PFOS in Michigan Fish
Fish testing program leads the nation
while the state allows toxic fish to be consumed.
By Pat Elder
April 2, 2021
In March, 2021, the Michigan Department of Environment, Great Lakes, and Energy - Water Resources Division (EGLE-WRD) released data showing the levels of PFAS contamination in 2,841 fish caught in the state. PFAS is short for toxic per-and-poly fluoroalkyl substances.
It’s OK to a eat Smallmouth Bass like this containing 307,000 parts per trillion of PFOS from Proud Lake in Michigan, while drinking water cannot exceed 16 parts per trillion of the toxins.
See the file, EGLE PFAS Filet Data 2, sorted by PFOS levels - from highest to lowest.
88% of the fish had results above 260 parts per trillion (ppt), the minimum levels reported in the study. 260 ppt is more than three times higher than the EPA’s Lifetime Health Advisory of 70 ppt for drinking water. The fish averaged 92,641 ppt of PFOS. The state issues “Do Not Eat” advisories for fish that top 300,000 ppt of PFOS, although Proud Lake is an exception.
The data summarizes the analyses of the edible portion samples of the fish in the EGLE database. 23 species from 178 locations were analyzed.
Michigan has measured contaminants in over 20,000 fish tissue samples collected since 1980. PFAS is studied because they are known to exhibit high bioaccumulation potential in fish tissue. The presence of the tiniest amounts of PFAS in surface water can result in fish tissue concentrations that pose a human or wildlife health risk.
The Michigan study analyzed 11 of the more than 8,000 varieties of PFAS. Per fluoro octane sulfonic acid (PFOS) was typically found in the highest amounts and is believed to be among the most toxic of all PFAS. I will focus on PFOS in this report.
The fish are poisonous in Proud Lake, Michigan.
The smallmouth bass caught in Proud Lake in Oakland County, Michigan contained 307,000 parts per trillion of PFOS. There are no Michigan consumption guidelines for Proud Lake. Neither the Michigan Safe Fish Guidelines nor the Consumption Guidelines include fish from Proud Lake.
Is it dangerous? The Europeans think so.
· A small serving of pan-fried smallmouth bass may weigh 4 ounces or 113 grams.
· If the filet of the fish contains 307,000 parts per trillion of PFOS, that’s 307 parts per billion, which is the same as 307 nanograms per gram.
· So, 307 ng/g x 113 g = 34,691 ng.
· The 4-ounce serving contains 34,691 nanograms of PFOS. It’s poison.
· We’ll say 4 ounces of this tasty fish is pan-fried and served to a five-year-old weighing 50 pounds.
· The European Food Safety Authority (EFSA) has set a Tolerable Weekly Intake (TWI) for a child weighing 50 pounds (22.6 kilos) at 100 nanograms per week of four PFAS chemicals, including PFOS.
· Four ounces of the smallmouth bass containing 34,691 ng of PFAS is 346 times greater than the European weekly limit for our child.
· The smallmouth bass contained 307,000 ppt of PFOS while Michigan limits drinking water to 16 ppt of PFOS
What’s in your fish, kiddo?
PFOS is among the most toxic chemicals ever produced. It’s responsible for immeasurable death and suffering from human ingestion at microscopic levels. The substance bioaccumulates in fish and in humans and it takes nearly forever to go away. The military, private companies, and the public recklessly use the substances and discard them into the environment. The EPA still refuses to regulate the stuff.
Michigan issues “Do Not Eat” advisories for fish with PFOS levels higher than those found in the smallmouth bass from Proud Lake. For instance, the state has issued a voluntary “Do Not Eat” advisory for all of the fish from the following seven bodies of water: Here’s a snapshot these waters and the highest PFOS levels found in fish.
MICHIGAN DO NOT EAT ADVISORIES
Water Species PFOS in ppt.
Clarks Marsh Pumpkinseed 9,580,000
Au Sable River Pumpkinseed 2,956,284
Kent Lake Largemouth Bass 1,998,000
Hubbell Pond Largemouth Bass 1,407,680
Helmer Creek Bluegill 497,000
Argo Pond Rock Bass 487,480
Base Line Lake Largemouth Bass 366,299
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Michigan’s fish advisories are not mandatory. They are only guidelines to help people make safer choices. Critics claim these advisories are poorly marketed while there are many areas where anglers approach poisoned lakes to fish while there is no signage. The advisories are somewhat like the federal Cigarette Labeling and Advertising Act of 1965 mandating that the warning “Caution: Cigarette Smoking May Be Hazardous to Your Health” be placed on one of the side panels of each cigarette package. In the case of hazardous fish, however, the federal government has not issued warnings on fish containing high levels of PFOS and most states have not posted fish advisories for PFOS.
The US Food and Drug Administration has steered clear of addressing the health concerns associated with astronomical levels of various PFAS chemicals in fish.
From the FDA - Should I stop eating particular foods to reduce my PFAS exposure? “There is no scientific evidence that supports avoiding particular foods because of concerns regarding PFAS contamination.” - 10/20/20
Michigan’s overall fish testing regime has been the most impressive nationwide. The state has measured various contaminants in over 20,000 fillet or other edible portions of fish tissue samples collected since 1980. EGLE stresses that the presence of “extremely low concentrations of some bioaccumulative pollutants in surface water can result in fish tissue concentrations that pose a human or wildlife health risk.” They’re not kidding. On the science end of the deal, Michigan is doing a great job, on the enforcement/human health side of the ledger, the state is failing. Consider the following chart.
Michigan Department of Health and Human Services (MDHHS)
Fish Consumption Screening Values for PFOS
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Meals/month ppt % of the 2,841 fish
Do Not Eat > 300,000 4.3
6 meals/ year > 150,000 to 300,000 1.5
1 > 75,000 to 150,000 3.7
2 > 38,000 to 75,000 6.3
4 > 19,000 to 38,000 12.9
8 > 13,000 to 19,000 9.5
12 > 9,000 to 13,000 10.4
16 260 - 9,000 39.6
Unlimited < 260 ppt 11.8*
*42% of the 336 fish below the minimum for PFOS had readings of other PFAS above 260 ppt, sometimes greater by orders of magnitude.
The state says no one should eat fish listed as “Do Not Eat.” EGLE explains that “eating even one meal of these fish could possibly lead to health problems in the future, regardless of age or health.”
It doesn’t make sense.
If you shouldn’t eat a single fish with 300,000 ppt of PFOS, how can it be OK to eat 6 meals a year of fish containing 299,000 ppt of the poisons?
A smallmouth bass from Holloway Reservoir was found to contain 247,004 ppt of PFOS. Rather than issuing a “Do Not Eat” advisory, the state suggests anglers limit consumption to 6 fish a year. To take this argument to the boundaries of mathematical logic, the state is allowing the consumption of fish to concentrations of 4,060 ppt daily while limiting concentrations of PFOS in drinking water to 16 ppt.
Surface water levels of PFOS
PFAS foam on a beach in Oscoda, Michigan, near Wurtsmuth Air Force Base
Michigan is also failing to protect public health by allowing high levels of PFOS in surface water. Michigan has generated a “Human Non-Cancer Value (HNV)” surface water level at 12 nanograms per liter (ng/l), or 12 ppt for PFOS, “for the protection of human health and aquatic life.” These values apply to practically all surface waters in Michigan. Sadly, having 12 ppt of PFOS in surface water can generate PFOS levels in fish in the tens of thousands of parts per trillion.
Having no PFOS in the water would protect human health.
This graphic from the Wisconsin Department of Natural Resources shows that 2 ppt of PFOS in surface water may threaten human health.
WQC is water quality criteria. - Wisconsin Department of Natural Resources PFOS & PFOA Surface Water Criteria - 23 March 2020 Meghan Williams Environmental Toxicologist, Water Quality Bureau
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More on the Michigan fish
The Michigan data identified 118 bodies of water where PFOS were found in various species of fish. Here’s a glimpse of the number of fish by species with the highest levels of PFOS in the 118 bodies of water. The chart also includes corresponding averages of PFOS levels.
# water bodies where this species
was the most contaminated
Species of those sampled Avg. PFOS in ppt
Largemouth Bass 39 126,637
Bluegill 15 68,204
Rock Bass 11 72,543
Smallmouth Bass 9 117,329
Walleye 7 13,216
Black Crappie 6 27,076
Brown Trout 6 34,443
Pumpkinseed 5 2,540,191
Lake Trout 4 3,314
Lake Whitefish 4 11,769
Yellow Perch 4 17,912
Coho 2 3,984
Northern Pike 2 1,114
Rainbow Trout 2 19,483
Lepomis 1 16,100
Carp 1 99,920
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Perhaps more telling is an examination of the highest levels of PFOS found in each species in the study.
Species PFOS in ppt
Pumpkinseed 9,580,000
Bluegill 2,450,000
Largemouth Bass 1,998,000
Black Crappie 1,378,189
Rock Bass 487,480
Smallmouth Bass 424,000
Warmouth 174,000
Walleye 145,302
White Sucker 143,350
Carp 99,920
Brook Trout 68,398
Channel Catfish 50,672
Rogue 50,400
Northern Pike 41,959
Longear sunfish 30,000
Rainbow Trout 27,767
Lepomis 19,899
Lake Whitefish 15,970
Coho 7,969
Lake Trout 7,900
Atlantic salmon 6,113
Redhorse Sucker 779
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These snapshots of data are subject to lots of variables, including the proximity of the fish to the source of contamination, the travels of the fish, the density of PFOS, the species of fish, and perhaps, the age, length, and weight of the fish. How the different species experience bioaccumulation of the substances must be factored in. There’s no consensus on the methodology for analyzing the fish. That’s because the EPA isn’t fully engaged, perhaps because there are too many monied interests in Michigan and in states across the country to allow for stringent PFOS fish advisories that are sure to cause a fuss and drive money-spending anglers away.
The EPA may not be engaged because of the astronomical price-tag facing the military, manufacturers, and municipalities. It’s easier and cheaper to dump untreated waste into our rivers.
Denise Trabbic-Pointer, a former Dupont chemist working with the Sierra Club’s Michigan Chapter explained, “PFAS, as a class, includes more than 4,700 compounds, each with their own physical properties. The physical properties of specific PFAS greatly influences how they act in water bodies, like whether they will disperse in water or cling to sediment.” This is an important factor to consider.
Trabbic-Pointer continued. “Where a fish species obtains its food source should therefore influence the type of PFAS compound they will ingest. Short-chain perfluorinated carboxylic acids (PFCAs) ( C7 chain length), reportedly tend to impact or accumulate in non-bottom feeding fish, like salmon, because they disperse in water. This differs from lipophilic* persistent organic pollutants (POPs) like PCB and long-chain PFASs such as PFOS, that are more likely to cling to sediments, therefore primarily impacting bottom-feeders like catfish, carp and bass.”
*tending to combine with or dissolve in lipids or fats.
The Michigan Department of Health and Human Services (MDHHS) is responsible for setting fish consumption advisories in Michigan. “The MDHHS toxicologists develop Fish Consumption Screening Values (FCSV’s) based on a review of the best available scientific literature about the adverse health effects associated with a chemical of concern.” The MDHHS has established FCSVs for PFOS, mercury, total PCBs, dioxin, DDT, selenium, and toxaphene. What’s in your fish?
A fish caught in Clarks Marsh near Wurtsmuth AFB
contained nearly 10 million ppt of PFOS
PFAS in drinking water and fish
The EPA has set a Lifetime Health Advisory (LHA) for PFOS in water at 70 parts per trillion. A LHA refers to a concentration that is not expected to cause adverse health effects over a lifetime of consistent daily exposure at that level. This is based on a 70-kilogram adult (154 pounds) consuming two liters of water each day.
While setting the LHA, the EPA made it clear that the dominant source of human exposure to PFOS is from the diet. “The LHA, according to the agency, “was calculated using a relative source contribution (RSC) of 20%, which allows for other PFOS exposure sources to make up 80% of the reference dose.” Public policy has been consumed by restricting drinking water to levels under 70 ppt and even lower in several states.
PFOS is not included as an analyte in the U.S. Geological Survey (USGS) National Water Quality Assessment Program, and it is not monitored in water as part of EPA’s National Aquatic Resource Surveys. Meanwhile, PFOS has been reported in U.S. water bodies including the Tennessee River (144 ng/l) Mississippi River, (245 ng/l), Lake Erie (39 ng/l), and Lake Ontario (121 ng/l). ng/l = ppt.
The fish are poisonous because the water is poisonous and that is largely due to a lack of federal and state regulations to curtail the amount of PFAS churned out of wastewater treatment plants and deposited into the nation’s rivers.
Consumer items like couches, carpets, and mattresses, and military and industrial wastes containing PFAS settle into landfills. Over the years, decomposition and precipitation creates subterranean liquid leachate, like a giant coffee brewer. The landfill leachate is typically transported to wastewater treatment plants that simply pass the chemicals into adjacent waterways. The PFAS contaminate the sludge which is spread on farm fields that grow contaminated crops. Some of the sludge, euphemistically called “biosolids”, are packaged and sold as potting soil at big-chain hardware stores.
The EPA has failed to regulate the substances, although the agency says it recommends wastewater treatment plants begin testing for the substances. At a snail’s pace, the EPA is in the process of initiating formal rulemaking to establish effluent limitation guidelines. In the absence of a firm federal commitment, a handful of states are beginning to test wastewater discharges for the toxins. Now they are beginning to realize exactly how contaminated the rivers are. It’s a necessary first step.
What’s in your fish?
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Notes:
Michigan Safe Fish Guideline
https://www.michigan.gov/mdhhs/0,5885,7-339-71548_54783_54784_54785-266083--,00.html
Michigan Consumption Guidelines
https://www.michigan.gov/pfasresponse/0,9038,7-365-86512_88987_88989-481104--,00.html
Michigan limits drinking water to 16 ppt of PFOS.
https://www.michigan.gov/pfasresponse/0,9038,7-365-95571_99970---,00.html
EPA Drinking Water Health Advisory for PFOS
https://www.epa.gov/sites/production/files/2016-05/documents/pfos_health_advisory_final_508.pdf
Three mattresses, two box springs, two couches, and one chair
MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY FISH CONTAMINANT MONITORING PROGRAM 2019 ANNUAL REPORT A SUMMARY OF EDIBLE PORTION SAMPLING EFFORT AND ANALYTICAL RESULTS WITH RECOMMENDATIONS FOR UPDATES TO THE MICHIGAN DEPARTMENT OF HEALTH AND HUMAN SERVICES’ EAT SAFE FISH GUIDE - OCTOBER 2020 PDF