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What They’re Saying: Experts and Policymakers Voice Concern Over Revised Health Advisories

Tom Flanagin

ACC recently filed a petition in D.C. Circuit Court challenging the Environmental Protection Agency’s (EPA) revised Lifetime Health Advisories (LHAs) for PFOA and PFOS.  These LHAs will have sweeping implications for policies at the state and federal levels. Getting the science right is of critical importance, and ACC has an obligation to challenge these advisories based on the underlying science and the flawed process.

But we’re not the only ones raising concerns with these advisories and the science behind them. 

For instance, the EPA’s Science Advisory Board recently held a meeting  on the science used to develop these advisories. Here were some of their key takeaways:

Dr. John Morris, chartered SAB member -

  • “If I was writing this as a review of a manuscript for a paper I would check the reject box - not the accept pending revisions.”
  • “These are significant problems that really can't be fixed.”

Dr. Jonathan Samet, chartered SAB member -

  • “There [is] a need to start over in a sense.”
  • “There are broad problems - this is not the state of practice.”
  • “If things move forward on a rapid timetable, we know that the document is not perfect and I don't see things that can be fixed.”
  • “The SAB considers these supporting documents to have methodological flaws that could undermine the rulemaking process and urges that these problems be addressed with revisions that represent state of the practice for gathering and using evidence for decision making.”

The EPA’s Science Advisory Board isn’t alone in raising concerns either. Consider these statements from key policymakers and the water community:

  • U.S. Senator Shelley Moore Capito (R-W.Va.), Ranking Member of the Senate Environment and Public Works (EPW) Committee: “I am extremely disappointed EPA has decided to act so radically and rashly on such a bipartisan issue. Let’s be clear: No technologies exist for water systems to detect PFOA and PFOS contamination at the infinitesimal levels EPA has set in its proposed lifetime health advisory levels. EPA’s announcement will only increase confusion for water systems’ compliance efforts and further complicate risk communication to the public. Setting these impossible levels misleads the public into thinking their water isn’t safe, even when that may not be true.
  • American Water Works Association (AWWA): “The PFOA and PFOS advisory levels are extremely low and do not reflect the draft recommendations of EPA’s own expert Science Advisory Board review. The health advisory levels at parts per quadrillion, undetectable by modern laboratory methods.”
  • AWWA in Bloomberg: “The health advisories are worrying water utilities nonetheless because the EPA is effectively telling the public that their water may be unsafe even if PFOA and PFOS can’t be measured, said Steve Via, director of federal relations at the American Water Works Association.”
  • Environmental Council of the States (ECOS): “Today's announcement of the Health Advisory Levels for four PFAS in drinking water raises some concern among state officials about impacts on EPA's upcoming enforceable, science-based regulations that will be required to take feasibility, costs, and benefits into account.
  • The Water and Health Advisory Council – “We strongly believe that the EPA must issue drinking water health advisories and regulations that align with the Safe Drinking Water Act and are based on the best science to address the greatest risks to public health. . . EPA’s actions run the risk of misleading the public and misallocating limited resources that could be better spent addressing more pressing drinking water risks. Our nation’s drinking water funding must continue to be directed to the areas of greatest public health concern. Communities with high levels of PFOA/PFOS in their drinking water must be immediately addressed, and we commend the EPA for issuing state-specific Infrastructure Investment and Jobs Act (IIJA) funding to address those communities in need. However, these extremely low health advisory levels are based on limited science and will impact drinking water utilities across the nation, even where PFOA/PFOS may not be a public health concern. With limited financial resources, water utilities must prioritize and address the greatest risks to public health. We urge the EPA to provide clear and actionable direction to water utilities and consider a cost-benefit and risk analysis when determining PFAS regulations.”

ACC supports the development of drinking water standards for PFAS based on the best available science. However, EPA’s revised LHAs for PFOA and PFOS reflect a failure of the Agency to follow its accepted practice for ensuring the scientific integrity of its process. We hope our challenge leads to science-based policies that are protective of human health and the environment.

American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.

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