May 28, 2024
Docket No. EPA-HQ-OW-2023-0580
We appreciate the opportunity to comment and support EPA’s proposed rule regarding: “POTW Influent PFAS Study Data Collection”
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and products are most effective for which patients and consumers. We do not accept funding from companies that have a financial interest in the subjects of our work, so we have no conflicts of interest.
We strongly support the EPA’s intention to collect national concentration data on contaminants found in sewage sludge and biosolids as it relates to the amount of per- and polyfluoroalkyl substances (PFAS) discharged to surface waters and publicly owned treatment works (POTWs). PFAS, commonly known as “forever chemicals” can easily travel in water, enter and accumulate in the water supply and soil around these factories or anywhere that the factories dump the chemicals. A 2016 study found that the drinking water of over 6 million Americans contains PFAS at higher levels than the EPA recommends is safe and in 2023 an environmental study found that 30% of U.S. tap water contains PFAS.1
Data collection of PFAS contaminants in surface waters and POTWs is vital to the mission of the EPA and an essential step toward reducing the health risks of PFAS in our environment. When researchers compared the health of people with high PFAS exposure to people who have an average level of exposure, they found that the people with higher PFAS exposure are more likely to develop testicular cancer, kidney cancer, liver disease, heart disease, and developmental delays.2 3 Pregnant women who were exposed to more PFAS had an increased likelihood of preeclampsia during pregnancy (a condition that can be life-threatening to the mother and baby) and of having babies with a low birth weight.2 Children whose mothers were exposed to higher levels of PFAS while pregnant had poorer health outcomes through age 10, including increased rates of infection. Vaccines could also be less effective for the people exposed to higher levels of PFAS, because they have a weaker immune response to vaccines.2 3 Research also indicates that people who are exposed to high levels of PFAS at work or who live close to water processing plants or factories with industrial runoff that contains PFAS have higher levels of PFAS in their bodies and therefore that exposure can harm their health and the public health.4 EPA needs the information proposed to better ascertain the risk of PFAS contamination to surrounding communities. These risks can result from direct exposure to PFAS chemicals or exposure to contaminated drinking water and soil in homes, neighborhoods, and communities. This data collection is a step in the right direction to help the EPA to better understand sources of PFAS contamination in water sources used by the public. The agency should use its power to help protect consumers by keeping industry accountable for unsafe levels of PFAS that are released into the environment. Such data will also help to inform future management of waste materials to ensure that PFAS are being effectively removed from wastewater and other water sources.
Regarding EPA’s POTW Influent PFAS Study design, we support the EPA plan to collect mandatory questionnaires from the 400 POTWs with the highest flow rates in the U.S.; however, we believe that all 400 POTWs should be required to participate in the two-phase sampling program instead of selecting 200-300 POTWs from the original 400 for sampling purposes. If the EPA decides to move forward with their initial plan to select 200-300 of the 400 POTWs, the methodology for selecting the POTWs should be made public. We also urge that the EPA not limit the number of facilities that will be sampled to 2,000 separate facilities. If the EPA plans to sample 10 industrial users per POTW, then the EPA should expect to sample at least 4,000 different facilities.
The proposed EPA study design would test for only 40 specific PFAS and adsorbable organic fluorine (AOF). There are thousands of known PFAS chemicals, with the potential risks of toxicity unknown for many of these substances.5 Limiting this study to only 40 specific PFAS would be a great disservice to the breadth of data that can be collected through this proposed investigation.The EPA should work with stakeholders and academic researchers to expand sample collection to test for AOF as well as all known PFAS chemicals for which testing is available. If the EPA chooses to limit the number of PFAS chemicals they test for in their sampling, they should provide the inclusion and exclusion criteria for the specific PFAS they choose to test for and all reports should clearly state which PFAS chemicals were tested and which were not as well as their implications for public health.
Gathering this data is a crucial step toward managing PFAS in waste and waterways, given the significant health risks these chemicals pose. This initiative will enhance our understanding of PFAS contamination sources, hold industries accountable for environmental discharges, and inform future waste management strategies to ensure effective removal of PFAS from wastewater, ultimately protecting public health and the environment. Given that PFAS chemicals are ubiquitous and harmful, the benefits of this plan outweigh any burden on those who must comply. While we commend the EPA for its proactive approach, we emphasize the importance of the EPA requiring more comprehensive data collection through this study in order to reduce harmful exposures for adults and children across the country.
[1] Hu XC, Andrews DQ, Lindstrom AB, Bruton TA, Schaider LA, Grandjean P, Lohmann R, Carignan CC, Blum A, Balan SA, Higgins CP. Detection of poly-and perfluoroalkyl substances (PFASs) in US drinking water linked to industrial sites, military fire training areas, and wastewater treatment plants. Environmental Science & Technology Letters. 2016;3(10):344-50.
[2] Smalling et al. “Per- and polyfluoroalkyl substances (PFAS) in United States tapwater: Comparison of underserved private-well and public-supply exposures and associated health implications.” Environmental International. 2023
[3] Agency for Toxic Substances and Disease Registry. Toxicological Profile for Perfluoroalkyls. U.S. Department of Health and Human Services; 2021
[4] What Are PFAS Chemicals and Why Are They Dangerous? (2021, October 25). National Center for Health Research. https://www.center4research.org/what-is-pfas-health-risks/
[5] Zheng G, Schreder E, Dempsey JC, Uding N, Chu V, Andres G, Sathyanarayana S, Salamova A. Per-and Polyfluoroalkyl Substances (PFAS) in Breast Milk: Concerning Trends for Current-Use PFAS. Environmental Science & Technology. 2021 Jun 1. to industrial sites, military fire training areas, and wastewater treatment plants. Environmental Science & Technology Letters. 2016;3(10):344-50.