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Perfluorooctanoic acid

Perfluorooctanoic acid (PFOA) was discovered by a Dupont scientist in 1938 but concerns about poisonous vapors from the chemical held up its use for a period of time by Dupont.  After about 15 yrs., without disclosure of potential toxic effects, it was made into Teflon and then into dozens of other applications including non-stick products such as Teflon pans.  3M Corporation developed further uses for PFCs.  Dupont also used fluorinated telomers, called “precursor chemicals”, which are found to break down into PFOA.  This family of chemicals was commonly used in nonstick papers such as food containers, stain resistant and water resistant fabric and rug coatings, and other consumer products.  Along with 3M Corporation, Dupont used PFOA and related perfluorinated chemicals for decades.  Many other companies used PFCs in patented products such as durable plastics and fire fighting foams.

PFOA use became so widespread over the decades and their nature is so durable that PFOA has become ubiquitous in our environment.  Blood studies that show the presence of PFOA chemicals in the blood of 96% of people in the U. S., approximately 4 ng/mL (nanogram/milliliter).  It has even been found in polar bears in the Arctic. The University of Pennsylvania School of Medicine found that PFOAs concentrate in the blood – because the chemical tends to build up in the human body and is difficult to excrete, the levels in an individual’s blood is about 105 times the amount in their drinking water. According to the U.S. Environmental Protection Agency (EPA): “Because PFOA can remain in the body for a long time, drinking water that contains PFOA can, over time, produce concentrations of PFOA in blood serum that are higher than the concentrations of PFOA in the water itself.” EPA-SAB-06-006    SAB Review of EPA's Draft Risk Assessment of Potential Human Health Effects Associated with PFOA and Its Salts 

A class-action lawsuit was brought against Dupont at their West Virginia Washington Works Plant by residents represented by attorney Robert Bilott, exposing willful pollution releases by Dupont of PFC to the environment and a cover up of the issue, setting a fire that eventually led to a sensational expose.  PFOA was found in the drinking water in the region, people in West Virginia and Ohio in the region around the factory were found to have excessive amounts of PFOA in their blood (298 to 369 ppb but some had ppb levels in the thousands); stories of local illness and disease were brought to light. 

By 2006, PFCs were being found in many media – ground and surface water, soil, sediments, and wildlife – the toxic properties and their inability to break down in the environment and to build up in human blood had become more evident and mounting evidence of the adverse health effects of PFCs led EPA to order the use of this family of chemicals phased out; federal rulemaking issued in 2006 removed exemptions previously given to these chemicals, making them subject to toxic chemical control requirements. (EPA 40 CFR Part 723) EPA fined Dupont $16.5 million in 2006 for covering up years of health hazard information.  3M Co. was fined $1.5 million for similar deception.  3M stopped using the compounds based on their own health studies but Dupont persisted.

A federal report by an independent scientific review panel, the Science Advisory Board, acknowledged in a report dated May 2006 that the compounds are a “likely” cause of cancer.  EPA-SAB-06-006    SAB Review of EPA's Draft Risk Assessment of Potential Human Health Effects Associated with PFOA and Its Salts  The Centers for Disease Control and John Hopkins reported health impacts in newborn babies such as low birth weight and reduced head circumference (Benjamin Apelberg, Department of Epidemiology, Bloomberg School of Public Health, John Hopkins University, August 2007).

More studies were published  relating to infertility in women. (Chunyuan Fei1,5, Joseph K. McLaughlin2,3, Loren Lipworth2,3, and Jørn Olsen1,4. Maternal levels of perfluorinated chemicals and subfecundity. Human Reproduction, Vol.1, No.1 pp. 1–6, 2009)  Metabolic effects are reported in mice in adulthood after prenatal exposure to PFOA. (Hines, E.P.; Gibbs-Flournoy, E.A.; Stanko, J.P.; Newbold, R.; Jefferson, W.; Fenton, S.E.  Testing the uterotrophic activity of perfluorooctanoic acid (PFOA) in the immature CD-1 mouse.  The Toxicologist 2009, 108, 297) Pregnancy loss, increased neonatal mortality, abnormal mammary gland growth and other developmental changes are also reported in recent studies. (Hines, E.P.; White, S.S.; Stanko, J.P.; Gibbs-Flournoy, E.A., Lau, C., Fenton, S.E.  Phenotypic dichotomy following developmental exposure to perfluorooctanoic acid (PFOA) in female CD-1 mice; Low doses induce elevated serum leptin and insulin, and overweight in mid-life.  Mol. Cell. Endocrinol. 2009, doi:10.1016/j.mce.2009.02.021) Studies have shown that workers who contact these chemicals are more prone to prostate and bladder cancer and higher than normal levels of cholesterol — a risk factor for heart attack and stroke. (Dupont Council, “Facts not Fiction”, The Case of C8, http://www.dupontcouncil.org/About_Us.htm)  In Oregon, studies on trout show that PFOA may promote liver cancer in trout and humans. http://www.sciencenews.org/view/generic/id/43712/title/Nonstick_chemical_pollutes_water_at_notable_levels 

A landmark paper by New Jersey scientists was published in 2009. Gloria B. Post*, Judith B. Louis, Keith R. Cooper, Betty Jane Boros-Russo§ and R. Lee Lippincott, Division of Science, Research and Technology, New Jersey Department of Environmental Protection, P.O. Box 409, Trenton, New Jersey 08625, Department of Biochemistry and Microbiology, Rutgers University, 76 Lipman Drive, Room 218, New Brunswick, New Jersey 08901, and Bureau of Safe Drinking Water, New Jersey Department of Environmental Protection, P.O. Box 426, Trenton, New Jersey 08625, “Occurrence and Potential Significance of Perfluorooctanoic Acid (PFOA) Detected in New Jersey Public Drinking Water Systems”, http://pubs.acs.org/doi/abs/10.1021/es900301s More studies and reports have been and continue to be published. 

Delaware Riverkeeper Network (DRN) has been working on the problems posed by the presence of perfluorinated compounds in our local environment since 2005 when our staff collected tap water samples in the neighborhoods close to DuPont’s Chambers Works facility in Deepwater, New Jersey on the Delaware River.  We suspected that there may be a problem because of news reports about a lawsuit that had been brought in West Virginia against DuPont for releasing PFOA into the environment there.  Our sampling revealed the presence of PFOA in the drinking water being used by people in the local community. 

We notified the residents and filed the information with New Jersey Department of Environmental Protection (NJDEP), setting off alarm bells and a chain of events that eventually led to NJDEP investigating the occurrence of perfluorinated compounds throughout the state.  When NJDEP conducted their first statewide occurrence study, PFCs were detected in 18 of 23 systems (78%) in 2006.  High blood levels of PFOA were found in Dupont workers in Deepwater. (Perfluorooctanoic Acid (PFOA) Updated Occupational Serum Sampling, Chambers Works Facility, Deepwater, New Jersey; submitted to EPA June 4, 2008 by DuPont Corporation)  A coalition of organizations - environmental groups and the United Steelworkers who represented workers at Dupont Chambers Works facility - formed in New Jersey to fight for the removal of PFOA from drinking water and the environment and its regulation by the State.  Since then, much more has occurred regarding public knowledge and inquiry into this nationwide problem but, unfortunately, not enough government action has resulted. 

NJDEP published its first Occurrence Study for PFOA in New Jersey public drinking water in 2007 and established a PFOA drinking water guidance level of 0.04 ppb (40 ng/L) based on lifetime health effects. 

The panel that sets safe drinking water standards, the New Jersey Drinking Water Quality Institute (DWQI), was shut down by the Christie Administration in September 2010, just prior to the reports from their various subcommittees, which were expected to recommend to New Jersey Department of Environmental Protection (NJDEP) a maximum contaminant level (MCL) for PFOA, which they had been researching and working on for years.  The MCL would require water systems in the state to treat their water supplies to remove PFOA to below the MCL. The DWQI was established by the 1983 amendments to the New Jersey Safe Drinking Water Act (N.J.S.A. 58:12A1 et seq., P.L. 1983, c. 443) and is responsible for developing maximum contaminant levels (MCL) or safe drinking water standards for hazardous contaminants in drinking water and recommending these standards to NJDEP.

Following the DWQI shut down, DRN filed many Open Public Records Act requests for a copy of a report that NJDEP was poised to issue in 2010 based on a second Occurrence Study which sampled water systems throughout New Jersey for perfluorinated compounds (PFCs).  On multiple occasions, DRN was denied access to the report with NJDEP claiming the report was “deliberative”.  Finally, after refiling an OPRA asking for the raw data and copies of notifications sent to water suppliers regarding the 2009 sampling, DRN received information from the Department between July 16 and 18, 2013, including data on 10 PFCs in 33 samples taken by the Department from 32 water supplies throughout New Jersey.  The data showed PFCs throughout many of New Jersey’s water supplies.  Because a large suite of PFCs were included in the 2009 testing, there were some obvious red flags in the results.  Some water supplies had very high levels of PFCs for which no New Jersey drinking water data was available previously, and very high levels were found in the Delaware River Watershed.  Those documents are available on DRN’s website.   

DRN filed a letter with DEP calling for immediate action to address this and to make the information available to the public.  DRN published the data on our website with the documents and notified news media.  The data revealed the highest level of any PFC in raw groundwater in New Jersey to be a long chain PFC, Perfluorononanoate acid (PFNA or “C9”), in the water well that supplies drinking water to the Borough of Paulsboro, Gloucester County, on the Delaware River.  In researching PFNA, DRN couldn’t find a record of any higher value for PFNA in the world.  DRN brought this to the attention of NJDEP and the public, notifying Paulsboro and the local community. DRN held several local meetings in the area around Paulsboro to raise awareness and spur action by municipalities.  Several letters to DEP, also available on this website, promoted no action in the weeks following the expose of the information. 

DRN’s efforts focused on the fact that people were drinking contaminated water in many places in the state and in the Gloucester County region, the highest of all groundwater contamination by the highly toxic PFC, PFNA.  DEP needed to take action to get people off polluted water and needed to reconvene the DWQI to jumpstart the PFC safe drinking water standard-setting process immediately.  DRN research revealed that Solvay, a plastics manufacturer in West Deptford was the likely source of the regional PFNA pollution.  Looking for a way to solicit independent outside experts, DRN looked to the federal government for support to get action on the unaddressed water contamination that the data showed. 

Getting no response from NJDEP to DRN’s letters or public calls for action, DRN reached out to an outside federal agency.  DRN filed a Petition with the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) in August 2013 requesting that the Agency conduct a public health assessment of Perfluorononanoate acid (PFNA) and other perfluorinated chemicals in the water supply for communities located near the Solvay Solexis Inc. facility in Thorofare/West Deptford and near Paulsboro, NJ.  The ATSDR is a federal public health agency, part of the Public Health Service in the U.S. Department of Health and Human Services that works to prevent exposure and adverse human health effects from pollution releases in the environment. 

DRN focused the Petition on Paulsboro because the raw groundwater that feeds the water supply for Paulsboro was found to contain extremely high levels of PFNA. ATSDR accepted the Petition and a study is ongoing.  Subsequently, the State of New Jersey Department of Health has received a multi-year multimillion dollar grant from the U.S. Centers for Disease Control to develop a monitoring program to analyze (at the state’s own lab) and monitor PFCs.

Available information showed the source of the PFNA in the Delaware River beginning at River Mile 88/90 was the Solvay Solexis plastics plant in West Deptford/Thorofare, NJ on the Delaware River near River Mile 90.  Fluorocarbons and fluoroelstomers are manufactured there using PFNA in their patented product.  At this location, near River Mile 90, Solvay Solexis is reported to have the second highest production capacity for PVDF (2002) in the world and is known to have emitted huge quantities of PFNA.  http://pubs.acs.org/doi/abs/10.1021/es0512475  According to a Solvay Solexis report to EPA, a large percentage of PFNA used in manufacturing at the facility is exhausted to the air or released as wastewater.  http://www.epa.gov/opptintr/pfoa/pubs/!Solvay%20Solexis%20report.pdf

IN 2009, the EPA set a federal Provisional Health Advisory Level for short-term drinking water exposure to perfluorooctanoic acid (PFOA) of 0.4ppb and perfluorooctane sulfonate (PFOS) of 0.2ppb, two of the most widely distributed PFCs. Due to widespread presence in the environment and people’s blood and due to the highly toxic and persistent nature of these compounds, EPA took several actions to stop the use of PFCs in the United States.  Of importance was the establishment of the stewardship program to phase out the manufacture and use of PFCs and the requirement by EPA that PFCs must be reported by dischargers and users to the agency. 

In 2012, EPA added PFOA and 5 other PFCs to the list of contaminants to be monitored in a selection of public water systems across the nation. https://www.epa.gov/dwucmr/third-unregulated-contaminant-monitoring-rule  The data is reported to EPA under the Unregulated Contaminant Monitoring Rule 3 (UCMR3) and is publicly available. https://www.epa.gov/dwucmr/fact-sheets-about-third-unregulated-contaminant-monitoring-rule-ucmr-3  This mechanism is how many local water purveyors and the public discovered the presence of PFCs in their water supplies.  But not enough has been done and PFCs all remain unregulated at the federal level; only a few states have any standards adopted – the strictest is Vermont at 20 ppt. (https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0ahUKEwjr9piUpaXMAhXIbj4KHZOkCAIQFggdMAA&url=http%3A%2F%2Fhealthvermont.gov%2Fenviro%2Fpfoa.aspx&usg=AFQjCNFR3Bcs-LuGTmyduIkQC2GrY0OL_g&sig2=mmGCUao320e3RWF53URz2Q)

The EPA advisory level of 0.4ppb is wrongly being used across the nation to judge the safety of drinking water where PFOA has been found; the 0.2ppb is being used as a trigger for action for PFOS.  The 0.4 and 0.2 levels are based on short term exposure (typically based on 10-14 days of exposure but EPA has never said how long they consider the PFOA/PFOS advisory levels to apply) and is not a valid level to use as a measurement of what is safe for drinking water. 

EPA says they are developing a lifetime health advisory level but it has not yet been issued.  The advisory does not mandate that water suppliers remove PFOA or PFOS from drinking water; it is just an advisory, not a federal enforceable standard.  Because the EPA PFOA advisory level is so high at 0.4 ppb and for PFOS at 0.2 ppb, those water systems that show levels below EPA’s advisory levels are under the mistaken impression that their water supply is safe and they don’t need to take any action. This has become a controversy where EPA has applied inconsistent levels in advice to communities with PFOA contamination.

For instance, in New York 0.1ppb was used by EPA as the trigger to advise people to use bottled water instead of tap water.  New Hampshire also is following that advice. Bucks County water systems around the military bases are considering using 0.1ppb until a lifetime advisory is issued.  The federal advice on PFCs has been inconsistent and inexcusably slow; the short term advisory was never explained fully by EPA to communities, which has led to wrong assumption about safety and a continuing lack of action to remove contaminated water from use.

Data collected by the Delaware River Basin Commission (DRBC) and published in a report in July 2012 revealed very high levels of PFNA in surface water in samples between 2007-2009 in the Delaware River.  PFCs were also found in river water and in fish flesh.  Additional investigations are ongoing by DRBC. http://www.state.nj.us/drbc/library/documents/contaminants-of-emerging-concernJuly2012.pdf

Extensive independent studies have concluded that there is a probable link between exposure to PFOA and testicular cancer, kidney cancer, and four other diseases, based on studies in West Virginia and Ohio communities and other information. (http://www.c8sciencepanel.org/pdfs/Probable_Link_C8_Cancer_16April2012_v2.pdf)  The Panel has also found many other health impacts in human populations exposed to PFOA in drinking water. (http://www.c8sciencepanel.org/index.html)  PFNA studies report similar health effects but at lower doses. 

Meanwhile, in 2013/14 Gloucester County municipalities were taking action on their own; people came out by the hundreds to public meetings demanding the pollution be addressed.  Municipal wells were shut down, the Borough of Paulsboro filed a Notice of Intent to Sue against Solvay and bottled water was paid for by Solvay for area residents while investigations were done.  Over the following months, the cleanup of PFCs under NJDEP’s Resource Conservation and Recovery Act program was amended to include PFCs and an interim groundwater standard was proposed.  NJDEP installed Point of Entry Treatment (POET) systems on private water wells where PFNA above 20 ppt were found.  DRN has taken part in all public processes available, including  engaging experts to provide technical and scientific input into the several decisions that are being made regarding bringing PFCs under regulation and cleaning it up from the environment.  Paulsboro settled with Solvay; Solvay agreed to install a carbon treatment system on the Borough’s water supply to remove PFCs; the installation is expected to be complete in spring 2016.  Other municipalities with high levels of PFNA have announced they will be filing notices to sue Solvay as well. 

The Drinking Water Quality Institute was reconvened in April 2014. http://www.nj.gov/dep/watersupply/g_boards_minutes.html The DWQI agenda was to research safe drinking water standard recommendations for PFNA, PFOA, and PFOS.  The Institute first worked to research PFNA, a highly toxic PFC that required immediate attention.  After extensive study, public input and discussion, the Institute issued a recommendation to DEP for PFNA of 13ng/L. http://www.nj.gov/dep/watersupply/pdf/pfna-recommend-final.pdf

Reports issued by the DWQI’s Health Effects Subcommittee, Treatment Subcommittee, and Testing Subcommittee all showed that the recommendation was scientifically based, that PFNA could be accurately tested for and that PFCs (all PFCs, including PFNA and PFOA) could be economically treated with available technology such as carbon filtration.  The maximum contaminant level of 13ng/L recommended to NJDEP for rulemaking has not been acted on by NJDEP and there has been no explanation offered to the public about why DEP has stopped further forward motion on a MCL for PFNA.

The DWQI is updating the current guideline of .04 ppb for PFOA, a value that is now out of date and not protective of public health considering the considerable amount of toxicology data and reports since the guidance level was set by DEP in 2007.  Up to that time, only developmental effects in rats had been studied and rats are not a good model for humans due to differences in blood.  Chief among the new bodies of data and findings available are those from the court-ordered C8 Health Panel and the C8 Health Project in West Virginia, related to the Dupont facility there.  Among the conclusions of this multi-year study of human subjects and scientific reports, it was found that PFOA is linked to Kidney Cancer, Testicular Cancer, Thyroid Disease, High Cholesterol, Pregnancy-Induced Hypertension/Preeclampsia, and Ulcerative Colitis.  http://www.c8sciencepanel.org/newsletter10.html

The probable link to the health effects were found by the study in the general population and in communities with water contaminated with PFOA.  In addition to the six diseases with probable links, the study also verifies probable links to decreased birth weight and decreased response to vaccines.  A report reviewing all of the studies on low birth weight concluded that PFOA does reduce human birth weight.  http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4181929/pdf/ehp.1307893.pdf

The DWQI is expected to issue a recommended safe drinking water level in 2016. NJDEP would then promulgate a regulation to establish a maximum contaminant level (MCL) for PFOA through a public rulemaking process.  NJDEP needs to take immediate action to establish these standards; the MCL will apply across the state to all water systems and will likely spur the installation of carbon filtration in many places.  PFOS is likely the next PFC that the DWQI will address. 

The scientific studies on PFOA make it very clear that low levels of exposure to PFOA build up in the body over time because the compound is not broken down by the body and takes years to excrete.  That means that even very low drinking water exposure increases blood levels over the levels found in the general population, risking disease and adverse health effects.  Infants are exposed through breast milk and also through formula that uses contaminated water.  Since infants and children are susceptible to developmental effects, the impact is even greater than for adults.  These facts show us that extremely vulnerable fetuses, infants, and children are being exposed to the risk of disease and developmental abnormalities from ingesting even low levels of PFOA.  This constitutes a health emergency and requires DEP to take regulatory action now.  

Compounding the pollution problem is the fact that PFCs do not break down in the environment either.  Even though they have been phased out of manufacture, they are still in groundwater, soils, treatment plant sludges, and other media (carried often for a distance due to air flows) and will remain there unless removed by intentional cleanup efforts.  Some sources of PFCs, such as firefighting foams containing PFCs that are the cause of most if not all military base contamination incidents, are still being used because the foams have a long shelf life and are expensive to replace.

Action is being taken in other places where this issue has come to light.  Pennsylvania, New York, Vermont, New Hampshire, and Michigan are some of the locations where high PFCs have promoted an outcry for action by communities; some states are responding, some are lagging behind.  EPA has said they expect to issue a lifetime health advisory in spring 2016.

Recent investigative news articles have highlighted the toxic legacy of Dupont, 3M and other sources of PFC pollution.  A series by Sharon Lerner in The Intercept chronicles PFC pollution, corporate responsibility, and government inaction.  https://theintercept.com/search/?s=Teflon%20toxin On January 10, 2016 the New York Times featured an article by Nathaniel Rich about attorney Robert Bilott who has spent his career battling Dupont to expose the truth about the dangers of PFOA. http://www.nytimes.com/2016/01/10/magazine/the-lawyer-who-became-duponts-worst-nightmare.html?_r=0   Another investigation by reporter Mariah Blake, published in the Huffington Post, told the Parkersburg, West Virginia story in detail. http://highline.huffingtonpost.com/articles/en/welcome-to-beautiful-parkersburg/

The recent media attention to this pollution issue shines an uncomfortable light on New Jersey where the PFOA pollution problem is huge, greater than most other states with 88 occurrences documented in  the last UCMR3 sampling, more than twice that of New York.  Yet NJDEP has not taken action to set a standard that would require treatment to remove PFOA or other PFCs from drinking water.

Also in the Delaware River watershed, Bucks County has become aware of the presence of PFCs, specifically PFOS and PFOA, in extremely high levels in water near 2 military bases. Of the sampling results available, the extremely high levels of PFOS and PFOA in the vicinity of the former Naval Air Station at Willow Grove and the Naval Air Warfare Center in Warminster, both in Bucks County, are of very high concern.  Sampling done in Warminster, Warrington and Horsham Townships report that the groundwater that feeds public and private wells there are among the worst in the nation. https://www.epa.gov/sites/production/files/2015-09/ucmr-3-occurrence-data.zip Subsequent sampling of local water supplies have confirmed the continuing presence of high levels of these compounds, several results showing even higher levels than the UCMR3 data. Illnesses reported in news media in the vicinity of the bases make the need for action to remove all of these toxic substances from the water even more urgent. 

In Doylestown Township in Bucks County, the Municipal Authority had the sixth highest PFOA sample report in the nation but reportedly is not taking action because the level was less than the EPA’s 0.4 ppb for PFOA and 0.2 ppb for PFOS; Bristol Township’s water provider, Aqua PA, is also reportedly not taking action based on the EPA advisory standard.  This mistake could be occurring in other places in the state where PFCs are being found.  Water suppliers are not taking action unless the levels reach the EPA short term advisory of 0.4 ppb for PFOA, which we know is not protective.

PFC contamination in Bucks County (and PFCs were found in other places in Pennsylvania as well) needs urgent action. Residents are becoming alarmed as more information emerges. DRN has written letters calling for action and recommending what can be done to PA Governor Wolf, Congressmen who represent the Bucks/Montgomery County area and PA State legislators and has met with legislators, attended municipal meetings to get attention to this issue, which the local municipalities are struggling to address.  All letters are available on this website. The Navy, National Guard Bureau and local water providers in Bucks County, where the PFOA and PFOS are so alarmingly high, are using incomplete data and inadequate standards to identify contamination that should be addressed.

Unfortunately, using too high a level as a trigger for action (the EPA short term advisory of 0.4ppb), meant that the water replacements and treatment being paid for by the military in the area around the Bucks County bases is likely not nearly what they, as the responsible party, should be covering.  For instance, as additional wells are shut down due to contamination, costs for replacement water could go up in amounts that are not covered by current agreements between the Navy and municipal water authorities.  Also, if too high a standard is applied some people could still be drinking contaminated water.

On May 19, 2016 EPA issued a combined drinking water health advisory for Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS) of .07 ppb (70 ppt).  EPA stated that the agency’s “…assessment indicates that drinking water with individual or combined concentrations of PFOA and PFOS below 70 parts per trillion is not expected to result in adverse health effects over a lifetime of exposure.”   See: https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos The new EPA health advisory has had a huge effect at the local level, requiring the removal form use of more water wells, both public and private supplies. This is a considerably lower level than the short term provisional health advisory that has been in place since 2009; the short term advisory was used as the trigger for action by communities facing PFOA and PFOS contamination.  Many people have been drinking water that was considered to be safe under the former short term advisory but is now not considered to be safe.  Water suppliers and private well users need to make sure that water that contains this level is taken out of use immediately.

DRN issued a statement called into question the adequacy of this advisory level considering the toxic effects of the compounds based on all the scientific literature and human health studies available.  See: http://www.delawareriverkeeper.org/sites/default/files/Press%20stmnt%20PFOAPFOS%20EPA5.19.16.pdf  DRN advocates for PFOA and PFOS to be removed completely from drinking water, requiring water supplies to be treated so that PFOA and PFOS are not present at all.  These toxic compounds do not occur naturally; they have been introduced to our drinking water and environment by dischargers and do not belong there. 

It is important to keep front and center the fact that Dupont and 3M, as the corporations that invented and manufactured perfluorinated compounds that went into the products discharged to the environment at these facilties must be investigated as the ultimate responsible parties.  Are these wealthy corporations being probed for culpability to identify all parties responsible that should contribute funds to address this crisis?  Cleanup of the contamination shouldn’t be stymied by or excused from immediate action by a lack of available money. 

Wherever PFCs have been found, there needs to be more thorough sampling of all drinking water sources and other media to locate these compounds and the specific sources of contamination at the lowest levels that can be detected.  The UCMR3 data is only the tip of the iceberg, snapshots of some selected water systems.  The presence of PFC contamination of water in regions around military bases where firefighting foams were used prolifically – such as in training and air fields over the decades – present the Department of Defense with a national problem that needs coordinated nationwide attention. 

Environmental and health agencies at the state level need to be involved in the response;  these  agencies should step up to help local communities by conducting further sampling of drinking water where these compounds may be present and conducting investigations to identify the responsible parties and hold them accountable for their actions. 

Where contamination is discovered but no responsible party is yet identified, the state should be providing alternative sources of safe water to residents.  The state can pursue re-imbursement from those responsible but immediate action should not be delayed.  The federal government should fully fund the Drinking Water State Revolving Fund and the Clean Water Revolving Fund to provide needed monies.

Additionally, there needs to be testing of human blood of residents who have been drinking this water and living near or working on land that has been contaminated, followed by health studies of the population.  The state’s cancer registry should be fully analyzed by state epidemiologists for occurrences of linked diseases in PFC contaminated regions.  Finally, safe drinking water standards need to be adopted federally and at the state level to remove to non-detect all PFCs from drinking water. The health risks (and the vulnerable populations exposed) are simply too great to warrant any less.

PFCs are a national problem and require active participation by EPA, the Department of Defense, state agencies, the Centers for Disease Control, academic institutions and others to get on top of this widespread water contamination issue and remove these toxic compounds from drinking water and the environment.  Ultimately, the costs must be covered by responsible parties to ensure our water and environment are safe from these highly toxic compounds so closely correlated to human disease and adverse health effects.

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Tracy Carluccio

Delaware Riverkeeper Network

June, 2016

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