Water operators are having to carry out more and more treatments on water to remove contaminants such as pharmaceuticals, nitrates and pesticides. We need better enforcement of EU laws to ensure that domestic consumers do not pay for additional treatments to keep our drinking water safe.

Despite a singular goal to keep water safe and clean, European water operators are having to spend millions of Euros to remove more and more contaminants from water. These micropollutants can enter the water cycle in many ways, and once present, they can pose a risk to human and environmental health. Pollution originating from agriculture, such as nitrates, pesticides, and pharmaceuticals, currently receives the most media coverage.

Micropollutants are organic or mineral contaminants emanating from either anthropogenic or natural origin giving rise to considerable toxicological concerns for the aquatic environment. They can be found in waters at very low concentrations, ranging from micrograms to nanograms per litre.

In 2018, only 40% of our surface water bodies achieved good ecological status. At the same time, 25% of our ground water reservoirs showed at least some contamination from certain pollutants known as priority substance1. This reflects the increasing number of products professionals and consumers use in daily activities. It is estimated that approximately 100,000 organic chemicals are in regular use in Europe, with 1,000 new ones entering the market each year.

The good news is that consumers are more aware of the effect human activities have on the environment, as concern is increasing over substances that may contaminate water resources. While reducing the levels of micropollutants within water resources is possible, it requires expensive additional treatments.
“given the upsurge in the use of chemicals and pharmaceutical products, the water sector is concerned for the protection of water resources”

“given the upsurge in the use of chemicals and pharmaceutical products, the water sector is concerned for the protection of water resources”

Given the upsurge in the use of chemicals and pharmaceutical products, the water sector is concerned for the protection of water resources. Furthermore, at present, knowledge regarding many new substances is patchy with respect to their effects on human health and the environment. Consequently, the water sector calls on policy makers to ensure that the industry immediately starts to thoroughly and transparently disclose the impact new substances have on the environment in order to make robust and effective EU legislation.

Micropollutants’ implications for water operators

These micropollutants are a challenge for water operators on both the drinking and waste water sides. According to the Water Framework Directive, Member States have to protect water resources so that drinking water operators are able to rely on these to supply consumers with safe drinking water with minimum intervention. On the other hand, the waste water operators’ mission is the return of safely treated waste water to the environment.

New pollutants may require additional treatments, however. Advanced treatment processes to remove micropollutants at the waste water treatment plants result in higher investment and operational expenditure, and increased energy use. These increased costs lead to increased consumer water bills. Moreover, there is no one-size-fits-all solution. Different micropollutants require different technologies to be removed. Hence, irrespective of the solution installed, it is unlikely to guarantee 100% removal of micropollutants from waste water.

It is predicted that the amount of micropollutants entering the environment will increase, partly due to our ageing population requiring more medications. Water operators agree that our water should be as clean as possible, so that they only have to perform a minimum of interventions to keep our water safe and water services affordable to be accessible to all European citizens.

For this reason, there is a more sustainable solution than treating micropollutants at the waste water treatment plants. The release of micropollutants needs to be – and can be – drastically reduced through effective control-at-source measures. If the release cannot be avoided completely, for example in the case of pharmaceuticals, the polluter should pay for additional treatment, and not the water consumer, according to the implementation of the Polluter Pays Principle.

The ghost of the EU’s past

The solution to the water contamination problem exists simultaneously with the lack of enforcement, or there is no political will to implement it.
The Treaty on the Functioning of the European Union (TFEU) lays out important principles that EU law has to follow to protect our health and the environment. It enshrines three important principles.

The Source Control Principle is the idea that “preventive action should be taken and environmental damage should, as a priority, be rectified at the source”. This means contaminants should be prevented from entering the water system at all.

Under the Precautionary Principle, if the outcomes or the effects of a substance are unknown then policy makers must err on the side of caution and protect the public and the environment from exposure to possible harm.

The ‘Polluter Pays’ (Principle) reinforces the other two principles, as it stipulates that those who pollute should bear the costs of preventing or rectifying the damage to human health or the environment.

If the three principles were mainstreamed in all EU legislation and correctly implemented and enforced, we would be well on the way to preventing contaminants from entering the water cycle, thereby protecting human health and the environment, and keeping our water affordable.

These principles constitute the underlying philosophy behind the Water Framework Directive (WFD) and European chemical legislation such as REACH, the Plant Protection Products Regulation, and the Biocides Regulation.

The EU is currently reviewing all its water legislation. It is the ideal time to ensure the principles laid out in the TFEU are in fact implemented. One such opportunity is the Urban Waste Water Treatment Directive (UWWTD), which protects the environment from the adverse effects of urban waste water discharges and discharges from certain industrial sectors. Robust and fit-for-purpose legislation is one thing and release of pollutants into sewers should be better controlled upstream by avoiding any harmful substances entering sewers. These laws must also be effectively implemented in Member States, and if not, the EU must take action to ensure they are.

Extended producer responsibility

Producers must assume responsibility for the products they design and place on the market. Fewer harmful substances released to the environment will also reduce the overall exposure of the population to chemicals and will be a strong driver for product innovation.

This is where Extended Producer Responsibility (EPR) can be used to implement the Polluter Pays Principle as enshrined in the EU Treaty. It works on the reasoning that a producer is responsible for the whole lifecycle of a product.

This means that the producer will have to pay attention to a product’s component materials and how these break down and affect the environment.

The EU is increasingly applying the Polluter Pays Principle, for example through the Single Use Plastics directive. Micropollutants have yet to be addressed and this must change.

A strategic approach to pharmaceuticals

One area where a lot of progress could be made is in pharmaceuticals. As outlined above, pharmaceuticals represent one group of micropollutants that is likely to grow in importance over the next decades. The European Commission’s recently published Strategic Approach to Pharmaceuticals in the Environment identifies six action areas the Commission will target to better protect the environment.

The actions cover pharmaceuticals for human and veterinary use during their whole lifecycle, from design and production to disposal and waste management.

Actions include raising awareness and promoting the more careful use of pharmaceuticals; improving training and risk assessment; information and monitoring; promoting and incentivising ‘green design’; reducing emissions from manufacturing; reducing waste and improving waste water treatment.

We are pleased that the proposed strategy is looking at the full lifecycle of pharmaceuticals and that the Commission intends to fill knowledge gaps. We also welcome the fact that the pharmaceutical industry will have to explore how EPR can be used to improve the efficacy of water treatment. This could avoid increased water bills for consumers, provided this rather vague wording translates into real obligations.

Nevertheless, the Strategic Approach remains weak in a number of respects. There is no mention of improving the way the Environment Risk Assessment is taken into account in the authorisation process for human pharmaceuticals. The review of the functioning of the interface between the medicinal products legislation and the chemical legislation has disappeared from an advanced version made public by an EU media outlet in 2018. The same goes for the technical and financial obstacles for waste water treatment that should be overcome.

Taking matters into their own hands

Some European countries and EurEau members are not waiting for the EU legislation to be implemented. They are already working to reduce the presence of micropollutants in the environment by investing in new technology for their Waste Water Treatment Plants (WWTP). The exact costs of removing micropollutants depends on many factors, including geography, the size of the plant, and the requirements in micropollutants removal.

For example, Switzerland is one of the first countries to start implementing a national policy to reduce pharmaceuticals in municipal waste water effluent. It is estimated that the average cost for waste water treatment including nutrient removal in Switzerland is around €0.61/m³.

The total investment costs to upgrade 100 waste water treatment plants (out of approximately 650 WWTPs and covering approximately 50% of the national annual waste water volume) are estimated at €1 billion.2

Other countries are also implementing strategies to reduce the amount of micropollutants in their effluent. The Dutch STOWA study3 estimates costs varying from roughly €5/ (population equivalent (p.e.)/ year for very basic treatment to €34 /p.e./year.

Meanwhile in Finland4, estimated costs for removing 90% of harmful pollutants will incur an additional cost of between €0.4 and €0.91 per m³. However, this depends upon the population equivalent and assumes the waste water treatment plant is already equipped with advanced nutrient removal treatment step. Improving the efficiency of removing harmful substances would require an investment of €700– 1,400 million and increase the annual operational costs of waste water management by €100–220 million.

Germany already had 17 full-scale applications with ozone and sand filtration in operation in 2015. Eleven others are planned. There is no national legislation for the introduction of an additional treatment stage but there are special political strategies in some regions where these technologies have been introduced. This is estimated to be around €1.2 billion /year.

Denmark is also carrying out studies and reports that on average, biological treatment removes up to 50% of pharmaceuticals. Some of the Danish water utilities are running pilot and full scale tests of extra end-of-pipe treatments to reduce the amount of pharmaceutical waste being discharged.

Looking forward

The EU is currently reviewing all of its water legislation. Legislators should take the opportunity to cement the Control at Source, Polluter Pays and Precautionary Principles into our directives and regulations. We want the European institutions to:

  • Adopt a holistic approach to micropollutants through making producers responsible for the whole lifecycle of products they make
  • Use the REACH authorisation process more frequently, identifying additional substances of concern and using the authorisation and restriction processes on persistent, mobile and toxic substances
  • Make the producer pay for damage to the environment or any measures taken down the supply-chain to avoid the release of pollutants into the environment
  • Encourage the development of innovative products that are environmentally-friendly
  • Use eco-design and ecolabel criteria more extensively to reduce harmful components from later leaching into the environment
  • Raise awareness amongst citizens and encourage them to make more environmentally-conscious decisions

We work with the European institutions to protect consumers and the environment. Having fewer harmful substances throughout our water-cycle benefits everyone. The EU and Member States need to act. The legal basis needed to protect human and environmental health is there. The end-of-pipe (i.e. waste water treatment plant) solution, which is often the default response, is not a sustainable one. Each revision of relevant EU legislation should be used to ensure that our laws are more effective.

References

  1. European Environmental Agency ‘European Waters’ report, 2018.
  2. Note that cost data varies widely depending on the different parameters considered (e.g. location of the WWTP, local conditions, capacity of the WWTP, measured in population equivalent size, water recharge rate, etc.) as well as national differences between WWTP structures.
  3. https://www.stowa.nl/sites/default/files/assets/PUBLICATIES/Publicaties%202017/ STOWA%202017-36%20%20defversie.pdf.
  4. https://www.vvy.fi/site/assets/files/1666/jatevedenkasittelyn_teknis-taloudellinen_ selvitys_21042016.pdf (page 65).