New Hampshire issues fish consumption advisory for PFOS
Measure fails to protect public health; Women of child-bearing age still allowed to consume fish with high levels of PFOS.
By Pat Elder
November 9, 2021
Many fish are not safe to eat in New Hampshire. Photo - NH Fish & Game
Last week the New Hampshire Department of Environmental Services issued the state’s first fish consumption advisories for PFAS, (per- and poly fluoroalkyl substances). The state is warning children under 7 not to eat fish from Robinson Pond in Hudson and Horseshoe Pond in Merrimack because of high PFAS levels. Women of child-bearing age, however, are allowed to consume one fish a month containing PFOS.
When evaluating the concentrations of PFAS in fish, specifically PFOS, (Perfluoro-octane sulfonic acid), the state compared the concentrations and various risk levels to those for the already-existing state-wide mercury advisory. New Hampshire already recommends fishers limit consumption of fish due to mercury. The mercury fish advisory says children under 7 should only consume one four-ounce meal per month. Women of childbearing age may consume one meal per month containing 8 ounces. Older children and other adults are allowed to consume four meals containing 8 ounces of the tainted fish.
The state figured it could kill two fish with one stone, so to speak.
Where PFOS concentrations were greater than 7,400 parts-per-trillion stricter consumption limits were recommended over the existing mercury advisory. The specific recommendations vary by age, rate of consumption and tissue concentration of PFOS. Those recommendations can be found here.
The “high risk” group is made up of children under 7 and women of child-bearing age. The “low risk” group is comprised of older children and adults. https://www.des.nh.gov/sites/g/files/ehbemt341/files/documents/2020-01/ard-ehp-25.pdf
Regulators examined PFAS levels in fish in 14 lakes in the southern part of the state. 9 of the lakes had fish under the 7,400 ppt threshold so they are following the “Statewide Freshwater Fish Advice Due to Mercury.” Women of childbearing age are still eating fish with lots of PFAS. This is a serious matter.
In the 5 lakes where PFOS concentrations were greater than 7,400 parts-per-billion, however, stricter consumption limits were recommended over the existing mercury advisory. The chart below shows the advisory for eating fish in the 5 lakes.
New Hampshire Department of Environmental Services - Summary of recommended fish consumption advisories for 5 New Hampshire lakes. Waterbodies not listed here should follow existing advisories for mercury in freshwater fish.
Five lakes in the southern region of the state contained fish that exceeded the 7,400 ppt threshold, yet women who are pregnant or may become pregnant are told they can still eat the fish. Expectant mothers may eat one fish a month containing 18,300 ppt of PFOS. It’s not good public policy.
Location Highest concentration in fish
Beaver Lake 7,750 ppt
Canobie Lake 12,400
Cobbett’s Pond 15,200
Horseshoe Pond 18,300
Robinson Pond 17,700
---------------------------------------------------------------------------------------------
See the following chart released by the state of New Hampshire. The concentrations of various PFAS compounds are shown in parts per billion. (multiply by 1,000 to get to parts per trillion)
New Hampshire - PFAS levels in fish from 14 lakes
Source: NHDES https://www4.des.state.nh.us/nh-pfas-investigation/?p=1405
New Hampshire reported a smallmouth bass from Horseshoe Pond contained 18,300 ppt of PFOS. Meanwhile, the state’s drinking water regulations limit concentrations of PFOS to 15 ppt.
Examine the Total PFAS row above. The average fish contained concentrations of 13,640 ppt for all PFAS, while the median value was 12,200 ppt, meaning half of the fish have levels above 12,200 ppt of PFOS.
Actually, the sampled were composite of fish fillets, not individual fish. So, the average is not actually that of any 1 fish, but the average of the combined result for 4-5 fish per waterbody. This is a common approach for initial studies like this, where 4-5 fish are combined for 1 representative sample from the waterbody.
The state limited its advisories to the PFAS it could assess under EPA’s current methodology and could have analyzed by its contracted lab. However, this approach does not account for the 8,000 varieties of PFAS known to exist.
The New Hampshire legislature fully understands how these chemicals are able to accumulate in fish. It is imperative they pony up. The state must put human health, especially the health of women who are pregnant or may become pregnant, above the financial interests of certain segments of the state’s economy.
The legislature requested a plan and budget to address the issue and the Department of Environmental Services delivered this report to the legislature in 2020. Sadly, the state has declined to pursue subsequent legislation.
According to Jonathan Petali, Ph.D. Toxicologist with the NH Department of Environmental Services, “This sampling effort was supported by a 1-time funding opportunity and without state or federal legislation (that includes funding) the process of addressing PFAS in fish tissue is very difficult and expensive.”
Dr. Petali explained, “Historically, the federal government (EPA/USDA/USGS/USFWS) develops this sort of guidance for chemicals in fish and their ecosystems (e.g. surface water standards and regulatory standards). This means states are rarely staffed and funded to do the basic research and applied research required to develop these solutions. States often prioritize having staff and resources to enforce the federally-crafted (and funded) guidance. There has been considerable effort amongst states to collaborate and fill some data gaps, but often this is a challenge that requires time and funding that states simply do not possess.”
Maybe more federal infrastructure dollars should head this way.
PFUnA - Perfluoro undecanoic acid
For the sake of the health of mother and child, let’s look at the concentrations of PFUnA. The average fish contained concentrations of 1,442 ppt of this type of PFAS nobody talks about. Perfluoro undecanoic acid (PFUnA) is a breakdown product of stain- and grease-proof coatings on food packaging, couches, and carpets, including Dupont’s Stainmaster. The chemical is part of a family of perfluoroalkyl carboxylates, all with structures similar to the well-known killer- chemical PFOA, but with carbon chain lengths ranging from 4 to 15 carbons. PFUnA is the 11 carbon first cousin of PFOA. It is a powerful toxin.
__________________________________________________
We must heed Rachel Carson’s warning:
“If we are going to live so intimately with these chemicals eating and drinking them, taking them into the very marrow of our bones — we had better know something about their nature and their power.”
_________________________________________________
Perfluoroalkyl carboxylates with carbon chain lengths of at least 8 carbons are of particular concern because they are known to be bioaccumulative, globally distributed pollutants. Although PFOA has been studied extensively, there has been very little research done on the toxicity of PFUnA. Congress has made sure of that. PFUnA is believed to cause serious health effects, including cancer, endocrine disruption, accelerated puberty, liver and immune system damage, and thyroid changes.
7,400 ppt
PFOS concentrations greater than 7,400 ppt in fish warrant stricter consumption limits over the existing mercury advisory in New Hampshire.
It's interesting because the Town of Chesapeake Beach, Maryland, adjacent to the Naval Research Laboratory - Chesapeake Bay Detachment, reported that a perch they tested contained concentrations of 7,400 ppt of PFOS. A spokesperson for the Maryland Department of the Environment told the Bay Journal that Marylanders could eat 48 of these fish a year. Maryland recently published a threshold for fish tissue concentrations of PFOS/PFOA. In the Old Line State, it's OK to eat 48 fish yearly, each containing concentrations up to of 56,000 ppt. Although it’s bad in New Hampshire. It’s worse in Maryland.
Miniscule concentrations of PFOS in surface waters translate to high levels in fish. New Hampshire reported that PFAS concentrations in surface water were “generally non-detect to the low single digits of parts-per-trillion, with few exceptions.” At the same time, total PFAS concentrations across all composite fish samples ranged from 4,540 to 26,270 parts-per-trillion.
It is amazing how these chemicals are able to accumulate in fish! It is imperative that municipal and state governments across the country come to terms with this.
NH v. MA
When I read the press release about the PFAS fish advisory in New Hampshire I sent an email to the contact provided and received a helpful reply from Dr. Petali, He answered my questions and provided me with the data I requested.
Massachusetts also enacted PFAS fish advisories last week. Instead of the friendly, personal response I received in New Hampshire, Massachusetts responded in corporate fashion:
"Re: Public Records Request: BEH-2021-330- Elder- PFAS Fish Advisories - This letter is to acknowledge that the Department of Public Health (the “Department” or “DPH”) received your public records request on November 5, 2021 made pursuant to the Massachusetts Public Records Law, G.L. c. 66, § 10. This request has been assigned a tracking number: BEH-2021-330. The Department is processing this request."
A follow-up email said the DPH is requesting an extension until November 30, 2021.
It is good to see New Hampshire include PFOS in its figuring of fish consumption advisories. It is reassuring that the state is warning children under 7 not to eat fish over certain PFOS levels. It is a start and it is a victory! However, the state must examine the levels of PFOS pregnant women are allowed to consume, especially during their first trimester. While the state is looking at this, it might want to re-examine the notion that consuming fish containing any PFOS is advisable.