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- Select your favorite reasons to add mifepristone and its active metabolites to UCMR 6 from our "Top 20" list below and paste them into an email.
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Subject: Regarding Docket ID No. EPA-HQ-OW-2023-0469
Suggested Introduction: Summarize in your own words why you believe mifepristone and its active metabolites need to be placed on UCMR 6. For example:
Dear Officials at the Environmental Protection Agency Docket Center,
I am writing today as a (mother / father / student / concerned citizen) regarding the potential health hazard posed by mifepristone contamination in our water supply. While there are numerous reasons to ensure mifepristone and its active metabolites are placed on the EPA’s final UCMR 6, I would like to highlight the following:
Body: Select your top reasons from among the following "Top-20 Reasons to Place Chemical Abortion Pill Contaminants on CCL 6" (copy and paste a mix of these):
1. Mifepristone has already been detected in U.S. drinking water.
A recently published peer-reviewed study reported the presence of mifepristone in multiple U.S. water samples, including municipal tap water. That fact alone justifies nationwide monitoring through UCMR 6.
2. The EPA cannot perform adequate risk assessments without real-world data.
The purpose of UCMR is to gather occurrence data on emerging contaminants. If mifepristone is already appearing in water samples, the EPA should collect nationwide data to determine how widespread this contamination is, and whether detected levels pose risks to human health, especially pregnant women and their developing children.
3. Mifepristone is not an ordinary pharmaceutical.
Mifepristone is unique among pharmaceuticals, being the only one developed and FDA-approved to end a life. It does so by blocking progesterone, a vital hormone for pregnancy. A drug with such powerful endocrine-disrupting effects deserves heightened scrutiny beyond that which is currently being proposed by the CCL 6 pharmaceutical group.
4. Active metabolites matter.
Scientific literature shows that mifepristone produces three metabolites that remain biologically active and retain anti-progesterone properties. Over 50% of the most common drugs “are excreted in higher amounts as metabolites [than the parent compound].” Monitoring should include mifepristone’s active metabolites, not just the parent drug.
5. Pharmaceuticals commonly enter the environment through human excretion.
The EPA has acknowledged that pharmaceuticals often enter the environment through human excretion — this is true for mifepristone. As wastewater and drinking water systems do not fully remove many of these compounds, they go into our lakes, streams, rivers, and eventually, our tap water.
6. Chemical abortions now occur on a massive scale, contributing to “pseudo persistence.”
Hundreds of thousands of women use mifepristone each year in the United States and excrete its active compounds into our water. As mifepristone is slow to biodegrade, the continual addition of it into our water systems makes it “pseudo-persistent” and creates a significant threat to our drinking water quality.
7. The increasing rates of infertility in America correlate to increasing use of the chemical abortion drug.
As use of the abortion pill, mifepristone, has increased from 6 percent in 2001 to 65 percent in 2023, and likely even higher today, fertility rates have declined. While correlation does not necessarily equate to causation, the absence of comprehensive monitoring data does not mean there is no risk. It means we need more information, which is exactly what UCMR 6 is designed to provide.
8. There are multiple potential analytical methods available.
A 2025 New York Times article outlined that “Scientists who specialize in chemical detection told the senior officials that there are currently no E.P.A.-approved methods for identifying mifepristone in wastewater — but that new methods could be developed.” In addition, Liberty Counsel Action compiled information from peer-reviewed studies on various methodologies for testing water for mifepristone and pharmaceutical metabolites in its comment to the EPA on the UCMR 6. Some are similar to the EPA’s testing method, “Determination of Pharmaceuticals and Personal Care Products in Drinking Water by Solid Phase Extraction and Liquid Chromatography Electrospray Ionization Tandem Mass Spectrometry (LC/ESI-MS/MS).” Utilizing the information in the compiled studies, it should be possible to determine the best way(s) to monitor mifepristone and its active metabolites in time for implementation.
9. Other endocrine disruptors receive EPA attention.
Per the EPA, possible adverse effects of EDCs include: “developmental malformations; interference with reproduction; increased cancer risk; and disturbances in the immune and nervous system function.” Furthermore, the EPA has devoted significant resources to studying endocrine-disrupting contaminants, such as PFAS. Two of them have maximum contaminant levels of 4 parts per trillion. Mifepristone and its active metabolites act as endocrine-disruptors and have been found in drinking water as high as 39 parts per trillion. They deserve similar attention and ultimately, maximum contaminant levels.
10. Peer-reviewed research outlines that mifepristone residues in our environment are “one of the most alarming public health concerns.”
A 2024 study in the peer-reviewed journal Environmental Science and Pollution Research summarizes other research on the same and succinctly presents the threat of mifepristone: “Mifepristone residues in the aquatic environment have recently grown to be one of the most alarming public health concerns. Mifepristone has the potential to be hazardous to [aquatic] life and humans, and it has been linked to the fast growth of endocrine disruptors in the environment . . . Mifepristone is widely distributed in the environment, and several studies that have been published using various analytical techniques demonstrate the ongoing interest in and intense level of research effort on this compound’s presence in the environment.”
11. Mifepristone has been detected in international waters.
Research has documented mifepristone in wastewaters in other countries, demonstrating this is not an isolated concern: a 2010 scientific study outlines that mifepristone has been detected in both hospital wastewaters and wastewater treatment plant effluent in China, and a 2014 scientific study detected mifepristone in Swiss wastewaters.
12. Scientists are calling for more investigation.
Researchers who have studied mifepristone in water state that “significant additional investigation into the levels . . . of mifepristone” in water is needed.
13. Monitoring is a first step, providing a needed response to input from numerous members of the public and high-profile stakeholders.
Over a thousand members of the public requested the EPA add mifepristone to the CCL 6, along with 19 Members of Congress, 14 Attorneys General, and multiple public policy organizations. Adding mifepristone to UCMR 6 is the logical next, needed step, allowing the EPA to gather occurrence information and make informed regulatory decisions based on real-world data.
14. Nationwide occurrence data does not exist.
The United States currently lacks comprehensive national monitoring data on mifepristone contamination in drinking water systems. UCMR 6 can fill that gap.
15. Wildlife studies raise concerns.
Several studies have reported reproductive and developmental effects in aquatic species exposed to mifepristone, demonstrating the need for further environmental evaluation:
- A 2019 study on sea urchins found “a decrease in fertility and embryo development” in females.
- A 2019 study on Nile tilapia found “long-term exposure” of mifepristone “resulted in sex reversal” of females.
- Studies in 2023 and 2024 on African clawed frogs found likely harms, with the 2024 study explicitly finding “Mifepristone caused a reduction in the reproductive success in exposed females.”
- Studies in 2024 and 2025 on tiger puffer fish found mifepristone exposure induces masculinization in females.
16. The current proposal to monitor pharmaceuticals in a future UCMR doesn’t account for the urgent risks posed by mifepristone contamination.
The EPA has recognized pharmaceutical contamination as a public concern both in the sixth draft CCL by proposing a pharmaceutical group, and with the recently published Human Health Benchmarks for Pharmaceuticals (HHB-Rx) in Drinking Water. However, there are thousands of FDA-approved pharmaceuticals, and the HHB-Rx entirely overlooks the abortion pill and its metabolites generally. While mifepristone should be a top priority, under the current framework, it will likely be ignored. Given the risks posed to human reproduction, the EPA should add mifepristone and its active metabolites to the UCMR 6.
17. Mifepristone satisfies UCMR criteria.
By the EPA's own selection criteria, mifepristone and its active metabolites qualify for inclusion on the final UCMR6: It has not previously been monitored under a UCMR' it is feasible to obtain a “validated drinking water method” in time for implementation; available “health-effects information” demonstrates a risk of harm to human health; there is clear “public interest;” “active use” of abortion drugs is increasing: a recently published peer reviewed study reports the presence of mifepristone in the drinking water of two American cities, providing “occurrence data;” and 19 Members of Congress, 14 Attorneys General, and multiple public policy organizations have provided high-profile “stakeholder input” on abortion pill pollution. Finally, while considerations of cost-effectiveness are subjective, they should not preclude action. To mitigate the cost to taxpayers, the EPA should work with Congress to implement a “polluter pays” model — abortion pill manufacturers and providers should pay to clean up the pollution they caused.
18. The American people deserve transparency.
Americans have a right to know whether compounds designed to interfere with reproductive hormones are entering public drinking water systems. To know whether mifepristone and its active metabolites in our water are causing harm to human health, we need to know: Is it in certain areas or widespread? At what levels is it contaminating our water? Who has been exposed? Do the populations in areas with higher concentrations have higher rates of infertility or other reproductive issues? Data obtained by the UCMR 6 can assist in answering these questions.
19. Waiting another five years is unnecessary.
The EPA has proposed to monitor pharmaceuticals in a future UCMR. Delaying the inclusion of mifepristone and its metabolites, along with other pharmaceuticals, ignores the health threats posed by these chemicals, postponing important data collection and risk assessment for years. Consider as well that the EPA recognized PFAS risks in 2006 by launching the PFOA Stewardship Program — yet they were not monitored until 2013, and it was another 11 years prior to maximum contaminant levels (MCLs) being established in 2024 and 18 years from determining risk to establishing a regulation. I urge swifter action on mifepristone and its active metabolites based on the ongoing, present risks that they pose to human health and fertility.
20. Progesterone is vital, mifepristone blocks it, and over a million Americans are not getting enough of it.
Progesterone is vital for wildlife, men, and women. Indeed, to conceive and remain pregnant, women often require progesterone supplementation. In 2024 alone, over fertility support, and this likely represents only a fraction of those who could benefit from it. With so many needing progesterone, we need to ask if our drinking water is laced with progesterone-blocking mifepristone contaminants. This alone suggests it warrants inclusion in the final UCMR 6.
Suggested Closing: Copy and paste the below and modify to your specific circumstances.
For these reasons, I respectfully urge the EPA to add mifepristone and its active metabolites to UCMR 6 so that national occurrence data can be collected and science-based decisions can be made to protect our drinking water quality, and ultimately, the reproductive health of all Americans.