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User Guide to Thresholds and Classification - Environmental ...

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347<strong>User</strong> <strong>Guide</strong> for <strong>Thresholds</strong> <strong>and</strong> <strong>Classification</strong>sdifficulties in achieving dissolution through normal solubilisation techniques is so severe that the twoprocesses of solubilisation <strong>and</strong> transformation become indistinguishable. Thus, where the compound issufficiently poorly soluble that the levels dissolved following normal attempts at solubilisation do not exceedthe available L(E)C50, it is the rate <strong>and</strong> extent of transformation, which must be considered. Thetransformation will be affected by a number of fac<strong>to</strong>rs, not least of which will be the properties of the mediawith respect <strong>to</strong> pH, water hardness, temperature, etc. In addition <strong>to</strong> these properties, other fac<strong>to</strong>rs such asthe size <strong>and</strong> specific surface area of the particles which have been tested, the length of time over whichexposure <strong>to</strong> the media takes place <strong>and</strong>, of course the mass or surface area loading of the substance in themedia will all play a part in determining the level of dissolved metal ions in the water. Transformation datacan generally, therefore, only be considered as reliable for the purposes of classification if conductedaccording <strong>to</strong> the st<strong>and</strong>ard pro<strong>to</strong>col in Appendix 19G.This pro<strong>to</strong>col aims at st<strong>and</strong>ardising the principal variables such that the level of dissolved ion can be directlyrelated <strong>to</strong> the loading of the substance added. It is this loading level that yields the level of metal ionequivalent <strong>to</strong> the available L(E)C50 that can then be used <strong>to</strong> determine the hazard category appropriate forclassification. The strategy <strong>to</strong> be adopted in using the data from the testing pro<strong>to</strong>col, <strong>and</strong> the datarequirements needed <strong>to</strong> make that strategy work, will be described.In considering the classification of metals <strong>and</strong> metal compounds, both readily <strong>and</strong> poorly soluble, recognitionhas <strong>to</strong> be paid <strong>to</strong> a number of fac<strong>to</strong>rs. As defined in section 19D.3, the term ‗degradation‘ refers <strong>to</strong> thedecomposition of organic molecules. For inorganic compounds <strong>and</strong> metals, clearly the concept ofdegradability, as it has been considered <strong>and</strong> used for organic substances, has limited or no meaning.Rather, the substance may be transformed by normal environmental processes <strong>to</strong> either increase ordecrease the bioavailability of the <strong>to</strong>xic species. Equally, the log KOW cannot be considered as a measure ofthe potential <strong>to</strong> accumulate. Nevertheless, the concepts that a substance, or a <strong>to</strong>xic metabolite/reactionproduct may not be rapidly lost from the environment <strong>and</strong>/or may bioaccumulate are as applicable <strong>to</strong> metals<strong>and</strong> metal compounds as they are <strong>to</strong> organic substances.Speciation of the soluble form can be affected by pH, water hardness, <strong>and</strong> other variables, <strong>and</strong> may yieldparticular forms of the metal ion that are more or less <strong>to</strong>xic. In addition, metal ions could be made nonavailablefrom the water column by a number of processes (for example, mineralisation <strong>and</strong> partitioning).Sometimes these processes can be sufficiently rapid <strong>to</strong> be analogous <strong>to</strong> degradation in assessing chronicclassification. However, partitioning of the metal ion from the water column <strong>to</strong> other environmental mediadoes not necessarily mean that it is no longer bioavailable, nor does it mean that the metal has been madepermanently unavailable.Information pertaining <strong>to</strong> the extent of the partitioning of a metal ion from the water column, or the extent <strong>to</strong>which a metal has been or can be converted <strong>to</strong> a form that is less <strong>to</strong>xic or non-<strong>to</strong>xic is frequently notavailable over a sufficiently wide range of environmentally relevant conditions, <strong>and</strong> thus, a number ofassumptions will need <strong>to</strong> be made as an aid in classification. These assumptions may be modified ifavailable data show otherwise. In the first instance it should be assumed that the metal ions, once in thewater, are not rapidly partitioned from the water column <strong>and</strong> thus these compounds do not meet the criteria.January 2012 EPA0109

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