4 ms·
There are two things to note here. 1. I believe the initial change from 12 to 131 ng/kg was science-based. Based on the literature and science process 12 ng/k
by fishguy23 3y ago
There are two things to note here.
1. I believe the initial change from 12 to 131 ng/kg was science-based. Based on the literature and science process 12 ng/kg was the wrong number.
2. This change won't matter. The amount of chemical required per use leads to concentrations that are 10-100 times the new limit.
SEPA rules require a prediction showing that the average concentration within the predicted deposition area is less then the limit. Regardless of the increased limit it will not be possible.
- theptip 3y agoWhat literature? The article just says this is based on a private report that the regulator didn’t even see. Is there published science that backs up your assertions? Would love more information either way.
- fishguy23 3y agoThis reviews the details of the changes over time and has further links. https://www.gov.scot/binaries/content/documents/govscot/publications/consultation-paper/2023/04/new-environmental-quality-standard-eqs-emamectin-benzoate-embz-consultation-implementation-timescales/documents/new-environmental-quality-standard-eqs-emamectin-benzoate-embz-consultation-implementation-timescales/new-environmental-quality-standard-eqs-emamectin-benzoate-embz-consultation-implementation-timescales/govscot%3Adocument/new-environmental-quality-standard-eqs-emamectin-benzoate-embz-consultation-implementation-timescales.pdf https://www.gov.scot/binaries/content/documents/govscot/publ... At either limit, the levels added to the environment from a single treatment of a farm will cause deposition higher than the limits. I have linked the SEPA regulations for aquaculture and a report for the modelling program (NewDEPOmod) used. On page 32 on the second link there are plots showing the observed and modelled concentrations, both of which are above the allowed limits. https://www.sepa.org.uk/regulations/water/aquaculture/ https://www.sepa.org.uk/regulations/water/aquaculture/ https://www.sams.ac.uk/t4-media/sams/pdf/publications/REFINING-SEA-BED-PROCESS-MODELS-FOR-AQUACULTURE-Final-Report-for-web.pdf https://www.sams.ac.uk/t4-media/sams/pdf/publications/REFINI...