A Regulatory Prioritization Framework for PMT/vPvM Substances

Abstract

A framework was developed to facilitate the regulatory prioritization of persistent, mobile, and toxic (PMT) and very persistent, very mobile (vPvM) substances registered under REACH. The prioritization framework includes four categories: (i) exposure data; (ii) REACH emission likelihood; (iii) analytical and monitoring gaps; and (iv) drinking water remediation feasibility, which are combined to give an overall prioritization level and were used to support the prioritization of PMT/vPvM substances under REACH. The prioritization framework was applied to 60 PMT/vPvM substances (according to the hazard classes in the Classification, Labeling, and Packaging (CLP) regulation), taken from a previous screening exercise. The available exposure data indicated that of the 60 substances, 6 were detected ubiquitously at high concentrations, 9 were detected ubiquitously at low concentrations, and 18 were detected in local regions (rather than ubiquitously) at either high or low concentrations. Of the 60 substances, 49 either had a high (33 substances) or very high (16 substances) REACH emission likelihood. There were 24 substances for which the analytical and monitoring gap was major as they were not monitored (with 6 of these having no analytical methods currently implemented); minor for 16 substances as they were monitored by some laboratories; and not apparent for 20 substances that were regularly monitored. There were substantial drinking water remediation feasibility gaps assessed by whether the substances could be removed by typical remediation processes, including activated carbon (AC) filtration or ozonation. 34 substances could not be removed using either method; 12 could be removed by ozonation only; and 10 could be removed by AC filtration only. Considering all these aspects, across the 60 substances, 30 were assessed to be of the highest priority for follow-up, 19 were of high priority, and 11 were of moderate priority. This prioritization framework can be further developed and applied to other REACH-registered substances or to other chemicals placed on the market to support the development of effective regulatory measures to safeguard water resources against contamination.