ASDWA and AMWA Letter to New AA at EPA Office of Chemical Safety and Pollution Prevention

On April 20th, ASDWA and the Association of Metropolitan Water Agencies (AMWA) submitted a joint letter to Dr. Michal Freedhoff, the Acting Assistant Administrator for EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP).  The letter asks for a meeting with Dr. Freedhoff and highlights the importance of using the Toxic Substances Control Act (TSCA) and all federal authorities to assess, address, and prevent potential impacts to both surface and groundwater sources of drinking water and public health from new and existing chemicals such as PFAS.

Our organizations emphasize the need for EPA to undertake a comprehensive and holistic risk assessment and risk management approach to consider potential impacts to drinking water, human health, and the environment throughout any part, or all of a chemical’s lifecycle – from manufacturing through processing, distribution, and disposal. The lack of adequate testing methods, health effects studies, and reporting requirements for many new and emerging chemicals creates challenges for states and public water systems to: explain what is known and unknown about their health effects; communicate the associated risks to customers and the public; investigate sources of contamination; and make important decisions about whether to install treatment, which is expensive and typically above and beyond conventional water treatment processes.

The five key takeaways of the letter include:

1. TSCA is the first line of defense for protecting drinking water sources from emerging contaminants, which must be addressed holistically across all regulatory statutes and agencies.
2. EPA should better utilize states, PWSs, and other stakeholders as the Agency works to develop risk assessments and risk management rules.
3. EPA must develop risk assessments and evaluations by including all exposure routes regardless of federal statutes in place. Specifically, EPA should re-open the risk evaluation for 1,4-dioxane to address drinking water exposure.
4. Significant New Use Rules provide a unique opportunity to assess and restrict the release of harmful chemicals into the environment.
5. EPA offices must better coordinate amongst themselves and with other federal agencies to leverage all regulatory tools and agency pollution prevention policies to better protect drinking water from emerging contaminants.

For more information, read the letter here.