Background
On April 10, 2024, the U.S. Environmental Protection Agency (EPA) released new regulations for PFAS chemicals in drinking water. The State of Vermont has regulated PFAS in drinking water since 2019. The new regulations from EPA are different from Vermont’s regulations—stricter in some regards and less strict in others.
Here is a comparison of the regulations from EPA and the State of Vermont:
EPA MCLs
The EPA set Maximum Contaminant Levels (MCLs) for five PFAS compounds. MCLs refer to the highest level of a contaminant that is allowed in drinking water.
| Individual PFAS Compounds | EPA MCL (ppt) |
|---|---|
| PFOA (Perfluorooctanoic Acid) | 4.0 |
| PFOS (Perfluorooctane Sulfonic Acid) | 4.0 |
| PFNA (Perfluorononanoic Acid) | 10 |
| PFHxS (Perfluorohexane Sulfonic Acid) | 10 |
| HFPO-DA (Hexafluoropropylene Oxide Dimer Acid or “GenX”) | 10 |
EPA Hazard Index
The EPA also set a Hazard Index for a combination of four PFAS compounds. This is a calculation of the hazard posed by a mixture of different chemicals. Each PFAS compound is represented by a fraction, and the sum of all four should not be greater than one. Learn how to calculate the Hazard Index at https://www.epa.gov/system/files/documents/2024-04/pfas-npdwr_fact-sheet_hazardindex_4.8.24.pdf
| Hazard Index Compounds | EPA Hazard Index (no unit) |
|---|---|
| PFNA, PFHxS, PFBS, HFPO-DA | 1.0 |
Vermont Regulations
Vermont’s regulations set a cumulative maximum contaminant level (MCL) for five PFAS compounds. The combined total of these five compounds should not exceed 20 parts per trillion (ppt).
| Vermont Regulated Compounds | Vermont Cumulative MCL (ppt) |
|---|---|
| PFOA, PFOS, PFNA, PFHxS, PFHpA | 20.0 |
Public Outreach for Water Systems
Following the announcement of EPA’s new PFAS regulations, there have been a lot of news stories about PFAS in drinking water. Water systems should be prepared to answer questions from reporters and customers about PFAS and the new regulations. You may also consider proactive outreach, such as a press release to local media or a letter to customers.
To help water systems with public outreach, Vermont Rural Water has put together template messaging that water systems can use. This document is based on a template created by Mike McGill at WaterPIO. You can hear Mike speak about PFAS and public communications at our 2024 Conference on May 9 at Lake Morey Resort.
Template Messaging
[Note to users of this template: Replace words in [brackets] with information that is specific to your utility. Feel free to add, edit, or omit language as needed. This document is based on a template created by WaterPIO and generously shared with the drinking water industry across the country.]
On April 10, 2024, the U.S. Environmental Protection Agency (EPA) released new regulations for PFAS chemicals in drinking water. [Utility name] wants to assure customers that we take these regulations seriously and our water is tested regularly for PFAS and other contaminants.
“PFAS” is short for per- and polyfluoroalkyl substances. It is a group of man-made chemicals that were first invented in the 1940s. There are thousands of different types of PFAS chemicals and more are being invented all the time. They are used in industrial manufacturing, firefighting foam, and common household products. PFAS has been found to cause negative health effects on humans, including developmental, immune, endocrine, reproductive, and carcinogenic effects.
The State of Vermont has regulated PFAS in drinking water since 2019, so [utility name] has already been testing our water for a number of years. The new regulations from EPA are different from Vermont’s regulations—stricter in some regards and less strict in others.
EPA has set Maximum Contaminant Levels (MCLs) for five PFAS compounds: PFOA and PFOS, PFNA, PFHxS, and HFPO-DA. Under the new regulations, any water system that is found to have PFAS levels above these MCLs is required to take action to reduce PFAS levels by 2029.
In addition, EPA set a Hazard Index for a mixture of four PFAS compounds: PFNA, PFHxS, HFPO-DA, and PFBS. For more information about EPA’s new drinking water standards for PFAS, visit https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas.
Vermont’s regulations set a cumulative MCL for five PFAS compounds: PFOA, PFOS, PFNA, PFHxS, and PFHpA. The combined total of these five compounds should not exceed 20 parts per trillion (ppt).
Most public water systems in Vermont have been required to test for PFAS since 2019, so [utility name] already has several years of data about PFAS levels in our drinking water. In light of EPA’s new PFAS regulations, [utility name] will review our PFAS test results to determine if additional courses of action are necessary. We will continue testing for PFAS results regularly. Test results can be found in our annual Consumer Confidence Report or by contacting us directly.
[IF APPLICABLE, DESCRIBE ANY ACTIONS YOU’VE ALREADY TAKEN TO MITIGATE PFAS HERE.]
EXAMPLE LANGUAGE…
Because PFAS levels from our previous testing could raise concerns before the EPA’s compliance deadline in 2029, [utility name] is taking the following proactive actions:
- We have installed/are working to install granular activated carbon filtration to remove PFAS from drinking water.
- We have switched to a new water source/are investigating a new water source with lower levels of PFAS.
- We are voluntarily testing our water (monthly/quarterly/annually) to gather the best data possible to guide future decision-making and keep our customers informed. We will also participate in all required federal and state testing.
- We will continue to coordinate and collaborate with state and federal regulatory agencies regarding ongoing research and rule-making developments.
- We will continue openly communicating about PFAS, and we encourage our customers to visit our webpage on PFAS at [LINK].
- We are examining strategies to effectively address PFAS contamination through our water treatment process.
It is important to understand that PFAS chemicals are not added to drinking water. Instead, water sources like rivers, lakes, wells, and springs may become contaminated with PFAS that come from manufacturing plants or use of commercial or household products that contain PFAS.
Rather than blaming water utilities for PFAS, the industrial manufacturers that produce and profit from these chemicals should be held accountable. There are currently a number of lawsuits against PFAS manufacturers that are responsible for drinking water contamination, and the Vermont legislature is working on a bill to ban PFAS in consumer products.
Only an estimated 20 percent of a person’s exposure to PFAS comes from drinking water. The rest comes from products that you likely have in your home: non-stick cookware, food packaging, cosmetics, stain/water-resistant clothing, carpet and furniture treatments, and more.
Bottled water may contain PFAS, so drinking bottled water will not necessarily help reduce a person’s exposure to PFAS. Bottled water is not usually tested for PFAS. The U.S. Food and Drug Administration (FDA) does not currently have safety standards for PFAS in bottled water.
The State of Vermont has taken some actions to restrict the use of PFAS chemicals. Act 36 of 2021 prohibits selling, manufacturing, and/or distributing the following products if they contain intentionally added PFAS: firefighting foam; food packaging; rugs, carpets, and carpet treatments; and ski wax.
The Vermont Legislature is also currently working on a bill (S.25) that will ban the manufacture, sale, and/or distribution of the following products that contain PFAS: cosmetic or menstrual products, aftermarket stain and water-resistant treatments, cookware, incontinency protection products, baby and toddler products, rugs and carpets, ski wax, textiles, and artificial turf.
Regardless of the challenges posed by PFAS, [utility name] is committed to providing safe, reliable drinking water. We will continue to operate as we always have, as a protector of public health that delivers high-quality drinking water to your taps.