EPA Health Advisories Drastically Lowered for PFAS Chemicals

The Environmental Protection Agency (EPA) has taken another significant step toward addressing emerging contaminants in the nation’s drinking water supply—specifically per- and polyfluoroalkyl substances (PFAS), as the agency prepares to propose new national drinking water regulations for two specific PFAS by next year.

On June 15, the EPA issued new, non-binding drinking water health advisories—representing extremely sharp reductions compared to the prior health advisories for two PFAS, perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). The revised interim health advisories for PFOA and PFOS have been set to 0.004 parts-per-trillion (ppt) (i.e., 4 parts per quadrillion) and 0.02 ppt, respectively—much lower than the 2016 health advisory level for PFOA and PFOS, which were both set at 70 ppt.

And for the first time, final health advisories have been issued for two additional emerging contaminants, perfluorobutane sulfonate (PFBS) and hexafluoropropylene oxide (HFPO or GenX), chemicals originally introduced as replacements for PFOA and PFOS.

Interim EPA Health Advisory Levels

  • Interim updated Health Advisory for PFOA = 0.004 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

Although PFAS production and usage has declined in recent years, the chemical substances have built up in the air, soil, sediment and water resources due to their lack of degradation—impacting the drinking water supply for more than 200 million Americans, according to the Environmental Working Group.

The updated EPA advisory levels consider lifetime exposure and are based on new science, data, and draft analysis, which was released publicly in November 2021, indicating some negative health effects may occur with concentrations of PFOA or PFOS in water that are below the EPA’s ability to detect.

When sufficient evidence of potential harm and adverse health risk associated with a public utility emerges, as with this recent data, the EPA may publish health advisories to provide information regarding occurrence and exposure, toxicological effects, and impact on regulatory standards.

Although not enforceable by law, EPA health advisories provide crucial technical information to help guide actions toward addressing contamination, including monitoring, optimizing existing technologies, and implementing strategies to safeguard against future exposure before regulations take effect. More specifically, the USEPA states that, “HAs serve as the informal technical guidance for unregulated drinking water contaminants to assist federal, state, and local officials, and managers of public or community water systems in protecting public health as needed. They are not to be construed as legally enforceable Federal standards.”

Nevertheless, these actions are another step in the EPA’s PFAS Strategic Roadmap—designed to safeguard communities from PFAS pollution and to reduce and eventually remove PFAS from manufacturing and industrial facilities, landfills, and wastewater treatment plants completely.

Going forward, these actions will scientifically inform upcoming efforts, including the Safe Drinking Water Act National Primary Drinking Water Regulation for PFOA and PFOS, which is expected to be proposed in Fall 2022—with a final rule expected by the end of 2023.

The time to prepare is now.

 

Questions? Contact James Hogan at The ELAM Group: james.hogan@elamusa.com