In 1962, I was inspired and moved by Rachel Carson’s book "Silent Spring."
Carson predicted the serious impact of pesticides, especially DDT, on birds and the ecosystem. She based her findings on facts.
She conducted significant research on the levels of these chemicals found in the environment and identified the specific adverse effects due to careless use.
Eight years after "Silent Spring" was published, Richard Nixon, a conservative Republican president, established the Environmental Protection Agency (EPA).
But Rachel Carson knew the difference between data that coincides with adverse health events versus data needed to prove a causal relationship.
For example, because drownings go up at the same time that ice cream sales go up does not mean ice cream causes drownings.
It means there is a correlation — in the summer, people buy more ice cream, they also swim more frequently; therefore, the number of drownings will increase.
That may be the serious flaw in the current proposed rule by the EPA concerning certain "forever" chemicals called Per- and Polyfluoroalkyl Substances or "PFAS," a group of over 10,000 different substances.
This rule has targeted two specific PFAS chemicals, PFOS and PFOA, which were historically used in a wide variety of applications including as lifesaving "aqueous film forming foam" (used by firefighters) but are no longer manufactured or used in the U.S.
This proposed rule would require water systems in the U.S. to reduce the levels of these targeted PFAS chemicals from 70 ppt (the level embraced by President Obama’s EPA) down to 4 ppt.
That’s right – parts per trillion. At 4 ppt, analytical chemists are barely able to detect any chemical at this infinitesimally low concentration.
As noted, the current proposed EPA rule (called a Maximum Contaminant Level, or MCL) is a reduction by 66 ppt.
Even more stark is the contrast between the proposed rule and the concentrations suggested by the World Health Organization (WHO) and the European Union, which has allowed targeted PFAS chemicals in drinking water at 100 ppt — or 25 times higher than the current EPA Proposal.
Moreover, the EPA’s proposed rule sets much lower limits for these PFAS chemicals than for arsenic and cyanide, both of which are fatal at certain levels to humans but allowed in drinking water at 10 parts per billion for arsenic (2,500 times higher than EPA’s proposed rule for targeted PFAS) and 200 parts per billion for cyanide (50,000 times higher).
Why is there such an extreme disparity in regulatory approaches when there is no agreement among toxicologists and epidemiologists about what concentrations in water might pose a genuine risk to humans?
Before they impose astronomical compliance costs on the American public, the Biden administration would be wise to convene an international task force to figure out why, across various western nations, the dose considered safe can vary by 1,000-fold.
According to the American Water Works Association, this regulatory proposal could cost households up to $3,570 extra in their annual water bills.
How?
Because these costs are passed on to water systems big and small, from urban areas to small towns in rural America, who will then pass it along to municipal and county water systems.
Finally, these costs will trickle down to American consumers, disproportionately impacting small-town and low-income communities; further exacerbating socioeconomic disparities in access to clean water.
The Pentagon has also recently expressed serious concerns at the impact of the proposed rule — in terms of the overwhelming costs to comply and how further restrictions on the use of PFAS could threaten our national security.
Proponents of the rule argue that stricter standards are necessary to protect public health, citing studies "linking" PFAS exposure to adverse health effects, including cancer, reproductive issues, and immune system disorders.
But to repeat: the words "linked" or "associated with" are often used to camouflage the difference between correlation and causation.
Notably, Bloomberg has estimated that the cost to address PFAS could approach $1T over 10-20 years, and this did not include the thousands of personal injury claims that an unnecessarily low MCL would generate.
Given this, the EPA should regulate reasonably and responsibly to protect human health in a sustainable manner that has sound science supporting its action.
The White House Office of Management and Budget (OMB), which oversees the EPA, should pause and require more data to definitively show that such an extreme reduction is truly necessary to protect public health before approving this regulation.
In the absence of such justification, they would simply be choosing an exceedingly low concentration out of over-reaching precaution. How could President Obama’s EPA, the WHO, the EU and Australia, among others, be so wrong?
Rachel Carson championed data-driven science which must be the basis of environmental regulation for the public good.
She knew to do otherwise — such as relying on weak data — would undermine the environmental movement that she believed in so strongly and that her seminal book launched.
Lanny J. Davis is the founder of the Washington, D.C., law firm, Lanny J. Davis & Associates and is co-chair of the global public affairs and strategic communications firm, Actum LLC. Davis uniquely operates at the intersection of law, media, and politics to solve client problems. In 1996-98, Mr. Davis served as Special White House Counsel to President Bill Clinton. In 2006-07, he was appointed by President George W. Bush, to serve on a special post-9/11 White House panel to advise the president on privacy and civil liberties issues. He is the author of six books. Read more of his reports — Here.
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