*Map courtesy of the Natural Resources Defense Council*

Analies Dyjak  |  Policy Nerd

Our inbox has been inundated with questions regarding the NRDC drinking water report that CNN retreated yesterday. We wanted to add some context and remind readers that these developments are not new. The scope of the drinking water problem in this country is much broader than the 90 federally regulated contaminants highlighted in the report. 

With myriad water quality crises popping up all over the country this past year, the topic of drinking water quality has once again commanded national media attention. CNN recently published an article underlining a 2017 report by the Natural Resources Defense Council.

Major Takeaways from the CNN Water Report:

1. It’s not easy to violate a drinking water standard. In fact, drinking water regulations are set so high in the United States that it’s surprisingly difficult for a municipality to surpass a federal threshold. The consensus in the scientific and toxicological community is that federal standards should be reduced across the board.

2. Why is the conversation being limited to regulated contaminants? For a bit of perspective, EPA regulates 90 drinking water contaminants that municipalities must comply with. These regulated contaminants include lead, arsenic, disinfection byproducts, and others. There are thousands, if not hundreds of thousands of potentially dangerous unregulated contaminants. Despite this growing problem, the CNN report focused entirely on the 90 federally regulated contaminants, which doesn't even scratch the surface of America's drinking water crisis. 

3. The article is vague about what constitutes a "violation." Municipalities can receive a violation from the state, or primacy agency for different reasons. Municipalities can be in violation if they are "out of compliance" or "in exceedance" of a drinking water standard. However, municipalities that fail to report data or test for a contaminant may also receive a violation. There's very little enforcement or repercussions imposed on municipalities that have violations, and often community members are left in the dark. 

How Can We Determine The Actual Scope of Drinking Water Contamination In The United States?

Figuring out the scope of this problem is extremely difficult, due to the slow-moving regulatory process and missing data. EPA estimates it would cost $743 billion to mitigate only the regulated contaminants in the U.S., meaning it would do nothing to address unregulated contaminants like Chromium 6, PFAS, and 1,4-Dioxane. Communities like Madison, Wisconsin could theoretically receive a gold star when looking at their compliance for regulated contaminants. Madison has low levels or lead, disinfection byproducts, and arsenic - all well within EPA standards. People are often surprised to find out that Madison has screamingly high levels of Chromium 6, which is also known as the "Erin Brockovich" chemical (the movie came out almost 20 years ago, and the contaminant is still unregulated). According to the most recent report, the average concentration of Chromium 6 in Madison is 1400 parts per trillion. This is 70 times higher than the concentration determined to have a negligible impact on cancer risk. 

America’s drinking water is more widespread than you think, and the scope of the problem goes well beyond the 90 contaminants addressed in the article. We must look beyond annual Consumer Confidence Reports to unveil the truth about our drinking water contamination.

Analies Dyjak  |  Policy Nerd 

Our blog has been following PFAS contaminants such as the GenX chemical for months now, often reporting on new developments before mainstream news.
Today marks an important milestone: EPA has released a draft toxicity profile for GenX. This long-awaited toxicity report contains critical information for many states who have been seeking answers on this harmful contaminant.

EPA’s Draft Toxicity Assessments for GenX and PFBS:

EPA determined a candidate Chronic Reference Dose of 0.00008 mg/kg-day. A reference dose is the daily oral intake not anticipated to cause negative health effects over a lifetime. A reference dose is not a carcinogenic risk factor, however, EPA states that the toxicity data for GenX are “suggestive of cancer.” According to the draft report, oral exposure in animals had negative health effects on the kidney, blood, immune system, developing fetus, and liver. The draft toxicity report also provided information on PFBS, which is a replacement chemical for PFOS. The candidate Chronic Reference Dose for PFBS is 0.01 mg/kg-day, and there was insufficient data to determine its carcinogenic potential.

What Is GenX?

GenX is part of a category of contaminants called PFAS, or per and polyfluoroalkyl substances. The GenX chemical linked to cancer has gained national attention since being discovered in the Cape Fear River in June of 2017.
PFAS have historically been used in consumer products like Scotchgard, Gore-Tex, Teflon, and even the inside of popcorn bags. PFAS are also used in firefighting foam, which is the major source of its pollution in waterways across the country.

Background:

The Chemours plant in Fayetteville, North Carolina produces refrigerants, ion exchange membranes, and other fluoroproducts. They have been discharging liquid effluent into the Cape Fear River for years, which has contaminated drinking water for the entire area. GenX is the replacement chemical for PFOA. After PFOA was discovered to be toxic, manufacturers addressed the issue by making an equally-as toxic replacement. Manufacturers of PFAS have been doing this for years, which is why there are so many different variations present in the environment.

Is GenX Federally Regulated By EPA?

No. This means that municipalities are not required to test for PFBS or GenX in water. Additionally, this draft toxicity level is not a lifetime health advisory level, which states would be more inclined to follow.

When Will A Drinking Water Standard Be Determined?

Don’t hold your breath on anytime soon! The regulatory process can take decades, especially for such a persistent contaminant in the environment. This is more than enough time for adverse health effects to set in, and we recommend consumers do everything they can to learn about their water and protect themselves, rather than wait for the government to step in.

What Does This Mean For Me?

EPA is in the very early stages of determining a regulation or even health advisory for GenX. This draft toxicity level needs to go through public comment so that states, tribes, and municipalities can offer input and recommendations. If you want to see third-party data on filters that remove GenX in water and other PFAS, click HERE. 

Analies Dyjak | Policy Nerd

October 4, 2018- Elon Musk and The Musk Foundation confirmed a donation of $480,350 to Flint, Michigan Community Schools in hopes of addressing lead contamination in drinking water. Flint is one of many school districts across the country that has been working hard to generate long-term solutions for lead contamination in drinking water. This article examines whether the proposed filtration technology will effectively remove lead from drinking water. 

How Will The Funding Be Used?

Musk initially announced the filters would comply with FDA’s 5 parts per billion standard (which is actually the standard for lead in bottled water), instead of EPA’s 15 part per billion Action Level. While definitely lower than EPA's threshold, the American Academy of Pediatrics and Center for Disease Control have both acknowledged that there is no safe level of lead for children. The Musk Foundation has not released the exact type of water filters Flint, Michigan Community Schools plans to use. Press releases have indicated some type of ultraviolet filtration system. 

What Is UV Water Filtration?

Ultraviolet filtration eliminates biological contamination from drinking water. This includes bacteria, viruses, and harmful microorganisms like E.coli. The idea behind UV filtration is it prevents microorganisms from reproducing, by striking each individual cell. It’s comparable to and often more effective than using chlorine to kill bacterial contamination.

Does UV Filtration Filter Lead?

No. While UV filters are great at removing biological contamination from drinking water, they have several limitations. UV filters by themselves are not able to remove chemical contaminants including Volatile Organic Compounds, chlorine, lead, mercury and other heavy metals. To remove chemical contaminants (including lead), a UV-based system would need to be paired with lead removal media or reverse osmosis.

Our Take

Contrary to a lot of media reports, UV filters do not remove lead from water, so we're hoping that the UV is paired with a system that removes lead. We also hope that the filters are installed at the point of use, because water treated by a point of entry filter can accumulate lead in any pipe "downstream" of the filtration unit. 

Analies Dyjak, M.A. | Head of Policy and Perspectives

**Updated 9/21/2021 to include recent studies

What Is 1,4-Dioxane?

1,4-dioxane is a synthetic industrial chemical, typically used as a stabilizer for chlorinated solvents. It was historically used in the production of 1,1,1-trichloroethane (TCA), which was phased out in 1985 after scientists determined it to be an ozone-depleting substance. Today, 1,4-dioxane is not typically added directly to consumer products but can be an unintentional byproduct in certain plastics. It’s introduced as a trace contaminant in certain ingredients, most commonly detergents, foaming agents, emulsifiers and solvents, including Polyethylene Glycol or PEG.  

Is 1,4-Dioxane Regulated?

1,4-dioxane in drinking water is not federally regulated under the Safe Drinking Water Act, even though EPA has classified it as “likely to be carcinogenic to humans by all exposure routes.” There are health advisories in place but a Maximum Contaminant Level (MCL) does not exist. This means that unless a state has its own enforceable standard, utility providers are not required to remove it from drinking water. 1,4-dioxane is regulated by the Occupational Safety and Health Administration (OSHA) for indoor workplace air quality. 1,4-dioxane is on the fourth drinking water Contaminant Candidate List and is also part of the Third Unregulated Contaminant Monitoring Rule. In 2019, New York State became the first state to regulate 1,4-Dioxane by establishing Maximum Contaminant Limits (MCL) of 10 ppb in cosmetics, and 2 ppb in personal care and household cleaning products by 12/31/2022, which will be further reduced to 1 ppb by 12/31/2023.  

How Does 1,4-Dioxane Enter Drinking Water?

1,4-dioxane has contaminated drinking water through both groundwater and surface water. Many instances of groundwater contamination are a result of 1,4-dioxane being used in various manufacturing processes. According to the Agency for Toxic Substances and Disease Registry, 1,4-dioxane can easily travel into groundwater because it is extremely soluble in water and does not stick to soil particles. 

1,4-dioxane contamination on Long Island, New York was a result of routine spills or direct disposal of solvents to the ground from manufacturing operations between the 1950s to the 1990s. 

1,4-dioxane was used in the manufacture of medical filters in Ann Arbor, Michigan. The methods of waste disposal used between 1966 to 1986 resulted in 1,4-dioxane being released into the environment, causing widespread groundwater contamination. 1,4-dioxane in drinking water continues to be a concern for local residents, even decades after the pollution was first discovered and remediation was to have been taking place. 

1,4-Dioxane has also been released into surface water, both into rivers or public sewage systems. Sources of contamination include effluent from industrial facilities as well as wastewater treatment plants.   

1,4-Dioxane Health Effects In Drinking Water

1,4-dioxane can harm the eyes, skin, lungs, liver, and kidneys. As previously stated, 1,4-Dioxane is classified by the US EPA as a likely human carcinogen. Like other contaminants, the dose and duration of exposure affect the likelihood and severity of adverse 1,4-dioxane health effects.

Why is 1,4-Dioxane So Hard To Remove From Drinking Water?

1,4-Dioxane is completely soluble in water. It dissolves completely, even at high concentrations. It also does not readily evaporate. Traditional treatment methods are ineffective at removing 1,4-Dioxane from drinking water, so a few larger municipalities have begun to incorporate specialized methods for 1,4-Dioxane removal in their processes. These can be prohibitively expensive for smaller municipal water suppliers, so there is not likely to be a widespread solution for 1,4-Dioxane removal implemented any time soon.  

What Can I Do if I Have 1,4-Dioxane in My Water?

There are no federal testing standards for 1,4-Dioxane, so we are unable to provide removal data. Hydroviv’s filters have however been tested and certified by NSF to remove VOC’s with similar chemical properties to 1,4-Dioxane. Most submicron pore size carbon block filters are able to address 1,4-dioxane, with the exception of granular activated carbon. A slower flow rate will also assist the carbon block filter by ensuring enough contact time with the 1,4-Dioxane and the filtration media. For example, Hydroviv drinking water filters incorporate carbon into our submicron block and at our 1 gallon/minute flow rate.