Response to the European Commission s Public Consultation on 'Policy options to optimize water reuse in the EU'

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1 CEN Identification number in the EC register: Response to the European Commission s Public Consultation on 'Policy options to optimize water reuse in the EU' November 2014 Background Information CEN (European Committee for Standardization) is an officially recognized organization (EU Regulation 1025/ ) responsible for developing and defining standards at European level. These standards set out specifications, requirements and recommendations in relation to a wide range of products and services. The members of CEN are the National Standards Bodies of 33 European countries including all of the EU member states plus Iceland, Norway, Switzerland, Former Yugoslav Republic of Macedonia and Turkey. CEN also works to promote the international harmonization of standards in the framework of a technical cooperation agreement with ISO (International Organization for Standardization). European Standards are developed through a process of collaboration among technical experts nominated by business and industry, research institutes, public authorities, consumer and other stakeholders. These standards are implemented throughout all of the 33 countries covered by CEN. Executive Summary CEN is fully committed to support environmental legislation and new policy initiatives. We are convinced that the role of the standardization as an EU-level instrument is to contribute also to the optimization of the water reuse in Europe by providing the necessary methodologies to foster water reuse, while ensuring the health and environmental safety of water reuse practices. CEN has already started to look at the standardization needs in the field of waste water reuse. The CEN community is in favor of the elaboration of EU level measures and more specifically 1 Regulation 1025/2012 on European standardisation CEN-CENELEC Management Centre, Avenue Marnix 17, 1000 Brussels, Belgium T: F: info@cencenelec.eu

2 European Standards that are applicable across Europe and could increase the credibility of water reuse projects by providing, in a longer term, the necessary technical methods needed for tackling the health and environmental risks related to water reuse. CEN decided to leave its National Standardization Bodies to reply to the questionnaire if they wish to do so. However, the CEN Strategic Advisory Body on Environment (SABE) identified a series of short, medium and long-term standardization priorities in this filed which need to be addressed at European level. These recommendations have been approved by the CEN Technical Board and are in the Annex to this document. CEN decided to send the standardization priorities to the European Commission as its reply to the consultation on water reuse. European Standardization priorities in the field of waste water reuse CEN identified the following standardization priorities in support of the optimisation of water reuse in the EU: Overview of the national standardization initiatives and call for harmonization at EU level Strong co-operation with the ongoing ISO work in the area Complement ISO work with EU initiatives. The specific EU standardization initiatives are the following: There are an increasing number of contaminants of emerging concern a lack of adequate standard monitoring methods (high precision and low cost). Standardization needs are identified for the development of harmonized sampling & testing protocols for the application of effect-based tools and non-target screening techniques. Antibiotic resistance and its spread via treated wastewater reuse (and effluent discharge) is the source of serious public health concern. Reliable and easy-to-perform methods for characterization of antibiotic resistance prevalence in treated wastewater should be optimized and articulated with water quality monitoring in view of integration in standardization. However, there is still a need to improve knowledge on the role of wastewater reuse practices on the accumulation of antibiotic resistance in the environment and the determination of resistance spread. CEN is convinced that the following factors should also be considered for the development of guidelines for treated wastewater reuse: the intended water reuse applications should govern the degree of wastewater treatment required; greater benefits may come from managing risks to acceptable levels rather than applying rigid guideline values if these are not applicable or if they make water recycling unaffordable. CEN intends to continue its dialogue with the European Commission and other relevant stakeholders to ensure that European standards are delivered in support of an informed and controlled reuse of treated wastewater. CEN reply Public consultation of November 2014 Page 2 of 9

3 Annex To CEN response to the European Commission s Public Consultation on 'Policy options to optimise water reuse in the EU' Wastewater reuse and implications for future standardization Strategic Position Paper Note: This Position Paper was elaborated by the CEN/SABE ENV Team (Environmental monitoring strategy team) and approved by CEN Technical Board in October Background and introduction Water reuse is considered as an effective way of helping to solve the water scarcity and droughts issues in the EU. It is also an effective means to achieve a smaller footprint with regard to the water abstraction and reduced energy consumption in relation to potable water production. Recycled water is most commonly used for non-potable (not for drinking) purposes. The dominant applications for the use of treated wastewater include irrigation, industrial reuse and groundwater recharge. Urban water recycling, in particular for landscape irrigation, is experiencing fast development and will play a crucial role for the sustainability of cities in the future. Other relevant and cost-efficient applications are also emerging, such as environmental enhancement, in-building recycling and industrial uses of reclaimed urban wastewater. Indirect potable reuse, in particular groundwater (aquifer) recharge, after complementary polishing and storage of recycled water in an environmental buffer, has been implemented in some countries as an efficient response to the need to increase water supply. While the reuse of water should not be regarded as the solution on a global scale (any decision to reuse treated wastewater should be based on a prior assessment of the economics, environmental impact and the continuity of supply compared with alternatives such as the use of surface- or groundwater), increased development of water reuse projects is considered globally as the most critical element of sustainable water management. In spite of the above-mentioned benefits, only a small proportion of the treated urban wastewater is reused globally in Europe today (2,4% of the treated urban wastewater effluents in Europe) (MED WWR WG, 2007). Currently, no harmonised regulations and no standards exist at the EU level to control this practice. In the Water Framework Directive (WFD), reuse of water is mentioned as one of the possible measures to achieve the Directive s quality goals (Part B of Annex VI), but this remains a recommendation rather than a requirement. The same applies to the Urban Waste Water Treatment Directive (UWWTD) (EU Commission, 2014). Lack of water reuse is one of the twelve priority problems identified in the "Blueprint to Safeguard Europe's Water Resources" (2012) and the European Commission (DG ENV) is currently developing an EU policy instrument (expected in autumn 2015) which should provide a basis to support an increased level of water reuse. CEN reply Public consultation of November 2014 Page 3 of 9

4 2. Current challenges: the research perspective From the research perspective, the reuse of treated wastewater involves challenges associated with quantity and quality aspects. The challenges associated with quantity aspects are about: the amount of wastewater available: sufficient in quantity to meet the demand? transport and storage: can the water be delivered to irrigated areas where and when it is needed? The challenges associated with quality aspects are about: human health, plant health, effects on non-target organisms in ecosystems, bioaccumulation, secondary poisoning in the food chain, soil accumulation, impact on groundwater (and its use): continuous progress in scientific knowledge leads to growth in the number of parameters considered as relevant. It has, however, to be stressed that the challenges associated with water quality aspects apply to the global water cycle and not only to treated wastewater reuse. It must be also underlined that the required water quality should be defined depending on its final use (drinking water, irrigation ), and not on its origin (sea water, sewage water ). Among the quality challenges, the following issues have been identified: a. Contaminants of emerging concern (CECs) The WFD sets out the EU strategy against pollution of water by hazardous substances. A list of priority (hazardous) substances identified as substances representing a significant risk to or via the aquatic environment at EU level is established and regularly reviewed 2. Besides these already regulated pollutants, contaminants of emerging concern, including pesticides, biocides, hormones, pharmaceuticals, personal care products, etc. and their associated transformation products raise increasing attention as they are regularly found both in treated urban wastewater and in the environment. Although the concentration levels are very low, the possibility of these substances having an impact on the environment (carcinogenic, teratogenic and/or mutagenic effects, endocrine disruption, etc.) cannot be neglected, since currently, there is no comprehensive understanding of their behaviour, fate and biological potency after their discharge or during reuse applications on flora and fauna species present in the environment (i.e. mixture effects). Moreover, since CECs are by definition non-regulated contaminants, their testing by wastewater treatment plant operators or national authorities is not mandatory. The current 2 The first (and most recent) review was conducted in leading to the current list of 45 substances (Dir 2013/39/EU). The next will have to be completed by CEN reply Public consultation of November 2014 Page 4 of 9

5 information available is based on findings from the research community and therefore the analysis performed is not yet standardized, including data generated from samples collected using differing sampling techniques (e.g. grab samples, composite samples, flow or volume proportional samples). Sampling is performed using varying sampling containers and also sample conservation methods vary. Different sample preparation methods (e.g. for preconcentration) are used, while a number of analytical methods based on multi-residue chromatographic methods are applied. Furthermore, the interpretation of the results and the definition of important parameters, such as the Limit of Quantification (LOQ), are not uniformly applied in this type of studies. b. Acquired antibiotic resistance Antibiotic resistance and its spread via treated wastewater reuse (and effluent discharge) is also an issue which needs further investigation. Antibiotic residues and bacteria with acquired resistance are able, at the concentration levels commonly found in treated wastewater, to produce alterations in the microbial community, with still unknown consequences. Certain microbial groups are found in both wastewater and soil, leading to the possible transfer of antibiotic-resistant bacteria and genes from treated wastewater to humans via water-soil-food products or surface and groundwater. Furthermore, the release of antibiotic residues in the environment through wastewater reuse applications can potentially contribute to the development of resistance in the environment. 3. State of play of standardization activities The International Technical Committee ISO/TC 282/SC1 "Treated wastewater reuse for irrigation" was created to provide guidance for treated wastewater reuse projects for irrigation. The draft Standards series ISO 16075, Guidelines for treated wastewater use for irrigation projects, are now available: - Drafts of Parts 1 to 3 are already available and will be published by 30 June 2015, whereas Part 4 ( Monitoring aspects ) is still under discussion. Finalising Part 4 (the most sensitive part, in view of the issues involved) will require a great deal of input from public and private research laboratories as well as the wider standards community. These standards provide specifications for all elements of a project using treated wastewater for irrigation, including design, materials, construction and performance. They address the widespread and common ranges of water quality rather than exceptional or unique ones. Agronomic parameters (nutrients, salinity factors), trace elements (heavy metals) and microbial parameters are addressed in this ISO standard, whereas contaminants of emerging concern (e.g. pharmaceuticals, endocrine disruptors, etc.) antibiotic resistant bacteria, mixtures and allergens are currently outside its scope. The European Technical Committee CEN/TC 165 Wastewater engineering has created a Working Group, WG50 on Use of treated wastewater which works on the development of CEN standards for on-site use of treated wastewater including rainwater and greywater. Scope: Principles of design, construction, installation, operation and maintenance (different CEN reply Public consultation of November 2014 Page 5 of 9

6 codes of practice for water reuse from rainwater, greywater and treated wastewater); Quality (only parameters and test methods how to measure the quality, no threshold values) and quantity in respect of the type of end use; Product standards (performance, test methods, structural behaviour, guide for installation) for different products, e.g. tanks, filters, controls, treatment units, infiltration units in cases where no specific material related TC or a CEN/TC 165/WG exists. Drinking water purposes are excluded from the scope. There are initiatives, developed by national standardization bodies, which are relevant for wastewater reuse (see Annex 1). 4. Points for consideration for standardization activities a. General considerations and recommendations for Standardization in the short term: Recommendation 1 CEN to encourage National Standardization Bodies (NSBs) to submit their national standards as new work item proposals to ensure early harmonisation of relevant standardized approaches across Europe. Recommendation 2 - NSBs should encourage active participation of their experts, including representatives of research laboratories from public and private sectors, in the finalization of the current work of ISO/TC 282/SC1 "Treated wastewater re-use for Irrigation" (Part 4 Monitoring of ISO ISO 16075, Guidelines for treated wastewater use for irrigation projects); - NSBs should encourage participation of their delegations in the development of the programme of standards coordinated by ISO/TC 282 "Water re-use". Recommendation 3 The CEN work programme should be allocated jointly to CEN/TC 165 "Wastewater engineering" for wastewater engineering-related topics and to CEN/TC 230 "Water analysis" for parameter-measurement-related topics. These two TCs should be encouraged to cooperate at CEN level through their chairs and secretariats and should proactively liaise at ISO level. The adoption of the relevant ISO standards as CEN standards could then be considered in the light of future European legislation. Recommendation 4 Wastewater reuse is a priority of the European Commission within EU Priority should be given to evaluating wastewater reuse relative to regulated and emerging priority pollutants and application of measures to minimize their impact. It is recommended that CEN continues a dialogue with the European Commission and other relevant stakeholders to ensure that standards are delivered in support of risk CEN reply Public consultation of November 2014 Page 6 of 9

7 evaluation and mitigation. This will support informed and controlled reuse of treated wastewater. In all cases, the following factors should be considered for the development of guidelines for treated wastewater reuse: the intended water reuse applications should govern the degree of wastewater treatment required; greater benefits may come from managing risks to acceptable levels rather than applying rigid guideline values if these are not applicable or if they make water recycling unaffordable. b. Recommendations for Standardization in the medium term: Chemical contaminants of emerging concern (CECs) There are an increasing number of contaminants of emerging concern and a lack of adequate standard monitoring methods (high precision and low cost). The best approach would be the selection of performance indicators for CECs and surrogates (bulk parameters / indicators of occurrence). Bioassays are becoming a tool of increasing significance for water quality assessment and in general for all environmental matrices. They appear to be an appropriate tool for routine analysis and evaluation of the efficiency of wastewater treatment plants in removing toxicological hazards and for evaluation of the quality of the wastewater to be reused. The integration of effect-based tools (a range of bioassays) and non-target screening techniques, to complement target analytical protocols for individual parameters, appears to be an appropriate approach for assessment of water quality for wastewater reuse purposes. Recommendation 5 Standardization needs are identified for the development of harmonised sampling & testing protocols for the application of effect-based tools and non-target screening techniques for the chemical contaminants of emerging concern. CEN should encourage relevant CEN Technical Committee chairs to examine these issues and regularly report to CEN Technical Board on standardization needs. c. Recommendations for Standardization in the long term: Antibiotic resistance Antibiotic resistance and its spread via treated wastewater reuse (and effluent discharge) is an issue of on-going serious public health concern. Wastewater treatment plants may be important nodes of the complex network of antibiotic resistance acquisition, as they act as biological reactors, contributing to the dissemination of antibiotic-resistant bacteria or genes. Even if some advanced treatment or disinfection processes may contribute to decrease the total bacterial loads (abundance), they will not reduce resistance prevalence (percentage of resistant bacteria). CEN reply Public consultation of November 2014 Page 7 of 9

8 Recommendation 6 Reliable and easy-to-perform methods for characterization of antibiotic resistance prevalence in treated wastewater should be optimized and articulated with water quality monitoring in view of integration in standardization. The currently recommended enumeration of bacteria in treated wastewater used for irrigation could be extended to include the detection of specific sub-populations with certain indicators of antibiotic resistance. There is a need to improve knowledge of the role of wastewater reuse practices on the accumulation of antibiotic resistance in soil, and in particular the following: - identification of the most stable resistance determinants in irrigated soils; - understanding which are the parameters / factors affecting the vulnerability of the receiving environment for resistance propagation / persistence. Recommendation 7 CEN should encourage the development of standardization deliverables which should include requirements for both, short-term and long-term assessment of wastewater and soil / receiving media. In particular it is necessary to reach a consensus on: - the evaluation of antibiotic resistance accumulation in soil and growing media for food crops - the definition of acceptable threshold values of antibiotic resistance in the environment - the development of harmonized risk assessment protocols for the determination of resistance spread and transmission to humans and the food chain. Recommendation 8 CEN to review recommendations 1 to 7 on a regular basis (recommended 5 years) in the light of the advancing state of the art wastewater reuse and research findings. References EU Commission - DG ENV, Background document to the public consultation on policy options to optimise water reuse in the EU Lazarova V., Global milestones in water reuse: keys to success and trends in development. Water 21, 2013 MED WWR WG (Mediterranean Wastewater Reuse Working Group) - Mediterranean Wastewater Reuse Report, accessible at CEN reply Public consultation of November 2014 Page 8 of 9

9 Petrie B, Barden R, Kasprzyk-Hordern B., A review on emerging contaminants in wastewaters and the environment: Current knowledge, understudied areas and recommendations for future monitoring. Water Res pii: S (14) doi: /j.watres Rizzo L, Manaia C, Merlin C, Schwartz T, Dagot C, Ploy MC, Michael I, Fatta-Kassinos D., Urban wastewater treatment plants as hotspots for antibiotic resistant bacteria and genes spread into the environment: a review. Sci Total Environ. 2013; 447: doi: /j.scitotenv Varela AR, Manaia CM., Human health implications of clinically relevant bacteria in wastewater habitats. Environ Sci Pollut Res Int. 2013; 20(6): doi: /s Vasquez MI, Lambrianides A, Schneider M, Kümmerer K, Fatta-Kassinos D., Environmental side effects of pharmaceutical cocktails: What we know and what we should know. Journal of Hazardous Materials, 2014; 279C: doi: /j.jhazmat CEN reply Public consultation of November 2014 Page 9 of 9