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ASDWA Summarizes States’ Challenges in Comments to EPA on Draft Toxicity Assessments for GenX and PFBS

In mid-November, EPA released draft toxicity assessments for GenX and PFBS. Comments were due to EPA yesterday (1/22) and ASDWA submitted comments (below) that summarized states’ challenges with toxicity assessments and health advisories. After the public comment period, EPA will consider the comments, revise the draft documents, as appropriate, and then publish final toxicity assessments. With the ongoing partial federal government shutdown (today is Day 32), it’s anybody’s guess when the final toxicity assessments will be published.

ASDWA’s comments (below) summarize some of the challenges states are facing with toxicity assessments versus health advisories versus regulatory standards. While it’s helpful to get as much information out as possible as quickly as possible, these toxicity assessments beg the question – “what’s next”? What are states (and water systems) supposed to do with these numbers? Some states have the knowledge, skills, and resources to combine these numbers with feasibility analyses, technical evaluations, and benefit-cost analyses to develop and implement action levels, health advisories, or regulatory standards in the absence of a federal advisory or standard. However, other states don’t know the authority, knowledge, skills, and resources to move forward without a federal advisory or standard. This leads to variation in states’ actions across the country to address the compounds with a plethora of numbers with different names, and that’s confusing to the public and doesn’t meet their expectations for uniform, safe drinking water across the country.

ASDWA GenX and PFBS Tox Comments 01222019 Final