You may have been reading in the media stories about “forever chemicals” in the environment. These stories refer to a category of chemicals known as per- and polyfluoroalkyl substances (PFAS), and there are thousands of different types. They have been in mass production in the country for over 60 years and are completely ubiquitous throughout the environment, meaning you will find them everywhere from water, grass, food, to clothing, carpeting, consumer care products, dust, and they are already in everyone’s bloodstream. Typically, the main source of ingestion of these chemicals is from consumer products and food, which have not been regulated to date. The only thing that is currently being regulated is drinking water. The Federal Environmental Protection Agency (EPA) develops drinking water standards for all contaminants and is currently working on nationwide standards for this category of chemicals. EPA currently has a Health Advisory of 70 parts per trillion for two PFAS chemicals (PFOA & PFOS). Some states went ahead and have already developed standards on their own (without EPA), which has lead to much confusion as there are different standards for different states. These standards were largely set in haste with little stakeholder input and limited data. MA is one of the states that developed their own standard, without using the same standard development process that the EPA uses. As result, the standards set for drinking water in MA were set so conservatively low (largely for legal liability reasons), that the levels are down to the lowest level that technology can test to. With detection levels of 5-10 parts per trillion (as low as technology can go) and maximum allowable levels of 20 parts per trillion (PPT) for six different types of PFAS chemicals. These six PFAS compounds are: perfluorooctane sulfonic acid (PFOS); perflourooctanic acid (PFOA); perflourohexane sulfanic acid (PFHxS); perfluoroonanonic acid (PFNA); perflourodecanoic acid (PFHpA); and perflourodecanoic acid (PFDA). MassDEP abbreviates this set of six PFAS compounds as “PFAS6”. The maximum allowable level of 20 PPT is so low that it is approaching background levels found in the environment. Additionally, laboratories are having a difficult time meeting quality control standards testing down to these levels. State Regulations were published in late 2020 and larger water systems were required to start testing in January and April 2021. As expected, there was confusion with sample results and many lab reports were rejected due to quality control issues. Our company is scheduled to test in October 2021. We have no reason to believe these chemicals will be found in our sources as they are well protected. But the uncertainty of such low standards has created many concerns about the reliability of results. Most contaminants tested in drinking water are in parts per million, some more recent contaminants have even been in parts per billion, but this new standard of parts per trillion is new territory for the industry (one part per trillion is equal to one second in 32,000 years). When sampling, our collector cannot wear certain types of clothing, or have used certain types of shampoo, or deodorant, or other personal care products in the past 48 hours or it may cause a positive test. So we will need to hire a professional firm to simply collect the samples. From a common sense stand point, this seems quite irrational because you are likely consuming far higher levels of these chemicals in your food from your local grocery store, but this goes unregulated. All the while, the state has set extremely low standards for public water systems. And one of the most significant concerns with this new standard is that the maximum allowable level of 20 parts per trillion is set ONLY for pregnant or nursing women, infants, and people diagnosed by their health care provider to have a compromised immune system. So this standard is NOT for the general public. This again is a first for the industry as all prior regulated contaminants were based on the health of the general public and not just a small sub group of the general public. To date, there is no standard for the general public as there is insufficient data to set a standard. As noted above, EPA has a Health Advisory of 70 parts per trillion. Some home treatment systems are certified to treat to this level. We are not aware of any home treatment units that are certified to treat down to the state standard of 20 parts per trillion.
And lastly, there is the issue of equity in that these chemicals are still being brought into the state and used for many different purposes. Massachusetts has not banned the import and use of these chemicals to date. Therefore the chemicals are still being introduced into the environment, consumer products, and the food industry through numerous sources. It seems unfair that water utility rate payers should be bearing the cost to clean up and remove these chemicals from water sources as the chemicals were not put there by the water suppliers. Further, there are currently no standards for wastewater discharges into rivers. So when a water utility removes the chemical through filtration (at a cost of many millions of dollars paid for by the rate payers), the filtration process may create a waste water stream that then gets sent to the local wastewater (sewer) treatment facility which is not equipped to remove the chemical. So the chemical gets put right back into the river. This seems highly inefficient. The State needs to develop a comprehensive plan to address these chemicals from start to finish, instead of just regulating one facet of the entire cycle.
As you can see, this is a very complex and confusing issue that has unfortunately been rushed through due to media and political pressures, which has resulted in untested standards that now must be met. We anticipate there will be many millions of dollars spent just in Massachusetts to treat drinking water down to these untested standards. These costs will be mostly born by the rate payers of the effected communities as the state is not providing sufficient funding for the treatment required in all effected communities. All the while, these chemicals continue to be used in various industries in the state without restriction.
For more information regarding PFAS, please visit: https://www.safewatermass.org/
Other fact sheets, data, and studies:
MADEP Study of PFAS Levels in Rivers where there are Sewer Discharges: https://www.mass.gov/doc/pfas-in-massachusetts-rivers-presentation/download
Note: This study did NOT sample the sewer effluent itself, only upstream and downstream of the discharge (doesn’t state how far downstream). It is reasonable to assume that if the effluent itself were sampled, levels would be exponentially higher than the current standard of 20 PPT. This again underscores the importance of a need for a comprehensive approach to addressing this issue instead of just regulating one single component.