Letter to EPA: Drinking water contamination from PFAS

May 22, 2018

Administrator Scott Pruitt

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington D.C. 20460

We are writing to you on behalf of the millions of residents in our states facing drinking water contamination due to the use of PFAS chemicals in our products, in firefighting foam and in manufacturing processes around the country.

PFAS is a family of over three thousand chemicals that are used as grease-­‐proofing and water-­‐ proofing agents. They are used in class B firefighting foam, food packaging, clothing, building materials and manufacturing processes. While the most well known PFAS—PFOA and PFOS— have been phased out of manufacturing in this country, their legacy of contamination lives on. Moreover, PFOA and PFOS have been replaced in many instances with other chemicals in the PFAS family despite a lack of safety data and against the advice of over 200 international scientists.

PFAS has now been confirmed to contaminate the water of over 16 million Americans and that number will likely increase as investigations into the chemicals increases. The cost of cleaning up these chemicals is enormous and, thus far, taxpayers have had to shoulder most of the burden.

We are encouraged that the EPA is hosting a summit to address PFAS contamination. States have been on the forefront of confronting this issue for many years. They best know their communities and the concerns that their citizens have over the pollution caused by the use of PFAS chemicals. Several states have taken action in the past three years to address PFAS including setting their own reference levels, suing manufacturers and banning products containing these products.

This summit provides the EPA with an opportunity to give states the additional tools they need to be able to confront this public health crisis:

1. EPA to release any information about PFAS health risks, including new risk levels developed by the Agency for Toxic Substances and Disease Registry (ATSDR).
2. Analytical methods for identifying all PFAS in water and soil. States rely on the EPA for scientific expertise and need the agency’s guidance as they move forward with state drinking water standards and other health protections. Current testing methods can identify only a handful of these chemicals in the environment, but the more states look for these chemicals, the more they find. States need the EPA to quickly develop analytical methods for all PFAS in water and soil so that states can better understand the scope of the problem and find solutions to mitigate this crisis.
3. Technical assistance on how to clean up PFAS in water and soil. While current technology will remove some of these chemicals from water, huge gaps exist in technology to remove many PFASs from environmental media. EPA must provide assistance to states on how to clean up these chemicals.
4. Information on where and how PFAS are used in the United States. States need more information about where all PFAS are used to better understand the sources of the contamination. EPA should make use data available to the public for all PFAS both in consumer products and manufacturing processes.
5. Support for changing the military specification to allow for PFAS-­‐free firefighting foams. The Department of Defense and Federal Aviation Association widely adopted the current military specification that requires the use of PFAS-­‐containing firefighting foams. The use of these foams at military bases is responsible for contaminating drinking water and creating many contaminated sites across the country, at great cost to states and federal taxpayers. The DOD is estimated to be spending over $2 billion to address the contamination created by these foams. Governments around the world no longer use these types of foams. Washington State just restricted the sale of PFAS foams for its local firefighting districts and adopted a ban on training with PFAS foams at any facility, including airports. As long as these foams remain in use, further contamination of drinking water and the environment is inevitable. EPA should actively support changing the DOD’s military specifications to ban the use of firefighting foam containing PFAS.

Polluted drinking water impacts everyone in a community. We need solutions now to protect this precious resource and ensure clean and safe drinking water for all. We need EPA’s help to make sure our states can adequately address PFAS pollution and prevent future contamination.

We additionally call on all states to eliminate the non-­‐essential uses of PFAS including in food packaging, textiles and firefighting foam.

States have long been on the forefront of environmental and public health protection and this issue is no different. With the assistance of the EPA, our states will be better equipped to protect the public from this environmental and public health threat.

Sincerely,

Laurene Allen, Merrimack Citizens for Clean Water

Christine Appah, New York Lawyers for the Public Interest

David Berrey and Nana Paldi, W.A.T.E.R.

Hacah Boros, CT Nurse’s Association

Sylvia Broude and Shaina Kasper, Toxics Action Center

Alvaro Palacios Casanova, Center for Environmental Health

Marcia Cooper, Green Newton

Angela Crowley-­‐Koch, Oregon Environmental Council

Kathy A. Curtis, Clean and Healthy New York

Tom Estabrook, Massachusetts Teachers Association

James Ewell, Sr., GreenBlue Institute

Beth Fiteni, Green Inside and Out

Rachel L. Gibson, Health Care Without Harm

Margo Golden, Massachusetts Breast Cancer Coalition

Susan Gordon, Fountain Valley Clean Water Coalition

Jon Groveman, Vermont Natural Resources Council

Loreen Hackett, #pfoaprojectny

Lauren Hierl, Vermont Conservation Voters

Anne Hulick, Coalition for a Safe and Healthy CT

Jillian Lane, Greenland Safe Water Action

Sharon Lewis, CT Coalition for Environmental Justice

Patrick MacRoy, Environmental Health Strategy Center

Kristi Marsh, Savvy Women’s Alliance

Lilly Marcelin, Resilient Sisterhood Project

Grady McCallie, North Carolina Conservation Network

Jamie McConnell, Women’s Voices for the Earth

Óskar Zambrano Méndez, Latino Community Fund of WA State

Rebecca Meuninck, Ph.D., Ecology Center

Pamela Miller, Alaska Community Action on Toxics

Lisa Moll, New Hampshire Safe Water Alliance

Suzanne Novack, Earthjustice

Dr. Mark S. Rossi, Clean Production Action

Sue Phelan, GreenCAPE

Gretchen Salter, Safer States

Elizabeth Saunders, Alliance for a Healthy Tomorrow

Bob Shavelson, Cook Inletkeeper

Lynn Thorp, Clean Water Action

Heather Trim, Zero Waste Washington

Laurie Valeriano, Toxic-­‐Free Future

Deanna White, Healthy Legacy