PA PFAS Drinking Water Standards - Open for Public Comment

Brian Oram, Licensed Professional Geologist

Proposed regulations regarding setting limits for PFOA and PFOS in drinking water are open for public comment by the Pennsylvania Department of Environmental Protection (PA DEP). The standard will likely apply to community water supply systems.

The KnowYourH2O Team encourages you to make a comment, but that prior to doing so that you Get Informed. We believe the Path to Clean Water starts with education first, then action to make the most informed decisions. To that end, we share the following information:

From the PA DEP Website:

The EPA has set a guidance limit of 70 parts per trillion, but the proposed standard by the PADEP is 14 parts per trillion for PFOA and 18 parts per trillion for PFOS. The standard is open for public comment until April 27, 2022, and there will be virtual public hearings on this topic.

PA DEP – Public Announcement (February 25, 2022)

"The comment period concerns a proposed rule to set maximum contaminant levels (MCLs) in drinking water for two forms of per- and poly-fluoroalkyl substances (PFAS) – perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) – to protect the public from potential adverse developmental and immune system effects linked to exposure to PFOA and PFOS. The comment period will begin Saturday, February 26, 2022, and close Wednesday, April 27, 2022.

The proposed rule would set an MCL of 14 parts per trillion (ppt) for PFOA and an MCL of 18 ppt for PFOS, which are stricter limits compared to the United States Environmental Protection Agency's lifetime Health Advisory Level (HAL) of 70 ppt for PFOS and PFOA combined.

This proposed rulemaking represents an unprecedented step in setting a Pennsylvania-specific MCL for drinking water. In June 2021, DEP's final results from sampling public water systems for PFAS were released (statewide sampling began in July 2019). Due to these efforts, Pennsylvania is at the forefront of states taking proactive steps to address PFAS. You can find more information on Pennsylvania's efforts to address PFAS at www.dep.pa.gov/PFAS.

PFAS are a class of synthetic chemicals used since the 1940s to make water, heat, and stain-resistant products such as cookware, carpets, clothing, furniture fabrics, paper packaging for food, and other resistant materials. These chemicals are persistent in the human body and throughout the environment. PFAS have been associated with adverse health effects but are classified by scientists as emerging chemicals because the risks to human health and the environment are not completely understood."

"Scientists classify PFAS as emerging contaminants because the risks to human health and the environment are not completely understood. While health impacts continue to undergo research studies, the research has concluded a probable link of PFAS to adverse health effects in laboratory animals and humans." 

PFAS in Pennsylvania

Health Effects (Emerging Contaminants - Suspected, Probable Link) Some of the potential effects on human health are:

• Thyroid Dysfunctions
• Delayed Puberty
• Osteoarthritis
• Increased Levels of Uric Acid
• Liver Problems
• Cholesterol Changes
• Immune Disorders

It has been suggested that exposure to high levels of PFOs and PFOA may also lead to impaired fetal development, skeletal issues, cardiovascular problems, testicular cancer, kidney cancer, and thyroid cancer. The International Agency for Research on Cancer has classified PFOA as possibly carcinogenic.

Definition of Probable Link: A "probable link" in this setting is defined in the Settlement Agreement to mean that, given the available scientific evidence, it is more likely than not that among class members, a connection exists between PFOA exposure and a particular human disease. On October 29, 2012, the C8 Science Panel concluded that there is no probable link between exposure to C8 (also known as PFOA) and Liver disease.

(Source)

Information from the KnowYourH2O Team:

Before making a public comment, we suggest all learn more about PFOA and PFOS.

A. If on a septic system, check the products you use to see if they contain PFOS or PFOA. They can be found in different products and industrial applications. Here is a partial list of some of the common consumer goods that are manufactured using PFOs or PFOAs.

• Leather
• Pesticides
• Firefighting Foams
• Polishes
• Adhesives
• Paint
• Waxes
• Protective sprays
• Cleaning products
• Coatings for Carpets and Upholstery
• Carpets
• Waterproof Clothing
• Cosmetics
• Grease-proof Food Packaging
• Heat Resistant Tape
• Non-stick Pans

B. Check out the KnowYourH2O page on PFOA and PFOS

C. Review the EPA Drinking Water Health Advisories for PFOA and PFOS
PFOS Health Advisory (2016)
PFOA Health Advisory (2016)

D. You may want to get your water tested, especially if you are likely to be potentially regulated – We Recommend the Resin Tech – PFAS – 18 compounds in Water and Drinking Water with a Reagent Blank.  
Order Test

E. Go to the Pennsylvanians Citizen Site on PFAS – Some PFOS data for sources is available

F. If you are located in another state – Check out the ATSDR PFAS in the Environmental Portal.

PA Environmental Quality Board Public Hearings

The EQB will also hold five virtual public hearings on the proposed rulemaking during the week of March 21, 2022. The public hearings will be held via Webex at the following dates and times:

• Monday, March 21, 2022, at 1:00 PM
• Tuesday, March 22, 2022, at 6:00 PM 
• Wednesday, March 23, 2022, at 1:00 PM
• Thursday, March 24, 2022, at 9:00 AM
• Friday, March 25, 2022, at 9:00 AM

Information on how to participate in the hearings will be posted on the EQB's webpage found through the Public Participation tab on DEP's website at www.dep.pa.gov (select "Public Participation," then "Environmental Quality Board"). Persons who want to present testimony at one of the hearings must contact Jennifer Swan at (717) 783-8727 or RA-EPEQB@pa.gov by 5:00 PM on Friday, March 18, 2022, to reserve a time to present testimony.

Submit Comments

When the comment period opens, comments may be submitted to the Environmental Quality Board (EQB) through DEP's eComment system at http://www.ahs.dep.pa.gov/eComment. Comments may also be submitted via e-mail at RegComments@pa.gov. Each comment must include a subject heading of the proposed rulemaking and the name and address of the person submitting the comment.

Written comments may be mailed to:
Environmental Quality Board 
PO Box 8477
Harrisburg, PA 17105-8477

The KnowYourH2O Team's Thoughts For Now

1. Since effective treatment, removal, and disposal are not clear, we would recommend focusing on changing consumer products, educating the public, encouraging the community to get blood screening completed, using the EPA action level, and using products that limit exposure to these chemicals.

2. Pennsylvania is proposing a standard similar to California and New Jersey. We recommend implementing a comprehensive program to screen drinking water samples and use the EPA 70 part per trillion drinking water standard and then allow consumers to decide to install point of use treatment systems.

3. Get your water tested - We Recommend the Resin Tech – PFAS – 18 compounds in Water and Drinking Water with a Reagent Blank.
Order Test

4. Point of Use Filtration – Meet NSF/ANSI 53 and NSF/ANSI 58 or the AO Smith Portal at Amazon or the Aquasana Portal at Amazon