On June 15, 2022 the U.S. Environmental Protection Agency (EPA) announced four new lifetime health advisory levels for PFAS (per- and polyfluoroalkyl substances) compounds in drinking water. The announcement outlined interim levels for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), and additional final levels for hexafluoropropylene oxide-dimer acid (HFPO-DA) or otherwise known as “GenX,” and perfluorobutane sulfonic acid (PFBS). The advisories detailed health risk thresholds of:
- PFOA – 0.004 parts per trillion (ppt)
- PFOS – 0.02 ppt
- GenX – 10 ppt
- PFBS – 2,000 ppt
These advisory levels reflect the lifetime human health risk from these chemicals. Through the Safe Drinking Water Act (SDWA), the EPA issues non-enforceable health advisories for contaminants outside of those listed in the National Primary Drinking Water Regulation (NPDWR). They are not considered legal federal standards and are subject to change as new information becomes available. In parallel, the EPA also announced $1 billion to help impacted organizations begin to address PFAS and other emerging contaminants in drinking water. This is the first funding opportunity within a total of $5 billion allocated for addressing emerging contaminants in small or disadvantaged community grants as part of the Bipartisan Infrastructure Law.
Considerations and next steps
The revised health advisories represent a significant change in EPA’s estimation of the human health risks associated with these compounds. Drinking water utilities should be prepared to address customer concerns and should consider scenario planning in preparation for the forthcoming Maximum Contaminant Levels (MCLs).
The lower health advisory levels for PFOA and PFOS will impact transactional due diligence with changing screening and action levels driving up risk uncertainties. As these levels also factor into the basis for potential future MCLs, we expect that groundwater remediation, drinking water, water reuse, and land application projects will be subject to more stringent requirements.
Tools and resources
We have a team of Brown and Caldwell professionals that has experience in working with municipal and industrial clients across the nation to unlock PFAS solutions with long-term reliability and sustainability in mind. While we continue to monitor updates on the federal PFAS regulations, we recommend taking a proactive approach. You can learn more about how you can plan and prepare to adapt to what’s emerging:
- BC’s Compliance News March 2022 Special Edition: EPA Strategic Roadmap for PFAS: Who, What, Where, When, How, and Why
- March 2022 BC Compliance Watch: PFAS Strategic Roadmap
- July 2021 BC Compliance Watch: EPA adds 17 ways to analyze drinking water samples
- PFAS Treatability Testing Laboratory brochure