EPA Releases Updated Interim PFOA and PFOS Health Advisories at Levels Below Detection Alongside Final Health Advisories for GenX and PFBS

Today (June 15), EPA released the long-anticipated updated interim health advisories for PFOA and PFOS, as well as the final health advisories for GenX and PFBS. Health advisories are not legally enforceable and reflect EPA’s assessment of the health risks of a contaminant. Unlike the legally enforceable maximum contaminant levels (MCL) under the Safe Drinking Water Act (SDWA), health advisories are based solely on the Agency’s assessment of the risks and are not based on any consideration of the feasibility, costs, or benefits of reducing contaminant levels. Like in the case of PFOA and PFOS, EPA issues an interim health advisory when a contaminant’s associated health effects assessment is in draft form, but there is a pressing need to provide information to public health officials before finalizing the health effects assessment. The PFOA and PFOS interim health advisories are intended to be in place during the time interval between initial understanding of health effects and publication of the final health advisory, maximum contaminant level goal (MCLG), and/or MCL. EPA is planning to publish proposed MCLs for PFOA and PFOS by the end of 2022 and publish the final rule by the end of 2023. Health advisories can be updated or removed as additional information becomes available.

The health advisories provide technical information to state agencies and other public health officials on health effects, analytical methods, and treatment technologies. Interim or provisional health advisories are based on health-based hazard concentrations above which EPA says that action should be taken to reduce exposure to unregulated contaminants in drinking water. These advisories can be updated or removed as additional information becomes available.

The health advisories for these four PFAS are listed below. The updated interim health advisories for PFOA and PFOS now supersede the 2016 health advisory of a combined 70 ppt.

• Updated Interim Health Advisories for PFOA and PFOS
  • Health Advisory Levels: PFOA = 0.004 parts per trillion (ppt); PFOS = 0.02 ppt
  • Basis for Health Advisory: Human studies which found associations between PFOA and/or PFOS exposure and effects on the immune system, the cardiovascular system, human development (e.g., decreased birth weight), and cancer.
• Final Health Advisory for GenX and PFBS
  • Health Advisory Level: GenX = 10 ppt; PFBS = 2000 ppt
  • Basis for Health Advisory: GenX – Animal studies linking GenX chemicals to health effects on the liver, the kidney, the immune system, and developmental effects, as well as cancer. PFBS – Animal studies linked to health effects on the thyroid, reproductive system, development, and kidney.

EPA makes a point to highlight that the health advisory levels for PFOA and PFOS are below the level of both detection (determining whether or not a substance is present) and quantitation (the ability to reliably determine how much of a substance is present). Therefore, it is possible for PFOA or PFOS to be present in drinking water at levels that exceed EPA’s health advisories even if there are no detections during drinking water testing.

Although the Agency is in the process of developing a National Primary Drinking Water Regulation for both PFOA and PFOS and intends to propose the regulation this fall, EPA felt it was necessary to release these interim health advisories due to the new scientific information related to health effects of these two PFAS. The Agency’s Science Advisory Board (SAB) PFAS Panel has been in the process of reviewing the documents EPA used to develop these interim health advisories but has yet to release their final recommendations. These same documents will be used to develop the Agency’s Maximum Contaminant Level Goals for PFOA and PFOS – the level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety. These MCLGs will be released with the NPDWR proposal.

The Agency recognized that these levels would raise questions from the public and regulated community and developed a series of fact sheets and resources to provide background on these actions and address frequently asked questions. EPA encourages the public to reach out to their local water systems if they are concerned about exposure to these four PFAS. For water systems that detect PFOA and/or PFOS, the Agency recommends that they “take steps to inform customers, undertake additional sampling to assess the level, scope, and source of contamination, and examine steps to limit exposure.”

Alongside the release of these four health advisories, the Agency’s announced the release of $1 billion in Bipartisan Infrastructure Law funding – the first of $5 billion to be released in the coming years. States and territories can apply for these funds to address PFAS and other emerging contaminants in drinking water, specifically in small or disadvantaged communities. EPA’s fact sheets consistently highlight these funds and their ability to be used to address levels of PFAS above the health advisory levels.