Dear list,
Looking at what we do know about contaminant bioaccumulation in the food chain, there appears to be a valid argument for soil targets to be driven in future by people who are likely to eat food and/or have an interest in food safety and/or protection.
The nature of the problem at present is not new, where relevant considerations at DQRA stage require in depth understanding of a variety of different standard drivers in separate regulatory environments.
Personally my view is that it would be great if the above were acknowledged and there was a forum at national level to support more joined up thinking.
In the meantime, luckily (as always) we can rely in advice and guidance from Public Health England, the expert panel, organisations such as SoBRA, Land Forum, esteemed peers and toxicologists.
Happy Christmas all!
Maybe think twice about having Mussels on Christmas day?
Kind regards
Ruth
Ruth Willcox
Environmental Protection Officer
Public Protection Service
Windsor House
Tavistock Road
Plymouth
Devon
PL6 5UF
T +441752304154
E [log in to unmask]
www.plymouth.gov.uk
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Chris Dainton
Sent: 22 December 2015 15:16
To: [log in to unmask]
Subject: Re: Water Framework EQS Values
From the link
https://circabc.europa.eu/sd/d/4e13a4c4-07b9-4e55-a43d-823e7cd4ce82/PAH%20EQS%20dossier%202011.pdf
The following is from a brownfield QRA perceptive, where this BaP Standard (and others) might get adopted in RTM-type assessments as the compliance concentrations at a POC.
Table 3.21: the 1.7E-4 ug/l is specifically for 'Human health via consumption of fishery products'
So from a risk-based perspective, if the site conceptual model can rule out production of 'fishery products' along the watercourse, then surely this EQS can be ruled out?
Plus, 0.00017 ug/l to protect against consumption of fishery products seems kind of silly (in the context of brownfield assessment) when the standard for drinking water is 0.01 ug/l (yes I know its because of accumulation). 0.01 ug/l at 2 litres a day, 365 days a year, for life.
It gets worse though when you look at Page 40 as the 0.00017 ug/l is the lowest of the values they could have chosen:
Fish: 0.015 ug/l
Molluscs: 0.00017 ug/l
Crustaceans/Cephalopods: 0.00045 ug/l
Are we REALLY going to let brownfield QRAs setting soil targets be driven by the protection of people who might eat shellfish, shrimps and squid??
Reality check required!
Chris Dainton
Peak Environmental Solutions
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