The EPA’s PFAS Strategic Roadmap falls short of regulating fish; calls for more study

By Pat Elder
October 18, 2021

The EPA published its PFAS Strategic Roadmap today. I’ll briefly address the brief segment on fish.

I’m pleased the EPA says all of the fish in the Great Lakes region contain PFAS. Certainly, it knows the state of Michigan tested more than 2,000 fish and found the average fish contains 80,000 parts per trillion (ppt) of PFOS. The state regulates the same chemical in drinking water at 16 ppt.

I’m happy the EPA will collect fish tissue throughout U.S. lakes, although there is already enough data available nationwide to promulgate regulations. An analysis by Military Poisons of PFAS concentrations in 3,262 fish and oysters from rivers and lakes in 48 states shows that America’s seafood is toxic.

Coming at this from the perspective of the military’s role in this contamination, most of the sewage outflows from military installations run into creeks and rivers, not lakes.  Military sewage is known to be full of PFAS.

The EPA says it wants to better understand “unique impacts on subsistence fishers.” I’m happy to see that, too, although there aren’t many subsistence fishers around here.  I’m more worried about women who are pregnant or may become pregnant. There are plenty of them in Southern Maryland and a lot of them love Rockfish from the Chesapeake Bay.

I’m also happy to see the EPA working with the CDC to see if certain PFAS compounds in human blood “could be associated with eating fish,” even though there’s already a ton of science out there saying so.  It’s good to generate more, although there’s enough data to get going on regulating the stuff.

I have a few questions for the EPA:

The Great Lakes Consortium has established these levels of PFOS in fish with corresponding meal frequency advice for all populations:

PFOS in Fish (ppt)                  Meal Frequency

≤ 10,000                                   Unrestricted 
10,000-20,000                       2 meals/week
20,000-50,000                       1 meal/week
50,000-200,000                    1 meal/month
> 200,000                               DO NOT EAT

Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, and Wisconsin all follow this advisory.

Are you all OK with this? Is it OK to attend an all-you-can eat fish fry with fish containing 10,000 ppt of PFOS?  Is it ever OK to consume a fish containing  a concentration of 200,000 ppt?  Is it OK to consume any PFOS?