Aquatic thresholds for ionisable substances, such as diclofenac, should consider pH-specific differences in uptake...

Diclofenac, a widely used nonsteroidal anti-inflammatory drug (NSAID), enters the aquatic environment worldwide. The effect values available for the derivation of an environmental quality standard (EQS) are markedly heterogeneous, even within the same species. This heterogeneity could partially be attributed to inter-laboratory variation, but is also observed in repeated tests within the same facility. Diclofenac is ionisable; its speciation and potential for uptake and thus toxicity is influenced by pH. A high correlation has previously been observed between effects in zebrafish embryos and the pH-specific partitioning coefficient logD for diclofenac. We hypothesized that the observed heterogeneity could also be attributed to differences in study pH. To test this hypothesis, we reviewed physicochemical data and selected ecotoxicity data that were considered to be reliable and relevant in the latest EU EQS Dossier for which a study pH was reported for further analysis and EQS derivation. We adjusted the reported effect concentrations for differences in uptake using the delta logD value for the worst case pH value of 6.5. pH adjustment of effect values resulted in decreased heterogeneity of the acute effect data and a better fit of the chronic species sensitivity distribution. Both, the MAC-EQS and the AA-EQS were derived using the deterministic approach as data requirements for deriving EQS based on the SSD were not fulfilled. Many studies had to be discarded because test pH was not reported or exposure concentrations had not been analytically verified. Physico-chemical data had to be discarded due to non-relevant experimental conditions or missing information. We strongly encourage scientists publishing ecotoxicity data for ionisable substances to report the test pH together with the effect values and encourage measurement of physico-chemical parameters at environmentally relevant conditions. We recommend to consider adjusting the effect data for ionisable substances according to a worst-case pH in future hazard assessments.