The Water & Health Advisory Council recently submitted comments to the U.S. Environmental Protection Agency (EPA) in response to the agency’s proposal to reconsider portions of the National Primary Drinking Water Regulation (NPDWR) for PFAS. Specifically, EPA has proposed rescinding regulatory determinations for PFHxS, PFNA, HFPO-DA (GenX), and the Hazard Index mixture while maintaining the drinking water standards for PFOA and PFOS and extending compliance deadlines for public water systems.
The Council’s comments reinforce its longstanding view that drinking water regulations should be grounded in sound science, achieve meaningful public health benefits, and account for the financial and operational realities facing drinking water systems. As EPA continues evaluating the proposal, the Council highlighted several considerations it believes remain central to the discussion.
Key Considerations
Science-Based Decision Making
The Council encourages EPA to continue grounding drinking water regulations in the best available occurrence, toxicity, and implementation data while recognizing that scientific understanding continues to evolve. Science-based, risk-informed decision making remains fundamental to ensuring regulations provide meaningful public health protection.
Meaningful Public Health Risk Reduction
The Safe Drinking Water Act is designed to achieve measurable public health benefits. The Council emphasized the importance of ensuring that regulatory decisions continue to prioritize actions that provide meaningful reductions in public health risk.
Practical Implementation
For many drinking water systems, particularly small and disadvantaged communities, new treatment requirements can present significant financial, technical, and operational challenges. The Council encouraged EPA to continue considering implementation feasibility alongside public health objectives as the rulemaking moves forward.
Risk Prioritization
The Council also noted that drinking water systems face multiple public health and infrastructure challenges simultaneously. Prioritizing limited resources toward actions that deliver the greatest overall public health benefit remains an important consideration as EPA continues implementing the Safe Drinking Water Act.
Looking Ahead
EPA’s reconsideration reflects broader discussions about how drinking water policy can best protect public health while supporting safe, reliable, and affordable water systems. As implementation continues to evolve, the Water & Health Advisory Council remains committed to serving as a science-based resource on drinking water policy, implementation, and the future of the Safe Drinking Water Act.
Read the Water & Health Advisory Council’s full comments to EPA