PEER proposes a three-step approach to Pharma Pollution: Prevention, Protection and Preparedness
1. Prevention. The most effective approach is to prevent the introduction of these chemicals into our water supply. While Dont Flush public education programs are laudable, these efforts are inadequate in that 1) disposal in wastefills does not prevent these chemicals from leeching into water supplies; 2) much of the chemical introduction comes from un-metabolized drugs in human and animal excretion; and 3) a number of the chemicals in shampoos and other personal care products are washed down drains.We are advocating comprehensive policy changes that are designed to keep PPCPs out of drinking water:
- Safe Disposal. We propose fostering collection of chemicals by local police departments or emergency services. Just as cities carry out special collection days for household hazardous wastes, the public needs safe and convenient disposal alternatives. To some extent, PPCPs need to be treated as household hazardous wastes.
- Siting of Hospitals and Care Facilities. Currently, PPCP-discharge is not considered in choosing sites for facilities. Facilities, such as hospitals and nursing homes, which will discharge highly concentrated streams of PPCPs need to be located away from drinking water sources and with plans for handling un-metabolized PPCPs.
- Drug Approvals. Currently, the Food and Drug Administration (FDA) does not consider the post-dosage effects of the products that it approves for prescription or OTC sale. FDA does, however, have broad discretion to consider health factors brought to its attention. FDA should begin to formally consider the secondary effects within our water supplies of the products it approves.
2. Protection. The issue of PPCPs and EDCs in our water is not new scientists have been aware of the problem for decades. In 1996, the U.S. Congress directed EPA to screen chemicals for hormonal effects on humans in the Food Quality Protection Act. During the intervening 13 years, EPA has done remarkably little, despite mounting evidence that thousands of chemical compounds are a spreading presence in drinking water:
- EPA is not listing known EDCs on its Contaminant Candidate List of priority contaminants which are anticipated to occur in public water systems. Even if EDCs made this list, however, Contaminant Candidates are still not regulated under federal drinking water regulations;
- Although it has identified more than 87,000 suspected EDCs, it has taken EPA 11 years (July 2007) to publish a list of only 73 chemicals for which it proposes to begin screening; and
- EPA has repeatedly missed statutory deadlines to begin testing and screening for EDCs.
We propose to undertake a series of administrative and legal actions to induce EPA to meet its current statutory responsibilities to screen, classify and regulate these contaminants in drinking water.
3. Preparedness through Research. Research on the issue began in the 1980s, and in 1996, EPAs Office of Research and Development (ORD) identified EDCs as one of its research priorities. Unfortunately, most of the research conducted until 2002 dealt only with assessing the presence of PPCPs and EDCs in wastewater and receiving surface waters such as streams, rivers and lakes.We will engage in advocacy to take the following steps:
- National PPCP Data Base. Coordinating the water monitoring undertaken by USGS, EPA and the states would yield a much more complete picture of the extent and nature of PPCP contamination. This open data set would also aid public health and wildlife researchers in linking effects they are finding to the presence of water-borne chemicals.
- Water Transparency Community Right to Know. Requiring treatment plants to publish the results of EDC testing on their treated water will create a powerful incentive to screen out or neutralize these chemicals.
- Treatment Technologies. More recently, attention has been turned to treatment technologies, and the efficacy of particular removal techniques. These inquiries are still in their infancy because there is no regulatory requirement that EDCs be removed from water supplies. Putting teeth in existing regulations also will spur on treatment technological research that suddenly has more legal and programmatic relevance.