1. MCLs for PFAS should be based on scientific evidence to protect human health and the environment. They should not be relaxed based on economic, commercial or industrial concerns.
2. The health-based values don’t include a total PFAS contamination level similar to the cumulative level that EPA recommends. EGLE needs to put a combined MCL in place for total PFAS.
3. PFAS should be regulated as a class of chemicals. There are over 5000 of them, and placing regulations on some may simply make polluters use other PFAS compounds. Class regulations, or regulations on subclasses would prevent users from making specific compound switches to avoid restrictions.
4. The Health-based values from MPART are an improvement from EPA guidelines, but new information coming from New Hampshire and North Carolina suggests that some of the Michigan HBVs are still way too high for specific chemicals. (Gen X, PFHxS, PFHxSA)