Moving Forward

Conclusions

Throughout our research, we have asked ourselves about the ways that PFAS contamination of drinking water might affect different groups, areas, and individuals disproportionately. Looking at the history of PFAS contamination, we have determined that the presence of PFAS in drinking water could be considered an environmental justice issue based on the incidences of drinking water contamination affecting predominantly working class areas surrounding manufacturing and chemical plants. This contamination has a demonstrated connection to adverse health impacts. While localized contamination of drinking water sources from PFAS exhibits environmental justice concerns, more research must be done to assess environmental justice concerns surrounding exposure to PFAS in a broader sense. Emerging research demonstrates that low income communities and communities of color may face increased exposure to PFAS through drinking water. An analysis from ABC News found that PFAS-contaminated sites are more prevalent in low income communities and communities of color. 

Furthermore, we know that all public health and environmental health issues are inextricably linked to inequities in society. Therefore, the issue of PFAS contamination does not exist in a vacuum, isolated from other social issues, but instead may amplify existing disparities and inequities in areas of health, access to safe drinking water, and access to safe environments. A publication from the National Academies of Sciences, Engineering, and Medicine recently explained, “When considering environmental justice, it is important to think beyond exposure disparities; core environmental justice issues relevant to PFAS also include rural health, industrial siting, and access to environmental exposure reduction and clinical care.” In other words, the issue of PFAS contamination is just as complex as the world we live in. Water contamination interacts and intersection with other structural inequalities and social norms. When considering the possible environmental justice issues that could emerge we have found that there could be injustice in areas including equal access to regulation of PFAS, equal access to water testing, access to sufficient medical support, and access to mitigation mechanisms. However, it is clear that more research is required on this topic.

"We need the data, and we don't have the data, and the [corporations] are not willing to give it to us."
Pat Elder Director, Military Poisons

Data Availability and Transparency

Due to the nature of PFAS and its relation to environmental justice, we are calling for more data availability and transparency around PFAS contamination in drinking water. In order to effectively respond to the major public health issue PFAS contamination poses, access to as much information as possible will be necessary. As such, the government, water utilities, wastewater treatment plants, manufacturers, corporations, and other entities should be transparent with all information concerning PFAS contamination. Additionally, governments should pass laws and create regulations requiring transparency from all entities around their use of and testing for PFAS. This will allow for researchers, regulators, and other decision makers to come to the most informed conclusions about this complex issue.

“We have industry, then we have the lack of responsibility of the federal government to hone in on that industry for decades and decades.”
Brent Walls Upper Potomac Riverkeeper
"Companies are always trying to get us to split out PFOS and PFOAS, so the big concern remains regulating PFAS as a class."
Sara Love Maryland State Delegate
“The US is taking, not only a sector by sector approach, but a substance by substance approach. They want to study basically every PFAS before they actually do something about it, which is both frustrating and dangerous.”
Johanna Adashek Visiting Associate Professor and Environmental Law Fellow at the George Washington Law School

Recommendations

The federal government should not address PFAS regulation on a chemical by chemical basis, which is what the chemical industry has argued for. Since PFAS are a class of over 14,000 chemicals, regulating them on a chemical by chemical basis is both inefficient and ineffective. Maryland Delegate, Sara Love equated this regulatory approach to “playing a game of Whack a Mole” as she stressed the importance of regulating PFAS as a class. Given that virtually all PFAS are found to harm human health and the environment, it is important to prevent the toxicity and pollution of PFAS overall, which is why we recommend regulating the entire class.

Since PFAS break down in their surroundings extremely slowly, it is important to prevent these chemicals from ever entering the environment. This means drastically reducing the manufacturing and production of these chemicals and products that contain them. In many products, use of PFAS is nonessential or substitutable, meaning use is either completely unnecessary to the quality of the product or there are alternative methods of manufacturing these products where PFAS can be replaced with other substances. However, some uses of PFAS are important in a few products necessary for the health and betterment of individuals and society as a whole. For example, the unique stability of PFAS has become important to medical devices including catheters and kidney dialysis machines. They are also currently necessary to manufacture computer chips, with no alternative material yet identified. 

All nonessential use of PFAS should be heavily regulated and phased out, given the danger these substances pose to human health and the environment. Research into alternatives to PFAS should be expanded in order to eventually phase out sources that are currently considered salient to human health or societal functions. Overall, preventing the manufacturing and use of PFAS and products containing PFAS will be much more effective than remediation of future pollution given the persistent and stable qualities of these chemicals. It will be more cost effective factoring in the avoided cost of remediation. It will also be more efficient for preventing adverse impacts on human health.

Due to the severity of PFAS contamination as a major public health issue, it will be costly to address. This cost could easily be passed to taxpayers and ratepayers at water utilities, who are not those most responsible for the widespread contamination of drinking water sources. Despite this, they are exposed to PFAS contaminated water everyday, often unknowingly. Those responsible for widespread PFAS contamination in groundwater and water sources are largely the corporations that manufacture PFAS products and have known about the dangers of PFAS for decades, yet have not taken substantive action. In some cases, manufacturers and corporate entities have chosen not to disclose research about the dangers of PFAS to regulators and the public. Therefore, we recommend that PFAS polluters are held financially responsible for the damage they have cause across the nation. 

How to stay informed about PFAS

In order to hold the government, institutions, and PFAS manufacturers accountable for PFAS pollution, it is important to stay up to date and informed on the issue. Following environmental watchdog organizations such as the Environmental Working Group is a good first step. Secondly, on May 4, 2023 the EPA is holding a public hearing regarding the proposed PFAS National Primary Drinking Water Regulation.