Review of the EC Bathing Water Directive

Dr Lorna Fewtrell

Centre for Research into Environment and Health

In December 2016, the World Health Organization (WHO) initiated an agreement with the European Commission to provide technical advice for the revision of Annex I of the European Bathing Water Directive (BWD) – Directive 2006/7/EC.

In May, I was employed to conduct a literature review of the recent recreational water publications.

Ultimate output will be a series of four factsheets, which will include WHO advice on aspects for consideration in the BWD review.

Background

WHO involvement

WHO Water Quality & Health Technical Advisory Group

Ingrid Chorus (Germany)

Jutta Fastner (Germany)

Marta Vargha (Hungary)

Teresa Lettieri (Italy)

Ciska Schets (Netherlands)

Rosario Coelho (Portugal)

Rosina Girones (Spain)

David Kay (UK)

Calum McPhail (UK)

David Cunliffe (Australia)

Nick Ashbolt (Canada)

Neil Chernoff (USA)

Tim Wade (USA)

Swimming in sewage?Dr Lorna FewtrellCentre for Research into Environment and Health

Not so long ago …

Parameters (current and potential)

E. coli

Enterococci

AdV

Bacteriophage

Current parameters Viral indicator HAB parameters

Current situation (all)

Occurrence (viral and HABs)

Epidemiological data (all)

Water quality analysis (all)

Bathing water profile (Enterococci, E. coli & HABs)

Prediction and discounting (Enterococci & E. coli)

Classification (all)

Discussion/Aspects for consideration for BWD revision (all)

Fact sheet content

Current situation (enterococci & E. coli)

0

100

200

300

400

500

600

700

800

900

1000

WHO* USEPA HC** EU WHO* USEPA EU HC**

cfu

/10

0m

l

Organization

ENT

E. coli

Marine waters Fresh waters

WHO Guideline

No viral indicators in any of the major recreational water regulations Although USEPA is in the process of developing a recreational

water quality criteria for coliphage

HABs (cyanobacteria and marine phytoplankton) are not currently assessed as part of BWD assessment and classification – but it is a requirement to consider them as part of the bathing water profile and when health risks are identified: “adequate management measures shall be taken”

Current situation(viral & HABs)

Current situation(HABs)

Parameters

Diff. action

levels

MS TP CB cell

count

CB BV Cyano-Chl-

a

Chl-a* Visual Scums or

foam

Transp Toxin determination

CZ √ √ √

DE √ √ √ √ √ √ √ √ (for de-warning) √

DK √ √ √ √ +/- √

FI √ √ √ √

FR √ √ √ √ √

HU √ √ √ √

IT √ √ √ √ √ √ √

NL √ √ √ √ √

SO √ √ √ √

Cyanobacterial-related parameters used in European legislation

Do find enteric viruses and coliphages in European waters (when we look)

Have recreational water outbreaks of viral illness

Of the enteric viruses adenovirus is found most frequently and, often, in the highest concentrations

Not much published data on European coliphage occurrence and concentration, globally somatic coliphage predominate and are present in greater numbers than F-specific coliphages

Occurrence (viral)

Examples of freshwater cyanobacterial blooms in Europe, with detection of cyanotoxins including microcystin, nodularin, cylindrospermopsin, anatoxinand saxitoxin

Marine blooms of Ostreopsis ovata (dinoflagellate) and cyanobacteria (including Nodularin spumigena; Aphanizomenon flos-aquae)

Occurrence (HABs)

Pre 2009 – Europe (Epibathe) Enterococci best predictor of illness in marine waters; E. coli may be a better index of GI symptoms in fresh water

(but results not statistically significant); Resulted in no change to WHO Guidelines.Since 2009 Mostly USA; Mostly marine non-point source beaches; Mostly no relationship between any water quality indicator

and health, unless point sources identified – then enterococci generally the best parameter.

Epidemiology (enterococci & E. coli)

Few epi studies have looked for, or found, a relationship between health outcomes and enteric viruses. A small-scale freshwater study in the States did suggest a relationship for adenovirus but only when E. coli was also included in the model

Epidemiology (viral)

A number of epi studies have considered F-specific and somatic coliphages, the evidence from these was described by the USEPA as “suggestive of a potential relationship between coliphages and human health”

Coliphages are often present in environmental waters at very low levels

Overall, the studies lack consistency and do not provide a clear exposure-response relationship

Epidemiology (viral)

Study by Pilotto et al. (1997) was used to inform the WHO Guidelines (2003)

Other, more recent, freshwater epidemiological studies (often small-scale) have struggled to show a relationship between health outcomes and cyanobacterial exposure

Stewart et al. (2006) did show increased respiratory symptoms in recreators using water with >12 mm2/ml cyanobacteria versus < 2.4 mm2/ml

Epidemiology(fresh water HABs)

Epidemiology(HABs)

Rather difficult to do:

Ethical issues (toxins)

Temporal challenges (blooms change rapidly)

Recreator behaviour (people, for the most part, avoid blooms and scum)

An exception: to prove the rule?

ISO methods in the BWD (membrane filtration and most probable number method for both)

Enterococci: ISO 7899-1 and 7899-2

E. coli: ISO 9308-1 and 9308-3

Undated – thus mandatory to use the current edition

ISO 9308-1 updated in 2014 but, for most part, not suitable for bathing waters – so no acceptable membrane filtration method for E. coli

Water quality analysis (enterococci & E. coli)

Development of rapid molecular methods Use of qPCR (quantitative polymerase chain reaction) method

for enterococci in USA regulations (Method 1611)

All epidemiological data supporting use of Method 1611 done in the USA (using prospective cohort studies)

Much more expensive than culture

Very variable recoveries seen

Enumerates non-viable and dead cells

What’s the hurry? Not applicable for the current BWD classification system

Water quality analysis (enterococci & E. coli)

No standard procedure, use of parameters or specific concentrations across Europe

Measurements include cyanobacterial cell counts, cyanobacterial biovolume, Cyano-chlorophyll-a, Chlorophyll a, total phosphorus, toxin (usually microcystin) levels

Also most countries use a visual inspection component (secchi depth, presence of scums or foams)

Water quality analysis (HABs)

USA has suggested draft toxin concentrations for recreational water:

Microcystins (4 µg/l)

Cylindrospermopsin (8 µg/l)

WHO currently working on toxin level guidance (microcystins, cylindrospermopsin and saxitoxin)

USEPA and WHO toxin levels based on toxicology (not epidemiology)

Water quality analysis (HABs)

Some States in the USA promote toxin-based monitoring, in order to “communicate … actual risks, as opposed to potential risk represented by cell count data alone” thus reducing the risk of “advisory fatigue”

But, toxin measurement is not straightforward (or cheap) and there are also temporal and spatial issues within a bloom to address

Water quality analysis (HABs)

Classification(enterococci & E. coli)

80

81

82

83

84

85

86

87

88

89

90

2013 2014 2015 2016

% a

chie

vin

g e

xce

llen

t (o

r gu

ide

line

)

Year

Classification(enterococci & E. coli)

Water type Classification

Excellent Good Sufficient Poor

Coastal & transitional 87 8 2.3 1.3

Fresh 82 9.5 2.8 1.6

2016 bathing water classification – by water type

Classification (HABs)

One size fits all/the ideal parameter?

In the same way as one size never fits all, there is no such thing as the ‘ideal’ parameter

Aspects for consideration in the BWD review

DISCLAIMERThe views expressed in the following slides are currently just my opinion and do not represent

any official policy or position.

BWD stated purpose is “to preserve, protect and improve the quality of the environment and to protect human health” (Article 1)

WHO remit is human health

What is the best way to protect human health?

A long term classification (i.e. the current system)?

Information on which to base day-to-day decisions (e.g. guidance on unacceptably high concentrations)?

Aspects for consideration(general points)

BWD is the only major set of regulations that:

Has a water quality value for E. coli in marine waters

Requires the measurement of enterococci and E. coli at each site

Sample numbers (classification can be based on 16 samples) – likely to lead to problems of misclassification

Aspects for consideration(enterococci & E. coli)

Change is good; no change is better?

Long history of use and much useful historical data

Modification, “barely five years after their implementation, would undermine the continuity of the evaluation, the credibility of the displayed rankings and the monitoring of the quantitative evolution of the beaches” (France – questionnaire response)

Aspects for consideration(enterococci & E. coli)

It is unlikely that a viral parameter will be recommended for inclusion in the BWD

Aspects for consideration(viral)

Currently not a formal part of the classification

Member States ‘left to their own devices’

Potentially different levels of protection across Member States

Good quality water (from a faecal pollution point of view) may be prone to closures due to HABs

A role for public education

Aspects for consideration(HABs)

Aspects for consideration(HABs)

If you can’t see your feet – don’t go in!

Meeting with EC stakeholders later this week in Brussels

Meeting with WHO expert group (Jan 2018)

Fact sheet finalization by June 2018 (aiming for March 2018)

Work in progress