Alert - Environmental Working Group (EWG) Report Showing Utilities Providing Finished Drinking Water Above EWG's "Health Guidelines"
The EWG published a provocative, highly questionable piece entitled: “Your Utility May Not Tell You About All Contaminants in Your Tap Water. EWG Will.” This immediately starting creating inquiries yesterday and knee-jerk negative media attention to water utilities. This email alert is for those of you with public water utilities to make sure everyone is aware and be prepared to respond. It shows many utilities in Virginia above “health guidelines” and some in SDWA noncompliance (likely incorrectly).
EWG asserts in its introduction to the database that: “The vast majority of the nation's drinking water supplies get a passing grade from federal and state regulatory agencies. However, many of the 250-plus contaminants detected through water sampling and testing are at levels that are perfectly legal under the Safe Drinking Water Act or state regulations, but well above levels authoritative scientific studies have found to pose health risks.” EWG goes on to explain that: “For the levels, this database endorses as safe, we relied on the best available science, going far beyond regulations that are too often driven by political compromise with polluters rather than protecting public health. Going forward, EWG will determine and publish truly safe standards not only for toxic chemicals in drinking water but also for those in food and consumer products. These EWG-endorsed levels are referred to in this database as health guidelines.”
EWG then provides a nationwide database for approximately 50,000 public water systems in the country. The database can be viewed here: https://www.ewg.org/tapwater/?_ga=2.183589286.1655927786.1501176935-1030209820.1501176934#.WXoskLpFzIU.
Essentially, EWG appears to take water system data mostly from 2015 and compare each water systems’ results against health guidelines/goals developed by the California Office of Environmental Health Hazard Assessment. Those guidelines/goals appear to date from 2010 and do not appear to have ever been adopted by the California Department of Public Health as State requirements. They are extremely low, far lower than SWDA standards. For example, the CA OEHHA 2010 DRAFT guideline for TTHM is 0.8 ppb as compared to the federal 80 ppb. Note that the California Department of Public Health adopted the 80 ppb standard for TTHMs in 2006. Thus, the national public is being misled by comparing your TTHM results to a DRAFT California report, which was never adopted and which set an impossibly low TTHM level.
EWG appears to target approximately 10 pollutant parameters and then compares for those parameters (1) statewide water system averages for the pollutants, (2) national water system averages, and (3) a variety of unpromulgated public health “guidelines” – some of which are draft. You won’t be surprised that your system exceeds likely several of these unpromulgated guidelines. Most, if not all, of the guidelines/goals, come from the California Office of Environmental Health Hazard Assessment. None of these “authoritative scientific studies” appear to have been adopted- even by California.
The EWG database is careful not to say you are in legal noncompliance. In fact, in just about every case, they state in bold: “For the latest quarter assessed by the EPA (January to March 2017), tap water provided by this water utility was in compliance with federal health-based drinking water standards.” That is a bit misleading in that it limits the qualification to the “latest quarter” and mixes legal compliance with their following hatchet job comparing your multi-year (not just the last quarter) finished water to unpromulgated “health guidelines”. However, when comparing your utility’s multi-year results to the unpromulgated EWG health guidelines they include a column entitled: “Legal Limit Exceeded 2010-2015” and in every case we viewed, the answer was “NO”.
Worse, the link in the EWG database to EPA’s ECHO enforcement database leads to reports that at least in some cases we know to be inaccurate – EPA records showing Water Utilities to be SDWA noncompliance for multiple quarters when in fact the utility was not. Be sure to check the EPA ECHO database for your utility. (We have asked EPA to take ECHO offline until this problem is fixed but do not have a response yet.)
You can search ECHO here: https://echo.epa.gov/facilities/facility-search?mediaSelected=sdw
While EWG may be sincere in wanting more stringent drinking water standards and standards for unregulated contaminants, this also appears in part to be an effort to promote the sale of household water filtration systems because for each pollutant, they offer to direct you to appropriate water filtration systems to address the contaminant of concern. Their web page also seems to indicate they have a deal with Amazon if you buy your water filter through Amazon (their web page conveniently notes which filters can be ordered through Amazon for all of you Prime users).
Here are some of the typical parameters for which EWG asserts its’ much more stringent “health guidelines” based upon all of those “authoritative scientific studies.”
- Dichloroacetic Acid
- Chromium (hex)
- Radiological contaminants
Bottom Line: The study seeks to undermine the protectiveness of current federal and State MCLs for finished drinking water largely based upon EWG-derived and unpromulgated California “health guidelines.” While there is room for public discussion about unregulated contaminants and appropriate MCLs for existing pollutant parameters, this study does not advance either of those balls in a constructive manner in my view.
If you are contacted about this study you should consult with your public relations manager and counsel. In that conversation you might consider the following discussion points:
- We are in full compliance with all State and Federal drinking water requirements.
- Our families and co-workers drink our water with confidence.
- All of our data about our finished water is submitted to State and federal regulators and is readily available publicly.
- The EWG document inappropriately seeks to compare public drinking water against contaminant levels which have never been adopted by EPA or the State. In some cases, the purported EWG health levels come from dated draft documents which were never adopted.
- We do not believe that our water customers need to purchase in-home water filtration equipment absent special circumstances with your indoor piping or due to special health circumstances (at the direction of your health professional).