• J.D. Solomon

What the New USEPA Health Advisory Levels for PFAS Means to You


Picture showing human ingestion and environmental contamination pathways.  Communicate with FINESSE!
PFAS is present in food packaging at the new USEPA Health Advisory Action Levels (visual: toxicfreefuture.org)

On June 15, 2022, US EPA reduced the current Health Advisory Levels (HALs) of 70 parts per trillion for PFOA and PFOS (combined) to 0.004 parts per trillion for PFOA and 0.02 parts per trillion for PFOS. This reduction is over 17,000 times lower than what was considered safe by USEPA six years ago.


Extremely Low Levels

One environmental association equates to one part per trillion is one drop of water in an Olympic swimming pool. The previous level, 70 parts per trillion, equates to 70 drops of PFOA/PFOS in the Olympic-sized pool. It is now down to a tiny fraction of one drop. These levels are so low they cannot even be measured.


EPA admits that these super-low levels could be very difficult to identify with current methods of detection: "It is possible for PFOA or PFOS to be present in drinking water at levels that exceed health advisories even if testing indicates no level of these chemicals" and that PFOA and PFOS can only "be reliably measured using specified analytical methods in appropriate laboratory settings."


Why Not Just Eliminate PFOA and PFOS?

PFOA and PFOS are two of several thousand PFAS chemicals. PFAS chemicals have been used in all sorts of products we interact with daily – from take-out food containers, non-stick cookware, cosmetics, waterproof clothing, fabric softener, and a whole host of other consumer and household products.


For the past several decades, there have been concerted government efforts to reduce the manufacture and use of these chemicals, even though there remains uncertainty about the health effects of most of these chemicals.


Moving Forward

USEPA moved too quickly when issuing its interim Health Advisory Levels (HALs). USEPA did not provide any advance notice to states and the regulated entities about communicating these Interim HALs to the public. The agency also did not provide what steps the regulated entities, including public water systems, are expected to take in response to the interim guidance. Prepare for the hype and the confusion, and there can be little doubt that this was what USEPA intended to do.

 

JD Solomon, Inc provides consulting services at the nexus of facilities, infrastructure, and the environment. Contact us for more information on our services related to regulatory facilitation, permitting, risk management, and third-party reviews.