A Federal Plan for PFAS: What Does That Mean in Missouri?
In October 2021, U.S. Environmental Protection Agency (EPA) Administrator Michael S. Regan announced a PFAS Strategic Roadmap for EPA to begin addressing PFAS pollution with specific actions through 2024. We’ll give you the run-down on PFAS chemicals, highlights of the Roadmap, and what we can expect to see in Missouri.
What are PFAS?
The acronym PFAS refers to per- and poly-fluoroalkyl substances: a group of manufactured chemicals that are gaining increased attention because of their prevalence and persistence in the environment. PFAS molecules are made up of a chain of carbon and fluorine atoms, which form extremely strong chemical bonds and therefore do not break down naturally. This is why PFAS are often called “forever chemicals”. You’ll also see the acronyms PFOA and PFOS, which refer to two of the most well-studied PFAS chemicals. Scientists are discovering new PFAS chemicals all the time and the National Institute of Environmental Health reports that there are at least 4,700. However, existing EPA methods for analyzing drinking water can only detect 29, which means that a number of PFAS chemicals could be present even in a water sample that comes back “clean” for these 29.
Use of PFAS chemicals is widespread. They have been found in commercial, consumer and industrial products, including non-stick coatings on cookware, pizza boxes and fast food containers; cleaning products; personal care products; electronics manufacturing; and fire extinguishing foam. PFAS pollution can come from the use and disposal of everyday items as well as industrial releases. Research shows that exposure to PFAS can have a number of negative health effects, including reproductive issues, hormonal disruption, increased cancer risk, and developmental delays in children – and we’ve only had the chance to study a handful of these chemicals. Since PFAS are so resistant to break down, they can accumulate in the human body and our environment. Surveys conducted by the Centers for Disease Control and Prevention (CDC) show that most people in the United States have been exposed to some PFAS and it is critical that we better understand the environmental health risk that they pose.
PFAS Strategic Roadmap
The PFAS Strategic Roadmap released by EPA outlines a plan of action to better study and address the emerging issue of PFAS contamination. The Roadmap focuses on three activities: researching, restricting, and remediating PFAS chemicals in our environment, with attention to their impacts on human health and in environmental justice communities. Key commitments in the Roadmap include:
- Advancing public health protections – EPA sets out to further research the health impacts of PFAS chemicals, set additional health advisories and educate the public about PFAS health risks.
- Undertaking nationwide monitoring of PFAS in drinking water – Notably, this round of monitoring from 2023 through 2025 would only detect 29 PFAS chemicals, however EPA has also made commitments to update its analytical methods.
- Setting enforceable limits for PFAS chemicals in drinking water – Establishing a national primary drinking water standard for PFOA and PFOS is a critical step to ensure public drinking water systems across the country have the same level of health protection in place.
- Building the technical foundation to address PFAS air emissions – EPA has committed to study sources of PFAS and air emissions and develop monitoring strategies, however until PFAS are listed as a hazardous air pollutant they can not be regulated under the Clean Air Act.
- Prioritizing environmental justice communities – EPA recognizes that many known and potential PFAS contamination sites are near low-income communities and communities of color, commits to study the cumulative impacts of PFAS in environmental justice communities and to engage these communities in decision-making.
- Holding polluters accountable – EPA is exploring ways to hold polluters accountable through toxics reporting, permitting, and designating PFAS as a hazardous substance. However, it is unclear in the Roadmap how EPA will ultimately ensure PFAS manufacturers and polluters are involved in remediation efforts.
While it is heartening to see EPA outline proactive efforts to research, restrict and remediate the impacts of this emerging environmental health concern, the actions and goals in this plan will not be enforceable until policies are put in place.
What Does This Mean for Missouri?
The Missouri Department of Natural Resources (DNR) is the agency responsible for protecting air, land, water and mineral resources in Missouri. Up to this point, the limited action on PFAS we’ve seen at the state level is from the Public Drinking Water Branch of DNR’s Water Protection Program. Between 2013 and 2015, Missouri conducted a study of public water systems (PSWs) under EPA’s Third Unregulated Contaminants Monitoring Rule (UCMR 3). UCMR 3 and subsequent work with the University of Missouri Science & Technology did not detect any samples above the health advisory (HA) levels at the time, however these studies were limited in both size and scope (learn more about these studies by listening to a roundtable discussion on PFAS hosted by the MOST Policy Initiative). While there have not been PFAS detected above HA levels in PSWs thus far, In January 2023, they have been detected at a number of Brownfields and defense restoration sites, including Fort Leonard Wood Army Training Center and Lambert-St. Louis Air National Guard Base. DNR will begin a more robust analysis of PSWs for PFAS chemicals under UCMR 5. Missouri plans to use additional grant funding to sample smaller PSWs which were not included under UCMR 3, but this round of sampling will still only be able to detect 29 of the thousands of PFAS chemicals and it will not collect data for Missouri’s 1.4 million private well water users.
Missouri’s HA level for PFAS in drinking water is currently set at 70 parts per trillion based on EPA’s most recent guidance. HA levels are not actionable; until a national primary drinking water standard on PFAS is established, states do not have to set limits on PFAS in drinking water. This has not prevented a number of states from being proactive in setting limits on PFAS in drinking water above and beyond EPA guidance and otherwise mitigating exposure to these chemicals in protection of human and environmental health, but Missouri is not among them. DNR has formed a workgroup on PFAS within the Division of Environmental Quality that includes the air, water, and waste management programs. However, at this stage DNR is largely awaiting further guidance from EPA to take action on what is outlined in the Roadmap. MCE will be following activities on PFAS at the state level to keep Missourians informed and to advocate for appropriate environmental health protections.