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Table 4 Conceptual comparison showing that PMT/vPvM substances pose an equivalent level of concern as PBT/vPvB substances

From: Persistent, mobile and toxic (PMT) and very persistent and very mobile (vPvM) substances pose an equivalent level of concern to persistent, bioaccumulative and toxic (PBT) and very persistent and very bioaccumulative (vPvB) substances under REACH

Criteria to assess PBT/vPvB PMT/vPvM
Serious effects to human health
 Poses a threat to human health? Yes
Accumulation in the food chain (exposure route)
Yes
Accumulation in the water cycle (exposure route)
 Irreversible health effects? Yes
Substances can bioaccumulate in humans; chronic and acute effects possible
Yes
The continuous human exposure through drinking water intake and continuous remote aquatic ecosystem exposure due to mobility and over long time scales means chronic and acute effects are possible
 Delayed health effects? Yes
Substances can continue to accumulate in humans long after emissions have ceased, causing chronic exposure effects to become more evident with time/age
Yes
Exposure may occur even long after emissions have ceased, causing chronic exposure effects to become more evident with time/age
 Impaired quality of life? Yes
Health effects (chronic or not) can impair quality of life
Yes
Health effects (chronic or not) can impair quality of life, including fouling of drinking water (taste, odour, etc.)
Serious effects to the environment
 Irreversible exposure? Yes
Once the contamination is in the environment it cannot be removed and impacts cannot be mitigated by reducing pollution levels. Emissions from contaminated areas can be ongoing long after phase-out
Yes
Once the contamination is in the environment it cannot be removed, particularly due to the lack of water treatment facilities. Emissions from contaminated areas can be ongoing long after phase-out
 Irreversible effect? Yes
Both chronic and acute irreversible effects possible, depending on toxic profile
Yes
Both chronic and acute irreversible effects possible, depending on toxic profile
 Intergenerational exposure and effect? Yes
Effects are long term and felt over more than one generation due to persistency, such as exposure through lactation and food chain uptake
Yes
Effects are long term and felt over more than one generation due to persistency, such exposure through lactation and exposure to the same aquatic media
 Unknown/uncertain spatial scale? Yes
Bioaccumulation within the trophic food chain in an environmental compartment has complex dynamics
Yes
Able to spread within aquatic compartments (such as ground water or surface water) to other environmental aquatic compartments relatively rapidly or over long distances
 Disparity between point of release and point of effect? Yes
Release occurs at one point and effects are felt at different trophic food chain levels
Yes
Release occurs at one point and effects are felt following transport to a new aquatic environmental compartment
 Unknown/uncertain temporal scale? Yes
Long term effects unknown
Yes
Long term effects unknown
 Uncertain/difficult to predict long term fate and toxic effects? Yes
Long term fate unknown
Long term toxic effect unknown
Quantitative environmental risk assessment and a safe environmental concentration cannot be performed or defined
Yes
Long term fate unknown
Long term toxic effect unknown
Quantitative environmental risk assessment and a safe environmental concentration cannot be performed or defined
 Harmful to the aquatic environment? Yes
Far reaching effects (spread with aquatic biota and long-range transport)
Effects on top predators of particular concern
Low effect concentrations to aquatic organisms possible
Mixture toxicities effects with other stressors cannot be ruled out
Yes
Far reaching effects (spread directly via water)
Can affect all aquatic trophic levels due to similar exposure
Low effect concentrations to aquatic organisms possible
Mixture toxicities effects with other stressors cannot be ruled out
 Potential to reach remote pristine areas? Yes
Particulate and biota assisted transport within water bodies and atmosphere
Yes
Transport across water bodies to pristine oceans, ground water or pristine lakes and watersheds
Additional effects
 Increased societal costs? Yes
Cost implications for society in terms of healthcare
Cost implications for society in terms of harm to wider environment, e.g., contaminated land and sediment remediations
Yes
Cost implications for society in terms of healthcare
Cost implications for society in terms of harm to wider environment, e.g., contaminated soil and groundwater remediation
Cost implications for drinking water treatment
 Negative effect on resources? Yes
Food resources impaired via uptake in the food chain
Land and sediment polluted by such substances comprised
Potential impact on product recycling and the circular economy due to such substances impacting food resources
Yes
Drinking water quality impaired (including taste, odour, resources for remediation having unfavourable outcomes)
Makes recycling wastewater more problematic and expensive
Land, ecosystem services and groundwater polluted by such substances and compromised
Potential impact on product recycling and the circular economy, due to products with such substances contaminating water resources-
 Do emissions need to be minimized? Yes
Mitigation measures must be put into place
Accumulation in biota and toxic effects difficult to reverse
Yes
Mitigation measures must be put into place
Impacts on the drinking water sources and pristine ecosystems difficult to reverse