The White House has released their three-year plan to address per- and polyfluoroalkyl substances (PFAS). Will this roadmap get us any closer to action?
Eight Agencies Involved
As an indication of the widespread impact of PFAS is the number of agencies involved in this plan. The agencies involved (beyond the EPA) include the White House Council on Environmental Quality (CEQ), the departments of Defense, Agriculture, Homeland Security, Health and Human Services, Food and Drug Administration, and the Federal Aviation Administration. This is not unlike the approach in Michigan under Michigan PFAS Action Response Team (MPART).
In the introduction to the PFAS Roadmap, the Environmental Protection Agency states, “The EPA Council on PFAS developed this strategic roadmap to lay out EPA’s whole-of-agency approach to addressing PFAS. To deliver needed protections for the American people, the roadmap sets timelines by which the Agency plans to take specific actions during the first term of the Biden-Harris Administration. The strategic roadmap builds on and accelerates implementation of policy actions identified in the Agency’s 2019 action plan and commits to bolder new policies to safeguard public health, protect the environment, and hold polluters accountable.”
The EPA says their integrated approach is focused on three central directives:
- Research. Invest in research, development, and innovation to increase understanding of PFAS exposures and toxicities, human health and ecological effects, and effective interventions that incorporate the best available science.
- Restrict. Pursue a comprehensive approach to proactively prevent PFAS from entering air, land, and water at levels that can adversely impact human health and the environment.
- Remediate. Broaden and accelerate the cleanup of PFAS contamination to protect human health and ecological systems.
The EPA states, EPA will bring “deeper focus to preventing PFAS from entering the environment in the first place—a foundational step to reducing the exposure and potential risks of future PFAS contamination.” This begs the question; could this focus lead to more site inspections and information requests by state and federal regulators?
According to the “roadmap” the EPA’s approach to PFAS will include the following:
- Consider the Lifecycle of PFAS. EPA will account for the full lifecycle of PFAS, their unique properties, the ubiquity of their uses, and the multiple pathways for exposure.
- Get Upstream of the Problem. EPA will bring deeper focus to preventing PFAS from entering the environment in the first place—a foundational step to reducing the exposure and potential risks of future PFAS contamination.
- Hold Polluters Accountable. EPA will seek to hold polluters and other responsible parties accountable for their actions and for PFAS remediation efforts.
- Ensure Science-Based Decision Making. EPA will invest in scientific research to fill gaps in understanding of PFAS, to identify which additional PFAS may pose human health and ecological risks at which exposure levels, and to develop methods to test, measure, remove, and destroy them.
- Prioritize Protection of Disadvantaged Communities. When taking action on PFAS, EPA will ensure that disadvantaged communities have equitable access to solutions
“Where’s the Action?”
Attorney, Robert Bilott (portrayed by Mark Ruffalo in the movie Dark Waters) was less sanguine about the roadmap and tweeted the following:
“Where is the actual ACTION by @EPA here? It’s been over 20 years since we asked EPA to take enforceable concrete action on #PFAS and still more talk and “plans” to act maybe next year or…the year after that…@DarkwaterMovie #ExposureBook @rightlihood.”
Maximum Contaminant Levels
Bloomberg Law states “The EPA’s planned rules include releasing by fall 2023 final drinking water limits for the two most-studied and particularly hazardous PFAS: perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS).”
Establishing scientifically sound, maximum contaminant levels for PFOS and PFOA at the federal level would be welcomed news. Some of the state-established MCLs have been called into question. Further, with federally-established MCLs, other standards such as groundwater cleanup criteria are more certain, when answering the question, “How clean is clean?”
Is this an actionable plan that will lead to establishing the long-awaited federal MCLs? Alternatively, is it as lawyer, Robert Bilott intimated, more plans than actions? Whether you are a regulator, the regulated community, or an environmental group, all would welcome some scientific certainty sooner than later.
As a consulting/advisory firm with a strong foundation in using science and data to drive decisions, we are pleased that the roadmap contains “science-based decision making.” Especially, as we hear about some groups suggesting treating all PFAS the same – a “one size fits all approach.”
If you need assistance with a PFAS issue, you can contact Jeffrey Bolin, M.S., Senior Environmental Scientist or Matthew Schroder, M.S., P.E., Senior Environmental Engineer. Our office phone number is 248-932-0228.
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