WHO’s PFAS Guidance May Increase Global Health Inequities

WHO’s Flawed Draft Guidance

This fall, the World Health Organization (WHO) released, for the first time, draft guidance for developing drinking water protections from two global pollutants that are toxic at very low levels yet are found in rain, snow, and water all over the world: PFOA and PFOS. Although these protections are urgently needed, the draft guidance was neither health protective nor based on the best available scientific evidence as expressed by over 115 public health advocates, scientists, and organizations. If countries or territories adopt these guidance values as drinking water standards, global health inequities are likely to be magnified and people exposed to these chemicals will be at an increased risk of disease.

Per- and polyfluoroalkyl substances (PFAS) are global environmental contaminants. Added to consumer and industrial products to confer grease-proof, water proof, and stain resistant properties, these man-made chemicals can now be found in ground, surface, and drinking waters across the world. Authoritative government bodies have indicated that exposure to PFAS is associated with several human health concerns, including immune system dysfunction and cancer. As a result, there are efforts underway to reduce exposure to PFAS, particularly by limiting the amount of PFAS in drinking water.

Since 1958, the WHO has provided guidelines for drinking water quality (guidelines) including for chemicals of concern. The guidelines are meant to be based on “the best available evidence and scientific consensus” in order to protect global public health. As guidelines, these values are not legally enforceable limits. Rather, they are intended to be a starting point for individual countries and territories to develop their own standards and risk management approaches as appropriate given the unique resources and concerns present in a location. However, in many instances the guidelines are directly translated to regulations or standards by countries and territories, especially those with fewer resources for conducting chemical risk assessments.

At the end of September 2022, the WHO released for public comment draft guidelines for the two most well studied PFAS, perfluorooctanoic acid (PFOA) and perfluooctanesulfonic acid (PFOS). Unfortunately, the document was neither health protective nor based on the best available evidence and scientific consensus. The conclusions reached in the document were so egregious that I joined 115 scientists in a letter to the WHO requesting that the draft guidelines be either withdrawn or completely rewritten. The WHO draft guidelines disregard the robust evidence that exposure to PFOA and PFOS causes health harms in human populations as well as in laboratory animals. Ultimately the draft recommends provisional guidance values for PFOA and PFOS that are significantly less protective than values derived by numerous state agencies in the last five years and by the US EPA.

The Potential Repercussions of WHO’s Draft Guidance

That the WHO’s draft guidelines are so far out of line with current recommendations from the US and the EU, lead some to question the transparency of the WHO process. The authors, contributors, and peer reviewers of the document were not listed in the publicly posted draft, making the development of the draft opaque rather than transparent. Without this information, it is difficult to investigate if any of the authors or contributors had a conflict of interest that may have influenced the development of the draft guidelines.

The finalization and subsequent widespread adoption of the draft guidelines for PFOA and PFOS in its present form may magnify existing global health inequities. Countries and territories that adopt a drinking water limit of 100 ppt for PFOA and PFOS may soon find themselves to be the dumping ground of the world’s PFAS wastes given the ever stricter limits that are being set for PFAS in the US and Europe. This is especially concerning given that the people in these countries and territories may not be the primary users of consumer products containing PFAS, nor directly benefit financially from the production or industrial uses of PFAS.

And shipping PFAS waste internationally and overseas as a way to avoid regulation isn’t new. For years Chemours shipped its waste from GenX production, a replacement for PFOA, from its plant in the Netherlands to its plant in North Carolina for final disposal in deep wells in Texas. The people in countries and territories that depend on the WHO for guidance on safe drinking water deserve more than the weak unsupported conclusions presented in the PFOA and PFOS draft guidelines.

Towards a PFAS-Free Future

To be better protected from the harms of PFAS, communities across the world need health protective standards that lead to the clean up of PFAS contaminated drinking water. To deliver these protections, the WHO needs a drinking water guidance process that is transparent, accountable and relies on scientifically valid processes–such as systematic review frameworks are already used by other divisions of the WHO.

And, improving WHO’s draft guidance on PFAS is just the tip of the iceberg. Communities would greatly benefit from policies that would:

• Eliminate the release of PFAS into the environment and provide resources to clean-up of existing contamination.
• Phase-out of all non-essential uses of PFAS.
• Expand testing to better understand the extent of PFAS contamination.
• Research safe, effective methods for the destruction of PFAS wastes.