What's in the Water? Lesson 6: Drinking Water Quality Regulation in the U.S.
In the sixth lesson of the "What's in the Water?" PFAS Contamination Unit", students learn about how drinking water quality and PFAS are regulated at the federal and state levels in the U.S. and within the E.U. to explore different approaches to the question of regulation. Using their knowledge from all the prior lessons in the unit, students will discuss benefits and challenges of PFAS regulation at different levels of the government, and contrast the likely outcomes of proactive vs. retroactive regulatory approaches. Finally, student groups take on the roles of various constituencies, and evaluate the current regulatory paradigm through the lens of that population.
This activity has been used in an introductory-level university course in environmental science that enrolls both majors and non-majors, as well as a summer intensive science course for high school students, both in North Carolina where the unit is set. It could easily be adapted to other locations where PFAS contamination is present, as well as to geology or biology courses.
Skills and concepts that students must have mastered
This lesson draws upon the knowledge and skills students have mastered throughout the prior five lessons. For example, knowledge of watersheds (both urban and geographic) and the fact that they often transcend political boundaries is crucial to helping students understand PFAS regulatory challenges at the local and state levels. Knowledge of the state of medical research on PFAS and the challenges of clearly establishing causal relationships between a particular chemical and a specific human health outcome helps students understand how the current regulatory paradigm is set up in a way that minimizes its ability to protect citizens. Finally, knowledge of environmental justice and how race and class shape power and access in the U.S. allows students to critically evaluate impacts of the current regulatory paradigm on different constituencies.
How the activity is situated in the course
This is the sixth instructional lesson of the "What's in the Water?" PFAS Contamination Unit". Prior to this lesson, students will have been introduced to the unit-long community-engaged project, met the community partners to understand the local PFAS contamination situation and the community partner's needs, and completed the Benchmarking Activity to take stock of their prior knowledge of water and water contamination. In Lesson 1 they learned about the natural and urban water cycles, focusing on PFAS contamination and how it cycles through the environment. In Lesson 2, students compared and contrasted emerging and established contaminants, and learned about the PFAS family of chemicals and their history. Lesson 3 took students through an analysis of remediation options for the local water contamination crisis. In Lesson 4, students read about and analyzed data visualizations related to environmental justice in the U.S., including issues of access and cost. In Lesson 5, students learned about human and animal studies of PFAS chemicals and their impacts on various health outcomes. Finally, in this lesson students learn about existing regulatory approaches to drinking water quality and contamination in the U.S., discuss the benefits and drawbacks of that approach for different stakeholders, and envision possible alternative approaches and advocacy routes that might lead to solutions to Pittsboro's drinking water crisis.
Content/concepts goals for this activity
- Students will be able to describe the current EPA process for water quality regulation and regulation of PFAS in particular.
Higher order thinking skills goals for this activity
- Compare and contrast PFAS regulation at the U.S. federal level with that in various U.S. states, the E.U., and Canada.
- Identify the benefits and drawbacks of water quality regulation at the state, local, and national levels.
- Analyze the impacts of proactive vs. retroactive regulatory paradigms on different stakeholder groups.
Other skills goals for this activity
Description and Teaching Materials
In this lesson, students examine the PFAS contamination crisis in Pittsboro through the lens of regulatory frameworks and existing advocacy efforts to understand how the situation came to be and how it might reach a positive resolution for the citizens:
- How is drinking water contamination regulated in the U.S.? At the national, state, and local levels?
- What alternative approaches might be possible?
- Who benefits most from different approaches to regulation, and how? Who suffers?
As the final lesson before end-of-unit Community-Engaged Projects are due, this lesson also offers an opportunity for synthesis of the many topics that have been explored. Throughout the activities, the instructor should ask students to reconsider and connect their assertions about regulation at various levels to concepts explored in earlier lessons in the unit.
Before class, students review the EPA regulation process and write about their initial reactions to that process (guided by several questions included in the Lesson 6 pre-class homework). This lays the groundwork for a preliminary discussion in class, in which the instructor can encourage students to dig a bit deeper and question their assumptions and reasoning.
In-Class Homework Debrief
We recommend setting up a poll using Mentimeter, PollEverywhere, or other software to ask the question, "After reviewing the way the EPA approaches drinking water contaminant regulation, how safe do you feel drinking the tap water in your home or dorm?" (safe, unsafe, not sure). After students respond to the poll, ask individuals to explain their reasoning, or what they noticed in the EPA website that led them to their conclusion. After students share out their initial reactions to the regulations, you can begin to shift gears, asking students how they think the process came to be, or what influences are centered (science, convenience for government regulators, convenience or profit for corporations inventing new potential emerging contaminants, etc.). Ultimately, ask students to explain the connection between this regulatory paradigm and the PFAS crisis being experienced in your community. This will likely lead students to begin asking what other regulatory approaches are possible.
Small Group Activity #1
In the first small group activity of the day, each group is assigned to review the PFAS regulations established by a U.S. state, the European Union, or Canada. Students summarize the approach and/or outcomes of that regulatory process and report back to the class, lending diversity and nuance to students' understanding of what regulation of PFAS could look like. As each group presents out, you might prompt them to consider, would your local PFAS crisis be the same if this approach were in place? How might it be improved, worsened, or just made different as a result?
Whole Class Discussion
To help students synthesize their findings and integrate ideas from prior lessons in the unit, the instructor should guide the whole class in a discussion aimed at filling out the table exploring the benefits and drawbacks of PFAS (or other emerging contaminant) regulation at the county, state, and federal levels. Ask students questions like, how large are watersheds, and what does that mean for regulatory processes? How many studies are needed to determine a clear link between contaminant exposure and human health, and how much money, time, and expertise (or other resources) would be necessary? Who will pay for regulators, tests, and other necessary infrastructure for regulation at this level, and how will that financial burden be distributed and experienced by individuals and organizations at this level? We found that students were relatively simplistic in their approach, determining that local regulation was better since power would be held locally, without recognizing geographic, financial, and equity concerns that might pose challenges to this approach.
Small Group Activity #2
The second small group activity guides students to consider the ramifications of a proactive vs. a retroactive regulatory approach for different stakeholders. The EPA uses a fundamentally retroactive approach, investigating and potentially regulating chemicals already used in industry only if they are determined to be harmful. A proactive approach, by contrast, would require industries to demonstrate the safety of new chemicals prior to being allowed to utilize them in their products and processes. In this activity, each team takes on the perspective of one constituency: the federal government, state governments, local governments, large corporations, small businesses, upper-class citizens, middle-class citizens, and working-class citizens. Each team attempts to compare and contrast the benefits and drawbacks of each regulatory approach for their constituency, and shares out their thinking briefly at the end of class. If possible, end class with a poll- which approach to regulation (proactive vs. retroactive) would you prefer?
Lesson 6 Class Plan and Timeline (Microsoft Word 2007 (.docx) 8kB Jan19 22)
Lesson 6 Pre-Class Homework (Microsoft Word 2007 (.docx) 8kB Jan19 22)
Lesson 6 Instructor Slides (PowerPoint 2007 (.pptx) 226kB Jan19 22)
Teaching Notes and Tips
It may be helpful for instructors to be familiar with other perspectives on the EPA's regulatory process, such as those crafted by non-profit organizations such as the Environmental Working Group, linked in the resources section below.
Based on our review of end-of-unit Benchmarking Activity responses, it seems that many students landed on the idea that bottled water is a better alternative after this lesson. We recommend directly addressing this potential misconception, including informing students that bottled water safety regulations are even more problematic, that bottled water often comes from a tap somewhere else, and that plastic water bottles contribute substantially to other important environmental problems (plastic pollution in the oceans, for example, seems to resonate strongly with our students).
As an optional homework assignment, you might ask students to write a brief paragraph justifying their response to the end-of-class poll on which regulatory approach they prefer. Prompting them to consider what they have learned throughout the unit may help guide them to develop more sophisticated rationales.
Assessment within the lesson is formative. As individuals and groups share out, the instructor can gauge understanding and ask questions to help students develop more complex and nuanced ways of considering the problem of regulation. Encouraging students to integrate or reconsider ideas in light of previous lessons within the unit can also help to reveal what knowledge they have retained, and help them build a more robust knowledge network around those prior concepts.
Ultimately, new or revised understandings from all lessons in the unit should be reflected by student answers to the Benchmarking Activity completed at the conclusion of the unit, which can be used for summative assessment purposes.
References and Resources
Resources for student work:
- How EPA Regulates Drinking Water Contaminants: https://www.epa.gov/sdwa/how-epa-regulates-drinking-water-contaminants
- EPA Actions to Address PFAS: https://www.epa.gov/pfas/epa-actions-address-pfas
- U.S. State Resources about PFAS: https://www.epa.gov/pfas/us-state-resources-about-pfas
- Portal on Per and Poly Fluorinated Chemicals: European Union. OECD. Retrieved from https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/european-union.htmhttps://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/european-union.htm
- Per- and polyfluoroalkyl substances (PFAS). Government of Canada. Retrieved from https://www.canada.ca/en/health-canada/services/chemical-substances/other-chemical-substances-interest/per-polyfluoroalkyl-substances.html
Additional links for instructors:
- PFAS Chemicals. Environmental Working Group, retrieved from https://www.ewg.org/areas-focus/toxic-chemicals/pfas-chemicals?type=reports_consumer_guides
Other materials in the "What's in the Water?" PFAS Contamination Unit":
- What's in the Water? Benchmarking Activity
- What's in the Water? Community Engagement Project
- What's in the Water? Lesson 1: Water Cycle and Watersheds
- What's in the Water? Lesson 2: Introduction to Emerging Contaminants
- What's in the Water? Lesson 3: The Economic Challenges of Clean Water
- What's in the Water? Lesson 4: Drinking Water & Environmental Justice
- What's in the Water? Lesson 5: The Health Effects of PFAS