Report on Proposed Reversal of PFAS Regulations and Implications for Sustainable Development Goals

Executive Summary

The U.S. Environmental Protection Agency (EPA) has initiated a request to reverse established regulatory standards for three per- and polyfluoroalkyl substances (PFAS) in public drinking water systems. This action poses a direct challenge to the achievement of several key United Nations Sustainable Development Goals (SDGs), particularly SDG 6 (Clean Water and Sanitation) and SDG 3 (Good Health and Well-being). The proposal seeks to replace specific Maximum Contaminant Levels (MCLs) with a “hazard index” approach, a move that has elicited significant concern from scientific experts and environmental organizations who argue it prioritizes industrial interests over public health and environmental protection.

Background on PFAS Contamination and Regulation

Health Risks and Environmental Persistence

Per- and polyfluoroalkyl substances (PFAS) are a large group of synthetic chemicals known as “forever chemicals” due to their extreme persistence in the environment. Their widespread use in industrial and consumer products has led to extensive contamination of U.S. drinking water sources. The health implications of PFAS exposure are severe and directly contravene the objectives of SDG 3: Good Health and Well-being.

• Carcinogenicity: PFAS are classified as a Group 1 carcinogen by the International Agency for Research on Cancer.
• Adverse Health Effects: Research links exposure to an increased risk of various cancers, as well as significant hormonal and reproductive health issues.

Original Regulatory Framework

The PFAS National Primary Drinking Water Regulation established a critical framework for safeguarding public water supplies, in line with SDG 6: Clean Water and Sanitation. This regulation mandated that water utilities reduce levels of six specific PFAS chemicals to below newly established MCLs by 2029.

1. MCL for PFOA and PFOS: 4.0 parts per trillion (ppt).
2. MCL for PFHxS, PFNA, and HFPO-DA: 10.0 parts per trillion (ppt).

Analysis of Proposed Regulatory Rollback

EPA’s Justification for Reversal

In a request to the U.S. Court of Appeals, the EPA has sought to vacate the regulations for PFHxS, PFNA, and HFPO-DA. The agency’s rationale is based on a procedural claim that “parts of the rulemaking process were unlawful” under the Safe Drinking Water Act, alleging that the public was not provided an adequate opportunity to comment.

Proposed “Hazard Index” Alternative

The EPA has proposed replacing the individual MCLs for the three chemicals with a “hazard index.” This method assesses the cumulative risk from a mixture of different PFAS chemicals rather than regulating them individually. The agency suggests this index focuses on the collective health hazard when multiple PFAS are present, even at low individual levels.

Implications for Sustainable Development Goals (SDGs)

Direct Conflict with SDG 6: Clean Water and Sanitation

The proposed rollback fundamentally undermines the core targets of SDG 6, which aims to ensure access to safe and affordable drinking water for all.

• Target 6.1 (Safe Drinking Water): By removing specific, enforceable limits for three known harmful chemicals, the action directly threatens the safety of public drinking water for millions of Americans.
• Target 6.3 (Improve Water Quality): The reversal would weaken efforts to reduce chemical pollution and protect water sources from contamination, moving away from the goal of improving ambient water quality.

Threats to SDG 3: Good Health and Well-being

The potential for increased levels of PFAS in drinking water presents a significant public health risk, directly opposing the aims of SDG 3.

• Target 3.9 (Reduce Deaths from Hazardous Chemicals): Allowing higher concentrations of carcinogenic and hormonally disruptive chemicals in drinking water is expected to increase public exposure, potentially leading to a higher incidence of related illnesses and deaths.

Contradiction of SDG 12: Responsible Consumption and Production

The rollback sends a signal that may reduce the impetus for industrial responsibility, in conflict with SDG 12.

• Target 12.4 (Sound Management of Chemicals): As noted by experts, removing federal MCLs may disincentivize manufacturers from reducing their use of PFAS, thereby hindering progress toward the environmentally sound management of chemicals and waste throughout their life cycle.

Stakeholder Concerns and Expert Analysis

Scientific and Environmental Community Response

Experts and environmental advocates have voiced strong opposition to the EPA’s request, framing it as a regression in environmental and public health policy.

• Phil Brown, Northeastern University: Expressed deep concern, stating that the move dismantles well-intentioned regulations developed over years of scientific study and community effort. He predicts the rollback will lead to increased PFAS in drinking water and the broader food chain, arguing the administration is prioritizing corporate profit over human health.
• Katherine O’Brien, Earthjustice: Accused the EPA Administrator of failing to protect the public from PFAS contamination, stating the plan to “delay and roll back” national limits prioritizes chemical industry and utility profits over the health of families.

Conclusion and Outlook

The outcome of the EPA’s request to the court remains uncertain. However, the proposed reversal of drinking water regulations for three PFAS chemicals represents a significant challenge to national public health protections and a substantial setback for the United States’ progress toward achieving key Sustainable Development Goals, particularly those concerning clean water, public health, and responsible chemical management.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 3: Good Health and Well-being

   • The article directly connects the presence of PFAS chemicals in drinking water to significant health risks. It states that these chemicals are “classified as a Group 1 carcinogen” and are associated with “increased risk of various cancers alongside hormonal and reproductive issues.” The entire debate around regulating these chemicals is centered on protecting human health from the adverse effects of pollution, which is a core component of SDG 3.

2. SDG 6: Clean Water and Sanitation

   • The central theme of the article is the contamination of drinking water systems in the U.S. by PFAS chemicals. It highlights that “millions of Americans are currently drinking water contaminated with the chemicals.” The discussion revolves around the “PFAS National Primary Drinking Water Regulation” and the establishment of “Maximum Contaminant Levels (MCLs)” to ensure water safety. This directly addresses the goal of providing access to clean and safe water for all.

3. SDG 12: Responsible Consumption and Production

   • The article mentions that PFAS chemicals “are used across various industries, featuring in consumer products.” The call to regulate these “forever chemicals” is linked to managing hazardous substances throughout their lifecycle to prevent environmental contamination. The concern that rolling back regulations would give chemical manufacturers “less incentive to reduce PFAS use” points directly to the need for more sustainable production patterns and sound management of chemicals.

4. SDG 16: Peace, Justice and Strong Institutions

   • The article details a conflict involving a key government institution, the Environmental Protection Agency (EPA). It discusses the EPA’s attempt to roll back its own regulations, citing that “parts of the rulemaking process were unlawful” because the public was not given “the opportunity to adequately comment.” This highlights issues of institutional transparency, accountability, and the development of effective regulations. The shift in policy between different administrations further underscores the challenges in maintaining strong and consistent institutional governance for environmental protection.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Under SDG 3: Good Health and Well-being

   • Target 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination. The article’s focus on regulating PFAS chemicals in drinking water to mitigate health risks like cancer and hormonal issues is a direct effort to achieve this target by reducing illness from water contamination.

2. Under SDG 6: Clean Water and Sanitation

   • Target 6.1: By 2030, achieve universal and equitable access to safe and affordable drinking water for all. The article reveals that millions of Americans lack access to safe drinking water due to PFAS contamination. The regulations being debated are a mechanism to ensure the water provided by utilities is safe for consumption, aligning with this target.
   • Target 6.3: By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials. The entire purpose of setting Maximum Contaminant Levels (MCLs) for PFAS is to reduce the pollution of drinking water by these hazardous chemicals, thereby improving overall water quality.

3. Under SDG 12: Responsible Consumption and Production

   • Target 12.4: By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle… and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment. The regulation of PFAS in drinking water is a critical component of managing these chemicals’ impact after their release into the environment. The article also touches on their lifecycle, noting that a lack of regulation could lead to more PFAS in “wastewater and hence in biosolids resulting from wastewater treatment, much of which ends up in fertilizer and then enters our food chain.”

4. Under SDG 16: Peace, Justice and Strong Institutions

   • Target 16.6: Develop effective, accountable and transparent institutions at all levels. The article’s discussion of the EPA’s legal justification for rolling back regulations—specifically, the claim that the public was not given an adequate “opportunity to adequately comment”—directly relates to the principles of transparent and accountable governance within public institutions.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. Indicators for SDG 3 and SDG 6

   • Maximum Contaminant Levels (MCLs): The article explicitly states the MCLs set by the EPA, which serve as direct, quantitative indicators for water safety. These are:
     • “For PFOA and PFOS, the MCL was 4.0 parts per trillion.”
     • “For PFHxS, PFNA, and HFPO-DA, the MCL was 10 ppt.”

     Progress towards Targets 3.9 and 6.1 can be measured by the proportion of water utilities and the population served by them that meet these specific contamination levels.

   • Hazard Index: The article mentions the EPA’s proposal to regulate some PFAS chemicals through a “hazard index.” This index, which “involves comparing the level of different PFAS measured in the water to the highest level below which there is no risk of health effects,” serves as a composite indicator for measuring the collective health risk from multiple chemicals in drinking water.

2. Indicators for SDG 12

   • Concentration of chemicals in water systems: While not a direct measure of production, the levels of PFAS (measured in parts per trillion) found in drinking water are an implied indicator of their release into the environment from industrial and consumer sources. Tracking these levels over time can measure the effectiveness of policies aimed at the sound management of chemicals (Target 12.4).

3. Indicators for SDG 16

   • Existence and enforcement of regulations: The article refers to the “PFAS National Primary Drinking Water Regulation” and its enforcement deadline. The existence, implementation, and consistent enforcement of such national environmental laws are qualitative indicators of the effectiveness of institutions (Target 16.6).
   • Adherence to procedural requirements: The legal challenge based on the public’s “opportunity to adequately comment” implies that adherence to procedural requirements under laws like the Safe Drinking Water Act is an indicator of institutional transparency and accountability.

4. Summary Table of SDGs, Targets, and Indicators

Source: newsweek.com