Safe drinking water and the new EPA boss

I am writing to the new CEO of the Environmental Protection Agency (EPA) regarding the recent rule establishing nationwide drinking water standards for certain polyfluoroalkyl substances (PFAS).

I have a strong interest in protecting residents from the harms of PFAS exposure through drinking water.

The presence of PFAS in drinking water poses a well-established threat to public health and safety. A growing body of research indicates that most, if not all, PFAS are highly toxic to humans and animals. Even minimal exposures over time are associated with adverse effects on human health.

PFAS are resistant to degradation in the environment, earning them the label of “forever chemicals.” These toxins were used for decades in various industrial and military settings, including airports and fire departments. As a result, dangerous and highly mobile PFAS have contaminated numerous drinking water sources throughout the state and have accumulated in the bodies of our residents, where they persist.

It is crucial that we regulate PFAS in drinking water. The EPA’s rule broadly complements and reinforces the various approaches taken by water utilities. The EPA must exercise primary enforcement authority over drinking water in our communities, particularly in mining districts, and must have a vested interest in the laws it enforces.

I urge you to carefully review the operations of water systems such as the Ghana Water Corporation and other water-producing companies in Ghana. Please pay particular attention to petitions from homeowners and residents across the country regarding the need for portable, affordable, safe drinking water.

Drinking water comes from both public water systems and private wells, which are supplied by surface waters and underground reservoirs that are vulnerable to contamination, including from PFAS.

PFAS are a class of synthetic chemicals used in numerous consumer and industrial products. They are characterised by strong carbon-fluoride bonds, which enable many PFAS to persist in the environment for years, decades, or even longer.

Research over the past two decades has clearly demonstrated PFAS toxicity, showing that even small exposures over time are associated with a range of adverse health effects, including various cancers, liver disease, developmental issues (such as low birth weight), hormonal changes, a weakened immune system, diabetes, and fertility issues. Moreover, oral exposure to certain PFAS is linked to harmful health effects, including impacts on the liver, thyroid, immune system, pregnancy, fetal development, and cancer. While some PFAS, such as PFOA and PFOS, have been phased out of domestic production, they remain in circulation through existing products and newly imported items.

The determination to regulate PFAS requires a notice-and-comment rulemaking process, considering public health-focused criteria to seize “meaningful opportunities for health risk reduction.” This process does not take cost into account, but instead uses the “best available public health information” and the EPA’s database of occurrences.

The enforceable drinking water standards must be set as close to the health goals “as is feasible.” While cost considerations are factored into the feasibility analysis, the Act does not mandate that the benefits of a standard outweigh its costs.

In setting these standards, the EPA is required to use the “best available, peer-reviewed science” and data gathered using the “best available methods.” In California, drinking water regulators have taken concrete steps to quantify PFAS contamination, starting with general drinking water monitoring orders in 2019, and establishing non-regulatory notification and response levels for certain PFAS beginning in 2020.

The Science Advisory Board supported the EPA’s conclusion by agreeing with its evaluation of contaminants based on similar health outcomes, noting that “many PFAS, including the four used in the examples in the draft EPA mixtures document and others, elicit effects on multiple biological pathways that have common adverse outcomes in several biological systems.”

Given that the Index PFAS have dose-additive effects when combined, the EPA cannot promulgate a health goal to avoid adverse human health effects and allow a margin of safety without considering the hazard index. Promulgating individual goals for the Index PFAS alone would be insufficient to meet the requirements of the Act. Therefore, the EPA must use the hazard index to address the relative toxicity and common health risks of these PFAS in compliance with the clear language and proactive intent of the Act.

Furthermore, the EPA cannot set appropriate goals if it considers contaminants in isolation, ignoring threats to public health arising from mixtures of contaminants with dose-additive effects. Such an approach would be inconsistent with the requirements of the Act. The EPA also regulates the sums of radionuclides under the Act, requiring water systems to aggregate the measured values of individual contaminants.

In light of the ongoing challenges posed by illegal mining (the “galamsey menace”) and its impact on our water bodies, I believe mining companies should be held accountable for supporting water systems in the country. I wish you the best in your new role and encourage both you and the Ghana Water Company to ensure that Ghana has access to safe, potable drinking water at an affordable rate.

While much attention has been focused on the energy sector, safe drinking water is intrinsically linked to our nation’s public health and well-being. I am raising this issue now because it has become critically important, especially in light of numerous media reports regarding the state of our water bodies and the district machines that clean and purify water for our homes. We are relying on you to prioritise this issue as you begin your tenure as CEO of the EPA.

The writer, Dr. Adomako Kissi, is the former Vice Chairman for the Environment, Science, Innovation and Technology Committee and Former Health Committee Member.