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Water Air Soil Pollut: Focus DOI 10.

1007/s11267-008-9178-6

Urban Rivers as Pollutant Sinks and Sources: a Public Health Concern for Recreational River Users?
Lian Scholes & Hazel Faulkner & Sue Tapsell & Stuart Downward

Received: 01 February 2008 / Accepted: 30 April 2008 # Springer Science + Business Media B.V. 2008

Abstract Although the area of urban river sediment quality has received increasing attention over the last 10 years, the presence of contaminated sediments in urban rivers and the potential risk to public health it poses has yet to be rigorously addressed within the urban river restoration context. This is an issue of particular concern at the current time, as the openingup of urban rivers is being strongly promoted by many legislative and non-legislative bodies as a multibenefit approach to tackling a range of urban challenges; from decreasing the risk of flooding to increasing the quality-of-life in urbanised areas. This paper brings together these two contrasting concepts; urban rivers as pollutant sinks and sources (presentation of data on urban river sediment quality) and urban rivers as sites of flood alleviation, amenity, recreation and wildlife value (review of the drivers
L. Scholes (*) Urban Pollution Research Centre, Middlesex University, The Burroughs, Hendon, London NW4 4BT, UK e-mail: L.Scholes@mdx.ac.uk H. Faulkner : S. Tapsell Flood Hazard Research Centre, Middlesex University, Trent Park Campus, Bramley Road, London N14 4YZ, UK S. Downward School of Earth Sciences and Geography, Kingston University, Kingston, Surrey KT1 2EE, UK

and initiatives behind the increasing implementation of urban river rehabilitation schemes). In light of this combined assessment, the urgent need for a risk assessment of restored urban river sites to establish whether the presence of contaminated sediments poses a risk to public health is strongly recommended. Should such a risk be demonstrated, a tiered approach to supporting the identification and pro-active management of these risks is proposed as a way to inform and enable, rather than to prevent, the safe and appropriate use of the increasing number of urban river restoration schemes being implemented. Keywords Recreation . Risk assessment . Sediment quality . Urban river restoration

1 Introduction Urban watercourses routinely receive inputs from a variety of sources including urban, highway and agricultural runoff. Cross-connections and overloads from foul to storm sewers further contribute to the episodic and persistent pollutant loadings which are a characteristic feature of many urban rivers. The majority of this pollutant load is transported by sediments (Lee et al. 1997 cited in Marsalek et al. 1999), which progressively settle-out of the receiving water column as a function of time in relation to the hydrological and geomorphological conditions within the river system (Rhoads and Cahill 1999). This

Water Air Soil Pollut: Focus

process can result in the build-up of substantial quantities of deposited sediment which remains lodged within the system, visible as sedimentary structures. However, despite the apparent persistence of sedimentary structures in urban watercourses, urban hydraulic regimes are characteristically flashy, so that deposited sediments (in particular the fine fraction and associated pollutants) are highly susceptible to resuspension (Old et al. 2004). Under such dynamic conditions, the change in physico-chemical conditions may result in the re-release of previously bound pollutants into the water column. Thus, not only have elevated concentrations of a wide range of substances including metals, hydrocarbons and faecal coliforms been reported in urban streams and rivers (e.g. Boxall and Maltby 1995; Crabill et al. 1999; Chen and White 2004, and Tables 1 and 2), the concentrations of these contaminants within deposited sedimentary structures also tends to be highly variable on both a spatial and temporal scale (Faulkner et al. 2000). For example, a recent survey of urban streams in Scotland reported that sediment from four of the nine streams sampled would be classified as special waste under UK regulations due to their total hydrocarbon content (Wilson et al. 2005). In relation to microbial

parameters, reports suggest that bacteria are deposited in the same manner as suspended solids (Jacobs and Ellis 1991), and several studies have reported elevated concentrations and higher survival rates of faecal indicators in sediments in comparison to values determined in the overlying water column (Desmarais et al. 2002; Craig et al. 2004; Jeng et al. 2005). Within this context, research by Snook and Whitehead (2004) on the lower stretch of the River Lee (urban tributary to the River Thames, UK) which reported levels of total and faecal coliforms in the water column between 71 and 59 times, respectively, the EU Bathing Water Quality Directive standard (see Table 2) is of particular concern. The same authors reported even higher elevations of both total and faecal coliforms relative to this standard (100 times and 343 573 times, respectively) on smaller streams in the surrounding River Lee catchment. Of particular importance is the fact that these smaller streams were not in receipt of sewage treatment work (STW) effluents, clearly highlighting the potential impacts of misconnections and combined sewer overflows (CSOs) discharging into urban watercourses. As the Environment Agency (the public body responsible for protecting and improving the environment in England and Wales), only monitors faecal coliforms in watercourses

Table 1 Minimum and maximum total concentrations of metals measured in a selection of urban stream and river sediments (g/g dry weight) n Scholes et al. (1999) Rhoads and Cahill (1999) Wilson and Clarke (2002) Filgueiras et al. (2004)a Tejeda et al. (2006) Thevenot et al. (2007)b Samecka-Cyerman and Kempers (2007) Walling et al. (2003)c 45 41 9 33 32 21 24 51 52 17 50d Cd 3.010 Cr 3169 9328 78139 47 4.928.5 1785.2 817 21181 65313 478 Cu 17178 655 440.6 30.555.9 9165 31 2.110.6 9.543.7 3392 118198 141235 <5172 Ni 22187 8244 80.9 32.560.7 Pb 33332 10225 43.691.1 1264 43 1557 1797 6891,471 90237 199343 <5278 Zn 211,035 29528 407.0 381,467 140 6.8458 22.9174 7751,850 274580 397907 39563

0.370.41 1.70 0.200.58 0.241.72

7.515.2 14.539.0

Carpentier et al. (2002)

<0.86

<530

Values in italics exceed one or more of the guideline values presented in Table 3 n number of samples
a b c

Range of values across 11 sites Estimated average metal contents over the time period 19952000 of dredged sediments

Range of values reflect average concentrations at multiple sampling points on three different rivers sampled approximately bi-monthly over 12-month period; rivers located close to metal mines (no longer operational) Number of samples analysed for Cd=42 and Cr=32

Table 2 Concentrations of microbiological parameters recorded in a selection of urban stream and river waters and sediments Total coliforms Water Sediment Water Sediment 11053106 CFU/100 mlb 2.8103 MPN/g 1.31025103 MPN/g 2.6104 MPN/g Faecal coliforms

Water Air Soil Pollut: Focus

2.2104 MPN/g 51041.3105 MPN/g 2.8105 MPN/g

Crabill et al. (1999) Snook and Whitehead (2004) Ellis and Yu (1995)c Miyabara et al. (1994)d He et al. (2007)e Torres (1997)f EU Bathing Water Directive (1975)g 7.1105 CFU/100 ml 31033106 MPN/100 ml <21034.9106 MPN/100 ml 81031.7105 MPN/100 ml 8.4104 CFU/100 ml 1104 CFU/100 ml

29527 CFU/100 mla 1.2105 CFU/100ml 81028105 MPN/100 ml <21037.9106 MPN/100 ml 201.3103 MPN/100 ml 1.8103 CFU/100 ml 2103 CFU/100 ml

Values in italics exceed EU Bathing Water Directive values

Range in mean annual values across eight sites

Range in mean annual values across four sites

Geometric mean densities across four sites; CSO discharging into an urban stream

Range of values reported across 14 urban rivers

Average of samples collected across approximately 165 sites

Maximum values

Value for marine waters

Water Air Soil Pollut: Focus Table 3 Sediment and soil quality guideline values utilised in various countries and contexts US EPA sediment guidelines (1977 cited in Rhoads and Cahill 1999) (mg/kg dry weight) Not polluted Cd Cr Cu Ni Pb Zn
a b c d

Swedish EPA quality criteria (mg/kg dry weight)a

Canadian interim sediment quality guideline (mg/kg dry weight)b

DEFRA contaminated land exposure assessment (mg/kg dry weight)c

Moderately polluted

Heavily polluted >6 >75 >50 >50 >60 >200 27 25100 25100 1550 150400 3001,000 0.6 37.3 35.7 35 123 30 200 75 450d

<25 <25 <20 <40 <90

2575 2550 2050 4060 90200

Concentration above which additional biological investigation is recommended (Swedish Environmental Protection Agency 2002) Values below which adverse biological effects are not thought to occur (Canadian Interim Sediment Quality Guidelines 2003) Soil guideline values as a function of land use: values selected are for residential land without plant uptake (DEFRA 2002a, b, c) Residential with/without plant uptake (DEFRA 2002d)

downstream of STWs, this contamination is effectively hidden from public records. As well as coliforms, Salmonella has also been recorded in the middle and lower stretches of the River Lee (Faulkner et al. 2000). Also of note is the fact that the River Lee runs through the heart of Londons new 2012 Olympic village, with its restoration promoted as a key theme and asset of the Olympics regeneration programme (Environment Agency for England and Wales 2006). This data, however, clearly indicates a need for a public health risk assessment before any remediation works which would promote direct recreational use of this river. The poor quality of many urban water bodies is clearly recognised at a European level. For example, the EU Water Framework Directive (WFD) requires that heavily modified water bodies such as urban rivers only need to attain good ecological potential as opposed to the more stringent good ecological status objective which all other water bodies must attain (EU 2000). The classification of heavily modified water body was developed in recognition of the fact that certain water bodies have been so affected by human activity that achievement of good ecological status would be impossible or disproportionately expensive. The EU WFD also specifically refers to the need to tackle diffuse pollution (of which urban runoff is a key component) as part of a combined approach to achieving its ecological objectives, further recognition of the poor quality of water bodies in receipt of this type of discharge.

2 Drivers for Change: the Push to Restore Urban Rivers and Why Concern Now? River culverting and channelisation techniques were developed at a time when sustainability criteria were not of major relevance, or, in many cases, even a consideration. However, views on hard engineering started to shift in the latter part of the last century as it began to be recognised that leaving rivers in a more natural state enhanced local flood attenuation, watercourse flood storage capacity and reduced downstream flooding, and was hence a cost-effective alternative to traditional engineering (Environment Agency for England and Wales 2002). Links between urban river restoration schemes and opportunities to access nature with its associated benefits for mental and physical health were also made (Landrigan et al. 2004). For example, Eden et al. (2000) suggest that urban rivers can be seen as remnants of nature, and that reconnecting communities with rivers can play an important role in promoting environmental consciousness and a reconnection with nature that engenders a sense of well-being and enhances the quality of life in urban areas (Environment Agency for England and Wales 2002, 2006; Greater London Authority The London Plan 2004). Both Curtis et al. (2002) and Tapsell et al. (2001) reported the positive health benefits associated with engagement with rivers in urban settings, such as an increased opportunity for exercise, fresh air, mental health and psychological benefits, which can all make a useful contribution to

Water Air Soil Pollut: Focus

achieving a range of sustainability, health and community goals. In response to such reports, the number of river restoration programmes initiated over the last few years has shown a dramatic increase (Skinner and Bruce-Burgess 2005). These schemes are widely promoted by a range of government and nongovernment organisations as a multi-benefit approach to greening urban areas able to provide a wide range of social, environmental and economic benefits from flood management to the provision of attractive and safe places for playing, feeding the ducks and generally connecting with nature providing new and exciting places to explore (DEFRA 2004a; Environment Agency for England and Wales 2005, 2006). However, despite the fact that urban river sediment quality has been the subject of considerable research (supported by an extensive body of literature referring to the role of sediments in capturing, transporting and storing pollutants (e.g. Davis and Atkins 2001; Caille et al. 2003; Filgueiras et al. 2004), the widely documented presence of highly contaminated sediments in urban rivers has only relatively recently begun to be recognised as a possible public health concern or management issue within the urban river restoration debate (e.g. CROCUS 2007), but such aspects have yet to been translated into best practice guidance documents. For example, within the UK, the main advisory and information body for river restoration and rehabilitation is the River Restoration Centre, but a review of both its best practice manual and database found no reference to sediment contamination (River Restoration Centre 1999, 2002). A factor contributing to this invisibility may be that sediment is not routinely sampled by any EU national agency, with the feasibility of developing sediment EQS under the EU WFD continuing to be strongly debated (Crane and Babut 2006). This omission exists partly because of the complexity of sedimentary environments, with the temporal and spatial variability of water-associated and bedform-associated sediments which represent an enormous challenge for representative sampling (Crane 2003 cited in Crane and Babut 2006). The interpretation of data, such as that reported in Tables 1 and 2, is therefore problematic as, in the absence of appropriate sediment standards, various researchers and organisations use different classification schemes to assess levels of contamination and the associated

risk they may pose in relation to a variety of receptors. For example, the Port of London Authority (UK) uses a combination of classification schemes (including comparison with the Canadian Interim Sediment Quality Guideline (ISQG) values and CLEA land contamination guidelines; see Table 3) to assess the impact of its dredging activities on the water column and biological communities (PLA 2008). The potential for the use for alternative classification schemes to influence the sediment assessment process is clearly demonstrated in a review of sediment quality in stormwater retention basins by Heal and Drain (2003) which collated published data from a wide variety of sources and classified levels of sediment contamination using three different schemes: the British Waterways Sediment Classification Scheme, the Hong Kong Interim Sediment Quality Guidelines and the Ontario Ministry for Environment Provincial Sediment Quality Guidelines. This review focused on heavy metals and found that the proportion of sites classified as highly contaminated varied from 3% (using the British Waterways Scheme) to 45% (using the Ontario guidelines). However, the complexity of the issue should not result in its exclusion from urban river restoration programmes. Irrespective of the lack of clarity over appropriate sediment quality standards, data on elevated sediment-associated pollutant concentrations in urban rivers (as reported in Tables 1 and 2) in combination with knowledge that restored sites are being actively promoted as recreational areas (as discussed above) suggests a potential risk to human health which urgently needs to be addressed. As stated in the WHO Guidelines for Safe Recreational Water Environments (WHO 2003), sediments located at a site subject to resuspension or where recreational users can come into intimate contact can result in direct exposure to elevated pollutant concentrations. It is now essential that those involved in river restoration recognise that whilst rivers may be engineered to appear aesthetically pleasing and to have a degree of restored morphological functionality, this is no guarantee that it will be biologically or chemically safe for human interaction (Palmer et al. 2005). Further, it is argued that it is in fact unethical to ignore the possibility of the presence of contaminated sediments at such sites. It is strongly recommended that a risk assessment on the recreational use of restored rivers

Water Air Soil Pollut: Focus

be completed using an established approach, (e.g. see DEFRA 2004b) to determine if the activities of recreational river users results in their exposure to sediment containing pollutants at a level of concern in a way which causes harm.

3 Options for Restoring Rivers Known to Contain Contaminated Sediments Whilst the quality of sediment in urban rivers is clearly a concern, poor sediment quality should not necessarily be seen as a barrier to increased social engagement with urban rivers as, if identified as posing a risk, there are a variety of ways, in which such a risk may be managed, as discussed in the following sections. 3.1 Identification and Mapping of Pollutant Hot Spots Research has shown that proximity to contaminant delivery sites is only an approximate predictor of concentrations of sediment-associated pollutants such as metals and E. coli (e.g. Faulkner et al. 2000), because of the way in which the hydrologic system sorts and remobilises sediments, especially the fine fraction. However, there are known relationships between stream power and sediment behaviour (e.g. Shields entrainment function; Knighton 1998); and between fine fraction and colloidal content and concentrations of sediment-bound pollutants. For example, Rhoads and Cahill (1999) investigated the dispersal of sediment-related heavy metal contaminants in an urban stream system. Their results demonstrate a link between local variability in metal concentration and spatial variation in reach-scale hydrodynamic conditions with highest metal concentrations occurring within two local geomorphological environments; regions of low velocity or flow circulation (e.g. vegetated point-bar surfaces) that preferentially enhance the build-up of fine sediments and organic materials in which contaminants are colloidal associated, and regions of intermediate velocity that promote the concentration of sand-sized inorganic particles (such as minerals and heavier metal particulates). Areas of the river with highest velocities and coarse bed substrates did not generally have elevated metal contents. The application of this

type of reach-scale fluvial geomorphology to inform and manage the movement of sediment through a restored river could offer an additional and valuable tool through which the potential for contact with contaminated sediments could readily be minimised. At a greater scale, other fluvial geomorphic models (e.g. see review by Coulthard et al. 2007) are available that link stream power to sediment entrainment and deposition, offering huge potential for the development of targeted models capable of identifying the provenance, behaviour and depositional location of contaminant-associated sediment over large stretches of rivers. Being able to predict the location and persistence of areas within which the fines-associated contaminants are likely to accumulate (known as hydraulic dead zones) mean that a riskbased modelling methodology could be developed. Such an approach was advocated by Coulthard and Macklin (2003) in relation to the proactive identification and management of sites contaminated by mining wastes. In considering the development of a framework to support the identification of sites for river restoration, a five stage tiered approach to risk minimisation has been developed (see Fig. 1). Applying the principles outlined in Coulthard and Macklin (2003) and Macklin et al. (2006), the framework presented in Fig. 1 commences with an initial good practice prescheme assessment stage (Stage 1) in which the levels of sediment-associated contamination are determined. At this stage, there are, it is argued here, situations where the rehabilitation of the channel for recreational purposes is deemed unsuitable because of the level of contamination identified. There is inevitably subjectivity in these assessments and the discussion of acceptable and unacceptable levels of pollution, in particular in relation to the allocation of values to be associated with classifications of low, medium and high levels of contamination, clearly require further debate and may also be context-specific. However, guidelines such as those presented in Table 3, together with the output of EU discussions on developing sediment EQS, could act as starting points. In conditions assessed as only moderately contaminated, the utilisation of source control measures (for example, see Section 3.2) are suggested prior to any decisions on the implementation or design of a scheme (see Stage 2 of Fig. 1). If the results of an initial audit indicate that pollutant loadings are

Water Air Soil Pollut: Focus Fig. 1 Outline framework for a tiered approach to risk minimisation. STW sewage treatment works, SWO stormwater overflow, CSO combined sewer overflow, EA Environment Agency for England and Wales, DEM digital elevation model

relatively low, the scheme design may proceed. Stage 3 of the framework sets out a two stranded approach to modelling watercourse dynamics using all available quantity and quality data to support an assessment of both routine and peak event contaminant loadings; Strand A focuses on the identification and assessment of pollutant sources in contrast to Strand B which considers in-channel spatial and temporal dynamics. Together with the sediments assays undertaken in Stage 1, this two-stranded modelling strategy would inform the design for the rehabilitation of the

watercourse (Stage 4 of Fig. 1) by describing hydraulic variables (such as meander dimensions and gradients) to support optimisation of design conveyance capacity and behaviour. Crucially, the impact of river rehabilitation on sediment dynamics needs to be considered both under the intended design conditions as well as in relation to the impact of likely changes in the fluvial regime which may occur as the river continues to evolve post-rehabilitation. Minimisation of public exposure would finally result from the prediction of persistent dead zones within the

Water Air Soil Pollut: Focus

watercourse design which could be screened by plantings or restricted in access by fencing and public awareness notices (Stage 5). Such a risk-based hot spot prediction approach, would allow managers to design schemes that steer recreational users of restored streams away from identified high risk sites, minimising opportunities for users to come into contact with contaminated sediments over both shorter and more long-term time frames. 3.2 Source Control In this context, the term source control refers to the management of stormwater runoff using a wide range of structural systems (e.g. ponds, infiltration trenches and porous paving) and non-structural approaches (such as street cleaning and education programmes) (Scholes et al. 2003). The aim of this approach is to reduce the pollutant load, volume and flow rate of stormwater runoff as close to source as possible, through processes such as reduction of pollutant input (e.g. modified herbicide management practices) and the infiltration and/or detention of stormwater (with its subsequent discharge at a controlled rate). The use of source control options (either individually or in combination as part of a treatment train) to manage stormwater flows prior to their discharge to urban receiving waters would have a two-fold effect. Firstly, it would effectively act to remediate sediment quality by a reduction in the input of toxic substances. Secondly, it would significantly reduce the number and magnitude of sediment resuspension events with their associated potential for the re-release of previously attached pollutants. A further aspect of pollutant source control in urban areas is the addressing of misconnections (where foul sewers are wrongly connected to surface water sewers), but these are notoriously difficult to locate in densely urbanised areas. However, such a direct approach was reported to be effective in relation to a river restoration project on the River Skerne (NorthEast England), in which Northumbrian Water tackled the issue in its role as a partner on the project (Halcrow Water 2000). In addition, the use of structural stormwater management source control options can also make a significant contribution towards reducing sewage contamination in urban watercourses through a reduction in runoff volumes entering both combined sewer systems and

sewage treatment plants, hence decreasing the number of combined sewer overflows to receiving watercourses (Bohannon and Lin 2005). It is primarily through such mechanisms that the adoption of source control options on a catchment-scale can additionally make a major contribution towards achieving the good ecological potential requirement for heavily modified urban water bodies set out in the WFD (EU 2000). 3.3 In Situ Measures The issue of contaminated sediment can also be managed in a number of ways involving in situ approaches to minimise the likelihood of recreational end-users coming into contact with stream sediments. Firstly, it is important to recognise that it is not always necessary to allow public access to the entire watercourse in an opened-up reach in order to contribute to the type of social objectives, such as increased amenity and public health well-being, often cited as being associated with river restoration schemes (see Section 1). This is because the degree of public engagement with restored rivers can range from direct physical contact with components of the river (such as access to the water through dipping ponds and stepping stones) to a less direct interaction (e.g. the provision of riverside walks) through to indirect interaction such as the provision of riverside views only (i.e. the river itself remains out of bounds). It may be necessary to accept that under certain sets of circumstances parts of the river have to be offlimits. For example, following completion of a risk assessment, perhaps only certain sections along a given reach of restored river identified as being of a low or acceptable level of risk could be deliberately designed as areas of direct public engagement (e.g. board walks) with access to other areas discouraged through the use of creative design (e.g. planting sediment bars, denser bankside vegetation). The net effect on public consciousness is that the river has been opened up physically, whereas in fact only a small percentage is readily accessible and proactively managed to minimise identified risks. The more drastic approach of sediment dredging and removal to an approved site is an alternative in situ option with perhaps a more immediate impact. However, unless the pollutant source has been identified and remediated (through options such as

Water Air Soil Pollut: Focus

source control management), it is only a short term solution as over a period of time pollutant concentrations will steadily increase in the absence of any proposal to tackle the problem at source. 3.4 Public Engagement with the Issues Further measures may also include the use of education campaigns and signage to inform the public of the risks associated with rivers. Without engendering panic, sites with good water quality should be publicised as exemplars of what can be achieved through good design practice, as well as informing the public of best practice measures such as washing hands after contact with river water/sediment and not entering the river after storm events. An example of this approach in practice is the use of on-site electronic signage by the Scottish Environment Protection Agency to inform the public of predicted beach water quality on a daily basis (SEPA 2008). It is essential to be transparent about quality issues and to not hide behind a smokescreenif the water and sediment quality is poor then people should be informed. The greater the public reaction to poor quality recreational environments, the better will be the political motivation to do something about it.

an assessment would require site-specific data on both the types and loads of pollutants present at a particular location together with an investigation of current and proposed patterns of user engagement. As urban river sediment quality data is generally not available for many rivers across Europe, the use of fluvial geomorphological sediment transport models to enable potential sediment hot-spots to be identified is recommended to support urban river managers in identifying sites which may or may not be suitable for restoration. Such an approach could be initially implemented on a catchment-wide scale as a gross screening procedure, which then allows targeting of sites of concern, reducing both the time and costs associated with a highly intensive sampling programme. Based on the findings of such a survey, available resources could then be targeted effectively towards a more detailed investigation of the identified areas of concern. Such an audit of sediment quality in urban rivers would then need to be combined with an evaluation of end-user activities within restored river areas to enable potential risks to human health to be robustly assessed. Any risks identified must then be carefully balanced against the public health benefits of relaxation and well-being associated with public access to high-quality blue-green spaces, in order to identify ways in which urban river restoration schemes can go ahead even if contamination is present.
Acknowledgements The authors gratefully acknowledge the assistance of both Dr. Jenny Mant at the River Restoration Centre for the provision of information, literature and guidelines, and Ms. Amalia Fernandez for background research at the RRC.

4 Conclusions and Recommendations Increased public and private funding is being directed towards the restoration of urban channels as a way of contributing towards meeting a range of sustainability and quality-of-life goals. However, there remains to-date a lack of engagement by the proponents of urban river restoration with the issues of sediment pollution. Urban watercourse sediments are frequently reported to contain elevated levels of a range of chemical and microbial contaminants, and, as the majority of urban pollutants are associated with sediments, sediment disturbance (through e.g. flooding and recreational activities), may resuspend and ultimately re-release previously adsorbed pollutants, creating a potential risk to public health. Given the recent enthusiasm for urban river restoration schemes, determining whether this known hazard translates into an actual risk to recreational users (and, if so, the nature and magnitude of this risk) is urgently required. Such

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