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EFFECTS ASSESSMENT<br />

biodegradability tests (Annex V C.4C,F,E,B; OECD 301B,C,D,E, 1992f). No-effect or EC0<br />

values were 1.5 to 10 times lower than the corresponding EC50 values. The authors recommend<br />

as a provisional rule that biodegradation testing should there<strong>for</strong>e be conducted at one-tenth of the<br />

EC50 concentration to ensure that a “probable non-inhibitory level” is employed in<br />

biodegradation testing. It would, there<strong>for</strong>e, seem appropriate to consider the test concentration<br />

from a positive ready biodegradability test to be an acceptable alternative to a NOEC obtained<br />

from a microbial toxicity test <strong>for</strong> the purposes of determining a PNECmicroorganisms. This is<br />

particularly the case if domestic sludge is used as the source of microorganisms <strong>and</strong> if there is no<br />

indication of toxicity <strong>for</strong> the test concentration, e.g. due to other available test results. Similarly,<br />

data from inherent biodegradability testing may also prove useful. However, some additional<br />

issues have to be considered:<br />

Only Ready Biodegradability Tests (RBT) relying on continuous monitoring, i.e. the MITI I test<br />

(EU Annex V C.4F; OECD 301C, 1992f) <strong>and</strong> the Manometric Respirometry test (EU Annex V<br />

C.4D; OECD 301F, 1992f), are considered reliable <strong>for</strong> observing the effects of a chemical on the<br />

inoculum, i.e. activated sludge diluted by factors ranging from ca. 100 to 1000. In parallel to the<br />

test itself, a toxicity control is run in extra bottles containing both the test chemical <strong>and</strong> a<br />

reference chemical that is easily degraded in the system. If <strong>for</strong> that purpose sodium acetate is<br />

used, the toxic effect is most often manifest as a delayed mineralisation of the substance.<br />

However, even if the vast majority of microorganisms are initially killed in the test system, such<br />

a delay may only be in the order of a few hours or days be<strong>for</strong>e rapid mineralisation of sodium<br />

acetate takes place. If measurements are carried out only weekly, which is the case in most<br />

RBT's, a delay in mineralisation of sodium acetate of only a few days may not be detected,<br />

leading erroneously to the conclusion that the test chemical is not inhibitory. Sodium benzoate<br />

may provide an acceptable alternative to sodium acetate when an inhibitory control test (i.e. the<br />

official term, not 'toxicity test') is per<strong>for</strong>med with an RBT method that is not based on<br />

continuous monitoring, because mineralisation of benzoate occurs at a much slower rate.<br />

Subject to expert judgement, consideration of data from biodegradation/removal studies using<br />

the laboratory/pilot scale Activated Sludge Simulation, Continuous Activated Sludge or Aerobic<br />

Sewage Treatment Coupled-Units tests (OECD 303A, 2001b; ISO-11733) may also prove useful<br />

in any consideration of PNECmicroorganisms. These tests are laboratory scale models <strong>for</strong> simulation<br />

of activated sludge, representing realistic approximation to actual conditions within full scale<br />

STPs. A NOEC from well-conducted simulation studies using domestic activated sludge would<br />

correspond to the concentration of the chemical substance that does not perturb the proper<br />

functioning of the Continuous Activated Sludge unit with regard to per<strong>for</strong>mance parameters such<br />

as:<br />

• test substance elimination;<br />

• COD removal;<br />

• nitrification;<br />

• denitrification;<br />

• phosphorus removal;<br />

• effluent quality etc.<br />

when compared to a parallel non-dosed control.<br />

Additionally, the results from tests with ciliated protozoa can be used <strong>for</strong> deriving a<br />

PNECmicroorganisms. In this case protozoa have to be regarded as additional species, not as an<br />

additional trophic layer. Ciliated protozoa, constituting the most important class of protozoa in<br />

STPs, are, except <strong>for</strong> certain industrial plants, important <strong>for</strong> their functioning. The toxicity data<br />

107

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