EA (UKWFD): Consultation on the proposed revised methodology for the determination of hazardous substances for the purposes of the Groundwater Daughter Directive
We believe the approach and methodology outlined to be basically sound. The approach is clear and should not result in additional burdens being placed on the laboratory community. The approach is consistent with the demands of the legislation. However, there is one specific area which gives rise to a little concern. The proposed methodology for dealing with a non-hazardous substance which has hazardous breakdown products, recommends that the parent and breakdown should be assessed independently. This is a complex subject, and a “one size fits all” policy may not be appropriate. Each substance will break down at a different rate, and this may also depend on the physical and chemical environment. Some substances would break down quickly to give hazardous breakdown products, and this needs to be taken into account. Assessing these substances in the recommended manner may lead to a few substances being classified as non-hazardous whereas their breakdown mechanism and speed would dictate otherwise.