The Wisconsin Water Quality Coalition, a group of non-profit organizations, industry partners, and trade associations of which MWFPA is a member, has submitted a letter and supporting comments to the Department of Health Services in response to its extremely restrictive recommended standards for two PFAS compounds – PFOA and PFOS. Unfortunately, The Governor only afforded interested stakeholders a one-day comment period to respond to these recommendations.
PFAS are synthetic compounds that have been used in industry and consumer products around the world since the 1940s. However, PFOS and PFOA, are no longer manufactured in the United States.
While they are no longer manufactured here, PFOS and PFOA still exist in soil, groundwater and other substances such as recycled paper pulp, making it nearly impossible to remove from some manufacturing processes.
Studies have found much higher than normal exposure to some PFAS compounds can have health effects on lab animals. However, no cause and effect relationship has been established for health effects of PFAS compounds on humans, and the results are not consistent across all human studies.
Wisconsin’s DHS has recommended one of the most restrictive proposed standards in the nation at 20 parts per trillion combined. Further, DHS recommends a combined preventive action limit for PFOS and PFOA of just 2 parts per trillion, the lowest enforceable limit in the World, to date. If the standard is enforced, state government could take regulatory and legal action against any company or local government that has even the smallest trace amounts of these two chemicals in public water systems or industrial discharge.
2 parts per trillion is equal to two grains of sand out of 1500 tons of sand.
The technology to eliminate these compounds from groundwater is extremely expensive and underdeveloped. We are deeply concerned that such a standard could devastate Wisconsin’s economy and significantly raise the cost of residential water. It would require municipal utilities, industrial facilities, and energy producers, to reach near-zero discharge levels of compounds that are pre-existing in groundwater. Even our smallest community utilities may be required to install extremely expensive control equipment. Manufacturing and agricultural facilities will be forced to clean up compounds they may never have produced or used. It will likely force the relocation of resources and jobs from Wisconsin to other states with more reasonable, science-based standards, and will increase utility costs for all Wisconsin citizens.
The Wisconsin Water Quality Coalition is concerned with the lack of transparency in the crafting of this recommended number as well as the potential detrimental impact on industry and the taxpayers alike. We will continue to advocate for regulation based on science that properly balances our health impacts with protecting the future of Wisconsin’s economy.
For more information on PFAS please visit: wisconsinwaterqualitycoalition.org