Published June 5, 2026
On June 5, 2026, EPPC scholars Eric Kniffin and Rachel N. Morrison in the Administrative State Accountability Project and Jamie Bryan Hall in the Life and Family Initiative submitted a public comment to the Environmental Protection Agency (EPA) in response to a Notice where EPA proposed adding pharmaceuticals to a list of drinking water contaminants that will be prioritized for research and potential regulation.
The comment encourages the EPA to identify the pharmaceutical mifepristone – an endocrine disruptor capable of harming vulnerable populations like pregnant women, unborn children, and those suffering from infertility – for further study.
The comment points out that the federal government has not published an environmental assessment on mifepristone since 1996, when the FDA was considering whether to approve the abortion drug. As the comment notes, the FDA’s 1996 “finding of no significant impact” was based on presumptions that no longer hold—many “are out of date, and some were flawed from the start.” For example, the FDA presumed that mifepristone supply would be small, that mifepristone would be uniformly distributed in America’s water supply, and that its initial restrictions and guidelines would be maintained.
From the comment:
Mifepristone has not been meaningfully studied not because the relevant environmental concerns are implausible, but because successive regulatory actions have expanded access to the drug without triggering the kind of interagency review those questions should have prompted. EPA has stated that it does not currently test for mifepristone in water because it is not compelled to do so. In turn, EPA is not compelled to test because there is no existing occurrence data or established regulatory benchmark for the drug. As shown below, however, the lack of federal occurrence data for mifepristone is at least partly the result of a decision not to look, and the absence of testing data does not establish the absence of contamination.
The FDA in 1996 also did not anticipate the way the Biden Administration’s political interference in the agency’s work after Dobbs. The comment cites Morrison’s and Kniffin’s recent amicus brief for EPPC, which documents the effects of Biden’s promise to do “everything in his power” to protect access to abortion.
The comment also argues that prioritizing mifepristone for further study would be consistent with EPA’s mandate from Congress, the EPA’s notice and recent actions, and with the Trump Administration’s MAHA agenda.
Other organizations also submitted comments to the EPA, including:
Eric Kniffin is a fellow at the Ethics and Public Policy Center, where he works on a range of initiatives to protect and strengthen religious liberty as part of EPPC’s Administrative State Accountability Project.
