SCREENING OF THE EUROPEAN UNION NEW CHEMICALS DATABASE CONCERNING AN AQUATIC EXPOSURE THRESHOLD OF NO CONCERN

摘要

With interest I read the paper "Mode of action and aquatic exposure thresholds of no concern" by de Wolf et al. published in Environmental Toxicology and Chemistry [1]. That paper presented a study to address environmental thresholds of no toxicological concern for freshwater systems (ETNC_(aq)), an exposure threshold value for chemicals below which no significant risk is to be expected. Environmental toxicological databases were analyzed, and lowest numbers and 95th-per-centile values for organic chemicals were derived based on mode of action (MOA). This resulted in an ETNC_(aq-MODL-3) of approximately 0.1 μg/L. The de Wolf et al. paper referred to a personal communication concerning an analysis of the European Union (EU) New Chemicals Database (NCD): "Sokull-Kluettgen and Vollmer reported that based on their analysis, which did not make a distinction between MOAs, no evidence suggests that an ETNC_(aq-MODL-3) of 0.1 μg/L is an unacceptable value." I feel that this statement misinterprets the communication between de Wolf et al. and Vollmer and Sokull-Kluettgen on behalf of the European Chemicals Bureau (ECB). At the request of the European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC), I analyzed the EU NCD. The results were sent by letter (IHCP/I03.00/GV/bsk/ D[2003]18062 dated 25th August 2003) with the following statement: "The above figures show that there is a reasonable number of notified new substances, which are acute[ly] toxic to aquatic organisms using an ETNC of 0.1 μg/l and an assessment factor of 1,000." This Letter to the Editor presents the data analysis of the NCD in an effort to avoid further misinterpretation and to provide background information not available in the paper by de Wolf et al. [1].