Science Must Shape the Process on PFAS
Ultimately, business wants clean water and a predictable approach to any rulemaking process. Toxicologists generally follow a three-part process to determine risk. We are concerned that, due to the nature of politics and election-year pressures, this process was not fully executed when it comes to regulating PFAS in North Carolina.
- The assessment needs to protect sensitive subgroups in our population; if they are protected, everyone else will be protected. We feel this piece is well covered.
- The assessment should not be overly protective; a zero dose is also safe, but many chemicals are useful. It is important to pick the highest safe dose with a reasonable margin of error. This is where we feel there is room for improvement.
- The assessment should consider the findings of similar expert bodies. Differences of three-fold are often found among expert groups and generally of no concern. Differences of 3 to 30-fold are some cause for reconsideration. Larger differences are cause for concern. The graphic below demonstrates that we are well beyond 30-fold with 100-fold or more differences.
At the federal level, EPA has set an aggressively low drinking water standard, or Maximum Contaminant Level (MCL), at 4 parts per trillion (ppt). We feel that number meets the first step in the above three-step process but falls short of answering #2 and #3.
North Carolina’s Department of Environmental Quality is being even more aggressive in a push to regulate not just drinking water, but the surface water and groundwater as well. Putting aside whether or not they have the authority to do that, the science to measure levels that low in surface and groundwater is problematic.
Your NC Chamber will not let politics overtake the science. We are focused on the facts, regardless of the misinformation being spread on our position. This is a broad family of chemistry with essential uses, not all PFAS are the same.
Why the Level Matters
Humans are exposed to tens of thousands of chemicals every day. A cup of coffee has more than 1,000 chemicals.
All chemicals are toxic at some level, even water. If you drink too much water, it will kill you. If you drink a little bit less than what would kill you, it will disrupt your endocrine system, specifically the hormones associated with your kidneys and adrenal glands.
All chemicals have a safe or virtually safe dose. It is the dose that makes any chemical a poison.
Even a very toxic chemical, like arsenic, has a level below which humans are not at risk. It’s a good thing, too, because arsenic is a naturally occurring element that can be found in nearly all water and the food we eat daily if one looks closely enough.
Fun fact: the EPA has set the current drinking water standard, or Maximum Contaminant Level (MCL), for arsenic at 10 parts per billion (ppb). Quite the contrast to the 4 ppt being proposed for PFAS/PFOA.
The level matters: the lower the level, the higher the cost of compliance. Let’s make sure the level meets the three criteria set by toxicologists, not just political polls.
Businesses are comprised of people and clean water is important to sustaining a healthy community and economy. Understanding the regulatory standards to which a business will be held, so they can safely operate and provide a way for people to earn a living, is also important.
