The following post is the result of a classroom writing assignment by Dr. Erika Martin at the University at Albany-SUNY who required students to write a commentary on a health-related topic of interest, explaining some of the complexities of solving the problem and offering recommendations. Three commentaries have been selected for publication on JPHMP Direct this year. Here, student Danielle St. Hilaire examines the regulation of PFOA contamination levels for the public water supply. 

The Problem with PFOA Contamination

Over the past few decades, contamination in the public water supply has become an increasingly apparent issue, with Perfluorooctanoic acid (PFOA) emerging as a critical contaminant. In Paulsboro, New Jersey, by the time the contamination was found, the residents had a PFOA level in their blood 285% higher than the average American citizen. This level of contamination could lead to severe ramifications for residents’ healths. Through a class action lawsuit in 2009, residents of Paulsboro were awarded a free blood test for their exposure levels. These blood tests showed that levels were higher in males compared to females, and older compared to younger residents. The residents of Paulsboro were drinking this water for decades before the contamination was discovered, inflicting upon them years of potential health issues. PFOA contamination

The EPA’s current approach to dealing with PFOA contamination is a reactive approach, suggesting using water filter systems that utilize a regenerable magnetic activated carbon as a potential fix. However, a better approach would be using preventative measures, including more stringent standards, procedural testing guidelines, and resources to implement testing and remediation. The current standard set by the Environmental Protection Agency (EPA) is 70 parts per trillion (ppt), though this level is not legally enforceable. If regular testing were put in place, the residents of Paulsboro could have been spared from their ongoing consumption of PFOA. It is important to recognize that a reactive approach will not suffice, and the EPA needs to implement some preventative measures to protect the people of the United States.

PFOA Is Dangerous

In order to discuss potential preventative measures, it is important to first understand why PFOA is such a dangerous chemical to consume. Although little research has been done to quantify the lasting effects PFOA has on the human body, there is a correlation of high PFOA levels and the prevalence of kidney and testicular cancers. PFOA has also been shown to have a high degree of correlation with thyroid disease, ulcerative colitis, and suppressed immune responses. One of the most vulnerable populations is newborn children as PFOA is directly transferred to the child from the mother via breastmilk. In one study, newborns had a serum level 4.4 fold higher than formula feed infants. Newborns have also been shown to have decreased birth weights and a decreased response to vaccines in areas with contamination. PFOA consumption can lead to myriad potential health detriments.

PFOA is much different from other contaminants familiar to the EPA. PFOA is an anthropogenic contaminant, meaning that is made by humans. Another component of this eight carbon compound is that it is not metabolized in the human body, and is persistent in the environment. Adsorbent technology is the only way to clean up this type of persistent chemical. Unlike most other contaminants, the human-dose response curve for several physiological effects appears to be the most prominent at the lower exposure levels. This means that at even extremely low levels, a PFOA presence in the blood could be detrimental, as PFOA is a known carcinogen. Combining PFOA’s carcinogenic component with its unusual human-dose response curve, it is clear that this chemical is new territory for the EPA.  PFOA contamination

The Current Approach

The current approach to dealing with PFOA is insufficient in protecting the health of Americans. The EPA assures the public of quick and efficient cleansing of any contaminated public water supply, but it is lacking when it comes to finding the contamination itself. The EPA currently has no procedural guidelines for the regular testing of the water supply for PFOA. This lack of testing allows contamination events to be prolonged with contaminated water supplies going unfiltered for years. The EPA currently has a standard of no more than 70 ppt of PFOA. This level is just a baseline as it’s not legally enforceable. Even if these standards were enforceable, the current standard at 70 ppt is insufficient. Due to this lack of federal legal standards, it is up to states to impose legal criteria for contamination levels, allowing these levels to vary quite significantly across the country, with states having allotted levels as low as 7 ppt. Also, the EPA has entered agreements called the Stewardship Program with different companies in an attempt to decrease the production of PFOA. These contracts are non-binding, allowing for a lot of leniency in this agreement. The Stewardship Program is insufficient as it has yet to produce quantifiable results in reducing the production of PFOA. The EPA needs to be much more aggressive with their approach to preventing PFOA contamination.

This table illustrates the extreme variation of advised “safe” levels of PFOA consumption. The orange color illustrates the agencies that allow for more PFOA than suggested by the EPA, while the blue indicates less than or equal to the EPA’s standard.

Calling for Action

There are many options the EPA should use to help prevent widespread PFOA contaminations. The first step the EPA needs to take is to implement a legally enforceable standard. If the EPA enforced its standard of 70 ppt, regular testing measures could be put in place, potentially saving the lives of consumers. Putting these procedural guidelines in place could help prevent another incident like the one in Paulsboro, NJ. Once these testing procedures were put in place, the EPA should reevaluate its standard of 70 ppt. Due to PFOA’s toxicity, especially at lower levels, the EPA should set a lower standard in order to ensure the health of all American citizens. Seven states have already (or are in the process of) enforced legal standards that are lower than current EPA standard of 70 ppt. The current standard at 70 ppt is evidently not sufficient in protecting American residents. Also, an alternative to the Stewardship Program would be using financial incentives to entice companies to reduce their PFOA production. Providing financial incentives to companies has always been a tactic the EPA uses against big corporations that distribute contaminants. This has proven to be an effective preventative measure as it is mutually beneficial for the companies and the public, avoiding litigation and contamination, respectively. These three preventative measures should be put in place to protect the health of all American citizens.

The contamination of PFOA in the public water supply is an urgent public health crisis that needs to be solved. Since PFOA is a relatively new chemical, there lacks research on its long term effects, and it could even be worse than we are anticipating. Hundreds of thousands of people have already discovered that their public water supply was contaminated with PFOA, from Paulsboro, New Jersey, to counties in Minnesota, to the small town of Hoosick Falls, NY. This type of contamination can exist for years before it is discovered. Immediate action needs to be taken as PFOA exposure can detriment the health of consumers. Environmental health issues are extremely important to recognize quickly, as there have been many times in the past when the lack of immediate intervention led to devastating health impacts. A prime example of this was the lead exposure event in Flint, Michigan, in 2014, which resulted in 12 deaths and nearly 100 cases of Legionnaires’ disease. By taking quick action, we have potential to mitigate some of these consequences in regards to public health. Action must be taken now to protect the citizens of the United States against exposure to PFOA.

Related Reading in the Journal of Public Health Management and Practice: 

• The Flint Water Crisis: A Coordinated Public Health Emergency Response and Recovery Initiative
• Root-Cause Analysis for Enhancing Public Health Emergency Preparedness: A Brief Report of a Salmonella Outbreak in the Alamosa, Colorado, Water Supply
• Implementation of a Legionella Ordinance for Multifamily Housing, Garland, Texas
• Facilitated Look-Back Analysis of Public Health Emergencies to Enhance Preparedness: A Brief Report of a Chemical Spill in Charleston, West Virginia

Related Posts:

• Designing University Writing Assignments to Foster Interest in Public Health Issues and Build Professional Skills
• Preventing Intimate Partner Violence: Integrating Routine Screening into Primary Care
• Through Haiti: How a Natural Disaster Disproportionately Affects Populations with Lower Socioeconomic Status
• i-Generation and the Use of Social Media to Help Dispel Misconceptions about Vaccines
• Increasing the Number of Advance Directives in the United States
• Are You Being Exposed to Lead Poisons in Your Own Home?
• Grad Student Helps Develop Website to Help Hurricane Victims Determine Toxic Waste Impact in Their Neighborhoods
• The Source of Legionnaires’ Disease Outbreak in New York City Not Yet Determined