Fate and behaviour

The approach for the risk envelope for the aspect ‘fate & behaviour’ is included in the Guidance (SANCO /11244/2011 rev. 5, 14 March 2011) elaborated in Chapter 7.4.

Specifically for a NLKUG application, the relevant assessment framework must first be established. The starting point is that the version of the Evaluation Manual (EM) that was used for the original assessment is also used for the assessment of the NLKUG application. If an adequate risk assessment cannot be performed, a more recent version of an EM can be used.

Please note: for every assessment, regardless of the assessment framework, the interception values from EFSA (2014) and the most recent monitoring data are used. Moreover, for pragmatic reasons we use the most recent versions of the PEARL and GeoPEARL models, and we use drift values that are relevant to practice (i.e. the values in the Activities Decree Environmental Management).

Risk envelope parameters

Subsequently, the newly requested uses are compared with the previously authorised uses with respect to a number of key parameters. The guidance states that for each sub-aspect (soil, groundwater and surface water/ sediment), various key parameters must be compared. Of particular importance are:

  • Dose
  • Frequency of use
  • Interval of use
  • Application method

Other specific parameters are also important for each sub-aspect.

  • For ‘Leaching to groundwater’, this concerns the crop scenario used for the PEARL (and possibly GeoPEARL) calculations.
  • For ‘Emission to surface water and sediment’, this concerns the crop scenario used for the GEM (substrate cultivation) calculations.
  • For ‘Deposition on surface water (drift)’, this concerns the possibility of mitigating measures.

Risk envelope assessment

In principle, the newly requested field uses are compared with previously authorised field uses; the newly requested greenhouse uses are usually compared with previously authorised greenhouse uses.

Furthermore, during the risk envelope analysis, the most recent groundwater monitoring data (using the Groundwater Atlas for pesticides in the Netherlands), monitoring data on surface water (using the Atlas for pesticides in surface water) and the drinking water criterion (using the VEWIN list of substances of concern for drinking water preparation) are considered.

The result of the risk envelope check is a conclusion regarding the newly requested uses on the application. The newly requested uses may fall under the risk envelope of the uses previously authorised; in another case, an additional risk assessment may have to be carried out for one or more compartments (soil, groundwater, surface water/sediment). The outcome of the risk envelope check also contains a conclusion with regard to the available monitoring data and the drinking water criterion.

See below the table used to implement the risk envelope check.