Rebuttal to the Scientists
Widely disseminated report on PFAS contamination
in freshwater fish downplays health risk
By Pat Elder
January 24, 2023
Landing a giant catfish from Maryland’s Piscataway Creek
The scientists are too conservative in the presentation of their findings. The fish are poisonous.
A new study by a team of leading scientists in the influential journal Environmental Research sounds an alarm about consuming freshwater fish in the United States because of high levels of PFAS toxins, especially the compound, per fluoro octane sulfonic acid, (PFOS). We’ve all seen the news reports. It’s good to see public attention focused on this pressing public health issue, but the researchers and press outlets buried the lead.
A handful of news sources reported the study’s finding that freshwater fish consumption can increase human blood serum PFOS levels but they didn’t go any further. Some news stories said PFAS in fish are likely to impact blood serum levels. Others said the transfer of PFAS from fish tissue to people’s blood serum is cited as a source of uncertainty.
The study is very clear. “A serving of fish with median levels of perfluorooctane sulfonic acid (PFOS) was calculated to increase serum levels 0.92 ng/mL if consumed once a year, 3.69 ng/mL if consumed four times a year, 11.07 ng/mL if consumed monthly, and 47.96 ng/mL if consumed weekly.”
There is a great and compelling public health crisis inherent in these blood serum concentrations.
The researchers reported a median (middle) value of 8,410 parts per trillion, (ppt) of PFOS from a total of 501 composites, corresponding to 1968 individual fish. They left out other databases, especially one from the state of Michigan that showed a mean (average) value of 80,000 ppt of PFOS in more than 2,841 fish. Amazingly, Michigan’s median value was 8,380 ppt, very close to the 8,410 ppt reported in the Environmental Research study. Fixing a study on median values misses the point, however, that there are plenty of highly toxic fish near military and industrial hotspots that have concentrations of hundreds of thousands, and even millions of parts per trillion of PFOS. This explains the wide gap between the median and mean values.
See our database, PFAS concentrations in 3,262 fish and oysters.
Highest concentrations of all PFAS in several
species, based on data collected from 3,262 fish and oysters (in parts per trillion)
Source – Military Poisons, America’s Fish are Contaminated with PFAS, 6/18/21.
Let’s go back to an important aspect of the study that is being largely ignored. One serving of fish with median PFOS levels was calculated to increase blood serum levels by 47.96 ng/mL if consumed weekly.
Ng/mL means nanograms per liter, or parts per billion, ppb. When we speak of blood we’re dealing with ppb. When we’re dealing with PFAS. it’s usually in ppt., at least, it ought to be so people can more easily understand the threat.
The Environmental Research study takes on added significance with the publication of Guidance on PFAS Exposure, Testing, and Clinical Follow-Up by the National Academies of the Sciences, Engineering, and Medicine in July of 2022. The authors mentioned the National Academies in passing, only to say that identifying and eliminating sources of human exposure to PFAS has become a priority for public health.
I served as a community liaison in preparing the National Academies report. They accepted our collective demand that the academies must encourage blood testing for PFAS for certain segments of the population and that they offer guidance to physicians for interpreting serum levels.
They rejected my specific demand that they issue warnings for consuming freshwater fish in specific locations. Here’s their lame rationale:
“It is important to acknowledge that communities across the United States have received guidance from state and federal agencies regarding PFAS exposure reduction, including advisories around consumption of drinking water and fish.
While it may seem obvious that avoiding exposure to sources of PFAS would result in reduced intake of PFAS and, in turn, lower internal PFAS levels, some caution in assuming that exposure and risk reduction would ensue is warranted.
For example, if one is advised to avoid locally caught fish because of known PFAS contamination in that fish, such avoidance could result in reduced exposure. However, if dietary fish is replaced by another food that is also high in PFAS, avoiding the fish may not result in lower PFAS exposure.
Another issue to consider is that avoiding one group of chemicals by changing diet or other behaviors can result in increased exposures to other chemicals.”
It sounds like The National Fisheries Institute or the Don’t Worry be Happy Consortium wrote this part.
To their credit, the National Academies is advising clinicians to offer PFAS blood testing to patients likely to have a history of elevated exposure. The august body says there may be increased risk of adverse health effects if the total of these seven compounds exceeds 2 ng/mL: PFOS, PFOA, PFHxS, PFNA, PFDA, PFUnDA, and MeFOSAA.
For patients with a serum PFAS concentration of 2 ng/mL or higher and less than 20 ng/mL, clinicians should encourage PFAS exposure reduction if a source of exposure is identified, especially for pregnant women. Within the usual standard of care clinicians should:
· Prioritize screening for dyslipidemia
· Screen for hypertensive disorders of pregnancy at all prenatal visits
· Screen for breast cancer
For patients with serum PFAS concentration of 20 ng/mL or higher, clinicians should perform the following tests during all routine visits:
· Conduct thyroid function testing (for patients over age 18) with serum thyroid stimulating hormone (TSH)
· Assess for signs and symptoms of kidney cancer (for patients over 45), including with urinalysis, and
· Assess for signs and symptoms of testicular cancer and ulcerative colitis.
The human crisis
A 2017 study by von Stackelberg, et. al found that approximately 17.6 million U.S. individuals consume three or more fish meals per week. Depending on the season, the incidence of individuals reporting consumption of self-caught species ranged between 10–12%.
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The Environmental Research study found
a serving of fish with median PFOS levels
was calculated to increase blood serum levels
by 47.96 ng/mL if consumed weekly
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Apparently, there are more than 2 million Americans who consume three or more self-caught fish weekly. For many, PFOS blood serum may approach 150 ng/mL They’re in trouble. This would have made an excellent lead for the Environmental Research study, rather than saying the fish are likely a significant source of PFOS.
Almost every fish in our database of 3,262 fish is dangerous to eat if we heed the limits in the EPA’s new drinking water advisory for PFOS. Of course, the EPA makes these grand proclamations but never seems to actually regulate anything.
(Thanks again to Teresa Gerade for her help in compiling this impressive database.)
It's not tough figuring out where PFOS comes from in the water.
St. Inigoes Creek in St. Mary’s City, Maryland, looking across the water to the Webster Field Annex of the Patuxent River NAS.
I live 2,000 feet across the creek from a navy base where they used PFAS in firefighting foams for 25 years. The oysters, (2,050 ppt tot. PFAS) crabs, (6,650 ppt PFAS) and rockfish (23,100 ppt PFAS) are severely contaminated, as you might expect.
There’s a strong correlation between PFOS levels in surface waters and in the seafood. Concentrations of PFOS in fish tissue can be expected to be several hundred up to several thousand times the ambient water levels.
In early February 2020 I tested the water in my cove after the daily foam subsided. The water had concentrations of 1,894 parts per trillion of the carcinogens at our beach. When press outlets picked up the story, the state’s top environmental official said the PFAS in the creek, if it existed, probably came from a landfill. (11 miles away.) See the first set of data below. In September of 2021 the thought occurred to me that I should test the foam. I found that the foam here contained 4,812 ppt of mostly PFOS. See the second set of data below.
Tests of the seawater taken by the state several hundred feet from my beach showed levels in the double digits. It is difficult trusting the state in these matters. After all, the Maryland Department of the Environment manipulated data when they tested Oysters in the creek. They say the oysters are fine. We say they’re not.
How do the fate and transport of these compounds work in surface waters? The Webster Field Annex of the Patuxent River Naval Test Center, the source of the contamination, was found to have more than 92,000 ppt of total PFAS, mostly PFOS in the groundwater that perpetually drizzles into the creek.
Foam data from Cyclopure.
The source of the contamination:
Firehouse 3 Webster Field
Highest Readings
PFOS 84,756.77
PFOA 2,816.04
PFBS 4,804.83
- Source: U.S. Navy
The Navy has refused to release more comprehensive data regarding the various concentrations of PFAS compounds in the surface water and groundwater on base. I demanded an apology from the Navy for contaminating my world but it has not been forthcoming.
Sometimes the carcinogenic foam looks like this when it leaves the Navy base and washes up on my property. The Navy has taken no responsibility for this environmental crime.
There is a great deal to be learned from studying the fate and transport of these chemicals and a lot of state and federal dollars ought to be spent trying to figure it out.
It’s not happening.
Water test kits are available for $79 from Cyclopure, a firm the DOD uses. Eurofins and others will test fish samples for $300, although the protocols are quite stringent. With the federal government and most state health and environmental departments on the sidelines, it is incumbent on activists to do this work, to rattle the cage. Human life is in the balance.
The new study points out that tens of thousands of manufacturing facilities, municipal landfills, wastewater treatment plants, airports, and sites where PFAS-containing fire-fighting foams (aqueous film-forming foam or AFFF) have been used - are potential sources of PFAS discharges into surface water.
This is where we must test the waters to cause a fuss. This is where people will suffer terrible deaths if they catch and eat too many fish from these locations. Nobody gives a damn.
Come to think of it, this would have made an excellent headline for the Environmental Research study. Nobody gives a damn.
Although this is not stated in the report, military burn pits draining into surface waters may result in fish containing nearly 10 million parts per trillion of PFOS. Frequent accidental discharges of PFAS in overhead fire suppression systems are a major cause of the contamination of fish at both military and civilian sites.
The military and certain industries also use copious amounts of PFAS in chrome plating, engine degreasing, and wire coating. These chemicals are typically dumped into our rivers. No matter how they’re “disposed of” they’ll haunt humanity forever.
The crime is inherent in manufacturing the stuff in the fist place.
The EPA's interim drinking water health advisory value for PFOS assumes that 80% of all PFAS exposure comes from non-drinking water sources. This truth fails to resonate. It’s pretty frustrating. Almost all of the PFAS related propaganda being churned out by the DOD, EPA, and state environmental and health agencies overwhelmingly address PFAS in drinking water and pretty much leave out the other 80%. The drinking water has a relatively quick fix. The other pathways to human ingestion do not.
Fish and water in Maryland
Several folks who live near Joint Base Andrews in Maryland have tested their water supplied by the Washington Suburban Sanitary Commission and report the total PFAS levels in their drinking water in the low single digits. It’s bad, but it’s miniscule compared to the fish.
Maryland is a beautiful state, except for when it comes to this. Photo shows the source of Piscataway Creek at the boundary of Joint Base Andrews. Notice the yellow boom used to keep oil and other contaminants from noticeably affecting the water.
The fire pits and contaminated soils at the Home of Air Force One perpetually belch out astronomical levels of PFAS into Piscataway Creek. We tested the surface water where the creek flows out of the base and found nearly 3,000 ppt of the substances in the water. The state also found comparable levels.
Red Dot – Maryland reported finding 94,200 ppt of PFOS in the filet of a Largemouth Bass at this location.
Blue Dot - Maryland reported 417,000 ppt in a Redbreast Sunfish here.
Washington is 6 miles north. George Washington’s Mount Vernon is on the Virginia side of the river. Joint Base Andrews is located about 4 miles up Piscataway Creek. This area was the center of the Piscataway nation that preceded the arrival of Maryland’s first settlers. In March of 1634 colonists from England met the Piscataway Chief (Tayac) at this location. The Piscataway Indians are saddened to see the destruction of their ancestral fishing grounds. Piscataway Indian Matriarch Julie Tayac Yates is deeply distraught. “It’s devastating to us. The fish are poisoned.” She said fish are laying dead along the banks of the Anacostia River in Washington.
After sustained public pressure, the Maryland Department of the Environment issued its only PFAS-related fish advisory in the state for Piscataway Creek. The “advisory” has no effect as soon as the fish enter the larger Potomac River. The agency recommends that adults limit their consumption of Largemouth Bass to 3 meals per month. The EPA health advisory for PFOS in drinking water is .02 ppt, so the concentrations of PFAS in the filet of one fish is 4.71 million over that limit. Charter fishing boats bring customers to these waters to fish for Largemouth Bass and other species of fish.
Pregnant women should be warned not to eat the fish. PFOS causes preeclampsia, a leading cause of maternal and perinatal morbidity and mortality worldwide, affecting up to 8% of all pregnancies. Does the public health community think this was only caused by obesity and cheeseburgers?
Another possible headline idea
A Pumpkinseed fish caught from the waters draining from the shuttered Wurtsmith AFB in Michigan contained a concentration of 9,580,000 ppt of PFOS. A serving of fish this size is pure poison.
The tiny sample shown here weighs .08 gram
8-ounce serving = 227 grams
9,580,000 ng/kg (poisoned Wurtsmith fish) = 9,580 ng/g
9,580 x 227g = 2,174,660 nanogram dose of PFOS from one 227 g serving.
The tiny portion contains a dose of 173,972 nanograms of PFOS
What’s in your fish?
What’s in your baby?
The Water
The EPA’s Lifetime Health Advisory (LHA) for PFOS is based on the exposure of a 70-kg adult consuming 2 liters of water per day with a concentration of .02 ppt of PFOS.
1 part per trillion (ppt) = 1 nanogram per liter (ng/l)
.02 ng/l in 2 liters daily creates a dose (as opposed to a concentration) of .04 nanograms daily.
02 / 2 = x / 39.6 (from the study – water consumed monthly)
·Drinking 39.6 L would create a dose of .992 nanograms monthly
.992 nanograms monthly x 12 = 11.9 nanograms yearly.
The .08 gram portion above contains a dose of 173,972.8 nanograms of PFOS
The dose of PFOS in the tiny portion of fish shown on the scale is 14,619 times over the EPA’s yearly drinking water dose.
This might have been a great headline for the newspapers:
The fish are poisonous! Nobody gives a damn.
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Special thanks to the Downs Law Group for their continued financial support. We couldn’t continue to create these reports at this pace without their help.
The firm is working to create a multi-base coalition to provide legal representation and blood testing 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. (2.1 K members and growing rapidly.)
Military Poisons and the Women’s League for Peace and Freedom, US are continuing to raise funds to cover the costs of PFAS seafood testing in Maryland, Washington, DC, Virginia, and Florida. You can make a tax-deductible contribution here. What’s in your fish? What’s in your blood?