Understanding the impact of the new EPA PFAS Interim Health Advisory Levels
At a glance
These very low values are less than commercially available laboratory detection limits – making it extremely challenging to confidently establish appropriate strategies to manage PFAS effectively.
These very low values are less than commercially available laboratory detection limits – making it extremely challenging to confidently establish appropriate strategies to manage PFAS effectively.
USEPA is signaling a substantially more conservative position with how they intend to manage PFAS through recent updates to the recommended health advisory levels (HALs). The HALs for PFOS and PFOA were derived using approaches inconsistent with the derivation of previously established HALs of 70 parts per trillion for the sum of PFOA and PFOS. USEPA has updated interim HALs of 0.004 and 0.02 parts per trillion for PFOA and PFOS, respectively, making these guidance values some of the most conservative in the world. We are continuing to review the underlying assumptions used to inform these HALs. In addition, USEPA released Health Advisory values for two additional PFAS compounds that had not previously had values: HFPO-DA (known as Gen X) and PFBS.
Our subject matter experts, Tamara House-Knight and Holly Churman share additional insights here within and via Water & Wastes Digest.
Our subject matter experts, Tamara House-Knight and Holly Churman share additional insights here within and via Water & Wastes Digest.
How this impacts current and future PFAS-related projects
Given that these HALs are lower than what can be detected using commercially available laboratory methods, and concentrations of PFAS being detected in rainwater where there are no apparent sources, USEPA is essentially signaling that there are no acceptable detectable levels for PFAS, and that PFAS impacts are latent and global. While we recognize our industry’s understanding of PFAS toxicology is rapidly evolving, we disagree the data are available to support these assumptions. We are concerned these conservative HALs will inadvertently shift focus and resource prioritization from problematic or high-risk sites to a blanket push for all facilities to address PFAS, regardless of the risk.
While the HALs are not enforceable and will be subject to additional tests and study prior to being promulgated as Maximum Concentration Limits (MCLSs), the direction for which USEPA is heading presents a material risk to the owners and operators of water treatment systems. At these low concentrations, facility owners and operators, water purveyors, and water and wastewater treatment operators working to address PFAS, may need to reconsider their PFAS management approaches. That includes a strong risk assessment and risk communication component, regardless of whether or not these interim updated HAL for PFOA and PFOS do not progress to enforceable criteria. What does this mean? Facilities that had not previously considered PFAS to be chemicals of concern to their operations may now need to assess and manage these chemicals. Also, for water utilities needing to monitor PFAS at these low concentrations may require additional funding under the Bipartisan Infrastructure Law to secure the infrastructure or infrastructure upgrades.
Despite the challenges in detecting PFAS compounds at these low levels, existing treatment technologies, such as activated carbon adsorption systems, may need to be augmented or operated differently to achieve the new HAL. Additionally, it is likely that emerging technologies, such as PFAS destruction systems, may undergo accelerated and rapid development so to tackle these pressing treatment challenges.
While the HALs are not enforceable and will be subject to additional tests and study prior to being promulgated as Maximum Concentration Limits (MCLSs), the direction for which USEPA is heading presents a material risk to the owners and operators of water treatment systems. At these low concentrations, facility owners and operators, water purveyors, and water and wastewater treatment operators working to address PFAS, may need to reconsider their PFAS management approaches. That includes a strong risk assessment and risk communication component, regardless of whether or not these interim updated HAL for PFOA and PFOS do not progress to enforceable criteria. What does this mean? Facilities that had not previously considered PFAS to be chemicals of concern to their operations may now need to assess and manage these chemicals. Also, for water utilities needing to monitor PFAS at these low concentrations may require additional funding under the Bipartisan Infrastructure Law to secure the infrastructure or infrastructure upgrades.
Despite the challenges in detecting PFAS compounds at these low levels, existing treatment technologies, such as activated carbon adsorption systems, may need to be augmented or operated differently to achieve the new HAL. Additionally, it is likely that emerging technologies, such as PFAS destruction systems, may undergo accelerated and rapid development so to tackle these pressing treatment challenges.
Effectively evaluating business preparedness
We have more than a decade assisting clients in solving PFAS challenges globally. Further to helping our clients understand their risk situation with respect to PFAS, we will continue to help our clients manage these risks, recognizing that complete treatment is generally neither practical nor the most environmentally, socially, or economically sustainable solution. We will continue to review the studies on which USEPA replied upon to develop these values to determine if these interim updated HAL are appropriate and scientifically sound. What is critical in light of the release of these HALs is effective stakeholder engagement and risk communication to communicate the actual risks to members of the public or community who may now be alarmed by the Interim updated HAL.