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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