FDA Says PFAS in Fish not a Problem

Evidence suggests otherwise

By Pat Elder
September 19,  2021

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Has the FDA been failing to protect public health from PFAS in fish?

Despite overwhelming evidence that the nation’s fish are highly contaminated with PFAS, a new U.S. Food and Drug Administration (FDA) report says PFAS levels in fish do not represent a human health concern. The FDA says it has tested 300 food samples, including fish, since 2019 and none have contained dangerous levels of PFAS. 

“The US food supply is among the safest in the world, and the available scientific evidence does not support avoiding particular foods because of concerns regarding PFAS exposure,” says the FDA.

The Biden-Woodcock FDA “advises consumers against avoiding certain foods over PFAS concerns.”  It’s a tricky statement. You may want to read it a second time. The FDA is a cheerleader for the corporate interests that supply our food.  Let’s look at how the Europeans are regulating PFAS in fish.

The Europeans say ‘Fish meat’, ‘Fruit and fruit products’ and ‘Eggs and egg products’ contribute the most to PFAS exposure. Effects on the immune system were considered the most critical. Since accumulation over time is important, a tolerable weekly intake of  4.4 nanograms per kilogram of weight (ng/kg) per week was established.

https://www.efsa.europa.eu/en/efsajournal/pub/6223 

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The Europeans regulate PFAS in fish. Generally, the U.S. does not. In short, the Europeans say someone weighing 150 pounds  can “safely” consume about 300 nanograms per week of PFAS chemicals. We can put this into meaningful perspective by analyzing results of fish testing conducted by the Michigan Department of the Environment.

Michigan tested 2,000 fish from around the state and found the average fish contained 80,000 parts per trillion (ppt) of PFOS. PFOS is Per fluoro octane sulfonic acid, perhaps the deadliest variety of PFAS.

A meal of the average, tasty, pan-fried Michigan fish weighing 8 ounces with a concentration of 80,000 ppt of PFOS contains 18,160 nanograms of PFAS.
[80,000 ppt = 80 ppb = 80 ng/g x 227 g (8 oz)  = 18,160 ng] 

Eating one fish  exceeds the European weekly limit 60 times over.

The highest concentration of a Michigan fish, caught near the former Wurtsmith Air Force Base in Oscoda, contained 10 million ppt, while the FDA looks the other way. Eating 8 ounces of this fish would exceed the European limit by 7,500 times.

Michigan follows the Great Lakes Consortium for Fish Consumption Advisories

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Levels of PFOS in Fish and Corresponding Meal Advice Categories
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

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Michigan limits PFOS in drinking water to 16 ppt,  while Minnesota, which also follows the guidelines set by the consortium, limits PFOS in drinking water tp 15 ppt..

Michiganders may not consume high levels of PFAS in drinking water but it’s OK if they consume astronomical levels by eating the fish. Why is that so?

Maryland’s Chesapeake Bay

A spokesman for Maryland’s Department of the Environment said a perch, caught in the Chesapeake just off-shore of the Naval Research Laboratory - Chesapeake Bay Detachment, could be consumed by the public 48 times a year while posing little health risk. The fish contained 9,470 ppt of PFAS which is 7 times greater than EFSA’s weekly limit. Here’s the science generated by EFSA  Maryland has not published the science behind its recent statement.  

Michigan and other states are primarily concerned with the consumption of PFAS in drinking water rather than food. 86% of the PFAS in our bodies comes from the food we eat, especially fish caught from contaminated waters, according to studies. 

Let’s put these frightening PFAS concentrations in fish into perspective:

The EPA’s  Lifetime Health Advisory (LHA) for drinking water is based on the exposure of a 70-kg (154 pound) adult consuming 2 liters of water per day.

The EPA says it’s OK to consume this much water containing 70 nanograms of PFAS per liter per day.

So, a 154 pound adult can consume up to 140 nanograms of PFAS in drinking water in a day.

The EPA says the LHA of 70 ppt for PFAS is calculated to account for 20% total PFAS exposure from all sources.

So, the EPA is allowing for a total consumption of 700 ng of PFAS from all sources. [20% of 700 ng = 140 ng]  

The average serving of fish in Michigan contains 18,160 ng of PFAS. (above)  The FDA, with its army of scientists, says the available scientific evidence does not support avoiding particular foods because of concerns regarding PFAS exposure. Meanwhile,  non-governmental organizations call for a limit of 1 ppt of PFAS in drinking water.

We must have a conversation about these chemicals.

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Foam in Chesapeake region of Maryland contains nearly 5,000 parts per trillion of PFAS