Twenty-Two State Attorneys General Provide Joint Comments on EPA’s PFAS Regulatory Determination

On June 10, the Attorneys General from 21 states and the District of Columbia submitted comments on EPA’s Preliminary Regulatory Determinations for Contaminants on the Fourth Contaminant Candidate List (CCL4) that focused on developing PFAS drinking water regulations. The states included California, Colorado, Connecticut, Delaware, Illinois, Iowa, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Virginia, Washington, and Wisconsin. The Attorneys General comment letter focuses on four main points:

  1. Supporting EPA’s positive SDWA regulatory determination for PFOA and PFOS.
  2. Urging EPA to develop PFOA and PFOS maximum contaminant levels “well below” EPA’s existing health advisory level (of 70 parts per trillion (ppt) for PFOA and PFOS combined) in order to reflect current science and protect human health.
  3. Encouraging EPA to regulate other PFAS in addition to PFOA and PFOS, and to evaluate potential approaches to regulate PFAS as a class.
  4. Encouraging EPA to promulgate final drinking water regulations as soon as possible, but no later than 18 months from the time the final determination to regulate is made.

The comments also provide supporting data and information from states and scientific health effects studies, and occurrence of PFAS detections beyond the UCMR3 monitoring results. For more information, read the letter here.