6/30/18
Updates on PFAS: Perfluorinated Compounds That Are Getting Much Attention

• Politics get involved.
• CDC - ATSDR releases draft PFAS Toxicological Profile.
• EPA hosts PFAS summits with states
• Meanwhile, Australian health experts find "limited, or in some cases no evidence, that human exposure to PFAS is linked with human disease."
• Meanwhile, NH continues to push ahead of other states on the PFAS issue.
• Understanding where the PFAS issue stands now...

NEBRA has been tracking the PFAS topic for 18 months, advancing awareness and understanding of what it means that there are traces of these chemicals in biosolids and other residuals. PFAS have been around for four decades or more - and in wastewater and biosolids and humans – and, in the past decade, some have been mostly phased out of use.  NEBRA's perspective, shared by other water quality groups, is that regulatory actions related to PFAS are important, but must be strategic and carefully thought out, to avoid excessive disruptions and costs for municipalities managing drinking water, wastewater, and residuals.  Recent NEBRA letters to USEPA and NEBRA's perspective fact sheet and more can be found here.

Politics get involved.

This spring, as the NH Legislature settled on one bill addressing PFAS (HB 1101 and an equivalent Senate bill), PFAS was also swept up in national partisan politics.  Since late 2017, the Centers for Disease Control (CDC) had been finalizing a draft report - an updated Toxicological Profile for four PFAS chemicals presented by ATSDR.  Professionals in the field and state agencies were aware of the report and expected its release in late spring.  Then a Politico report made the assumption that USEPA was holding up the report's release for political reasons, when, according to U.S. Environmental Protection Agency (EPA) staff, what was really happening was that EPA and the Dept. of Defense (DoD) wanted to understand and present together with CDC, in consistent terms, the findings in the CDC report, to reduce public confusion about the issue.

Soon after the Politico story, the NH delegation and others in Congress scored political points by demanding the release of the report, which CDC did on June 20th. As anticipated, the report's conclusions suggest that a lower cautionary level for PFAS in drinking water may be needed - although it does not include specific drinking water screening values and includes an abundance of hedged language that indicates that the health science is immature and the risks are not certain (Seacoast Online quoted much of this hedging language). But the media and concerned groups have quickly emphasized the idea that EPA's current public health advisory level of 70 ppt for PFOA plus PFOS in drinking water "should be seven to 10 times lower" (EWG news release).  The ATSDR report is a draft, and states, federal agencies, and other experts are currently reviewing it.  Media statements about it imply that the ATSDR report is clear on its findings. Key, experienced, scientific voices say otherwise.  A NH state epidemiologist said at the regional PFAS Summit (see below) that "they do not yet have the data to link exposure to PFAS to negative health outcomes," according to a Union Leader article. 

EPA Hosts PFAS Summits with States

On May 22 - 23, 2018 EPA held a national PFAS summit in Washington, DC, on the broad issue of PFAS in drinking water and the environment. EPA Administrator Scott Pruitt outlined a four-step plan. It includes possibly setting a maximum contaminant level (MCL) for drinking water and listing some PFAS as hazardous wastes, which would allow federal law to be applied to require those who cause PFAS contamination to pay for clean-up.

NACWA attended the national Summit as the only representatives for wastewater and biosolids management and reported...

• There were "more than 150 federal and state regulators and other stakeholders at EPA’s National Leadership Summit on Per- and Polyfluoroalkyl Substances (PFAS).....
• "Mike Lunn, Utilities Director for NACWA Member Agency the City of Grand Rapids Environmental Services in Michigan – a state that is actively engaged in the PFAS issue – and NACWA staff participated in the first day of the two-day meeting. The second day of the meeting was restricted to federal and state regulators to help EPA begin work on an action plan the Agency hopes to release by the end of the year.
• "One of the main challenges EPA will face is the fact that the PFAS family includes more than 3,000 different compounds, and for only two of these – PFOS and PFOA – has EPA developed any sort [of] advisory level. The lack of information from federal authorities – other than a drinking water advisory level of 70 ppt for PFOS and PFOA – has led several states to develop their own action levels, in some cases establishing values much lower than the federal advisory level.
• The Department of Defense participated in the Summit as well, as many of its current and former installations have contaminated surrounding drinking water supplies due in large part to the historic use of fire-fighting foams containing PFAS.
• While the Summit focused on drinking water and clean up levels, the presence of PFAS compounds in biosolids was noted a number of times throughout the discussion. In several instances, states have looked to biosolids as a “source” of PFAS compounds and are carefully considering how land application may impact the water quality in groundwater."

NACWA also noted that, at the National Summit, EPA Region 1 Administrator Alexandra Dunn was "talking about the need to proceed carefully when identifying/addressing sources and to avoid the temptation to act blindly without having all the information in terms of relative contributions, risk, etc." 

A month later, on June 25 - 26, USEPA hosted the first of several planned regional PFAS listening sessions/summits; it was held by and for Region 1, in Exeter, NH.  Some 200 people from all six New England states participated. (See WMUR's introduction and NHPR coverage.) 

Both Summits provided opportunities for citizens from communities where PFAS contamination has been most significant to voice their concerns and urge EPA and states to take action. But, as some citizens noted, their voices have been raised for some time, and actions are not coming fast enough for them.  This may be because scientists, state regulators, and EPA are stymied by the complications, uncertainties, and challenges of dealing with these chemicals, which are ubiquitous, numerous, difficult to measure, and may or may not be significant threats to human health. PFAS are almost the only chemicals of concern in the environment - and the only fairly common ones – that are being regulated at the parts-per-trillion level in drinking water.  A part per trillion (ng/kg) is equal to about 1 second in 32,000 years!  This means the science - especially the epidemiology and risk assessment modeling - are rife with uncertainties. 

Meanwhile, Australian health experts found "limited, or in some cases no evidence, that human exposure to PFAS is linked with human disease." 

That is a summary of the findings of a similar, thorough review of the health effects of PFAS by a panel of health experts advising the government of Australia.  As the Australian Health Department notes:

• "It is not practically possible to prevent all PFAS exposure due to the large number of sources from which people may still get very low exposures. Internationally, everyone generally has low levels of PFAS chemicals in their blood."
• There are several commonly noted health effects of some PFAS, but, for these health effects, "the Panel concluded that many of the biochemical (for example, higher cholesterol and uric acid levels in the blood) and disease links reported in the studies may be able to be explained by reverse causation or confounding."
• "For cancer, the Panel concluded there is no current evidence that suggests an increase in overall cancer risk."

• "The Panel’s advice to the Minister on this public health issue is that the evidence does not support any specific health or disease screening or other health interventions for highly exposed groups in Australia, except for research purposes."

The Australian Chief Medical Officer went on to say:

• "The panel’s report has been provided to the National Health and Medical Research Council (NHMRC) and it will be used to inform the $12.5 million National Research Program into the Human Health Effects of Prolonged Exposure to PFAS. 
• "When reviewing the panel’s report, it is important to understand the difference between an association and causation. An association indicates a relationship between one thing measured and another — in this case, PFAS exposure and an adverse health outcome. Causation means that the thing measured directly causes a change in the other."

Read the Australian health experts' report.

(This June Australia news story shows the controversy in Australia and refers to Minnesota and the U. S. controversy.)

The hedging language of the U.S. ATSDR report and the Australian report are more similar than not.  There is considerable uncertainty.

Meanwhile, NH continues to push ahead of other states on the PFAS issue.

To date, New Hampshire has been one of a few states (others are MI, MN, NJ, VT) taking aggressive measures to understand and address PFAS concerns.  All are stymied by the complications of the PFAS issue.  The NH Department of Environmental Services (NH DES) provided updates about its efforts at an air and water regulatory conference coordinated with NH Business and Industry on May 31st in Manchester.  NH DES Commissioner Scott's introductory slides, and slides of DES PFAS investigator Brandon Kernen, can be seen here, along with slides of the panel that discussed all angles of the PFAS issue (includes a slide by NEBRA).  As he had done at the national PFAS Summit in Washington in May, Mr. Kernen mentioned wastewater and biosolids as sources of PFAS. NEBRA urged a more accurate perspective: wastewater and biosolids convey PFAS that are in our daily living environments.  Other scientists speaking at the conference raised concerns about jumping too quickly to conclusions about human health impacts and fate and transport of PFAS in soils and waters in the environment. NEBRA's concerns are expressed in this slide. 

Other states in this region have taken different approaches from that of NH. Most are going more slowly, understanding the uncertainties, as well as the potential for unintended, disruptive consequences of rushed regulatory actions.

Understanding where the PFAS issue stands now...

While PFAS has become a well-known issue in some of the environmental field, it is still not front and center for most people. While individuals and groups of citizens, state regulatory agencies, and associated consultants have been working for more than two years on the issue - especially around highly-contaminated sites (e.g. Pease International Tradeport, Merrimack NH, Hoosick Falls NY, No. Bennington VT) – much of the media coverage is still just introducing the topic and there is little depth in media and public understanding.  For example, even in NH, where the issue has been a high priority for NH DES, NHPR continues to introduce the topic of PFAS fairly simplistically (for example, listen to The Exchange discussion that aired July 2nd). 

And, even as the media and public are starting to learn about the issue, NH DES and other agencies are finding more and more challenges and complications daily: new sites with high PFAS from fire-fighting training, car washes, and more; a wider variety of PFAS chemistries to think about; and more challenges with analysis and understanding the fate and transport of PFAS.

As has happened with concerns raised about other trace contaminants conveyed in wastewater and biosolids, after initially jumping to conclusions that traces in biosolids must be a concern, regulators and experts are beginning to realize that, with PFAS too, sources and human exposures are far greater in our daily lives, and biosolids are rarely a significant route of potential exposure. Wastewater and biosolids convey PFAS and other traces of contaminants. They reflect the chemistry of modern living, but they generally do not contribute to exposure in any significant way. Still, more research is needed with regards to PFAS in wastewater and biosolids.

It is notable that, in the EPA Summits, one of the key agenda items has been risk communications.  EPA and states recognize that communicating the PFAS topic and achieving an appropriate level of public concern is important.  Yes, PFAS is an issue to address, especially at sites with direct industrial and military discharges creating very high levels in drinking water.  But risk from PFAS is not as great as risk from such long-known threats as lead, mercury, arsenic, and radon.  More risk communications are needed.  The gap between how experts view the complexity of PFAS issues and the simplicity expressed by some concerned citizens and the media seems to be widening, which could make it more difficult to find responsible, balanced policies and actions. A test of this will come when NH DES begins developing new water quality standards later this year, as required by the Legislature. Stakeholders with widely divergent perspectives are likely to be involved. NH DES staff will be caught in the middle and will have to carefully focus on and communicate the science and relative risk.

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NEBRA has proactively engaged in the PFAS issue since January 2017, providing fact sheets, guidance, presentations, research proposals, and a NEW PFAS & biosolids literature review & bibliography to advance knowledge and inform policy.  NEBRA members have access to all these materials on the members' only page (contact the NEBRA office for password).