PFAS Health Advisory Announced

After years of delay, last week at the 3rd National PFAS Conference in Wilmington, North Carolina the U.S. Environmental Protection Agency (EPA) in the person of Assistant Administrator Water Radhika Fox announced updated interim health advisory levels for four compounds in drinking water that are part of a group of compounds called PFAS (per- and polyfluoroalkyl substances). In February 2021 the EPA had made the final determinations to regulate perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) in drinking water. These regulations are now expected in fall 2022.

These substances have been used in industrial settings and production of consumer products like non-stick pans, waterproof clothing, and fire suppression foams since the 1940s. The concern is that PFAS generally break down very slowly, meaning that concentrations can accumulate in people, animals, and the environment over time.

Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS) are two of the most widely used and studied chemicals in the PFAS group. PFOA and PFOS have been replaced in the United States with other PFAS in recent years. In chemical and product manufacturing, GenX chemicals are considered a replacement for PFOA, and perfluorobutane sulfonate (PFBS) is considered a replacement for PFOS. The revised health advisory levels focus on these four chemical compounds: PFOA, PFOS, GenX, and PFBS.

• Interim updated Health Advisory for PFOA = 0.004 parts per trillion (ppt)
• Interim updated Health Advisory for PFOS = 0.02 ppt
• Final Health Advisory for GenX chemicals = 10 ppt
• Final Health Advisory for PFBS = 2,000 ppt

The interim updated health advisories for PFOA and PFOS are based on human studies in populations exposed to these chemicals. Human studies have found associations between PFOA and/or PFOS exposure and effects on the immune system, the cardiovascular system, human development (e.g., decreased birth weight), and cancer.

The final health advisories for GenX chemicals and PFBS are based on animal studies following oral exposure to these chemicals. GenX chemicals have been linked to health effects on the liver, the kidney, the immune system, and developmental effects, as well as cancer. PFBS has been linked to health effects on the thyroid, reproductive system, development, and kidney.

Drinking water health advisories provide information on contaminants but are non-enforceable and non-regulatory and generally provide technical information to states agencies and other public health officials on health effects, analytical methods, and treatment technologies associated with drinking water contamination.

EPA plans to propose a PFAS National Drinking Water Regulation in fall 2022. As EPA develops this proposed rule, the agency is also evaluating additional PFAS beyond PFOA and PFOS and considering actions to address groups of PFAS.

As part of a government-wide effort to confront PFAS pollution, EPA is making available $1 billion in grant funding through President Biden’s Bipartisan Infrastructure Law to help disadvantaged communities and communities facing disproportionate impacts reduce PFAS in drinking water. EPA is making $1 billion available in FY2022 and a total of $5 billion for fiscal years 2022-2026.

According to the American Chemistry Council, an industry trade group, these new levels cannot be achieved with existing treatment technology and, in fact, are below levels that can be reliably detected using existing EPA methods. This could be a significant problem with the proposed regulation and protecting public health if the level of detection in the method of analysis does not meet the level of sensitivity necessary to implement the interim standard.

We may have a local problem that could be very expensive to fix. In 2021 the Environmental Working Group (EWG) tested tap water samples from throughout Northern Virginia looking for a group of PFAS. They took samples from the tap water in 19 locations and found PFOA present in all 19 locations above the interim guidelines and PFOS present at 18 of the 19 samples above the interim guidelines. Though there were some samples with QC/QA issues and the work should be confirmed, the preponderous of the limited evidence is that the water supplied by Fairfax Water has contamination above the interim updated health advisories for PFOA and PFOS. The full results from the EWG can be found here.