Time to take action to protect people from PFAS contaminated fish

We have the data showing serious public health threats

 By Betsy Southerland for the Environmental Health News

The federal Clean Water Act was established by Congress in 1972 to ensure that the nation’s waters would be “fishable and swimmable.”

Today, more than 50 years later, that goal is unachievable because of unregulated discharges of toxic PFAS chemicals into rivers, lakes and streams. These hazardous chemicals have contaminated freshwater fish in waters throughout the continental 48 states. It’s past time to regulate PFAS to protect the health of everyone who drinks water and consumes fish from contaminated waters.

PFAS-contaminated freshwater fish 

PFAS, short for per- and polyfluoroalkyl substances, is a class of more than 9,000 chemicals with strong carbon-fluorine bonds that make them highly persistent in the environment. 

They are used in hundreds of industrial and consumer products that ultimately result in releases into the environment from manufacturing facilities, municipal landfills, wastewater treatment plants, airports and other sites where PFAS-containing fire-fighting foams have been used. 

The adverse health effects of the PFAS chemicals studied to-date include immune system suppression, increased risk of cancer, thyroid disease, high cholesterol, and reproductive and developmental impairments.

The U.S. Environmental Protection Agency (EPA) has been monitoring PFAS chemicals in fish since 2008 through the National Rivers and Streams Assessment, and since 2010 under the Great Lakes Human Health Fish Fillet Tissue Study. 

These monitoring studies have found detectable levels of at least 5 different PFAS chemicals in most fish sampled, even though the fish were collected from randomly selected sites instead of known or suspected PFAS hotspots. A new study uses the EPA’s recent fish tissue data to estimate the concentrations of PFOS – the most frequently found PFAS chemical – in the blood of people who consume fish. 

The study estimates that eating only one meal a year of freshwater fish can elevate blood serum concentrations above 2 Nanograms per milliliter (ng/mL), the level at which the National Academies of Sciences, Engineering and Medicine (NAS) recommends reducing PFAS exposure. 

The study also found that eating freshwater fish weekly can elevate concentrations above 20 ng/mL, the level at which the NAS recommends clinicians test for thyroid function, kidney and testicular cancer, and ulcerative colitis.

In July 2022, NAS published guidance on PFAS exposure, testing and clinical follow-up that advises clinicians to offer PFAS blood testing to patients likely to have elevated exposure, and to test for certain health effects if blood serum concentrations for PFOS and other PFAS chemicals exceed the concentration of 2 ng/mL.

We need PFAS fish consumption advisories 

Given their widespread use and persistence, it is not surprising that PFAS chemicals have contaminated fish throughout the country. What is surprising is that federal and state governments have been so slow to regulate these toxic chemicals. 

The immediate priority should be for states to develop fish consumption advisories that recommend consumption limits based on existing EPA data from and state monitoring programs. 

Only 14 states have issued fish consumption advisories for PFAS. The Great Lakes states should consider developing a single advisory applicable to all the lakes since the EPA data show Great Lakes fish generally have higher PFAS concentrations than the fish from rivers and streams in other parts of the country.

Related: Just one meal of caught fish per year is a significant dose of PFAS

The EPA and the states must focus on eliminating PFAS releases into the environment. The EPA is working on rules to regulate PFAS discharges from two major industries and from landfills, but these rules will take several years to put in place. 

States should not wait for national rules. They should use their authority to set PFAS limits in permits for industries that discharge directly into their waters or into municipal wastewater treatment plants.

PFAS monitoring

More PFAS monitoring —using better analytical methods — is also essential. The EPA and states should monitor surface water, wastewater, sewage sludge and fish tissue using the EPA’s new analytical method, which allows detection of 40 individual PFAS chemicals. 

Wastewater samples should be analyzed using the EPA’s new method for total adsorbable organic fluorine, which indicates the presence of additional PFAS chemicals beyond the 40 detectable ones. 

The EPA has no plans to develop a total adsorbable organic fluorine method for fish tissue, but it is needed so the potential for additional PFAS contaminants can be evaluated.

The EPA should also prioritize the development of non-cancer and cancer toxicity levels for PFAS chemicals frequently found in freshwater fish in order to determine safe consumption levels. 

To date, the EPA’s monitoring programs have found five PFAS chemicals in most fish (PFOS, PFUnDA, PFDA, PFDoA, and PFNA), but has only developed toxicity levels for PFOS. 

If critical data needed for assessing the toxicity of the other PFAS chemicals are missing, the EPA should use its authority under the Toxic Substances Control Act (TSCA) to require industry to provide that data. 

Finally, the EPA should accelerate use of its TSCA authority to restrict or ban the existing uses of PFAS and to prevent future uses of these toxic chemicals.

The EPA and states have years of data showing that PFAS contamination of our nation’s waters poses serious public health threats. There is no longer any merit to the argument that further study is needed before we take action to protect our drinking water and fisheries. We must act to protect people’s health.

Betsy Southerland is the former Director, Office of Science & Technology, U.S. Environmental Protection Agency Office of Water.