Acting Administrator Wheeler:
We write to you about drinking water contamination from per- and polyfluorinated chemicals (PFAS) and the existing health advisory levels for PFOA and PFOS.
We are glad that after what seemed like a long delay, on June 20, 2018, a draft Toxicological Profile for PFAS written by the Agency for Toxic Substances and Disease Registry (ATSDR) was released to obtain public comment on its contents. Now that it has been released, we have heard suggestions that this draft study shows the U.S. Environmental Protection Agency's (EPA's) current health advisory levels for PFOA and PFOS in drinking water - set at 70 parts per trillion (ppt) - could be 7 to ten times higher than what ATSDR has preliminarily identified as the minimal risk level (MRL) for these chemicals.
According to the draft Toxicological Profile, exposure to PFOS and PFOA above the MRL might be associated with: pregnancy-induced hypertension/pre-eclampsia, liver damage, increases in total cholesterol and LDL cholesterol, increased risk of thyroid disease, decreased antibody response to vaccines, increased risk of decreased fertility; and decreases in birth weight.
In light of the potential serious health issues that could result from exposure to PFOS and PFOA above this draft MRL, we urge the U.S. Environmental Protection Agency (EPA) to review the final toxicological profile and, as appropriate, act immediately to adjust the health advisory levels for PFOS and PFOA.
In addition, the draft Toxicological Profile identified PFHxS and PFNA, additional types of PFAS, that are also potentially associated with health issues. Currently, there is no health advisory level for these chemicals. If warranted, the EPA should move to create health advisories for these additional chemicals.
We urge you to work with ATSDR as you develop toxicity values, analytical methods, and treatment options on PFAS for states, tribes, local governments, and health professionals.
While critical scientific inputs on PFAS are missing, the information that is currently out there is raising many public questions. The EPA should move quickly to make appropriate changes to the existing drinking water health advisories that effectively communicate and explain risks to the public, as well as provide tools for adequate protection from exposure to these chemicals.
Sincerely,