Michigan submits comment on draft PFAS Toxicological Profile to federal government

LANSING, Mich. – The Michigan PFAS Action Response Team (MPART) has submitted comments to the U.S. Centers for Disease Control and Prevention (CDC) Agency for Toxic Substances and Disease Registry (ATSDR) regarding the draft Toxicological Profile for Perfluoroalkyls posted in June 2018.

In its submission, MPART is requesting that the ATSDR include additional information regarding the new proposed Minimum Risk Levels (MRLs), as well as guidance about how the MRLs will impact the current Lifetime Health Advisory used by the U.S. Environmental Protection Agency (EPA). Application of MRL information is beyond the typical scope of a Toxicological Profile. However, additional guidance is needed from the federal government regarding use of the MRLs, their translation into policy, and resulting drinking water comparison values, especially within the context of other federal agency guidance documents and advisories.

MPART continues to support the need for additional toxicology studies that would provide further information about immunological and developmental evaluation after acute, intermediate, and chronic exposure to perfluoroalkyl and polyfluoroalkyl substances (PFAS). MPART officials called upon the EPA to accelerated research and rule-making on PFAS compounds at a recent EPA summit meeting on the emerging contaminant in May.

Given the evolving knowledge on PFAS, and the limited nature of ATSDR’s draft report, MPART suggests that a focused literature review of newly available case studies be completed. The draft Toxicological Profile for Perfluoroalkyls appears to have captured all relevant peer-reviewed literature available at the time of development and their potential environmental and health effects. The draft report reviewed 14 PFAS compounds, but only comments on four compounds due to a lack of data: PFOA, PFOS, PFHxS and PFNA. The draft report’s conclusions are also limited to intermediate exposure levels, demonstrating that much more needs to be learned about this emerging class of contaminants.

Michigan is now addressing more than 34 sites of PFAS contamination. The draft report’s additions of MRLs for will assist the state in responding to these contaminants which have been have also been found along with PFOS and PFOA during MPART’s investigations. Because of the very high level of interest and concern about the MRLs, MPART believes this information should be completely transparent and requests that additional detail regarding these MRLs be added to clarify what blood serum levels were considered and what uncertainty factors were applied.

Governor Snyder created MPART, the first multi-agency action team of its kind in the nation, in 2017 to address the emerging contaminant of PFAS and take proactive steps to protect the health of Michigan residents. Michigan has moved quickly to protect people from potentially unsafe drinking water in communities with known PFAS contamination from historic industrial or military activities, including being one of only a handful of states to establish clean-up standards for any PFAS compounds found in groundwater used for drinking. Less than half of all states have adopted any guidance or standards for PFAS, and only four have standards below Michigan’s groundwater criteria of 70 ppt.

MPART has created an independent Science Advisory Panel to review current research on PFAS and make recommendations regarding health effects, environmental pathways, remediation, and whether PFAS analytes in addition to PFOA and PFOS should be of concern. This independent panel is evaluating the draft ATSDR report and other available literature and will determine if the state should change its current groundwater clean-up criteria from the current EPA Health Advisory Lebel of 70 ppt. The MPART science board is also working closing with state scientists to determine whether additional PFAS compounds should be regulated. 

MPART will continue taking proactive steps to survey the state, gather important baseline data on the presence of PFAS in our communities, and review the best available science regarding this emerging contaminant.

MPART provided additional detail regarding MRL development in its response to ATSDR, including a request for how these may be updated as the toxicology and epidemiology research on PFAS continues. For Michigan’s full response to the draft Toxicological Profile for Perfluoroalkyls, visit https://www.regulations.gov/document?D=ATSDR-2015-0004-0050.

For more information about MPART or PFAS in Michigan, visit www.michigan.gov/pfasresponse.