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Policy, the Production of Ignorance, & the Challenges of Building

More Circular Systems

Laura Rabinow, PhD

Director of Research�Rockefeller Institute of Government

A Case Study of Federal Standards for PFAS

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2014

(Times Union)

PFOA first detected in Hoosick Falls’ water

by resident Michael Hickey

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2015

Existing Levels:

  • EPA’s Health Advisory: 400 ppt
  • NYS’s Standard for Unspecified Organic Contaminants: 50,000 ppt

New York State Department of Health:

Environmental Protection Agency:

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  • The co-production of ignorance contributed to the delayed/uneven testing for PFOA & other PFAS, and the absence of enforceable standards.
  • Ignorance. The absence and inaccessibility of knowledge or science.

Why did this come to light outside of regulatory testing?

Why was there no enforceable regulatory standard for PFOA at the time?

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Unseen Science

(Grandjean 2018)

“research that is conducted but never shared outside of institutional boundaries”

(Billott 2001)

(Richter et al. 2018)

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Incommensurate Science

  • Science that is produced at speeds, scales, or in forms that cannot possibly address the speed, scale, or form of its subject matter
  • Unregulated Contaminants Monitoring Rule’s (UCMR) Incommensurate Science

(Eurofins Eaton Analytics)

Speed

Slowness with respect to large universe of potential contaminants

Scale

Exclusion of water �systems serving under 10,000 & private wells

Form

Reporting levels higher�than detection levels

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Incommensurate Science

Third to Fifth Unregulated Contaminants Monitoring Rule (UCMR) changes:

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Policy & the Production of Ignorance

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Circular Systems: Biosolids

  • Biosolids. Treated sewage sludge that meets certain regulatory standards
  • Through the early 1970s ocean dumping used as a common disposal methods
    • In 1968, roughly 4.5 million tons of sewage sludge was dumped into the ocean in the U.S.

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Circular Systems: Biosolids

  • 1972 — Marine Protection, Research and Sanctuaries Act (MPRSA)
  • 1987 — Clean Water Act Amendments -> required new regulations
  • 1988 — Ocean Dumping Ban Act

Biosolids Use and Disposal from 2022 Biosolids Annual Reports

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Biosolids & PFAS

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Circular Systems: Biosolids

  • 1972 — Marine Protection, Research and Sanctuaries Act (MPRSA)
  • 1987 — Clean Water Act Amendments
    • required new regulations
  • 1988 — Ocean Dumping Ban Act
  • 1993 — First federal regulation for biosolids finalized
    • “Biosolids Rule”
    • EPA review based on available information

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Circular Systems, Ignorance, & Interlinkages

1940s

PFAS begin to be manufactured and used in the U.S.

1960s

Industry studies

2001

EPA notified of earlier industry studies

2013

13 PFAS included in Biosolids Bienniel Review

No human health toxicity data identified

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3rd UCMR includes 6 PFAS

2023 - 25

5th UCMR includes 29 PFAS

Includes smaller systems; lower reporting levels

2024

First national drinking water standards for PFAS

2025

Draft Risk Assessment for PFOA & PFOS in Biosolids

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Circular Systems, Ignorance, & Interlinkages

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