Considerations of temperature in the context of the persistence classification in the EU

Simulation degradation studies for industrial chemicals, biocidal products and plant protection products are required in the EU to estimate half-lives in soil, water and sediment for the comparison to persistence criteria for hazard (P/vP) assessment, and for use in exposure assessments. There is a discrepancy between European regulatory approaches regarding the temperature at which degradation half-lives should be (1) measured in simulation degradation testing of environmental compartments, and (2) compared to the P/vP criteria. In this paper, an opinion is provided on the options for the experimental temperature and extrapolation to other conditions. A review of the historical development of persistence criteria did not give conclusive evidence of the temperature at which the half-lives that underpin the P-criteria were measured, but room temperature is likely. Half-lives measured at 20 °C are in line with the intentions of some international agreements, but in the EU there is a continued political debate regarding the relevant temperature for comparison with persistence criteria. Measuring degradation at 20 °C has the advantage that metabolites/transformation products can be identified with greater accuracy, and that kinetic fits to determine half-lives for parent compounds and metabolites carry less uncertainty. Extrapolation of half-lives to lower temperatures is possible for assessing environmental exposure, but the uncertainty of the persistence classification is smaller when measured half-lives are used for direct comparison with P/vP criteria, without extrapolation. Model simulations demonstrate the pattern of concentrations that can be expected for realistic worst case climate scenarios in the EU based on the half-life of 120 days in soil at 20 °C and of 40 days in water at 20 °C, and their temporal and spatial variability.