|
Essential Oils |
Bella Mira Essential Oil Supplements
Essential Oil Information and Use
|
Chemical Free |
Chemical Free Body Care Products
Chemical Free Cleaning Products
|
Gluten Free |
Gluten Free Living and Recipes
|
Important Information |
Detoxification and Digestion Products
Save Your Computer Free Protection
|
Great Products |
|
FREE Wellness Tests |
Hormone Balance Test New Improved
|
Contact Us |
(918) 640-2973
Our Shopping Cart Is:
Free Samples w/$100 Order.
EWG Urges Drinking Water Standards for Teflon Chemical 5-24-08
Water Docket (2822T)
Environmental Protection Agency
1200 Pennsylvania Ave., NW.
Washington, DC 20460
Regarding: Drinking Water Contaminant Candidate List 3—Draft; Docket EPA–HQ–OW–2007–1189
FRL-08529--7
To Whom It May Concern:
The Environmental Working Group (EWG) is a non-profit public health and
environmental research and advocacy organization based in Washington, DC. EWG
research addresses toxic industrial chemicals that pollute the environment and
may be present in everyday consumer products. With this letter, we provide
detailed comments and recommendations to the EPA regarding its draft Drinking
Water Contaminant Candidate List 3 (CCL3), especially highlighting the urgent
need for the inclusion of pharmaceuticals and perfluorochemicals (PFCs) on the
final CCL3, and the promulgation of drinking water standards for these
wide-spread pollutants that pose health risks to millions of Americans.
EWG analysis of water utilities’ tap water test results shows that nationwide,
water contaminated with 260 chemicals, including 166 industrial pollutants, such
as plasticizers, solvents, pharmaceutical production ingredients, and
propellants, are served to 210,528,000 people in 42 states (EWG 2005b). Fifty
six percent of those people drink water with one or more industrial contaminants
present at levels above non-enforceable EPA guidelines. In fact, more than 140
of the chemical contaminants detected in tap water are unregulated, without an
enforceable, health-based limit in tap water. Due to the lack of federal
oversight and the absence of monitoring and health standards, vulnerable
populations, especially pregnant women and children, are not protected from this
multitude of toxic chemicals in drinking water.
As highlighted by the recent national investigation by the Associated Press
(Mendoza 2008), in addition to industrial chemicals, a wide range of
pharmaceuticals that include antibiotics, sex hormones, and drugs used to treat
epilepsy and depression, contaminate drinking water supplies of at least 41
million Americans. With every refreshing glass of water, millions of Americans
are also drinking low-level mixtures of highly potent pharmaceuticals. The
health effect of this cocktail of chemicals and drugs has not been studied, but
there are many reasons to be concerned about risks for infants and others who
are vulnerable. Pharmaceuticals, hormones, pesticides, and anti-microbial
ingredients from personal care products contaminate many streams around the
entire United States (Kolpin 2002). Chemical pollution of ambient waters
contributes to the load of chemicals in tap water. EPA needs to show leadership
and act with utmost dedication to protecting public health by mandating
monitoring and setting enforceable health standards forthese hazardous
contaminants.
We especially urge the EPA to include perfluorinated compounds on the final CCL3
list. PFCs are persistent, long-lasting industrial chemicals that have been
utilized in a variety of manufacturing applications such as production of
non-stick Teflon cookware, stain-proof Scotchgard products, grease-resistant
food packaging and other types of paper materials, as well as carpets,
water-proof textiles, and fire-fighting foam. In addition to the major
fluorochemical producers (DuPont and 3M in the United States), many secondary
manufacturers have used PFCs for decades in their products. Industrial
wastewater discharges and air emissions of PFCs from businesses that produce
stain- and grease-resistant paper, carpets, textiles, and furniture likely
contributed to the PFC pollution of drinking water supplies across the country.
Due to their extraordinary stability, PFCs last in the environment for thousands
of years. PFCs accumulate in bodies of both wildlife and humans, recirculating
through groundwater, lakes, rivers, and oceans, and coming back to people with
water, food, air and dust. As a result of decades of environmental discharges of
PFCs, these toxic chemicals are now found in many areas of the country, in many
bodies of water, and in bodies of more than 98% of all Americans (Calafat,
Kuklenyik 2007; Calafat, Wong 2007). At least 11 different states have
documented drinking or ambient water contamination with PFCs and a national
survey is critically needed to reveal the fullextent of PFC water contamination.
PFCs such as perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS)
and related chemicals, bioaccumulate and remain in blood, liver, and other
tissues for years. This persistence in the human body distinguishes PFCs from
other contaminants and significantly elevates the level of health concern,
making monitoring and the establishment of tap water standards critical for PFC
compounds. Contamination of drinking water with PFCs creates a constant source
of exposure and has been associated with some of the highest blood levels of
these toxic compounds ever measured. Some residents of communities in Ohio and
West Virginia drinking PFOA contaminated tap water had blood levels of PFOA 250
times the national average. These individuals experienced PFOA exposures
equivalent to occupational levels and in amounts associated with serious adverse
health effects, as demonstrated by initial data obtained in a major ongoing
epidemiological study in the region (West Virginia University School of Medicine
2008). It is thus reasonable to feel concerned that other communities in other
states drinking PFOA contaminated water would face similarly elevated exposures
and health problems.
PFCs have a broad spectrum of adverse health effects. PFOA exposure has been
associated with impaired fetal and neonatal development, changes in reproductive
and thyroid hormones, compromised immune and liver function, increased blood
cholesterol levels, and potential predisposition to chronic diseases later in
life. Gestational period, newborn babies and young children are the most
sensitive developmental stages that should be especially protected from PFC
contaminants in drinking water. During pregnancy, PFCs move to the body of the
fetus through the placenta (Apelberg, Goldman 2007; Inoue 2004; Midasch 2007;
Tittlemier 2004); a newborn child also gets a large dose of PFCs with breast
milk (Arcaro 2008; Karrman 2007; Kuklenyik 2004; So 2006; Tao 2008; Volkel
2007). Tap water standards for PFOA and other PFC will go a long way in
protecting the health of this vulnerable population from adverse effects both in
early development and in later life.
The Safe Drinking Water Act (SDWA) requires EPA to publish an updated list every
five years which details currently unregulated drinking water contaminants that
may pose human health risks. From this list, EPA must make determinations on
whether to establish tap water standards for at least five contaminants with a
national primary drinking water regulation. EPA originally considered three
candidate perfluorochemicals for inclusion into the Contaminant Candidate List
3: PFOA, a processing aid for manufacturing of Teflon non-stick and
water-resistant chemicals, PFOS, the primary ingredient in the furniture
stain-proofing coating Scotchgard that was phased out in 2000, and
perfluorobutanoic acid (PFBA), a replacement chemical that manufacturers are
increasingly using instead of longer-chain PFCs.
Of the three PFCs nominated for CCL3, only PFOA was included in the current
draft of CCL3. While we support the EPA decision to place PFOA on the list, we
urge the agency to add other perfluorochemicals including, but not limited to
PFOS and PFBA, as potential water contaminants that ought to be regulated under
the Safe Drinking Water Act. Given the widespread use of PFCs in industrial
applications and consumer goods ranging from food packaging to carpets and
textiles, as well as detection of multiple PFCs in bodies of 98% of Americans,
PFC contamination of drinking water requires thorough scrutiny in order to meet
current scientific and regulatory standards for safety.
Specifically, we urge EPA to:
* List a full range of perfluorochemicals on the CCL3, including, but not
limited to, PFOA, PFOS, PFBA, and other PFCs that have been found in the
environment and in people and that are likely to contaminate both finished and
ambient water sources;
* Establish regulatory standards for PFOA in drinking water;
* Include in the final CCL3 a broader list of contaminants found by water
utilities in tap water, especially focusing on antibiotics and other
pharmaceuticals.
Details and our rationale for these recommendations are provided below.
1. List a full range of perfluorochemicals on the CCL3, including PFOA, PFOS,
PFBA, and other PFCs found in the environment and in people.
We support the EPA decision to place PFOA on the Draft Drinking Water
Contaminant Candidate List 3. However, we disagree with the Agency’s decision to
exclude PFOS and PFBA from consideration as hazardous water contaminants. The
stability of PFCs in the environment makes these chemicals distinct from many
other classes of chemical water pollutants that have been previously regulated
by the EPA (Conder 2008). Biomonitoring studies carried out by the Center for
Disease Control found PFOS, PFOA, perfluorohexane sulfonic acid (PFHxS) and
perfluorononanoic acid (PFNA) in more than 98% of 2,094 people tested. For some
of these chemicals, children younger than 12 years of age have higher levels
than adults (Olsen, Church 2004). PFCs enter human bodies from different
sources, such as food, chemical-laden dust and water (Emmett 2006; Frisbee
2008). Various PFCs have been detected in finished and/or ambient water sampled
in various locations in 11 states (Table below). PFOA has been found in tested
water samples from all of these 11 states, PFOS has been found in 7 states, and
PFBA appears poised to become an emergent water contaminant (MDH 2008).
We urge the Agency to add PFOS and PFBA to the CCL3. Even though production of
PFOS has been banned by the EPA (US EPA 2002), this persistent and
bioaccumulative compound is still present in many water sources in the US (MDH
2008). PFOS negatively affects early development in animals and humans (Apelberg,
Witter 2007; Lau 2004); it interferes with the function of the nervous system
and causes neurobehavioural defects (Johansson 2008), kills immune cells and
weakens body’s capacity to resist infection (Keil 2008; Peden-Adams 2008), and
affects thyroid hormones that are critical for normal growth and maturation in
children (Lau 2003; Luebker 2005). Considering how common is PFOS contamination
of water sources, we believe EPA needs to set a regulatory standard to protect
the health of people, especially young
children, from PFOS.
In the absence of EPA guidance, states need to carry out their own risk
assessments and set water contamination levels for PFCs. For example, the
Minnesota Department of Health issued advisory guidelines of 1.0 μg/L for PFBA
and set the limits for other PFCs chemicals in drinking
water as well (MDH 2008). The presence of PFBA and other PFCs in groundwater at
the fluorochemical manufacturing sites points to the potential of these
replacement PFC chemicals to become new, emergent water contaminants whose
health consequences will be directly tested on
people exposed through drinking water. Now that the human health effects of PFC
contamination in drinking water are becoming widely known from the C8 (PFOA)
Health Project (West Virginia University School of Medicine 2008), it is
imperative to protect vulnerable populations from future exposures to PFCs.
EPA needs to assess cumulative risks associated with multiple PFCs in finished
and ambient water sources for children and other vulnerable populations. New
data are constantly coming to light that demonstrate the extent of water
contamination with PFCs (Fuchs 2008; Fuquay 2008;
Hawthorne 2008; Konwick 2008; United Steelworkers Union 2006). Already, drinking
and ambient water in 11 states is contaminated with PFCs and the full scope of
this problem might be even larger since businesses using fluorochemical products
are found all around the country. This gap in our knowledge should be filled
with a national survey of PFCs in water and a full range of PFCs should be
included in the Unregulated Contaminant Monitoring Program.
In summary, we urge the EPA to list perfluorochemicals on the final CCL3,
including, but not limited to, PFOA, PFOS and PFBA, and other PFCs that are
commonly detected in people and the environment, so that the agency can mitigate
the human health risks posed by these chemicals.
2. Establish regulatory standards for PFOA in drinking water.
We support the EPA in including PFOA on the Contaminant Candidate List 3 and we
urge the agency to take the next, urgently needed step for public health
protection by issuing national regulatory standards for PFOA levels in drinking
water. In order to help the individual states that look to EPA for guidance and
protect the health of all Americans, the agency should proceed with this step
immediately, even while the data on other PFC water contaminants are collected.
Unquestionably, PFOA meets all the criteria for a contaminant that requires
regulation by the EPA. Together with other PFCs, PFOA is now found in bodies of
98% of Americans (Calafat, Wong 2007); often, children younger than 6 years of
age have higher PFOA levels compared to adults (Emmett 2006; Olsen, Church
2004). PFOA can cross the placenta and transfer from the mother’s body to the
fetus (Apelberg, Goldman 2007; Inoue 2004; Midasch 2007; Tittlemier 2004). PFOA
contaminates the milk of breast-feeding mothers (Karrman 2007; Kuklenyik 2004;
So 2006; Tao 2008; Volkel 2007). Once ingested with food or water, PFOA
accumulates in the human body to 100-fold greater levels and persists for many
years (Emmett 2006; Olsen, Burris 2007). This means that trace levels of PFOA in
tap water can produce much higher long term exposures in people. For example,
drinking water from the Little Hocking water system in Ohio was contaminated
with PFOA at about 3.5 parts per billion (ppb), but some individuals drinking
this water, who had no other unique exposures to PFOA, had blood levels of PFOA
as high as 1,000 ppb (Emmett 2006).
As demonstrated by numerous studies in people and in animals, PFOA has an
adverse effect on many health parameters, such as fetal and neonatal development
(Lau 2004), immune function (DeWitt 2008; Yang 2002), reproductive and thyroid
hormones (Lau 2007), liver function (Frisbee 2008; Son 2007), and blood levels
of cholesterol and other lipids (Frisbee 2008; Olsen and Zobel 2007; Sakr,
Kreckmann 2007; Sakr, Leonard 2007). In two studies of newborn babies, higher
PFOA levels correlated with smaller weight and size at birth (Apelberg, Witter
2007; Fei 2007, 2008). PFOA exposure increases predisposition to obesity, heart
disease, diabetes, and stroke (European Congress on Obesity 2008; Leonard 2007;
Lundin 2007). PFOA causes liver, pancreatic, testicular, and mammary cancer in
animals (Sibinski 1987). In epidemiological studies, PFOA has been shown to
increase the risk of various cancers, especially prostate cancer, as well as
liver, kidney, and bladder cancers (Leonard 2007; Lundin 2007; Olsen, Burlew
2004).
Despite extensive denial of PFOA health effects by the chemical industry, toxic
effects of this chemical have been revealed by the chilling initial results from
the C8 Health Project (West Virginia University School of Medicine 2008), a
major epidemiological survey of residents in Ohio and West Virginia whose
drinking water supply has been contaminated by PFOA. Sixty nine thousand people
have been enrolled in the project, making it by far the largest study ever of
PFC health effects in people (Frisbee 2008). The health effects observed in the
study population are strong indicators of health problems that might be caused
by PFOA in average Americans. Toxic effects from PFOA were observed in study
participants with blood levels of the chemical equal to those found in the more
highly exposed individuals in the US population. It is reasonable to expect that
people in other states with contaminated drinking water may reach the same
levels of exposure associated with significant adverse health effects in this
study. As reported by the scientific team from the West Virginia University:
* Higher levels of PFOA in people correlate with lower levels of liver-produced
C-reactive protein that helps the body fight bacteria, viruses, and other
pathogens.
* PFOA exposure is associated with higher serum levels of two enzymes that can
indicate liver damage; the same findings as have been found in occupational
studies (Olsen and Zobel 2007; Sakr, Kreckmann 2007). These two findings
indicate powerful liver toxicity of PFOA.
* Elevated PFOA levels in children are associated with high cholesterol levels,
predisposing children to future weight problems and accompanying risk of heart
disease.
* PFOA-exposed people have abnormal levels of thyroid hormones.
The multitude of PFOA health effects is especially worrisome because both PFOA
and other PFCs are known to occur in public water systems with a frequency and
at levels of public health concern. PFOA has been detected in public water
supplies in many localities in West Virginia and Ohio (Emmett 2006; WVDEP 2005),
78% of drinking water systems tested by the New Jersey Department of
Environmental Protection (NJDEP 2007), and in multiple townships in Washington
County, Minnesota (MDH 2008). Additionally, drinking water supplies in some
localities in Georgia may potentially be contaminated with PFOA (United
Steelworkers Union 2006), where surface waters have been shown to be polluted
with high levels of various PFCs (Konwick 2008). Other affected states include
North Carolina (NCDENP 2008a), where groundwater contamination with PFOA in the
vicinity of DuPont’s Fayetteville Works plant doubled between 2006 and 2007
(Fuquay 2008), Alabama, where the Tennessee River is contaminated with PFOA and
PFOS emitted by the 3M fluorochemical plant (Decatur) (Hansen 2002), Illinois,
where both PFOA and PFOS have been detected in Chicago drinking water supply
(Hawthorne 2008) as well as New York and Virginia (Clean Water Action Alliance
of Minnesota 2008). All of these data are presented in the Table below:
State/affected water sources PFCs detected References
Ohio (drinking water serving city of Belpre, Little Hocking Water Association,
Tuppers Plains, Village of Pomeroy) PFOA (Emmett 2006; Frisbee 2008)
West Virginia (drinking water serving Lubeck Public Service district, Mason
county) PFOA (Frisbee 2008; WVDEP 2005)
New Jersey (78% of 23 drinking-water systems tested) PFOA, PFOS (NJDEP 2007)
Minnesota (cities of Oakdale, Lake Elmo, Woodbury, Cottage Grove) PFOA, PFOS,
PFBA (MDH 2008)
Alabama: Decatur/Tennessee river;
Mobile River PFOA, PFOS
PFOA (Hansen 2002);(3M 2001)
Georgia: Conasauga River; streams and ponds near Dalton, GA;
city of Dalton drinking water supply;
city of Columbus drinking water PFOA, PFOS, PFNA, PFDA, PFUA, PFOSA∗
PFOA, PFOS
PFOS (Fuchs 2008; Konwick 2008);
(United Steelworkers Union 2006);
(3M 2001)
North Carolina (ground water in Bladen County) PFOA (Fuquay 2008)
Illinois (Chicago tap water) PFOA, PFOS (Hawthorne 2008)
Virginia (ground and surface water) PFOA (Clean Water Action Alliance of
Minnesota 2008)
New York (rivers and lakes) PFOA, PFOS (Sinclair 2006)
Florida (Port St. Lucie, surface water) PFOA, PFOS (3M 2001)
Lakes Erie and Ontario PFOA, PFOS (Boulanger 2004)
∗perfluorononanoic acid (PFNA), perfluorodecanoic acid (PFDA),
perfluoroundecanoic acid (PFUA), perfluorooctane sulfonamide (PFOSA).
All together, various PFCs have been detected in finished and/or ambient water
sampled in various locations in 11 states. PFOA has been found in tested water
samples from all of these 11 states; PFOS has been found in 7 states. Most
worrisome, groundwater levels of PFBA, a replacement chemical for some of the
older PFC applications, appear to be on the rise (MDH 2008).
Without federal health standards for PFOA, individual states are forced to set
their own standards so as to protect their citizens. For example, PFOA standards
or risk-based levels have been established by North Carolina (2 μg/L) (NCDENP
2008b), Minnesota (0.5 μg/L) (MDH 2007) and New Jersey (0.04 μg/L) (NJDEP 2007).
The 2006 consent order between EPA and DuPont required the company to offer
alternative drinking water source or treatment for both public and private water
users living near the Washington Works plant in Parkersburg, West Virginia
whenever PFOA levels in their drinking water exceed 0.5 μg/L (US EPA 2006).
When confronted with such regulatory patchwork and the lack of guidance from the
EPA, many states do not know how best to proceed, leaving the health of
Americans at jeopardy (Hawthorne 2008; Sohn 2008). Many other states do not have
the resources or expertise to establish and enforce drinking water standards for
PFCs. Most states and the people who live in them depend on the EPA to protect
them from drinking water contaminants. A failure to act will leave the residents
in those states drinking tap water contaminated with highly toxic and persistent
PFC pollutants for many years to come.
EPA regulation of PFOA and other PFCs that are commonly detected in people and
the environment presents a meaningful opportunity for reduction of health risk
due to these industrial chemical pollutants in drinking water. We urge the EPA
to take much-needed action on PFOA and set a health-protective standard for PFOA
in drinking water that will rely on the best available science and safeguard the
health of millions of people.
3. Include in the final CCL3 a broader list of contaminants found by water
utilities in tap water, especially focusing on antibiotics and other
pharmaceuticals.
Pharmaceutical residues contaminate drinking water supplies when people take
various prescribed and over the counter medications. While their bodies absorb
and metabolize some of the chemicals, the rest is flushed out of the body and
down the drain. Drinking water treatment plants are not designed to remove these
residues, and the Associated Press (AP) National Investigative Team uncovered
data showing these same chemicals in treated tap water and water supplies in 24
major metropolitan areas around the US (Mendoza 2008). Together with earlier
publications by the US Geological Survey that identified pharmaceuticals and
personal care product chemicals in waters bodies and streams around the United
States (Kolpin 2002), the results of the AP investigation point to the potential
health dangers presented by pharmaceuticals in drinking water.
All of the pharmaceuticals reported in drinking water supplies are unregulated
in treated tap water—any level is legal. So far, the federal agencies have
failed to set standards for pharmaceuticals which are generally exempted by the
FDA from any environmental assessment (FDA 2008). Moreover, the EPA has not even
required water utilities to test for these chemicals. Drug residues in tap water
join hundreds of other synthetic chemicals Americans are exposed to daily, as
contaminants in food, water, and air, or in common consumer products. EWG found
an average of 200 industrial chemicals, pesticides and other pollutants in
umbilical cord blood from 10 babies born in the U.S., indicating that our
exposures to toxic chemicals begin in the womb, when risks are greatest (EWG
2005a). EWG analysis shows that of the top 200 drugs commonly prescribed in the
U.S., 13 percent are known to have serious side effects at levels less than 100
parts-per-billion (ppb) in human blood, with some causing potential health risks
in the parts-per-trillion range. These levels are dangerously close to the ones
found in drinking and ambient water sources (Kolpin 2002; Mendoza 2008).
We now call on the EPA to take swift action by setting standards for antibiotics
and pharmaceuticals in tap water that will protect the health of all Americans,
especially children. By the very nature of their design, pharmaceuticals can
have effects on human body even at low doses. We urge the EPA to include in the
final CCL3 a broad range of pharmaceutical resides and other contaminants found
in tap water. This action will serve as the first, much needed step for ensuring
the long-term health of our tap water – and the people who drink it.
In conclusion, presence of pharmaceuticals and perfluorochemicals in all states
where water samples have been tested for these compounds, and their effects on
the environment and on human health makes these chemicals very important
candidates for federal regulation under the Safe Drinking Water Act. Federal
drinking water policies and regulations should be set to ensure that vulnerable
populations, including pregnant women and children, are protected from chemical
contaminants in drinking water. Ingestion of drugs and PFCs with drinking water
presents a significant hazard for human health, especially during sensitive
times in life, such as in utero. Most states do not have the resources to
establish or enforce drinking water standards, and people in these states depend
on strong protections from the EPA. Regulation of these pollutants will assure
equitable and uniform protection for the health of all Americans. Thus, we urge
the EPA to follow up on the draft CCL3 by setting regulatory standards for both
pharmaceuticals and PFCs in drinking water.
Sincerely,
Olga V. Naidenko, Ph.D.
Senior Scientist
Environmental Working Group
1436 U street NW Suite 100
Washington, DC 20009
202-939-9157
Comment:
After reading this I can think of better reason to get a water ionizer!