On November 11, 2022, EPN submitted comments on the World Health Organization’s (WHO) draft guidelines for PFAS in drinking water. We are disappointed in the mischaracterization of hundreds of animal, human, and epidemiological studies on the health effects of PFOA, PFOS, and other PFAS compounds used by multiple public health agencies throughout the U.S. and the world. As a result, these guidelines undermine every health-based guideline value developed by those public health agencies. The background document is deficient in rigor, method, and comprehensiveness.
Because WHO did not conduct a systematic review of health effects or treatment technology studies, they have omitted many critical findings and mischaracterized the studies that are included. EPN is concerned that WHO is racing to get these provisional guidelines reviewed before EPA publishes a proposed MCL and MCLG for PFOA and PFOS in December 2022. We are also concerned with the lack of transparency regarding the authors of the WHO report, who provided peer-review comments, and what organizations those authors and peer reviewers represent. EPN finds that the provisional guidelines reflect a biased and dangerous approach to public health protection that falsely equates the natural and unavoidable uncertainty inherent in all scientific studies with a lack of evidence.
Read the comments.Â