On July 11, the U.S. Environmental Protection Agency issued updated recommendations under the Clean Water Act for contaminants that states, Tribes, and territories should consider monitoring in locally caught, freshwater fish. For the first time, the EPA has added several per- and polyfluorinated substances (PFAS) to the contaminant list (e.g., PFDA, PFHxS, PFNA, PFOA, PFOS), in addition to lead, three cyanotoxins, a flame retardant, and amphetamine.

States, Tribes, and territories monitor and analyze contaminants in fish and shellfish caught in local, fresh waterbodies. When they find contaminants at concentrations that can negatively impact people’s health, they issue consumption advisories. Some state and territorial programs that issue fish and shellfish advisories rely on the EPA’s recommendations to determine which contaminants to monitor.

According to the EPA, many states are already monitoring for certain PFAS in fish and using local data to issue fish consumption advisories where appropriate. Examples of states that have advisories in place include Alabama, Connecticut, Indiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Hampshire, New Jersey, New York, North Carolina, Oregon, Pennsylvania, Washington, and Wisconsin.

Results from the EPA’s most recent National Aquatic Resource Survey, which monitors fish tissue from lakes and streams across the country, “have found PFAS in freshwater fish and shellfish at levels that may impact human health,” according to the EPA. “These studies indicate the presence of PFAS in fish, but they do not give enough information at a local level to inform public health decisions, which is why the role of states, Tribes, and territories in gathering local data is essential.”

The EPA has established two lists of contaminants that fish and shellfish advisory programs should consider monitoring. According to the EPA, both lists contain substances that have been found to occur in the edible tissue of fish and shellfish “at concentrations that may be of concern for human health.”

1. The first list, “Contaminants to monitor for advisories,” contains contaminants for which the EPA or other federal agencies have released measures of oral toxicity in humans (e.g., reference dose, cancer slope factor). The EPA recommends that advisory programs use this list for monitoring and issuing advisories with consumption limits. (newly added contaminants on this list are named above).
2. The second list, “Contaminants to monitor to watch,” contains contaminants for which the EPA or other federal agencies have not yet released assessments of the effects on human health. The EPA recommends that advisory programs monitor compounds on this list to determine if they are accumulating in fish in local waters. The advisory programs could calculate their own or use another agency’s scientifically based measures of oral toxicity in humans to calculate consumption limits or wait for such values to be released from a federal agency. This list contains 7 other PFAS compounds.

EPA advises that any time a fish and shellfish advisory program deems a contaminant of public health concern within its jurisdiction (i.e., there is a spill or known discharge source, or it is found in high enough concentrations to potentially affect the health of people eating fish and shellfish), they should include it in their contaminant monitoring program. Our readers interested in learning more about these programs can find further information here.