EPA today released updated interim drinking water health advisories for PFOA and PFOS.  The health advisory level was previously 70 ppt (parts per trillion) for the total of PFOA and PFOS.  The updated interim health advisory levels are now 0.004 ppt for PFOA and 0.020 ppt for PFOS, three orders of magnitude lower.  EPA’s health advisories are not enforceable or regulatory, but are painful in civil litigation because they have the look of a standard.  These interim health advisories will be in place until EPA passes its PFAS National Primary Drinking Water regulation.  When EPA eventually undergoes a rulemaking process, we can expect a torrent of negative comments focused on achievability and cost. 

EPA also set final health advisory levels for the first time for GenX Chemicals at 10 ppt and for PFBS at 2,000 ppt. In chemical and product manufacturing, these chemicals are considered replacements for PFOA and PFOS.