Recently several states (
e.g. MN, NH, NJ, VT, MI) have proposed drinking water regulatory or guideline levels below 70 ppt (
Cordner et al., 2019;
MDHHS, 2019;
NHDES, 2019).
For various reasons, including uncertainties in data and biological significance, the EPA did not select the most sensitive health effects currently associated with PFOA and PFOS when generating their 2016 health advisories. There is evidence that both
altered mammary gland development for PFOA (
Macon et al., 2011;
Tucker et al., 2015;
White et al., 2011) and
immunotoxicity for PFOS (
Dong et al., 2009;
Grandjean and Budtz-Jorgensen, 2013;
Guruge et al., 2006;
Peden-Adams et al., 2008) can occur
at levels an order of magnitude or lower than the health effects selected by the EPA. Since the EPA issued its 2016 advisories, the National Toxicology Program (NTP) released
a report concluding that both PFOA and PFOS are presumed to constitute immune hazards to humans (NTP, 2016). And most recently, the New Jersey Drinking Water Quality Institute (NJDWQI) and the Agency for Toxic Substances and Disease Registry (ATSDR) have either acknowledged or attempted to account for these more sensitive health effects in generating their proposed health standards (
ATSDR, 2018;
NJDWQI, 2017;
NJDWQI, 2018). As a result, both NJDWQI and ATSDR have proposed significantly more protective (5–10 times lower) health thresholds for PFOA and PFOS than the EPA health advisories (
ATSDR, 2018;
NJDWQI, 2017;
NJDWQI, 2018).