May 4, 2023
I’m Dr. Diana Zuckerman, president of the National Center for Health Research. Our nonprofit think tank focuses on the safety of medical and consumer products. We provide research-based information to Congress, federal agencies, and the public and we do not accept funding from companies that make the products we evaluate.
My comment today relies on my research experience at Yale and Harvard and in my current position, as well as my policy expertise from working in the House, Senate, federal agencies, and the White House.
We agree that this proposed rule will improve public health, reducing cancer, heart disease, stroke, low birth weight, and other harms to adults and children. It will save lives. But we have recommendations to improve it.
- We disagree that 4 ppt is the lowest level that can be reliably tested and removed. Eurofins routinely and reliably measures 2 ppt in water. And it is likely that 2 ppt will be widely usable to measure and remove PFOA and PFOS well before this rule is finalized. Since EPA acknowledges that no level of PFOA and PFOS is safe, the limit should be 2 ppt.
- We understand the agency’s desire to be flexible, but flexibility to satisfy monitoring requirements will likely generate a huge loophole. EPA needs more explicit limits to prevent a weakening of these regulations
- This proposed rule is an important first step, but it is long past time for the EPA to define PFAS broadly, regulate them as a class, and ban all non-essential uses.
- Lastly, we appreciate the law that provides funding for these efforts, but it’s time to start shifting the costs to the companies that have made these chemicals. When companies are held financially responsible, they will be less likely to inundate us with PFAS in products. Taxpayers are already stuck with the health risks. It is not fair for municipalities and taxpayers to get stuck with the work and the cost.