PFAS levels comparisons (FOI)

Request

A

I wish to compare the individual PFAS in our tap water, to the individual PFAS found in our blood. 

Please can we see a plotted graph, of the PFAS blood test results of the recent Government testing, with ALL separate individual PFAS chemicals outlined, and another graph showing ALL separate individual PFAS levels our tap water. 

- Note - PFAS is the group name.

PFOA, PHHxS, PFNA, PFOS are some of the individual PFAS chemicals that are high locally. One could assume that if levels across the board are high in blood, and also high in the tap water, then that blood chemical came from the tap.

Some PFAS that are high in the blood of locals possibly didn't come from the tap, so that can also be demonstrated by this graph.

B

We do not require the individual readings from household taps. The individually identified subtype levels, as found in the reservoirs, would suffice. This will protect individual household privacy. 

For example (there are at least 16 subtypes on the water test, and 33 on the Vista blood tests that were done) - 

In mains water (Island average)

PFBA 5.2 ng/l

PFOA, 4.8 ng/l 

PFHxS, 6.5 ng/l

In completed blood tests (Island average)

PFBA 0.40 ng/l

PFOA 2.2 ng/l 

PFHxS, 2.2 ng/l

I believe that islanders have a right to know if the individual chemicals that are high in the mains tap water are the same chemicals that are registering high in islanders’ blood. Is there a correlation?

If it is too much trouble to plot a new graph, it would be acceptable to publish the average quantities of each PFAS subtype found in the bloods, across the whole tested group, and we will plot our own graph. 

Response 

A

The Government of Jersey does not hold this information in the format requested. The Freedom of Information (Jersey) Law 2011 does not require a Scheduled Public Authority to create new data sets specifically for this purpose, therefore Article 3 of the Freedom of Information (Jersey) Law 2011 applies.  

Additionally, due to the small number of households where water testing took place, sharing this information could potentially identify individuals. It is considered that their right to privacy outweighs the public interest supporting the release of the information requested, it is therefore exempt under Article 25 (Personal Information) of the Freedom of Information (Jersey) Law 2011.

B

The requested information relating to PFAS levels in tap water not held by the Government of Jersey. Article 3 of the Freedom of Information (Jersey) Law 2011 applies. 

The information is, however, collected by Jersey Water. You may wish to direct your request to them by using the details below: 

Jersey Water, St Helier, Jersey, JE1 1JW.

It should be noted that Jersey Water are not Scheduled Public Authority, therefore, they are not required to respond under Freedom of Information legislation. 

Regarding the quantities of each PFAS subtype found in the bloods sampled, the table below lists the average result (expressed as the median (middle) value) for all of analytes which have a result that is greater than the limit of detection. All other analytes that are not listed in this table had an average value which was below the limit of detection. 88 Jersey samples were included in the total analysis. 

Please note, interpretation of any correlation existing between tap water and blood levels will require extreme care, given the wide range of other variables. 

Articles applied

Article 3 - Meaning of “information held by a public authority”

For the purposes of this Law, information is held by a public authority if –

(a)     it is held by the authority, otherwise than on behalf of another person; or

(b)     it is held by another person on behalf of the authority.

Article 25 - Personal information

(1) Information is absolutely exempt information if it constitutes personal data of which the applicant is the data subject as defined in the Data Protection (Jersey) Law 2005.

(2) Information is absolutely exempt information if –

(a) it constitutes personal data of which the applicant is not the data subject as defined in the Data Protection (Jersey) Law 2005; and

(b) its supply to a member of the public would contravene any of the data protection principles, as defined in that Law.

3)      In determining for the purposes of this Article whether the lawfulness principle in Article 8(1)(a) of the Data Protection (Jersey) Law 2018 would be contravened by the disclosure of information, paragraph 5(1) of Schedule 2 to that Law (legitimate interests) is to be read as if sub-paragraph (b) (which disapplies the provision where the controller is a public authority) were omitted.