Comments of Olga V. Naidenko, Ph.D. EWG Senior Scientist Before the New York City Council Committee on Environmental Protection
Hearing on the testing by the Department of Environmental Protection for the presence of pharmaceuticals and personal care products in the NYC drinking water supply
Tuesday, October 27, 2009
Mr. Chairman and distinguished Members of the Committee: My name is Olga Naidenko, and I am a Senior Scientist at Environmental Working Group (EWG), a nonprofit research and advocacy organization based in Washington, DC; Ames, Iowa; and Oakland, California. We focus much of our research on potential health risks from chemical contamination of food, water, consumer products and the environment.
With this testimony, we express our strong support for the proposed law to amend the administrative code of the city of New York that would require testing by the Department of Environmental Protection for the presence of pharmaceuticals and personal care products in the New York City drinking water supply and the effluent from wastewater treatment plants. We commend the Council for considering this important measure that will serve as an essential step toward protecting public health from potential adverse effects of life-long, cumulative exposure to mixtures of multiple pharmaceuticals and endocrine disrupting chemicals in drinking water.
The presence of hundreds of unregulated pharmaceuticals and other synthetic chemicals in the nation’s surface, ground, waste and drinking water has been documented in studies done by the U.S. Geological Survey, U.S. Environmental Protection Agency (U.S. EPA) and water utilities. Research demonstrates that although individual pharmaceuticals occur at relatively low levels, conventional wastewater treatment does not effectively remove them. This is cause for concern and a call for timely action.
Below, we highlight three key areas of concern around pharmaceuticals in drinking water:
- The full spectrum of pharmaceuticals and related contaminants in the New York City drinking water supply is currently unknown; this gap must be urgently addressed by systematic, long-term water quality monitoring;
- The results of the testing must be fully disclosed in order to maintain the public’s confidence in the health and safety of their drinking water;
- The development of appropriate, economically feasible plans for the protection of drinking water and for ensuring the healthy survival of aquatic life requires a robust dataset on the occurrence of pharmaceutical contaminants in water sources.
Below we address these points in detail.
1. The full spectrum of pharmaceuticals and related contaminants in the New York City drinking water supply is currently unknown; this gap must be urgently addressed by annual water quality monitoring.
The Associated Press investigation ("AP Probe Finds Drugs in Drinking Water," March 9, 2008) brought to the attention of the public what the scientific literature has been documenting for a decade – our waters are polluted with a mixture of synthetic chemicals that have been designed to have powerful effects at very low concentrations. Of especial concern are human and veterinary medicines such as steroids, antibiotics, anti-depressants and hormones, which find their way into wastewater due to pharmaceuticals excreted by the body; disposal of unused drugs; farm fields treated with biosolids (sewage sludge); manure from animals fed antibiotics that is used as fertilizer; and industrial discharge from pharmaceutical manufacturing (AP (Associated Press) 2008).
There are no federal or state standards or monitoring requirements for the vast majority of these contaminants in drinking water or wastewater. While the health effects of these pharmaceuticals at therapeutic doses are relatively well-known, their ecological and public health impacts, especially their side effects and potential for synergism with other pollutants, remain to be addressed and cannot be dismissed (Jones 2003; Pringle 2008).
Some studies have suggested that for individual pharmaceuticals, a person would have to drink hundreds of gallons of water to get anywhere near a medical dose (Caldwell 2009; Snyder 2008). However, no study has so far addressed the cumulative human health risk posed by the mixtures of pharmaceuticals that we may ingest on a daily basis (Benotti M.J. 2009; Focazio 2008; Kingsbury 2008; Kolpin 2002). Meanwhile, according to the U.S. EPA, many drug classes of concern are found in the nation’s water sources, including (U.S. EPA 2009b):
- Antibiotics and antimicrobials that may lead to the development of drug-resistant bacteria;
- Estrogenic steroids that may affect the reproductive system in wildlife and people;
- Antidepressants and calcium-channel blockers, which have been associated with effects on spawning in shellfish and "dramatic inhibition of sperm activity in certain aquatic organisms" (U.S. EPA 2009b);
- Antiepileptic drugs such as phenytoin, valproate, carbamazepine that may act as human neuroteratogens and trigger cell death in the developing brain, which leads to neurodegeneration.
- Genotoxic drugs that are primarily used at hospitals and have a high acute toxicity.
Scientists do not yet understand what impact all of these water pollutants will have on human and environmental health.
The presence of pharmaceuticals in the nation’s waters highlights the challenges we face from severe flaws in the nation’s current regulatory framework for water protection. The first step to address these challenges is to find out what pharmaceuticals and personal care products are actually found in the New York City drinking water supply. We strongly support the proposed law that would mandate annual water quality monitoring for the presence of pharmaceuticals and personal care products in treated wastewater discharged from the city’s wastewater treatment plants and in drinking water, including sampling at drinking water treatment plants serving the city, at monitoring wells for underground aquifers and at distribution sites of drinking water.
With this law, New York will be able to devise a science-based policy by collecting real data on the occurrence of pharmaceuticals in drinking water sources and developing the necessary information for any mitigation steps that may be needed to avoid the risks to people and the environment.
2. The results of the testing must be fully disclosed in order to maintain the public’s confidence in the health and safety of their drinking water.
Up to now, New York City residents have been fortunate to enjoy some of the best drinking water in the world, well known for its purity and good taste. Yet, both water quality and public trust in the water that comes from the tap cannot be taken for granted. In addition to a pro-active testing program, protecting public confidence in the health and safety of drinking water requires transparency about the findings, particularly with respect to pharmaceutical contaminants that usually cannot be seen, tasted or smelled, yet may exert powerful effects on health. Infants and others who are vulnerable may be especially at risk from these involuntary exposures.
Members of the public do not want to wake up in the morning and read about anti-convulsive medication in their tap water. Hundreds of news stories around the country on pharmaceutical contaminants in drinking water clearly indicate the intense interest that all Americans feel about this issue. Snippets of data will not be sufficient to allay these concerns; instead, full disclosure is needed.
Drinking water utilities are supportive of this disclosure. The Association of Metropolitan Water Agencies, an organization of metropolitan drinking water suppliers had made the following statement in March 2008:
"Water utilities should take steps to keep their consumers informed of their efforts to monitor and remove pharmaceuticals from water sources. Just as water utilities need data to make informed decisions, we believe that consumers should have the information they need to make personal health decisions" (Association of Metropolitan Water Agencies 2008).
Because utilities often do not disclose the presence of unregulated contaminants in tap water, and because there is no national, centralized source of information on tap water contamination, Environmental Working Group maintains a National Tap Water Quality database where people can find out what urban, industrial, or agricultural pollutants may be present in their drinking water (EWG 2005). The water quality testing data in our database have been obtained from records that state health and environmental departments obtain from drinking water utilities and include tests conducted by utilities for more than 44,000 communities nationwide. The drug residues in tap water join hundreds of other synthetic chemicals Americans are exposed to daily, as contaminants in food, water, air and in common consumer products.
Yet, we only have data on chemicals that are tested for by utilities. Only limited information is available about pharmaceuticals because very few tests are performed and even fewer are disclosed to the public. All of the pharmaceuticals reported in drinking water supplies are unregulated in treated tap water -- any level is legal. Not only have the U.S. EPA and the U.S. Food and Drug Administration failed to set standards for pharmaceuticals in water, but also they have failed to require mandatory testing for these chemicals. This situation needs to be remedied on the federal level (Association of Metropolitan Water Agencies 2008).
According to the research articles published on the subject, there is a large range of concentrations at which pharmaceuticals, personal care product chemicals and endocrine disrupting compounds are present in water; there is also significant variation in the combinations of chemicals that are found at specific locations. Arguments are sometimes made that pharmaceuticals in drinking water pose little human or environmental health risk because they get diluted over the entire water supply (Grumbles 2008). This may be true for the majority of people; yet, people are exposed not to generalized risks but to specific, local risks and this information must be provided to the public.
We strongly support the provision of the proposed law that would require the mayor to submit to the council an annual report on the results of water quality testing. We also urge the city to make these data publicly available via the Department of Environment Protection website. This degree of transparency is essential in order to maintain public confidence in the quality of drinking water.
3. The development of appropriate, economically feasible plans for the protection of the drinking water and for ensuring the survival and thriving of aquatic life requires a robust dataset on the occurrence of pharmaceutical contaminants in water sources.
The occurrence of pharmaceuticals in the nation’s waters is a complex problem and requires a comprehensive multi-faceted response by policy makers, drinking water- and wastewater utilities, pharmaceutical industry, scientists and individual citizens. No individual group can solve the problem single-handedly. Moreover, they are all united by one common need: need for data.
Traditional wastewater systems are designed to treat microorganisms and nutrients, not pharmaceuticals and other synthetic compounds found in the studies across the country. Advanced treatments such as ozonation, granulated activated carbon, UV treatment and advance oxidation process can remove significant amounts of pharmaceuticals but are expensive (Benotti M. J. 2009; Gerrity 2009; Rossner 2009). Ozonation can remove many pharmaceuticals (Broseus 2009) but it is associated with the production of toxic byproducts (Stalter 2009). Activated carbon filtration and other absorbents may be a good alternative treatment (Rossner 2009), although the costs tend to be higher (Joss 2008).
To resolve these challenges, several water utilities in the US and a number of groups in Europe are actively involved in researching wastewater treatments that can remove pharmaceuticals (Gunnarsson 2009; Joss 2008; Radjenovic 2008; Southern Nevada Water Authority 2008). In order to make the treatment process as cost-effective as possible, we have to know what pharmaceuticals are most commonly found in water sources; which ones of them pose the greatest health risks; where they primarily released; how they are transported through the water supply; and what treatments are most effective in removing individual contaminants. There is a great need for research on treatment technology upgrades that industrial dischargers, large urban dischargers such as hospitals and nursing homes, wastewater systems and drinking water utilities can use to remove drugs from water (Pringle 2008).
It is also important to look at the risks posed by pharmaceutical pollutants to the aquatic life and thus, indirectly, to people. Studies by the U.S. EPA and academic scientists found that pharmaceuticals and personal care product chemicals can and do accumulate in fish and other aquatic animals (Brooks 2005; Chu 2007; U.S. EPA 2009c). In a recently published study, EPA researchers detected a range of pollutants in fish: diphenylhydramine (antihistamine); norfluoxetine and sertraline (antidepressants); other pharmaceuticals as well as galaxolide and tonalide, synthetic fragrances frequently added to personal care products (Ramirez 2009). These studies were of sufficient concern to the EPA, prompting the Agency to embark on a national survey of pharmaceuticals in 150 randomly-selected urban river sites across the country (U.S. EPA 2009a).
We do not know what would be the human health outcome of cumulative exposure to pharmaceuticals in water and in fish for people who are active in recreational fishing, a common pastime for many people who live in New York City and its suburbs. Exposure to toxic levels of water contaminants that accumulate in fish is a well-recognized public health problem for pollutants such as polychlorinated biphenyls (PCBs) and mercury (Fitzgerald 2007)
In order to forestall any potential human health problems due to pharmaceuticals in fish, it would be highly desirable to monitor the potential effects of pharmaceutical pollution on aquatic life and to ensure that these contaminants would not pose an adverse impact on aquatic ecosystems (Batt 2008; Molander 2009; Swedish Foundation for Strategic Environmental Research (Mistra) 2009). Aquatic species often serve as sentinels for human health (Kostich 2008). For example, it would take a lot of estrogen to cause an acute health effect. In contrast, low-level, chronic exposure to estrogenic pollutants in water has been associated with health effects as severe as gender change, such as feminization of male fish (Caldwell 2008; Tyler 2009). Clearly, this is not the type of severe change that we would be willing to accept with respect to human health.
By ensuring that the levels of pharmaceutical pollutants are safe for aquatic life, we will make a significant investment in the protection of human health as well, a key decision that will be greatly appreciated by our own children.
Ultimately, we would need to capture as much pollution as we can at the source by implementing pollution prevention and protection of water supplies (American Water Works Association (AWWA) 2008; Association of Metropolitan Water Agencies 2008). The options may include environmentally friendly design of the waste stream, labeling of pharmaceuticals according to their proper disposal strategies, support for proper pharmaceutical disposal programs and treatment of significant point sources of pharmaceutical discharge into the wastewater (Association of Metropolitan Water Agencies 2008; Joss 2008; Pringle 2008; Snyder 2008). These programs should be implemented in parallel with water quality testing and development of additional treatment infrastructure at wastewater plants.
We all know that bottled water is not a solution to concerns about pharmaceuticals in tap water: bottled water is much more expensive; it is drawn largely from the same sources as public tap water supplies; and it is associated with immense amounts of plastic waste (EWG 2008). Yet, for the public to not turn to bottled water, we need to focus on pollution prevention, data collection and disclosure and developing appropriate mitigation treatments.
Environmental Working Group congratulates the City Council for moving forward with this important legislation and we are glad to be of any assistance in accomplishing this task.
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