Regulatory Brief

 Draft Recreational Water Quality Criteria (RWQC) availability announced by EPA (December 2011)

Formal title: Docket Number [EPA-OW-2011-0466] Draft Recreational Water Quality Criteria and Request for Scientific Views

On December 21, 2011 the Environmental Protection Agency (EPA) announced and solicited public comments on the Agency's Draft Recreational Water Quality Criteria (RWQC).

Brief Description:

Pursuant to section 304(a) of the Clean Water Act (CWA), the EPA announced the availability of the draft RWQC, which contains the EPA's draft ambient water quality criteria recommendations for protecting human health in waters that are primarily designated as recreational. The recommendations when finalized are intended as guidance to States and Tribes in developing water quality standards.

AVMA Response:

The AVMA supports scientific studies of the impact of pathogens from animal and human waste sources and commends the Agency's pursuit of science based evidence on the various unknowns and data gaps relevant to the potential for human illness from exposure through recreational water to nonhuman fecal contamination compared to that of human fecal contamination. We applaud the EPA for its recognition and inclusion within the RWQC that "the risk presented by fecal contamination from nonhuman sources varies and, has been shown in some cases, to be potentially less significant than the risk presented by fecal contamination from human sources (Soller et al., 2010a,b; Schoen and Ashbolt, 2010, Bambic et al., 2011)" and that not all animal fecal material presents the same level of risk. Both points further support the value of site-specific quantitative microbial risk assessment (QMRA) when needed. The AVMA appreciates the fact that EPA is not developing separate national criteria for nonhuman sources of fecal contamination of recreational waters.

Additionally, we congratulate the EPA on the development, validation, and utilization of a qPCR method for rapid analytical techniques for detecting enterococci in recreational waters.

The AVMA supports zoonotic disease education programs targeting veterinarians, physicians, public health planners, and others involved in One Health efforts so that they are better informed about zoonotic diseases and the impacts such can have on animals and humans.

Background Documents:

February 15, 2012 – Full AVMA Response (PDF)

December 21, 2011 – Federal Register Notice (PDF)

Draft Recreational Water Quality Criteria (PDF)

Relevant AVMA Policies