherent, nationwide intake and thus human health from PMT/vPvM (and Pollutant Release and Transfer Registers (PRTRs). The other) substances, by prescribing additional pollution resulting “E-PRTR” is the EU system for collecting and abatement methods. In practice this means that when disseminating information about environmental releases a discharge of a PMT/vPvM substance is proposed, the and transfers of hazardous substances from industrial effect of this emission for a drinking water company and other facilities. Integration and implementation of is assessed. If it is found that the discharge could seri- these regulations could provide a basis for more, and ously affect the surface water quality, additional puri - improved, governance of PMT/vPvM substances, as they fication using the best available technology (BAT) or include risk assessment models and methods that local BAT with additional measures (BAT +) by the polluter authorities could put into practice, including a frame- is required, or the license will not be granted. work for the proper registration of emissions. The current review and revision of the IED and Based on the above, it appears that the WFD, the IED, UWWTD provides the opportunity to improve the the UWWTD, the Aarhus Convention and the Kyiv permitting procedures of PMT/vPvM substances and Protocol, in combination, provide an adequate frame- other relevant pollutant emissions in a similar manner. work of relevant environmental legislation and obliga- Movement in a common direction could improve inter- tion for transparency, at least in theory. However, the nal harmonization between all European regulations. results of these frameworks to date have not matched The identification of PMT/vPvM substances under REACH as Substance of Very High Concern (SVHC), as proposed by the European Commission in the Hale et al. Environmental Sciences Europe (2022) 34:22 Page 12 of 24 Chemicals Strategy for Sustainability Towards a Toxic when considering local pollution caused by an industrial Free Environment, could be used by the watershed or site or an incident. In addition, improvements in risk river authorities to demand extra purification when assessment models such as European union system for these (and other relevant) substances are emitted to the evaluation of substances (EUSES) and SimpleTreat the aquatic water environment, and for registration in can contribute to providing a more accurate assessment the in the E-PRTR system. Such an optimized licensing of the current situation. In particular, exposure-based and registration system could lead to improved water models are well defined for substances entering water via quality. soil leaching. However, another relevant entry pathway is linked to the process of riverbank filtration. Currently, Getting in control of PMT/vPvM substances this pathway is not sufficiently covered by existing mod - through chemical industry stewardship (M. Collard, D. els and additional research is needed. Drmač, T. Kullick, S. Pawlowski) It is important that the approach taken to regulate The chemical industry is constantly improving measures PMT/vPvM substances is harmonized both geographi- to reduce the release of chemicals into the environment. cally and across regulations. Within the EU, risk assess- Successful stewardship measures have been used in the ment approaches for the protection of drinking water past to reduce major environmental contaminants which resources (focusing on groundwater) are well established led to the increase in both species number and abun- for plant protection products (PPP) and biocidal active dance in large urbanised rivers, such as the Rhine [1, products, for deriving Guideline Values for drinking 96–98]. Due to improved analytical methods, more sub- water by the WHO and the Drinking Water Directive, stances can be detected at low concentrations including and to some extent under REACH (i.e. man via the envi- those found in drinking water. In Germany, an initiative ronment). The interplay between hazard assessment, risk launched by the German Federal Environment Ministry assessment and risk management in those frameworks is (BMU) entitled “Trace substance strategy of the German illustrated in Fig. 7. Environment” is currently underway to tackle this issue. In the context of establishing a global approach, poten- The chemical industry (through the German Chemical tial drinking water contaminants can be assessed as the Industry-VCI) is strongly contributing to this round table other chemicals under REACH, i.e. a hazard assessment discussion with strategies and options for actions in a based on the intrinsic properties of the substances with a multi-stage process. follow-up risk assessment based on its uses. As part of this work, both chemical properties and use patterns are considered in order to quantify the impact of contaminants found in water on human health and the Prevention environment. Whilst persistent and mobile substances Getting in control of PMT/vPvM substances may have a higher probability of contaminating ground- through regulation (F.S. Averbeck, S.E. Hale, M. Neumann, water, the amount and use pattern as well as the way it J. Schulze) is emitted into the environment are also the major driv- Active steps towards new policies and regulations ers for its detection [84]. This is true of caffeine. Whilst for PMT/vPvM substances are currently occurring it is not persistent (because it is readily biodegradable) at the highest European level. Upstream preventative it is a major drinking water contaminant, and was also approaches are recognised as one of the most effective detected in the Dutch monitoring study mentioned ear- methods to reduce environmental and human health lier, because it is emitted constantly and daily by millions hazards as well as exposure from harmful substances as of people all across Europe [99]. Conversely, a persis- part of the Chemicals Strategy for Sustainability Towards tent and mobile substance used under strictly controlled a Toxic Free Environment [15]. Key aspects to achieving conditions with risk management measures in place to these goals is the revision of the CLP regulation and the avoid release to the environment is unlikely to be a drink- REACH regulation, which are important cornerstones of ing water contaminant. It is apparent, therefore, that to the EU’s regulation of chemicals. Therein, the following tackle possible contamination of water at concentra- action points, related to getting control of PMT/vPvM tions posing a risk to human health and the environment, substances, have been defined: emission patterns need to be considered in addition to substance properties [55]. A stepwise process: “screen— • create new hazard classes and criteria in the CLP prioritise—assess—control” is useful to minimize envi- regulation by 2021, ronmental and human health risks. This can be assisted • amend Article 57 of REACH to add endocrine dis- by a strong collaboration among local stakeholders, e.g. ruptors as well as PMT and vPvM substances by local industry and drinking water suppliers, especially Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 13 of 24 Fig. 7 Typical hazard assessment and risk assessment approach applied for chemical assessment today and their use in current legislative frameworks for drinking water and/or groundwater protection. DW drinking water, GW groundwater, DWD drinking water directive, GV guideline value, PPPR plant protection products regulation, BPR biocide products regulation, IED Industrial Emissions Directive 2022 in order to identify those as Substances of Very across a wide range of sectors (e.g. consumer products, High Concern (SVHC), waste, or industrial applications) can be achieved. This is • restrict all PFAS in a broad manner to ensure a PFAS being referred to as "one substance-one assessment". The phase out for "all but essential uses" by 2024 and implementation of new hazard classes in the CLP Regu- • define criteria for essential use drawing on the defi - lation without prior implementation at the level of the nition in the Montreal Protocol by 2022 (date to be Globally Harmonized System of Classification and Label - confirmed). ling of Chemicals (GHS) is an unusual step. Since the CLP Regulation is the legal instrument for the translation To drive these changes, the EU will promote and of GHS on the European level, changes are usually made reward production and use of safe and sustainable chem- in a “top down” manner. However, this approach could icals and incentivize innovation and substitution of sub- build the basis for modifications of GHS using a more stances of concern, as described below. “bottom up” approach. Criteria for the more specific drafting of the new haz - ard classes are currently being discussed by the Com- CLP regulation petent Authorities for REACH and CLP (CAR ACA L), a As part of the revision of the CLP Regulation, the follow- group advising the EU Commission on questions related ing new hazard classes have been proposed by the EU to REACH and CLP in close exchange with the respective Commission: endocrine disruptors (EDs); PBT and vPvB experts, e.g. ECHAs PBT expert group. An adoption of substances; and, PMT and vPvM substances. From 2015, the changes is expected in 2022. the CLP Regulation represents the only legal instrument in force for the classification and labelling of substances in the EU and as such has implications for other chemi- REACH regulation cal legislations. By expanding the CLP Regulation, a more Similar to the changes of the CLP Regulation, adap- harmonized and higher level of protection from harm- tations of the REACH Regulation are part of a broad ful chemicals for human health and the environment Hale et al. Environmental Sciences Europe (2022) 34:22 Page 14 of 24 development of the EU’s substance related and envi- release factors and emission calculations. In addition, ronmental regulations. Plans to adapt the legal text by information on the availability and feasibility of alterna- amending Article 57 to include PMT and vPvM sub- tives as well as the socio-economic impact of a PFAS ban stances to be identified as SVHC aim to provide a higher needs to be considered. level of protection. Currently, identifying PMT/vPvM The five authorities aim to submit the restriction substances as SVHC is only possible by demonstrating proposal to the European Chemicals Agency (ECHA) an equivalent level of concern to substances that are, for in July 2022 [103]. It will then be assessed by ECHA’s example, CMR or PBT/vPvB substances. Other changes scientific committees RAC (Committee for risk assess - to the legal text shall ensure a stronger and more efficient ment) and SEAC (Committee for socio-economic enforcement by requiring dossier evaluations for all reg- analysis). In parallel, a consultation on the proposal istrations (currently only required for a share of new reg- will provide a possibility to stakeholders to submit istrations) and revising the authorization and restriction evidence and comments. The committees have to pro - procedure. vide their scientific opinion on the proposal within Additionally, revisions of the Annexes of REACH are 9  months (RAC) or 12  months (SEAC) after publica- planned to better prioritize SVHC for (group) restric- tion of the restriction dossier. After finalisation, the tions as well as to adapt the data requirements (i.e. what opinions of the committees together with the proposal kind of information needs to be provided in the registra- and the comments received during the consultation will tion dossier) for EDs, and to restrict all “non-essential” be submitted to the EU Commission for political deci- uses of PFAS by adding the group to the list of restricted sion-making. A decision by the EU Commission and substances in Annex XVII. entering into force of the restriction can be expected in 2024; given a transition period, the restriction could apply from 2025. PFAS restriction The broad restriction of PFAS as a group is being led by Germany, the Netherlands, Denmark, Norway and Swe- Essential use den. The restriction will cover all uses of PFAS and will The concept of essential use is applied in the Montreal aim to reduce regrettable substitution possibilities (such Protocol, which outlines the global agreement on the as when HFPO-DA replaced PFOA [100]). PFAS was phase-out of the production and use of ozone deplet- recently defined as substances that contain at least one ing substances [104]. However, it also allows parties to aliphatic carbon atom that is both saturated and fully propose exemptions for certain substances and uses of fluorinated. This includes any chemical with at least one that are considered essential at a national level. The two perfluorinated methyl group (-CF ) or at least one per- elements of an essential use under the Montreal Proto- fluorinated methylene group (-CF -), including branched col are that a use is “necessary for health, safety or is fluoroalkyl groups and substances containing ether link - critical for the functioning of society” and that “there ages, fluoropolymers and side chain fluorinated polymers are no available technically and economically feasible [101, 102]. More details about PFAS and their uses and alternatives”. Scientific discussion and debate around environmental occurrence can be found in section "More the essential use concept has increased since a paper details about PFAS and their uses and environmental was published in 2019 applying it to uses of PFAS [105]. occurrence" in the Additional file 1. Three use categories were defined: 1) “Non-essential As the broad restriction process continues, there are uses" which are those driven by convenience and busi- several points that need special attention. The first is ness opportunities and that are “nice to have” rather that there are only very few substances within the diverse than having a function that is critical for health and PFAS class for which hazardous properties are known. safety, and the functioning of society, 2) “Substitutable For most of the substances in the group, no or only very uses", where the substance of concern does have a func- little information is available. Nevertheless, the restric- tion necessary for health, safety or critical for the func- tion proposal will demonstrate that a precautionary tioning of society, but its use is considered unnecessary approach is needed for PFAS and that they should be reg- because there are suitable alternatives available, and 3) ulated as a group even if data is lacking. Another impor- “Essential uses" as described in the Montreal protocol. tant point is the availability of data related to aspects Since this first publication, debate between scientists, such as operational conditions or containment during regulators and chemical manufacturers has been ongo- manufacture and use or emissions during the whole ser- ing and the most recent scientific paper published in vice-life including end of life. Where specific information 2021 [106] sets out to address common questions and is missing, realistic worst-case scenarios will be used for possible misinterpretations of the essential use criteria. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 15 of 24 Questions such as "Who should apply the essential use requires some knowledge of the foreseen use of the concept?", "Is the essential use concept a threat to inno- design candidate substances. Crucial elements in such vation or an opportunity?", "For which uses of which design would be how to fill data gaps for the design chemicals should the essential use concept be applied?" candidates, which models to use, the protection level to and "Which uses of chemicals are critical for the func- apply, and the criteria for assessing the overall impacts tioning of society?" are addressed. The authors go on of a chemical, a material, a product or process. In the to conclude that many of the challenges for the further final scoring of the design candidates’ minimum crite - implementation of the concept are not insurmount- ria need to be set so that the design candidates ‘do no able. For instance, one important way to address many significant harm’ on all the four parameters of safety to of these challenges is to innovate towards safe and sus- human and environmental health. A maximum score is tainable alternatives to PFAS. set for each parameter, to allow to sum the scores with- out one score skewing the total score. Getting in control of PMT/vPvM substances through safe Another consideration might be if the chemicals in and sustainable by design strategies (H.P.H. Arp, A. practice are likely to be kept inside the technosphere, also Lennquist, N. Reineke, X. Trier) at their end of life during the separation and collection of The ambitions in the Chemical Strategy for Sustain - the chemicals. Such considerations of whether a risk can ability Towards a Toxic Free Environment [15] call for a be ‘managed’ are currently applied in risk assessments, transition towards a new approach for how we use and e.g. under REACH. The concern is however that it is very assess substances. This new approach should increase difficult to foresee future uses of materials in a global the ability to generate goods in ways that minimize recycling market, as well as assessing if the incidences of harm from chemicals along lifecycles of the chemicals e.g. spills will increase with climate change, due to e.g. and the products they are used in, and for the multi- flooding of contaminated sites or storms and fires lead - ple aims of the EU Environmental Green Deal: Mak- ing to accidents at industrial sites or even just overflow ing chemicals safe towards human and environmental of waste water. In such an approach, substances with- health, i.e. related to ecotoxicity, resource extraction out hazard properties or the most manageable hazard and climate change. Such impacts along the lifecy- properties, as confirmed with the most assessment data cles will have to be considered not just in the typical possible, would be preferential design candidates. There - 5–10  years short term, but over the next 50–100  years fore, there would be an increasing market for chemicals to protect future generations. This approach is referred that are less risky, even if they accidentally are spilled to as Safe and Sustainable by Design (SSBD) in the in the environment – and therefore also for substances Chemical Strategy for Sustainability Towards a Toxic that are and form non-persistent, non-(eco)toxic sub- Free Environment. Given the complexity of chemicals, stances, and which require low energy to synthesize and and their (un)foreseen uses across multiple cycles of to manage though their supply chains. As another con- the materials, it is key to avoid the use of substances sequence this will call for less complex materials that do of concern, such as PMT/vPvM substances from the not require persistent, (eco)toxic substances to achieve very beginning of the design phase [107]. The current their functionality, and which are possible to separate approach where only substances classified as SVHC are into clean materials during repair and recycling. The avoided (or not even given authorisations) has not been EU’s Directorate-General for Research and Innovation sufficiently proactive to avoid pollution by e.g. PMT/ (DG RTD) mapped all the SSBD and related methodolo- vPvM substances and their precursors. Therefore, it is gies in 2021 [107] and the EU’s Joint Research Council very important that the identification and subsequent is currently developing the SSBD criteria for DG RTD. risk management of PMT/vPvM substances is acceler- European Commission activities on SSBD include fund- ated under current and future EU laws. In the SSBD ing of public–public research such as the Partnership for approach, the design starts with a consideration of Assessment of Risks of Chemicals (PARC), public–pri- which service to provide [107]. To ensure as broad and vate partnerships to start in 2022 and stakeholder meet- open innovation space as possible, different types of ings [108]. expertise will have to be included in the process, from the industrial and environmental chemists, material Prioritizing substances for substitution designers, toxicologists, end-user experts, supply chain, As mentioned above, one important way to approach the marketing, economic and legal experts. This group will SSBD strategy is to prioritize which substances should be select a few design candidate substances not containing replaced or avoided at the design stage. Databases and or foreseen to generate substances of concern, which lists of harmful chemicals, such as the REACH SVHC list, will be assessed for impacts along their lifecycles. This addressing classes of chemicals known to be of concern Hale et al. Environmental Sciences Europe (2022) 34:22 Page 16 of 24 Avoiding regrettable substitution (such as PFAS, phthalates, bisphenols, isocyanates, anti- When replacing substances of concern with sustainable microbials, organochlorines and organobromines [109]), chemicals as part of an SSBD strategy, there are several or the Substitute It Now List (SIN List [110]) published by lessons that can be learned from previous unsuccess- ChemSec provide good starting points to alert industry ful attempts, so called "regrettable substitution" [112]. to which chemicals are needed to be replaced by safe and A well-known example of regrettable substitution was sustainable alternatives. Increasingly companies avoid the substitution of the endocrine disrupting chemical using such classes of substances of concern in their pro- bisphenol A with alternative bisphenols that were simi- curement, both to protect their customers, the environ- larly harmful [113]. An example of burden shifting is ment, and their business reputation and hence income found in the Montreal Protocol, where the substitution (for example companies included in the ChemSec busi- of refrigerants from ozone depleting chlorofluorocarbons ness group). The SIN List was launched in 2008 to pro - (CFC) to hydrofluorocarbons (HFCs) was made, despite vide guidance to industry on what substances to expect their very high global warming potential [114]. This led to be included in upcoming regulations. The SIN List to amendments of the Montreal Protocol to reduce use uses the criteria for SVHC in REACH to list substances of the most potent greenhouse cases, and hydrofluor - ahead of the official and much slower process to populate oolefins (HFO). However, some HFCs and HFOs can the Candidate SVHC List. This means that in addition to degrade to the vPvM substance TFA discussed above, at applying the existing criteria, the SIN List contains sub- yields of between 7 and 100% [18]. The newest iteration stances that are predicted (by ChemSec) to be targeted of the Montreal Protocol, the Kigali Amendment, which by regulations in the near future, based on an analysis is not yet ratified, seeks to phase out all hydrofluorocar - of potential developments in chemical regulations. For bons; possible non-halogenated alternatives like CO and instance, the SIN List has managed to both predict and ammonia (see section "Additional details about avoiding influence the development of new regulations for endo - regrettable substitution of refrigerants" in the Additional crine disrupting chemicals. Some EDCs were added to file  1 for more details). Both bisphenol A and the his- the SIN List in 2011 and 2014, which in turn influenced tory of the Montreal protocol serve as examples of how their chemical management and policy discussion, ulti- important it is to avoid regrettable substitution and eval- mately culminating with their suggested inclusion as uate burden shifting of risks to other domains [89, 115]. a new category for SVHCs in REACH, as well as a new Currently we are in a situation where there is a strong hazard class. The 32 EDCs included in the SIN list were demand to move away from burning of fossil fuels that added on the basis of peer reviewed data and regulatory pollutes the atmosphere with greenhouse gases (such as guidance documents. This list was used and referred to CO and methane) to ‘clean’ renewable energy. While by companies, authorities, financial investors and others. there is no doubt of the urgency of reducing GHG emis- The first EDC was added to the Candidate List in 2012, sions, there is a risk that the replacement technolo- and since then more and more EDCs have been placed on gies contribute to pollution of freshwater resources. For the Candidate List, but at a slow pace. To date 19 chemi- instance, many are ionic liquids and molten salts, such cals have been placed on the Candidate List because of as bis(trifluoromethane)sulfonimide is used as coun - endocrine disrupting properties. ter ions in lithium batteries. Both the substance itself as In 2019, 16 PMT substances were added to the SIN well as its degradation products such as C F -SO -OH, List after ChemSec realized that the most likely devel- 3 2 are likely persistent and highly water mobile substances. opment of REACH would relate to the PMT/vPvM sub- Recent studies have detected CF -SO -OH widespread stance concept being developed at the time [4, 41]. The 3 2 in German surface waters [18]. This risk is particularly initial PMT/vPvM substance list was narrowed down high if the recovery of Lithium metals in batteries occurs to 16 substances following in-depth scientific evalua - under uncontrolled conditions in open systems by ther- tions [111] and by considering substance uses in order mal recovery at smoldering temperatures of 300–500 °C, to ensure that the listed substances were actually of rel- where also the fluoropolymers PVDF and PTFE may evance for companies. Since then, two of these 16 sub- form smaller PFAS degradation products. Since recovery stances (PFBS and 1,4-dioxane) have been identified systems for fluorinated polymers and such ionic liquids as SVHC based on their intrinsic properties and being are not in place in the scale of the development of renew- regarded as posing an equivalent level of concern (ELoC) able energy technologies, there is a high risk of regretta- to PBT/vPvB substances. In addition, 2,3,3,3-tetrafluoro- ble substitution replacing greenhouse gas pollution with 2-(heptafluoropropoxy)propionic acid (HFPO-DA, also human and ecotoxic chemical water pollution—particu- known as GenX) was identified as a SVHC due to PMT larly if recovery takes place outside of Europe where it is substance properties giving rise to an ELoC to PBT/vPvB difficult to ensure controlled closed-loop systems. substances. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 17 of 24 Based on these previous examples, the main chal- Sustainability Towards a Toxic Free Environment [15], lenge in alternatives assessment, is to identify better including its ambitious targets such as the PFAS restric- and safer solutions for problematic applications in the tion and incorporating PMT/vPvM in the CLP and long term [116], following the safe and sustainable by REACH regulations, as discussed above. An important design approach [107]. Even in cases where alternatives concern was related to the lack of harmonized approach are available, the transition to SSBD requires much that either unifies or explicitly accounts discrepancies in more. Enabling conditions such as policies (covering other European regulations or international regulations is policies on products, and finance), education and tech - accounted for, such as the potential discrepancy between nical support centres (to help industry to run SSBD the CLP regulation in Europe and the United Nations and develop documentation of compliance) must be in Global Harmonized System regulation. place [107]. Education is of particular interest since it is related to changes in perceptions and values, which Gap in analytical methods range as some of the most powerful elements in cre- Poll results: Wide gap (33%); closing gap (57%); negligible ating transitions. Not only will new technical skills be gap (10%). required, but process skills to run an interdisciplinary The gap in analytical methods being ranked second design process are needed. This is key to keep the inno - smallest is reflective of the recent advances in analyti - vation space open for providing services in various cal methods presented above, as there are currently a ways, including also by other business models that sell great number of tools available for PMT/vPvM sub- services rather than products. stance quantification. The main limitations to their use are practical, due to the small number of labs with the needed equipment, lack of reference standards for target Conclusion analysis, and the difficulty in quantifying unknowns from Size of the gaps related to getting in control of PMT/vPvM non-target analysis. That said, the current regulatory and substances (H. P H. Arp, S. E. Hale) environmental and human health protection focus given At the Third PMT/vPvM workshop where all of the to PMT/vPvM substances may potentially drive further information in this review was presented and discussed, establishment of more accessible analytical methods for the participants and attendees, consisting of regulators, PMT/vPvM substances in the coming years. Regarding researchers, chemical industry representatives, water reference standards, there is need for more examples of producer representatives, and public safety NGOs, were stewardship, such as that of the European Crop Protec- invited to answer an online poll designed by the work- tion Association who agreed to provide reference stand- shop organisers (consisting of this paper’s co-authors: ards of pesticide transformation products that are not Sarah E Hale, Hans Peter H Arp, Michael Neumann, commercially available. Ivo Schliebner and Jona Schulze). The poll consisted of 10 gaps related to getting in control of PMT/vPvM sub- Gap in risk assessment tools stances and the respondents were asked whether they Poll results: Wide gap (34%); closing gap (53%); negligible thought the gap was wide, closing, or negligible [117]. gap (13%). A summary of the 120 respondents, presented in order The gap in risk assessment tools was ranked 8th, and of the size of the gap, from smallest to largest, is given this may be reflective of positive experiences with risk below. It must be noted that this response rate is just 17% assessment models, such as the European union sys- of the peak audience numbers and the conclusions draw tem for the evaluation of substances (EUSES) [118] and may not reflect the view of all workshop participants. RIVM’s SimpleTreat model for waste water treatment plants [119]. However, there are several substantial chal- lenges for the development of risk assessment tools for Gap in chemical legislation industrial substances, such as accounting for a diverse Poll results: Wide gap (23%); closing gap (63%); negligible array of emission scenarios [120], linking multi-media gap (14%). modelling with subsurface flow modelling (e.g. bank fil - Chemical legislation was considered to have the small- tration) [84], and accounting for the complex sorption est gap (ranked tenth), despite some short comings and behaviour of mobility ionic and ionizable substances difference of opinion of how well the WFD, the IED, the [121]. Currently there are research initiatives to improve UWWTD, the Aarhus Convention and the Kyiv Protocol risk assessments of persistent and mobile substances, were protecting the environment from exposure to PMT/ (e.g. [122]), being driven by industrial stewardship (see vPvM substances. This small gap may have been reflec - Fig. 7) and other programs. tive of the recently announced Chemicals Strategy for Hale et al. Environmental Sciences Europe (2022) 34:22 Page 18 of 24 Gap in mobility data solutions in critical areas, particularly around points of Poll results: Wide gap (37%); closing gap (47%); negligible highly concentrated chemical discharge. gap (16%). The gap in mobility data, particularly log K , was Gap in toxicity data oc ranked 7th and notably lower in comparison to the gaps Poll results: Wide gap (60%); closing gap (30%); negligible in persistency data and toxicity data. An important con- gap (10%). cern related to the gap in mobility data is the complex Though there is a lot of toxicity data required for chem - nature of the sorption behaviour of ionic and ionizable ical registration as part of the REACH regulation, this gap substances [41, 83, 123]; K experiments or sorption being ranked 4th important may be related to the lack of oc experiments may be considered much easier than simu- data for long-term chronic exposure to drinking water, lated half-life studies or a battery of toxicity tests, as indi- and the time lag it has taken to recognize toxic mecha- cated by the large number of substances with K values nisms of many PFAS substances, after initial monitoring oc in the literature compared to half-lives [16]. It should be data have become available [85]. This was recently dem - noted that the gap P, M and T data is linked to the gap in onstrated when PFBS and 1,4-dioxane were identified as risk assessment models, as without detailed knowledge of SVHC owing to their equivalent level of concern, as envi- half-lives, environmental pathways and toxicity, in addi- ronmental monitoring data go back decades before the tion to exposure pathways, it is challenging to accurately classifications of ecotoxic (PFBS) and carcinogenic (1,4 foresee risks. dioxane), respectively [10, 126, 127]. Another concern is mixture effects from the multiple, mostly unknown Gap in persistency data PMT/vPvM substances and transformation products in Poll results: Wide gap (41%); closing gap (50%); negligible drinking water, requiring the advancement of techniques gap (9%). like effect directed analysis to assess drinking water safety The gap in measured half-life data (reflective of per - [128]. sistency), is known to be substantial, as this is so rarely quantified [73, 75] and thus this gap was ranked 6th. Per- Gap in safe and sustainable substitutes sistency data is the biggest bottle neck to a PMT/vPvM Poll results: Wide gap (60%); closing gap (34%); negligible substance evaluation, hence the need for methods like gap (6%). the OECD 309 test presented above. It is likely that this The gap in safe and sustainable substances being rd gap could be reduced by adjusting the regulatory defini - ranked 3 largest is reflective of the newness and argu - tion of persistency, which is difficult based on the strong ably complexity of this topic. SSBD represents a new consensus around the current definition [124], or devel - approach that will require collaboration of various pro- oping simpler methods or guidelines to infer environ- fessionals including industrial designers, materials chem- mental half-lives, which appears most practical. ists, chemists, toxicologists/modellers, risk assessors, supply chain experts, marketing and retail experts. For Gap in water remediation infrastructure instance, chemists could select feedstock/process/fin - Poll results: Wide gap (56%); closing gap (31%); negligible ishing chemicals, assess their characteristics and risks gap (13%). by modelling. Traditional synthetic chemistry must be The gap in water infrastructure, ranked 5th, is a reflec - weighed against biochemical synthesis, an appreciation tion on water remediation infrastructure varying geo- of how the materials used can be recycled is needed and graphically, from areas with advance treatment, to areas compliance method to test final products for substances with only basic treatment [125]. This paper has shown of concern must be developed. that certain PMT/vPvM substances, like TFA, can only be removed using expensive, energy intensive processes Gap in monitoring data like reverse osmosis or ion exchange resins. Upgrad- Poll results: Wide gap (64%); closing gap (32%); negligible ing equipment at water treatment plants would be not gap (4%). feasible in all geographic regions. End of pipe solutions The gap in monitoring data was considered as the sec - should only be considered as complementary strategies ond largest because most industries and regional regu- for specific scenarios where the “polluter pays” princi - lators are not currently investing in screening programs ple may, to some extent, be applicable. Thus, substitution for emerging PMT/vPvM substances, particularly out- and avoidance of PMT/vPvM substance emission needs side of Western Europe. Even within Europe, monitor- to be prioritized as the safer, cheaper, and more sustain- ing for such substances has mainly been carried out by able strategy to get in control of these substances. Never- universities, research institutes and in some areas water theless, advance remediation infrastructure can provide producers. Analytical techniques are not the problem Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 19 of 24 (as this was ranked the 9th), but the scarcity of monitor- advocate groups and regulatory mechanisms are in place ing occurring. One main reason for this is likely lack of to stimulate innovation away from harmful PMT/vPvM regulatory pressure, as initial findings from scientists will substances. Realising the goals set out in the Chemicals often not spread into conventional monitoring programs Strategy for Sustainability Towards a Toxic Free Environ- without such regulatory guidance. Further, as the Swiss ment will form an important basis for this cooperation monitoring study highlighted here illustrated, there are towards zero pollution of PMT/vPvM substances. several lines of evidence through non-target analysis that there are instances of pollution by unknown synthetic Methods chemicals and their transformation products [50]; which The "Third PMT Workshop: Getting control of PMT leads us to the largest gap. and vPvM substances under REACH", took place on the 25th and 26th of March 2021 (online) and was attended Gap in the knowledge of substance mixtures by over 700 people. The audience and presenters con - and transformation products sisted of scientists, chemical and water regulators, envi- Poll results: Wide gap (91%); closing gap (7%); negligible ronment and health non-government organisations, and gap (2%). representatives from the chemical production and water The gap in the knowledge of substance mixtures and services sectors, all concerned with protecting the quality transformation products was ranked as the largest gap. of our water resources. Presentations were held about the Many REACH registered substances are "unknown knowledge gaps detailed above and attendees were invited or variable composition, complex reaction products" to provide their opinions about the size of the knowledge (referred to as UVCBs). Their substance composition is gaps related to PMT/vPvM substance research and regu- complex, but may contain several PMT/vPvM substances lation. The diverse perspectives from the presenters who of concern. Further, it is often observed that many of the make up the author group are presented herein to show known transformation products of persistent substances new ideas of how PMT/vPvM substances can be brought are persistent substances that are also mobile [12, 129]. under control in order to protect water resources, par- There are also many unresolved signals from non-target ticularly those registered under REACH. screening approaches that could be transformation prod- ucts, as presented with Swiss monitoring study above any Supplementary Information database [50]. Smart suspect lists on PMT/vPvM sub- The online version contains supplementary material available at https:// doi. org/ 10. 1186/ s12302‑ 022‑ 00604‑4. stances including transformation products identified in studies by industry for the REACH registration process Additional file 1. Additional file consisting of figures, tables and text. could be very beneficial for future comprehensive moni - toring. Ideally, these lists should not only contain the compounds’ names and properties but also link to open Acknowledgements Karin Kiefer, Eawag, generated Additional file 1: Fig. S1. access spectra libraries where the MS spectra are avail- able to support the identification process. Authors’ contributions SEH conceived the original article structure, co‑ developed the original draft, contributed to original writing and led revisions of the manuscript, ensuring Getting in control of PMT/vPvM substances all authors have approved the submitted article. HPA co‑ developed the origi‑ through collaboration (H. P H. Arp, S. E. Hale) nal draft, contributed to original writing, co‑revised the entire manuscript, and Getting in control of PMT/vPvM substances requires led the data analysis of polling results. All other authors wrote and revised the chapters for which they are explicitly named. All authors read and approved collaboration and dialogue between all stakeholders, the final manuscript. even beyond the diverse set represented by the authors of this current review. Regulation and governance strate- Funding S.E. Hale and H.P.H. Arp acknowledge funding from the German Federal Min‑ gies would work best alongside industrial stewardship to istry for the Environment, Nature Conservation, Building and Nuclear Safety best manage PMT/vPvM substances. SSBD tools require (FKZ3719654080). a collaboration of environmental scientists and toxicolo- Availability of data and materials gists that conduct risk and alternatives assessment, based The datasets used and/or analysed during the current study are available from on the input from all designers, synthetic chemists, sup- the corresponding author on reasonable request. ply chain experts and material scientists concerned with the design of the product or service that is seeking to phase out PMT/vPvM substances. 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Getting in control of persistent, mobile and toxic (PMT) and very persistent and very mobile (vPvM) substances to protect water resources: strategies from diverse perspectives

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Abstract

Background: Safe and clean drinking water is essential for human life. Persistent, mobile and toxic (PMT ) sub‑ stances and/or very persistent and very mobile (vPvM) substances are an important group of substances for which additional measures to protect water resources may be needed to avoid negative environmental and human health effects. PMT/vPvM substances do not sufficiently biodegrade in the environment, they can travel long distances with water and are toxic (those that are PMT substances) to the environment and/or human health. PMT/vPvM substance research and regulation is arguably in its infancy and in order to get in control of these substances the following (non‑ exhaustive list of ) knowledge gaps should to be addressed: environmental occurrence; the suitability of cur‑ rently available analytical methods; the effectiveness and availability of treatment technologies; the ability of regional governance and industrial stewardship to contribute to safe drinking water while supporting innovation; the ways in which policies and regulations can be used most effectively to govern these substances; and, the identification of safe and sustainable alternatives. Methods: The work is the outcome of the third PMT workshop, held in March 2021, that brought together diverse scientists, regulators, NGOs, and representatives from the water sector and the chemical sector, all concerned with protecting the quality of our water resources. The online workshop was attended by over 700 people. The knowledge gaps above were discussed in the presentations given and the attendees were invited to provide their opinions about knowledge gaps related to PMT/vPvM substance research and regulation. Results: Strategies to closing the knowledge, technical and practical gaps to get in control of PMT/vPvM substances can be rooted in the Chemicals Strategy for Sustainability Towards a Toxic Free Environment from the European Commission, as well as recent advances in the research and industrial stewardship. Key to closing these gaps are: (i) advancing remediation and removal strategies for PMT/vPvM substances that are already in the environment, how‑ ever this is not an effective long‑term strategy; (ii) clear and harmonized definitions of PMT/vPvM substances across *Correspondence: sarah.hale@ngi.no Norwegian Geotechnical Institute (NGI), Ullevål Stadion, P.O. Box 3930, 0806 Oslo, Norway Full list of author information is available at the end of the article © The Author(s) 2022. Open Access This article is licensed under a Creative Commons Attribution 4.0 International License, which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons licence, and indicate if changes were made. The images or other third party material in this article are included in the article’s Creative Commons licence, unless indicated otherwise in a credit line to the material. If material is not included in the article’s Creative Commons licence and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder. To view a copy of this licence, visit http:// creat iveco mmons. org/ licen ses/ by/4. 0/. Hale et al. Environmental Sciences Europe (2022) 34:22 Page 2 of 24 diverse European and international legislations; (iii) ensuring wider availability of analytical methods and reference standards; (iv) addressing data gaps related to persistence, mobility and toxicity of chemical substances, particularly transformation products and those within complex substance mixtures; and (v) advancing monitoring and risk assess‑ ment tools for stewardship and regulatory compliance. The two most effective ways to get in control were identified to be source control through risk governance efforts, and enhancing market incentives for alternatives to PMT/vPvM substances by using safe and sustainable by design strategies. Keywords: Water protection, Regulation, Governance, Stewardship, Prevention, Remediation Introduction contamination if they are emitted in substantial quanti- PMT/vPvM substances as a threat to water security (H.P.H. ties. In the content of this paper, mobility of PMT/vPvM Arp, C. Castell‑Exner, S.E. Hale and X. Trier) substances refers to the fact that they can travel long Safe and clean drinking water is essential for human life. distances with water, even in the subsurface and thus The European Drinking Water Policy began in the 1980s are able to spread over large spatial and temporal scales. with the aim to ensure that water intended for human This means it may be difficult to relate the point of pollu - consumption is consumed safely on a life-long basis and tion release to the final point of contamination. Concur - as such guarantees a high level of health protection. In rently these substances can present a threat to planetary order to meet the set of legal requirements stipulated boundaries [5]. If continuously emitted into freshwa- by current policies, water suppliers must have access to ter systems, and not removed, concentrations of PMT/ adequate and reliable drinking water resources that are vPvM substances will gradually increase and they will be protected from chemical pollution and other threats. Ide- detected in more areas. As many PMT/vPvM substances ally, these drinking water resources should have a natural are extremely difficult to remove from water resources status or should only have to be treated using natural or especially when waste water is recycled for drinking conventional techniques, like sand filtration or aeration, water purposes, exposure will also increase with continu- to meet drinking water quality standards. In this way, ing emissions [6–8] unnecessary consumer costs are avoided while conserv- PMT/vPvM substance research and regulation is argu- ing water’s pristine qualities. ably in its infancy [9–13] and several gaps have already It is possible to manage the threat from chemical pol- been outlined [14]. In order to forward knowledge lution in such a way that harm to human health and the related to these substances the following (non-exhaustive ecosystem is minimized. This has been demonstrated list of ) gaps should be addressed: environmental occur- over recent decades in areas such as the Rhine River rence; the suitability of currently available analytical Basin [1]. However, as the chemical industry continu- methods; the effectiveness of treatment technologies; the ously innovates, currently developed tools for environ- ability of regional governance and industrial stewardship mental risk assessment struggle to keep up with the to contribute to safe drinking water and environmen- diversity of chemicals and their uses [2]. Pollution occurs tal protection while supporting innovation; the ways in across the whole life cycle of a product from its produc- which (new) policies and regulations can be used most tion until its final disposal, whilst regulation typically effectively to govern these substances; and, the iden - only addresses the point at which products are placed on tification of safe and sustainable alternatives. Many of the market, which is only a small part of that lifecycle [3]. these knowledge gaps were discussed at the "Third PMT The increasing amount and diversity of emerging chemi - Workshop: Getting control of PMT and vPvM substances cals on the EU market that can enter water resources, under REACH", which took place on the 25th and 26th means it is important to consider whether changes to of March 2021 (online) which was attended by over 700 chemical and water resources management need to be people. made in order to inexpensively safeguard water resources in their natural state. Structure of this paper Persistent, mobile and toxic (PMT) substances and/or This paper presents a summary of the state of play for very persistent and very mobile (vPvM) substances pre- PMT/vPvM substances from many of the workshop sent an important example where additional measures to presenters with diverse backgrounds, including chemi- protect water resources may be needed to avoid negative cal and water regulators, analytical and environmental environmental and/or human health effects [4]. Owing chemists, representatives from environment and health to their persistent nature, they do not sufficiently biode - non-government organisations, and industry represent- grade in the environment and this can result in pervasive atives from the chemical production and water services Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 3 of 24 sectors. Each section of the paper is written by a sub- PMT/vPvM substances in the spotlight set of coauthors, as indicated. The perspectives from The examples of PMT/vPvM substances below reflect this author group are bought together  to present new those discussed at the third PMT workshop. These are ideas of how PMT/vPvM substances can be brought by no means exhaustive and the reader is referred to under control in order to protect water resources, par- additional literature containing extensive lists of sub- ticularly for those substances registered under REACH stances identified as PMT/vPvM substances. [16]. (Regulation 1907/2006 on the registration, evalua- tion, authorisation and restriction of chemicals). The knowledge gaps and perspectives are presented below Trifluoroacetate (TFA) (K. Nödler and M. Scheurer) by drawing on the toxic free hierarchy presented in the In 2016, elevated concentrations (10–20  µg/L) of the recently published "Chemicals Strategy for Sustainabil- chemical trifluoroacetate (TFA) (or trifluoroacetic ity Towards a Toxic Free Environment" [15]. Figure  1 acid, TFAA) were detected in tap water samples from schematically illustrates the toxic free hierarchy for a major city in Baden-Württemberg, Germany. Waste- PMT/vPvM substances, where the preferred options water discharge from an industrial company was later in green and at the top of the hierarchy are to prevent identified as the source of the contamination to bank use of PMT/vPvM substances, followed by strategies to filtrate which was used to produce tap water. Extended minimize and control PMT/vPvM substances in orange monitoring showed a measurable impact on the drink- and in the middle and, finally, the least preferred solu - ing water supply along the lower River Rhine [17]. TFA tion is to remediate PMT/vPvM substances, illustrated does not have a significant degradation pathway and in red at the bottom. This article begins by introducing this results in accumulation in the aquatic environ- PMT/vPvM substances that are currently in the spot- ment. This persistence, combined with the mobility light, then outlines strategies that can be used to get in of TFA and a lack of suitable water treatment options, control of analytical and monitoring methods for PMT/ presents a highly relevant and complex problem to vPvM substances to set the stage, and this is followed solve in order to minimize and control exposure [17]. by discussing options upward through the toxic-free In addition to industrial emissions there are many hierarchy; remediation, minimisation and control and, other primary product and process sources that emit finally prevention strategies. To conclude the paper, TFA directly, as well as secondary sources which are survey results from the third PMT workshop are used synthetic substances that form TFA in the environ- to highlight opinion related to what the largest knowl- ment. For example, the photochemical degradation of edge gaps are that need to be closed to get in control of certain propellants, refrigerants and blowing agents PMT/vPvM substances. [18] as well as the (bio)degradation of various com- pounds from other substance classes (e.g. pesticides and pharmaceuticals), all result in TFA formation [17, 19, 20]. Current monitoring studies show that TFA is a common contaminant in tap water [17], food crops [21] as well as in beer and tea [22] and, consequently, TFA was recently detected in blood samples from the gen- eral population (Chinese adult men and women, detec- tion rate 97%, median 8.5 µg/L) [23]. In addition, recent studies investigating ice cores from the Arctic [24] and precipitation in Germany [25] have confirmed increas - ing TFA levels in the environment from the 1990s dem- onstrating the ubiquitous nature of this substance. The toxicity of TFA in animals and aquatic systems is rather low. However, the microalga Raphidocelis subcapitata (formerly known as Selenastrum capricornutum) was identified as the most sensitive species [26] and the Fig. 1 Ways to manage PMT/vPvM substances in the environment according to prevention, minimization and remediation strategies. NOEC of 0.12  mg/L was shown to be exceeded in a Inspiration is drawn from the toxic free hierarchy presented in surface water near a TFA discharging industrial facility the "Chemicals Strategy for Sustainability Towards a Toxic Free [17]. For terrestrial plants NOELs and NOECs > 1 mg/L Environment" [15] Hale et al. Environmental Sciences Europe (2022) 34:22 Page 4 of 24 were reported by several authors. A comprehensive (pH 7) value < 0. The other substances (i.e. 19%) were summary of toxicity data regarding TFA can be found mixtures and could not be classified or have log D ow in Seiber and Cahill [27]. (pH 7) values above 4. Of the 74, 72 and 62 substances above, 32, 17 and 4 substances, respectively, contained 1,4‑Dioxane (Ivo Schliebner) chlorine or bromine; and 1, 18 and 33 substances, 1,4-dioxane has been found in groundwater and surface respectively, contained amino/acidic groups. water in Germany [11, 28], Spain [29], Belgium [30], the Analytical techniques capable of simultaneously USA and Japan [31–33], as well as detected in drinking detecting such diverse substance classes over a broad water in these and other regions [31, 34–36]. 1,4-Diox-log D range are advantageous when screening for ow ane has a plethora of uses. 1,4-Dioxane is a known by- such a diversity of PMT/vPvM substances that are product during the synthesis of polyethoxylates and suspected to be present. However, these methods may polyesters. The widespread uses of polyethoxylates encounter challenges related to separation and detec- (and polyesters) containing residual concentrations tion of such substances [42]. Figure 2 illustrates today’s of 1,4-dioxane can result in emissions to the environ- chromatographic techniques and their capabilities. For ment, mainly to waste water. It is also a solvent used as example, super-critical fluid chromatography (SFC) an industrial processing aid, but this use is unlikely to and reversed-phase liquid chromatography (RPLC) result in substantial emissions. coupled to hydrophilic interaction liquid chromatog- There are several studies that have pointed to the fact raphy (HILIC) allows for the analytical determination that 1,4-dioxane can be attenuated naturally to varying of substances with log D from −  9 to + 9 [24–26]. ow degrees [35, 37, 38]. However, a recent study reported This range is much wider than when using the con- that 1,4-dioxane was only marginally removed during ventional and common reversed-phase chromatogra- subsurface passage via river bank filtration and that the phy, which is mostly used in commercial laboratories. removal of 1,4-dioxane using an activated carbon filter Due to increasing needs in PMT/vPvM substance does not occur in practice [39]. Based on this evidence analysis, more commercial laboratories are installing of high persistency and mobility in the aquatic envi- a polarity-extended chromatography. The techniques ronment, together with 1,4-dioxane’s classification as shown in Fig. 2 can be coupled using electrospray ioni- Carc. 1B, it is a priority substance for regulatory assess- zation with high-sensitivity, high-accuracy and high- ment. At the time of writing this paper 1,4-dioxane was resolution tandem mass spectrometry (HRMS/MS). identified as a substance of very high concern under With such HRMS/MS systems non-targeted screening REACH [40], based on its PMT/vPvM properties being (NTS) analysis of ‘unknown’ PMT/vPvM molecules considered an equivalent level of concern to persistent, can be conducted. There are several openly accessi- bioaccumulative and toxic substances (PBT), and very ble platforms such as XCMS [43], MZmine [44], FOR- persistent, very bioaccumulative (vPvB) substances IDENT [45] and patRoon [46], which cover parts of [10]. or the entire NTS data evaluation and prioritization Getting in control of analytical methods and monitoring of PMT/vPvM substances Advances in analytical methods for PMT/vPvM substances (J. Hollender and T. Letzel) There are many more persistent and mobile substances than TFA and 1,4-dioxane. The previous studies report - ing compilation lists of PMT/vPvM substances [11, 12] are dominated by organic molecules with varying polar, ionizable and ionic functional groups. Taking for instance a list of 260 REACH substances that fulfil the PMT/vPvM criteria proposed by the German Environ- Fig. 2 Polarity scheme for chromatographic (electrophoretic) mental Agency in 2019 [4, 41], and further classifying separation techniques (like reversed‑phase liquid chromatography them on the basis of ‘polarity’ according to their log (RPLC), hydrophilic interaction liquid chromatography (HILIC), ion D , 74 of the 260 substances (i.e. 29%) have a log D ow ow chromatography (IC), capillary electrophoresis (CE) and supercritical (pH 7) value between 2 and 4, 72 of the 260 substances fluid chromatography (SFC)) based on log D values (at several pH ow (i.e. 28%) have a log D (pH 7) value between 0 and 2, values) of separable molecules and molecule characteristics, [48] ow adapted with polarity extended chromatography [49] and 62 of the 260 substances (i.e. 24%) have a log D ow Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 5 of 24 process. Using polarity extended chromatography, develop customized methods. A combination of meth- HRMS, FOR-IDENT and compound databases, sev- ods might be needed to separate and detect a broad eral vPvM substances (in the log D range from −  9 range of PMT substances in a robust way as shown in ow to + 9) such as N,N′-ethylenedi(diacetamide) [12] or Schulze et al. [57] and Fig. 2. 4-hydroxy -2,2,6,6- te trame thylpip er idine-1-e thanol [47] could be identified in surface waters and other Monitoring PMT/vPvM substances in groundwater (H.P.H. aqueous samples [12, 40, 42–44]. By comparing physic- Arp, J. Hollender and M. de Jonge) ochemical properties of suspect substances with target Many PMT/vPvM substances have been identified substances, information can be gained as to whether through groundwater monitoring using the analytical the suspect substance can be found with a given ana- techniques described above. In many regions ground- lytical method. Additional file  1: Fig. S1 shows 1162 water is the major drinking water resource, providing PMT/vPvM suspect substances (NORMAN Suspect approximately 50% of domestic water supply worldwide; List S82, https:// www. norman- netwo rk. com/ nds/ in Switzerland this can reach 70 to 80% [58]. Groundwa- SLE/) compiled for the Swiss groundwater screening ter is considered better protected from contamination study described below, [50] where approximately 90% compared to surface water [58], reducing the need for have a predicted log D and molecular volume in the water treatment. Despite this, a broad variety of com- ow same range as almost 500 target compounds that can pounds used in households, industry and agriculture be detected with polar modified RPLC coupled to elec- have been reported in groundwater at concentrations in trospray ionization to HRMS. the ng/L to µg/L range [59]. Here two illustrative cases However, even when polarity-extended chromato- studies are presented, one from Netherlands and one graphic separations are used, there are still several from Switzerland. challenges in the analysis of PMT/vPvM substances. The Dutch groundwater survey investigated the pres - To detect them with sufficient sensitivity in monitor- ence of 778 organic substances in raw water samples ing campaigns, enrichment is often needed; however, taken from 110 groundwater well fields in 2020 [60]. very mobile substances are easily lost during conven- Most of these well fields are considered vulnerable to pol - tional enrichment techniques like solid phase extrac- lution in newly formed groundwater, with about 30% of tion (SPE). Vacuum-assisted evaporative enrichment them being influenced by the infiltration of polluted sur - of water samples [51, 52], using a combination of sev- face water. Travel times in these groundwater sampling eral SPE materials including anion and cation exchange sites range from two years to several hundreds of years. materials [53], polarity extended SPE (e.g. [49]) or Results from the monitoring showed concentrations of larger injection volumes (e.g. [54]) are all potential 134 of the 778 monitored organic substances above the ways to overcome this problem. In addition to the analytical detection limit. issue with enrichment, identification of unknown sub- The Swiss groundwater study was based on samples stances can be time consuming and reference stand- from 60 national monitoring sites in Switzerland, and ards are often needed for the final confirmation of the included NTS analysis [50]. The samples were classified PMT/vPvM substance in question. However, reference as having high or low urban or agricultural influence standards are often not available, especially for trans- based on the occurrence of 139 of approximately 500 formation products [55]. It would be very beneficial screened target substances associated with either urban for the process of detection and confirmation of new or agricultural sources at the sites. High intensity and contaminants that reference materials or at least sub- frequency of occurrence of unknown peaks associated stance characteristics such as mass spectra would be with potential urban or agricultural sources were investi- provided by industry, such as during the chemical reg- gated further with suspect and non-target screening (for istration process. Finally, prioritization of unknown more information see the section "Monitoring data" in signals for substance identification is often based on the Additional file  1). New substances, not yet reported intensity [56] which can be misleading, as the sub- in groundwater were identified, including the industrial stance in question might not be ionized sufficiently. substance 2,5-dichlorobenzenesulfonic acid (log D ow, pH7 In summary, to detect novel PMT/vPvM substances 0.0, 19 detections, up to 100 ng/L), phenylphosponic acid in the environment, suspect screening with appropri-(log D −  2.0, 10 detections, up to 50  ng/L), triiso- ow, pH7 ate suspect lists and broad-scope analytical meth- propanolamine borate (log D 1.5, 2 detections, up ow, pH7 ods can be applied successfully, as has been recently to 40 ng/L), a transformation product of the blood pres- demonstrated [42, 50]. In the context of regulatory sure regulator amlodipine (log D −  0.4, 17 detec- ow, pH7 monitoring it is beneficial to define the targeted tions), and another of the herbicide metolachlor (log D ow, PMT/vPvM substances as precisely as possible and Hale et al. Environmental Sciences Europe (2022) 34:22 Page 6 of 24 of these 57 are considered Potential P/vP (or Potential P/ −  1.7, 33 detections, estimated concentrations up to pH7 vP + +) because screening tests indicated they were not 100–500 ng/L). readily and/or inherently biodegradable, but they lacked PMT/vPvM criteria for REACH registered substances established half-lives to give a definitive P, vP or Not P have recently been proposed [4] and are currently being conclusion. There were 19 detected substances consid - discussed for adaptation or modification in a revision ered "Not P", because they were readily or inherently bio- to Regulation 1272/2008 on the classification, labelling degradable according to screening tests. The presence of and packaging of substances and mixtures (CLP), and "Not P" substances in groundwater could be due to half- the REACH regulation (EC No. 1907/2006), [15], as will lives in the environment being much longer than inferred be discussed more in the "Minimize and Control" sec- from readily biodegradable screening tests, substan- tion. Of the substances that were detected in either the tial local emissions, or both. Substantial local emissions Dutch or Swiss study, 127 were found to be registered are considered an important factor here, as 19 of the under REACH as of May 2019. It is therefore of inter- detected "not P" compounds were either BTEX compo- est to see how many of these substances would be con- nents associated with petroleum leakage (5 substances), sidered   as  PMT/vPvM substances  based on the 2019 high production volume phthalates (4 substances), criteria. By consulting a recently established database of organophosphates (3 substances), or other high-volume persistency data and experimental log K data (similar to oc commodity substances (p-cymene, bisphenol-a, phenol, Arp and Hale, 2019 [79]), 86 of the 127 substances could aniline, caffeine, tetrahydrofuran and adenosine) that be matched with an experimental log K within the data- oc may be emitted from urban areas or landfills [62] (see base. Figure  3 presents a box-plot of these substances, the Additional file  1: Table S1). In principle, the concen- comparing the log K with persistency evaluation (raw oc tration of these "Not P" substances could be minimized data can be found in section "Monitoring data used to through emission reduction, such as to a point where produce Fig. 3" in the Additional file 1). natural biodegradation would be sufficient for negligible As is evident from Fig.  3, most observed substances pollution levels (i.e. "natural attenuation"). had a log K < 3 (76 out of 86). In addition, for 57 out of oc the 86substances, a definitive P conclusion could not be made. For substances monitored in the environment it Remediation and removal is common that log K data are more commonly avail- oc Getting in control of treatment technologies for PMT/vPvM able than environmental half-lives [41]. For 8 substances substances (G. Sigmund) no experimental persistency data, such as readily biode- The removal of PMT/vPvM substances from water gradable screening tests were available at all; the other 49 remains an intense field of research, as no single solution for the removal of all PMT/vPvM substances exists. Their structural and functional diversity, as well as differences in emission sources, calls for a differentiated assessment of treatment technologies. One of the most widely used advanced water treat- ment technologies to remove organic contaminants from waters is adsorptive removal via activated carbon. Because of their high porosity, high specific surface area and graphene-like aromatic structures, activated car- bons are very good sorbents for aromatic compounds, such as polycyclic aromatic hydrocarbons, polychlorin- Fig. 3 Box plots of experimental log K values for REACH registered OC ated biphenyls and other “traditional” persistent organic substances reported in the Swiss or Dutch groundwater survey, pollutants (POP) [63], as well as polar and ionizable grouped according to their persistency classification. See the SI for aromatic compounds which generally sorb efficiently to more information about the monitoring data. Also shown is the these graphene-like surfaces [64–66]. Accordingly, acti- PMT/vPvM classification presented in 2019. Briefly, for persistent (P) and very persistent (vP) environmental half‑life criteria established vated carbon was recently found suitable for removing in REACH Annex XIII are used [61]; substances that meet the P or vP 15 pollutants known to be only partly removed in con- criterion can be considered "PM" if the minimum experimentally ventional waste water treatment plants, all of which con- measured log K is < 4.0 (and therefore a PMT substance if oc tained aromatic structures [67]. However, many PMT/ additionally found to be toxic), and vP substances can be considered vPvM substances are not aromatic (132 out of the 260 a vPvM substance if there is a minimum experimentally measured log K < 3.0 according to the currently proposed definition of PMT/ prioritized REACH PMT/vPvM substances are not aro- oc vPvM substances [4]. The thresholds of log K < 4.0 (red line) and log oc matic [41]), and/or are ionizable or ionic (148 out of K < 3.0 (dark red line) are presented oc 260 prioritized REACH PMT/vPvM substances), which Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 7 of 24 complicates their sorption behaviour, as additional elec- quantitatively removing organic micropollutants such as trostatic interactions can occur [66]. For non-aromatic HFPO-DA, TFA and melamine [71]. The removal of all and negatively charged substances, removal rates by acti- relevant PMT/vPvM substances needs an ever-increasing vated carbon are often low. A recent study considering combination of technologies. Further, the implementa- PFAS (where some of the individual substances are ani- tion of many technologies in Fig. 4 undermines the prin- onic), revealed generally unsatisfactory removal rates via ciple of limiting water treatment to natural processes activated carbon, and anion exchange resins have been [72]; and are best practiced at the site of initial emissions, suggested as alternative sorbents [68] before exposure to raw water. For substances where activated carbon or ion exchange resins do not remove them to a sufficient degree, reverse Minimize and control osmosis and nanofiltration can be effective technologies Getting in control of substance property assessments for water purification (Fig.  4). However, these techniques to identify PMT/vPvM substances (H.P.H. Arp, J. Hartmann, are energy intensive and produce brine (often 25% of the R.C.H.M. Hofman‑Caris, E. Rorije, E. Verbruggen) volume) which has to be disposed or remediated [69]. As Identification of a PMT/vPvM substance well before an example, TFA, described above, can only be removed it is emitted into the environment in large quantities, by reverse osmosis [17]. Advanced oxidation processes increases the chances for control. If a high-quality PMT/ including the use of Fenton’s reagent (H O + ferrous vPvM substance assessment could be carried out before 2 2 ion), photo catalysis (UV + TiO ) or supercritical water a substance is even produced in large volumes, risk man- oxidation are also proposed for the removal of substances agement efforts could be put in place to prevent contami - from water [70]. However, oxidation-based processes nation of ground and surface water; or safer alternative pose the risk of forming unwanted by-products which chemicals could be used instead. Persistence (P), mobility may need to be removed by activated carbon as a sub- (M) and toxicity (T) are all intrinsic substance properties sequent step. An overview of these treatment processes, related to if the chemical structure is resistant to naturally and substances they are most suitable for, is presented occurring biodegradation reactions (P), partitions pref- in Fig.  4. Each of these treatments have a limited imple- erably to water from environmental soils and sediments mentation window due to their costs, and none of them (M), and acts deleteriously with biology at the cellular or are wholly protective. Even these expensive, advanced ecological level at low levels of chemical activity (T). As P, drinking water treatments in Fig.  4 are not capable of M and T are all dependent on ambient and environmental Fig. 4 Water treatment technologies (left column) and the organic compound groups that cannot be removed by the respective method and/or can survive treatment (right column) Hale et al. Environmental Sciences Europe (2022) 34:22 Page 8 of 24 properties (e.g. temperature, nutrient levels, etc.), they are was then added to this pristine water and stored in the best quantified through standardized tests. dark at 13  °C. Aniline is used as a benchmarking sub- stance, as its biodegradation behaviour is well-known. At Persistence regular time intervals, bottles were removed for chemical When assessing persistence, Annex XIII of the REACH analysis to account for changes in concentration of the regulation ((EC) No. 1272/2008) sets half-life thresholds analytes, alongside adenosine triphosphate (ATP) analy- in water, sediment and soil at 12˚C. Substances with half- sis to account for microbial activity and to account for lives exceeding threshold values would meet the classifi - the possibility of a substance acting as a biocide. Results cation for P or vP. For mobile substances, the half-lives from the test showed that there was no degradation for in (marine) surface water are particularly relevant, as soil gabapentin, 1H-benzotriazole, diglyme, 1,4-dioxane and and sediment retain these substances only to a limited melamine while for DTPA and urotropine, slow degrada- extent and surface water is the compartment in which tion (with half-lives of 68 and over 128 days, respectively) these substances end up. Unfortunately high-quality occurred. The degradation half-live of the benchmark half-life data are quite rare, even for REACH registered substance aniline was 5  days. Based on these results, all compounds, due to their high cost and difficulty of meas - tested substances were determined to be very persistent urement [41, 73]. The PBT guideline makes several rec - according to REACH Annex XIII, having a half-life in ommendations to assess persistence, and particularly freshwater > 60  days. As the test was carried out with- non-persistence, in the absence of half-lives, such as the out the need for C-labelled compounds, the method is use of readily biodegradable or inherently biodegradable more accessible and by far cheaper than the OECD 309 screening tests like the OECD Test Guideline 301 and performed with radiolabelled test substances. This exam - 302 series [61]. Quantitative structure activity relation- ple shows that existing guidelines allow for generating ships (QSARs) can also be used to predict half-lives, but high-quality biodegradation data at reduced costs. More are generally too uncertain for a definitive P conclusion details about this test can be found in section "Additional and are best used for screening [41]. Therefore, simpler details about the persistency test" Additional file 1. approaches are needed to ascertain half-lives of sufficient quality. Mobility In the OECD Guideline 309 "Aerobic Mineralisation Mobility assessments are the only truly new part of in Surface Water—Simulation Biodegradation Test" [74] a PMT/vPvM substance assessment protocol, as the for assessing biodegradation half-lives, a time course of assessments of P and T follow the current PBT assess- aerobic primary and ultimate degradation in surface ment, with slight modifications. It is emphasized that water can be determined using kinetic rate expressions in the PMT/vPvM criteria under discussion in Europe for degradation, mostly performed using C-labelled for inclusion in the CLP and REACH regulations [15], compounds. However, it is very difficult to obtain C mobility assessments are only required for persistent labelled compounds, especially in cases where the com- substances [4]. This is largely based on the rationale pre - pounds are observed for the first time in the aqueous sented in the monitoring section that non-persistent sub- environment. This makes the procedure poorly acces - stances monitored in groundwater or drinking water, like sible and very expensive. The OECD 309 test may how - caffeine (Fig.  3), would disappear more readily from the ever, be performed with non-radiolabelled material as subsurface if emissions were suddenly reduced or elimi- well, with a validity criterion for the mass balance of nated. Gustafson et al. [76] first suggested the use of the 70–110%. This test with non-radiolabelled materials was organic-carbon partition coefficient, K , in combina- oc recently applied to the following potential PMT/vPvM tion with persistency in terms of soil half-lives, as a way substances: gabapentin, 1H-benzotriazole, diglyme, of assessing the potential for subsurface mobility. This DTPA, 1,4-dioxane, melamine and urotropine, identified combination of log K and soil half-lives has been used oc by Arp and Hale [41] that were at the time not subject to in the EU biocide regulations [77], and adapted to the any regulation [75]. For the test, a pure, pristine surface discussed PMT/vPvM criteria (with log K < 4.0 and < 3.0 oc water source from Schalterberg (NL) used for drinking as the cut-off for M and vM, respectively, for all P and vP water production was obtained and was tested to confirm substances, not just those persistent in soil). A current the following: i) it did not contain the test substances; ii) proposal from the European Commission for Classifica - it contained very little synthetic chemical contamination, tion and Labelling (CLP regulation) currently uses log and iii) it contained microbiological activity. The micro - K < 3.0 and < 2.0 as the cut-off for M and vM [78]. These oc organisms in this water had not previously been exposed proposals compared with classifications used in the ("adapted") anthropogenic micropollutants. A spiked GUS (Groundwater Ubiquity Score) index as proposed stock solution of the PMT/vPvM substances and aniline Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 9 of 24 for many ionic organic compounds, as soil organic car- bon has a substantial cationic exchange capacity [80]. The major shortcoming with organic carbon as the proxy phase for mobility is that data and models are lacking for ionic and zwitterionic species [81], partly because these ionic interactions could vary widely across types of organic carbon, as well as counterions in the porewa- ter. This is evidenced empirically as K measurements oc for ionic and ionizable substances are often quite vari- able [82], in part due to ionic interactions with soil min- erals that can further reduce mobility [83]. Therefore for mobility assessments of ionic substances, a recom- mended approach is to use the minimum empirical meas- ured log K from batch tests with actual soils (where the oc K value is corrected using the soil organic carbon con- tent), sediments or sludges as the basis [41]; however, it should be kept in mind for local risk assessments that Fig. 5 A groundwater ubiquity score (GUS) showing the thresholds for groundwater leachers (GUS > 2.8), non‑leachers (GUS < 1.8), and additional local factors are also important for subsurface regions that correspond to the UBA and EC commissions current mobility (e.g. flow rates, clay content, etc.) [84]. proposal (Sept 30, 2021) for very persistent, very mobile (vPvM) substances and persistent and mobile substances (PM) Toxicity Toxicity assessments generally follow those defined in REACH Annex XIII for PBT/vPvB assessments. These by Gustafson [76] are shown in Fig.  5. The GUS index is include the toxicity categories of carcinogenicity, muta- based on the equation below: genicity, reproductive toxicity, specific organ toxicity (repeated exposure), freshwater ecotoxicity and more GUS = log DT50 4− log K , (1) OC recently also endocrine disruption [15]. Other catego- ries can also play a role, including terrestrial ecotoxicity Where DT50 is the soil half-life (degradation time— [78], skin sensitization, and immunotoxicity. It must be 50%) in days. In this metric, a GUS > 2.8 is considered noted that for those endpoints based on effect concen - a groundwater leacher, a GUS < 1.8 a non-leacher, and trations in environmental media, the same effect caused those between 1.8 and 2.8 a transition zone where both within the organism should occur at a lower fugacity than are possible. For a half-life of 180  days in soil (the vP for PBT substances, because of the general lower bioac- criterion) this would mean a log K value of 2.76 as the oc cumulation from these environmental media for PMT upper value (rounded to 3 and thus in agreement with the substances. Although large amounts of toxicity data are current proposal [4]). With a soil half-life of 120 days (the available [16], it cannot always be assumed that such tox- P criterion) this would lead to a K value 3.13 to match oc icity data sets are complete or reliable. For certain persis- the boarder between "non-leachers" and the transition tent compounds that are widespread in the environment, zone. However, it was argued based on empirical data of long time scales of exposure were needed before the chemicals in drinking water, groundwater and breaking mechanisms of toxicity were elucidated [85]. This is part through bank filtrate that the M criteria should be a log of the justification for the establishment of the vPvM cri - K of 4 to be protective of the majority of detected sub- oc teria, which does not consider toxicity [4]. stances in these media [41]. The European Commission in consultation with the PBT expert group of ECHA has Screening and predictive approaches proposed to lower these cutoffs to log K of 2 and 3 for oc Due to the lack of empirical persistency, mobility and vM and M, respectively, because "a comparison of criteria toxicity data, it is currently only possible to conduct a provided in different legislations [and] guidance […] indi - high-quality PMT/vPvM substance assessment for a cate that log K of 4 would include also substances with oc relatively small number of substances [41]. To address great adsorption capacity and not likely to be mobile" this gap, screening and predictive models can be useful [78]. to prioritize where further testing is needed. For per- The advantage of using K is that organic carbon is oc sistency, this includes readily biodegradable tests (e.g. often a good "proxy phase" for soil and sediment sorp- OECD301A-F, OECD310). For mobility assessments, tion, as it is often dominating sorption phase in soils and octanol–water distribution coefficients D values, sediments for neutral organic compounds [79], and even ow Hale et al. Environmental Sciences Europe (2022) 34:22 Page 10 of 24 Getting in control of PMT/vPvM substances have been recommended as a screening parameter in through various types of chemical risk governance (H. the lack of K data, though there are concerns that D oc ow Timmer) does not account for ionic interactions with soil [4, 41]. The Dutch and Swiss monitoring studies discussed above For toxicity screening the Cramer Class III method has highlight that drinking water suppliers are faced with an been recommended [86]. A proposal for a more elabo- increasing number of known and unknown PMT/vPvM rate screening of potential (human health) toxicity by substances in their water sources. Strategies are there- including alert models for carcinogenicity, mutagenicity, fore needed to avoid detrimental effects of pollutants on reproductive toxicity (CMR) as well as potential endo- the quality of water bodies, aquatic life, natural areas and crine disruption (ED) is described in the supporting biodiversity. Stricter drinking water threshold concentra- information. A discussion of the performance of various tions are becoming more and more common; the revised quantitative structure activity relationship (QSAR) for version of the drinking water directive (98/83/EC) [90] predicting persistence and mobility properties has been is a prominent example. The revision includes several described in recent articles and reports [12, 41]. parameters for PFAS concentrations where threshold Two QSAR approaches to conduct a complete PMT values are in the ng/L range. The growing gap between assessment, requiring only the chemical structure as detected concentrations of certain PMT/vPvM sub- input, have been proposed. One was developed using a stances (in addition to other micropollutants) in drinking Danish QSAR database and was described by Holmberg water sources exceeding the acceptable concentrations in et  al., [87]. The other one was recently developed by the drinking water results in an increasing requirement for Dutch National Institute for Public Health and the Envi- purification treatment levels. This has been highlighted ronment (RIVM), presented in section "Additional details in a recent study [91] where a framework was developed about the RIVM QSAR" Additional file  1, which scores to evaluate the required purification treatment level. This substances on a scale from 0 to 1, from low to high PMT framework was applied to Amsterdam and its surround- substance potential. This screening approach also enables ings from an intake along the river Rhine, the major separate evaluation of persistence, mobility and toxicity Dutch river, at Nieuwegein. The results showed that the of a chemical structure making a score for P, M and T, treatment effort required to provide safe drinking water and aggregates them using the following function: actually increased between 2000 and 2018, despite the 0.4 0.4 PMT − score = P − score ∗ M − score ∗ ambitions of the water framework directive (WFD, (2) 0.2 2000/60/EC [72]) to reduce the level of purification treat - T (humanhealth) − score . ment required. When PMT/vPvM substances were con- The two approaches differ. The approach developed by sidered alone, as shown in Fig. 6 for the Nieuwegein river the Danish team only considers mobility for substances intake, the level of purification treatment was even higher that exceed a persistency threshold, and toxicity only for [92]. For this evaluation, water quality data for 1161 sub- those substances exceeding a persistency and mobility stances with P, M and/or T assessments from the Dutch threshold. The approach developed by RIVM considers PMT Working Group were used. In total, 626 substances persistency, mobility and toxicity simultaneously. The were detected, and 91 substances exceeded the target approaches also include different toxicity endpoints, but value in the European River Memorandum of 0.1 µg/l at both include QSARs predicting a substance’s carcino- least once between 2000 and 2019. This pollution affects genic, mutagenic, reprotoxic and endocrine disruptive about 3 million people that depend directly on Rhine potential. The RIVM approach also incorporates toxic - water (including lake IJssel) and a similar situation is ity screening based on Cramer Classes. Both approaches assumed at the Dutch Meuse water intakes. Both riv- consider some human health-related endpoints, while ers provide about 40% of Dutch drinking water, in areas ecotoxicity based on long-term toxicity to fish, daphnia where fresh groundwater is scarce. Extensive monitoring or algae is considered by the Danish team but not in the along the Rhine at the location Lobith identified that the RIVM approach. composition of these PMT/vPvM substances changed An inherent feature of all QSARs is that they work best over time, indicating that some substances were switched for substances that have similar structures to those in with other substances, due to regulatory or commercial their chemical calibration data set, which tend to be neu- forces (Additional file  1: Fig. S2). For example, efforts to tral substances [12, 88]. Despite this, if the uncertainty of identify and reduce the emissions of diglyme, MTBE/ predictions and application domains are taken into care- ETBE and pyrazole were effective, whilst the "hot" PMT/ ful consideration, QSAR-based screening approaches are vPvM substances such as 1,4-dioxane and TFA can be a valuable tool for the initial screening of potential PMT seen to have been introduced during the study period. substances [89]. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 11 of 24 Fig. 6 Removal Requirement Index for PMT substances at the intake of Nieuwegein (River Rhine), based on the methodology of Pronk et al. (2021) as described in https:// iwapo nline. com/ ws/ artic le/ 21/1/ 128/ 77954/A wat‑er‑ quali ty‑ index‑ for‑ the‑ remov al‑ requi rement. The Water Quality Removal Requirement Index is an indicator sum parameter that describes the gap between the standards in the Dutch drinking water act, and the quality of the source water. The gap increases when the concentrations of the pollutants increase, or when environmental quality standards are lowered There are many ambitious goals established via the the ambitions set. Reaching good ecological and chemi- WFD, the Urban Waste Water Treatment Directive cal status for water bodies covered by the WFD by 2027 (UWWTD, directive 91/271/EEC) and the Industrial seems increasingly unlikely [93, 94]. Similarly, results Emissions Directive (IED, directive 2010/75/EU) to pro- on the transparency of emissions is disappointing as tect surface and groundwater from the adverse effects of currently available information shows limited qual- discharges of urban and industrial waste water. In addi- ity, completeness, and homogeneity [95]. In contrast tion, both the Aarhus convention (1998) and the Kyiv to this, steps are being made forward in certain more Protocol (2003) provide a transparent ambition for the regional situations. For example, the Dutch system of registration of discharges and emissions. The Aarhus licensing industrial discharges was revised in 2019 to Convention details rights that organisations are entitled include a drinking water test as an additional require- to receive environmental information that is held by pub- ment to the existing regulatory WFD ecological and lic authorities. The Kyiv Protocol aims to enhance public chemical requirements. This ambitious approach is in access to information on industrial and WWTP emis- line with EU regulations and protects drinking water sions through the establishment of coherent, nationwide intake and thus human health from PMT/vPvM (and Pollutant Release and Transfer Registers (PRTRs). The other) substances, by prescribing additional pollution resulting “E-PRTR” is the EU system for collecting and abatement methods. In practice this means that when disseminating information about environmental releases a discharge of a PMT/vPvM substance is proposed, the and transfers of hazardous substances from industrial effect of this emission for a drinking water company and other facilities. Integration and implementation of is assessed. If it is found that the discharge could seri- these regulations could provide a basis for more, and ously affect the surface water quality, additional puri - improved, governance of PMT/vPvM substances, as they fication using the best available technology (BAT) or include risk assessment models and methods that local BAT with additional measures (BAT +) by the polluter authorities could put into practice, including a frame- is required, or the license will not be granted. work for the proper registration of emissions. The current review and revision of the IED and Based on the above, it appears that the WFD, the IED, UWWTD provides the opportunity to improve the the UWWTD, the Aarhus Convention and the Kyiv permitting procedures of PMT/vPvM substances and Protocol, in combination, provide an adequate frame- other relevant pollutant emissions in a similar manner. work of relevant environmental legislation and obliga- Movement in a common direction could improve inter- tion for transparency, at least in theory. However, the nal harmonization between all European regulations. results of these frameworks to date have not matched The identification of PMT/vPvM substances under REACH as Substance of Very High Concern (SVHC), as proposed by the European Commission in the Hale et al. Environmental Sciences Europe (2022) 34:22 Page 12 of 24 Chemicals Strategy for Sustainability Towards a Toxic when considering local pollution caused by an industrial Free Environment, could be used by the watershed or site or an incident. In addition, improvements in risk river authorities to demand extra purification when assessment models such as European union system for these (and other relevant) substances are emitted to the evaluation of substances (EUSES) and SimpleTreat the aquatic water environment, and for registration in can contribute to providing a more accurate assessment the in the E-PRTR system. Such an optimized licensing of the current situation. In particular, exposure-based and registration system could lead to improved water models are well defined for substances entering water via quality. soil leaching. However, another relevant entry pathway is linked to the process of riverbank filtration. Currently, Getting in control of PMT/vPvM substances this pathway is not sufficiently covered by existing mod - through chemical industry stewardship (M. Collard, D. els and additional research is needed. Drmač, T. Kullick, S. Pawlowski) It is important that the approach taken to regulate The chemical industry is constantly improving measures PMT/vPvM substances is harmonized both geographi- to reduce the release of chemicals into the environment. cally and across regulations. Within the EU, risk assess- Successful stewardship measures have been used in the ment approaches for the protection of drinking water past to reduce major environmental contaminants which resources (focusing on groundwater) are well established led to the increase in both species number and abun- for plant protection products (PPP) and biocidal active dance in large urbanised rivers, such as the Rhine [1, products, for deriving Guideline Values for drinking 96–98]. Due to improved analytical methods, more sub- water by the WHO and the Drinking Water Directive, stances can be detected at low concentrations including and to some extent under REACH (i.e. man via the envi- those found in drinking water. In Germany, an initiative ronment). The interplay between hazard assessment, risk launched by the German Federal Environment Ministry assessment and risk management in those frameworks is (BMU) entitled “Trace substance strategy of the German illustrated in Fig. 7. Environment” is currently underway to tackle this issue. In the context of establishing a global approach, poten- The chemical industry (through the German Chemical tial drinking water contaminants can be assessed as the Industry-VCI) is strongly contributing to this round table other chemicals under REACH, i.e. a hazard assessment discussion with strategies and options for actions in a based on the intrinsic properties of the substances with a multi-stage process. follow-up risk assessment based on its uses. As part of this work, both chemical properties and use patterns are considered in order to quantify the impact of contaminants found in water on human health and the Prevention environment. Whilst persistent and mobile substances Getting in control of PMT/vPvM substances may have a higher probability of contaminating ground- through regulation (F.S. Averbeck, S.E. Hale, M. Neumann, water, the amount and use pattern as well as the way it J. Schulze) is emitted into the environment are also the major driv- Active steps towards new policies and regulations ers for its detection [84]. This is true of caffeine. Whilst for PMT/vPvM substances are currently occurring it is not persistent (because it is readily biodegradable) at the highest European level. Upstream preventative it is a major drinking water contaminant, and was also approaches are recognised as one of the most effective detected in the Dutch monitoring study mentioned ear- methods to reduce environmental and human health lier, because it is emitted constantly and daily by millions hazards as well as exposure from harmful substances as of people all across Europe [99]. Conversely, a persis- part of the Chemicals Strategy for Sustainability Towards tent and mobile substance used under strictly controlled a Toxic Free Environment [15]. Key aspects to achieving conditions with risk management measures in place to these goals is the revision of the CLP regulation and the avoid release to the environment is unlikely to be a drink- REACH regulation, which are important cornerstones of ing water contaminant. It is apparent, therefore, that to the EU’s regulation of chemicals. Therein, the following tackle possible contamination of water at concentra- action points, related to getting control of PMT/vPvM tions posing a risk to human health and the environment, substances, have been defined: emission patterns need to be considered in addition to substance properties [55]. A stepwise process: “screen— • create new hazard classes and criteria in the CLP prioritise—assess—control” is useful to minimize envi- regulation by 2021, ronmental and human health risks. This can be assisted • amend Article 57 of REACH to add endocrine dis- by a strong collaboration among local stakeholders, e.g. ruptors as well as PMT and vPvM substances by local industry and drinking water suppliers, especially Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 13 of 24 Fig. 7 Typical hazard assessment and risk assessment approach applied for chemical assessment today and their use in current legislative frameworks for drinking water and/or groundwater protection. DW drinking water, GW groundwater, DWD drinking water directive, GV guideline value, PPPR plant protection products regulation, BPR biocide products regulation, IED Industrial Emissions Directive 2022 in order to identify those as Substances of Very across a wide range of sectors (e.g. consumer products, High Concern (SVHC), waste, or industrial applications) can be achieved. This is • restrict all PFAS in a broad manner to ensure a PFAS being referred to as "one substance-one assessment". The phase out for "all but essential uses" by 2024 and implementation of new hazard classes in the CLP Regu- • define criteria for essential use drawing on the defi - lation without prior implementation at the level of the nition in the Montreal Protocol by 2022 (date to be Globally Harmonized System of Classification and Label - confirmed). ling of Chemicals (GHS) is an unusual step. Since the CLP Regulation is the legal instrument for the translation To drive these changes, the EU will promote and of GHS on the European level, changes are usually made reward production and use of safe and sustainable chem- in a “top down” manner. However, this approach could icals and incentivize innovation and substitution of sub- build the basis for modifications of GHS using a more stances of concern, as described below. “bottom up” approach. Criteria for the more specific drafting of the new haz - ard classes are currently being discussed by the Com- CLP regulation petent Authorities for REACH and CLP (CAR ACA L), a As part of the revision of the CLP Regulation, the follow- group advising the EU Commission on questions related ing new hazard classes have been proposed by the EU to REACH and CLP in close exchange with the respective Commission: endocrine disruptors (EDs); PBT and vPvB experts, e.g. ECHAs PBT expert group. An adoption of substances; and, PMT and vPvM substances. From 2015, the changes is expected in 2022. the CLP Regulation represents the only legal instrument in force for the classification and labelling of substances in the EU and as such has implications for other chemi- REACH regulation cal legislations. By expanding the CLP Regulation, a more Similar to the changes of the CLP Regulation, adap- harmonized and higher level of protection from harm- tations of the REACH Regulation are part of a broad ful chemicals for human health and the environment Hale et al. Environmental Sciences Europe (2022) 34:22 Page 14 of 24 development of the EU’s substance related and envi- release factors and emission calculations. In addition, ronmental regulations. Plans to adapt the legal text by information on the availability and feasibility of alterna- amending Article 57 to include PMT and vPvM sub- tives as well as the socio-economic impact of a PFAS ban stances to be identified as SVHC aim to provide a higher needs to be considered. level of protection. Currently, identifying PMT/vPvM The five authorities aim to submit the restriction substances as SVHC is only possible by demonstrating proposal to the European Chemicals Agency (ECHA) an equivalent level of concern to substances that are, for in July 2022 [103]. It will then be assessed by ECHA’s example, CMR or PBT/vPvB substances. Other changes scientific committees RAC (Committee for risk assess - to the legal text shall ensure a stronger and more efficient ment) and SEAC (Committee for socio-economic enforcement by requiring dossier evaluations for all reg- analysis). In parallel, a consultation on the proposal istrations (currently only required for a share of new reg- will provide a possibility to stakeholders to submit istrations) and revising the authorization and restriction evidence and comments. The committees have to pro - procedure. vide their scientific opinion on the proposal within Additionally, revisions of the Annexes of REACH are 9  months (RAC) or 12  months (SEAC) after publica- planned to better prioritize SVHC for (group) restric- tion of the restriction dossier. After finalisation, the tions as well as to adapt the data requirements (i.e. what opinions of the committees together with the proposal kind of information needs to be provided in the registra- and the comments received during the consultation will tion dossier) for EDs, and to restrict all “non-essential” be submitted to the EU Commission for political deci- uses of PFAS by adding the group to the list of restricted sion-making. A decision by the EU Commission and substances in Annex XVII. entering into force of the restriction can be expected in 2024; given a transition period, the restriction could apply from 2025. PFAS restriction The broad restriction of PFAS as a group is being led by Germany, the Netherlands, Denmark, Norway and Swe- Essential use den. The restriction will cover all uses of PFAS and will The concept of essential use is applied in the Montreal aim to reduce regrettable substitution possibilities (such Protocol, which outlines the global agreement on the as when HFPO-DA replaced PFOA [100]). PFAS was phase-out of the production and use of ozone deplet- recently defined as substances that contain at least one ing substances [104]. However, it also allows parties to aliphatic carbon atom that is both saturated and fully propose exemptions for certain substances and uses of fluorinated. This includes any chemical with at least one that are considered essential at a national level. The two perfluorinated methyl group (-CF ) or at least one per- elements of an essential use under the Montreal Proto- fluorinated methylene group (-CF -), including branched col are that a use is “necessary for health, safety or is fluoroalkyl groups and substances containing ether link - critical for the functioning of society” and that “there ages, fluoropolymers and side chain fluorinated polymers are no available technically and economically feasible [101, 102]. More details about PFAS and their uses and alternatives”. Scientific discussion and debate around environmental occurrence can be found in section "More the essential use concept has increased since a paper details about PFAS and their uses and environmental was published in 2019 applying it to uses of PFAS [105]. occurrence" in the Additional file 1. Three use categories were defined: 1) “Non-essential As the broad restriction process continues, there are uses" which are those driven by convenience and busi- several points that need special attention. The first is ness opportunities and that are “nice to have” rather that there are only very few substances within the diverse than having a function that is critical for health and PFAS class for which hazardous properties are known. safety, and the functioning of society, 2) “Substitutable For most of the substances in the group, no or only very uses", where the substance of concern does have a func- little information is available. Nevertheless, the restric- tion necessary for health, safety or critical for the func- tion proposal will demonstrate that a precautionary tioning of society, but its use is considered unnecessary approach is needed for PFAS and that they should be reg- because there are suitable alternatives available, and 3) ulated as a group even if data is lacking. Another impor- “Essential uses" as described in the Montreal protocol. tant point is the availability of data related to aspects Since this first publication, debate between scientists, such as operational conditions or containment during regulators and chemical manufacturers has been ongo- manufacture and use or emissions during the whole ser- ing and the most recent scientific paper published in vice-life including end of life. Where specific information 2021 [106] sets out to address common questions and is missing, realistic worst-case scenarios will be used for possible misinterpretations of the essential use criteria. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 15 of 24 Questions such as "Who should apply the essential use requires some knowledge of the foreseen use of the concept?", "Is the essential use concept a threat to inno- design candidate substances. Crucial elements in such vation or an opportunity?", "For which uses of which design would be how to fill data gaps for the design chemicals should the essential use concept be applied?" candidates, which models to use, the protection level to and "Which uses of chemicals are critical for the func- apply, and the criteria for assessing the overall impacts tioning of society?" are addressed. The authors go on of a chemical, a material, a product or process. In the to conclude that many of the challenges for the further final scoring of the design candidates’ minimum crite - implementation of the concept are not insurmount- ria need to be set so that the design candidates ‘do no able. For instance, one important way to address many significant harm’ on all the four parameters of safety to of these challenges is to innovate towards safe and sus- human and environmental health. A maximum score is tainable alternatives to PFAS. set for each parameter, to allow to sum the scores with- out one score skewing the total score. Getting in control of PMT/vPvM substances through safe Another consideration might be if the chemicals in and sustainable by design strategies (H.P.H. Arp, A. practice are likely to be kept inside the technosphere, also Lennquist, N. Reineke, X. Trier) at their end of life during the separation and collection of The ambitions in the Chemical Strategy for Sustain - the chemicals. Such considerations of whether a risk can ability Towards a Toxic Free Environment [15] call for a be ‘managed’ are currently applied in risk assessments, transition towards a new approach for how we use and e.g. under REACH. The concern is however that it is very assess substances. This new approach should increase difficult to foresee future uses of materials in a global the ability to generate goods in ways that minimize recycling market, as well as assessing if the incidences of harm from chemicals along lifecycles of the chemicals e.g. spills will increase with climate change, due to e.g. and the products they are used in, and for the multi- flooding of contaminated sites or storms and fires lead - ple aims of the EU Environmental Green Deal: Mak- ing to accidents at industrial sites or even just overflow ing chemicals safe towards human and environmental of waste water. In such an approach, substances with- health, i.e. related to ecotoxicity, resource extraction out hazard properties or the most manageable hazard and climate change. Such impacts along the lifecy- properties, as confirmed with the most assessment data cles will have to be considered not just in the typical possible, would be preferential design candidates. There - 5–10  years short term, but over the next 50–100  years fore, there would be an increasing market for chemicals to protect future generations. This approach is referred that are less risky, even if they accidentally are spilled to as Safe and Sustainable by Design (SSBD) in the in the environment – and therefore also for substances Chemical Strategy for Sustainability Towards a Toxic that are and form non-persistent, non-(eco)toxic sub- Free Environment. Given the complexity of chemicals, stances, and which require low energy to synthesize and and their (un)foreseen uses across multiple cycles of to manage though their supply chains. As another con- the materials, it is key to avoid the use of substances sequence this will call for less complex materials that do of concern, such as PMT/vPvM substances from the not require persistent, (eco)toxic substances to achieve very beginning of the design phase [107]. The current their functionality, and which are possible to separate approach where only substances classified as SVHC are into clean materials during repair and recycling. The avoided (or not even given authorisations) has not been EU’s Directorate-General for Research and Innovation sufficiently proactive to avoid pollution by e.g. PMT/ (DG RTD) mapped all the SSBD and related methodolo- vPvM substances and their precursors. Therefore, it is gies in 2021 [107] and the EU’s Joint Research Council very important that the identification and subsequent is currently developing the SSBD criteria for DG RTD. risk management of PMT/vPvM substances is acceler- European Commission activities on SSBD include fund- ated under current and future EU laws. In the SSBD ing of public–public research such as the Partnership for approach, the design starts with a consideration of Assessment of Risks of Chemicals (PARC), public–pri- which service to provide [107]. To ensure as broad and vate partnerships to start in 2022 and stakeholder meet- open innovation space as possible, different types of ings [108]. expertise will have to be included in the process, from the industrial and environmental chemists, material Prioritizing substances for substitution designers, toxicologists, end-user experts, supply chain, As mentioned above, one important way to approach the marketing, economic and legal experts. This group will SSBD strategy is to prioritize which substances should be select a few design candidate substances not containing replaced or avoided at the design stage. Databases and or foreseen to generate substances of concern, which lists of harmful chemicals, such as the REACH SVHC list, will be assessed for impacts along their lifecycles. This addressing classes of chemicals known to be of concern Hale et al. Environmental Sciences Europe (2022) 34:22 Page 16 of 24 Avoiding regrettable substitution (such as PFAS, phthalates, bisphenols, isocyanates, anti- When replacing substances of concern with sustainable microbials, organochlorines and organobromines [109]), chemicals as part of an SSBD strategy, there are several or the Substitute It Now List (SIN List [110]) published by lessons that can be learned from previous unsuccess- ChemSec provide good starting points to alert industry ful attempts, so called "regrettable substitution" [112]. to which chemicals are needed to be replaced by safe and A well-known example of regrettable substitution was sustainable alternatives. Increasingly companies avoid the substitution of the endocrine disrupting chemical using such classes of substances of concern in their pro- bisphenol A with alternative bisphenols that were simi- curement, both to protect their customers, the environ- larly harmful [113]. An example of burden shifting is ment, and their business reputation and hence income found in the Montreal Protocol, where the substitution (for example companies included in the ChemSec busi- of refrigerants from ozone depleting chlorofluorocarbons ness group). The SIN List was launched in 2008 to pro - (CFC) to hydrofluorocarbons (HFCs) was made, despite vide guidance to industry on what substances to expect their very high global warming potential [114]. This led to be included in upcoming regulations. The SIN List to amendments of the Montreal Protocol to reduce use uses the criteria for SVHC in REACH to list substances of the most potent greenhouse cases, and hydrofluor - ahead of the official and much slower process to populate oolefins (HFO). However, some HFCs and HFOs can the Candidate SVHC List. This means that in addition to degrade to the vPvM substance TFA discussed above, at applying the existing criteria, the SIN List contains sub- yields of between 7 and 100% [18]. The newest iteration stances that are predicted (by ChemSec) to be targeted of the Montreal Protocol, the Kigali Amendment, which by regulations in the near future, based on an analysis is not yet ratified, seeks to phase out all hydrofluorocar - of potential developments in chemical regulations. For bons; possible non-halogenated alternatives like CO and instance, the SIN List has managed to both predict and ammonia (see section "Additional details about avoiding influence the development of new regulations for endo - regrettable substitution of refrigerants" in the Additional crine disrupting chemicals. Some EDCs were added to file  1 for more details). Both bisphenol A and the his- the SIN List in 2011 and 2014, which in turn influenced tory of the Montreal protocol serve as examples of how their chemical management and policy discussion, ulti- important it is to avoid regrettable substitution and eval- mately culminating with their suggested inclusion as uate burden shifting of risks to other domains [89, 115]. a new category for SVHCs in REACH, as well as a new Currently we are in a situation where there is a strong hazard class. The 32 EDCs included in the SIN list were demand to move away from burning of fossil fuels that added on the basis of peer reviewed data and regulatory pollutes the atmosphere with greenhouse gases (such as guidance documents. This list was used and referred to CO and methane) to ‘clean’ renewable energy. While by companies, authorities, financial investors and others. there is no doubt of the urgency of reducing GHG emis- The first EDC was added to the Candidate List in 2012, sions, there is a risk that the replacement technolo- and since then more and more EDCs have been placed on gies contribute to pollution of freshwater resources. For the Candidate List, but at a slow pace. To date 19 chemi- instance, many are ionic liquids and molten salts, such cals have been placed on the Candidate List because of as bis(trifluoromethane)sulfonimide is used as coun - endocrine disrupting properties. ter ions in lithium batteries. Both the substance itself as In 2019, 16 PMT substances were added to the SIN well as its degradation products such as C F -SO -OH, List after ChemSec realized that the most likely devel- 3 2 are likely persistent and highly water mobile substances. opment of REACH would relate to the PMT/vPvM sub- Recent studies have detected CF -SO -OH widespread stance concept being developed at the time [4, 41]. The 3 2 in German surface waters [18]. This risk is particularly initial PMT/vPvM substance list was narrowed down high if the recovery of Lithium metals in batteries occurs to 16 substances following in-depth scientific evalua - under uncontrolled conditions in open systems by ther- tions [111] and by considering substance uses in order mal recovery at smoldering temperatures of 300–500 °C, to ensure that the listed substances were actually of rel- where also the fluoropolymers PVDF and PTFE may evance for companies. Since then, two of these 16 sub- form smaller PFAS degradation products. Since recovery stances (PFBS and 1,4-dioxane) have been identified systems for fluorinated polymers and such ionic liquids as SVHC based on their intrinsic properties and being are not in place in the scale of the development of renew- regarded as posing an equivalent level of concern (ELoC) able energy technologies, there is a high risk of regretta- to PBT/vPvB substances. In addition, 2,3,3,3-tetrafluoro- ble substitution replacing greenhouse gas pollution with 2-(heptafluoropropoxy)propionic acid (HFPO-DA, also human and ecotoxic chemical water pollution—particu- known as GenX) was identified as a SVHC due to PMT larly if recovery takes place outside of Europe where it is substance properties giving rise to an ELoC to PBT/vPvB difficult to ensure controlled closed-loop systems. substances. Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 17 of 24 Based on these previous examples, the main chal- Sustainability Towards a Toxic Free Environment [15], lenge in alternatives assessment, is to identify better including its ambitious targets such as the PFAS restric- and safer solutions for problematic applications in the tion and incorporating PMT/vPvM in the CLP and long term [116], following the safe and sustainable by REACH regulations, as discussed above. An important design approach [107]. Even in cases where alternatives concern was related to the lack of harmonized approach are available, the transition to SSBD requires much that either unifies or explicitly accounts discrepancies in more. Enabling conditions such as policies (covering other European regulations or international regulations is policies on products, and finance), education and tech - accounted for, such as the potential discrepancy between nical support centres (to help industry to run SSBD the CLP regulation in Europe and the United Nations and develop documentation of compliance) must be in Global Harmonized System regulation. place [107]. Education is of particular interest since it is related to changes in perceptions and values, which Gap in analytical methods range as some of the most powerful elements in cre- Poll results: Wide gap (33%); closing gap (57%); negligible ating transitions. Not only will new technical skills be gap (10%). required, but process skills to run an interdisciplinary The gap in analytical methods being ranked second design process are needed. This is key to keep the inno - smallest is reflective of the recent advances in analyti - vation space open for providing services in various cal methods presented above, as there are currently a ways, including also by other business models that sell great number of tools available for PMT/vPvM sub- services rather than products. stance quantification. The main limitations to their use are practical, due to the small number of labs with the needed equipment, lack of reference standards for target Conclusion analysis, and the difficulty in quantifying unknowns from Size of the gaps related to getting in control of PMT/vPvM non-target analysis. That said, the current regulatory and substances (H. P H. Arp, S. E. Hale) environmental and human health protection focus given At the Third PMT/vPvM workshop where all of the to PMT/vPvM substances may potentially drive further information in this review was presented and discussed, establishment of more accessible analytical methods for the participants and attendees, consisting of regulators, PMT/vPvM substances in the coming years. Regarding researchers, chemical industry representatives, water reference standards, there is need for more examples of producer representatives, and public safety NGOs, were stewardship, such as that of the European Crop Protec- invited to answer an online poll designed by the work- tion Association who agreed to provide reference stand- shop organisers (consisting of this paper’s co-authors: ards of pesticide transformation products that are not Sarah E Hale, Hans Peter H Arp, Michael Neumann, commercially available. Ivo Schliebner and Jona Schulze). The poll consisted of 10 gaps related to getting in control of PMT/vPvM sub- Gap in risk assessment tools stances and the respondents were asked whether they Poll results: Wide gap (34%); closing gap (53%); negligible thought the gap was wide, closing, or negligible [117]. gap (13%). A summary of the 120 respondents, presented in order The gap in risk assessment tools was ranked 8th, and of the size of the gap, from smallest to largest, is given this may be reflective of positive experiences with risk below. It must be noted that this response rate is just 17% assessment models, such as the European union sys- of the peak audience numbers and the conclusions draw tem for the evaluation of substances (EUSES) [118] and may not reflect the view of all workshop participants. RIVM’s SimpleTreat model for waste water treatment plants [119]. However, there are several substantial chal- lenges for the development of risk assessment tools for Gap in chemical legislation industrial substances, such as accounting for a diverse Poll results: Wide gap (23%); closing gap (63%); negligible array of emission scenarios [120], linking multi-media gap (14%). modelling with subsurface flow modelling (e.g. bank fil - Chemical legislation was considered to have the small- tration) [84], and accounting for the complex sorption est gap (ranked tenth), despite some short comings and behaviour of mobility ionic and ionizable substances difference of opinion of how well the WFD, the IED, the [121]. Currently there are research initiatives to improve UWWTD, the Aarhus Convention and the Kyiv Protocol risk assessments of persistent and mobile substances, were protecting the environment from exposure to PMT/ (e.g. [122]), being driven by industrial stewardship (see vPvM substances. This small gap may have been reflec - Fig. 7) and other programs. tive of the recently announced Chemicals Strategy for Hale et al. Environmental Sciences Europe (2022) 34:22 Page 18 of 24 Gap in mobility data solutions in critical areas, particularly around points of Poll results: Wide gap (37%); closing gap (47%); negligible highly concentrated chemical discharge. gap (16%). The gap in mobility data, particularly log K , was Gap in toxicity data oc ranked 7th and notably lower in comparison to the gaps Poll results: Wide gap (60%); closing gap (30%); negligible in persistency data and toxicity data. An important con- gap (10%). cern related to the gap in mobility data is the complex Though there is a lot of toxicity data required for chem - nature of the sorption behaviour of ionic and ionizable ical registration as part of the REACH regulation, this gap substances [41, 83, 123]; K experiments or sorption being ranked 4th important may be related to the lack of oc experiments may be considered much easier than simu- data for long-term chronic exposure to drinking water, lated half-life studies or a battery of toxicity tests, as indi- and the time lag it has taken to recognize toxic mecha- cated by the large number of substances with K values nisms of many PFAS substances, after initial monitoring oc in the literature compared to half-lives [16]. It should be data have become available [85]. This was recently dem - noted that the gap P, M and T data is linked to the gap in onstrated when PFBS and 1,4-dioxane were identified as risk assessment models, as without detailed knowledge of SVHC owing to their equivalent level of concern, as envi- half-lives, environmental pathways and toxicity, in addi- ronmental monitoring data go back decades before the tion to exposure pathways, it is challenging to accurately classifications of ecotoxic (PFBS) and carcinogenic (1,4 foresee risks. dioxane), respectively [10, 126, 127]. Another concern is mixture effects from the multiple, mostly unknown Gap in persistency data PMT/vPvM substances and transformation products in Poll results: Wide gap (41%); closing gap (50%); negligible drinking water, requiring the advancement of techniques gap (9%). like effect directed analysis to assess drinking water safety The gap in measured half-life data (reflective of per - [128]. sistency), is known to be substantial, as this is so rarely quantified [73, 75] and thus this gap was ranked 6th. Per- Gap in safe and sustainable substitutes sistency data is the biggest bottle neck to a PMT/vPvM Poll results: Wide gap (60%); closing gap (34%); negligible substance evaluation, hence the need for methods like gap (6%). the OECD 309 test presented above. It is likely that this The gap in safe and sustainable substances being rd gap could be reduced by adjusting the regulatory defini - ranked 3 largest is reflective of the newness and argu - tion of persistency, which is difficult based on the strong ably complexity of this topic. SSBD represents a new consensus around the current definition [124], or devel - approach that will require collaboration of various pro- oping simpler methods or guidelines to infer environ- fessionals including industrial designers, materials chem- mental half-lives, which appears most practical. ists, chemists, toxicologists/modellers, risk assessors, supply chain experts, marketing and retail experts. For Gap in water remediation infrastructure instance, chemists could select feedstock/process/fin - Poll results: Wide gap (56%); closing gap (31%); negligible ishing chemicals, assess their characteristics and risks gap (13%). by modelling. Traditional synthetic chemistry must be The gap in water infrastructure, ranked 5th, is a reflec - weighed against biochemical synthesis, an appreciation tion on water remediation infrastructure varying geo- of how the materials used can be recycled is needed and graphically, from areas with advance treatment, to areas compliance method to test final products for substances with only basic treatment [125]. This paper has shown of concern must be developed. that certain PMT/vPvM substances, like TFA, can only be removed using expensive, energy intensive processes Gap in monitoring data like reverse osmosis or ion exchange resins. Upgrad- Poll results: Wide gap (64%); closing gap (32%); negligible ing equipment at water treatment plants would be not gap (4%). feasible in all geographic regions. End of pipe solutions The gap in monitoring data was considered as the sec - should only be considered as complementary strategies ond largest because most industries and regional regu- for specific scenarios where the “polluter pays” princi - lators are not currently investing in screening programs ple may, to some extent, be applicable. Thus, substitution for emerging PMT/vPvM substances, particularly out- and avoidance of PMT/vPvM substance emission needs side of Western Europe. Even within Europe, monitor- to be prioritized as the safer, cheaper, and more sustain- ing for such substances has mainly been carried out by able strategy to get in control of these substances. Never- universities, research institutes and in some areas water theless, advance remediation infrastructure can provide producers. Analytical techniques are not the problem Hale  et al. Environmental Sciences Europe (2022) 34:22 Page 19 of 24 (as this was ranked the 9th), but the scarcity of monitor- advocate groups and regulatory mechanisms are in place ing occurring. One main reason for this is likely lack of to stimulate innovation away from harmful PMT/vPvM regulatory pressure, as initial findings from scientists will substances. Realising the goals set out in the Chemicals often not spread into conventional monitoring programs Strategy for Sustainability Towards a Toxic Free Environ- without such regulatory guidance. Further, as the Swiss ment will form an important basis for this cooperation monitoring study highlighted here illustrated, there are towards zero pollution of PMT/vPvM substances. several lines of evidence through non-target analysis that there are instances of pollution by unknown synthetic Methods chemicals and their transformation products [50]; which The "Third PMT Workshop: Getting control of PMT leads us to the largest gap. and vPvM substances under REACH", took place on the 25th and 26th of March 2021 (online) and was attended Gap in the knowledge of substance mixtures by over 700 people. The audience and presenters con - and transformation products sisted of scientists, chemical and water regulators, envi- Poll results: Wide gap (91%); closing gap (7%); negligible ronment and health non-government organisations, and gap (2%). representatives from the chemical production and water The gap in the knowledge of substance mixtures and services sectors, all concerned with protecting the quality transformation products was ranked as the largest gap. of our water resources. Presentations were held about the Many REACH registered substances are "unknown knowledge gaps detailed above and attendees were invited or variable composition, complex reaction products" to provide their opinions about the size of the knowledge (referred to as UVCBs). Their substance composition is gaps related to PMT/vPvM substance research and regu- complex, but may contain several PMT/vPvM substances lation. The diverse perspectives from the presenters who of concern. Further, it is often observed that many of the make up the author group are presented herein to show known transformation products of persistent substances new ideas of how PMT/vPvM substances can be brought are persistent substances that are also mobile [12, 129]. under control in order to protect water resources, par- There are also many unresolved signals from non-target ticularly those registered under REACH. screening approaches that could be transformation prod- ucts, as presented with Swiss monitoring study above any Supplementary Information database [50]. Smart suspect lists on PMT/vPvM sub- The online version contains supplementary material available at https:// doi. org/ 10. 1186/ s12302‑ 022‑ 00604‑4. stances including transformation products identified in studies by industry for the REACH registration process Additional file 1. Additional file consisting of figures, tables and text. could be very beneficial for future comprehensive moni - toring. Ideally, these lists should not only contain the compounds’ names and properties but also link to open Acknowledgements Karin Kiefer, Eawag, generated Additional file 1: Fig. S1. access spectra libraries where the MS spectra are avail- able to support the identification process. Authors’ contributions SEH conceived the original article structure, co‑ developed the original draft, contributed to original writing and led revisions of the manuscript, ensuring Getting in control of PMT/vPvM substances all authors have approved the submitted article. HPA co‑ developed the origi‑ through collaboration (H. P H. Arp, S. E. Hale) nal draft, contributed to original writing, co‑revised the entire manuscript, and Getting in control of PMT/vPvM substances requires led the data analysis of polling results. All other authors wrote and revised the chapters for which they are explicitly named. All authors read and approved collaboration and dialogue between all stakeholders, the final manuscript. even beyond the diverse set represented by the authors of this current review. Regulation and governance strate- Funding S.E. Hale and H.P.H. Arp acknowledge funding from the German Federal Min‑ gies would work best alongside industrial stewardship to istry for the Environment, Nature Conservation, Building and Nuclear Safety best manage PMT/vPvM substances. SSBD tools require (FKZ3719654080). a collaboration of environmental scientists and toxicolo- Availability of data and materials gists that conduct risk and alternatives assessment, based The datasets used and/or analysed during the current study are available from on the input from all designers, synthetic chemists, sup- the corresponding author on reasonable request. ply chain experts and material scientists concerned with the design of the product or service that is seeking to phase out PMT/vPvM substances. 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Journal

Environmental Sciences Europe – Springer Journals

Published: Dec 1, 2022

Keywords: Water protection; Regulation; Governance; Stewardship; Prevention; Remediation

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