EPA Yet Again Fails to Set Health-Protective Levels for PFAS
By Anna Reade, Natural Resources Defense Council
Yesterday the U.S. Environmental Protection Agency (EPA) released draft interim recommendations for addressing groundwater contaminated with PFOA and PFOS, just two of a class of approximately 4,700 chemicals of health and environmental concern. It recommended:
- Screening level (level over which a potential contamination site should be investigated further) of 40 parts per trillion (ppt) for PFOA and PFOS, individually
- Preliminary remediation goal (target for groundwater cleanup) of 70 ppt for PFOA and PFOS combined
These levels are disappointingly high and based on the EPA’s lifetime health advisory for PFOA and PFOS in drinking water set in 2016. According to the EPA, “This guidance is based on EPA’s current scientific understanding of the toxicity of PFOA and PFOS and is consistent with other relevant EPA guidance.” However, several states and federal agencies have since determined that the 2016 health advisory is not health-protective and have proposed stricter standards or guidelines for drinking water and groundwater.
The federal Agency for Toxic Substances and Disease Registry (ATSDR), part of the Centers for Disease Control and Prevention (CDC), released a report in the summer of 2018 which proposed health thresholds for PFOA and PFOS approximately 10 times lower than EPA’s health threshold (reference dose) used to generate its health advisory for drinking water.
More recently, the Michigan PFAS Science Advisory Panel found that a person exposed to 70 ppt of PFOA in their drinking water would have a blood serum level of PFOA in the same range as the blood serum levels where adverse health effects have been observed in human studies, such as the C8 study in West Virginia. Therefore, the Panel concluded that, “the research supports the potential for health effects resulting from long term exposure to drinking water with concentrations below 70 ppt.”
Some states facing PFAS contamination crises, including Michigan, New York, New Jersey, Vermont, California, Massachusetts, and Minnesota, are not waiting for the EPA to act. These states are performing more comprehensive monitoring for PFAS and/ or proposing lower drinking water, groundwater or hazardous waste cleanup standards or guidelines:
Yesterday the U.S. Environmental Protection Agency (EPA) released draft interim recommendations for addressing groundwater contaminated with PFOA and PFOS, just two of a class of approximately 4,700 chemicals of health and environmental concern. It recommended:
- Screening level (level over which a potential contamination site should be investigated further) of 40 parts per trillion (ppt) for PFOA and PFOS, individually
- Preliminary remediation goal (target for groundwater cleanup) of 70 ppt for PFOA and PFOS combined
These levels are disappointingly high and based on the EPA’s lifetime health advisory for PFOA and PFOS in drinking water set in 2016. According to the EPA, “This guidance is based on EPA’s current scientific understanding of the toxicity of PFOA and PFOS and is consistent with other relevant EPA guidance.” However, several states and federal agencies have since determined that the 2016 health advisory is not health-protective and have proposed stricter standards or guidelines for drinking water and groundwater.
The federal Agency for Toxic Substances and Disease Registry (ATSDR), part of the Centers for Disease Control and Prevention (CDC), released a report in the summer of 2018 which proposed health thresholds for PFOA and PFOS approximately 10 times lower than EPA’s health threshold (reference dose) used to generate its health advisory for drinking water.
More recently, the Michigan PFAS Science Advisory Panel found that a person exposed to 70 ppt of PFOA in their drinking water would have a blood serum level of PFOA in the same range as the blood serum levels where adverse health effects have been observed in human studies, such as the C8 study in West Virginia. Therefore, the Panel concluded that, “the research supports the potential for health effects resulting from long term exposure to drinking water with concentrations below 70 ppt.”
Some states facing PFAS contamination crises, including Michigan, New York, New Jersey, Vermont, California, Massachusetts, and Minnesota, are not waiting for the EPA to act. These states are performing more comprehensive monitoring for PFAS and/ or proposing lower drinking water, groundwater or hazardous waste cleanup standards or guidelines:
| State | Threshold | PFOA | PFOS | Other PFAS chemicals |
| Michigan | Screening level | 9 ppt | 8 ppt | PFNA (9 ppt), PFHxS (84 ppt), PFBS (1000 ppt) |
| New York | Proposed MCLs | 10 ppt | 10 ppt | |
| New Jersey | Proposed MCLs | 14 ppt | 13 ppt | PFNA (13 ppt – FINALIZED MCL) |
| California | Notification level | 14 ppt | 13 ppt | |
| Minnesota | Guidance level | 35 ppt | 15 ppt | PFHxS (47 ppt) |
| Vermont | Proposed MCL | 20 ppt for the sum of 5 PFAS, including PFOA and PFOS | ||
| Massachusetts | Waste cleanup | 20 ppt for the sum of 6 PFAS, including PFOA and PFOS | ||
* MCL – maximum contaminant level, an enforceable standard for drinking water
Equally concerning is the EPA’s continued focus on PFOA and PFOS, just two members of this large class of synthetic chemicals, known as PFAS (per- and polyfluoroalkyl substances).
PFAS chemicals have been used for decades to provide non-stick, stain- and water-resistant properties to products such as carpet, furniture, cookware, and food packaging. They are also used in fire-fighting foams and industrially as surfactants, emulsifiers, and coatings. Although the class is broad, they are related in their extreme persistence and mobility in our environment and potential to cause health harm. They are often referred to as “forever chemicals” because they don’t breakdown. They are now found in the blood of virtually all Americans and in the drinking water serving millions of people across the nation. Unfortunately, they have been linked to many harmful health effects, including cancer, immune system disfunction, liver damage, hormone disruption, low birth weight, and reproductive harm, some of which can occur at extremely low doses.
Mounting evidence linking other PFAS chemicals to human health harms, combined with concerns over their similar environmental mobility and persistence and widespread human and environmental exposure, have led independent scientists and other health professionals from around the globe to express concern about the continued and increasing production and release of PFAS (examples include Helsingørstatement, Madrid statement, and journal articles).
The CDC and some states have determined there is enough data to support thresholds for other PFAS, and Vermont and Massachusetts are proposing to regulate multiple PFAS under a combined (or summed) threshold due to their chemical similarity and potential to target the same biological systems.
Based on these impacts and the best available science, NRDC recently has completed a scientific report urging strict, health-protective drinking water and groundwater standards for 5 specific PFAS, and a treatment technique requirement using state of the art treatment for total PFAS. Specifically, NRDC recommends a drinking water and groundwater standard of 2 ppt for PFOA, PFOS, PFHxS, and PFNA; a 5 ppt standard for GenX, and a treatment technique for total PFAS of reverse osmosis or the equivalent.
EPA has failed to carry out its duty by proposing groundwater cleanup and screening levels that will not protect the public. NRDC will submit comments based on our recommendations urging the EPA to set protective cleanup standards for our groundwater. We also urge citizens to comment by June 10th, 2019 to EPA and point out that the CDC and numerous states have found that EPA’s 70 ppt cleanup level and 40 ppt screening level for PFOA and PFOS are far too high. EPA’s proposal would leave Americans across the country who live near contaminated sites unprotected from potentially dangerous levels of these toxic forever chemicals.