We advocate a risk-based approach to identifying, addressing and prioritizing the challenges associated with delivering safe drinking water, including emerging contaminants.
We have seen that the Environmental Protection Agency (EPA) has announced the much-anticipated PFAS maximum contaminant level (MCL) proposed regulations. Our nation’s water systems have limited resources, funding, and operational capacity. We hope to find the following emphasis from the EPA in the proposed MCL and urge lawmakers to consider a science-based approach to the regulation of PFOA and PFOS which might include:
- More Robust Occurrence Data: More occurrence data is needed to determine where high-concentration areas of PFOS/PFOA exist nationally. There are regions in the U.S. that face high PFOS/PFOA concentrations, and those communities require immediate action and response. However, regulating on a national level must be based on accurate and current national occurrence data. A one-size-fits-all approach will require water systems to regularly monitor, test and invest millions of dollars and staffing to address contaminants that may not be impacting their community.
- More Substantial Epidemiological and Toxicity Data: Based on the current epidemiological and toxicological data available, regulating PFOA and PFOS does not represent a meaningful opportunity for health risk reduction as defined by previously regulated contaminants. The Meaningful Opportunity for Health Risk Reduction is an essential mandate of the Safe Drinking Water Act, and we believe it must be considered as policymakers deliberate on this proposed rule.
- A Careful Assessment of Cost and Impact: A handful of known microbial or naturally occurring contaminants present the greatest threats to our drinking water systems, and we must prioritize funding to the areas of highest need. Some communities require swift remedial action to address unacceptable levels of PFOA and PFOS in their drinking water supply, while many others do not. As we evaluate this national standard, the financial impact on local water systems that do not have a threat of these substances in their systems must be carefully considered. We have great concern that such national standards will shift funding priorities away from known threats impacting public health, such as failing and aging water infrastructure and protections against microbial contaminants.
- International Standards: The World Health Organization (WHO) recently released their PFAS guidelines, and these values are 25,000 and 5,000 times higher than the proposed EPA HAs. We commend the WHO for tackling this complex issue with a thoughtful and balanced assessment of the available data and arriving at a reasonable and practical conclusion. It reflects the conclusions that most countries have reached on PFAS chemicals, and we believe the EPA should consider these international guidelines in their approach.
- Prioritize the Highest Risks: Water systems protect our citizens from hundreds of threats to drinking water safety daily. It is essential to consider PFOA/PFOS regulations in context with the known threats to our drinking water, such as: microbial contamination, decaying water distribution systems infrastructure, and underfunded small systems.
The Safe Drinking Water Act calls on our nation’s leaders to take effective steps towards ensuring a safe, affordable, and reliable drinking water supply for everyone. We ask that policymakers continue to apply a science-based, risk- and cost-benefit analysis when approaching regulating PFOA / PFOS.
Sincerely,
Water & Health Advisory Council
