Coalition Letter on Proposed Public Health Goals for Trihalomethanes in Drinking Water

  • Jan 8, 2019
  • Comment Letters

Agency: Office of Environmental Health Hazard Assessment

Subject: Proposed Public Health Goals for Trihalomethanes in Drinking Water

Letter excerpt: 

The Association of California Water Agencies, the California Water Association, the California Municipal Utilities Association, the Southern California Water Coalition, and the California – Nevada Section of the American Water Works Association appreciate your receipt of our coalition letter dated November 15, 2018 and the extension of the public comment period regarding the release of the draft technical support document (TSD) for the proposed Public Health Goals (PHGs) for trihalomethanes (THMs) by the Office of Environmental Health Hazard Assessment (OEHHA). This release is of tremendous interest to the drinking water community in California. The effective treatment and distribution of water for safe use is one of the greatest advancements of the last century and is an essential public health protection. Drinking water disinfection is the first and most important line of defense in this process – it protects water users from pathogens in organic matter that can cause disease and death.

As our industry has indicated in discussions with OEHHA staff dating back to 2010, the
establishment of individual PHGs for each of the four regulated THM constituents would be a
major departure from the current risk management approach in California involving regulation of total THMs. OEHHA’s proposed PHGs place too much emphasis on reducing incremental cancer risks from exposure to THMs that other authoritative bodies have established are minor in comparison to the health risks posed by inadequate drinking water disinfection. To the extent they result in new drinking water standards that force changes to effective drinking water disinfection practices, the proposed PHGs could have unintended consequences for public health.

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