NH Passes Common Sense Limits for Cancer-Causing PFAS Chemicals in Drinking Water
After the historical vote, I walked out into the hall at the Legislative Office Building and noted that the Business and Industry Association (BIA) and NH Municipal Association were being interviewed by the press. The BIA and NHMA were having a tantrum, trying to scare rate-payers, and continuing to claim that the passage of the strictest drinking water standards for PFAS in the nation was “emotional” and “not science-based.” I thought they would have given up on that tact by now. Who’s being emotional?
The clear intent of the legislation that compelled the NHDES to take another look at what is safe for us to drink for 4 PFAs chemicals specified that drinking water standards had to be protective of the most vulnerable — prenatal and early childhood exposures. I always knew this was the most important part of my legislation and as it turned out, it was. The following section from Senate Bill -309 that was signed into Chapter Law #0368:
“The commissioner shall consider the standards of other states, including the science considered by states with standards lower than those contained in the lifetime health advisory promulgated by the United States Environmental Protection Agency. The commissioner shall adopt standards that reasonably protect public health, particularly prenatal and early childhood health, and that are reasonably supported by peer-reviewed science and independent or government agency studies.”
The clear intent of the law was to be particularly protected of “prenatal and early childhood.”
There have been over 400 peer-reviewed studies published on health effects from prenatal and early childhood life exposure to PFAs since the last systematic review in 2017.1 A substantial increase in peer-reviewed recently about health outcomes about prenatal and early childhood exposure. We know enough about the health effects from exposure to these toxins and it is not appropriate to call these “emerging contaminants” any longer. As detailed in “The Devil We Know,” the manufacturers have known for decades.
Recent studies indicate that prenatal and early childhood accumulation of PFAS from maternal transfer. The study showed that PFOA and PFOS concentrate in the lungs and liver in fetal tissue2 and reproductive impacts.
The basis for the revised MCLs, is a peer-reviewed study concluded that peak breastfed infant serum levels were 4.4 times higher for in formula-fed infants. Further, they concluded that even short exposures during infancy “have dramatic impacts on serum levels for many years” in critically sensitive developmental periods (critical growth window). 4 The intent of the law is to protect this population.
Additionally, a study conducted in humans showed association between PFAs exposure and impaired male reproductive health including, reduced sperm counts, micro penis development. This study concluded that PFCs have a substantial impact on human health as they interfere with hormonal pathways, potentially leading to male infertility.5 Similar male reproductive health impacts are identified from exposure to other endocrine disruptors.6
Others have identified dose-related response between PFAs exposure and impaired serum vaccine antibody concentrations.7
The final NH MCLs are similar to proposals by other states like New Jersey, New York, and Michigan.
According to the CDC, the state of NH has the highest rates of children with pediatric cancer and we have a pediatric cancer cluster on the seacoast. We also have the highest in the nation rates of breast, bladder and esophageal cancers. Our rates of thyroid and kidney cancer are also higher than the national averages.
We have significant releases of PFAs which have contaminated our drinking water across the state exposing 10s of thousands of people to PFAS-impacted drinking water. We know that many chronic diseases and cancers can be prevented by limiting exposures to toxins.
With such high rates of cancer, the high cost of treating cancer (including direct and indirect costs) needs to be weighed against the constant claims from those who oppose stricter standards due to increased costs to treat water to remove PFAS. According to a 2008 estimate, New Hampshire spent $1.1B to treat cancer. The costs have likely doubled since 2008 due to increased incidence and healthcare costs. This is a downshifting of costs to the health insurance market and the population where many NH residents are $400 from bankruptcy if a family member is seriously ill.
Technically, we can achieve non-detect levels, as evidenced by the Pease Water Treatment system and we have a responsibility to prevent cancer and chronic disease to the extent that it is technically achievable.
About 3,000 people have been shown to have been exposed to elevated PFAS in the drinking water at Pease but tens of thousands of residents have been exposed in the Merrimack area due to releases from Saint Gobain. One case of adult-onset rhabdomyosarcoma (extremely rare) has been reported with ties to Greenland and Coakley Landfill and two cases of adult-onset RMS are known in the Merrimack area. The only tie known between the two communities is PFAS exposure from the drinking water.
On July 18th, 2019, NH made history when the Joint Legislative Committee on Administrative Rules (JLCR) voted along party lines to pass the final proposed PFAS MCLs which comply with the intent of the law to protect the critical developmental window during prenatal and early childhood development. NH has the strictest MCLs for 4 of the PFAS compounds in our drinking water. Now, on to the remaining 4,696 that are not regulated and untested for safety but are on the market already.
1. Rappazzo KM, Coffman E, Hines EP. Exposure to perfluorinated alkyl substances and health outcomes in children: A systematic review of the epidemiologic literature. Int J Environ Res Public Health. 2017;14(7). Accessed Mar 5, 2019. doi: 10.3390/ijerph14070691.
2. Mamsen LS, Björvang RD, Mucs D, et al. Environment international. Environment international. 1978;124:482–492. http://www.sciencedirect.com/science/article/pii/S0160412018326102.
3. Li Y, Fletcher T, Mucs D, et al. Half-lives of PFOS, PFHxS and PFOA after end of exposure to contaminated drinking water. Occupational and Environmental Medicine. 2018;75(1):46–51. http://dx.doi.org/10.1136/oemed-2017-104651. doi: 10.1136/oemed-2017–104651.
4. Goeden HM, Greene CW, Jacobus JA. A transgenerational toxicokinetic model and its use in derivation of minnesota PFOA water guidance. Journal of exposure science & environmental epidemiology. 2019;29(2):183–195. https://www.ncbi.nlm.nih.gov/pubmed/30631142. doi: 10.1038/s41370–018–0110–5.
5. Di Nisio A, Sabovic I, Valente U, et al. Endocrine disruption of androgenic activity by perfluoroalkyl substances: Clinical and experimental evidence. J Clin Endocrinol Metab. 2019;104(4):1259–1271. Accessed Mar 12, 2019. doi: 10.1210/jc.2018–01855.
6. Gaspari L, Sampaio DR, Paris F, et al. High prevalence of micropenis in 2710 male newborns from an intensive-use pesticide area of northeastern brazil. Int J Androl. 2012;35(3):253–264. Accessed Mar 4, 2019. doi: 10.1111/j.1365–2605.2011.01241.x.
7. Grandjean P, Andersen EW, Budtz-Jørgensen E, et al. Serum vaccine antibody concentrations in children exposed to perfluorinated compounds. JAMA. 2012;307(4):391–397. http://dx.doi.org/10.1001/jama.2011.2034. doi: 10.1001/jama.2011.2034.