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Publishing Organisation
Environment Agency, Rio House, Waterside Drive, Aztec West, Almondsbury, BRISTOL, BS32 4UD.

Tel: 01454 624400 Fax: 01454 624409

Website: www.environment-agency.gov.uk

© Environment Agency 2002 March 2002

ISBN 1 857 05728 7

All rights reserved. No part of this document may be reproduced, stored in a retrieval system, or
transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise
without the prior permission of the Environment Agency.

The views expressed in this document are not necessarily those of the Environment Agency or DEFRA.
Its officers, servants or agents accept no liability whatsoever for any loss or damage arising from the
interpretation or use of the information, or reliance upon views contained herein.

Dissemination Status
Internal: Released to Regions
External: Released to Public Domain

Statement of Use
This publication sets out the derivation of the Soil Guideline Values for inorganic mercury contamination.
The report has been written for technical professionals who are familiar with the assessment and
management of the risks posed by land contamination to human health. It is expected to be of use to all
parties involved with or interested in contamination, but in particular to those concerned with the
assessment of land contamination.

Keywords
Soil Guideline Values, mercury, land contamination, priority contaminants, risk assessment.

Environment Agency Contact

Ian Martin, Exposure Assessment Manager, Olton Court, 10 Warwick Road, Olton, Solihull, B92 7HX

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Acknowledgement

The CLEA model was developed between 1992 and 1997 by the late Professor Colin Ferguson at the
Centre for Research into the Built Environment, the Nottingham Trent University. The Environment
Agency’s National Groundwater and Contaminated Land Centre, National Centre for Risk Analysis and
Options Appraisal and Land Quality Management Ltd have prepared this report.

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Contents

1 INTRODUCTION.................................................................................................................... 1

2 DEVELOPING SOIL GUIDELINE VALUES FOR COMPOUNDS OF INORGANIC

MERCURY............................................................................................................................... 3
Occurrence in soil....................................................................................................................... 3
Behaviour in the soil environment..............................................................................................3
Potential for harm to human health and relevant health criteria values for soil.......................... 5

3 SOIL GUIDELINE VALUES FOR INORGANIC MERCURY COMPOUNDS .............. 7

Purpose....................................................................................................................................... 7
Soil Guideline Values according to land-use.............................................................................. 8
Further information for assessors applying these Soil Guideline Values.................................... 9
Comparison with other approaches .......................................................................................... 12

REFERENCES.................................................................................................................................... 15

LIST OF TABLES

Table 1.1 Assessment of risk to human health from land contamination. Key reports from
DEFRA and the Environment Agency................................................................................ 2

Table 2.1 TDSI for inorganic mercuric compounds............................................................................ 6

Table 3.1 A brief description of the standard land-uses for Soil Guideline Values ............................ 8

Table 3.2 Soil Guideline Values for compounds of inorganic mercury as a function of land-use ...... 9

Table 3.3 Contribution to total exposure from soil for the relevant pathways expressed as a
percentage of the mean exposure calculated by the CLEA model .................................... 11

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Soil Guideline Values for Inorganic Mercury Contamination

 Introduction

1.1 This report is one of a series of documents issued by the Department for Environment, Food and
Rural Affairs (DEFRA), its predecessor departments, and more recently the Environment Agency.
The main purpose of the CLR series is to provide regulators, developers, landowners and other
interested parties with relevant, appropriate, authoritative and scientifically based information and
advice on the assessment of risks arising from the presence of soil contamination.

1.2 This report describes Soil Guideline Values, generic assessment criteria for assessing the risks to
human health from chronic exposure to soil contaminated with inorganic compounds of mercury.
This report does not present Soil Guideline Values for other forms of mercury, that is, elemental
metal and organic mercury compounds. It is essential that the information presented here be used
in conjunction with an understanding of the main reports in this series (see Table 1.1) and the wider
context of assessing environmental risk (DETR, Environment Agency and IEH, 2000).

1.3 This technical material can be used in support of the application of the statutory regimes addressing
land contamination, especially Part IIA of the Environmental Protection Act 1990 (the contaminated
land regime) and development control under the Town and Country Planning Acts. In particular,
they are intended to be regarded as “relevant information”, and to assist in the assessment of
“relevant and available evidence”, for the purposes of paragraphs A.31, B.39 and B.44–B.49 of the
Part IIA statutory guidance contained in DETR Circular 02/2000 (DETR, 2000).

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Soil Guideline Values for Inorganic Mercury Contamination

Table 1.1 Assessment of risk to human health from land contamination. Key reports from DEFRA
and the Environment Agency.

CLR7 Assessment of Risks to Human Health from Land Contamination: An Overview of the Development of
Soil Guideline Values and Related Research (DEFRA and Environment Agency, 2002a). CLR7 serves as an
introduction to the other reports in this series. It sets out the legal framework, in particular the statutory definition
of contaminated land under Part IIA of the Environmental Protection Act (EPA) 1990; the development and use
of Soil Guideline Values; and references to related research.

CLR8 Priority Contaminants for the Assessment of Land (DEFRA and Environment Agency, 2002b). This
identifies priority contaminants (or families of contaminants), selected on the basis that they are likely to be
present on many current or former sites affected by industrial or waste management activity in the United
Kingdom in sufficient concentrations to cause harm; and that they pose a risk, to either human health, buildings,
water resources or ecosystems. It also indicates which contaminants are likely to be associated with particular
industries.

CLR9 Contaminants in Soil: Collation of Toxicological Data and Intake Values for Humans (DEFRA and
Environment Agency, 2002c). This report sets out the approach to the selection of tolerable daily intakes and
Index Doses for contaminants to support the derivation of Soil Guideline Values.

CLR10 The Contaminated Land Exposure Assessment Model (CLEA): Technical Basis and Algorithms (DEFRA
and Environment Agency, 2002d). This report describes the conceptual exposure models for each standard land-
use that are used to derive the Soil Guideline Values. It sets out the technical basis for modelling exposure and
provides a comprehensive reference to all default parameters and algorithms used.

TOX 7 (DEFRA and Environment Agency, 2002e). This report details the derivation of the TDSI for elemental
mercury, and its inorganic and organic compounds.

This document:

SGV 5 Soil Guideline Values for Inorganic Mercury Contamination. This report presents the Soil Guideline
Values for inorganic compounds of mercury and sets out their derivation. Soil Guideline Values for elemental
and organic compounds of mercury will be covered in a future report in this series.

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Soil Guideline Values for Inorganic Mercury Contamination

 Developing Soil Guideline Values for Compounds of Inorganic Mercury

Occurrence in soil

2.1 There are more than twenty principal mercury minerals that occur naturally in the environment,
although almost all commercial production of mercury comes from the simple sulphide ore,
cinnabar, which results from hydrothermal mineralisation (Steinnes, 1995). Sedimentary rocks such
as shales tend to have the highest mercury contents in natural rocks because of their deposition
environment (reducing conditions, presence of organic matter and sulphur). Although the parent
rock contributes to the levels of mercury found naturally in soil, a significant component is also
derived from atmospheric deposition as a result of mercury being emitted during volcanic activity
and by the evaporation of the oceans (Steinnes, 1995). Available information on the mercury
content of UK soils is poor (Environment Agency, in preparation), although a summary of four
studies by Steinnes (1995) gives an indicative range of between 10 and 1800 µg kg–1.

2.2 Anthropogenic activity is a major source of aerial emissions of mercury and a significant contributor
to soil contamination. The main sources of emissions have been the mining and smelting of ores,
burning of fossil fuels, production of chlorine and caustic soda, and waste incineration. Mercury is
used in the chlor-alkali industry, in dental preparations, in the manufacture of batteries, in
measurement, control and electrical appliances, and as a component of paints to prevent mildew.
Mercury occurs in minor amounts in fertiliser, lime and manure applied to agricultural land and was
used historically in fungicides and seed disinfectants (Steinnes, 1995).

Behaviour in the soil environment

2.3 Mercury is in Group IIB of the Periodic Table and is therefore considered to be a transition element.
In the soil, mercury can be found in one of three forms, namely, elemental mercury (Hg0), as
inorganic compounds (mainly as Hg2+) and as organic compounds such as methyl mercury (Kabata-
Pendias, 2001). The environmental fate and transport of mercury depend greatly on its form, which
itself depends on the type of contamination and soil conditions such as the redox potential (Yin et
al, 1997).

2.4 The most common form of mercury in soil is as compounds of Hg2+. It rarely occurs as a free ion
under natural soil conditions, preferring to form compounds such as mercury dichloride, to be bound
strongly to soil organic matter or adsorbed to mineral surfaces, or to precipitate as compounds of
sulphur under more reducing conditions (Steinnes, 1995). Compounds with chloride such as HgCl2
and Hg(OH)Cl are poorly adsorbed by mineral surfaces; however, most mercury is retained in soil
as slightly mobile organic complexes (Yin et al, 1997; Kabata-Pendias, 2001). Mercury sorption
varies with pH, the highest being at pH 4 to 5 (Probst et al, 1999). Adsorption of mercury
compounds is positively correlated with the organic carbon and cation exchange capacity (CEC) of
soil (Kabata-Pendias, 2001).

2.5 Elemental mercury occurs in soils as a result of anthropogenic pollution. However, it may form
naturally under strongly reducing conditions such as those found in acid gley soils or as a by-
product of microbial activity (Kabata-Pendias, 2001). The release of elemental mercury and possibly

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Soil Guideline Values for Inorganic Mercury Contamination

other volatile mercury compounds from soil is probably very significant in the cycling of mercury
and may explain elevated concentrations of mercury observed in the vicinity of mercury-bearing ore
bodies (Steinnes, 1995).

2.6 The transformation of organomercury compounds, especially the methylation of elemental mercury,
plays an important role in the environmental mercury cycle (Kabata-Pendias, 2001). The potential
for microbial methylation by bacteria and fungi exists under both aerobic and anaerobic soil
conditions. Although not yet fully understood, studies have shown that humic substances mediate
the chemical methylation of inorganic mercury by releasing labile methyl groups (Kabata-Pendias,
2001). Methylated mercury is readily mobile and can be absorbed by living organisms, including
higher plants.

2.7 Increasing soil concentrations of mercury lead to an increase in the mercury content of plants
(Kabata-Pendias, 2001). Plants differ in their ability to take up mercury and can also develop a
tolerance to high mercury concentrations in their tissues when grown in soils overlying ore bodies.
Possible mechanisms of uptake by plants include passive absorption by the roots from the soil
solution and of free vapour and methylated compounds through the leaves (Kabata-Pendias, 2001).
Fruits and vegetables, such as carrots, lettuce, mushrooms and apples, grown in polluted soils have
been shown to accumulate higher than normal amounts of mercury (Byrne and Kosta, 1970;
Lodenius and Herranen, 1981; Maclean, 1974).

2.8 There is a paucity of information available relating the soil concentration of mercury to its
concentration in the edible portions of vegetables. In the CLEA model, the soil-to-plant
concentration factors (CF)1 for inorganic mercury compounds have been derived from a review of
the relevant literature (Maclean, 1974; Cappon, 1981, 1987; Elsokkary, 1982; John, 1972; Bache
et al, 1973). The CF for leafy vegetables is obtained from a regression analysis of the plot of CF (µg
g–1 DW plant over µg g–1 DW soil) against soil organic matter content, and is corrected to plant
fresh weight by a conversion factor (see DEFRA and Environment Agency, 2002d). The regression
equation is set out in Equation (2.1) and the plotted data shown in Figure 2.1. The spread of the data
for root vegetables did not support the derivation of a regression equation, and therefore the
arithmetic mean of the data has been used, that is, CFroot is 0.05 µg g–1 DW plant over µg g–1 DW
soil.

Equation 2.1

ln(CF) = − 0.5685 − (0.478 × SOM )

where CF is the soil-to-plant concentration factor for leafy vegetables (µg g–1 DW plant over µg g–1
DW soil)
SOM is the percentage soil organic matter content of the soil


1
For more detail on how plant uptake of soil contaminants is modelled by CLEA, read CLR10 (DEFRA and
Environment Agency, 2002d).

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Soil Guideline Values for Inorganic Mercury Contamination

Figure 2.1 Plot of the natural log of the soil-to-plant concentration factors for leafy vegetables
against soil organic matter content

Observations based on the work of Maclean (1974), Cappon (1981, 1987), Elsokkary (1982), John (1972)
and Bache et al (1973). Regression shown as middle line with 95% confidence limits.


ln(CF)








       
Organic matter (%)

Potential for harm to human health and relevant health criteria values for soil

2.9 The principles behind the selection of health criteria values and the definition of concepts and terms
used are outlined in CLR9 (DEFRA and Environment Agency, 2002c). Information on the toxicity
of mercury and reasons behind the selection of the most appropriate health criteria values for the
derivation of this set of Soil Guideline Values are described in Contaminants in Soil: Collation of
Toxicological Data and Intake Values for Humans. Mercury (DEFRA and Environment Agency,
2002e). Reference to these documents is necessary to understand the information presented below.

2.10 The Soil Guideline Values in this report refer only to inorganic compounds of mercury. Other
reports in this series will address methyl mercury and elemental mercury. The kidney is the critical
organ for chronic exposure to inorganic compounds of mercury (DEFRA and Environment Agency,
2002e). The USEPA recommends an oral chronic Reference Dose (RfD) of 0.3 µg kg–1 bw day–1,
which is based on rat studies with renal toxicity as the critical effect (USEPA, 2001). This value has
been used here to derive a TDSI of 0.26 µg kg–1 bw day–1 and 0.22 µg kg–1 bw day–1 for an adult and
six-year-old respectively (see Table 2.1).

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Table 2.1 TDSI for inorganic mercuric compounds (DEFRA and Environment Agency, 2002e)

oral TDSI for an adult a oral TDSI for six-year-old inhalation TDSI for an adult and
(µg kg–1 bw day–1) child b for six-year-old child c
(µg kg–1 bw day–1) (µg kg–1 bw day–1)

0.26 0.22 0.3

Notes
a
. Adult oral TDSI based on oral TDI and oral MDI for a 70 kg person
b
Child oral TDSI based on oral TDI and oral MDI for a 20 kg child.
c Inhalation TDSI based on inhalation TDI. Compounds of inorganic mercury contribute
approximately 5% to the total mercury concentration in urban air and therefore the inhalation MDI
is negligible compared with the inhalation TDI (DEFRA and Environment Agency, 2002e).

2.11 A WHO Working Group proposed an estimated guideline for mercury in air of 1 µg m–3 (WHO,
2000). This was based on studies of occupational exposure to mercury vapour, which had
demonstrated a low frequency of objective tremor, biochemical signs of kidney effects and “non-
specific symptoms” in exposed workers. This would correspond to a TDIinh of 0.3 µg kg–1 bw day–1,
for a 70 kg adult inhaling 20 m3 of air per day (see Table 2.1). Although the derivation of the
guideline was based on data on mercury vapour exposure, the Working Group indicated that it
would also be applicable to inorganic mercury compounds. Cationic forms of mercury are retained
in the lungs about half as efficiently as is inhaled mercury vapour, and the Working Group
concluded that “the guideline also protects against mild renal effects caused by cationic mercury
compounds”.

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Soil Guideline Values for Inorganic Mercury Contamination

 Soil Guideline Values for Inorganic Mercury Compounds

Purpose

3.1 Soil Guideline Values are a screening tool for use in the assessment of land affected by
contamination. They can be used to assess the risks posed to human health from exposure to soil
contamination in relation to land-use. They represent “intervention values”, indicators to an assessor
that soil concentrations above this level might present an unacceptable risk to the health of site-users
and that further investigation and/or remediation is required. Further information on applying Soil
Guideline Values in the regulatory context, including Part IIA of EPA 1990, can be found in CLR7
Assessment of Risks to Human Health from Land Contamination: An Overview of the Development
of Soil Guideline Values and Related Research (DEFRA and Environment Agency, 2002a).

3.2 Soil Guideline Values have been developed on the basis of many critical assumptions about possible
exposure to soil contamination and the development of conceptual exposure models to describe
different land-uses. The standard land-uses considered are described briefly in Table 3.1. It is
important that an assessor understands these conceptual models and is aware of their assumptions
and limitations before applying Soil Guideline Values to an area of land. See CLR10 The
Contaminated Land Exposure Assessment (CLEA) Model: Technical Basis and Algorithms for a
detailed description of the CLEA model on which these Soil Guideline Values are based (DEFRA
and Environment Agency, 2002d).

3.3 If used correctly, an exceedance of a Soil Guideline Value can indicate a potentially significant risk
to human health. However, this does not necessarily imply that there is an actual risk to health, and
the assessor should take into account site-specific circumstances. Furthermore, if incorrectly applied
to a site where the critical pathway or chemical form of the contaminant is not one that has currently
been evaluated, a potentially significant risk might be present even though a Soil Guideline Value
is not exceeded. So it is important that a risk assessor uses Soil Guideline Values as a component
of an overall risk assessment and management strategy for a site in accordance with good practice
(DEFRA and Environment Agency, in preparation; DETR, Environment Agency and IEH, 2000)
and, in particular, an appropriate sampling and testing strategy (DEFRA and Environment Agency,
2002a).

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Table 3.1 A brief description of the standard land-uses for Soil Guideline Values

Further information on the underlying conceptual exposure models for each land-use can be found in
DEFRA and Environment Agency (2002d).

Residential

People live in a wide variety of dwellings including, for example, detached, semi-detached and terraced property
up to two storeys high. This land-use takes into account several different house designs including buildings based
on suspended floors and ground-bearing slabs. It assumes that residents have private gardens and/or access to
community open space close to the home. Exposure has been estimated with and without a contribution from
eating homegrown vegetables, which represents the key difference in potential exposure to contamination between
those living in a house with a garden and those living in a house where no private garden area is available.
Allotments

Provision of open space, commonly made by the local authority, for local people to grow fruit and vegetables for
their own consumption. Typically, each plot is about a one-fortieth of a hectare with several plots to a site.
Although some allotment holders may choose to keep animals, including rabbits, hens and ducks, potential
exposure to contaminated meat and eggs has not been considered.

Commercial/industrial

There are many different kinds of workplace and work-related activities. This land-use assumes that work takes
place in a permanent single-storey building, factory, or warehouse where employees spend most time indoors
involved in office-based or relatively light physical work. This land-use is not designed to consider those sites
involving 100% hard cover (such as car parks) where the risks to the site-user are from ingestion or skin contact
because of the implausibility of such exposures arising while the constructed surface remains intact. Further
guidance on the limitations in applying this land-use to different industries can be found in DEFRA and
Environment Agency (2002d).

Soil Guideline Values according to land-use

3.4 The Soil Guideline Values for inorganic mercury contamination are summarised in Table 3.2. For
residential and allotment land-uses, the Soil Guideline Values are set to be protective of young
children because in general they are more likely to have higher exposures to soil contaminants. For
the commercial/industrial land-use, an adult is assumed to be the critical receptor, with exposure
considered over the working lifetime.

3.5 The Soil Guideline Values have been estimated using the CLEA model where certain parameters,
such as body weight, are treated probabilistically by Monte Carlo sampling. The Soil Guideline
Value is the concentration at which predicted exposure equals the relevant health criteria value for
each standard land-use. Because the final exposure is itself a distribution of values, a point in this
distribution is chosen for comparison with the relevant health criteria value. In deriving the Soil
Guideline Values in this report, the Monte Carlo components in CLEA are sampled 5000 times and
the 95th percentile of the predicted exposure compared with the health criteria value. See CLR10
for a detailed discussion (DEFRA and Environment Agency, 2002d). The final Soil Guideline
Values reported in Table 3.2 have been rounded to the nearest one or two significant figures.

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3.6 The Soil Guideline Values for inorganic mercury are based on considering oral exposure and
compared with the oral TDSI described in paragraph 2.10. Dermal and inhalation routes have been
excluded from this comparison because, for many types of inorganic mercury contamination and
in the context of the standard land-uses, the contribution of these pathways to overall exposure will
be much less than 1%. To check this assumption was valid, inhalation exposures at the level of the
Soil Guideline Value for each land-use were evaluated to ensure that these were always less than
the inhalation TDSI (see paragraph 2.11).

Table 3.2 Soil Guideline Values for compounds of inorganic mercury as a function of land-use

Soil Guideline Value

Standard land-use
(mg kg–1 dry weight soil)

Residential with plant uptake 8

Allotments 8

Residential without plant uptake 15

Commercial/industrial 480

Notes

1. Based on total mercury concentration in the soil. However, the assessor should note that these
Soil Guideline Values do not apply to elemental mercury and organic mercury compounds.

2. Based on sandy soil as defined in CLR10 (DEFRA and Environment Agency, 2002d).

3. For allotments and residential settings where consumption of homegrown produce is important,
the Soil Guideline Values vary only slightly according to soil organic matter, and this has not
been reported here.

4. Based on comparison of oral TDSI with oral exposure routes.

3.7 The Soil Guideline Values are based on the sandy soil described in CLR10 and may vary according
to the other soil types outlined in that report. The availability of mercury to plants depends on a
number of factors (see paragraphs 2.7 and 2.8) and is correlated to soil organic matter content.
However, the variation in soil-to-plant concentration factor according to organic matter content has
only such a marginal effect on the Soil Guideline Values that it has not been shown in Table 3.2.

Further information for assessors applying these Soil Guideline Values

3.8 In applying the Soil Guideline Values in this report to a contaminated site, assessors will find the
advice presented in the following paragraphs useful. It is good practice for risk assessors to
accompany their risk assessment with an appropriate risk evaluation, including a clear statement of
whether or not representative soil concentrations from the site exceed any generic or site-specific
assessment criteria (DEFRA and Environment Agency, in preparation; DETR, Environment Agency

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and IEH, 2000). In using Soil Guideline Values, it is essential that the assessor reviews the wider
context as discussed in CLR7 (DEFRA and Environment Agency, 2002a).

3.9 The assessor is referred to TOX 7 (DEFRA and Environment Agency, 2002e) for a detailed
explanation of the derivation of the health criteria values used in this report, and the attendant
uncertainties. This is important, especially when considering the significance of any exceedance of
a Soil Guideline Value.

3.10 As noted in paragraph 3.6 the Soil Guideline Values presented here are based only on oral exposure.
The proportion of exposure attributable to each individual pathway for each standard land-use is
summarised in Table 3.3.

3.11 The Soil Guideline Values presented in Table 3.2 are for inorganic mercury compounds. The reason
for this is two-fold:

• The human toxicology of mercury differs for each of its three main forms: inorganic mercury,
organic compounds of mercury, and elemental mercury.

• There are likely to be substantial differences in fate and transport of the three forms of mercury
in the environment. In particular, elemental and methylated forms of mercury have substantial
vapour pressures that increase the likelihood of inhalation exposure. Differences in dermal
absorption are also likely to be significant.

3.12 In most soils, mercury probably occurs mainly as interchangeable associations of inorganic
mercury(II) with organic or inorganic ligands such as chloride, sulphide and humic matter (Davis
et al, 1997). The SGVs in Table 3.2 will therefore be applicable to many near-surface soils, for
which “total mercury” has been analysed. However, site-specific considerations should be given to
peaty or flooded soils, or soils amended with sewage sludge, as these more reducing soil conditions
may trigger the methylation of mercury.

3.13 Although unlikely to form naturally in near-surface soils, elemental mercury may be present as a
result of the historical use of the land by processes that used amalgam such as for millinery or chlor-
alkali production. It is therefore important to consider all available site information before testing
for mercury and prior to comparing site investigation data with this set of Soil Guideline Values.

3.14 Where it is included in the conceptual model for a specific land-use, the highest contribution to
exposure is from the consumption of homegrown vegetables, although direct ingestion of soil and
dust is also a major contributor. In other cases, the most important exposure pathway is the direct
ingestion of soil and dust (see Table 3.4). The general uncertainties in modelling exposure via these
pathways are discussed in CLR10 (DEFRA and Environment Agency, 2002d).

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Soil Guideline Values for Inorganic Mercury Contamination

Table 3.3 Contribution to total exposure from soil for the relevant pathways expressed as a
percentage of the mean exposure calculated by the CLEA model

Contribution to exposure from soil according to land-use (%)

Residential with plant

Exposure pathway
uptake and allotments Residential without Commercial
plant uptake /industrial
2.5% 5% 10%

Ingestion of soil and indoor dust 100 100

31 38 42
Consumption of homegrown 66 58 54 – –
vegetables
Ingestion of soil attached to 3 4 4 – –
vegetables
Notes

1. Soil Guideline Values derived by comparing only oral exposure routes with oral TDSI.
2. “–“ indicates that this pathway is not included in the conceptual model for the standard land-use.

3.15 Given the importance of exposure via plant uptake in the standard residential and allotment land-
uses, the assessor should carefully consider the use of these Soil Guideline Values for soils with an
organic matter content of less than 2%. Although in theory the mobility of mercury will likely
increase as the organic binding potential of soil decreases, the regression in Equation (2.1) to derive
the soil-to-plant concentration factors for leafy vegetables is not supported by any data below 2%.
It may therefore over-predict likely plant uptake. For soils with a low organic matter content, it is
recommended that the bioavailability of inorganic mercury to plants should be determined on a site-
specific basis, and further investigation (including the sampling of fruits and vegetables) is
suggested.

3.16 Inhalation of soil-derived dusts contributes less than 1% of total site related exposure for each of
the standard land-uses described in Table 3.1. However, in undertaking a site assessment, the
assessor should always consider the possibility that inhalation of dust may be a more important
exposure pathway; for example, where:

• the majority of the site is bare for long periods and dry/windy conditions prevail;

• activities such as vehicle movements increase dust generation;

• the contamination itself is present in a dry and/or dusty form.

In such cases, the assessor should estimate the risk posed by dust inhalation by carrying out a more
detailed site-specific assessment.

3.17 Guidance on using Soil Guideline Values in the presence of one or more other contaminants is given
in CLR9 (DEFRA and Environment Agency, 2002c). In general, for threshold and non-threshold
substances, chemical mixtures are only considered where effects are mediated through the same
receptor or where substances act on the same target organ or biological system. In the case of

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inorganic mercury, it is worth noting that the critical threshold effect has the kidney as its target
organ and that it is also associated with neurological effects (DEFRA and Environment Agency,
2002e).

3.18 The Soil Guideline Values presented here apply only to the protection of health from long-term
chronic exposure to contamination by inorganic mercury compounds. However, as noted in DEFRA
and Environment Agency (2002e), inorganic mercury poisoning can occur as a result of very high
single exposures in the range 700–3000 mg (the calculated range for the acute lethal dose). It would
also be anticipated that significant acute effects might occur from oral exposure below the lethal
dose. Although such levels of exposure are likely to occur rarely and only at mercury soil
concentrations substantially above the Soil Guideline Value, an assessor dealing with small hotspots
of highly elevated concentrations of inorganic mercury should always consider the potential for
acute toxicity.

Comparison with other approaches

3.19 It is essential that any comparison between the Soil Guideline Values presented in this report and
other approaches, including quantitative criteria, should be informed by reference to the conceptual
models behind each set of guidelines and taking into account the context in which they are intended
to apply. There are a number of reasons why the generic assessment criteria developed in one
country may differ from those found in another.

3.20 It is not easy to transpose technical guidance from one jurisdiction to another and to make
comparisons between the various quantitative levels set. Such guideline values may have been
developed in a different management context, depending on legislation and policy, with different
overall objectives.2 There may be subtle but significant differences between the conceptual exposure
models that take into account the different ways that people behave between countries and
differences in site conditions such as soil organic matter content, soil type and depth to water table.
The characterisation of the critical human receptor may also be quite different, and this can have
a major impact on the guidelines derived.

3.21 The Interdepartmental Committee for the Redevelopment of Contaminated Land (ICRCL) published
trigger concentrations for mercury (ICRCL, 1987). The threshold concentration for mercury for
“domestic gardens and allotments” is 1 mg kg–1 and that for “parks, playing fields and open space”
is 20 mg kg–1. The Soil Code (MAFF, 1998) reports a maximum permissible and advisable
concentration of mercury in soil of 1 mg kg–1. This value relates to the application of sewage sludge
to agricultural land and is intended to protect human and animal health from consumption of arable
crops. It is normally assumed that these values apply to all forms of mercury in soil. There is little
information available on the conceptual models that are implicit in these values, although plant


2
Such objectives might include as intervention values or as remediation standards to be applied to different current
and future uses.

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uptake is specifically considered in each case with precautionary advice for soils with a low pH. It
is difficult to compare these values further with the Soil Guideline Values.

3.22 A comparison of the Soil Guideline Values with generic assessment criteria in other countries shows
that the Soil Guideline Values tend to be significantly lower. Variations in the modelling of the plant
uptake pathway and policy considerations, such as the choice of health criteria values and exposure
and averaging period, are significant contributors to this difference.

3.23 The current Dutch integrated Intervention Value (IV) for inorganic mercury and all land-uses is 10
mg kg–1 (RIVM, 1994). This is based on the ecotoxicity IV, since the human health IV is 197 mg
kg–1. Pathways included in the human health IV are direct ingestion of soil, consumption of crops
and inhalation of soil-derived dust. The health criteria value is higher than that used in the
derivation of Soil Guideline Values and exposure is averaged over a lifetime.

3.24 Adjusting for the default soil type used in CLEA (15% clay and 2% soil organic matter), the Dutch
human health IV would reduce to approximately 166 mg kg–1, still significantly higher than the
guidelines presented in this report. While the UK aims to be protective of sensitive groups within
the population, the current Dutch Intervention Values are based on the average person. Using the
Dutch oral TDI of 0.61 µg kg–1 bw day–1, taking into account the lifetime averaging, and excluding
consideration of background exposure, the Soil Guideline Value derived using the CLEA model at
an organic matter content of 2.5% would rise to approximately 31 mg kg–1. This is still much lower
than the Dutch human health IV, the difference appearing to relate to the exposure factors used to
model consumption of homegrown produce.

3.25 It is likely that the Dutch Intervention Values will soon be changing (RIVM, 2001). The new
guidelines are termed “serious risk concentrations” (SRC) and the proposed integrated SRC for
inorganic mercury is 36 mg kg–1. Again, this is based on considerations of ecotoxicity, since the
proposed human health SRC is 210 mg kg–1, which is significantly higher than the Soil Guideline
Values in this report.3 Taking into account the new higher Dutch TDI and lifetime averaging, and
excluding consideration of background exposure, the SGV derived using the CLEA model, for an
organic matter content of 2.5%, would rise to approximately 100 mg kg–1.

3.26 The USEPA provides separate Soil Screening Levels (SSLs) for mercury via the soil ingestion and
inhalation pathways (USEPA, 1996). The SSLs were developed to “help standardise and accelerate
the evaluation and cleanup of contaminated soils at sites on the National Priorities List (NPL) with
anticipated future residential land use scenarios”. The soil ingestion SSL is 23 mg kg–1 and the SSL
for inhalation of volatiles is 10 mg kg–1 (USEPA, 1996). The notes on the ingestion SSL explicitly
state that the health criterion value used is that for mercuric chloride (that is, an inorganic mercury
compound). It is likely that the inhalation SSL relates to elemental or organic compounds of
mercury because its volatility in inorganic forms is very low under ambient conditions.


3
The Dutch apply a TDI value of 2 µg kg–1 bw day–1 for the derivation of the human health SRC for inorganic
mercury. Applying the correction for soil type or pH proposed in RIVM (2001) for the human health SRC would
not further reduce the value of 210 mg kg–1.

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3.27 The only pathway that is considered for the ingestion SSL is the direct ingestion of soil and dust.
However, a generic SSL for plant uptake is also provided within the Annexes of USEPA (1996).
This is 270 mg kg–1, and thus significantly higher than the ingestion SSL, suggesting that the plant
uptake pathway is not regarded as a major contributor to on-site exposure. The generic assumptions
within the ingestion SSL include exposure and averaging over the first six years of life and a
Reference Dose of 0.3 µg kg–1 bw day–1, the same as the value used in this report. However,
background sources of exposure are not taken into account.

3.28 Excluding the MDI, the Soil Guideline Value produced by the CLEA model, for an organic matter
content of 2.5%, would rise to approximately 10 mg kg–1, still significantly lower than the ingestion
SSL, highlighting the importance of the different approach to plant uptake.

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