ACC Comments on MCL Proposal
WASHINGTON (March 14, 2023) — Today, the American Chemistry Council (ACC) issued the following statement in response to the Environmental Protection Agency’s draft proposal for Maximum Contaminant Levels (MCLs):
“PFOA and PFOS were phased out of production by our members more than eight years ago. We support restrictions on their use globally, and we support drinking water standards for PFOA and PFOS based on the best available science.
“However, we have serious concerns with the underlying science used to develop these proposed MCLs and have previously challenged the EPA based on the process used to develop that science. We are not alone in our concerns, as others have been on the record criticizing their development. And new peer-reviewed research also calls into question the basis for EPA’s overly conservative approach to assessing one of the health endpoints.
“Importantly, the World Health Organization is also at odds with EPA on the health threshold for PFOA and PFOS. Furthermore, while we review the details, we would note that EPA has not yet evaluated two of the four chemistries included in the proposed ‘hazard index’ MCL. We will be interested to see how EPA explains its rationale for combining substances affecting different health endpoints into a single index, in violation of its own guidance1.
“The EPA’s misguided approach to these MCLs is important, as these low limits will likely result in billions of dollars in compliance costs. The proposals have important implications for broader drinking water policy priorities and resources, so it’s critical that EPA gets the science right.
“We look forward to reviewing these proposals in detail and commenting to EPA throughout the process.
“PFAS are a diverse universe of chemistries critical to renewable energy applications like solar and wind power, medical devices, the production of life-saving drugs, as well as cell phones, tablets and semiconductors, among many other uses. All PFAS are not the same and they should not all be regulated the same way.”
ACC’s Comments on EPA’s “Expensive, Ineffective, and Unworkable” CERCLA Proposal
EPA Should Not Move Forward with The Proposal Until It Has Established an Appropriate Cleanup Level Based on The Best Available Science