On January 9, 2020, the Isthmus published a cover story on PFAS: “The fight for safe drinking water; Will Madison officials pay attention to the science on PFAS?”
I commend the Isthmus for publishing this excellent story. Ms. Feener’s interviews with national-level scientific experts outside of Madison—who are not under pressure to agree with status quo institutions here about the safety of our water—were healthy and needed additions to our city’s ongoing discussions about PFAS.
It is very troubling, however, that Isthmus gave Amy Barrilleaux—the Water Utility’s public relations person, also a freelancer for the Isthmus—a full page for an op-ed to rebut Ms. Feener’s article. This doesn’t match our expectations for our local “independent” newspaper, nor does it bode well for the health of democracy in this purportedly progressive city.
Below is my response to some of Ms. Barrilleaux’s comments.
Water Utility dismisses public concerns, puts public relations over public health
Ms. Barrilleaux began her op-ed by lamenting the fact that members of the public contacted the Utility, concerned about Well 9 (on Madison’s east side off Buckeye Rd) after seeing the Isthmus graphic showing the levels of total PFAS in that well. Her comments implied that the public’s concerns are unfounded because the levels of PFBA (perfluorobutanoic (or butyric) acid), the PFAS compound at the highest levels in the well, are well below Minnesota’s standards.[1]
Firstly, the Water Utility should respect their customers’ concerns about any toxic contaminants in the water they drink every day (and pay the Utility for), regardless of whether they are above or below standards. No PFAS compounds, including PFBA, should be in this well or any drinking water. PFBA is a synthetic industrial compound—a shorter chain version of PFOA—that we shouldn’t be ingesting. Why is it in this deep well at levels higher than at any other Madison wells? Where did it come from? The public has every right to ask these questions.[2]
Further, just because most of the regulatory and risk assessment focus to date has been on PFOS and PFOA does not mean PFBA is A-OK. The few studies on PFBA suggest it could have similar effects as other PFAS, such as liver, thyroid, and developmental effects (which is not surprising given that its structure is similar to PFOA), but there are significant uncertainties and more studies need to be done.[3],[4]
As Ms. Feener’s story points out, history illustrates again and again that contaminant levels at one time considered “safe” are often later deemed unsafe as more scientific studies show that they are more toxic than previously thought. In fact, Barrilleaux’s piece also supports this, accurately stating that standards for PFOA and PFOS dropped dramatically several years ago. Dr. Linda Birnbaum, former top scientist with the National Institute of Environmental Health Sciences, recently stated that based on studies showing connections between PFOA and pancreatic cancer, the standards for this compound should be 0.1 ppt—700 times lower than EPA’s current health advisory.
Also, a growing number of studies (see here and here and here) suggest that though smaller chain PFAS compounds tend to be eliminated from the body more quickly than larger ones, they may be as or more toxic as the longer chain compounds. They are also more soluble, persistent and mobile in the environment, and less amenable to carbon-based filtration than longer-chain PFAS. PFBA is no exception. In Minnesota, where the large corporation 3M produced the compound, it has spread over 130 square miles (see pg. 16) around the company’s production and waste sites.[5],[6],[7]
Even without considering PFBA, people who drink Well 9 water have legitimate reasons to question its quality. Besides PFBA and a few other PFAS compounds, Well 9 is contaminated with tetrachloroethylene (PCE), several other volatile organic compounds (VOCs) and hexavalent chromium (hex chromium is at levels well over DHS’s proposed standards). So people who drink water from this well are not only drinking PFAS—they’re drinking a cocktail of contaminants, likely with additive and synergistic effects. Several are known or suspected carcinogens. Does anyone know the health effects of drinking all these chemicals together? Is the Water Utility or our public health department even asking these questions? We see no evidence of that.
The public should be asking questions about the risks from drinking this toxic cocktail, why all these chemicals are there, and what the Water Utility and our public health department will do about it. Public officials in these agencies should respectfully engage these important questions, not dismiss them.
Water Utility proactivity? Or citizen advocacy?
Ms. Barrilleaux also highlighted the Water Utility “proactivity.” This is disingenuous at best. I appreciate that she recognized my work in “bringing attention” to the issue, but I and my activist collaborators did far more than that. MEJO and community members organized in the community and lobbied elected officials and then the Water Utility Board, which finally directed the Utility to test all Madison wells for an expanded set of PFAS compounds. This in turn led to many of the other Water Utility actions Barrilleaux calls out as proactive.
As a key example of the Utility’s proactivity, Barrilleaux highlights a “city that has carried out more drinking water testing for PFAS than any municipality in the state, results of which have helped the Department of Natural Resources develop its list of PFAS compounds for lab certification.”
Yet without the hard work of community activists, only a small portion of this PFAS testing would have happened.
It is true that the Water Utility did EPA-required PFAS testing in 2012 and 2015 and found no detections, because they used high detection limits,[8] but in 2017 the Water Utility’s Technical Advisory Committee (TAC) recommended testing five Madison wells for PFAS using lower detection limits (which was not required by EPA). This resulted in the first PFAS detections in two Madison wells.[9] We commend this decision by the TAC.
The above notwithstanding, many discussions and decisions at TAC meetings did not reflect proactivity, attention to current science on PFAS risks, or concern about protecting public health. (I attended and audiotaped all TAC meetings in 2018 and 2019.)
First, some context. In 2018, the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) proposed drinking water guidelines that were lower (more protective) than the EPA’s 70 ppt “health advisory” for PFOA and PFOS issued in 2016. ATSDR’s guidelines were based in part on scientific studies indicating that EPA’s 70 ppt health advisory level doesn’t adequately protect infants. By this point, several states had also proposed or adopted more protective standards; some states, like Vermont, included more PFAS compounds than just PFOA and PFOS in their standards.
Informed by these developments, along with numerous studies and reports we’d reviewed, in 2018, in collaboration with a statewide group of environmental activists, MEJO began advocating for more protective standards, testing an expanded number of PFAS compounds (more than the 12 the Water Utility had been testing), and moving toward regulating PFAS as a class as recommended by Dr. Linda Birnbaum in a testimony before Congress in 2018.
Yet at TAC meetings in 2018 and 2019, TAC members repeatedly dismissed more protective standards proposed by ATSDR and other states, and did not recommend expanded PFAS testing in Madison—at times they did the opposite.[10]
For instance, at the October 9, 2018 TAC meeting, Dr. Henry (Andy) Anderson said the lower proposed ATSDR numbers were not relevant to the Madison PFAS context and advised the Water Utility to stick with the 70 ppt EPA health advisory levels.[11] After the discussion, the TAC recommended reducing testing to once every three years at Wells 15 and 16 (only) for at least 12 PFAS, which many scientists by that point said was not enough. The committee did not recommend testing any other Madison wells.
Troubled by these statements, on November 2, 2018, MEJO leaders and Sue Pastor from the Greater Sandburg Neighborhood Association (in the Well 15 area) met with several city alders and county supervisors, along with city, county, airport, and Water Utility officials. We again asked for expanded PFAS testing. Joe Grande repeated the TAC decision to scale back testing to once every three years. After Grande said he believed that the PFAS levels at Well 15 were likely the “leading edge” of the plume, Alder Baldeh said that given this, it seemed that they should do more, not less, testing—and alders Kemble, Ahrens, and Rummel agreed. Joe said he would do so if directed to by alders or the board.[12]
Following from this meeting, in subsequent weeks we continued to argue for testing of all Madison wells for a broader range of compounds. We shared extensive PFAS information with a local reporter, and the first local news about PFAS in Madison wells was published by the Wisconsin State Journal on Dec. 9, 2018.
Two weeks later, another article quoted my proposal that the Water Utility use methods that can detect 30 PFAS compounds, to “better inform the risks to public health and assure that subsequent decisions are based on the most comprehensive data.” But the Water Utility, at that point, planned to stick with the TAC advice. “Testing that begins in January will probably be able to detect at least 12 of the compounds,” Barrilleaux was quoted in the story.
Realizing that the Water utility wouldn’t do expanded testing without being directed to do so by the Water Utility Board, which wouldn’t happen without pressure from the community, at my request, on January 2, 2019, Sue Pastor asked Alder David Ahrens to put PFAS on the next Water Utility Board meeting on January 29. He asked the WUB chair to do so and she agreed.
So even though the Water Utility and TAC had been discussing PFAS internally for several years, thanks to citizens’ efforts, this was the first time PFAS was on the agenda of an official government decision-making body that allows citizen input (the TAC does not).
Meanwhile, on January 7, 2019, the TAC again discussed PFAS monitoring plans. They decided that Well 16 would be tested once every three years, and Well 15 would be monitored monthly, but no other wells would be tested nor would a broader range of PFAS compounds be included.[13],[14] MEJO board member Jim Powell countered this in a letter to the Wisconsin State Journal on Jan. 9, highlighting the need to test a broader range of PFAS at all wells.
Apparently alders’ pressure, along with community advocacy and resulting media coverage, shifted Utility plans just before the planned January 29 meeting on the number of PFAS compounds that would be tested at Well 15. That day the Wisconsin State Journal reported: “In December the utility said it would probably use a method that can detect at least 12 PFAS compounds in the monthly Well 15 tests but “[a]s citizen groups prepared to ask the Madison Water Utility Board on Tuesday for a more aggressive response… the utility announced it plans to test for at least twice as many toxic compounds as previously announced.”
But the Water Utility still had no plans to test more than two wells for PFAS. MEJO submitted comments for the Jan. 29 meeting asking for expanded testing at all wells, but the meeting was cancelled due to bad weather. We submitted slightly revised comments for the rescheduled meeting on Feb. 5, again requesting expanded testing at all wells, and also for the creation of a public city-county PFAS Task Force so that citizens could have some say in PFAS decisions in the community in the future.[15]
Many other citizens we organized also submitted comments and testified. Responding to the citizen pressure, the board unanimously agreed to direct the Water Utility to test all 23 Madison wells for an expanded number of PFAS and supported the creation of a public PFAS Task Force—as the Wisconsin State Journal reported a couple days later.
In sum, given all the work MEJO and other citizens did to convince alders and then the Water Utility Board to direct the Water Utility to do this expanded testing, is it honest to call this “proactivity” on the part of the Water Utility?
Water Utility’s fear of public alarm overrides transparency
Ms. Barrilleaux’s column also stated that accusing Water Utility officials of not being transparent “is easy, but it’s not honest.”
She’s referring to the Isthmus article’s mention of the Water Utility’s decision to report “present” for well PFAS results instead of the actual numbers in lab reports. As I explained in a previous post after attending the April 15, 2019 TAC meeting where this decision was made, TAC members advised this because they felt the public “wouldn’t understand” the numbers and might become inappropriately concerned if they added up total PFAS levels. So they chose to withhold them.
In other words, this decision was primarily about their fears of public alarm— based on their assumption that the Madison public isn’t intelligent enough to understand the lab numbers and might become to worried about PFAS in their drinking water. This perspective from TAC members is nothing new; at many TAC meetings I attended, committee members expressed concern that the public, if they got wind of the plethora of toxic contaminants in their drinking water, might become overly alarmed.
Sadly, while very worried about not raising public concerns, protecting public health did not appear to be a priority in TAC discussions I witnessed. I saw little to no evidence that TAC members considered preventing PFAS exposures, especially among the most vulnerable people, when advising the Water Utility on what levels of contaminants should be allowed in our drinking water, or where and how often to test for these contaminants.
Moreover, as for the process, TAC meetings are anything but transparent—also reflecting the Water Utility’s and TAC’s concerns about keeping information from the public in order to prevent alarming them. In past years, at the request of TAC members, Water Utility leaders asked a city attorney if they could ban citizens from the meetings altogether, worried that citizen attendees might share what they learn there publicly. Fortunately, the city attorney advised them that this wasn’t legal.
At this point, the public can attend TAC meetings but cannot comment or ask questions, with rare exceptions.[16] TAC meetings agendas are very difficult to find and minutes are posted months after the meetings, in obscure documents posted with board agendas (that all but the most experienced Water Utility attendees wouldn’t have any idea how to find). Clearly the Water Utility and TAC do not want input from the public at these meetings; they would rather not have public attending them at all.
Ms. Barrilleaux called the Isthmus—and indirectly, those of us who called out these problems—“not honest” for saying the Water Utility was not transparent. Why is it dishonest to point out that keeping full contaminant data from the public, and working to prevent public attendance and input at meetings, aren’t transparent?
Postscript: After submitting the final PFAS report (based on the expanded testing we advocated for), in October 2019 Joe Grande recommended reducing PFAS testing in 2020 at all wells to “at least once a year.” At that time, community advocates were exhausted and overwhelmed with other issues, and didn’t have the time or energy to question or oppose this. I attended the October meeting and argued for more frequent testing, but my comments were dismissed.
Alder David Ahrens, who had helped the community push for more aggressive testing, was no longer on the Water Utility Board, having left the Common Council. The board approved this testing plan with no opposition or questions.
What happened in 2019, and my many years of experience with the Water Utility before that, provide abundant evidence that if citizens don’t constantly push, question, send information, etc., neither the Water Utility Board nor the Utility will be proactive on toxic contaminant issues.
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[1] Minnesota is the only state other than Texas that has set standards for this compound, because there are few scientific studies on which to base standards at this point.
[2] The Water Utility, which sells water to Madison residents, has an obvious bias toward claiming its water is safe no matter what type or levels of contaminants are found there. The assurance that all the levels of PFAS in Madison’s wells are safe defies current science (some of which the Isthmus reported).
[3] Minnesota Department of Public Health
[4] U.S. Agency for Toxic Substances and Disease Registry
[5] PFBA is also a breakdown product of other PFAS compounds, and of stain-and great-proof coatings on food packaging, couches, and carpets, including Stainmaster.
[6] Most standards pertaining to chemicals’ toxicity, and the science behind them, are also heavily influenced by powerful corporate lobbyists who want standards to be as lax as possible. Firstly, these corporations work to keep the chemicals they are producing as trade secrets as long as possible, so scientists cannot study them. By the time these secret chemicals are known by government and scientists, they have been on the market, in the environment and people’s bodies, for a long time. It is also well known that chemical companies and corporations fund science that finds that chemicals are less or non-toxic—and this science then is used to support less protective standards. What industrial and/or chemical industry interests are lobbying to keep PFBA standards as high (unprotective) as possible? The giant corporation 3M produced PFBA in the past. It would be to their advantage to keep PFBA standards remain as high as possible, since PFBA has spread in huge underground plumes in Minnesota, and the lower the standards are, the more likely it will be that 3M will have to pay to clean it up. We don’t know if 3M is influencing the PFBA standards, but it seems likely.
[7] For more detailed information, also see this report.
[8] Testing required under EPA’s Unregulated Contaminated Monitoring Rule or UCMR
[9] Analytical methods were becoming more sensitive, and TAC members with lab analytical backgrounds knew this. Several work at the University of Wisconsin State Lab of Hygiene, which analyzes contaminants in soils, groundwater, other media for public and citizen clients and had been analyzing PFAS compounds for many years before 2017 (as early as 2006 if not earlier).
[10] In spring 2019 the TAC dismissed, and even ridiculed, Vermont’s standard of 20 ppt for five PFAS compounds combined as unscientific, while admitting they knew nothing about how the standard was developed.
[11] This was very odd since he told WU Water Quality manager Joe Grande at a previous TAC meeting that these EPA guidelines would likely decrease by at least 50% in the future.
[12] MEJO audiotaped this meeting.
[13] The testing, the TAC agreed, would involve the six UCMR3 compounds “along with variations of additional PFAS compounds”—not the 24-30 PFAS compounds (at least) we thought should be monitored.
[14] We suspected the sudden shift to monthly testing at Well 15 was a political decision. Monthly testing at just one well seemed like overkill (since past monitoring had already showed that PFAS levels at this well didn’t change much from month to month) and we thought limited resources for PFAS testing should be spread out among all the wells.
[15] This Task Force was quashed by the end of 2019. See some of the sad saga of what happened here.
[16] E.G., recently the DHS presented to the TAC on how they came up with their proposed PFAS standards. At this meeting, public attendees were allowed by the DHS presenter to ask questions. However, at regular TAC meetings the public is not allowed to comment or ask questions.
