Applying a culture of health to unregulated contaminants
Welcome to the new Aqua Talk blog! Let's dive right in and discuss an important issue...In the third Aqua Talk issue of 2018 I wrote about establishing a culture of health across the entire community of people involved with providing safe drinking water to the public, including state and local health departments, public water system owners, operators and utility staff. But how do we apply a culture of health when it comes to unregulated contaminants?
Regulations have their pluses and minuses, but one of the benefits we get from regulated contaminants under the Safe Drinking Water Act is a sort of play book or recipe regarding how to address them. Specifically, for regulated contaminants the sample locations, frequencies, lab methods, maximum contaminant level (MCL), compliance determination method, e.g. annual average, best available treatment technologies, etc. are all spelled out so we have a guide to follow so that we can protect public health. That specific approach does not exist when it comes to unregulated contaminants.
Are we on our own to figure things out?
It might be easy to answer yes to the above question. However, I would like to point out that when issues with unregulated contaminants have arisen in Colorado, the Safe Drinking Water Program has formed strong partnerships with EPA, the local health department, the involved water systems and their personnel and others to do our collective best to deal with the situation. It is still quite difficult and involves public communication. Together these partners have not completely solved the problems, but we have put funding toward additional sampling to understand the issue, and have taken steps to reduce public exposure – thereby helping protect public health.Remember, the public does not place as heavy an emphasis on regulated versus unregulated contaminants. Safety is paramount. So the answer is that partners engage to understand and address the problems as quickly and as best they can while providing information to the public.
PFAS, Legionella, manganese and cyanotoxins
The main unregulated contaminants that we are concerned about include per- and polyfluoro alkyl substances (PFAS), Legionella, manganese and cyanotoxins. The department does not have sufficient resources to provide comprehensive and proactive services to help water systems with these contaminants but we are staying connected to or participating in national efforts involving them and will help water systems to address problems if they arise. Manganese and cyanotoxins are part of EPA’s fourth Unregulated Monitoring Contaminant Rule (UCMR4) and are currently being tested by numerous water systems around Colorado.We are working closely with EPA to monitor results and inform water systems if we see potential problems with UCMR4 contaminants. It is important for water systems to realize that there are required actions when contaminants are detected under UCMR4 including reporting detections in the next Consumer Confidence Report (CCR). The department also recommends that water systems seek to understand more about these contaminants if detected above a health reference concentration and work with the department to assess risk and respond if needed.
For cyanotoxins, we plan to continue working with our partners to implement Colorado’s guidance for drinking water and recreational water bodies. In late 2020 as resources permit we hope to be able to work with water systems and building and health facility owners to develop guidance or best practices regarding Legionella. For PFAS, we will be working with interested water utilities to develop a response toolbox and working to incorporate consideration of potential PFAS contamination sources into source water protection planning.
The department is also reaching out to facilities that could be a source of PFAS contamination including airports, fire training areas, and industrial and manufacturing facilities that may have used or produced PFAS-containing products. Based upon what we learn, we will prepare an inventory of those facilities with high potential for PFAS releases across the state. We will also identify public drinking water systems near these locations to better understand the scope of PFAS impacts on drinking water systems. This effort will take considerable time and resources.
More problems with unregulated drinking water contaminants are likely to be found. By working together we can provide a credible response that stems from our culture of health.
➽ Ron Falco, safe drinking water program manager
