PFAS in Maine - another fish story?
Fish like this Smallmouth Bass in Maine’s Kennebec River are loaded with carcinogens while the state says they’re OK to eat.
By Pat Elder
June 12, 2023
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Although the fish are highly contaminated with PFAS, the Maine Center for Disease Control and Prevention says it’s OK for the public to enjoy nine meals of Smallmouth Bass a year taken from the Kennebec River just north of Fairfield.
This table shows concentrations of PFAS compounds found in a Smallmouth Bass taken from this location, in parts per trillion.
PFOS 16,300
PFUNDA 1,240
PFTRDA 1,065
PFDA 885
PFDOA 751
PFTEA 621
PFOSA 332
Total 21,194 ppt
Maine has established a fish tissue action level (FTAL) for PFOS at 3.5 nanograms per gram, (3.5 ng/g) based on a fish consumption rate of 227 grams (8 oz) per week.
3.5 ng/g = 3.5 parts per billion = 3,500 parts per trillion.
(At the same time, Maine limits PFOS and five other compounds in drinking water to 20 parts per trillion.)
3.5 ng/g x 227 grams = 795 nanograms of PFOS.
Maine says it’s OK to consume 795 nanograms of PFOS in fish weekly.
Maine uses Fish Tissue Action Levels as a guide to determine the need to develop a fish consumption advisory. Many are catching and consuming poisoned fish. Women who are pregnant or may become pregnant should not be eating this fish and neither should anyone else.
The Smallmouth Bass from the Kennebec
The 16,300 parts per trillion of PFOS in the Smallmouth Bass is a concentration of the carcinogen in the tissue. Let’s derive the dosage, in nanograms, for a single 8-ounce portion:
8 oz = 227 grams
16,300 ppt = 16.3 nanograms per gram, or 16.3 ng/g
16.3 ng/g x 227 g = 3,700 ng of PFOS.
One serving of the fish contains 3,700 nanograms of PFOS. Maine says people can eat 9 servings of this fish per year, (9 x 3,700) allowing for a total consumption of 33,300 nanograms of PFOS in a year. The state is saying it’s OK for women who are pregnant or may become pregnant to consume 11,100 nanograms of the carcinogens during their first trimester. Can the state show us the science proving these levels are harmless to the developing fetus?
Currently, PFOS is the only PFAS compound that is used by the Maine CDC to determine if fish consumption advisories are necessary for PFAS. Targeting PFOS alone is detrimental to public health.
For instance, Maine does not regulate Perfluorodecanoic acid, (PFDA) in fish. PFDA is a particularly dangerous 9-carbon chain compound that may not exceed 20 ppt in drinking water in Maine. It is found in the filet of fish people regularly consume at levels up to 127,100 ppt. See Table 3 – Summary statistics of 51 composite samples.
PFDA is closely regulated in the drinking water because it has been associated with the following:
Adenoma, Liver Cell
Aneuploidy
Asthma-related traits
Breast Neoplasms
Carcinoma, Hepatocellular
Diabetes Mellitus, Type 2
Glioblastoma
Heart Septal Defects
Liver Neoplasms
Pneumonia
Poisoning
Pre-Eclampsia
Prenatal Exposure - Delayed Effects
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Maine keeps the total of these six dangerous PFAS compounds under 20 ppt in drinking water: PFOA, PFOS, PFHxS, PFNA, PFHpA, and PFDA.
Here are the highest concentrations reported for the “Maine PFAS 6” by the state in fish filet collected from various locations:
PFOA 8,070
PFOS 1,504,000*
PFHxS 1,010
PFNA 10,790
PFHpA 1,820
PFDA 127,100
Total 1,652,790
* The lake where this fish was caught is off-limits for fishing. If this is what it takes to tell the public not to eat the fish, we’re in trouble.
Non-PFOS compounds like PFOA depicted here may be freely consumed in poisoned fish throughout the state.
PFOA may be the deadliest of all PFAS compounds. It’s been four years since the nation’s top toxicologist Linda Birnbaum warned that drinking water limits for PFOA ought to be set at .1 part per trillion because of research linking tiny exposures of PFOA to pancreatic cancer. Many PFAS compounds are thought to adversely affect human health at miniscule levels. The EPA’s interim Lifetime Health Advisory is now .004 ppt in drinking water for PFOA. These chemicals are powerful!
The concentration of 8,070 ppt of PFOA in the fish described above is 2 million times over the EPA threshold. We are in trouble, like Icarus and Pandora of old.
Maine Department of Health and Human Services
Levels of PFOS in fish and corresponding 8-ounce meal advice categories
PFOS in fish (ppt) Meal advice
3,500 1 meal per week
7,500 2 meals per month
15,000 1 meal per month
30,000 6 meals per year
60,000 3 meals per year
> 60,000 Do Not Eat
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The threshold is too high for “Do Not Eat.” This entire exercise is absurd because the public doesn’t have a clue while state enforcement is lax.
Let’s examine PFAS in the fish from China Lake, Maine, about 15 miles northeast of Augusta. The state allows the public to consume one fish a month from China Lake.
Highest concentrations of PFAS compounds found in various fish caught from China Lake:
PFOS 20,720
PFUnDA 5,041
PFDA 2,997
N-EtFOSE 1,900
PFTRDA 1,657
PFDOA 1,295
PFTEA 611
PFNA 508
PFOSA 319
Total 35,048
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Let’s look at how these chemicals hurt us.
(Artwork by Victor Pytko)
PFOS (20,720 ppt) causes cancer. PFOS is associated with multiple cancers and diseases and that’s because it has been intensely studied for years. Other compounds have not been studied as extensively, although the science is rapidly catching up!
PFUnDA (5,041 ppt) is associated with Diabetes Mellitus, Eczema, Testicular Disease, Weight Loss.
PFDA (2,997 ppt) Hazards likely exist with respect to the potential for liver, immune, developmental, and male and female reproductive effects in humans, given sufficient PFDA exposure. PFDA might also have the potential to cause cardiometabolic and neurodevelopmental effects in humans, according to the EPA.
PFOSA (319 ppt) is associated with Teratogenesis, the process by which congenital malformations are produced in an embryo or fetus.
PFNA (508 ppt) is associated with Adenoma, Liver Cell Adenoma, Asthma, Breast Neoplasms, Hepatocellular Carcinoma, Liver Injury, Cholestasis, Hepatomegaly, Hyperbilirubinemia, Liver Neoplasms, Non-alcoholic Fatty Liver Disease, Osteoporosis, Perinatal Death, Prenatal Exposure, Delayed Puberty, Weight Loss
What’s in your fish?
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I’ll be travelling to Japan in September and October with a delegation from Veterans for Peace to test surface waters for PFAS in 20 cities. It’s expensive. Please help us! The 40 tests kits will cost 440,000 Yen - or $3,160. Please make a note that your contribution is for the Japan delegation.
Financial support from the Downs Law Group makes this work possible.
The firm is working to provide legal representation to individuals with a high likelihood of exposure to PFAS and other contaminants.
Interested in joining a multi-base class action law suit pertaining to illnesses stemming from various kinds of environmental contamination?
Join the Veterans & Civilians Clean Water Alliance Facebook group.