An attorney representing a large group of PFOA-exposed individuals sent a letter to EPA Administrator Stephen Johnson and ATSDR Director Howard Frumkin, urging them not to delay any further the release of hazard information and risk assessments on the contaminant perfluorooctanoic acid (PFOA, a.k.a. C8).  Mr. Bilott was writing on behalf of residents who live near DuPont’s Washington Works plant near Parkersburg, WV and 

“who continue to be exposed to this poison in their residential drinking water on a daily basis.”   

In a 2005 legal settlement with the residents, DuPont agreed to clean-up parts of the C8-contaminated water systems and sponsor an unbiased scientific panel to investigate links between C8 exposure and human disease; for the most part those are ongoing.  Mr. Bilott writes that he was compelled to send his letter after reading or otherwise learning that EPA is being pressured to

“discontinue or delay its efforts to pursue further toxicity and exposure research on perfluorooctanoic (PFOA).”

He explains the consequences EPA’s inaction is having on State agencies, which are the entities which actually have to respond to instances of PFOA-contaminated water supplies and residents’ concerns about the compound in human blood and breast milk.

Bilott writes:

“Although USEPA has released several draft hazard assessments and risk assessments for PFOA since 2001, none have been finalized.  In addition, although USEPA has taken steps to initiate the process for evaluating PFOA through the IRIS process, USEPA has not publicly released any draft of any such assessment.”

The attorney’s letter provides a chronology of events, but still no final product.

“It has now been approximately a decade since USEPA first learned of the existence of PFOA (and related perfluorochemicals) in the environment and in human blood.  More than seven years have passed since we first reported to USEPA the presence of excessive levels of PFOA in residential drinking water supplies, and more than five years have passed since USEPA first announced the commencement of its formal investigation into the sources of effects of PFOA in the environment and humans” (emphasis added).

“USEPA first released a draft risk assessment in 2003.  Over the next several years, USEPA indicated that it could not finalize its risk assessment for PFOA until it had been reviewed and approved by USEPA’s Science Advisory Board’s independent PFOA Review Panel.”

The review panel gave its final report and recommendation to EPA in May 2006. 

“Although it has now been almost two years… USEPA has not released any revised risk assessment or IRIS review for PFOA and has now confirmed that it does not intend to do so for at least several years.”

About ATSDR, Bilott reports:

“Although it was publicly-stated years ago that ATSDR was working on an evaluation of health risks, including risks arising from PFOA contamination of human breast milk, arising from PFOA-contaminated drinking water in Ohio and West Virginia, ATSDR also has not yet released a draft of any such report and has not clarified if or when it intends to do so.”

Bilott also warns of the adverse public health consequences of delaying release of information or protective action in a mistaken quest for newer, better, or more complete data.  He writes:

“New studies and data will continue to be released, as is the case with essentially every other chemical.  As USEPA and ASTDR have done in the past, the new studies should be evaluated to determine whether present agency conclusions warrant modification; but the present conclusions should not be held by the agencies while researchers continue their work.  Waiting another ‘several years’ to complete the PFOA work in hopes that some ‘better’ or more ‘complete’ data may come along is too long for those drinking the contaminated water (and breast milk) every day to continue to wait.”

For decades, advocates for public health, communities and workers have seen how polluters and manufacturers of dangerous products have made claims of scientific uncertainty to delay action to protect the public’s health and environment.   We don’t need our government officials doing the same thing.  Hats off to Mr. Bilott for advocating the community’s right-to-know, even if that information is incomplete.  As Sir Austin Bradford Hill stated in 1965:

“All scientific work is incomplete—whether it be observational or experimental.  All scientific work is liable to be upset or modified by advancing knowledge.  That does not confer upon us a freedom to ignore the knowledge we already have, or to postpone action that it appears to demand at a given time…”