Note from the ANSES Recast of Directive 98/83/EC Consumer waters

ANSES recently published a note on a request for scientific and technical support for the recast of Directive 98/83/EC, as amended, concerning the quality of water intended for human consumption. The collective expertise was carried out by the Emergency collective expert assessment group (GECU) “Redrafting of the EDCH Directive”.
The European Commission (EC) published on 1 February 2018 a proposal to recast this Directive 98/83/EC. This new text should be adopted at the end of 2018.
The draft revision shall include in particular an updating of the list of parameters to be analysed and the associated parametric values in the light of the most recent scientific evidence.

Below are some remarks made by the GECU concerning this update:
•The GECU approved the introduction of bacteriophages in the draft Directive with a parametric value of 0 UFP/100 mL.
•The GECU supports the introduction of the parameter Legionella and recommends to carry out simultaneously the analysis of L. spp and L. pneumophila and to clarify the proposed thresholds.
•In the case of E. coliform and enterococcal bacteria, the GECU proposes to replace the value of “0 in 100 mL” by expressing the result as “not detected in 100 mL” and to specify the methods to be used for analysis in raw water.
•The GECU recommends adding intestinal enterococci to the list of “fundamental” parameters in the same way as E. coli with regard to their resistance to disinfection treatments and to retain coliform bacteria as an indicator of treatment effectiveness.
•The GECU recommends not including Clostridium perfringens spores in the “fundamental” parameters, so that their research can be adapted according to risk analysis.
•The GECU recommends maintaining the parameter Pseudomonas aeruginosa in Annex I of the draft Directive as it is a potentially pathogenic bacterium and an indicator of good maintenance of the bottling chain.
•The GECU considers that the search for Cryptosporidium oocysts and Giardia cysts would be relevant in raw water (surface water and groundwater influenced by surface water) in the context of applications for authorisation to use water to produce an EDCH.
•The GECU proposes to set a limit value of 1 NFU for turbidity at the point of distribution of the EDCH and to set a value of 2 NFU at the consumer tap in order to take into account the possible degradation of water quality in the public and private network (corrosion problems in particular).
•The GECU supports the inclusion of chlorates, chlorites, haloacetic acids and Uranium in the draft recast of the Directive.
•The GECU notes that the proposed values for the sum of PFAS and individual molecules are not based on health considerations. In view of the large number of molecules constituting the chemical family of per and polyfluorinated alkyl, he stressed the need to define a list of compounds to be searched (with their CAS numbers) and to associate individual values with them.
•The GECU stresses the importance of the issue of exposure to endocrine disrupters and is aware of the strong concerns expressed about the potential health impact of these compounds.
With regard to the 3 molecules proposed, the GECU stresses in particular the very strong analytical constraints, the risks of contamination of samples during sampling and analysis, the low contribution of drinking water to total dietary exposure for BPA and nonylphenol and the proposed parametric values which are significantly lower than the existing reference health values.
Therefore, the GECU considers that the inclusion of these 3 substances in Annex I of the Directive is not relevant.
•The GECU recommends to propose a parametric value for all quantifiable microcystins and to specify that it is the sum of intra and extracellular microcystins.
•In view of the toxicity of chromium VI, the GECU is in favour of lowering the parametric value of chromium in EDCH, but considers that the proposed value should be of the order of 6 µg/L for chromium VI.

You will find attached the complete note of the ANSES: https://www.anses.fr/fr/system/files/EAUX2018SA0027.pdf

Please be aware that our laboratory is following this draft directive very closely in order to be able to meet future regulations.

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