The EPA has released its 2012 water quality criteria recommendations for protecting human health in all coastal and non-coastal recreational waters. This is the first time since the BEACH Act was passed back in 2000 that the EPA has revised their federal water quality standards. These standards are used to make beach management decisions and to determine if a water body meets the health threshold to support swimming, surfing and other primary contact recreational activities.
View the EPA’s fact sheet and criteria document on their website.
These new criteria are the result of scientific research and epidemiological studies performed by the EPA and other researchers looking at the sources of bacteria pollution, testing methods, and the effects of different levels of pollution on the beach-going public.
The new criteria are similar to the current water quality standards, but the EPA has presented multiple options for states to choose from and has recommended changes in implementation.
What are the new criteria?
Option 1: based on an illness rate of approximately 1 in 28 people
Marine & fresh water: 130 c.f.u. Enterococcus per 100 ml water for a single sample
35 c.f.u Enterococcus per 100 ml water, 30 day average
Option 2: based on an illness rate of approximately 1 in 31 people
Marine & fresh water: 110 c.f.u. Enterococcus per 100 ml water, single sample
30 c.f.u Enterococcus per 100 ml water, 30 day average
The EPA has also presented values for use of E. coli at both illness rates for use in freshwater only.
In addition to these criteria, Beach Action Values (BAVs) are proposed as “conservative, precautionary tools” that can be used similarly to a single sample maximum to issue health advisories at beaches. The BAVs for Enterococcus are 70 c.f.u. at the health risk of 1 in 28, and 60 c.f.u for the health risk of 1 in 31. Additionally, states can continue using their current single sample maximum values, i.e. 104 c.f.u. Enteroccoccus.
Here's a graph that summarizes these options:
For beach notification programs the EPA has also approved a rapid testing method that can give same day results. It’s worth noting, however, that EPA only recommends use of this rapid method after thorough ground-truthing on a site-by-site basis, the cost of which will likely prove prohibitive in most instances.
The EPA’s criteria document also recognizes the value of water quality models in many locations by predicting poor water quality as conditions deteriorate and allowing early warnings to be issued to the public. Models have been used very successfully, particularly in the Great Lakes region, for several years now.
The Good News
These final criteria are better than those first proposed by EPA in December 2011. The draft criteria were based solely on the 1 in 28 health risk, allowed an averaging period of up to 90 days which could have masked pollution problems, and even allowed a water body to exceed its single sample maximum 25% of the time before it was considered out of compliance.
These new criteria are also based upon a better scientific understanding of the effects of polluted water on human health coming from several recent epidemiological studies.
We also like the BAVs and early detection methods that, if used, could do more to protect the health of beachgoers.
The Bad News
As the states are left to choose which set of criteria to apply, this will likely result in different standards across the county. The concept of a consistent national standard will no longer exist. Beachgoers will have to determine which standard is being used and whether they feel confident that the standard is adequately protective. The possibility also exists that a state could allow more pollution into its surface waters or at their beaches than a neighboring state.
The range of options also makes the true health risk of exposure to polluted water very difficult to communicate to the general public and even to stakeholders with a clear interest in beach water quality.
If a state decides to use the least protective daily standard of 130 c.f.u. Enterococcus to open and close beaches, we could see communities tolerating more pollution at our beaches than is currently allowed with the current single sample maximum of 104 c.f.u..
Where do we go from here?
The EPA will be holding a webinar in January 2013 to further explain the new criteria to stakeholders. It is likely that the EPA will continue to explain how the criteria are intended to be implemented well into the new year.
As beach advocates, the Surfrider Foundation will track state implementation of these criteria, being particularly vigilant that the water quality at our beaches is at least maintained. We must not allow relaxation of standards that could result in swimming or surfing in dirtier water.
We will also continue to advocate at the federal level for continued funding for beach water testing programs. Without testing, we won't have any information available to us on whether a beach is safe or not, and we will be unable to identify polluted areas that need to be addressed, so that we can solve our beach pollution problems.
If you have any questions about the new EPA water quality criteria, please contact Mara Dias at mdias@surfrider.org or Rick Wilson at rwilson@surfrider.org
Read some other reactions to the new criteria:
http://www.healthebay.org/blogs-news/new-epa-regulations-water-quality-mixed-bag