Dead in the water: comment on “Development of an aquatic exposure assessment model for imidacloprid in sewage treatment plant discharges arising from use of veterinary medicinal products”

Anthe et al. (Environ Sci Eur 32:147, 2020. https://doi.org/10.1186/s12302-020-00424-4 ) develop a mathematical model to calculate the contribution of veterinary medicinal products (VMPs) to the levels of imidacloprid observed in the UK water monitoring programme. They find that VMPs make only a very small contribution to measured pollution levels, and that the estimated concentrations do not exceed ecotoxicological thresholds. However, shortcomings in methodology—including the implicit assumption that imidacloprid applied to pets is available for release to the environment for 24 h only and failure to incorporate site-specific sewage effluent data relating to measured levels—raise questions about their conclusions. Adjusting for these and other deficiencies, we find that their model appears consistent with the conclusion that emissions from VMPs may greatly exceed ecotoxicological thresholds and contribute substantially to imidacloprid waterway pollution in the UK. However, the model utilises imidacloprid emissions fractions for animals undergoing the different scenarios (for example, bathing) that are extrapolated from unpublished studies that do not clearly resemble the modelled scenarios, with insufficient evidence provided to support their derivation. As a result, we find that the model presented by Anthe et al. provides no reliable conclusions about the contribution of veterinary medicinal products to the levels of imidacloprid in UK waterways.