CDC Report on PFASs: A Good Start But Improvements Needed

NRDC's comments on how the CDC's toxicological report on PFAS can be even more protective of public health.

Credit: Bigandt_Photography/iStock

The federal Agency for Toxic Substances and Disease Registry (ATSDR), part of the Centers for Disease Control and Prevention (CDC), is moving forward to finalize a report which reveals that current standards and regulations are failing to protect people from a broad group of toxic chemicals contaminating our water, food and homes.

The draft report, released this June, proposes new lower health thresholds for PFOA and PFOS, the most studied chemicals in the class. These lower health thresholds would result in maximum contaminant levels (MCLs) in drinking water approximately 10 times lower than EPA’s current drinking water health advisory (7-11 parts per trillion (ppt) versus 70 ppt).

This week, NRDC submitted comments on the report that outline additional reasons why even stronger health-based standards are needed to protect public health.

These man-made chemicals, known as PFASs (per- and polyfluoroalkyl substances), are widely used in commerce for their non-stick and stain-resistant properties, in products ranging from carpet, furniture, cookware, food packaging, and clothing. Although the class is broad, they are related in their extreme persistence in our environment and are often referred to as “forever chemicals” because they don’t breakdown. They are now found in the blood of virtually all Americans. Unfortunately, they have been linked to many harmful health effects, including cancer, immune system disfunction, liver damage, hormone disruption, low birth weight, and reproductive harm.

Over the past few decades PFAS contamination has grown into a serious global health threat. How we decide to use and regulate these chemicals now will have far reaching consequences for decades to come.

ATSDR’s report is a good start, especially given that the report’s release had been delayed for several months due to reported political interference from certain officials concerned with the “public relations nightmare” it would produce - because it clearly indicates that current regulations and health advisories are insufficient, that many more people are being exposed to dangerous levels of these chemicals than previously thought and many more polluters need to clean-up their mess.

While we commend ATSDR’s extensive analysis, based on our review, even greater health protections are warranted. That is, in part, because ATSDR provides health thresholds for only four chemicals in this broad class, though, it is estimated that there are a staggering ~4,700 different PFASs on the global market. 

NRDC comments made the following additional points:

ATSDR did not consider the health effects that occur at the lowest levels—which would result in drinking water thresholds below 1 ppt.

Although ATSDR chose health effects that occur at lower levels than the EPA used in generating their health thresholds for PFOA and PFOS, multiple studies find harmful effects on the immune system or development at doses well below the proposed health threshold for PFOS and PFOA, respectively. As the report notes, there is strong evidence linking:

  • PFOS exposure to harmful effects on the immune system, such as asthma and reduced antibody response to vaccines in children, and
  • PFOA exposure to changes in mammary gland development, which may lead to difficulty in breastfeeding and/ or increased risk of breast cancer later in life.

ATSDR failed to set thresholds for other harmful chemicals in the report.

Although not regulatory, health thresholds set by ATSDR serve as an important screening tool to help the public health community determine areas and populations potentially at risk from exposure to a particular chemical. Not providing a health threshold or guidance on a chemical suggests that there is no risk associated with the chemical. However, almost every PFAS that ATSDR profiled (14 in total) has data linking its exposure to health hazards. We commend ATSDR for setting two additional health thresholds, for PFNA and PFHxS; however, ATSDR should generate health thresholds whenever possible for any chemical linked to health hazards.

ATSDR should recognize PFASs as a class of hazardous chemicals. 

The 2014 Helsingør and 2015 Madrid Statements, founded on extensive reviews of the scientific literature, provided consensus from more than 200 scientists on the potential for harm associated with the entire class of PFAS. In order to better protect Americans from this public health threat, ATSDR should utilize information on PFASs with greater amounts of data to generate health-protective thresholds for PFASs with data limitations.

ATSDR failed to address real-world, simultaneous exposures.

Exposures do not occur in isolation. Multiple PFASs are found in drinking water, food, dust, and consumer products. Studies looking at levels in people (known as biomonitoring studies) demonstrate that Americans have chronic exposure to multiple PFAS chemicals throughout their lifetimes. An ever-growing body of evidence is linking many different PFASs to human health hazards. Additionally, because PFASs are a chemically related to each other, they likely can amplify the harm and have additive or synergistic effects on target systems in our bodies.

States across the country—including Michigan, North Carolina, New Jersey, New York and Vermont—are scrambling to deal with widespread contamination of these chemicals in our drinking water. Some state experts are making findings similar to ATSDR, flagging the need for protections at levels lower than EPA’s drinking water health advisory—including New Jersey, New York, and Vermont. The Food and Drug Administration has banned several PFASs from use in food packaging. California’s Safer Consumer Products program has listed PFASs in carpets as a priority concern and has begun the process of requiring safer alternatives to be investigated and used. Washington state recently banned the use of all PFASs in aqueous firefighting foam (AFFF)—a major source of water contamination—and food packaging. 

But much more needs to be done to address this growing public health threat. Essential to any effort is the establishment of health thresholds that are properly protective of public health. We urge ATSDR to move quickly to consider and incorporate recommendations to improve the quality of this report, so that this critical public health tool can be finalized in a timely manner.

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