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Environmental Science and PollutionResearch ISSN 0944-1344 Environ Sci Pollut ResDOI 10.1007/s11356-014-3283-z

The link between descriptors 8 and 9 ofthe Marine Strategy Framework Directive:lessons learnt in Spain

J. Gago, L. Viñas, V. Besada & J. Bellas

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SHORT RESEARCH AND DISCUSSION ARTICLE

The link between descriptors 8 and 9 of the Marine StrategyFramework Directive: lessons learnt in Spain

J. Gago & L. Viñas & V. Besada & J. Bellas

Received: 8 November 2013 /Accepted: 3 July 2014# Springer-Verlag Berlin Heidelberg 2014

Abstract The aim of this note is to discuss the relevance ofthe interaction/integration of monitoring of contaminants forthe protection of the marine environment and for humanhealth safety (descriptors 8 and 9, respectively) within theMarine Strategy Framework Directive (MSFD). The identifi-cation of possible relations between contaminant levels insediments and tissues of fish and other seafood, as well asthe association of those levels to pollution sources, are majorchallenges for marine researchers. The Spanish initial assess-ment in the North-East Atlantic marine region was used as anexample to show some gaps and loopholes when dealing withthe relationship between descriptors 8 and 9. The main prob-lem to deal with is that monitoring programmes intended forthe assessment of marine environmental quality and for hu-man health safety usually apply different approaches andmethodologies, and even different tissues are analysed insome species (mainly fish). It is therefore recommended tomake a profound revision of current sampling strategies,procedures and methodologies, including the selection oftarget species and tissues and to improve the traceability ofsamples of fish and other seafood for human consumption. Onthe other hand, despite the scope of descriptor 9 which islimited to commercially relevant species, this fact should notbe an obstacle in the application of the ‘ecosystem approach’within the MSFD. In order to appropriately solve these short-comings, an information exchange system between authoritiesdealing with descriptors 8 and 9 should be strongly encour-aged for the next steps of the MSFD’s implementation.

Keywords MSFD .Marine environment . Contaminants .

Contaminants in fish/seafood .Monitoring . North-EastAtlantic

Introduction

European seas are affected by intense human activities, whichconstitute sources of chemical contamination and may causeserious impacts or risks to coastal andmarine zones that lead toenvironmental degradation (EEA 2003). In particular, coastalareas are expected to face even greater pressures mainly due tointense industrial activity, intensive agriculture and high pop-ulation density. Contaminants can adversely impact organisms,populations, communities and ecosystems (Kennish 1992;Walker et al. 2001), so preventing and reducing their inputsin the marine environment are urgently needed.

The European Directive 2008/56/EC (Marine Strategy Frame-work Directive,1 MSFD) establishes that European Union mem-ber states shall adopt, in a coordinated manner, the necessarymechanisms for managing the marine waters under their jurisdic-tion. The MSFD is an integrated policy which aims to protect,preserve and prevent the degradation of the marine environment.

The MSFD establishes 11 descriptors to assess the status ofthe marine environment. These descriptors are very diverse,although closely linked to each other, covering all aspects ofmarine environmental conservation and protection, includingissues from biodiversity to marine noise. The relevant criteriaand indicators applicable to those descriptors are defined inthe Commission Decision 2010/477/EU.2 Some descriptors

1 European Commission (EC), Directive 2008/56/EC of the EuropeanParliament and of the Council of 17 June 2008 establishing a frameworkfor community action in the field of marine environmental policy.2 European Commission (EC), Commission Decision 2010/477 of 1September 2010 on criteria and methodological standards on good envi-ronmental status of marine waters.

Responsible editor: Philippe Garrigues

J. Gago (*) : L. Viñas :V. Besada : J. BellasInstituto Español de Oceanografía (IEO), Subida a Radio Faro,50-52, Vigo 36390, Spaine-mail: jesus.gago@vi.ieo.es

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are related to the general status of the environment (‘state-based’descriptors), whilst others deal with specific pressures and im-pacts (‘pressure-based’ descriptors). The descriptors relating tocontaminants and their formulation according to the MSFD aredescriptor 8 (‘Concentration of contaminants are at levels notgiving rise to pollution effects’) and descriptor 9 (‘Contaminantsin fish and other seafood for human consumption do not exceedlevels established by Community legislation’).

The MSFD requires that the European Union memberstates should establish ecological monitoring programmes by2014, covering all their marine waters and develop strategiesin order to achieve or maintain the good environmental status(GES) of their jurisdictional waters in respect of the 11 de-scriptors by 2020.

Many challenges are emerging due to the implementationof the MSFD (see, e.g. Borja et al. 2010; Frazão Santos et al.2012), and several papers have been recently published(Zampouckas et al. 2013; Bertram and Rehdanz 2013). How-ever, the relevance of the link between descriptors 8 and 9 ofthe MSFD has not been discussed in detail in the literature, atleast we know.

In this work, we discuss the importance of cooperationbetween the communities of scientists, policy-makers, envi-ronmental managers or stakeholders dealing with descriptors8 and 9 of the MSFD.We show, as a practical example on thistopic, the implementation of the MSFD in the North-EastAtlantic Ocean marine region, corresponding to the Spanishjurisdiction, specifically the Iberian coast sub-region.

MSFD descriptors dealing with contaminants (8 and 9)

The reduction of chemical contaminant concentrations in themarine environment is considered in the MSFD context toachieve clean, safe, healthy, biologically diverse and produc-tive seas. All environmentally relevant contaminant types andpollution effects in the marine environment need to be con-sidered. Contaminants are defined as ‘substances (i.e. chemi-cal elements and compounds) or groups of substances that aretoxic, persistent and liable to bioaccumulate and other sub-stances or groups of substances which give rise to an equiv-alent level of concern’. This definition is in line with thedefinition of hazardous substances used in the Water Frame-work Directive (WFD).3

Descriptor 8: contaminants in the marine environment

The essence of descriptor 8, as formulated in Annex I of theMSFD (‘Concentrations of contaminants are at levels not

giving rise to pollution effects’), is to gradually reduce marinepollution by achieving decreasing trends of marine contami-nants and avoiding pollution effects on marine ecosystems(e.g. Law et al. 2010). Therefore, the assessment of the envi-ronmental status to address indicators under descriptor 8 willbe based upon monitoring programmes covering a range ofchemical and biological measurements relating to the effectsof pollutants on marine organisms.

The design of the monitoring programmes should take intoconsideration the measurement and assessment of relevantcontaminants considered in other directives (e.g. WFD) andinternational agreements (such as Regional Sea Conventions)in environmental matrices such as water, sediment and thetissues of biota.

It must be pointed out that the compounds of most concernin the marine environment are generally those that are persis-tent, toxic and bioaccumulative. In addition, compoundswhich undergo long-range atmospheric transport can contam-inate remote marine areas far from pollution sources(Derocher et al. 2003). The scientific knowledge on the use,sources and pathways, fate, distribution or ecotoxicology ofsubstances of concern is crucial for the assessment of theenvironmental status of marine waters. This knowledge isvery different depending on the contaminants considered(see, e.g. Bruland et al. 1991; Cossa et al. 2009), and a greatresearch effort is needed to gather this information.

It is important to mention that exposure to contaminantsand mechanisms of toxicity in marine organisms and inhumans is very different. It is therefore necessary to comparethe sensitivity of species from different trophic levels. In fact,theWFD and the REACH regulation (EC 1907/2006)4 requiredose-response toxicity testing with organisms of at least threetrophic levels in order to carry out the assessment of ecotox-icological effects. For a complete review of bibliography onthe effects of contaminants in the marine environment, see forinstance Newman and Clements (2008) or Landis et al.(2011).

Descriptor 9: contaminants in fish and other seafood

Descriptor 9 considers the presence of contaminants, as de-fined in the Commission Decision (2010/477/EU), “in edibletissues (muscle, liver, roe, flesh, soft parts as appropriate) offish, crustaceans, molluscs and echinoderms, as well as sea-weed, caught or harvested in the wild, the possible presence ofsubstances for which maximum levels are established at Eu-ropean, regional, or national level for products destined tohuman consumption”.

3 European Commission (EC), Directive 2000/60/EC of the EuropeanParliament and of the Council of 23 October 2000 establishing a frame-work for Community action in the field of water policy.

4 Regulation (EC) No 1907/2006 of the European Parliament and of theCouncil of 18 December 2006 concerning the Registration, Evaluation,Authorisation and Restriction of Chemicals (REACH).

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Therefore, the Commission Decision restricts the scope ofdescriptor 9 to the assessment of contaminants in fish andother seafood against standards established by the communitylegislation or by other relevant regional or national regula-tions. Information on the environmental persistence, bioaccu-mulation and toxicity of contaminants is essential to imple-ment standards for contaminants in seafood.

Regarding contaminants for which regulatory levels havebeen set, certain provisions as regards sampling proceduresand method of analysis are laid down in Regulation (EC) Nos.333/2007, 1881/2006 and 1883/2006 and in their amendmentsand modifications. These methods should preferably be usedwhen determining levels of contaminants in fish and seafoodfor human consumption. The task group report on descriptor 9includes a recent and complete review on this matter(Swartenbroux et al. 2010).

The link between descriptors 8 and 9

As mentioned above, it is obvious that there is a close linkbetween descriptors 8 and 9. Chemical pollution may alsoaffect other indicators of the MSFD, namely biodiversity (e.g.indicators on habitat condition), integrity of food webs (e.g.indicators on abundance of key species) and sea floor ecosys-tems (e.g. indicators on the condition of the benthic commu-nity), which are therefore linked to descriptors 8 and 9. Itshould be taken into account that the thresholds for assessingpollution effects in the marine environment are usually lowerthan regulatory levels for human health (see Table 2 in ‘Theexample of metals (Hg, Cd and Pb)’). The criteria and indica-tors established for descriptor 9 share the underlying concernof legislators about impacts on human health rather than onmarine ecosystems. Anyway, the effects on the public healthdue to pollution of the marine environment need to be con-sidered in the MSFD, as described in Art. 1 (paragraph 2.b).

In this section, we discuss some important elements whenintegrating these two related descriptors, specifically regard-ing the monitoring programmes and research needs.

Monitoring programmes

According to the MSFD, monitoring programmes for theongoing assessment of pollution in the marine environmentshould include the measurement of concentrations of contam-inants in relevant environmental matrices (i.e. water, sedimentand biota), as well as the quantification of biological effects ofcontaminants at different levels of biological organisation(descriptor 8). The Directive also demands the control ofcontaminant concentrations in edible tissues of harvested orcollected fish, crustaceans, mollusks, echinoderms and algae(descriptor 9).

Those monitoring programmes are required to be able toassess trends and distribution patterns of contaminants in themarine environment and to evaluate the influence of potentialmeasures aimed to reduce their environmental concentrations.In fact, some EU member states (e.g. Spain) have definedspecific environmental targets intended to pollution reductionlinked concurrently to descriptors 8 and 9, as well as to ensuretraceability of seafood sampled for human health safety pur-poses. The achievement of those environmental targets willalso need to be examined within the MSFD monitoringprogrammes.

Thus, both descriptors are intended to address questionsrelated to the impact of contaminants on the marine environ-ment, and since the MSFD promotes the application of the‘ecosystem approach’, a combined monitoring programme,based on similar approaches, should be considered, takinginto account limitations as the difference in methodologiesused to address descriptors 8 and 9 or the use of commercialspecies only in the case of descriptor 9.

Although there is some shared information between agen-cies responsible for human health and for environmentalprotection in many cases, this exchange is not sufficient andneeds to be improved. In this regard, results from monitoringunder descriptor 8 are to be considered in selecting contami-nants for descriptor 9, and a concurrent development of thesetwo descriptors, considering their close interaction, will im-prove knowledge in several aspects as the transfer of contam-inants through the food web (Kelly et al. 2007) or theirbiodegradation processes (Kang et al. 2006).

Implementing a coordinated monitoring programme fordescriptors 8 and 9 that serves to assess the status of themarine environment would require a profound revision ofcurrent sampling strategies, procedures and methodologies,including the selection of target species and tissues, size,sex, sampling season and, above all, improving the traceabil-ity of samples of fish and other seafood for human consump-tion (see, e.g. Law et al. 2010), which at this moment hindersthe use of those samples for MSFD purposes. The logisticalviability of these adaptations is a major factor to take intoaccount for an efficient and cost-effective research strategy inthe MSFD monitoring programmes related to pollution. InTable 1, a brief comparison among the main characteristicsof the programmes set for environmental pollutants in MSFD,WFD and OSPAR is presented.

In general, marine pollution monitoring programmes donot use regulatory levels of pollutants set for public healthprotection, as is the case of Spain, but EU standards related tohuman consumption may be used as environment qualitycriteria or environmental assessment criteria due to the lackof valid environmental criteria for some contaminants. In fact,the OSPAR Commission recommends the use of EU foodstandard limits for metals (Hg, Pb and Cd), as an alternative tothe OSPAR Environmental Assessment Criteria (EAC) since

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those criteria, which indicate pollutant concentrations belowwhich no chronic effects are expected to occur in marinespecies, have not yet been agreed for metals (OSPARCommission 2010). This approach is not satisfactory for theassessment of environmental risk, and the use of dietarystandards is a temporal solution until appropriate criteria aredeveloped for those pollutants.

However, in the case of aquaculture installations in the EU,environmental chemical data must be provided in order tocomply with the requirements of the Environmental ImpactAssessment legislation. A complete review on the environ-mental impact assessment and environmental monitoring aswell as environmental regulation methods in aquaculture inEurope and North American countries can be consulted on thestudy of Telfer et al. (2009).

Also, current monitoring programmes carried out to meetthe requirements of public health legislation follow differentprocedures and strategies than monitoring programmes for theassessment of marine environmental quality. For instance,monitoring programmes intended for human health safety,which use specific regulations, often lack the necessary datato link the samples and results to a particular marine(sub)region (i.e. traceability from source) (Swartenbrouxet al. 2010). An important challenge on this matter refers tothe point of the processing chain (e.g. collection at sea, atretail) at which samples are collected, which may difficult thecorrect assignment of the geographical origin of the samples.

These programmes are based on sampling methodsintended to evaluate human exposure to contaminants andinclude size ranges and tissues of fish and seafood marketedfor human consumption rather than using a standardised sam-ple as in environmental monitoring programmes, which al-lows quantifying the degree of contamination in the marineenvironment. Since such programmes use fish from differentsizes and ages, higher levels of pollutants cannot beinterpreted straightforward as a poor environmental statusand may hamper the identification of spatial and temporalpollution trends (Swartenbroux et al. 2010). In addition,bioindicator species used for environmental monitoring mustmeet certain requirements such as accumulating high levels ofpollutants without death, high abundance and wide distribu-tion, low dispersion ability or sessile lifestyle, representinglocal pollution (see, e.g. Viñas et al. (2012)). However, certaincommercial fish species are highly migratory and cannot beused to assess the GES of a particular marine area, not even ofthe jurisdictional waters of a particular state.

Concerning Regional Seas Conventions, the ‘WorkingGroup on Monitoring and on Trends and Effects of Sub-stances in the Marine Environment (MIME)’ and the ‘Haz-ardous Substances and Eutrophication Committee (HASEC)’,within the OSPAR Convention, have also considered thisissue and concluded that there was limited scope for integrat-ing monitoring of biota for D8 and D9, with the exception ofT

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shellfish sampling, although further cooperation among com-petent authorities for the optimization of environmental andfood safety control monitoring is recommended both at na-tional and international level. In the Barcelona Conventionthough, the relation between descriptor 8 and 9 has not beendiscussed in detail since political and socio-economic issuesrepresent a challenge for the MSFD implementation, includ-ing the presence of third countries not obligated to implementthe MSFD.

Research needs

Besides assessing the status of the marine environment andestimating the distance to achieve the GES, MSFD’s monitor-ing programmes are supposed to identify the causes of changeand to guide the process for the development of correctivemeasures to restore the GES. It is evident that it would becrucial to strengthen the scientific and technical developmentof different subjects. An intense research effort would beneeded, especially on the processes affecting contaminantbiogeochemistry, distribution and availability, including theidentification of pollution sources and the quantification oftheir fluxes and inputs in the marine environment.

The understanding of causal relationships and mechanisticprocesses between the presence of contaminants in the envi-ronment and their ecological effects are essential to determinethe environmental status of marine ecosystems. With this aim,the responses ofmarine organisms to contaminants needmuchresearch effort, above all regarding the information of emerg-ing pollutants. Appropriate monitoring tools and methodolo-gies will be needed, including passive sampling techniques,new biological effects techniques and analytical methodolo-gies (Davies and Vethaak 2012).

In the particular case of research needs for marine moni-toring development, another topic which is poorly understoodis related to the establishment of the relationships between thepresence of contaminants in abiotic environmental compart-ments and the concentrations reached in marine biota in

particular in fish and other seafood (see, e.g. Kidd et al.2007). In general, it would be necessary to identify possiblerelations between contaminant levels in sediment and tissues(such as liver and muscle) of fish and other seafood (De Bruynand Gobas 2006; Casas and Bacher 2006) that would benefitfrom joint monitoring programmes.

A practical case from the Spanish evaluation

In the initial evaluation of Spanish marine waters in order tocomply with MSFD requirements, descriptors 8 and 9 wereanalysed. All the documents of the Spanish marine strategycan be consulted in the website of the Ministry of Agriculture,Food and the Environment (http://www.magrama.gob.es/es/costas; documents in Spanish).

We will discuss the relationship between initial assessmentof descriptors 8 and 9 in the North Atlantic Spanish region,Iberian coast sub-region, with two paradigmatic examples:metals and benzo[a]pyrene (BaP).

The example of metals (Hg, Cd and Pb) and BaP

In the descriptor 8 assessment, well-established environmentalquality criteria, such as those defined by OSPAR (for exam-ple, Background Assessment Concentrations, BAC and Envi-ronmental Assessment Criteria, EAC) were used. BACs arederived mathematically from Background Concentrations(BCs) to enable the robust analysis of monitoring data inrelation to the objective that concentrations should be ‘nearbackground levels’ (OSPAR Commission 2010). Due to thelack of EAC values for metals in biota, the regulatory levelsset for public health protection used in descriptor 9 were alsoused in descriptor 8, as recommended by the OSPAR Com-mission in the Quality Status Report 2010 (http://qsr2010.ospar.org).

Table 2 Reference values for mercury, cadmium, lead andBaP (μg/kgw.w.) used in theMSFD initial assessment for Spanish marine waters (descriptors8 and 9) and WFD-EQS

Species Descriptor 8 Descriptor 9 WFD-EQS

BAC EAC or PHRL PHRL

Mercury Mussels and fish 18 (mussel) 500 500 20

Species listed in 3.3.2a - 1,000 1,000 20

Cadmium Mussels and fish 192 (mussel) 1000 (mussels and fish liver) 50 (fish muscle) 1,000 (mussels) Not proposed for biotaSpecies listed in 3.2.6 and 3.2.7a - 1,000 100–300

Lead Mussels and fish 260 (mussel) 1,500 (mussels and fish liver) 300 (fish muscle) 1,500 (mussels) Not proposed for biota

BaP Mussels 0.4 120 5 10

a Species in the Annex of the Commission Regulation (EC) No. 629/2008 of 2 July 2008 amending Regulation (EC) No. 1881/2006 setting maximumlevels for certain contaminants in foodstuffs

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Concentrations of metals (Hg, Cd and Pb) in wild mussels(used as sentinel species in coastal waters) have been evalu-ated for the initial assessment of descriptor 8 from 40 sam-pling locations within the Spanish Marine Pollution Monitor-ing Programme framework. Table 2 shows the Public HealthRegulatory Level (PHRL) standards (established in the Reg-ulation (EC) No. 1881/2006) for Hg used in the MSFD initialassessment of Spanish marine waters.

Detected levels of Hg were lower than the BAC in 32.5 %of samples and none of the sampling areas were above thePHRL. Cd levels were lower than the BAC level (192 μg/kgw.w.) in 80 % of the sampling areas and none of them werehigher than the PHRL. On the other hand, detected concen-trations of Pb were lower than the BAC level (260μg/kgw.w.)in 30.8 % of samples and 5.1 % exceeded the PHRL value.

To carry out the evaluation within descriptor 9 (MSFDInitial Assessment for Spanish Marine Waters), 33 fisheryproducts were considered. It is noticeable that only onespecies (Mullus surmuletus) was above the PHRL, andonly 7 % of the samples showed higher Hg levels than thePHRL.

The WFD establishes an Environmental Quality Standard5

(EQS) for Hg in biota that is supposed to protect both aquaticenvironment and human health (see Table 2). The EQS for Hgin biota (fish, crustaceans or mollusks) is very low (20 μg/kgw.w.) in line with the BAC set by OSPAR for mussels (18 μg/kg w.w.) and fish muscle (35 μg/kg w.w.). If the criteria usedin descriptors 8 and 9 for Hg in biota were to be substituted byWFD-EQS, the assessment would have been quite different.For instance, for the assessment of descriptor 8, the levels ofHg in wild mussels would have exceeded the EQS in 62.5 %of the samples. In the case of descriptor 9, if EQS referencevalues would have been used in the study, 93.9 % of the

fishery products (representative commercial species of fish,crustaceans, mollusks and cephalopods) would have exceededthe EQS.

The Cd evaluation in descriptor 9 showed that none of the33 species of fishery products present levels of Cd whichconstitute a hazard for the human health. In the case of Pb,the values were higher than PHRL in 3 % of samples (for thescallop species Aequipecten opercularis). In the case of Pband Cd, the comparison with EQS is not possible since thesecriteria have not been set for these metals in biota.

In the case of BaP, available criteria, both for human healthand for the environment, have been set, and there is also avalue suggested as EQS for biota in the recent legislativeproposal.6 These values are shown in Table 2. It is importantto point out in this case the incoherence of the value proposedby the WFD (as a possible EQS for biota) as it is higher thanthe value set as a PHRL since EQS values are supposed toprotect both the environment and human health. Therefore, arevision of the EQS value for BaP is suggested.

BaP-detected levels in wild mussel used for the assessmentof descriptor 8 were lower than the BAC in 12.8 % of thesamples and never exceeded the EAC. When assessing BaPdata for descriptor 9, among the ten shellfish species studied(fish are known to metabolise PAH—e.g. Varanasi and Stein1991—so the analysis of these compounds is not recommend-ed), only one sample of one species (A. opercularis) exceededthe PHRL value. In this case, the use of the proposed WFD-EQS would have led to an increase in the exceedances indescriptor 8 (to 7.7 %) but a decrease in descriptor 9 to 0 %exceendances, so the selection of the criteria (BAC, EAC,PHRL, EQS) to be used in the assessment is one of the keyissues to be considered, as it can completely change the outputof the assessment. Table 3 summarises the results, according

5 European Commission (EC), Directive 2008/105/EC of the EuropeanParliament and of the Council of 16 December 2008 on environmentalquality standards in the field of water policy.

6 Proposal for a directive of the European Parliament and of the Councilamending Directives 2000/60/EC and 2008/105/EC as regards prioritysubstances in the field of water policy (COM(2011)/876).

Table 3 Summary of percentage of samples in each range of concentrations for mercury, cadmium, lead and BaP used in the MSFD Initial Assessmentof North Atlantic Spanish waters for descriptors 8 and 9

Descriptor Matrix Substance Concentration<BAC BAC<Concentration<PHRL PHRL<Concentration

D8 Mussel Mercury 32.5 % 67.5 % 0

Cadmium 80 % 20 % 0

Lead 30.8 % 64.1 % 5.1 %

BaP* 12.8 % 87.2 % 0

Concentration<PHRL

D9 33 fish and shellfish species Mercury 100 and 93 % of 1 species 7 % of 1 species

Cadmium 100 % 0

Lead 100 and 50 % of 1 species 50 % of 1 species

10 shellfish species BaP 100 and 80 % of 1 species 20 % of 1 species

EAC for BaP instead of PHRL

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to the abovementioned criteria, used in the initial evaluationof the North Atlantic Spanish jurisdiction for descriptors8 and 9.

Moreover, it should be pointed out that fish samplingcarried out in environmental monitoring programmes gener-ally focus in liver, whilst ‘human health programmes’ focuson edible parts of the fish (mainly muscle). Therefore, theresults obtained for metals on fish species within descriptors 8and 9 cannot be compared directly.

In addition, as mentioned previously, traceability of fisheryproducts is not a major issue in human health monitoring, butit is essential to fulfil the requirements of MSFD regardingdescriptor 9 and to establish a potential link with descriptor 8.It should be indicated that the main purpose of the MSFD is toevaluate the marine environmental status by applying anecosystem-based approach, and the descriptor 8 evaluationshould not be limited to a short list of commercial seafoodspecies as would be descriptor 9.

Final remarks

In our view, the coordination of monitoring programmes forassessing contaminants under descriptor 8 and descriptor 9should be explored. In order to develop comparable andcoherent approaches between (sub)regions, it would be con-venient to agree at least on a short list of species from the mostconsumed species of fish and other seafood, as indicated bySwartenbroux et al. (2010), but it should be taken into accountthat the application of the ecosystem approach demanded bythe MSFD cannot be limited to the consumer’s criteria.

Another important aspect when discussing the integrationof descriptors 8 and 9 is the traceability of the samples. Inenvironmental studies, this aspect is obviously essential, butas regards of descriptor 9, there is a lack of information sincethe monitoring is designed to protect human health and not todetermine the origin of the problem.

A reasonable connection between the levels of contami-nants in the marine environment (sediment, water) and thelevels in fish and other seafood have not yet been established,indicating a general research need on the life cycle of contam-inants between abiotic compartments and seafood species.Developing strategies for gathering information on the levelsof contaminants in fish and seafood, concurrently for theassessment of the environmental quality and for public healthreasons, should be strongly encouraged within the frameworkof the marine strategies. In this way, the levels of contaminantsin fish and seafood monitored for human health protectioncould be used for evaluating the impact of contaminants onmarine ecosystems provided that sampling and traceabilityfulfil environmental purposes and taking into account thatadaptations would be needed in the methodologies.

Despite the joint development of descriptors 8 and 9 that isnot demanded by the MSFD, we suggest that a close synergyof these descriptors in the near future would represent a cost-effective approach and may help increase the knowledge oncontaminant effects on the marine environment and possiblyalso in the human health. It is important to mention that thisjoint approach may be an opportunity to increase our knowl-edge on how contaminants are transferred through the foodweb, but the MSFD implementation should not be limited to ashort list of commercial species with the final objective ofhuman health protection.

As shown with our example in the Spanish sub-region ofthe North Atlantic, it is important to point out the necessity ofsetting the assessment criteria in a coordinated way betweenmember states in a specific technical working group dealingwith the integration of descriptors 8 and 9.

Finally, the connection between descriptors 8 and 9, whichdemands a coordinated monitoring program, results also fromthe fact that intoxication in humans as a result of consumptionof contaminated fish and seafood would probably point to asignificant pollution episode causing at the same time majorimpacts on marine ecosystems.

In conclusion, a coherent and consistent joint developmentof descriptors 8 and 9 of the MSFD would provide an unsur-passable opportunity to increase the protection of the marineenvironment and our knowledge of contaminants and theirinteractions in the oceans and seas.

Acknowledgments This work has been supported by the InstitutoEspañol de Oceanografía (IEO). We are very grateful to the SpanishMinistry of Environment and to all the people involved in the MSFDprocess in Spain, especially to those dealing with descriptors 8 and 9. Weare very grateful to the three reviewers that made a number of goodsuggestions to improve this work.

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