Drinking Water Contaminant Candidate List - Draft; Notice of Availability

The International Bottled Water Association (IBWA) supports the EPA's inclusion of PFAS and microplastics on the Draft Sixth Contaminant Candidate List (CCL 6). They advocate for a science-based approach that prioritizes the development of standardized testing methodologies, clear definitions, and collaborative research with the Department of Health and Human Services.

Seaman Paper, a Massachusetts-based paper manufacturing company, supports the EPA's decision to include microplastics as a chemical group on the draft Contaminant Candidate List 6. The company urges the EPA to prioritize research and regulatory action on microplastics while providing a peer-reviewed study on the interactive effects of nanoplastics and PFAS.

The Indiana Department of Environmental Management (IDEM) supports the EPA's draft Contaminant Candidate List 6, noting its value in identifying research priorities for emerging contaminants. However, the agency urges the EPA to prioritize clarity and feasibility, specifically requesting more research on microplastics and more specific criteria for identifying pharmaceuticals to ensure the list is scientifically actionable.

The Consumer Brands Association supports the EPA's proposal to include microplastics on the Drinking Water Contaminant Candidate List 6 (CCL6) as a precautionary step for research. However, the organization emphasizes that the listing is premature for regulatory action and urges the EPA to focus on establishing standardized definitions, analytical methods, and robust scientific evidence regarding health impacts before pursuing any regulations.

The Rural Community Assistance Partnership (RCAP), a non-profit network supporting rural and Tribal communities, supports the EPA's Draft Contaminant Candidate List 6 as a logical approach to identifying contaminants. However, they urge the EPA to adopt a risk-based, phased, and flexible implementation strategy to ensure that the resulting regulations remain affordable and technically feasible for small rural water systems with limited resources.

The National Association of Manufacturers (NAM) opposes the inclusion of overly broad group listings for microplastics and pharmaceuticals on the Drinking Water Contaminant Candidate List 6. They argue that these categories lack clear limiting principles and request that the EPA instead focus on specific, scientifically validated substances and methods to avoid regulatory uncertainty and public confusion.

A coalition of trade associations and industry groups argues that the draft Drinking Water Contaminant Candidate List 6 (CCL 6) is overly broad and lacks sufficient scientific data, specifically regarding chemical groups like PFAS, microplastics, and pharmaceuticals. They request that the EPA adopt a more disciplined, risk-based approach with clear definitions and validated analytical methods before proceeding with these listings.

John Mueller, a retired civil and control systems engineer, argues that sodium fluoride, sodium fluorosilicate, and fluorosilicic acid should be added to the Drinking Water Contaminant Candidate List (CCL-6). He cites a National Research Council study and subsequent research to argue that these substances pose health risks and require more restrictive regulatory limits.

The Texas Chemistry Council, representing 60 chemical manufacturing and research companies, submitted comments regarding the draft Drinking Water Contaminant Candidate List 6. They advocate for the use of robust science methodologies, transparency regarding analytical limitations, and a clear distinction between contaminants requiring further research versus those suitable for nationwide monitoring.

The American Chemistry Council's Bisphenol A North American Team opposes the proposed listing of BPA on the Drinking Water Contaminant Candidate List 6. They argue that the proposed Hazard Quotient (fHQ) is overly conservative, based on a "controversial" European Food Safety Authority (EFSA) opinion, and fails to account for high-quality scientific evidence like the CLARITY-BPA Core Study.