Due Date for PFNA Comments
Tell NJDEP You Want Clean Water NOW!
Safe Drinking Water Standards proposed for PFNA and 1,2,3,-TCP
Write a letter by October 6 demanding safe drinking water standards be set to remove these toxic compounds from our water!
NJDEP has proposed regulations that will require the removal of 2 toxic compounds from New Jersey’s drinking water systems: Perfluorononanoic Acid (PFNA) and 1,2,3-trichloropropane (1,2,3-TCP). These chemicals are unregulated at the federal level and are found in drinking water in New Jersey at higher levels than in other states. Both are human-made chemicals that have been released into the environment primarily through industrial use and manufacturing.
PFNA is in a family of chemicals called perfluorinated compounds or PFCs. PFNA is more toxic at lower doses than most other PFCs, and can cause liver damage, metabolic and immune system problems, increased cholesterol, and may have negative developmental effects on fetuses and young children. PFNA does not break down in the environment and builds up in the human body. 1,2,3-TCP is a potent “likely” carcinogen and is both mutagenic and genotoxic.
After years of research and scientific analysis, the New Jersey Drinking Water Quality institute recommended the state adopt a maximum contaminant level (MCL) of 13 parts per trillion (ppt) for PFNA and 30 ppt for 1,2,3-TCP. DRN is advocating for an even stricter standard for both these chemicals to provide more effective protection. For instance, independent toxicologists commissioned by Delaware Riverkeeper Network conclude that the MCL for PFNA should be between 3 to 5 ppt to better protect vulnerable fetuses and young children whose development can be permanently marred by PFNA exposure.
NJDEP is finally proposing rules that will require that water systems test for these contaminants and, when they find them, remove them to below the MCL. It is imperative that these regulations be swiftly adopted to protect people from the elevated risk they now face of developing diseases correlated with drinking water contaminated with these toxic compounds.
You can help get these toxins out of our water by submitting a letter by October 6, COB, in support of rulemaking
To read the proposed rulemaking, which includes the MCLs and several amendments to the Safe Drink Water Act and Private Well testing Act, and to submit comments, click here.
Since NJDEP uses a form submittal, you may use our Talking Points below to quickly write your own letter and submit through the NJDEP link. (In the "Rulemaking" drop down list, make sure to select: DEP Dkt No. 13-17-06, Safe Drinking Water Act Rules, MCLs; Private Well Testing Act Rules)
However you choose to weigh in, please speak up for safe drinking water by supporting action by New Jersey to adopt MCLs for these highly dangerous chemicals!
Here are some talking points:
- PFNA is highly toxic at low doses, doesn’t break down in the environment, and remains a threat indefinitely yet there is no federal regulation; people don’t even know if it’s in their water
- PFNA builds up in the blood from very small concentrations in drinking water, is difficult for the body to excrete, lasting for many years after exposure in the body
- The adverse health effects from PFNA exposure include liver damage, metabolic and immune system function problems, increased cholesterol, and development defects in fetuses and young children
- There are higher concentrations of PFNA in New Jersey drinking water than other states
- For these reasons PFNA must be removed from our drinking water immediately to protect people’s health and the environment
- New Jersey is proposing a MCL for PFNA of 13 ppt but independent toxicologists engaged by Delaware Riverkeeper Network have concluded that to protect the most vulnerable populations - fetuses and young children - a MCL should be set between 3 and 5 ppt. It is essential we provide the most protection possible to fetuses and children from the risk of developmental damage that that can be indelible for a person’s entire life or can cause devastating disease later in life. DEP should adopt the stricter standard of 3 to 5 ppt.
- Monitoring for PFNA should not be phased in slowly in 2019-2020, as is proposed by DEP. Monitoring for PFNA should begin rapidly in order to locate all water systems that are contaminated with this toxic compound so that PFNA can be quickly removed from our water.
- PFNA should be added to the contaminants that must be tested for and removed under the Private Well Testing Act; this rule does not propose sampling of private water wells. All New Jerseyans need protection, whether they are private well users or are on public water systems.
- Treatment with carbon filtration will remove many dangerous pollutants from drinking water, in addition to PFNA. Treatment should be required to be installed immediately upon its discovery in a water system; granular activated carbon will provide multiple benefits to public health.
- 1,2,3-TCP is an extremely potent carcinogen; it is both mutagenic and genotoxic, so acts multiple ways to cause cancer. It is not regulated so suppliers are not required remove it from our water.
- 1,2,3-TCP is found in higher concentrations in New Jersey than our neighboring states and is in very high levels in Moorestown, Burlington County. As the most densely populate state in the nation, water contamination causes harm to millions when water systems are polluted.
- NJDEP is proposing a MCL of 30 ppt for 1,2,3-TCP but California has just adopted a standard of 5 ppt based on the most up to date science. New Jersey should adopt 5 ppt as the MCL for 1,2,3-TCP to provide the protection people need from the risk of developing cancer or other devastating disease.
- For these reasons 1,2,3-TCP must be removed from our drinking water immediately to protect people’s health and the environment
- Many New Jerseyans who first found PFNA and 1,2,3-TCP in their drinking water have been exposed for a long time to dangerous concentrations of these toxic chemicals, increasing the likelihood that they and their families could develop diseases related to the exposure. They and the rest of the state’s population that are drinking contaminated water deserve regulatory action to remedy the lack of controls that led to this unjust situation. Establishing a MCL will not only get these out of our drinking water but will also set clean-up standards to be used to remove these chemicals from our environment once and for all. NJ must act now!
- NJ Drinking Water Quality Institute has thoroughly studied and recommended a MCL for Perfluorooctanoic Acid or PFOA, another highly toxic perfluorinated compound (PFC). That was February 2017 but the Institute’s recommendation inexplicably languishes on DEP’s desk. PFOA has been found in most of the water supplies in New Jersey where it has been investigated, affecting millions of New Jerseyans. DEP has a responsibility to act to protect people from being exposed to elevated levels of this toxic compound, a likely carcinogen among other diseases. Toxins in our drinking water constitute a public health emergency and DEP must take action - the science is done and there is absolutely no excuse for this delay in establishing a drinking water standard for PFOA. DEP should urgently move ahead with the rulemaking to adopt a MCL to get PFOA and other toxins out of our water!
Don’t forget, NJDEP uses a form submittal, you may use our Talking Points below to quickly write your own letter and submit through the NJDEP link. (In the "Rulemaking" drop down list, make sure to select: DEP Dkt No. 13-17-06, Safe Drinking Water Act Rules, MCLs; Private Well Testing Act Rules)