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Position paper - An appropriate regulatory approach to protect ground- and drinking water from contamination of chemicals
The American Chamber of Commerce to the EU (AmCham EU) strongly supports the responsible care and protection of the ground and drinking water from chemical contamination. There is however concern around the current proposal regarding two new categories: (1) Persistent, Mobile and Toxic (PMT), and (2) very Persistent, very Mobile (vPvM) and how it could be used for regulatory purposes, since these criteria are not defined under REACH. Prior to any regulatory use of the PMT/vPvM criteria, be it for REACH registration or risk management measures, an objective scientific and political discussion is required.
Now is the time to have an in-depth and open discussion on the PMT/vPvM concept in order to make it a functional instrument for the protection of ground- and drinking water. Of critical and far-ranging importance is how to assess ‘Equivalent Level of Concern’ for the environment.
For more information or questions, please contact Florian Gleissner (email@example.com).