Science Advisory Board (SAB) Criticizes Draft EPA PFAS Documents Over Lack of Transparency

In the first week of January 2022, the Science Advisory Board (SAB) PFAS Panel reviewed draft documents for deriving a maximum contaminant level goal (MCLG) for perfluorooctanoic acid (PFOA) or perfluorooctanesulfonic acid (PFOS) as well as an analysis of cardiovascular disease (CVD) risk reduction as a result of reduced PFOA and PFOS exposure in drinking water.  EPA uses health-based MCLGs to set enforceable drinking water standards after taking into consideration cost and technology concerns.  EPA will use the CVD document in its cost-benefit analysis for the enforceable drinking water standard.

EPA has asked the panel to weigh in on a number of issues related to the MCLG documents. These include: whether the agency clearly described the studies it considered in developing the MCLG process documents, whether the agency has chosen the right endpoints for assessing noncancer effects, whether the agency has made the right cancer classifications and properly calculated the cancer slope factor, whether the agency’s toxicokinetic models are appropriate, whether the agency chose the appropriate epidemiological studies to derive the reference doses (RfDs) for PFOA and PFOS, and whether the agency’s decision to use a relative source contribution of 20 percent is appropriate.

EPA science advisors criticized several aspects of the draft documents the agency plans to use to set enforceable drinking water limits, saying that even when the agency’s approach appears to be reasonable, EPA has failed to adequately explain its rationale.  The criticisms follow, and in some cases echo, concerns a variety of public commenters have raised about the documents, where state health officials, industry groups and drinking water officials have said the documents contain numerous errors and inconsistencies. Specifically, the panel reviewed a draft framework for estimating noncancer risks associated with PFAS mixtures, raising concerns it could hamper ongoing state efforts to control the chemicals.

While the SAB panel raised numerous technical concerns over EPA’s data and conclusions, it was not clear if the panelists would provide clear direction to EPA.  Public commenters urged the SAB to provide specific recommendations and definitive direction to EPA regarding the scientific basis provided to support a drinking water standard for PFOS and PFOA.  The technical and scientific information provided by EPA and reviewed by the SAB will be part of the administrative record to support EPA’s rulemaking process to set drinking water standards for PFO and PFOA.

On behalf of NASF, The Policy Group will continue to work with EPA, state agencies, drinking water utilities, and industry trade groups on this rulemaking development and provide updates to NASF members.  If you have any questions or would like additional information, please contact Christian Richter or Jeff Hannapel with NASF at crichter#@thepolicygroup.com or jhannapel@thepolicygroup.com.   

This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.