America’s Fish are Contaminated with PFAS
By Pat Elder
June 18, 2021
A Pumpkinseed fish near an Air Force base in Michigan contained nearly 10 million parts per trillion of PFAS, while states rush to limit PFAS in drinking water to levels under 20 parts per trillion.
An analysis of PFAS concentrations in 3,262 fish and oysters from rivers and lakes in 48 states shows that America’s seafood is toxic. The average fish in the database contained 93,224 parts per trillion (ppt) of PFAS. The median (middle) value was 13,600 ppt. 83% of the samples were from Michigan.
To put these numbers into perspective, the EPA has established a voluntary Lifetime Health Advisory of 70 ppt of PFAS in drinking water while many states have been enforcing much lower levels. Public health officials are increasingly warning that we should not be consuming more than 1 ppt of these substances in our drinking water. But what about the fish?
Generally, fish caught near military bases, wastewater treatment plants, airports, and industrial sites had elevated (and sometimes astronomical) levels of the poisons. People who eat these fish can become extremely ill. Fish move around, so this is anything but an exact science.
PFAS is also raining from the sky to pollute our rivers and fish. Researchers in Cleveland, Ohio recently found rainwater containing 1,000 ppt of PFAS. Scientists say it only takes 1-2 ppt of PFAS in our rivers to start the bioaccumulative process of PFAS in fish.
The researchers attributed the presence of the chemicals in rain to the consumer products we use every day. Yeah maybe, a little, although the DOD's ongoing incineration of PFAS-saturated materials causes the hard rain to fall while the pellets of poison are flooding our waters. The Pentagon has incinerated twenty million pounds of the materials and continues to do so. One collection of data shows the military origins of two million pounds of the toxins burned in Cohoes, New York. PFAS doesn’t burn easily, if at all. It just sprinkles a quiet death on us.
Almost all public attention regarding PFAS has been focused on contaminated drinking water, although the food we eat, especially the seafood, is the primary route of ingestion. PFAS are per-and poly fluoroalkyl substances, and they’re deadly. Of the more than 8,000 varieties of PFAS, one chemical - PFOS - is the most troublesome because it travels far in water and it bioaccumulates in aquatic life. PFOS accounted for 93.4% of all PFAS in this study.
Meanwhile, the US EPA, the Department of Defense, and states across the country have been focused almost exclusively on PFAS in drinking water, rather than the fish. Go figure.
PFAS in drinking water can be treated, while seafood poisoned with PFAS is a multibillion-dollar inconvenient truth that threatens several industries. Entire watersheds and countless millions of cubic feet of soil and sediment are contaminated. There’s no easy fix.
Teresa Gerade and I created the database. Teresa lives in Newport, Vermont and works with Don't Undermine Memphremagog's Purity, DUMP, an organization that strives to “restore and protect the international waters of Lake Memphremagog and its watershed.” PFAS from the American side has contaminated the Canadian portion of the lake and the Canadians are upset.
Wisconsin can help explain our findings.
News from Wisconsin this week provides a fitting context for our data collection, examined below. Wisconsin has issued new fish consumption advisories for waters within the Yahara Chain of Lakes. The area is just a few miles southeast of Madison, and the 115th Fighter Wing of the Wisconsin Air National Guard, where high levels of the chemicals have been documented.
Surface water near the burn pit at the Truax Field Air National Guard Base (Red X) contained 3,700 ppt of PFOS while surface water in Lafollette contained 6.63 ppt., more than enough to start the deadly bio accumulative process in fish. Wisconsin Dept. of Nat. Res.
The highest level of PFOS in surface water, 3,700 ppt, was detected just south of the Truax Field burn pits where training with firefighting foam had been conducted for decades. The levels in the lakes in the graphic above don’t seem to be too alarming until we consider how PFOS bioaccumulates in fish. The Wisconsin Department of Natural Resources says that surface water levels throughout the state that exceed 2 ppt pose a threat to human health.
Meanwhile, the Air Force has claimed “sovereign immunity” in lawsuits attempting to force it to stop the flow of contamination and to clean up the mess it has made. Sovereign immunity is a dreadful medieval concept that means the US government and its military can do whatever they want.
In response to the contamination from the Air Force, Wisconsin is recommending people eat no more than one meal per month of Largemouth Bass, Northern Pike, Crappie, and Walleye from those waters. People should limit meals of Bluegill, Pumpkinseed and Yellow Perch to four times a month. Samples collected by the state showed high levels of PFOS in fish species collected from lakes Monona, Kegonsa and Waubesa.
These recommendations are based on guidelines established by the Great Lakes Consortium for Fish Consumption Advisories, which recommends no more than one meal per month when PFOS levels are between 50,000 and 200,000 ppt. The consortium recommends no more than four meals per month when PFOS concentration are between 20,000 and 50,000 ppt. Levels in fish tissue above 200,000 ppt would trigger a do not eat advisory for fish.
This is nuts and it’s dangerous.
Minnesota limits PFOS in drinking water to 15 ppt. Michigan limits PFOS in drinking water to 16 ppt and Wisconsin officials have proposed a groundwater standard of 20 parts per trillion for six PFAS substances that include PFOS. More than two-thirds of Wisconsin residents get their drinking water from groundwater.
Why aren’t the fish being regulated like the drinking water?
Because rules barring the consumption of fish at these levels would be tantamount to banning the consumption of most wild fish in America. This is a big problem.
The Great Lakes Consortium, as it is known, typically includes representatives from the eight U.S. states bordering the Great Lakes - Indiana, Illinois, Michigan, Minnesota, New York, Ohio, Pennsylvania and Wisconsin. The group provides the primary forum for guidance on regional fish consumption advisories. Their recommendations may be contributing to widespread disease. Who are these folks, how did they get there, and who, exactly, do they represent?
In essence, Wisconsin says it’s OK for people to have one meal per month of Largemouth Bass, Northern Pike. Crappie, and Walleye from these waters and it’s OK with consuming Bluegill, Pumpkinseed and Yellow Perch four times a month. In total, that’s sixteen servings of fish per month. The average fish in our database contained 93,224 ppt of PFAS. Even if we consider the median PFAS concentration of the study at 13,600 ppt, we’re still talking about a ton of toxins. Catching and eating fish becomes a lethal game of chance.
According to new data recently provided by the Wisconsin Department of Natural Resources, the average PFOS levels within fish they sampled ranged from 16,900 ppt to 72,400 ppt. Some fish, like Largemouth Bass, had maximum concentrations as high as 180,000 ppt. The findings in Wisconsin mirror our findings.
Wisconsin will release fish tissue and water sample results in a report in late 2021/early 2022. Key results will be summarized on this page and will be available in July 2021.
Our database
The average 6-ounce serving of fish in our study contained a concentration of 93,224 ppt. We also calculated the amount of PFAS in a 6 ounce serving.
6 ounces equates to 170 grams. The equation is simple:
Nanograms x 170 g (6 oz)
The average concentration (93,224) x 170 grams = 15,848 nanograms of PFAS. (almost entirely PFOS). Again, this figure is an amount, or a dose, rather than a concentration of chemicals.
So, the 16 average contaminated Wisconsin fish discussed above x 15,848 ng = 253,568 ng. The state is apparently OK with its residents consuming these levels of PFAS in fish every month.
Let’s try to put these numbers into perspective. The EPA’s Lifetime Health Advisory (LHA) is based on the exposure of a 70-kg adult consuming 2 liters of water per day with a concentration of 70 ppt of PFOS/PFOA.
1 part per trillion (ppt) = 1 nanogram per liter (ng/l)
70 ng/l in 2 liters daily is the same dose as 140 ng/l.
A 70-kg adult can consume up to 140 nanograms (ngs) of PFAS in drinking water in a day, according to the LHA.
The EPA says the LHA of 70 ppt for PFAS is calculated to account for 20% total exposure from all sources They call this the Relative Source Concentration, or RSC factor.
So, the EPA is allowing for a total limit per day of 700 ng of PFAS.
Our average 6-ounce serving of fish contained 15,848 ngs, although many fish contained over a million ngs.
Fish Stories
Fish with more than 1,000,000 ppt
Of the 3,262 fish in our sample, 80 contained more than 1 million parts per trillion of PFAS, and these fish have a tale to tell.
From the chart above, the Black Crappie and the Largemouth Bass with the highest concentrations of PFAS were caught in Kent Lake, Michigan just two miles from the General Motors Proving Grounds. Whatever they’re proving there is likely to involve a lot of PFAS. A Largemouth Bass caught in the Huron River/Hubbell Pond, close to the GM installation, had 1,099,680 ppt of PFAS.
These numbers are staggering and the implications for human health are frightening.
The Bluegill, Pumpkinseed, and Yellow Perch shown in the chart were caught in Clark’s Marsh which runs along the perimeter of the now-shuttered Wurtsmuth Air Force Base. The Pumpkinseed fish topped the chart with 9,580,000 ppt of PFAS.
A threadfin shad was caught just south of Paducah, Kentucky that contained 1,250,000 ppt of PFAS. The river is lined with a wastewater treatment plant and several industries that are likely to use the chemicals.
An oyster was found to contain 1,106,000 ppt of PFAS at Hog Point in the Chesapeake Bay just off-shore of the burn pit at the Patuxent River Naval Air Station, Maryland.
A Brook Trout had 1,080,000 ppt of PFAS just outside of the burn pit at Loring Air Force Base in Maine.
An oyster from Matagorda Bay, Texas had 1,225,000 ppt not far from the Sweeny Refinery/Phillips 66 company in Old Ocean.
77 Oysters are identified in the spreadsheet. Here, the mean and the median were very close - at 330,831 ppt and 330,000 ppt respectively. Oysters near military bases, wastewater plants, airports, and industrial sites appear to be most contaminated. Samples were taken from 7 states/territories: AL, FL, LA, MD, VA, TX, & PR.
A softshell clam from Broad Cove, Maine contained 7,645 ppt PFAS. The Eastport Municipal Airport borders Broad Cove in this remote region of northern Maine. Now, I can’t think of anything tastier than fried clams the way those Yankees cook ‘em, but I won’t eat them anymore. Imagine a seafood platter in Maine containing Brook Trout and fried clams! What about the lobsters?
American society isn’t prepared to seriously tackle the causes of disease and cancer. This is a manifestation of a vicious for-profit health care system and it’s also the product of federal and state campaign finance laws that allow for-profit industries to finance congressional campaigns on behalf of its military and corporate customers. This is the result:
The EPA and the FDA say pregnant women should eat 2-3 servings of fish a week.
More numbers
All of the states except Alaska and Hawaii are represented. An oyster in Puerto Rico contained 543,000 ppt of PFOS.
The database contains 3,072 entries that include values for PFOS. As stated, PFOS accounted for 93.4% of all PFAS in the fish. The average contained 91,474 ppt for PFOS alone.
The database contained 3,019 entries of “other PFAS” in fish. This accounted for 6.6% of the overall concentrations. The average “other PFAS” contained 7,646 ppt. The median was 3,421.
2,728 fish contained entries showing their weight. The average was 635 grams or 22.4 ounces.
We calculated multiples over the EFSA weekly limit of 100 ng of PFAS/week. EFSA is the European Food Safety Authority. They’ve concluded that “fish and other seafood” account for up to 86% of dietary PFAS exposure in adults." This single fact should drive federal and state responses toward protecting human health, but the American public health system is badly broken. The average 6-ounce serving of fish in our study is 158.5 times over the EFSA weekly limit. The median is 23.2 times over. We’re in trouble.
To drive home the point to a complacent public we calculated EFSA’s "safe" amount of fish consumed weekly for a child weighing 50 lbs. The child may consume 11.74 grams of the average filet in our study, or .41 ounce. This would be about the size of the child’s thumb.
To illustrate this apocalyptic absurdity, a 6 ounce portion of the Pumpkinseed fish at the top of our chart, caught near the old burn pit at Wurtsmuth AFB, contains 1,653,899 nanograms of PFAS. Using responsible European standards, a 50-pound child may “safely” consume a little less than .01 gram of this fish weekly. Our scale would only go as low as .08 of a gram, so he could consume one eighth of the amount shown below in the course of a week.
One-eighth of this amount weekly - Bon appétit, kiddo.
Postscript: Almost every time I reach out to members of Congress, I am blocked from doing so because I’m limited to correspondence with my Maryland representatives. Could you send a link of this piece to your members of Congress, please? It’s most important to reach out to the membership of the U.S. Senate Committee on Environment and Public Works.
Sincerely, Pat Elder pelder@militarypoisons.org