ASBG expresses concern the NHMRC is adopting the PFOS 4 ng/L guideline value recently issued by the US EPA.
The NHMRC’s methodology used includes a 300 fold safety factor in addition to other margins of safety added.
ASBG recommended the HBGVs be reviewed especially given FSANZ’s evidence that on 2% of foods examined show the presence of PFOS.
ASBG supported the use of WHO's approach to PFOA by the NHMRC, as the US EPA uses a non-threshold linear approach.
Consequently, the NHMRC has a PFOA HBGV of 200 ng/L compared to US EPA’s at 4 ng/L.
The NHMRC should also consider the knock-on impacts of setting lower PFAS HBGVs which will become hard limits in many documents.
This will include, soil and groundwater, largely affected by changes to PFAS NEMP 3.0, water limits, sewage acceptance, landfill acceptance and
will impact many wastes especially organic wastes including biosolids, compost etc, waste soils with PFAS, etc.
A submission by the US American Water Works Association, was critical of the US EPA’s science or lack of it, and also showed that increasing the
PFOS & PFOA limits from 4 ng/L to 10 ng/L would reduce drinking water treatment costs by 65%.
Finally ASBG recommended the NHMRC should publish contextual information to place is PFAS HBGVs in comparison with other major harmful substances.
This is to show the assumptions used, full safety margins used – over 300 x- and the concentrations being set in context with other harmful substances.
This will enable the public to balance the PFAS risks with other known risks.
 ASBG's Submission on the NHMRC Review of PFAS in Australian Drinking Water 2024 | 1032 kB |
