TO: Stiven Foster, Office of Land and Emergency ManagementEnvironmental Protection Agency
RE: Public Comment on USEPA Draft Interim Recommendations to Address Groundwater Contaminated with Perfluorooctanoic Acid and Perfluorooctane Sulfonate
Docket ID No. EPA-HQ-OLEM-2019-0229Comment period ending June 10, 2019
Dear Mr. Foster:
As communities impacted by PFAS contamination, we object to the EPA’s proposed site screening levels, preliminary remedial goals for groundwater as a source of current or potential drinking water, and recommendations extrapolated from the discredited lifetime health advisory level of 70 ppt – all which assume no prior exposure.
The Agency’s proposal is not protective of human health particularly infants, children and expectant mothers as it fails to incorporate critical risk factors including placental and breast milk transfer to baby nor the potential for transgenerational body burden as evidenced by the ever-growing, undeniable body of scientific research and health studies.
EPA’s institutional failure to protect public health is reflected in the much lower PFAS standards and advisories set by a growing number of states that recognize the much larger intake rates for infants and the observed biological activity of these chemicals even at very low exposure levels. Moreover, these failures have the unavoidable effect of targeting less resilient communities and those most vulnerable to harm.