RE: Recent Policy Statement from American Academy of Pediatrics Council on Environmental Health Concerning Perchlorate Regulation

June 4, 2014 – The Perchlorate Information Bureau (PIB) agrees with the recommendation from the American Academy of Pediatrics Council on Environmental Health (AAP) that the U.S. “Environmental Protection Agency (EPA) should proceed with appropriate (emphasis added) regulation” of perchlorate in drinking water and emphasizes that the best available science should guide this process.

More than 60 years of research and a 2005 National Academy of Sciences (NAS) report determined that disruption of the thyroid gland can only occur at levels of perchlorate thousands of times higher than levels commonly found in the environment. Partially due to its use as a medicine, the way perchlorate acts in the body is well understood, and the fundamental science of perchlorate’s health effects has been documented.

Based on that fact of the perchlorate research and EPA’s own studies of perchlorate in drinking water, perchlorate does not meet the statutory criteria established under the Safe Drinking Water Act to justify additional regulation of perchlorate beyond what many states and existing cleanup agreements have already established. Specifically, at environmental levels, perchlorate does not cause an adverse effect on human health, nor is it present at a frequency or level that creates a public health concern.

  • NAS identified a No Observable Effect Level (NOEL) for perchlorate that is equivalent to 245 parts per billion (ppb) in water. Below this level, perchlorate has no measureable effect on human health.
  • A 2005 study analyzed the occurrence of perchlorate in water across the country. The study tested more than 34,000 water samples, and in more than 99 percent of the samples where perchlorate was detected, it occurred at levels nearly 40 times lower than the NOEL identified by NAS.
  • More than six decades of research has determined the low levels of perchlorate found in drinking water systems do not present a public health concern.
  • Several studies (EPA OIG (2010), Tarone et al. (2010), Bruce et al., (2013) have determined that perchlorate accounts for less than 2% of the inhibition of iodide uptake in the thyroid resulting from environmental exposure to perchlorate, nitrate and thiocyanate in food and water. Both nitrate and thiocyanate were also addressed by AAP in its statement.
  • EPA’s own Office of the Inspector General (OIG) concluded on April 10, 2010 that “EPA’s interim perchlorate health advisory of 15 μg/L (micrograms per liter – equivalent to parts per billion) provides for an ample margin of safety to protect against adverse effects in humans” and “protects against all human biological effects from exposure.” Because of this, the OIG went on to say that “potentially implementing a perchlorate regulation below 15 μg/L does not decrease the occurrence of adverse effects in the public.”

Finally, it is important to recognize that an EPA decision not to regulate perchlorate would not mean that there is no regulatory action being taken on the compound. EPA has already released an interim Health Advisory of 15 ppb, based on the findings of the NAS panel and more recent FDA studies. Individual states also retain the authority to regulate perchlorate in drinking water and have taken a range of protective actions.

Please visit www.perchlorateinfo.org for factual information on perchlorate, or contact Bill Romanelli at 916-448-3152 or 916-212-1446 (cell).