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EPA’s New PFAS Health Advisories Set the Stage for Lower Regulatory Exposure Limits

These new, much lower, health advisory levels will guide future federal and state regulatory action.

July 11, 2022

By: Martha Maier

On June 15, 2022, the U.S. Environmental Protection Agency (EPA) released four drinking water health advisories for per- and polyfluoroalkyl substances (PFAS) as part of its commitment to implementing its PFAS Strategic Roadmap.

In this latest health advisory, the agency drastically lowered the acceptable levels for two types of PFAS, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), from 70 parts per trillion to 0.004 parts per trillion for PFOA and 0.02 parts per trillion for PFOS. In using these numbers, the agency asserts that adverse health effects can result from these chemicals at concentrations approaching zero. Notably, the agency acknowledges that current technologies and EPA’s mandated analytical methods (Method 537.1 and Method 533) cannot detect PFOA and PFOS at these extraordinarily low levels.

In its recent release, EPA also issued its first-ever health advisories for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (GenX chemicals) as well as perfluorobutane sulfonic acid and its related compound potassium perfluorobutane sulfonate (PFBS).

As noted in the table below, health advisories for PFOA and PFOS are interim, while the advisory values for GENX and PFBS are final.

Chemical 2016 Health Advisories (ppt) New Health Advisory Value (ppt) Minimum Reporting Level (ppt)
PFOA 70 0.004 (Interim) 4
PFOS 70 0.02 (Interim) 4
GenX Chemicals (PFOA Replacement) N/A 10 (Final) 5
PFBS (PFOS Replacement) N/A 2000 (Final) 3

The agency uses health advisories for unregulated contaminants that can cause human health effects and are known (or anticipated) to be present in drinking water. They are non-enforceable federal limits but serve as technical guidance for federal, state, and local officials to inform if action is needed to protect public health. These actions can include water quality monitoring, optimizing existing PFAS reduction technologies, and developing strategies to reduce exposure to PFAS.

As noted in the chart above, for detection purposes, EPA’s forthcoming Fifth Unregulated Contaminant Monitoring Rule (UCMR 5) established Minimum Reporting Limits (MRLs) for each of these four PFAS chemicals. The MRLs correspond to the minimum contaminant levels that can be measured accurately by 75 percent of the testing laboratories able to perform the analytical method.  PFAS below these levels cannot be detected or quantified reliably.

Not enforceable, but a forecast of what’s coming.

It is critical to understand that these health advisory limits (HALs) assume a lifetime of exposure, are not regulations, are not enforceable, and cannot be reliably detected using EPA’s technical methods. Nonetheless, they signal that the agency will promulgate far more conservative/restrict exposure levels, setting the stage for what’s coming regarding future regulation on the state and federal levels, as well as the potential for expanded litigation exposure. Current PFAS litigation has already shown that although we don’t necessarily have the scientific ability to test at these low levels, the courts have been hesitant to shut down PFAS-related exposure claims.

Although these are interim advisory numbers and not yet final, all signals coming from EPA indicate that the final HALs will be extremely low, significantly lower than the 70ppt numbers upon which certain state regulatory limits are currently based.

According to its strategic roadmap, the agency is expected to propose National Primary Drinking Water Regulations and maximum contaminant levels (MCLs) for PFOA and PFOS by the end of 2022. The HALs will undoubtedly inform the MCLs, but it is important to note that in establishing final, enforceable drinking water concentration limits, the agency must consider both the financial costs and technological feasibility. So, while we anticipate that the final HALs for PFOA and PFOS will be considerably lower than they were, any new enforceable MCLs must be financially feasible, technologically available, and tied to established EPA Methods that produce reliable results.

Montrose is a global leader in PFAS treatment

During this time of regulatory uncertainty and confusion, Montrose continues to track these developments closely. Our resolute team of experts can help you navigate these changing requirements and can provide you with resources and solutions that cover the full PFAS lifecycle, including exposure and health risk, testing and analysis, water treatment technology.

Montrose Environmental Group was founded with the vision of bringing together smart people and impactful resources to answer the toughest environmental challenges that we all face today, such as PFAS. To date, the Montrose family has successfully treated more than 2 billion gallons of PFAS water while consistently meeting 99%+ PFAS waste reduction. Our people are dedicated to delivering the best integrated PFAS solutions to our clients. Because we are all in this together.

Contact us today with any questions. We are here for you.

Martha Maier – PFAS Program Leader, Montrose Environmental
Martha heads the expansive and innovative PFAS Program at Montrose. Formerly the President and Laboratory Director of Vista Analytical Laboratory, located in El Dorado Hills, CA, Martha has been at the forefront of PFAS analysis since Vista developed their in-house analytical method for serum in 2007. She is a member of the ITRC PFAS Committee, as well as the Sampling and Analysis Subcommittee. Before Vista was acquired by Montrose in 2021, she had been the Laboratory Director at Vista since 2002 before becoming the majority owner in 2011. Martha earned her BS in chemistry and philosophy at the University of Wisconsin-Madison. She has over 30 years of experience in environmental chemistry, primarily involving high resolution mass spectrometry for the analysis of chemicals such as dioxins, PCBs and chlorinated pesticides.

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