ASDWA Provides Recommendations to EPA Ahead of SAB PFAS Review Panel Discussions

Last week (December 30, 2021), ASDWA sent a comment letter to EPA and the Science Advisory Board (SAB) in response to the SAB’s review of the Agency’s Draft Framework for Estimating Noncancer Health Risks Associated with Mixtures of Per- and Polyfluoroalkyl Substances (PFAS). The association maintained its support for EPA’s use of the SAB and urged the Agency to ensure that the board is provided with the resources and time needed to provide EPA with the best possible feedback. ASDWA noted that, although the Agency has set a tight deadline to develop a Safe Drinking Water Act (SDWA) standard for PFOA and PFOS, it “should not compromise the valuable insights the SAB can provide, nor constrain EPA from fully incorporating the board’s recommendations.”

Although the SAB is in the process of reviewing four separate documents that are meant to help inform EPA’s work to address PFOA and PFOS, ASDWA’s comments focused specifically on the draft framework for estimating noncancer health risks associated with PFAS mixtures. The association’s letter asserts that the document “sets a significant precedent for the future evaluation and assessment of chemical mixtures,” and that the final framework “will likely have a considerable impact on the methodology used to assess any chemical mixtures, not just PFAS mixtures, and on EPA’s regulatory development process.”

ASDWA provided a series of recommendations to help optimize the value of the draft framework, encouraging EPA to:

• Be more transparent and precise regarding the Agency’s intentions for the framework;
• Provide further context as to how this framework should, or could, be used to inform SDWA actions;
• Engage and coordinate with state drinking water programs in the further development of this framework; and
• Provide risk communication messaging in conjunction with the final framework and the Agency’s other ongoing PFAS initiatives.

EPA has provided these comments to the SAB”s PFAS Review Panel ahead of their final three meetings on January 6, 7, and 8.

Attachment: Association of State Drinking Water Administrators Comments to EPA Regarding the SAB PFAS Review Panel