PFAS Playbook

On July 22, the state of California unveiled for public review its draft public health goals (PHGs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), two of the most widely studied types of PFAS. As noted in the goals, these two particular compounds have been used in consumer products and industrial settings for the last half-century. Because of their prevalence, California now proposes establishing a limit of PFOA at 7 parts per quadrillion in drinking water, and 1 part per trillion for PFOS. Even if finalized, California’s PHGs are not directly enforceable, but would be considered when setting enforceable drinking water standards. Still, the goals could result in strict standards that significantly limit the amount of PFOA and PFOS in drinking water. The PHGs (if adopted as written) would be the most stringent regulatory guidelines in the nation for PFOS and PFOA levels in drinking water. For comparison, the Environmental Protection Agency’s current guidelines limit the occurrence of both PFOA and PFOS to 70 parts per trillion. The PHGs may also push the boundaries of testing capabilities for PFOA and PFOS.

The California Environmental Protection Agency cites the pervasiveness of PFOA and PFOS and long elimination times as reasons to impose new regulatory limits. The proposed PHGs are set at a level of risk of one additional cancer case per one million persons exposed over a lifetime, and are based exclusively on public health considerations. The goals could certainly serve to influence future environmental regulations at both the state and federal level. California EPA’s Office of Environmental Health Hazard Assessment (OEHHA) is accepting public comments on the PHGs from July 30, 2021 to September 28, 2021. OEHHA is hosting a public workshop for the proposed PHGs on September 28, 2021.