AWWA Articles

AWWA on PFAS: Advance public health with sound standards

In comments submitted today, the American Water Works Association (AWWA) expressed support for the U.S. Environmental Protection Agency’s proposal to move forward on regulating two per- and polyfluoroalkyl substances (PFAS), urging the agency to use the best available science in evaluating a drinking water standard.

EPA on Feb. 20 announced its proposal to regulate PFOS and PFOA and requested comment on regulatory approaches for other PFAS. In the months leading up to the decision, AWWA published four guiding principles for sound PFAS regulation: commitment to public health protection, fidelity to scientific process, protection of source water, and investment in research. 

“EPA should move forward to develop primary standards for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) expeditiously but not without undertaking the analyses required to ensure that the resulting regulations are sound,” AWWA wrote in its comments. AWWA recommended that EPA take advantage of upcoming data from the Fifth Unregulated Contaminant Monitoring Rule and ongoing toxicity assessments in consideration of additional PFAS.

Several states are setting their own standards for PFOA, PFOS and other PFAS. AWWA said that the lack of consistency among these efforts “create[s] a communication challenge for water systems surrounding the public health risks of PFAS exposure, confuse the public, and hurt the credibility and validity of risk assessment processes.”

EPA’s proposed regulatory determination notes that an analysis will be done to “inform future decision making,” specifically providing for “further scientific review of new science prior to promulgation of any regulatory standard.”

“AWWA welcomes a robust scientific review of the toxicological research that is available,” the comments stated. “Attributing specific health effects to PFOA and PFOS is complicated and different toxicologists have come to very different conclusions based on the available data. These conclusions are so different as to have substantial implications for regulatory thresholds and drinking water treatment.”

AWWA’s comments pointed out that existing state and federal statutory authorities -- the Toxic Substances Control Act (TSCA), Clean Water Act, Clean Air Act, Resource Conservation and Recovery Act -- are not being effectively applied to stop PFAS from entering U.S. surface water and ground water. “Safe Drinking Water Act (SDWA) standards are not intended to be the trigger for protective actions, but rather the failsafe for when other best available business practices and regulatory barriers have failed,” AWWA wrote. “If drinking water standards are to be developed, then these authorities should be used to minimize drinking water supply contamination.” 

AWWA stressed that regardless of EPA’s future regulatory approach, a sound path forward for PFAS must:

  1. Provide meaningful public health benefit through removing an appropriately targeted contaminant or group of contaminants.
  2. Rely on an available treatment technology that has been demonstrated to be effective under a robust array of field conditions.
  3. Minimize adverse unintended consequences including simultaneous compliance and operational considerations.
  4. Avoid forcing water systems to make long-term capital investments, which are subsequently left stranded by shifting regulatory policies. 
  5. Recognize that funds utilized by water systems to address poorly characterized potential risks reduce the amount of funding available to use to address well-understood risks and make necessary improvements.

Find the AWWA Briefing on PFAS and other resources at awwa.org/pfas.

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Established in 1881, the American Water Works Association is the largest nonprofit, scientific and educational association dedicated to managing and treating water, the world’s most important resource. With approximately 51,000 members, AWWA provides solutions to improve public health, protect the environment, strengthen the economy and enhance our quality of life.


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