LDA Michigan Input for Proposed PFAS MCL Standards

Thank you to Tracy Gregoire, LDA America’s Healthy Children Project Coordinator, and the Ecology Center for helping us prepare comments for Michigan’s legislators related to PFAS and its impact on Michigan’s children.

January 31, 2019

Comment to: State of Michigan’s Department of Environment Great Lakes and Energy regarding proposed PFAS MCL standards

Thank you for the opportunity to comment on this proposed rule.  The Learning Disabilities Association of Michigan urges the State of Michigan’s Department of Environment Great Lakes and Energy to reevaluate the recommended values for the maximum contaminant levels (MCLs) of PFAS chemicals permitted under Michigan’s regulatory drinking water standards. We ask that these standards, in order to be truly health protective, take into account the potential impacts of PFAS chemicals on child development.

Approximately 13% of children in the United States have a developmental disability. The CDC now estimates that 1 in 59 children in the United States have an autism spectrum disorder.  The incidence of these types of disabilities is rising every year at an alarming pace, especially for autism and ADHD.

In Michigan, children eligible for special education include 58,509 identified with a Specific Learning Disability (3.73% of all MI school-age students) and 21,550 identified with autism (1.37% of MI students). While ADHD is harder to document, the Center for Health and Research Transformation out of University of Michigan reported in 2013 that approximately 6.3 percent (approximately 17,000 patients) of children aged 4 to 17 living in Michigan had a claim related to ADHD. In addition, the Special Education for Otherwise Health Impaired (OHI) in 2018-2019 children which can include children with ADHD eligible for special education and lead poisoned children had 28,426 students (another 1.81% of children) receiving special education services.

The National Academy of Sciences Committee on Developmental Toxicology, estimates that at least 28% of developmental defects are caused in whole or part by environmental exposures to toxic chemicals.  These are PREVENTABLE causes of these disabilities.

Per- and polyfluoralkyl substances, also known as PFAS chemicals, are man-made chemicals that are found in our food, water, air and products. They are used to make products more resistant to stains, grease and water.  There are nearly 5000 PFAS chemicals and they are used in many products including food containers, electronics, cleaning products, textiles, and some firefighting foams.

The proposed standards do not adequately consider the impact of PFAS on the most vulnerable populations in our state. In particular, PFAS pose significant health risks for pregnant women and children. PFAS are nicknamed “forever chemicals” because they are bio accumulative and don’t break down (also known as PBT chemicals – Persistent, Bioaccumulative and Toxic). There is widespread human exposure and can stay in our bodies for years. They are such a concern that the EPA has set a lifetime health advisory level for a few of these chemicals.

People are exposed to PFAS through contaminated food, water and air, from products containing these chemicals, and worker related exposures. PFAS are linked to many health concerns including certain types of cancer, disrupting the immune system including poor response to vaccines[1], impaired liver function, high cholesterol, preeclampsia (potentially fatal pregnancy complication with high blood pressure), and birth defects.

Of particular concern for the LDA of MI are the developmental effects of in utero exposure to Hexafluoropropylene oxide dimer acid (HFPO-DA) which has been associated with negative developmental effects, Perfluorobutane sulfonic acid (PFBS) associated thyroid hormone disruption,  Perfluorononanoic acid (PFNA) and Perfluorooctane sulfonic acid (PFOS) both with links to  developmental delays, decreased body weight gain, and Perfluorooctanoic acid (PFOA) and it’s associate with neurodevelopmental effects.

Studies of the above chemicals have linked PFAS to impaired fetal development as well as interfering with the thyroid and low birth weight, which can then affect children’s brains. The CDC states that some studies in people have shown certain PFAS chemicals may affect “learning, and behavior of infants and older children”.

In addition, scientific studies have shown the effects of PFAS chemicals on mammary gland development, harming both children and their mothers. Lab tests show that mammary glands have a low-dose sensitivity to PFOA. In the proposed Michigan standard for PFOA, mammary gland development was not considered as a health end point. Mammary gland development is critical to the ability of mothers being able to breastfeed, and support healthy child development.

Biomonitoring studies have shown that nearly every person in the US, including newborns, have PFAS in their bloodstream. Drinking water and other dietary sources are considered to be the largest exposure pathway to PFAS.

To tackle contamination by PFAS that are harming our families, the state must first set MCLs that are truly health protective, taking into account the most sensitive health end points, cumulative exposure to more than one of the seven PFAS considered here at a time, and synergistic harmful effects of PFAS with other chemicals that can harm brain development. The proposed levels are too high and will not protect pregnant women or children.

On behalf of Michigan children, Learning Disabilities Association urges this committee to consider the most vulnerable populations and most sensitive health end points for each chemical, consider cumulative exposures to these chemicals, and use the best available science to set and periodically evaluate these standards. In doing this, Michigan can better protect all families from unnecessary harmful chemicals such as PFAS.


Learning Disabilities Association of Michigan

Healthy Children Project Coordinator