Enclosed are my comments on your approaches for deriving HRLs on Perchlorates and other chemicals in our drinking water.
4.
a. No, I do not feel EPA appropriately took into account specific and appropriate exposure values for all potentially sensitive life stages, including infants, children and the fetuses of pregnant women. Any exposure to these type of chemicals should be eliminated and controlled to protect Americas' drinking waters. The 70 kg body weight and 2 liter per day consumption used for past regulatory determinations are grossly inappropriate levels to consider safe.
b. I feel none of these these values are low enough to be appropriate levels to determine health concerns against which to compare the levels of perchlorates found in public water systems. I urge you to adopt the smallest exposer levels considered or preferably lower them to no (0) exposure at all.
c. I feel the EPA did not use the best available and most appropriate data to estimate alternative HRLs in Table 2 because you cannot control how much water any one person consumes or the amount of perchlorate exposure from other sources. No, your drinking water ingestion rates in Table 2 do not take into account the life stages (birth to 6 months, and women ages 15–44) and does not provide an accurate representation of the exposure to the most vulnerable life stages because you cannot control how much water any one person consumes or the amount of perchlorate exposure from other sources.?
d. EPA should regulate all exposures from these types of chemicals as we know little about the harm they cause when exposed to or mixed with different medicines or the multiple other chemicals in our bodies or in individual water systems.
Because there is not enough data about our exposures to these chemical "soups" to assure protection for the American people and until there is more data assuring our safety from mixing perchlorates with other drugs and chemicals, EPA should aim to control all exposure.
Comment submitted by W. Cucinotta
This is comment on Notice
Drinking Water: Perchlorate Supplemental Request for Comments
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