Michigan tells a fish story
Fish advisory for PFOS fails to protect public health
By Pat Elder
November 2, 2021
The state of Michigan says it’s OK to consume fish containing concentrations of PFOS up to 150,000 parts per trillion (ppt) per month. The state says the advisory “provides the public with the information needed to make decisions to protect themselves and their families from the health risks of consuming fish that contain environmental contaminants.”
A comparison of these standards with those in place in Europe suggests the fish advisories issued by the Michigan Department of Health and Human Services (MDHHS) endanger human health.
Here are the guidelines:
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State of Michigan
Fish Consumption Screening Value Ranges for PFOS
PFOS in Fish (ppt) Frequency per month
< 9,000 16
9,000-13,000 12
13,000-19,000 8
19,000-38,000 4
38,000-75,000 2
75,000-150,000 1
150,000-300,000 .5 (6 meals per year)
>300,000 Do Not Eat
https://www.michigan.gov/documents/mdch/MFCAP_Guidance_Document_500546_7.pdf
See, also our database of PFAS levels in 3,263 fish collected from 48 states.
Mchigan says it’s OK for a pregnant woman (or anyone) to consume an eight-ounce serving of fish containing 38,000 ppt of PFOS weekly. A woman in her first trimester of pregnancy may safely consume fish containing total concentrations of 456,000 parts per trillion of PFOS, according to the state.
PFOS, or Perfluoro-octane-sulfonic acid, is a particularly toxic variety of per-and poly fluoro-alkyl substances, or PFAS. The compounds are used in a host of military and industrial applications. Once discarded, the carcinogens contaminate groundwater, lakes, and rivers throughout the state. PFOS is known to travel long distances in water. It does not break down in nature, while it bioaccumulates in the fish and in our bodies - and the tiny bodies of the developing fetus.
Michigan Public Radio reported last year that the state tested over 2,000 fish and the average fish contained 80,000 parts-per-trillion (ppt) of PFOS, more than twice the arbitrary weekly limit chosen by the state. According to the report, the highest concentration in the state was 10,000,000 parts-per-trillion in a fish caught near the former Wurtsmith Air Force Base in Oscoda!
Meanwhile, Michigan limits PFOS in drinking water to 16 ppt.
Just a little Math
· 8-ounce serving = 227 grams
· 38,000 ppt of PFOS is the same as 38 nanograms per gram.
· So, 38 ng/g x 227 g = 8,626 ng of PFOS.
Michigan says it’s OK to consume 8,626 ng of PFOS in fish weekly. Hold the thought.
Despite all the talk and recent bluster, the EPA and the FDA still have not set standards. We can look to the more responsible European Food Safety Authority, (EFSA), which has set a Tolerable Weekly Intake of 4.4 nanograms per kilogram of body weight for PFOS (and several other PFAS) in food.
So, according to this guideline, an expectant mom weighing 150 pounds (67.8 kilos) can “safely” consume about 300 nanograms per week of PFAS chemicals.
· 4.4 ng x 67.8 kg = 298.32
One meal of the Michigan fish containing 8,626 ng of PFOS is 29.5 times greater than the European weekly limit. Of course, this is based on a fish containing 38,000 ppt when the average fish in Michigan contains twice the level of PFOS.
Sure, recreational fishing alone generates more than $2 billion in economic activity annually in Michigan, but the state ought to be warning women who are pregnant or may become pregnant about the dangerous PFOS levels in fish.