USEPA Proposed PFAS National Primary Drinking Water Regulation - PFAS chemicals
"EPA expects that if fully implemented, the rule will prevent thousands of deaths and reduce tens of thousands of serious PFAS-attributable illnesses.”
“On March 14, 2023, EPA announced the proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA anticipates finalizing the regulation by the end of 2023. EPA expects that if fully implemented, the rule will prevent thousands of deaths and reduce tens of thousands of serious PFAS-attributable illnesses.” ~USEPA
With the goals set at 0, EPA is saying no level of PFAS exposure is safe.
My Take:
So far, more than 50,000 comments have been submitted but most of the comments (100) that are publicly posted were written by industry and trade organizations who oppose the EPA’s proposaland/or are asking for an extension. Particularly dismaying is the very substantial and organized lobby effort by the US Chamber of Commerce, municipal water systems, and municipal organizations to openly oppose efforts to make our water systems safe. For example:
"In addition, the low proposed detection levels, for these PFAS, including PFOA and PFOS send a misleading message about the real degree of known risk to members of the public – especially as compared to the known risks of other hazards. Finally, setting the levels as low as EPA has proposed would inevitably lead to diversion of resources from other water quality priorities." ~US Chamber of Commerce
Your voice matters.
There is a very organized effort to pressure the EPA to slow down and stop regulating these chemicals. We need to mount an effort on our side to ensure that this doesn’t happen. No matter how long or how short, please consider submitting comments to EPA by May 30, 2023.
No level of PFAS exposure has been proven to be safe.
While science and regulation continue to try to catch up, I do not want any of these dangerous chemicals in my water or food, or consumer products until the industry can prove they are safe. EPA’s health advisories say no level of PFAS exposure is safe and the enforcement levels should be the lowest they can be. We should not have to assume any additional level of risk to appease industry and trade organizations.
Therefore, EPA should set regulations at the limit that the labs can detect rather than the proposed 4 ppt for PFOA and PFOS each.
How to comment:
Let EPA know what you think by May 30, 2023. You may send comments, identified by Docket ID No. EPA-HQ-OW-2022-0114 by any of the following methods:
You can use the tool we created to make it super easy by clicking here!
Federal eRulemaking Portal: (our preferred method) comments can be provided at https://www.regulations.gov/commenton/EPA-HQ-OW-2022-0114-0027 under Docket ID: EPA-HQ-OW-2022-0114.
Mail: U.S. Environmental Protection Agency, EPA Docket Center, Office of Ground Water and Drinking Water Docket, Mail Code 2822IT, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
Hand Delivery or Courier: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. The Docket Center's hours of operation are 8:30 a.m. to 4:30 p.m., Monday through Friday (except Federal Holidays).
Instructions: All submissions received must include the Docket ID No. for this rulemaking. Comments received may be posted without change to https://www.regulations.gov/, including any personal information provided.
Comments must be submitted during the public comment period that ends on May 30, 2023.
Additional tips, info, and facts:
Here are some facts that might help you in your letter writing-
PFAS chemicals, once in our bodies, continue to build up with every exposure. If all further PFAS exposure is halted, the amount of time needed to reduce the PFAS concentration in the body ranges from approximately 2 to more than 15 years.[1]
For decades, we have been exposed to PFAS without our knowledge or consent from contaminated drinking water, cosmetics, sunscreens, rain jackets, Teflon pans, and food.
Babies are exposed to PFAS in utero through prenatal transplacental transfer as well as early in life. Babies often have higher serum PFAS concentrations than their mothers and increasing PFAS serum levels with longer breastfeeding duration.[2] In response, EPA has set reference doses to protect babies and young children during sensitive developmental stages.[3]
Four PFAS PFOA, PFOS, PFHxS, and PFNA were detected in 99% of serum samples from humans over 12 in the US, indicating nearly universal exposure.[4]
PFAS is an umbrella term for more than 12,000 -- or possibly as many as 21 million -- man-made chemicals.[5]
Prior research indicates that high levels of PFAS are associated with a variety of adverse health outcomes, including an increased risk of cancer.
PFAS are endocrine-disrupting chemicals (EDCs) that can disrupt hormonal balance and result in abnormalities like the delayed onset of puberty, interference with developmental hormone signaling, reproductive organ malformation, etc.[6]
Epidemiological studies that focus on potential connections between PFAS exposure and cancer are limited. Our work, published in Environmental Health Insights found that residents in southern NH who are exposed to PFAS industrial emissions experience elevated rates of certain cancers.[7]
Studies of health outcomes in 69,000 people exposed to PFOA from DuPont’s Washington Works plant in West Virginia concluded that PFOA exposure was “more probably than not” associated with testicular and kidney and renal pelvis cancers, ulcerative colitis, thyroid disease, hypercholesterolemia, and pregnancy-induced hypertension.[8]
Previous research indicates that PFOA exposure is also associated with a variety of impaired developmental outcomes, reduced vaccine response, and more severe COVID-19 outcomes.
In June 2022, EPA revised Health Advisories (HAs) for PFOA and PFOS and issued new HAs for PFOA (0.004 ppt) and 0.02 ppt for PFOS along with HAs for four additional PFAS. The new PFOA and PFOS HAs are 17,500 times lower than the prior HAs.
The 2022 HAs are below the current capabilities of laboratories to detect PFOA and PFOS, indicating that the EPA determined there is no safe level of exposure to PFOA and PFOS in drinking water which agrees with prior scientific conclusions.[9]
Analytical testing and in turn, our ability to detect and identify these manmade chemicals in our water has made significant advances. The EPA proposed limits are more than twice as high as laboratories can detect them (1 to 2 ppt) and 1,000 times higher than the EPA 2022 HA of 0.004 ppt. After decades of unknowingly being exposed to these dangerous chemicals, we need the agency to protect us, not the industry's bottom lines.
Tips for commenting on public documents here: https://www.epa.gov/dockets/commenting-epa-dockets.
(Kudo & Kawashima, 2003; Li et al., 2018; Russell et al., 2015)
(Fromme et al., 2010; Gyllenhammar, et al, 2018; Papadopoulou et al. 2016; VanNoy et al., 2018
(US Environmental Protection Agency, 2016)
(Calafat et al., 2007)
(Kim et al., 2021; US Environmental Protection Agency, 2021)
(Di Nisio et al., 2022; Tarapore & Ouyang, 2021)
(Messmer et al., 2022)
(C8 Science Panel, 2020)
(Grandjean & Clapp, 2015)
Thank you, Mindi, for this great analysis. It’s so disheartening to learn that most comments have been in favor of protecting corporations and municipalities and not people. I’m going to write a comment and ask friends to do the same, using your message as a guide. I appreciate your relentless pursuit of protecting the public from these horrible chemicals.