Authors: Emily Larson, Elizabeth Denly, & Catriona Smith | juin 24, 2022
On June 15, 2022, the U.S. Environmental Protection Agency (EPA) released updated Health Advisory (HA) Levels for four per- and polyfluoroalkyl substances (PFAS) in drinking water, replacing the HAs that EPA previously issued in 2016. HA Levels are non-regulatory, non-enforceable, chemical-specific drinking water levels where exposure at or below is not anticipated to cause adverse human health effects. This action is in accordance with EPA’s PFAS Strategic Roadmap and is in support of EPA’s development of the National Primary Drinking Water Regulation (NPDWR) for PFAS.
The new PFAS HAs are shown below for the four PFAS including, perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorobutane sulfonic acid (PFBS) and hexafluoropropylene oxide dimer acid (HFPO-DA) and its ammonium salt (known as “GenX” chemicals). Additionally, the current lowest analytical reporting limit (the lowest concentration that current analytical technology can accurately report) is also included in the table for reference.
Chemical | Minimum Reporting Limit (ppt) | 2016 EPA Health Advisory Level (ppt) | 2022 EPA HAL (ppt) |
---|---|---|---|
PFOA | 4 | 70 (individual and combined) | 0.004 (Interim) |
PFOS | 4 | 0.02 (Interim) | |
GenX Chemicals | 5 | NA | 10 (Final) |
PFBS | 3 | NA | 2,000 (Final) |
ppt = parts per trillion (nanograms per liter) |
Interpreting the HA Values:
- PFOA/PFOS HAs are interim levels; associated health effects assessments for each chemical are in draft form
- GenX/PFBS HAs are final levels
- Any detection of PFOA/PFOS can be inferred as an exceedance of the interim HAs
- It’s confusing to impose criteria that cannot be measured; with the ubiquitous nature of PFAS and the potential for cross-contamination, it is currently impossible to measure PFOA and PFOS down to these low levels
- It’s confusing to impose criteria that cannot be achieved by current specialized waste treatment technologies
- The 21 states listed below that adopted, use or plan to use the previous EPA HA of 70 parts per trillion (ppt) for PFOA and PFOS may have to determine if they will implement the new levels; however, since these are interim values, that shift may be premature:
- Alabama, Alaska, Arizona, Colorado, Delaware, Florida, Idaho, Iowa, Kansas, Kentucky, Missouri, Montana, Nebraska, New Mexico, Ohio, Pennsylvania, Rhode Island, Tennessee, Virginia, West Virginia, Wyoming
Why are the PFOA/PFOS Values So Low?
There are three main input factors that contribute to the derivation of the interim HAs:
- The noncancer Reference Dose (RfD) – the toxicity value that establishes the “safe level” for ingestion of a contaminant
- The Relative Source Contribution (RSC) – the portion of an individual’s total exposure to a contaminant that is attributed to drinking water ingestion
- Body Weight-Adjusted Drinking Water intake (DWI-BW) – exposure factor for the liters of water an individual consumes per day normalized to body weight
For both PFOA and PFOS:
- RSC = assumed 20% of exposure is through drinking water (80% other sources)
- RfD = derived from the epidemiological study showing decreased serum antibody concentration in children (suppression of vaccine response)
- DWI-BW = a standard USEPA exposure factor that was based on the receptor (5-year-old) in the epidemiological study used to derive the RfD
While the RSC and the DWI-BW are standard values that are generally viewed as reasonable, the derivation of the RfD is subject to criticism with only a single epidemiological study as the basis. One of the many recommendations from the SAB in their April 2022 release of its review of the PFOS/PFOA toxicity assessment, was that the EPA should consider multiple human and animal studies for various endpoints to provide convergent evidence that is more reliable than a single study or health endpoint.
Additional Information
- With the release of the interim HAs, EPA also released $1 billion in grant funding (part of President Biden’s Bipartisan Infrastructure Law) for general technical assistance, water quality testing, contractor training and installation of treatment technologies to help reduce PFAS in drinking water in small or disadvantaged communities facing disproportionate PFAS impacts
- A cancer-based toxicity value (cancer slope factor [CSF]) will be developed for PFOA as part of the NPDWR
- The proposed NPDWRs for PFOA/PFOS are anticipated to be released in fall 2022 with finalization in fall 2023
- The current HALs do not incorporate the SAB’s most recent recommendations
- According to the EPA PFAS HA webinar on June 23, 2022, if the EPA revises the HAs, they do not anticipate the new levels to exceed the Method Detection Limit (MDL) for PFOA/PFOS
Don’t Panic: Key Considerations
- EPA’s release of unattainable chemical values is not unprecedented; in 2000, the EPA proposed an arsenic MCL that needed to be reassessed, then was eventually doubled, due to a national debate surrounding the science and costs associated with the ruling
- Before the EPA can finalize the HAs and subsequently the Maximum Contaminant Level (MCL) for PFOA/PFOS, they will have to address the Science Advisory Board’s (SAB’s) numerous suggestions
- EPA reassures that these HAs are subject to change and also acknowledges that the interim values may be updated or removed altogether
- A proposed impending MCL will consider both the science (toxicity and treatment technology) and the economics and will likely be higher than the HAs
In the meantime, calming public concern and addressing public confusion will be at the top of state and municipality agendas.
For more information on managing PFAS at your facility and public outreach efforts, please contact:
Elizabeth Denly, ASQ CMQ/OE Vice President, PFAS Initiative Leader & Chemistry Director
Catriona V. Smith, R.E.M. Vice President
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The Biden Administration signals both a renewed and accelerated focus on climate change.
EHS Due Diligence in 2022
Décembre 7, 2020
Some of observations and trends in the EHS due diligence market since the beginning of the pandemic.
TRC Announces Collaboration with Greenstone Reinforcing Integrated ESG, Sustainability and Climate Risk Solutions
juin 26, 2020
The dominant trend in improving the efficiency and profitability of the logistics and supply chain industry will continue to be achieved through automation. Environmental, social and governance (ESG) issues can be important considerations for investments in this sector due to potential reputational risks for the acquiring entity. Key issues include negative publicity surrounding the perception of job elimination, as well as the procurement of specialty materials required to produce batteries and other components of autonomous robots. The recycling or responsible disposal at the end of the life of the product is also a key focus especially in Europe. TRC was asked to provide ESG risk screening for a foreign auto manufacturer’s investment in a U.S.-based autonomous robotics company. A two-step approach was taken to access the risks associated with this target. The first step evaluated the inherent risks of the target company’s sector based on its geographical spread and operations using public information like the Sustainability Accounting Standards Board (SASB) and the CDC Investment Works Toolkit. The second step involved deeper analysis of ESG risk assessments & insights based on a review of specific controls that the company uses to manage its risks. This included a questionnaire, reviewing company documents and programs, and interviewing company representatives.
COVID-19 and Implications for ESG Investing
juin 3, 2020
This global pandemic has exposed business vulnerabilities and recalibrated material Environmental Social and Governance factors for investors.
La relation entre les dangers météorologiques liés au climat et le stockage de produits chimiques et la préparation aux situations d’urgence
août 22, 2024
La gestion des risques chimiques aborde les risques que les produits chimiques nocifs posent pour les humains et l’environnement.
Renforcer la résilience organisationnelle aux changements climatiques
Décembre 15, 2023
Atténuer les risques opérationnels potentiels en suivant quatre étapes clés
Preparing the Grid for Transportation Electrification
août 14, 2023
Electric vehicle use is on the rise, and cities need to prepare. Discover how the power grid can accommodate growing transportation electrification trends.
Regulators Update Design Storm Rainfall Depths in Response to Climate Science Projections and Recent Storm Data
août 3, 2023
Regulators are responding to anticipated increases in extreme rainfall events by updating design storm rainfall depth regulations.
Community Benefits Plans – A Winning Formula for Federal Funding
mai 12, 2023
The CBP acts as the project’s roadmap for ensuring communities workers, and other stakeholders have opportunities for meaningful engagement.
New Executive Order 14096 Broadens Environmental Justice Initiatives
mai 9, 2023
Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, seeks to deepen the Biden administration’s “whole-of-government” approach to environmental justice (EJ) by fully integrating the consideration of unserved and overburdened communities and populations into all aspects of federal agency planning and delivery of services.
Water Resiliency: Military Base Experience and Application to Communities and Industries
février 23, 2023
Water resiliency is the ability to effectively operate if the water resources you rely on are stressed, contaminated or even cut off for a specified amount of time.
Agrivoltaics
février 8, 2023
Agrivoltaics is the simultaneous use of land for both solar photovoltaic power generation and agriculture.
How to Develop a Climate Resiliency Plan for Extreme Weather Events
Décembre 15, 2022
Planning now for weather-related risks is crucial to preserving local communities.
Carbon Sequestration
Décembre 14, 2022
Carbon Sequestration is an emerging technology to combat climate change by mitigating carbon emissions.
Preparing Your RMP Facility for a Future of Extreme Weather
novembre 29, 2022
Facilities dealing with hazardous materials must prepare for extreme weather events that pose a risk to their operations and the community.
Data Requirements to Improve Statistical Decision Making
octobre 25, 2022
One goal of statistics is to draw meaningful inferences but your dataset must be large enough to provide technically-defensible and robust statistics.
TRC Companies Inc. welcomes the Founder and Key Principals of ESG Advisory Firm Enzo Advisors, LLC
septembre 27, 2022
TRC Companies announces the expansion of its Climate Solutions offering and ESG capabilities with the addition of the Founder and CEO, and key members of Enzo Advisors, LLC
A Green Future for Stormwater Management
septembre 26, 2022
Green Stormwater Management is an effective strategy for flood control and pollution mitigation.
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
juin 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
Why Are ESG Frameworks Important?
avril 13, 2022
ESG standards significantly impact long-term growth, leading many companies to integrate ESG reporting into their corporate social responsibility (CSR) strategies. ESG frameworks are broad and diverse, and establishing a reporting system that covers your industry’s most relevant metrics can be challenging.
10 Takeaways from the COP26 Climate Meeting
novembre 17, 2021
There are compelling reasons to be optimistic about the outcomes of the COP26 meeting. Notably, agreement among all nations that more needs to be done, by both private and governmental bodies, to contain and mitigate climate change.
The View on Climate Change has Changed in Washington
mars 1, 2021
The Biden Administration signals both a renewed and accelerated focus on climate change.
Emily Larson
Emily Larson has more than 10 years of experience modeling the bioaccumulation of semivolatile compounds and metals in ecological systems, modeling exposure to human and ecological receptors, and preparing human health and ecological risk assessments. She has experience conducting risk assessments with emerging contaminants, specifically per-and polyfluoroalkyl substances (PFAS). In addition, she serves as a technical expert on PFAS within the intermountain region for TRC. She has experience with Superfund (CERCLA) as well as several state-led programs specifically in the Inter Mountain West and Pacific Northwest regions. Emily has worked with several clients in both the private and the public (state and federal) sector. She can be reached at ELarson@TRCcompanies.com.
Elizabeth Denly
Elizabeth Denly serves as TRC’s Vice President, PFAS Initiative Leader. She is also the Quality Assurance & Chemistry Director, responsible for the creation and implementation of the Quality Management Plan and standard operating procedures (SOPs) for field sampling and documentation protocols. Ms. Denly also leads Quality Coordinator networks, which are responsible for the development and communication of quality initiatives within the organization. She is a chemist with 29 years of consulting experience encompassing field and laboratory analyses and audits, QA/QC, data validation, and consulting for regulatory agencies. Ms. Denly is a leader in ITRC’s PFAS and TPH Risk Work Groups and in TRC’s Center of Research & Expertise (CORE) Emerging Contaminants Team and received the ITRC’s Industry Member of the Year Award in 2017. She is currently focusing on PFAS, specifically the nomenclature, chemistry, sampling procedures, QA/QC, and laboratory analytical methodologies, and has a significant role in educating clients, attorneys, and regulators about PFAS. As a senior QA specialist at TRC, Ms. Denly is responsible for providing QA/QC oversight in support of a variety of environmental investigations and remediation programs including risk-based soil cleanups, ambient air monitoring, and human health and ecological risk assessments. In this role, she has directed the preparation of QAPPs, coordination with the laboratory, selection of the appropriate analytical methodologies to achieve the desired remedial standards, oversight and performance of the data validation process, and determination of the usability of the data and achievement of data objectives. Ms. Denly has provided this oversight under different regulatory programs. Read more on Ms. Denly's bio page. Please contact her at edenly@trccompanies.com.
Catriona Smith
Catriona (Cat) Smith has over 30 years of professional experience in the interpretation and application of regulations for industrial facilities relating to compliance, remediation and negotiations with regulatory agencies. Her clients include upstream and downstream oil and gas, chem-pharma, petrochem, manufacturing and federal, state, and local governments. Ms. Smith is a Vice President and Environmental Sector Market Director for TRC, with nationwide responsibilities to manage our clients’ PFAS challenges, support and grow our Oil and Gas clients and bring multi-disciplinary solutions to their complex projects. Contact Cat at CVSmith@trccompanies.com.