Chemicals used in modern-day society enter the sewer systems from households and consumer products, from consumer services, industrial discharges, or simply
through urban rain-water. To be able to work for a sustainable water environment with respect to European drinking water abstraction and wastewater treatment, it
is necessary to have a sustainable use of chemical substances within the urban water cycle.

As Wastewater Treatment Plants (WWTP) cannot treat all kinds of discharges, restrictions on waste water discharge have to be backed by additional E uropean restrictions on market authorisation. Often, it is not possible to treat non-biodegradable chemical substances coming to WWTP from cities. These substances may destroy the important nitrogen removal process and decrease sludge quality, thereby reducing the possibility of recycling valuable phosphorous for agricultural land.

Drinking water operators have similar concerns. Non-biodegradable chemical substances in water catchment areas will also reduce the quality of E uropean drinking water sources. Drinking water catchment areas must be protected against contamination by (hazardous) substances whose removal would require additional purification treatment (see article 7 of Water Framework D irective (WFD)). Taking into account water and sludge quality requirements in the EU, operators of WWTP may in the future be placed in a difficult position, as they can hardly control the quality of incoming urban waste water (in particular, the priority hazardous substances) whilst having to meet requirements for sludge and discharge into the aquatic environment.

REACH is important for water operators as it creates the possibility if having a better product control strategy. For the water industry, there is need for a strong implementation of REACH in order to:

• have well-functioning treatment processes in E uropean
  WWTP
• obtain a quality of the influents to WWTP and effluents from
  stormwater, making it possible to fulfil the requirements of
the Water Framework D irective of Priority Substances (EQS)
in the receiving waters and the to aquatic environment
• minimise the energy use of the treatment processes
• improve the quality of sludge to increase its use as an
  agriculture fertiliser and soil conditioner.

There is a clear need to have improved E uropean control of chemical substances at source, both for sustainable waste water treatment and for sustainable drinking water production. This can be achieved through an "upstream approach".

With the present weak proposal of the WFD on Priority Substances, REACH turns out to be water and wastewater operators' most important instrument to control chemicals at the source. Without a strong, implemented REACH, it is unlikely that water operators will see less hazardous chemicals discharged from the urban water catchment area into wastewater treatment plants. A European Union without the possibility to better control chemicals at source will make it difficult for many water and wastewater operators to fulfil relevant Directives such as the EQS in WFD, the Drinking Water Directive and a future Sludge Directive.

The upstream approach in practice: Examples of silver, nonylphenols, mercury and triclosan

Silver content in sludge is a very good indicator of the use of silver within the urban water catchment area. The wastewater sector has for many years worked together with photographic laboratories, X- ray clinics and amateur photo developers to reduce the silver discharged into waste water. The recent digital revolution has dramatically decreased silver leakage into the wastewater treatment works. Swedish farmers have underlined that not all impacts of silver on the microbiological soil activity are known, and they therefore put high pressure on the wastewater sector to decrease silver in sludge. Over the years, silver emissions have decreased, however, today there is again an emerging pressure to use silver in several products.

In the last five years, products emitting silver into wastewater have again become more common on the market. Examples include washing machines that use silver ions as bactericide, the use of silver as a bactericide in swimming pools, and in sports clothing and apparel. If all these products enter the market through these products, it will be difficult to maintain the necessary trend of reducing silver in wastewater and sludge.

After a one-year debate in Norway and Sweden on the environmental disadvantages of selling and using household washing machines that emit silver into the wastewater, it seems that retailers have started to withdraw the silver-emitting washing machines from the market.

Nonylphenolethoxylate easily breaks down in the environment into nonylphenol. Nonylphenol is difficult to break down, and it bio-accumulates in the environment. It is highly toxic to aquatic organisms and can cause adverse long-term effects in the aquatic environment. Nonylphenol also has oestrogen effects, causing, among other things, the feminisation of male fish.

Nonylphenol is included in the WFD (Directive 2000/60/EC) list of substances and substance groups that must be prioritised in work to achieve good surface water status. Nonylphenolethoxylates and nonylphenols have, until the EU-restrictions in 2005, been used in plastics and paints, as tensides in cleaning agents, in cutting and drilling fluids, and used in glues and emulsifiers. They are still used outside the EU, and nonylphenols can therefore easily be detected in many articles imported to the EU.

Despite the 2005 restrictions, there are still too many nonylphenols in urban wastewater. The main source in Swedish wastewaters, sludges and in the receiving waters is now estimated to be nonylphenols from imported clothes. I n several investigations, nonylphenols are found in high concentrations in many different textiles such as children clothes, towels, and clothes imported to the Sweden. Nonylphenol was identified as being of primary concern in Sweden with regards to the Water Framework Directive. Nonylphenol is probably the most widespread of all priority substances, and it is likely that this is the case all over Europe.

There is now an acute need for pressure on European textile suppliers to phase out and control the use of Nonylphenols among their suppliers.

Mercury is one of the most hazardous environmental toxins and is a threat to human health and the environment. Mercury cannot be broken down but accumulates in soil, water and living organisms. The more mercury that is supplied to society, the higher its levels in the environment. I t is therefore of great importance that the use and release of mercury should be eliminated, particularly in dental care.

The mercury used in dental amalgams is currently an important source of pollution in E urope. Mercury can enter the water industry's sewage systems as a diffuse pollutant. Studies have indicated that the use of amalgam has been identified as the single largest source of mercury in sewage sludge, and crematoria are a large source of emissions to air in the UK. The discharge of dental amalgam to sewers should be regulated to ensure that in the long-term such diffuse sources be eliminated as a source of mercury to the aquatic environment.

Today in Sweden, only 2-5 % of new dental fillings are of amalgam. As a consequence, the mercury in the wastewater has started to decrease. The judgement of the N ational Board of Health and Welfare is that there is no justification for using amalgam in the case of children and young people. For adults there may be situations where for special medical reasons, the use of amalgam on patients in hospitals is the only option.

Ceasing the use of using amalgam in European dental care would have a large effect on mercury in the European waters.

Triclosan is a widely used biocide. It is included in many contemporary consumer and professional health-care products, particularly oral and dermal products, but also in household items including plastics, textiles and food packaging materials. Concerns have been raised regarding the widespread use of triclosan, both as regards the potential for selection of resistant bacterial strains that may confer cross-resistance to other antimicrobial agents, and as regards the potential harm to the environment. Triclosan is classified as "very toxic to aquatic organisms" and "may cause long-term adverse effects to the environment" by the European Commission.

The conclusions by the Norwegian Scientific Committee for Food Safety are: "Widespread use of triclosan, including use in cosmetic products, selects for development of triclosan resistance. Since this may contribute to the development and spread of concomitant resistance to clinically important antimicrobial agents, such use represents a public health risk. Therefore, the use of triclosan should be restricted. The current regulation of use of triclosan in cosmetic products is, from a toxicological point of view, a matter of concern and it is recommended that human exposure to triclosan be reduced. Moreover, triclosan is classified as an agent that may cause adverse environmental effects and hence the use should be restricted also from an ecotoxicological standpoint."

Many European water companies are working to inform consumers and retailers about avoiding use of articles containing triclosan.

Next step - The need for a strong candidate list and strict authorisation process

EUREAU welcomes REACH as an excellent opportunity for the EU to further sustainability. Indeed, we need a strong managed REACH to facilitate the sustainable provision of the essential services we offer to several hundred million European citizens. REACH is important for European water and wastewater operators, as it presents the potential to have a better product control strategy for chemicals, through better information, safer use and stricter authorisations and restrictions for chemicals in products. This potential, however, requires clear provisions that facilitate a stricter authorisation process which will benefit down stream users as well as consumers.

The authorisation process under REACH for the use of the most hazardous chemicals should only be granted if no safer alternatives are available, and where socio-economic advantages outweigh the risk. This report is indeed an important step to show the way forward. A strong REACH will be of great importance for the sustainability of our businesses and also much better in line with the objectives of article 174 of the EC Treaty; the principles of preventive action, the principle that environmental damage should as a priority be rectified at source, and that the polluters should pay.

EUREAU is the voice of Europe's drinking water and waste water operators. The members of EUREAU collectively provide vital water and waste water services to more than 400 million European citizens. We are committed to sustainability in all aspects of our business operations and particularly in the provision of drinking water and waste water services.