# Supplemental Information to Support the Fish Consumption Rates Technical Support Document

July 20, 2012

Toxics Cleanup Program Washington State Department of Ecology Olympia, Washington



# Contents

Estimating Annual Fish Consumption Ra tes Using Data from Short-Term Surveys

Recreational Fish Consumption Rates

Health Benefits and Risks of Consuming Fish and Shellfish

Chemical Contaminants in Dietary Protein Sources

Salmon Life History and Contaminant Body Burdens

# Technical Issue Paper



# Estimating Annual Fish Consumption Rates Using Data from Short-Term Surveys

# Technical Issue Paper



# Estimating Annual Fish Consumption Rates Using Data from Short-Term Surveys

July 20, 2012

Toxics Cleanup Program

Washington State Department of Ecology

Olympia, WashingtonTechnical Issue Paper July 20, 2012 Page i 

# Table of Contents

Page

List of Tables ................................................................................................................ .................. ii

Introduction .................................................................................................................. ....................1

Limitations of short-te rm dietary studies ..................................................................................... ....3

I. AMEC summary of short-term study limitations ..............................................................3

II. Comparison of short-term a nd longer-term survey data ....................................................4

III. Consumption frequency vs. c onsumption rate estimates ..............................................6

Quantitative methods for adjusting sh ort-term dietar y recall data ...................................................7

I. Adjustment of consumption frequency estimates ..............................................................7

II. Adjustment of consumption rate estimates ........................................................................8

III. Statistical reanalysis of national fish consumption data .............................................10

Summary ....................................................................................................................... .................12

References .................................................................................................................... ..................13Page ii July 20, 2012 Technical Issue Paper 

# List of Tables

Page

Table 1. Mean population intake, consumer-only in take, and percent consumers of fish after 1, 3, 5, 7, 10, and 14 days of data collection ..........................................................8

Table 2. Adjustment of short-term (3-day) to long-term estimates and comparison to longer-term (14-day) fish consump tion rates (Lambe et al. 2000b) ...............................9

Table 3. Adjustment of short-term (24-hour recall) to long-term estimates and comparison to long-term fish consumption rates - Suquamish Tribe study .......................................9

Table 4. Adjustment of short-term (2-day recall) to long-term estimates and comparison to long-term fish consumption rates – General Population (CSFII Data) ........................10

Table 5. Adult U.S. National Fish Consumption Rates, Consumers Only (From NHANES 2003–2006) ...................................................................................................................1 1Technical Issue Paper July 20, 2012 Page 1 

# Introduction

Ecology received comments on the draft Fish Consumption Rate Technical Support Document (TSD) expressing concern with the way short-te rm fish consumption surveys were used to extrapolate consumption hab its over the long term.

In some populations, fish are consumed fre quently and in large quantities (USEPA 2011). Estimating the rate of fish consumption for high-fish consuming groups is important; these groups may be at greater health risk if the fish they consume are from contaminated water

bodies.

Studies to estimate fish consumption rates for sp ecific target populations are generally one of two types: creel surveys and interviews/mail surveys. 1 In a creel survey, fishermen are asked, among other things, how many fish they have ca ught and the number of family members with which they will share their catch. Creel survey data do not represent usual behavior because a fisherman may not have the same fishing succe ss over time. As a result, results from creel

studies have often been mi sinterpreted (USEPA 2011).

Mail surveys, personal inte rviews, or telephone interviews ask participants to recall how much each family member ate over a certain period of time. The recall period determines whether the survey characterizes long-term (i.e., usual) intake or shor t-term consumption. For risk assessment, estimates of long-term consump tion are needed, but l ong recall periods are associated with generally higher re porting errors (i.e., it is harder for people to remember what and how much they ate over a longer period of time). Short-term studies, on the other hand, may underestimate the number of people who cons ume fish and may overestimate long-term consumption. This is particularly true for high en d consumers, because short-term studies tend to underestimate the number of days when respondents do not consume fish.

Ebert et al. (1994) describe the problem as follows:

Although an individual may consum e at a rate in the upper 5 th percentile of the distribution during a specific two-week peri od, it is not necessarily true that the same angler will be an upper 5 th percentile consumer throughout the season. Rather, that individual may fish only occasionally , may only be interested in consuming certain species when they are available, and is not likely to be equally successful on every trip. The same uncertain ty exists for anglers who have had no activity or success during a single two-week period but may, in fact, have different behavior at other times. It is likely that activity and consumption by individual anglers are highly variable through the season due to weathe r, fishing regulations , differences in species availability, and flu ctuations in success rates for the individual angler. Although, much of this variability tends to be averaged out in longer-term estimates, extrapolation from single-day or short-term measurements can result in an over- or

1 Additional information on fish consumption survey methodology is provided in Consumption Surveys for Fish and Shellfish: A Review and Analysis of Survey Methods (USEPA 1992) and Gui dance for Conducting Fish and Wildlife Consumption Surveys (USEPA 1998).Page 2 July 20, 2012 Technical Issue Paper underestimation in the inter- individual variation of annua l intake. Thus, short-term surveys may be useful for characterizing the central tendency in consumption rates

but not the variance wi thin the population.

Attempts to account for the variance and uncertain ty associated with the use of short-term consumption studies have generally included qual itative evaluation of data from a range of sources, coupled with consideration of the intended use of the data.

In the draft Fish Consumption Ra te TSD, Ecology identified four fish consumption surveys as appropriate for use in establishi ng a technically defensible defa ult fish consumption rate for Washington:

 Fish Consumption Survey of the Umatilla, Nez Perce, Yakama, and Warm Springs Tribe of the Columbia River Basin (Columbia Ri ver Inter-Tribal Fish Commission [CRITFC] 1994).

 Fish Consumption Survey of the Tulalip a nd Squaxin Island Trib es of the Puget Sound Region (Toy et al. 1996).

 Fish Consumption Survey of the Suquamish Indian Tribe of the Port Madison Indian Reservation, Puget Sound Region (The Suquamish Tribe 2000).

 Asian and Pacific Islander Seafood Consum ption Study, King County (Sechena et al. 1999).

These four studies relied on personal interviews and food frequency surv eys to obtain dietary recall information. The Suquamish survey quan tified consumption rates using both a 24-hour recall and a food frequency survey.

The draft TSD also included information on esti mated United States per capita fish consumption. These national fish consumption rates were ba sed on participant responses to 24-hour dietary recall surveys conducted on two nonconsecutive days.

Public review comments on the draft TSD identif ied several issues of concern. Many reviewers noted correctly that the length of the survey period can have a significant effect on the resulting fish consumption rates. Some re viewers suggested that estimate s of annual fish consumption rates be adjusted to account for lifetime cons umption. One reviewer wa s concerned about the difference in mean consumption rates measured in the 24-hour recall por tion of the Suquamish survey compared to the food frequency survey.

This Technical Issue Paper discu sses the limitations of using shor t-term studies to estimate longterm consumption, and presents options for adju sting short-term results to better characterize long-term consumption habits. It is a targeted examination of the issues raised by review comments received on the draft Fish Consumption Ra tes TSD, and was prepared within a limited time frame. Therefore, it may not include al l available information on this subject.Technical Issue Paper July 20, 2012 Page 3 

# Limitations of short-term dietary studies

USEPA (2011) has acknowledged that short-te rm dietary records pr esent problems when estimating long-term consumption rates. AMEC (2003), in a paper prepared for the Northwest Pulp and Paper Association, summarized the lim itations of short-term dietary studies. Key elements of this summary are presented below.



## I. AMEC summary of short-term study limitations

The length of the recall period in dietary studies ca n significantly affect the estimate of long-term fish consumption. For example, dietary data co mpiled by the U.S. Department of Agriculture (USDA) were collected from survey particip ants during two non-cons ecutive 24-hour periods (USEPA 2000). Because of the way in wh ich sampling was conducted, the actual fish consumption behaviors reported ar e strongly biased toward those respondents who consume fish with a high frequency.

All of the individuals in cluded as fish consumers in the USDA estimate consumed fish at least once during the 2-day sampling period. To use th ese data to estimate long-term consumption rates, it is necessary to assume that the cons umption behavior that oc curred during the 2-day period is the same as the consumption behavior that occurs throughout every other 2-day period during the year. Thus, if an i ndividual reported eating one fish meal during the sampling period, the extrapolation necessary to estimate long-ter m consumption requires the assumption that the

individual continues to eat fi sh with a frequency of once ev ery two days, or as many as 183 meals per year. If an individual eats one-half pound (227 grams) of fish per meal, this results in a consumption rate of 114 grams/day.

However, the individual who consumed fish durin g that sampling period may not actually be a regular fish consumer. In fact, that fish meal ma y have been the only fish meal that the individual consumed in an entire year. Thus, that person’s fish consumption rate would be substantially overestimated. Unfortunately, because of the way that the USDA data are collected, there is no way to determine if the behaviors reported by survey respondents during the sampling period were representative of their l ong-term behaviors. Thus, for th e “consumers” in the population who were reported in these data, the reported c onsumption rates must have a minimum of one meal every two days.

Conversely, individuals who di d not consume fish during th e 2-day sampling period were

assumed to be non-consumers of fish when in stead, those individuals may have been fish consumers who coincidentally did not consume fish during the 2-day sampling period. Because there are no data on which to base consumption estimates for these individuals, they must be assumed to consume 0 gram/day. However, they may in fact consume fish with a frequency ranging from as little as 0 meals pe r year to as much as one meal per day (or even more than one meal per day) on all days except the two that USDA conducted the survey. As with the high consumers identified in the USDA database, ther e is no way to determine whether 0 gram/day consumers are actually non-consumers or just in dividuals who consume with less frequency than once every two days.Page 4 July 20, 2012 Technical Issue Paper To demonstrate the effect that the length of the sampling period can have on resulting fish consumption rates, the findings of other short-term dietary studies can be compared to long-term studies. For example, a USDA su rvey reported by Mertz and Kelsay (1984) asked 29 people to track the types and amounts of food they ate for a one-year period. Because the daily dietary records kept by the study subjects could be cond ensed into 52 discrete one-week periods, it was possible to investigate the rela tionship between annual and weekly average fish consumption rates. The mean annual fish consumption rate fr om the Mertz and Kelsay (1984) survey data was estimated by summing the entire quantity of fish consumed by each survey respondent during the year and dividing by 365 days. The mean per capita “365-day” fish consumption rate developed using this approach was 26 grams/day. In addi tion, the mean daily fish consumption rate averaged over a one-week period, the “7-day” fi sh consumption rate, was estimated to be 26 grams/day. Thus, the mean per capita consump tion rate did not appear to be affected substantially by the recall pe riod. Although this study included only 29 participants, results suggest that the mean is a fairly robust and meaningful measure of the average consumption rate, regardless of the survey period.

The same cannot be said, however, of the upper percentiles of the fish consumption rate distribution. When comparing the 7-day intake rates collected by Mertz and Kelsay (1984) with the 365-day intake rates, the upper percentiles were very different . For example, when looking at the 7-day intake rates, the maximum value re ported is 228 grams/day. However, when the 365- day averages are developed, by combining all of the 7-day periods throughout the year, the maximum consumption rate is 78 grams/day. Thus, the short-term estimate overstates the actual long-term maximum by a factor of thr ee. Similarly, when comparing the 95 th percentiles reported for these two periods, the 7-day daily average (87.7 grams/day) s ubstantially overestimated the 365-day average (51.1 grams/day) by 72 percent, again demonstrating th at the 7-day recall period did not provide a reliable surrogate for long-term consum ption behavior at the upper end of the distribution. It is very li kely that extrapolating from a 2-day sampling period would further overestimate long-term behavior.

This problem has also been demonstrated and discussed by Ebert et al . (1994), who compared reported rates of self-caught fish consumption based on the duration of the recall period. Ebert et al. reported that when a one-day recall period was used by Pierce et al. (19 81) and Puffer et al. (1981), “high-end” (95 th percentile) intakes ranged up to 339 grams/day for consumers. When Pao et al. (1982) used a 3-day recall period, the 95 th percentile intake for consumers was reported to be 128 grams/day. Using a 30-day reca ll period, Javitz (1980) reported a 95 th percentile intake of 42 grams/day, and when a recall period of one year (365 days) was used (Fiore et al., 1989; Ebert et al. 1993), the 95 th percentile estimates for sport-caugh t fish consumers ranged from 26 to 37 grams/day.



## II. Comparison of short-term and longer-term survey

data

USEPA has acknowledged that shor t-term dietary records are problematic when attempting to estimate long-term rates of consumption. In its Exposure Factors Handbook (USEPA 2011), USEPA stated that “percentiles of the distribution of average daily intake reflective of long-term consumption patterns cannot in general be estima ted using short-term (e.g., one week) data. SuchTechnical Issue Paper July 20, 2012 Page 5 data can be used to adequately estimate mean av erage daily intake rates (r eflective of short- or long-term consumption); in addition, short-term data can serve to validate estimates of usual intake based on longer recall.”

As part of its compilation of fish consumption survey data for the 2011 Exposure Factors

Handbook , USEPA obtained the raw data from a study of Michigan sport anglers that included both a long-term and short-term component (t he West et al. 1989 study). The long-term component asked respondents about the frequency of fish meals during each of the four seasons, among other questions. The short-term component was a recall survey of fish meals consumed by all household members during the past 7 days. USEPA used the short-term data to validate the results of the longer recall part of the survey. The results of the analysis showed that there was general agreement between mean consumpti on estimates made using the 1-year recall and estimates made using the 7-day recall (14.4 gr ams/day and 14.0 grams/day for consumption of sport-caught fish, respectively), although there was some tendency for infrequent fish consumers to underestimate their usual frequency of fish consumption.

A follow-up survey of Michigan sport anglers was conducted in 1993 (West et al. 1993); this survey used a one-week recall pe riod. The mean consumption rate for sport-caught fish was 16.7 grams/day, similar to the 1989 study. In addi tion, USEPA (1995) calculated an overall 95 th
percentile fish consumption rate based on the 199 3 7-day recall data; this value, 77.9 grams/day,

was about double the 95 th percentile estimated using the yearlong consumption data from the 1989 Michigan survey (38.7 grams/day). USEPA states that “because this survey only measured fish consumption over a short (1 week) interval, the resulting distributi on will not be indicative of the long-term fish consumption distributi on, and the upper percentil es reported form the [1995] U.S. EPA analysis will likely considerably overestimate the corresponding long-term percentiles” (USEPA 2011).

In the Suquamish Tribal fish consumption survey, one of the four studies selected as appropriate for use in developing a Washingt on State default fish consump tion rate in the draft TSD, respondents provided information about fish c onsumption frequency during the period when specific fish and shellfish were “in season” and “during the re st of the year.” In addition, respondents were asked about fish or shellfish th ey had consumed in the previous 24 hours. All respondents indicated that they are consumers of seafood; how ever, 55 percent of respondents indicated that they had not consumed fish or shellfish in the previ ous 24 hours. Correspondingly, the mean consumption rate measured in the 24 -hour recall portion of the study (1.5 g/kg-day) was nearly half the consumption rate estimated in the food frequency and portion size survey (2.7 g/kg-day). The authors concluded that “low er mean consumption rate for dietary recall suggests that a brief set of questions does not uncover al l forms of consumption.”

This conclusion is not consistent with the West et al. (1989) st udy described above, or with other literature on dietary surveys, which show that wh ile a 24-hour recall does not capture day-to-day variability, on a population level it may provide a more accurate account of the consumption rate than the food frequency survey (Exponent 2012). Some studies indicate th at longer-term diet history surveys, such as the Suquamish food fre quency survey which looked back over a year, may be more likely to overestimate usual c onsumption than a 24-hour recall (Rasanen 1979). Others indicate that the upper percentile estimate s of fish and shellfish intakes based on a 30-day daily average are lower than thos e based on two- or three-day da ily averages (Tran et al. 2004).Page 6 July 20, 2012 Technical Issue Paper 

## III. Consumption frequency vs. consumption rate

estimates

Dietary studies may be conducted for two pur poses: (1) to determine the proportion of individuals in a population who are at risk, or (2) to evaluate long-term intake rates of a specific food or food group.

To determine the proportion of i ndividuals in a population who are at risk, habitual intake must be estimated (Rutishauser 2005). In this case, a single 24-hour recall surv ey is not adequate. Instead, at least two, preferably non-consecutive, days of dietary recall data are needed. Thus, a survey such as the USDA 1994–1996 and 1998 C ontinuing Survey of Food Intakes by Individuals (CSFII) may be appropriate for evalua ting the proportion of individuals in the U.S. population who consume fish; however, this will not provide reliable es timates of individual consumption rates. This lim itation is recognized by the au thors of the USEPA (2002) Estimated Per Capita Fish Consumption in the United States (which used the CSFII data), who note that the limited time period for collecting informa tion on dietary intake does not produce habitual

intake estimates. Because short-term studies do no t reflect habitual intake , the results of the 24- hour recall portion of the four principle studies used by Ecology were used to qualitatively evaluate the habitual intakes reported in the resu lts of the longer-term food consumption surveys, rather than to develop a pr oposed fish consumption rate.

To evaluate long-term (habitual) intake of a specific food or food group, a food frequency survey is preferable to short-term di etary recall data (Rutishauser 2005). One disadvantage of selfadministered surveys (such as mail surveys) is of ten the lack of detail th at is provided. Using trained interviewers to collect diet histories rather than relying on self-administered questionnaires can overcome this problem. The surv eys used in the four principle studies used by Ecology were all conducted by personal interview.

Another disadvantage of food frequency surveys fo r general nutrition studie s is the inability to accurately track ingestion of a large range of food types. Ru tishauser (2005) recommends restricting the use of fo od frequency surveys to estimating long-term intake for a limited number of foods. The surveys used in the four principl e studies used by Ecology included only questions regarding patterns of hab itual seafood consumption.

Basiotis et al. (1987) conducted a statistical analysis on data collected in the year-long USDA

Beltsville Human Nutrition Research Center stu dy. The analysis determined the average number of days of dietary intake data needed in order to estimate a “t rue” average of intakes for a group or for an individual. (In this case, the parameters of interest were ener gy and various nutrients.) An estimate was determined to be “precise” if it fell within + 10% of the average from the 365- day dietary study for that individual or group, 95% of the time. The number of days required varied significantly by the numbers of individuals in the group, as well as by the nutrient of interest. For estimating “true” aver age daily energy intakes, the aver age number of days of intake data required ranged from 27 to 35 for individuals, with only three days of data required for a

group.Technical Issue Paper July 20, 2012 Page 7

# Quantitative methods for adjusting shortterm dietary recall data

I. Adjustment of consumption frequency estimates

Carrington and Bolger (2001, 2002) developed a math ematical model to estimate the number of annual servings from short-term dietary survey s. Their model is based on the hypothesis that using results from short-term surveys to proj ect food consumption over longer periods of time may overestimate the amount of food individu als consume and underestimate the number of

individuals who consume the food.

First, the algorithm decreases the number of seafood consumption events and increases the number of consumers using a Long-Term to Short-Term Consumer Ratio (LTSTCR). Second, the algorithm adjusts the LTST CR for frequent seafood consumer s using an exponential function

that reduces the LTSTCR as the number of servi ngs increases. An example of this function for adjusting daily serving data to proj ected annual servings is provided as:

LTS = STS x 365

LTSTCR ( α /DS) β

Where

LTS = projected annual serv ings (long-term estimate) STS = daily servings from short-term survey LTSTCR = long-term to short-term consumer ratio DS = daily serving

α = adjustable parameter inversely rela ted to consumption frequency to keep average consumption frequency constant β = adjustable parameter to determine th e shape of the functi on and keep the low

end of the curve consistent with short-term estimates

Estimates based on this model were validated usi ng the resulting seafood consumption rates in an exposure model to relate seafood co nsumption to levels of mercury in blood and hair. Using data from the 1989–1991 CSFII (USDA 1998), which record ed consumption over a 3-day period, the projected annual seafood serv ings were estimated as:

LTS = D3S x 122

LTSTCR ( x /D3S)

Where

D3S = 3-day servings from short-term survey LTSTCR = long-term to short-term consumer ratio = projected % c onsumers in the total population ÷ % consumers recorded in short-term survey = 70 to 90% ÷

33.5% = 2.1 to 2.7

x = exponential slope set to maintain the mean per capita consumption near the value measured in the short-term surveyPage 8 July 20, 2012 Technical Issue Paper In this assessment, a value of 1.5 was used for x to result in a mean per capita seafood consumption that was within 3% of the value repo rted in the 3-day survey. As an example, for individuals who report consuming 3 servings of seafood over the c ourse of the 3-day survey, the projected annual consumption was calculated as:

LTS = 3 servings/day x 122 = 227 to 257 servings/year 2.1 to 2.7 ( 1.5 / 3 )

Use of the consumption rates projected in th is manner along with Monte Carlo simulation of species distribution and mercury concentration resulted in a clos e approximation (within a factor of 2 up to the 90 th percentile) to mercury biomarke r (blood and hair) survey data.



## II. Adjustment of consumption rate estimates

Lambe et al. (2000a) evaluated the influence of survey duration on estimates of food intakes using consumption rate data fo r 32 different foods (including fi sh) collected for 14 consecutive days from 948 teenagers. This evaluation suppo rted the conclusion that shorter-term surveys used to predict long-term food consumption ma y overestimate the amount of food individuals consume; however, estimates of group mean inta kes are reasonably independent of the survey duration once the sample size is sufficient. The re sults for fish ingestion are representative of

most of the other 31 foods evaluated. Table 1 show s the survey results for fish consumption rates reported after 1, 3, 5, 7, 10, and 14 days.

Table 1. Mean population in take, consumer-only intake, and percent consumers of fish after 1, 3, 5, 7, 10, and 14 days of data collection

Study Length Mean Population Intake (g/day) Consumer-only Intake (g/day) Percent Consumers 1-Day Diary a 13 112 12% 3-Day Diary a 14 46 30% 5-Day Diary a 13 31 41% 7-Day Diary a 12 24 49% 10-Day Diary a 12 21 56% 14-Day Diary 12 18 63%

Source: Lambe et al. 2000a

a Data reported for the first 1, 3, 5, 7, and 10 days of a 14-day diary survey.

While the the mean population intakes showed little difference between the various survey durations, food chemical exposure assessments generally require consumption rates for

consumers rather than the total popul ation (Renwick 1996), and the consumer-only rates were strongly influenced by survey duration.

Using these data, Lambe et al. (2000b) investig ated whether combining the data from a shortterm (e.g., 3-day) dietary survey with a long- term food frequency questionnaire could produce consumer-only consumption rate estimates comp arable to those calculated from a 14-day food diary based on the premise that consumer-only intakes are really the mean total populationTechnical Issue Paper July 20, 2012 Page 9 intakes adjusted for % consumers. As shown in Table 2 for fish ingestion, Lambe et al. demonstrated that the mean total population inta kes, based on a 3-day food diary, can be divided by total % consumers, based on a food frequency que stionnaire, to provide values comparable to the mean consumer-only intakes from a 14-day food diary.

The adjusted mean consumer-only fish intake calculated as the total (consumers and nonconsumers) fish intake from the 3-day diary ( 14 g/day) divided by the total % consumers from the food frequency questionnaire (5 7%) is 25 g/day and is similar to the consumer-only intake reported from the 14-day diary survey of 18 g/day.

This approach has been applied to the result s of the short-term study data reported by The Suquamish Tribe (2000) in Table 3 and to th e national (CSFII) data reported by USEPA (2002)

in Table 4.

Table 2. Adjustment of short-te rm (3-day) to long-term estimates and comparison to longer-term (14-day) fish consumption rates (Lambe et al. 2000b)

Parameter 3-Day Diary a 14-Day Diary Long-Term %

Consumers b Mean Population Intake 14 g/day 12 g/day -- Consumer-only Intake 46 g/day 18 g/day --

Percent Consumers 30% 63% 57% Consumer-only 3-dayrecall adjusted for longterm exposure 14 g/day

= 25 g/day 57% consumers

Source: Lambe et al. 2000b

a Data reported for the first 3 days of a 14-day diary survey.

b From food frequency survey.
-- = intake rates not calculated from food frequency questionnaire

Table 3. Adjustment of short-term (24- hour recall) to long-term estimates and comparison to long-term fish consumption rates - Suquamish Tribe study

Parameter 24-hour Recall Long-Term Recall Long-Term %

Consumers b Mean Population Intake 119 g/day 214 g/day -- Consumer-only Intake 263 a g/day 214 g/day --

Percent Consumers 45% 100% 97% Consumer-only 1-dayintake adjusted for longterm exposure 119 g/day

= 123 g/day 97% consumers

Source: The Suquamish Tribe 2000

a Calculated as 119 g/day/45%

b Upper-bound of non-consumers reported as 3% (The Suquamish Tribe 2000)

-- = intake rates not calculated from food frequency surveyPage 10 July 20, 2012 Technical Issue Paper Table 4. Adjustment of short-term (2-d ay recall) to long-term estimates and comparison to long-term fish consumpt ion rates – General Population (CSFII Data)

Parameter 2-day Recall Long-Term Recall Long-Term %

Consumers b Mean Population Intake 19.9 g/day -- -- Consumer-only Intake 74.3 a g/day

-- -- Percent Consumers 27% -- 85.4% Consumer-only 2-dayrecall adjusted for longterm exposure 19.9 g/day

= 23.3 g/day 85.4% consumers

Source: USEPA 2002

a Calculated as 74.3 g/day/27%.

b Percent of people who never eat meat reported as 14.6 (+ 3%) in (Stahler 2006)

-- = not reported

Applying this approach results in minor upwar d adjustments of the Suquamish 24-hour recall (from 119 g/day to 123 g/day) and United States 2-day recall (from 19.9 g/day to 23.3 g/day) survey data. The relatively small impact of the ad justment is due to the assumption that a large percentage of the population eats fish (97% for the Suquamish population and 85.4% for the U.S. population).



## III. Statistical reanalysis of national fish consumption

data

Ecology conducted a statistical rean alysis of national and regional-sp ecific fish consumption data to derive consumption estimates for different fish species groups (e.g., shellfish, anadromous, non-anadromous), estimates of fi sh consumed based on harvest pa tterns, and long-term national fish consumption estimates statistica lly derived from short-term episodic 2 dietary data. Detailed descriptions of the statistical me thods used to reevaluate the na tional and regional-specific data are presented in Draft Statistical Analysis of National and Washington State Fish Consumption

Data (Polissar et al. 2012), a companion docum ent to the Fish Consumption Rate TSD.

The methodology developed by Tooze et al. (20 06), which estimates the usual intake of episodically consumed foods such as fish, was used to reassess data from individual responses to

the 2003–2006 National Health and Nutrit ion Examination Survey (NHANES).

These methods were not applied to the regional-sp ecific fish consumption da ta due to differences

in data collection methods: the national data we re based on two 24-hour recall surveys, while the regional data were based on f ood frequency questionnaires.

Detailed descriptions of the methodology are prov ided in the following technical literature:

2 “Episodic” refers to consumption that is intermittent or occasional.Technical Issue Paper July 20, 2012 Page 11  Tooze et al. 2006. A New Statistical Met hod for Estimating the Usual Intake of Episodically Consumed F oods with Application to Their Distribution. Journal of the
American Dietetic Association, October 2006, 106: 1575-1587

 Kipnis et al. 2009. Modeling Data with Excess Zeros and Measurement Error: Application to Evaluating Relationships between Episodically Consumed Foods and

Health Outcomes. Biometrics , December 2009, 65: 1003-1010.

 Subar et al. 2006. The Food Propensity Questi onnaire: Concept, Development, and

Validation for Use as a Covariate in a Model to Estimate Usual Food Intake. Journal of

the American Dietetic Association , October 2006, 106: 1556-1563.

 Keogh and White, 2011. Allowing for never and episodic consumers wh en correcting for

error in food record measur ements of dietary intake. Biostatistics (2011), 12, 4, PP. 624-

636.

 Dodd et al. 2006. Statistical Met hods for Estimating Usual Intake of Nutrients and Foods: A Review of the Theory. Journal of the American Dietetic Association , October 2006,

106: 1640-1650.

The fish consumption estimates resulting from this reanalysis are presented below. For comparison, national estimates were also derived based on standard statistical methods that did not account for estimating the usua l, or long-term, fish dietary consumption from episodically consumed foods. These estimates are also presented below.

Table 5. Adult U.S. National Fish Cons umption Rates, Consumers Only (From NHANES 2003–2006)

Usual Intake Based on Tooze et al. Methodology (Data from NHANES 2003-2006) Population

National Species Group Descriptive Statistics (grams/day)

50 th

Percentile 90 th

Percentile 95 th

Percentile

National U.S.

Population all 12.7 42.5 56.6

finfish 9.0 31.8 43.3

shellfish 2.4 13.2 20.5 Adapted from Table 4, Polissar et al., 2012

Observed Consumption on Two Da ys (Data from NHANES 2003-2006) Population

National Species Group Descriptive Statistics (g/day)

50 th

Percentile 90 th

Percentile 95 th

Percentile

National U.S.

Population all 37.9 127.9 168.3

finfish 34.6 115.3 149.8

shellfish 25.7 100.5 146.6 Adapted from Table 3, Polissar et al., 2012Page 12 July 20, 2012 Technical Issue Paper 

# Summary

Because food intake rates from short-term surveys are highly variable and result in a wide range of fish consumption patterns, these surveys te nd to overestimate the pr evalence of low and high

intake rates. This variation is particularly relevant for assessments of food chemical exposure where the parameters of interest are at the extrem es of the exposure distribu tion rather than at the center (Lambe 2002).

Attempts to account for the variance and uncertain ty associated with the use of short-term consumption studies have generally included qual itative evaluation of data from a range of sources, coupled with considera tion of the intended use of th e data. To evaluate long-term (habitual) seafood intake, longer-te rm survey data are preferable to short-term dietary survey

data.

While there are mathematical appr oaches that attempt to adjust short-term recall data for longerterm consumption estimates, such adjustments are complex, do not provide a clear improvement in the fish consumption rate estimate, and are them selves subject to uncerta inty. If the percentage of fish consumers is high in the population be ing considered, these adjustments result in a relatively minor change in the es timated fish consumption rate.

Ecology conducted a statistical r eanalysis of short-term nationa l fish consumption data to estimate long-term (usual) national fish cons umption rates, using the methodology of Tooze et al. (2006). National fish consum ption rate estimates based on this reanalysis are significantly lower than estimates based on simple extrapolat ion of the short-term fish consumption data. Additional information is provi ded in Polissar et al. (2012).Technical Issue Paper July 20, 2012 Page 13 

# References

AMEC. 2003. Evaluation of the Fish Consum ption Rate Selected by Oregon DEQ for the Development of Ambient Water Quality Criter ia. Submitted to Northwest Pulp and Paper Association, Bellevue, WA. Prepared by Elle n S. Ebert and Paul Anderson, AMEC Earth & Environmental. May 2003.

Basiotis, P., Welsh, S., Cronin, F., Kelsay, J., and Mertz, W. 1987. Number of Days of Food Intake Records Required to Estimate Individua l and Group Nutrient Intakes with Defined

Confidence. The Journal of Nutrition , May 1987 http://jn.nutrition.org/content /117/2/local/ed-board.pdf.

Carrington, C.D., Bolger, M.P. 2001. Methods for Projecting Long-Term Dietary Exposure from Short-Term Survey Data for Environmental Contaminants. Center for Food Safety and Applied Nutrition, U.S. Food and Drug Admi nistration, College Park Maryland, USA. Toxicology and Industria l Health 2001 17:176-179.

Carrington, C.D., Bolger, M.P. 2002. An exposur e assessment for methylmercury from seafood for consumers in the United States. Center for Food Safety and Applied Nutrition, U.S. Food and Drug Administrati on, Washington, DC 20204, USA. Risk Anal. August 22(4):689-99.

CRITFC (Columbia River Inter-Tr ibal Fish Commission). 1994. A fish consumption survey of the Umatilla, Nez Perce, Yakima, and Warm Springs Tribes of the Columbia Basin. Technical Report 94-3. October 1994.

Ebert, E.S., Harrington, N.W., B oyle, K.J., Knight, J.W., and Keenan, R.E. 1993. Estimating consumption of freshwater fish among Maine anglers. N. Am. J. Fish. Mgt. 13:737-745.

Ebert, E.S., Price, P.S., and Keenan, R.E. 1994. Selection of Fish Consumption Estimates for Use in the Regulatory Process. J. Expos. Anal. Environ. Epidemiol. 4(3):373-393.

Exponent. 2012. Letter from Mark W. Johns a nd Michael R. Garry, Exponent, to Washington State Department of Ecology, Re: Comme nts on Publication No. 11-09-050, Fish Consumption Rates Technical Support Docume nt, A Review of Data and Information about Fish Consumption in Washington. January 17, 2012.

Fiore, B.J., Anderson, H.A., Hanrahan, L.P., Olson, L.J., and Sonzogni, W.C. 1989. Sport fish consumption and body burden levels of chlo rinated hydrocarbons: A study of Wisconsin anglers. Archives of Environmental Health 44(2):82-88. As c ited in AMEC 2003.

Javitz, H. 1980. Seafood Consumption Data Analysis: Final Report. Prepared by SRI

International for USEPA Offi ce of Water Regulations a nd Standards. September 24,

1980. As cited in AMEC 2003.

Keogh and White. 2011. Allowing for never and episodi c consumers when corr ecting for error in

food record measurements of dietary intake. Biostatistics (2011), 12, 4, PP. 624-636.Page 14 July 20, 2012 Technical Issue Paper Kipnis, V., Midthune, D., Buck man, D.W., Dodd, K.W., Guenth er, P.M., Krebs-Smith, S.M., Subar, A.F., Tooze, J.A., Carroll, R.J., a nd Freedman, L.S. 2009. Modeling Data with Excess Zeros and Measurement Error: Appli cation to Evaluating Re lationships between Episodically Consumed Foods and Health Outcomes. Biometrics, December 2009, 65:

1003-1010.

Lambe, J., Kearney, J., Leclercq, C., Zunft, H., De Henauw, S., Lamberg- Allardt, C., Dunne, A., and Gibney, M. 2000a. The Influence of Survey Duration on Estimates of Food Intakes

and its Relevance for Public Health Nutrition and Food Safety Issues. European Journal of Clinical Nutrition (2000) 54, 166-173.

Lambe, J., Kearney, J., Leclercq, C., Berardi, D., Zunft, H., Sulzer, S., De Henauw, S., De Volder, M., Lamberg-Allardt, Karkkain en, M., C., Dunne, A., and Gibney, M. 2000b. Enhancing the Capacity of Food Consumpti on Surveys of Short Duration to Estimate Long Term Consumer-Only Intakes by Combin ation with a Qualitative Food Frequency Questionnaire. Food Additives and Contaminants , 2000, Vol. 17, No. 3, 177-187.

Lambe, J. 2002. The Use of Food Consumption Data in Assessments of Exposure to Food Chemicals Including the Applicatio n of Probabilistic Modeling.

Mertz, W. and Kelsay, J. 1984. Rationale and desi gn of the Beltsville one-year dietary intake study. Am. J. Clin. Nutr. 40(Suppl. 6):1323-1326.

Pao, E.M., Fleming, K.H., Guenther, P.M., a nd Mickle, S.J. 1982. Foods commonly eaten by individuals: amount per day and per ea ting occasion. Home Economic Report No. 44. U.S. Department of Agriculture, Wa shington, DC. As cited in USEPA 2011.

Pierce, D., Noviello, D., and Rogers, S.H. 1981. Commencement Bay Seafood Consumption Study: Preliminary Report. Tacoma-Pierce County Health Department, Seattle, WA.

December 1981. As cited in AMEC 2003.

Polissar, N.L., Neradilek, M., Aravkin, A.Y., Danaher, P., and Kalat, J. Draft Statistical Analysis of National and Washington State Fish Consumption Data. Prepared for Washington State Department of Ecology by The Mountai n-Whisper-Light Statistics, Seattle, Washington. June 2012.

Puffer, J.W., Azen, S.P., Duda, M.J., and Y oung, D.R. 1982. Consumption rates of potentially hazardous marine fish cuaght in the me tropolitan Los Angeles area. Grant R 807 120010. University of Southern California School of Medicine for Environmental Research Laboratory. As cite d in AMEC 2003.

Rasanen, L. Nutrition survey of Finnish rural children. VI. Methodologic al study comparing the

24-hour recall and the diet ary history interview. Am. J. Clin. Nutr. 32:2560-2567.

December 1979.

Renwick, A. G., 1996. Needs and Methods for Prior ity Setting for Estimating the Intake of Food

Additives. Food Additives and Contaminants , 13, 467-475.

Rutishauser, I. 2005. Dietar y Intake Measurements. Public Health Nutrition : 8(7A), 1100-1107.Technical Issue Paper July 20, 2012 Page 15 Sechena, R., Nakano, C., Liao, S., Polissar, N., Lorenzana, R., Truong, S., and Fenske, R. Asian and Pacific Islander Seafood Consump tion Study (EPA 910/R-99-003). May 27, 1999.

Stahler, C. 2006. How Many Adults Are Vegetari an? Results of a survey conducted by Harris

Interactive® on behalf of Th e Vegetarian Resource Group. Vegetarian Journal 2006

Issue 4. http://www.vrg.org/journal/vj2006issue4/vj2006issue4poll.htm

Subar, A.F., Dodd, K.W., Guenther , P.M., Kipnis, V., Midthune, D., McDowell, M. Tooze, J.A., Freedman, L.S., Krebs-Smith, S.M. 2006. The Food Propensity Questi onnaire: Concept, Development, and Validation for Use as a C ovariate in a Model to Estimate Usual Food

Intake. Journal of the American Dietetic Association, October 2006, 106: 1556-1563.

The Suquamish Tribe 2000. Fish Consumption Survey of the Suquamish Indi an Tribe of the Port

Madison Indian Reservation.

Dodd, K.W., Guenther, P.M., Freed man, L.S., Subar, A.F., Kipnis, V., Midthune, D., Tooze, J.A., Krebs-Smith, S.M. 2006. Statistical Me thods for Estimating Usual Intake of Nutrients and Foods: A Review of the Theory. Journal of the American Dietetic

Association , October 2006, 106: 1640-1650.

Tooze, J.A., Midthune, D., Dodd, K.W., Freedma n, L.S., Krebs-Smith, S.M., Subar, A.F., Guenther, P.M., Carroll, R.J., Kipnis, V. 2006. A New Statistical Method for Estimating the Usual Intake of Episodically Consumed Fo ods with Application to Their Distribution.

Journal of the American Dietetic Association, October 2006, 106: 1575-1587

Toy, K.A., Polissar, N.L., Liao, S., Mittelstaedt, G.D. 1996. A fish consumption survey of the Tulalip and Squaxin Island Tribes of the Puget Sound Region. Tulalip Tribes, Department of the Environmen t, Marysville, Washington.

Tran, N.L., Barraj, L., Smith, K., Javier, A., and Burke, T.A. 2004. Combining Food Frequency and Survey Data to Quantify Long-Term Di etary Exposure: A Me thyl Mercury Case Study. Risk Analysis , Vol. 24, Issue 1, pp 19-30. February 2004.

USEPA (U.S. Environmental Protection Agency). 1992. Consumption Surveys for Fish and Shellfish: A Review and Analysis of Surv ey Methods. U.S. Environmental Protection Agency, Office of Water. EPA 822/R-92-001. February 1992.

USEPA. 1995. Fish consumption estimates base d on the 1991-1992 Michigan sport anglers fish consumption study. Final Report. Prepared by SAIC for the Office of Science and Technology, Washington, DC. As cited in USEPA 2011.

USEPA. 1998. Guidance for Conducting Fish a nd Wildlife Consumption Surveys. U.S. Environmental Protection Agency, Offi ce of Water. EPA-823-B-98-007. November

1998.

USEPA. 2000. Methodology for deriving ambient wa ter quality criteria fo r the protection of human health. U.S. Environmental Protection Ag ency, Office of Water, Office of Science and Technology. EPA-822-B-00-004. October 2000.

USEPA 2002. Estimated Per Capita Fish Consum ption in the United States. EPA-821-C-02-003.Page 16 July 20, 2012 Technical Issue Paper USEPA. 2011. Exposure Factors Handbook: 2011 Edition. EPA/600/R-090/052F. U.S. Environmental Protection Agency Office of Research and Development, Washington, DC. September 2011.

West, P.C., M.J. Fly, R. Marans, and F. Larki n. 1989. Michigan sport anglers fish consumption survey. A report to the Michigan Toxic Substance Control Commission. Michigan Department of Management and Budget, Contract No. 87-20141. As cited in AMEC

2003.

West, P.C., Fly, J.M., Marans, R., Larkin, F ., and Rosenblatt, D. 1993. 1991-92 Michigan Sport Anglers Fish Consumption Study. Prepared by the University of Michigan, School of Natural Resources, for the Michigan Departme nt of Natural Resources. Technical Report No. 6. May 1993. As cited in AMEC 2003.

# Technical Issue Paper



# Recreational Fish Consumption Rates

# Technical Issue Paper



# Recreational Fish Consumption Rates

July 20, 2012

Toxics Cleanup Program

Washington State Department of Ecology

Olympia, WashingtonTechnical Issue Paper July 20, 2012 Page i 

# Table of Contents

Page

List of Tables ................................................................................................................ ................... i

Introduction .................................................................................................................. ....................1

Marine Recreational Studies ................................................................................................... .........2

I. Commencement Bay Seafood Consump tion Study (Pierce et al. 1981) .............................3

II. Seafood Catch and Consumption in Ur ban Bays of Puget Sound (McCallum 1985) ......................................................................................................................... ...........4

III. 1983-1984 Puget Sound Survey (Landolt et al. 1985, 1987) ...............................................5

IV. Survey of Fish Consumption Patterns of King County Recreational Anglers (Mayfield et al. 2007) ........................................................................................................ ..6

Freshwater Recreational Studies ............................................................................................... .......8

I. Consumption Patterns of Anglers Who Fr equently Fish Lake Roosevelt (WDOH 1997) ......................................................................................................................... ...........8

II. Lake Whatcom Residential and Angler Fish Consumption Survey (WDOH 2001) ...........9

III. Survey of Fish Consumption Patterns of King County Recreational Anglers (Parametrix 2003) ............................................................................................................. ...9

Summary ....................................................................................................................... .................11

References .................................................................................................................... ..................13



## Appendices

Appendix A. Recreational Fish Consumption Rates



# List of Tables

Tables

Page

Table 1. Fish and Shellfish Consumption Rates (g/d ay) for Marine Recreational Fishers in King County, WA ...........................................................................................................7

Table 2. Fish Consumption Rates (g/day) for Fr eshwater Recreational Anglers in King County, WA ..................................................................................................................10

Table 3. Summary of Recreational Fish Consumption Rates .....................................................11Page ii July 20, 2012 Technical Issue Paper This page purposely left blank for duplicate printing.Technical Issue Paper July 20, 2012 Page 1 

# Introduction

The draft Fish Consumption Rates Technical Support Document (TSD) identified four fish/shellfish dietary surveys as appropriate for use in establ ishing a technically defensible default fish consumption rate for Washingt on. These surveys included two Native American fish/shellfish dietary surveys for three tribal populations in Puget Sound, one Native American finfish dietary survey for four tribal populations in and aroun d the Columbia River basin, and

one Asian and Pacific Islander fish/shellfish dietary survey from King County. In addition, the draft TSD provided information on United States pe r capita fish consumption, based on the U.S. Department of Agriculture’s 1994–1 996 and 1998 food intake surveys.

The draft TSD did not provide specific informa tion about consumption of fish and shellfish by

recreational fishers. 1 Ecology received review comments re questing the inclusion of additionalfish consumption information for this receptor group. This issue paper summarizes regionalspecific and selected national fish dietary information for recreatio nal fishers. It is a targeted examination of the issues raised by review comments received on the draft Fish Consumption Rates TSD, and was prepared within a limited tim e frame. Therefore, it may not include all available information on this subject.

Although data for the general popula tion is useful for evaluating fish consumption rates, data on recreational fishing are needed to assess exposure to individuals with po tentially higher fish consumption levels. Recreational fishers may c onsume fish more frequently, and may consume larger portions at each meal, th an the general population. In add ition, they may frequently fish from a single contaminated source. These factors may put recreational fisher s at higher risk of exposure to contaminants in fish and shellfish.

1 In this issue paper, the term “fisher” denotes a person who fishes for any type of seafood by any method, including finfish an d shellfish. The term “angler” refers to a person who fishes with hook and line. Some fish consumption surveys reviewed during preparation of th is issue paper use the terms “fisher”, “fisherman”, and “angler” interchangeably.Page 2 July 20, 2012 Technical Issue Paper 

# Marine Recreational Studies

This section describes fish consumption rate studies for marine and estuarine finfish and shellfish. Four recreational fish consumption st udies have been conducte d in marine/estuarine areas of Washington State. Three of these we re conducted in the early to mid-1980s, over 25 years ago (Pierce et al. 1981; McCallum 1985; Landolt et al. 1985, 1987), and the fourth was

conducted in 2007. All four studies were creel surv eys, in which anglers were interviewed while fishing. They were asked questions about how much fish they had caught on the day of the survey, and the number of family members with which they intended to share the catch. These data do not represent usual behavior because an a ngler does not catch the same number of fish on each fishing occasion.

In a creel study, the target popul ation is typically anyone who fishes at the location being studied. Creel studies may not provide data repr esentative of the target population, because the probability of being sampled is not the same fo r all members of the target population (USEPA 2011). The Environmental Protection Agency ’s (EPA) Exposure Factors Handbook (2011) describes the problem as follows:

“For instance, if the survey is conducted fo r 1 day at a site, then it will include all persons who fish there daily, but only a bout 1/7 of the people who fish there weekly, 1/30 of the people who fish ther e monthly, etc. In this example, the probability of being sampled (or inverse weig ht) is seen to be proportional to the frequency of fishing. However, if the surv ey involves intervie wers revisiting the same site on multiple days, and persons are only interviewed once for the survey, then the probability of being in the surv ey is not proportional to frequency; in fact, it increases less than pr oportionally with frequency.”

In most creel studies, there is no mention of samp ling weights; by default, all weights are set to one, implying equal probability of sampling. B ecause the sampling probabilities in a creel survey, even with repeated inte rviewing at a site, are highly de pendent on fishing frequency, the fish intake distributions reported for these surv eys may overestimate intake rates of the total fishing population that uses the sampled water body (USEPA 2011).

Price et al. (1994) proposed using the inverse frequency of fishing to adjust data derived from creel surveys to statistically “c orrect” for the increased probab ility of encountering frequent fishers (relative to infrequent fishers). Price’s reanalysis of the Commencement Bay Seafood Consumption Study data is de scribed below (Section I).

Keill and Kissinger (1997, pp. 21-22) noted that multiplying the numbe r of infrequent anglers by the inverse of the number of days that they fish per year results in greater weight being given to the infrequent angler. For example, an individu al who fishes once a year would be assigned a weight 365 times an individual who fishes daily. Keill and Kissinger (1997) maintained that this adjustment obscures and negates the importan ce of the subpopulation most likely to incur exposure to contaminated fish. They noted that some researchers have specifically excluded infrequent anglers from surveys, and/or nonc onsumers from analyses, in order to avoid characterizing consumption for a po pulation that is not at risk.Technical Issue Paper July 20, 2012 Page 3 CalEPA (2001) stated that many factors can affe ct the relationship between fishing frequency and the probability of sampling, including the actual timing and frequency of sampling, the methods for selecting respondents, and whether repeat in terviews occur. In addition, a fisher’s frequency of fishing may be correlated with th e time of day, day of w eek, climate and seasonal factors, and other parameters th at may not be equivalent across sampling days. These factors are not accounted for in the basic weighting adjustment used by Price et al. (1994).

Other limitations associated with creel studies were described in the draft Fish Consumption Rate TSD, as well as by CalEPA (2001) and Kissinger (2010). These include:

 Difficulties in eliciting year-round consumption information;

 Difficulties in using visual aids or other mate rials to assist in quantifying consumption;

 Inability to obtain a random, unbiased sample of the study population;

 Willingness (or unwillingness) of the interviewee to provide information in a field situation when the interviewee would rather be fishing;

 Concerns about accurate transmission of fishing information due to trust issues;

 Language and communication issues if anglers do not speak English;

 Inadequate measurement of fish consump tion over the geographic area of concern;

 Inadequate assessment of fishing activity at all times when fishing might occur;

 Underestimation of catch associated with meas uring catch prior to the end of the fishing activity; and

 Problems in relating an angler’s catch to consumption rates of the angler’s family and community.

The Washington State studies are discussed below. Additional studies of marine/estuarine fish consumption rates are summarized in Table A-1 (Appendix A of this Technical Issue Paper).

These include other studies on the West Coast, particularly along th e California coast, as well as

studies from New York/New Je rsey, Texas, and Delaware.



## I. Commencement Bay Seafood Consumption Study (Pierce et al. 1981)

Pierce et al. (1981) conducted a creel survey in 1980 for th e Tacoma-Pierce County Health Department to study seafood consumption pattern s and demographics of sport fishermen in Commencement Bay, near Tacoma. Th e objectives of the survey were to: determine the extent to which local species of fish and shellfish were used as food; de termine which species were most commonly consumed; and assess methods of prepar ation of the catch. Only successful anglers were interviewed, and salmon were excluded from the study because they were considered to

have minimal contact with Commencement Bay pollutants.

Surveys of shore and boat anglers were conduc ted in the mornings and evenings, and each subarea was sampled five times during the summer and four times during the fall, except for onePage 4 July 20, 2012 Technical Issue Paper area that was sampled only twice during the fall. The boat fishing area was sampled four times during the fall only. Interviews were conducted on ly with anglers who had successfully caught fish, and each angler was interviewed only on ce during the survey period. The following data were recorded: species, wet weight, size of the family, place of residence, fishing frequency, planned uses of the fish, age, sex, and race. Sampling periods lasted as late as 1:00 a.m.; however, the study authors noted that a considerab le portion of the total catch was suspected to have been obtained during al l-night fishing (CalEPA 2001).

A total of 304 interviews of shore anglers we re conducted during the summer of 1980 (July to September), and 204 interviews of shore and boat anglers were conducted in the fall (September to November). About 60 percent of the anglers interviewed were white, 20 percent were black, 19 percent were Asian, and the remainder was Hispanic or Na tive American (USEPA 2011). The dominant species caught were P acific hake and walleye pollock. Pierce et al. (1981) did not present a distribution of fish inta ke or a mean fish intake rate.

In 1994, Price et al. obtained the raw data from this survey and re-analyzed it using sampling weights proportional to inverse fi shing frequency. Price et al. (1994) calculated a median intake rate of 1.0 g/day and a 90 th percentile rate of 13 g/day. When equal weights were applied, the median intake rate was 19 g/day and the 90 th percentile was 155 g/day. According to USEPA, all of these values are probably underestimates, b ecause the sampling probab ilities are less than proportional to fishing frequency; thus, the true median for the target population is probably somewhat above 1.0 g/day, and the true 50 th percentile of the resource utilization distribution is probably higher than 19 g/day (USEPA 2011).

Limitations to this study in cluded the following (CalEPA 2001):

 Local seafood contamination in this area may have suppressed the reported fish consumption rate;

 Salmon were excluded from the fish consumption rate;

 Anglers who had not caught any fish at the tim e of the interview were not included; and

 Sampling was conducted in summer and fall only; no samples were collected in winter or spring.



## II. Seafood Catch and Consumption in Urban Bays of Puget Sound (McCallum 1985)

McCallum (1985) studied shore-based recreational fishers in Elliott Bay, Everett Harbor (Port Gardner), and Sinclair Inlet. Th e objective of the st udy was to collect information on the species consumed, the amount consumed, the frequency of fish or shellfish consumption, and the location of collection. Of partic ular concern was whether South east Asian immigrants or other low income groups were frequent users of urba n fishing sites and whet her they consumed the more contaminated species (e.g., sole) or the mo re contaminated parts (e.g., fish liver, crab hepatopancreas).Technical Issue Paper July 20, 2012 Page 5 Shore-based fishing, crabbing, or clamming sites within contaminated bays were sampled. Onsite interviews were conducted between July 198 3 and June 1984. Initial survey attempts were conducted on different days of the week and at different hours of the day. Subsequently, survey effort was adjusted to high use days/times. The survey schedule was also modified to reflect seasonal changes in fishing, crabbing, or cl amming. Only those fishers seeking bottomfish, crabs, or clams were fully interviewed. Anglers fishing for salmon or squid were excluded, as these species are highly migrator y and were not expected to be impacted by contaminants in the urban bays.

Tetra Tech (1988) calculated a 95 th percentile consumption rate of 24.3 g/day based on the data collected during this study.

Limitations to this study included (Kissinger 2010):

 Language barrier problems in conducting interviews;

 Many individuals refused to be interviewed; and

 Interviews were not conducted at night (midnight to 6 a.m.), a time period when fishing may have occurred.



## III. 1983-1984 Puget Sound Survey (Landolt et al. 1985, 1987)

Landolt et al. (1985, 1987) conducted a two-year st udy of recreational fish and shellfish catch and consumption from four urban embayments of Puget Sound: Commencement Bay, Elliott Bay, Sinclair Inlet, and Edmonds. The objectives of the study were to: identify the most commonly consumed species; assess the demographi c characteristics of the fishing population; describe patterns of consumption; and estimate the quantity of selected chemicals consumed by anglers and their families.

Personal interviews were used to obtain spec ies-specific catch and consumption information. Over 4,000 shore fishers were interviewed dur ing the first year (November 1983 through November 1984). Sampling times were initially selected at random, and interviews were conducted during all times of the day. After the pr eferred fishing times we re identified, sampling focused on those times when the largest number of fishers were expected (CalEPA 2001). The second year of the study focused primarily on chemi cal analysis of tissue samples, but catch and consumption patterns for 437 boat anglers at tw o of the four embayments (Elliott Bay, Commencement Bay) were also evalua ted during February to October 1985.

Calculations of consumption rates were based on estimates of the weight of the catch (fish in hand) divided by the number of consumers in th e household, and by the number of days since fish caught at the same site were last eaten. This value was multiplied by a cleaning factor of 0.3 for fish and 0.49 for squid and cra b, to derive the mean daily gr ams of available edible portion per person. Geometric means were then calcul ated for each embayment and ethnic group. An overall geometric mean daily fish consumption ra te of 11 g/day for all ethnic groups and species

was calculated.Page 6 July 20, 2012 Technical Issue Paper Geometric means ranged from 8 to 14 g/day per person. Consumption rates for the most common species were significantly highe r than the average. The most common species, squid, was consumed at a geometric mean rate of 39 g/da y, but only during the fall. Landolt et al. (1987) noted that boaters fished primarily for salm on, and consumed 51.7 g/day of King salmon from the two bays where boat anglers were surveyed (CalEPA 2001). Correlations were made between ethnicity and fishing mode, time of fishing, household size, parts of fish consumed, and seasonality of fishing.

Limitations to this study included:

 Shore anglers were not interviewed at the end of their fishing trips, potentially underestimating consumption; and

 Measurement of shellfish intake was limited to crab.



## IV. Survey of Fish Consumption Patterns of King County Recreational Anglers (Mayfield et al. 2007)

Mayfield et al. (2007) summari zed results of two fish cons umption surveys conducted among recreational anglers at marine a nd estuarine sites in King County. 2

The first survey was conducted during a 10-w eek period from June 1997 to August 1997 at marine and estuarine public parks and boat laun ches throughout Elliott Bay and the Duwamish River. Simmonds et al. (1998) originally summar ized the results of th e survey but did not perform a detailed analysis of fish and shellf ish consumption rates. Surveys were conducted on weekends and 10 randomly selected weekdays, over a period of 10 weeks. Locations were visited at least twice a day (morning and after noon) between the hours of 5:00 am and 10:00 pm. A total of 807 and 152 anglers were surveyed in Elliott Bay and the Duwamish River, respectively.

The second survey was conducted between March 2001 and March 2002 at marine locations in North King County and Snohomish County. This study followed a random st ratified design and was conducted on both weekdays and weekends, typically between 7:00 am and 8:00 pm. Locations were visited randomly, and surveyors attempted to interview as many anglers as possible within a 1-hour site visit. The interviews typically were 5 to 10 minutes each. A total of 228 anglers were surveyed in No rth King and Snohomish Counties.

Data were collected on fishing location prefer ences, fishing frequency, consumption amounts, species preferences, cooking methods, and whet her family members would also consume the catch. Respondent demographic data were also collected. Consumption rates were estimated using information on fishing fre quency, weight of the catch, a cl eaning factor, a nd the number of individuals consuming the catch. The majority of anglers surveyed were over male, 15 years and older, and were either Caucas ian or Asian/Pacific Islander.

2 Mayfield eta l. (2007) also summarized results of a fish consumption survey among recreational anglers at freshwater locations ; these results are discussed in the Freshwater Recreational Studies section of this issue paper.Technical Issue Paper July 20, 2012 Page 7 Mayfield et al. (2007) used the harvest method to calculate fish consump tion rates; this method estimates consumption by combining information on fishing frequency and the weight of fish caught during the time of the in terview. Due to the limited numb er of fish actually measured during the time of the interviews, a mean value for total fish weight was used to calculate consumption. The mean weights for uncleaned fi sh and shellfish caught by anglers were 1,574 and 1,053 g/catch at Elliott Bay, 544 and 821 g/ca tch at Duwamish River sites, and 1,035 and 683 g/catch in North King and Snohomish Coun ties. The North King County survey did not query for the number of fish consumers in the fa mily; an average family size of 2.5 was used.

Mean recreational marine fish and shellfish consumption rates were 53 g/day and 25 g/day, respectively (Table 1). Mayfield et al. (2007) also re ported differences in intake according to ethnicity. Mean marine fish intake rates we re 73, 60, 50, 43, and 35 g/day for Native American, Caucasian, Asian and Pacific Islander, African American, and Hispanic/Latino respondents, respectively.

Table 1. Fish and Shellfish Consumpti on Rates (g/day) for Marine Recreational Fishers in King County, WA

Location Sample Size Mean SD SE 50 th

Percentile 90 th

Percentile 95 th

Percentile Marine Fish Consumption

Duwamish River 50 8 13 2 2 23 42 Elliott Bay 377 63 91 5 31 145 221 North King County 67 32 40 5 17 85 102

All Locations 494 53 83 4 21 121 181 Shellfish Consumption

Duwamish River 16 20 33 8 3 77 123 Elliott Bay 49 28 33 5 14 74 119 North King County 31 22 33 6 12 62 132

All Locations 96 25 33 3 11 60 119

Source: Mayfield et al. (2007)

SD = Standard deviation; SE = Standard error

Limitations to this study included:

 The Elliott Bay survey was conducted over 10 weeks during peak summer fishing activity;

 A substantial number of individuals refused to have their catch we ighed, and/or refused to be interviewed;

 Surveys were very brief (5 to 10 minutes); and

 The study does not address how language issu es were dealt with in administering the survey to non-English speakers.Page 8 July 20, 2012 Technical Issue Paper 

# Freshwater Recreational Studies

This section describes fish cons umption rate studies for freshwater fish and shellfish. Three recreational fish consumption studies have been conducted in the freshwater areas of Washington State: Lake Roosevelt (WD OH 1997), Lake Whatcom (WD OH 2001), and King County lakes (Mayfield et al. 2007, Parametrix 2003).

Additional studies of freshwater fish and shellfish consumption ra tes are summarized in Table A2. These include studies in Oregon, California, South Carolina, Tennessee, Minnesota, North Dakota, Indiana, Georgia, Connecticut, Alabama, Michigan, New York, Maine, and Wisconsin.



## I. Consumption Patterns of Anglers Who Frequently Fish Lake Roosevelt (WDOH 1997)

A fish consumption survey was conducted at Lake Roosevelt during August through November 1994 and May through September 1995. The purpose of the survey was to evaluate the consumption patterns of anglers who repeatedly fi shed from the lake, in order to assess the public health impacts associated with ingest ion of chemically-contaminated fish (WDOH 1997). The study included a creel survey (trip length info rmation, fish species, length, and weight) and shoreside interviews of boat angl ers upon return from their fishing trips. The consumption survey form (used during the shoreside interviews) was se parate from the creel survey. Lake Roosevelt

was divided into three secti ons (upper, middle, and lower); morning and afternoon survey locations were randomly selected from a tota l of 48 possible locations. Anglers who did not consume Lake Roosevelt fish and anglers who we re previously surveyed were excluded during data analysis. A total of 348 survey responses we re used to estimate fish consumption rates.

Surveyed individuals were primarily older adu lt Caucasian males that are part of two-adult

households in which both individuals consume fi sh. Results indicate that surveyed anglers consume an average of 42 meals per year, w ith over 90 percent consuming 103.2 meals or less per year (2 meals per week). Fish are consum ed primarily as fillets, and rainbow trout and walleye are preferred above kokane e and bass. No sturgeon, sucker , or whitefish were reported caught and consumed. Consumption rates were estimated based on an assumed 8-ounce meal size (Table A-2).

Limitations of this study include:

 Reported consumption rates may have been de pressed due to the presence of chemical contamination in Lake Roosevelt;

 The survey questions were not adequa te for determining fish meal size;

 Combining the consumption interviews with th e creel survey resulted in a survey that was too lengthy;

 Some anglers were anxious to depart the boat launch facilities at the completion of their fishing trip, and may have pr ovided responses in haste.Technical Issue Paper July 20, 2012 Page 9 

## II. Lake Whatcom Residential and Angler Fish Consumption Survey (WDOH 2001)

WDOH conducted a survey of Lake Whatcom re sidents and anglers in July 2000, to gather information on consumption of fish caught in La ke Whatcom and percepti ons related to fish advisories (WDOH 2001). A retr ospective on-site study design w ith a four-week recall period was selected for this survey. Three populations were surveyed: residents who live on or near the lake or in developments with di rect access to the lake; boat an glers accessing the lake at public boat launch facilities; and shore anglers at public access points. Surveys were conducted through door-to-door interviews, at freque ntly used boat launch facilities, and at popular shore-fishing locations. A total of 220 surveys were comple ted, however only 10 shore anglers and 16 boat anglers were surveyed; 40 percent and 6 percent of these, respectively, reported eating fish in the previous four weeks. Of the 194 residents that were surveyed, 22 percent identified themselves as fishers, and only 2 per cent reported eating fish in the previous four weeks.

The primary species caught and consumed were cu tthroat trout and smallmouth bass. All anglers reported consuming Lake Whatcom caught fish th ree or fewer months per year. Average meal size for shore and boat anglers was 256 grams (9 ounces). The mean fish consumption rate for consumers was estimated at 6.0 g/day (ODEQ 2008).

Limitations of this survey in clude the followi ng (ODEQ 2008):

 Small sample size and low number of peopl e who reported consuming fish during the previous four weeks;

 Reports of mercury in Lake Whatcom fish may have affected consumption rates;

 Accurate frequency of m eals per week or month wa s not clearly presented;

 The calculated fish consumption rate was ba sed on a number of assumptions, including average fillet weight for each species.



## III. Survey of Fish Consumption Patterns of King County Recreational Anglers (Parametrix 2003)

Parametrix (2003) conducted a series of freshw ater surveys between 2002 and 2003 at locations around Lake Sammamish, Lake Washington, and La ke Union. Mayfield et al. (2007) included this study in their survey of fish consumption patterns of King County recreational fishers.

This study followed a random stratified de sign and was conducted on both weekdays and weekends, typically between 7:00 am and 8: 00 pm. Locations were visited randomly, and surveyors attempted to interview as many anglers as possible within a 1-hour site visit. The interviews typically were 5 to 10 minutes each (May field et al. 2007).

A total of 212 individuals were interviewed at these locations. The majority of participants were male, 18 years and older, and were either Caucas ian or Asian and Pacifi c Islander. Data were collected on fishing location pr eferences, fishing frequency, consumption amounts, species preferences, cooking methods, and whether fam ily members would also consume the catch. APage 10 July 20, 2012 Technical Issue Paper visual representation of typical serving sizes was used to esti mate portion sizes, and respondents estimated how many times they had eaten self -caught fish during the previous 30 days. Respondent demographic data were also collected.

Approximately 98 percent of anglers interviewed s ought finfish rather than other types of aquatic organisms, and over 50 percent reported that they fished only from the location where they were interviewed. This indicates that a majority of anglers consistently fish from a single unique location (Parametrix 2003). Reported fishing fre quencies were 6, 16, and 20 days/year at Lake Union, Lake Sammamish, and Lake Washington, respectively.

Consumption rates were estimated using responses on fish meal frequency and meal size. Mean fishing frequency in the King County lakes was 19 days/year, with a 95 th percentile value of 74 days/year. Most anglers (94 pe rcent) reported eating fillets without skin. Meal sizes were generally in the 6- to 8-ounce range (64 percent of anglers), with over 30 percent of anglers reporting an average meal size greater than 8 ounces (Parametrix 2003). The mean reported family size (including respondents) sh aring the anglers’ catch was 4.1.

The mean recreational freshwater fish consump tion rates were 10 g/day for all respondents and 7 g/day for the children of survey respondents (T able 2). Mayfield et al. (2007) also reported differences in intake according to ethnicity. Mean freshwater fish intake rates were 26, 13, 8, and 6 g/day for African American, Asian and Paci fic Islander, Caucasian, and Hispanic/Latino respondents, respectively.

Table 2. Fish Consumption Rates (g/day ) for Freshwater Recreational Anglers in King County, WA

Location Sample

Size Mean SD SE 50 th

Percentile 90 th

Percentile 95 th

Percentile Lake Washington 93 11 26 2.7 5.7 NA 30

Lake Sammamish 35 9.1 18 3.1 0 NA 57 King County Lakes (all respondents) 128 10 24 2.2 0 23 42

King County Lakes (children of respondents) 81 7.2 20 2.2 0 17 29

Source: Parametrix (2003); Mayfield et al. (2007)

SD = Standard deviation; SE = Standard error

Limitations to this study included:

 A substantial number of individuals refused to have their catch we ighed, and/or refused to be interviewed;

 Surveys were very brief (5 to 10 minutes); and

 The study does not address how language issu es were dealt with in administering the survey to non-English speakers.Technical Issue Paper July 20, 2012 Page 11 

# Summary

Results of recreational fish consumption surveys are presented in Tables A-1 and A-2. It should be noted that the fish consumption surveys iden tified in these appendices were conducted for a variety of purposes, used different methods of es timating fish and shellfish consumption, and had different target populations. The fish consumption rates listed in Tables A-1 and A-2 typically

include both finfish and shellfis h, although several studies reported separate finfish and shellfish consumption rates. Some studies estimated c onsumption rates for fish consumers only, while

others included nonconsumers. These differences are noted in the tables, as appropriate.

A summary of the recreational fish consumption rates listed in Appendix A is provided in Table

3 below.

Table 3. Summary of Recreati onal Fish Consumption Rates

Mean (g/day) Median (g/day) Upper (90 th

to 95 th

)

Percentile

(g/day) Marine Fish/Shellfish Consumption Rates Washington State 11 – 53 1.0 – 21 13 – 246

Other West Coast Studies 1.2 – 50 2.9 – 37 6.8 – 225 Studies in Other Regions 12 – 48 9.1 5.1 – 68 Freshwater Fish Consumption Rates Washington State 6.0 – 22 NA 42 – 67

Other West Coast Studies 27 3.8 – 24 5.7 – 127
Studies in Other Regions 4.9 – 55 1.1 – 24 18 – 235

Mean estimated marine/estuarine consumption ra tes for recreational fishers ranged from 1.2 to 53 g/day, with similar results reported in Wash ington State and other re gions. Upper percentile (90 to 95 th percentile) marine fish/shellfish consum ption rates ranged from 5.1 to 246 g/day for all studies reviewed; consumption rates were somewhat higher in st udies conducted along the West Coast (Washington, Oregon, and California) th an in studies conducted in other regions.

For freshwater fish, mean consumption rate s ranged from 4.9 to 55 g/day. Results from Washington and other West Coast states were somewhat lower (6.0 to 27 g/day), however studies along the West Coast were very limited (three studies in Washington, and one each in Oregon and California). The fish consumption dataset from studies of freshwater fish consumption in other regions is more robust (16 studies), and the upper end of the range of mean consumption rates is very similar to that estimat ed for marine fish/shell fish (50 to 60 g/day).

Upper percentile freshwater fish consumption rates ranged from 5.7 to 235 g/day in all studies reviewed, and from 42 to 67 g/day in studies conducted in Washington State. The highest reported freshwater fish consum ption rates were from a study c onducted by Burger (2002b); this study, which included both freshwater and marine sport-caught fish and was based on a one-year recall survey at a sportsman’s event in South Carolina, likely overestimates freshwater fishPage 12 July 20, 2012 Technical Issue Paper consumption rates by recreational anglers. The next highest uppe r percentile result is 136 g/day, which is based on a 3-month recall survey of minor ity recreational anglers in Indiana. With the exception of the Burger (2002b) study, results of freshwater fish consumption rates in other regions are similar to those observed along the West Coast.

In conclusion, fish consumption surveys reviewed during preparation of this issue paper can be used to provide a conservative estimate of mean and upper (90th to 95th) percentile

marine/estuarine and freshwater fish consumption rates for re creational fishers in Washington State, as follows:

 Mean consumption rates for both freshwater and marine/estuarine fish and shellfish are in the range of 20 to 60 g/day;

 Upper percentile consumption rates are in the range of 200 to 250 g/day for marine/estuarine fish and shellfish, and in the range of 100 to 150 g/day for freshwater

fish.

Based on these studies, recreati onal fish consumption rates deve loped in Washington State and

elsewhere are consistent with th e preliminary default fish consumption rate of 157 to 267 g/day presented in the draft TSD. In other words, a defa ult fish consumption rate in this range would be protective of marine and fres hwater recreational fishers.Technical Issue Paper July 20, 2012 Page 13 

# References

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Adolfson Associates. 1996. Technical Memo randum on the Results of the 1995 Fish Consumption and Recreational Use Surveys – Amendment No. 1. From Chee Choy, City of Portland, to Jean Ochsner, Adolfson Associates. April 19, 1996.

Alcoa (Aluminum Company of America). 1998. Draft report for the finfish/shellfish consumption study Alcoa (Point Comfort)/Lav aca Bay Superfund Site, Volume B7b: Bay System Investigation Phase 2. Point Co mfort, TX. As cited in USEPA 2011.

Balcom, N., Capacchione, C., and Hirsch, D.W. 1999. Quantification of seafood consumption rates for Connecticut. Prepared for the C onnecticut Department of Environmental Protection, Office of Long Island Sound Programs. As cited in USEPA 2011.

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Burger, J., 2002a. Consumption patterns and why people fish. Environ Res 90:125-135. As cited

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Campbell, K., Dickey, R., and Sexton, R. 2002. Fishing along the Clinch River arm of Watts Reservoir adjacent to the Oak Ridge Reserv ation, Tennessee: Behavior, knowledge, and risk perception. Sci Total Environ 299:145-161. As cite d in USEPA 2011.Page 14 July 20, 2012 Technical Issue Paper ChemRisk. 1992. Consumption of freshwater fish by Maine anglers, a Technical Report. Revised July 24, 1994. As cited in USEPA 2011.

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KCA Research Division. 1994. Fish consumption of Delaware recreational fishermen and their households. Prepared for the State of Delawa re, Department of Natural Resources and Environmental Control, in support of the De laware Estuary Program. As cited in USEPA

2011.

Keill, L. and Kissinger, L. 1997. Analysis and Selection of Fish Consumption Rates for Washington State Risk Assessments and Ri sk-Based Standards. Washington State Department of Ecology. Review draft. October 1997. As cited in CalEPA 2001.

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Landolt, M.L., Hafer, F.R., Nevissi, A., Van Belle, G., Van Ness, K., and Rockwell, C. 1985. Potential Toxicant Exposure Among Consum ers of Recreationally Caught Fish from Urban Embayments of Puget Sound. NOA A Technical Memorandum NOS OMA 23.

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in USEPA 2011.

Puffer, H.W., Azen, S.P., Duda, M.J., and Young, D.R. 1981. Consumption rates of potentially hazardous marine fish caught in the metropo litan Los Angeles area. As cited in USEPA

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cited in USEPA 2011.

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West, P.C., Fly, J.M., Marans, R., Larkin, F., and Rosenblatt, D. 1993. 1991-1992 Michigan sport anglers fish consumption study. Prepared by the University of Michigan, School of Natural Resources, for the Michigan Departme nt of Natural Resources. Technical Report No. 6. May 1993. As cited in USEPA 2011.

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# Appendices

Appendix A. Fish Consumption Rates for

Recreational FishersPage A-2 July 20, 2012 Technical Issue Paper This page purposely left blank for duplicate printing.Technical Issue PaperJuly 20, 2012Page A-3Table A-1. Recreational Marine Fish/Shellfish Consumption RatesSourcePurpose of StudyLocationPopulation/SubgroupType of Fish/ShellfishSampleSizeMedian(g/day)Mean(g/day)UpperPercentile(g/day)NotesWashington State StudiesSurvey of Fish ConsumptionPatterns of King CountyRecreational Anglers(Mayfield et al. 2007)To support environmental analysesof proposed capital improvementprojects.Elliott Bay,Duwamish River,and north KingCountyHouseholds with memberswho fish; consumers andnonconsumersMarine fish; species include seaperch, salmon, rockfish, sole,herring, flounder.4942153181 (95th)Creel survey/personal interviews at publicparks and boat launches; consumption ratecalculated using information on fishingfrequency, mean weight of catch at eachlocation (Elliott Bay, Duwamish River, NorthKing County), a cleaning factor, and number ofindividuals consuming the catch.Shellfish, primarily crabs andshrimp.961125119 (95th)1983-1984 Puget Sound Survey(Landolt et al. 1985, 1987);reanalysis by Tetra Tech 1988To identify most commonlyconsumed species, demographiccharacteristics of the fishingpopulation, and patterns ofconsumption.CommencementBay, Elliott Bay,Sinclair Inlet,EdmondsRecreational fishers and theirhouseholdsFish and shellfish: marketsquid, Chinook salmon, Cohosalmon, unidentified salmon,Pacific hake, Pacific cod, pileperch4,43711Creel survey; reported value is a geometricmean. Based on weight of catch, number ofconsumers in household, number of dayssince fish caught at the same site were lasteaten, and a cleaning factor.Recreational fishers (shoreanglers) and their households26.1246 (95th)Data reanalyzed by Tetra Tech (1988).Recreational fishers (boatanglers) and their households12.395.1 (95th)Data reanalyzed by Tetra Tech (1988).Seafood Catch and Consumptionin Urban Bays of Puget Sound(McCallum 1985); reanalysis byTetra Tech 1988To assess the number of peoplewith repeated, long-term exposureto fish and shellfish fromcontaminated urban bays.Port Gardner, ElliottBay, Sinclair InletShore-based recreationalfishers; consumers andnonconsumersSablefish, striped perch, pileperch, Pacific cod, Dungenesscrab, red rock crab, butterclams, littleneck clams; salmonand squid excluded7021.9NA24.3 (95th)Creel survey. Intake rates calculated by TetraTech (1988); methodology and assumptionsnot specified.Commencement Bay SeafoodConsumption Study (Pierce et al.1981); reanalysis by Price et al.(1994)To examine seafood consumptionpatterns and demographics ofsport fishermen in CommencementBay.CommencementBayShore and boat anglers;surveyed fishers onlyCommon species includedPacific hake, walleye pollock;salmon excluded50819NA155 (90th)Creel survey. Intake rates calculated by Priceet al. (1994).Shore and boat anglers; totalrecreational fisher population1.0NA13 (90th)Creel survey; results weighted inverselyproportional to sampling probability (Pricereanalysis).Other West Coast StudiesSan Francisco Bay SeafoodConsumption Report (SFEI 2000)To conduct a comprehensive studyof San Francisco Bay anglers.San Francisco Bay,CaliforniaRecreational fishers;consumers onlyMarine finfish, including stripedbass, halibut, jacksmelt,sturgeon, and white croaker.465162380 (95th)Questionnaire; consumers are respondentswho reported eating fish in the previous 4weeks.Seafood Consumption Survey ofthe Laotian Community of WestContra Costa County, CA(Chiang 1998)To obtain data on fishing and fishconsumption activities of theLaotian community.San Francisco Bay,CaliforniaMembers of the Laotiancommunity; consumers onlyMarine finfish, including catfishand striped bass.1999.121.485.1 (95th)Questionnaire; the proportion of reported fishconsumption that was self-caught is not clear.Seafood Consumption Habits ofRecreational Anglers in SantaMonica Bay (SMBRP 1994)To study the seafood consumptionhabits of recreational anglers inSanta Monica Bay.Santa Monica Bay,CaliforniaRecreational fishers;consumers onlyMarine finfish, including barredsand bass, Pacific barracuda,kelp bass, rockfish species,Pacific bonito,and Californiahalibut.55521.449.6161 (95th)Field survey: 28-day recall.Page A-4July 20, 2012Technical Issue PaperTable A-1. Recreational Marine Fish/Shellfish Consumption RatesSourcePurpose of StudyLocationPopulation/SubgroupType of Fish/ShellfishSampleSizeMedian(g/day)Mean(g/day)UpperPercentile(g/day)NotesNational Marine Fisheries Service(NMFS 1993); USEPA analysisTo estimate the size of therecreational marine finfish catch bylocation, species, and fishingmode, and to estimate the totalnumber of participants in marinerecreational finfishing and the totalnumber of fishing trips.Oregon andCalifornia (PacificRegion)Adult recreational fishers;consumers and nonconsumersMarine finfish1,827NA2.06.8 (95th)Intake rates calculated by USEPA.Consumption rate calculated from fieldintercept (creel) survey; estimated yearlyamount of fish caught (based on weight ofcatch) was adjusted by 0.5 assumed ediblefraction and 2.5 intended consumers percatch. No data for Washington.Oregon284NA2.28.9 (95th)Intake Rates of PotentiallyHazardous Marine Fish Caught inthe Metropolitan Los AngelesArea (Puffer et al. 1981);reanalysis by Price et al. (1994)To evaluate intake rates ofpotentially hazardous marinefish/shellfish by local, nonprofessional fishermen.Los Angeles,CaliforniaRecreational fishers; surveyedfishers onlyFinfish and shellfish1,05937NA225 (90th)Creel survey.Total recreational fisherpopulation2.9NA35 (90th)Creel survey; results weighted inverselyproportional to sampling probability (Pricereanalysis).Studies in Other RegionsConsumption Patterns and WhyPeople Eat Fish (Burger 2002a)To evaluate fishing behavior andconsumption patternsNewark Bay andNew York-NewJersey HarborestuaryRecreational fishers;consumers onlyMarine/estuarine fish111NA22.2NAInterviews with recreational fishers at variousfishing locations. Fish consumption rate isbased on number of reported fish meals permonth, an average portion size (8 ounces),and the number of months per year that selfcaught fish are consumed. Crab consumptionrate based on reported number of crabs eatenper month, an estimated average edibleportion weight (70 grams), and the number ofmonths per year that self-caught crabs areeaten.Marine/estuarine crabs110NA15.8NAAnalysis of Consumption ofHome-Produced Foods(Moya and Phillips 2001)To estimate consumption of selfcaught fish.United StatesHouseholds with memberswho fishFreshwater and saltwater fish220NA11.8NABased on USDA Nationwide FoodConsumption Survey. Intake calculated for fishtaken into the household; no correction appliedfor edible fraction.Fishing, Consumption, and RiskPerception in Fisherfolk along anEast Coast Estuary(Burger et al. 1998)To examine fishing behavior,consumption patterns, and riskperceptions of people fishing/crabbing in Barnegat Bay.Barnegat Bay, NewJerseyAdult recreational fishers;consumers and nonconsumersMarine finfish and shellfish,including bluefish, fluke/summerflounder, weakfish, and crabs.515NA48.3NAField survey: one-month recall.Finfish/Shellfish ConsumptionStudy - Alcoa (Point Comfort)/Lavaca Bay Superfund Site(Draft) (Alcoa 1998)To evaluate the quantity andspecies of finfish and shellfishconsumed by individuals who fishat Lavaca Bay.Lavaca Bay, TexasAdult male recreational fishers;consumers and nonconsumersSaltwater fish , including reddrum, speckled sea trout, andflounder.1,979NA24.868.1 (90th)Telephone and mailed surveys: 28-day recall.Consumption rates for women, small children,and youths also reported.Shellfish, including oysters, bluecrab, and shrimp.NA1.25.1 (95th)Fish Consumption of DelawareRecreational Fishermen andTheir Households(KCA Research Division 1994)To obtain information on thenumber of fishing trips, and theamount of fish caught, kept, andeaten by fishing households.DelawareMarine recreational fishers andtheir householdsMarine finfish; some freshwaterfish and crabs867NA17.5NATelephone survey: 30-day recall.Technical Issue PaperJuly 20, 2012Page A-5Table A-2. Recreational Freshwater Fish Consumption RatesSourcePurpose of StudyLocationPopulation/SubgroupType of Fish/ShellfishSampleSizeMedian(g/day)Mean(g/day)UpperPercentile(g/day)NotesWashington State StudiesSurvey of Fish ConsumptionPatterns of King CountyRecreational Anglers (Parametrix2003; Mayfield et al. 2007)To support environmental analysesof proposed capital improvementprojects.King County: LakeWashington, LakeSammamishHouseholds with memberswho fish; consumers andnonconsumersFreshwater fish including yellowperch, trout, salmon, bass,bullhead128010.341.7 (95th)Personal interviews at public parks and boatlaunches; consumption rate calculated basedon reported fish meals in the previous monthand meal size estimates based on visual aid.Consumption Patterns of AnglersWho Frequently Fish LakeRoosevelt (WDOH 1997)To determine the consumptionpatterns of anglers who repeatedlyfish this lake.Lake RooseveltRecreational fishers;consumers onlyRainbow trout, walleye,kokanee, bass348NA2267 (95th)Interviews at fishing locations; consumptionrate based on number of fish meals reportedper week and assumed 8-ounce meal size (L.Kissinger, personal comm., 6/6/2012)Lake Whatcom Residential andAngler Fish Consumption Survey(WDOH 2001)To gather exposure information foruse in assessing the human healthimplications associated with theconsumption of mercurycontaminated fish from LakeWhatcom.Lake WhatcomBoat anglers, shore anglers,and residents living on or nearthe lakeSmallmouth bass, cutthroattrout, yellow perch, kokanee220NA6.0NAPersonal interview, 4-week recall. Elevatedmercury levels and media reports may haveaffected fish consumption. Calculated basedon number of fish per meal, how many monthsfish were consumed, and average fillet weightfor each species (as presented in ODEQ2008).Other West Coast StudiesFish Consumption andRecreational Use Surveys -Columbia Slough (AdolfsonAssociates 1996)To provide information on thefishing habits of people angling inthe Columbia Slough.Columbia Slough,Portland, OregonColumbia Slough fishermen,consumers onlyResident finfish and shellfish,fresh and estuarine8424NA36 (75th)Creel survey; fish consumption rates based onfish weights, assumed edible fraction, andhousehold size.Sauvie Island,Portland, OregonSauvie Island fishermen,consumers only353.8NA5.7 (75th)Contaminated Fish Consumptionin California's Central Valley(Shilling et al. 2010, as cited inUSEPA 2011)To assess consumption ofcontaminated fish in a region withhigh subsistence fishing rates.Sacramento-SanJoaquin River Delta,CaliforniaRecreational and subsistenceanglersStriped bass, salmon, shad,catfish37319.727.4127 (95th)Interviews at fishinglocations; 30-day recall.Studies in Other RegionsDaily Consumption of Wild Fishand Game (Burger 2002b, ascited in USEPA 2012)To determine consumption patternsfor wild-caught fish and game byhigh-end recreationists.South CarolinaHigh-end recreational anglersSport-caught fish, freshwaterand marine45817.650.2216 (95th)Personal interviews at sportsman event. One-year dietary recall.High-end recreational anglers,male30821.355.2235 (95th)High-end recreational anglers,female14911.639.1172 (95th)Fishing Along the Clinch RiverArm of Watts Bar Reservoir(Campbell et al. 2002, as cited inUSEPA 2011)To examine consumption habits ofanglers fishing along the ClinchRiver near the USDOE Oak RidgeReservation.Clinch River,TennesseeRecreational anglers,consumers onlyLocally-caught freshwater fish,including crappie, striped bass,white bass, sauger, and catfish202NA20.3NAPersonal interviews at fishing locations.Annual reported fish consumption divided by365.Recreational anglers,consumers who eat fish fromthe study area77NA37.5NAAnalysis of Consumption ofHome-Produced Foods (Moyaand Phillips 2001, as cited inUSEPA 2011)Analysis of data from thehousehold component of theUSDA's 1987-1988 National FoodConsumption Survey.NationalFishers, consumers onlySelf-caught fish, freshwater andsaltwater220householdsNA6.0NAPage A-6July 20, 2012Technical Issue PaperTable A-2. Recreational Freshwater Fish Consumption RatesSourcePurpose of StudyLocationPopulation/SubgroupType of Fish/ShellfishSampleSizeMedian(g/day)Mean(g/day)UpperPercentile(g/day)NotesMinnesota and North DakotaFish Consumption Survey(Benson et al. 2001, as cited inUSEPA 2011)To evaluate fish consumption bythe general population, licensedanglers, and members of NativeAmerican tribes.MinnesotaLicensed anglersSport-caught fish, freshwaterand marine2,0203.9NA30.4 (95th)Mail survey.Fish from all sources2,02013.2NA64.5 (95th)North DakotaLicensed anglersSport-caught fish, freshwaterand marine1,1014.5NA30.8 (95th)Fish from all sources1,10114.0NA76.2 (95th)Examination of FishConsumption by IndianaRecreational Anglers (Williams etal. 2000, as cited in USEPA2011)To evaluate fish consumption byIndiana recreational anglers as afunction of ethnicity and income.IndianaCaucasian recreationalanglersSport-caught fish1777.620113 (95th)On-site surveys at fishing locations; 3-monthrecall period.Minority recreational anglersSport-caught fish1437.627.2136 (95th)Role of Self-Caught Fish andWild Game in Meat and FishDiets (Burger 2000, as cited inUSEPA 2011)To evaluate sex differences inconsumption patterns of selfcaught fish and wild game in ameat and fish diet.South CarolinaHigh-end recreational anglers,maleSport-caught fish, freshwaterand marine457NA27.5NAPersonal interviews at sportsman event.Consumption rates calculated based onreported monthly meal frequency and mealsize.High-end recreational anglers,femaleSport-caught fish, freshwaterand marineNA11.6NAConsumption of Indiana SportCaught Fish (Williams et al.1999, as cited in USEPA 2011)To estimate consumption of sportcaught fish by licensed Indianaanglers.IndianaRecreational anglers,consumers onlySport-caught fish1,0459.519.860.5 (95th)Mail survey, 3-month recall period.Ethnic and SocioeconomicDifferences in Fishing andConsumption of Fish CaughtAlong the Savannah River(Burger et al. 1999, as cited inUSEPA 2011)To examine the differences infishing rates and fish consumptionof people fishing along theSavannah River as a function ofdemographics.Savannah River,GeorgiaRecreational anglers,consumers and nonconsumersSport-caught fish252NA48.7NAPersonal interviews at fishing locations.Consumption rate calculated based onreported servings per month and meal size.Quantification of SeafoodConsumption Rates forConnecticut (Balcom et al. 1999,as cited in USEPA 2011)To evaluate seafood consumptionrates for Connecticut residentsConnecticutSport-fishing households,consumers and nonconsumersSport-caught fish, freshwaterand saltwater502NA51.1NAMail survey with portion size models, and 10-day diary. Consumption rate reflects cookedweights.Sport-fishing households,consumers only487NA52.7NASportfish Consumption Patternsof Lake Ontario Anglers and theRelationship to Health Advisories(Connelly et al. 1996, as cited inUSEPA 2011)To provide accurate estimates offish consumption among LakeOntario anglers, and to evaluatethe effect of health advisoryrecommendations.Lake OntarioLicensed anglers in sixcounties bordering LakeOntarioSport-caught finfish3662.24.917.9 (95th)Consumption rates based on self-recordeddiary information plus follow-up telephonecalls. Health advisories in effect, which mayhave impacted consumption rates.Fish from all sources36614.117.942.3 (95th)Estimation of Daily Per CapitaFreshwater Fish Consumption ofAlabama Anglers (ADEM 1994,as cited in USEPA 2011)To estimate fish consumption forsport-fishing Alabama anglers.AlabamaRecreational anglers,consumers onlySport-caught fish563NA43.1NAPersonal interviews at fishing locations;consumption based on "harvest method"which used actual harvest of fish and dressingmethod.1,313NA44.8NAPersonal interviews at fishing locations;consumption rate estimates based on "4-ounce serving method."Technical Issue PaperJuly 20, 2012Page A-7Table A-2. Recreational Freshwater Fish Consumption RatesSourcePurpose of StudyLocationPopulation/SubgroupType of Fish/ShellfishSampleSizeMedian(g/day)Mean(g/day)UpperPercentile(g/day)NotesFollow-up to Michigan SportAnglers Fish ConsumptionSurvey (West et al. 1993, ascited in USEPA 2011)To provide short-termrecall data offish consumption by recreationalanglers over a full year.MichiganRecreational anglers,consumers onlySport-caught fish2,475NA16.777.9 (95th)Mail survey based on 7-day recall; 95thpercentile (calculated by EPA) is believed toconsiderably overestimate long-termpercentiles.Effects of Health Advisory andAdvisory Changes on FishingHabits and Fish Consumption inNew York Sports Fishers(Connelly et al. 1992, as cited inUSEPA 2011)To assess the awareness andknowledge of New York anglersabout fishing advisories andcontaminants, and their fishing andfish consuming behaviors.New YorkRecreational anglers,consumers onlySport-caught fish1,030NA27.4NAMail survey based on one-year recall.Assumes 8-ounce meal size. Fish advisoriesin effect.Consumption of Freshwater Fishby Maine Anglers (Chemrisk1992, as cited in USEPA 2011)To characterize the rates offreshwater fish consumptionamong Maine residents.Maine - flowing andstanding waterbodiesLicensed anglers and theirhouseholds, consumers onlySalmon, white perch, brooktrout1,0532.06.426.0 (95th)Mail survey based on one-year recall;calculated from estimated weight of fishcaught, edible fraction, and number ofintended consumers.Licensed anglers and theirhouseholds, consumer andnonconsumers1,3691.15.021.0 (95th)Michigan Sport Anglers FishConsumption Survey (West et al.1989, as cited in USEPA 2011)To evaluate sport angler fishconsumption by Michigan residentswith fishing licenses.MichiganLicensed anglers and theirhouseholdsSport-caught fish73810.914.438.7 (95th)Survey based on one-year recall (usualintake). Serving size assumed to be 8 ounces.Consumption rates calculated by EPA.NA14.0NASurvey based on short-term (7-day) recall;serving size based on comparison to picturesof an 8-ounce portion. Consumption ratecalculated by EPA.Fish from all sources73824.227.758.1 (95th)Survey based on one-year recall (usualintake). Serving size assumed to be 8 ounces.Consumption rates calculated by EPA.Sport Fish Consumption andBody Burden Levels ofChlorinated Hydrocarbons (Fioreet al. 1989, as cited in USEPA2011)To assess sociodemographicfactors and sport-fishing habits ofanglers, to evaluate anglers'comprehension of fish advisories,and to examine the relationshipbetween body burden levels ofPCBs/DDE with consumption ofsport-caught fish.WisconsinLicensed anglers, consumersand nonconsumersSport-caught fish8016.211.237.2 (95th)Based on one-year recall survey. Intakescalculated by EPA, assuming an 8-ounce mealsize.Licensed anglers, consumersonlySport-caught fish729NA12.337.3 (95th)

# Technical Issue Paper



# Health Benefits and Risks of Consuming Fish and Shellfish

# Technical Issue Paper



# Health Benefits and Risks of Consuming Fish and Shellfish

July 20, 2012

Toxics Cleanup Program

Washington State Department of Ecology

Olympia, WashingtonTechnical Issue Paper July 20, 2012 Page i 

# Table of Contents

Page

List of Figures and Tables..................................................................................................... .......... ii Figures........................................................................................................................ ............... ii

Tables ........................................................................................................................ ................ ii

Acronyms & Abbreviations ...................................................................................................... ..... iii

Introduction .................................................................................................................. ....................1

Analysis....................................................................................................................... .....................2

I. Benefits associated with eating fish and shellfish ..........................................................2

A. Seafood as a high quality protein source .......................................................................2

B. Seafood as a source of es sential fatty acids ...................................................................2

C. Seafood as a source of nutrients (vitamins and minerals) ..............................................4

D. Seafood consumption and improved health outcomes ...................................................5

II. Risks associated with eating fish and shellfish ............................................................12

A. Brief summary of potenti al health effects ....................................................................12

B. Adverse health effects associated with primary contaminants of concern ..................14

III. Comparison of health benefits and risks ......................................................................17

A. Metrics for evaluating risks .........................................................................................17

B. Risk/Benefit Comparisons ...........................................................................................17

Conclusions ................................................................................................................... .................34

References .................................................................................................................... ..................35Page ii July 20, 2012 Technical Issue Paper 

# List of Figures and Tables

Figures

Page

Figure 1. n-3 PFA intake and mercury exposure (hai r-mercury) compared to the mercury RfD and recommended daily allowance of DHA=EPA ...............................................27

Figure 2. Decision pathway representing the balance between benefits and risks associated with seafood consumption ............................................................................................29

Figure 3. EPA+DHA and mercury content in representative seafood portions ...........................30



## Tables

Page

Table 1. Frequency of consumption rank a nd concentrations of n-3 PFAs ..................................3

Table 2. Classification of the cont ent of EPA plus DHA by total mercury content in 96 finfish and shellfish species ..........................................................................................18

Table 3. Classification of the content of EPA + DHA by dioxin content in 76 finfish and shellfish species ............................................................................................................1 9

Table 4. Estimated changes in child IQ resulting fr om maternal consumption of fish with different methylmercury and EPA plus DHA contents a ...............................................20

Table 5. Estimated changes in mortality per million people from consuming fish with different dioxin and EPA plus DHA contents a ............................................................21

Table 6. Fish Species Most Consumed (>4 percent of total) for Japanese Population ...............25

Table 7. Fish Species with Greatest Mercury Intake (>5 percent of total) for Japanese Population .................................................................................................................... .25

Table 8. Fish Species Most Consumed (>4 percent of total) for Korean Population .................26

Table 9. Fish Species with Greatest Mercury Inta ke (>5 percent of total) for Korean Population .................................................................................................................... .26

Table 10. Estimated mercury intake from fish c onsumption for Tulalip Tribes, Squaxin Island Tribe, and Suquamish Tribes .............................................................................32Technical Issue Paper Ju ly 20, 2012 Page iii 

# Acronyms & Abbreviations

AD Alzheimer’s disease

AHA American Heart Association
ALA alpha-linoleic acid
AMD age-related macular degeneration
BMD bone mineral density
CHD coronary heart disease
CKD chronic kidney disease

CVD cardiovascular disease
DDT dichloro diphenyl trichloroethane
DEHP di-ethylhexyl phthalate

DHA docosahexaenoic acid
DPA docosapentaenoic acid
Ecology Washington State Department of Ecology

EPA eicosapentaenoic acid

FAO Food and Agriculture Organization of the United Nations

IOM Institutes of Medicine
LCP long-chain polyunsaturated fatty acid

n-3 PFA or PUFA Omega-3 polyunsaturated fatty acid
NSAID nonsteroidal anti-inflammatory drug
PAH polycyclic aromatic hydrocarbon

PBT Persistent Bioaccumulative Toxics

PCB polychlorinated biphenyl

PCDD polychlorinated dibenzo- p -dioxin
PCDF polychlorinated dibenzofuran
PTMI provisional tolerable monthly intake

TCDD 2,3,7,8-tetrachlorodiobenzo- p -dioxin
TERA Toxicology Excellence for Risk Assessment
TEQ toxic equivalent

TSD Fish Consumption Rates Technical Support Document
USDA U.S. Department of Agriculture
USEPA U.S. Environmental Protection Agency
WDOH Washington Department of Health
WHO World Health OrganizationPage iv July 20, 2012 Technical Issue Paper This page purposely left blank for duplicate printing.Technical Issue Paper July 20, 2012 Page 1 

# Introduction

Multiple comments received by the Washington St ate Department of Ecology (Ecology) on the

draft Fish Consumption Rates Technical Support Document (TSD) (Ecology 2011) asked why

the TSD did not include a discussi on of the relative bene fits of consuming fish and shellfish or address the potential public hea lth risks if people consume less fi sh. Others also suggested that the TSD should include some information rega rding the contaminant concentrations in Washington State fish and shellfish.

Fish is a good source of protein and, unlike fatty meat products, it is not high in saturated fat. Fish is also a good source of omega-3 fatty aci ds. Omega-3 fatty acids benefit the heart of healthy people, and those at high risk of, or wh o have, cardiovascular disease. While some types of fish may contain high levels of mercury, PCBs (polychlorinat ed biphenyls), dioxins and other environmental contaminants, the American Heart Association recommends eating fish (particularly fatty fish) at least two times (two servings) per week. 1

According to the Food and Agriculture Organizat ion of the United Nations, worldwide fish consumption reached an all-time high in 2011, with an average consumption of 17 kg per

person. 2

This Technical Issue Paper summarizes the known health benefits of consuming seafood and the

risks associated with a set of common contaminants in Washington State seafood, and compares these health benefits and risks. It is a target ed examination of the issues raised by review comments received on the draft TSD, and was prepar ed within a limited time frame. Therefore, it may not include all available information on this subject.

Throughout this paper, use of the word “seafood” denotes fish and shellfish. A review of Washington State seafood contaminant concentr ations and potential human exposures is presented in another T echnical Issue Paper ( Chemical Contaminants in Dietary Protein Sources)

.

1 http://www.heart.org/HEARTORG/GettingHealthy/Nutrit ionCenter/HealthyDietGoals/Fish-and-Omega-3-FattyAcids_UCM_303248_Article.jsp

2 http://www.fao.org/news/story/en/item/50260/icode/Page 2 July 20, 2012 Technical Issue Paper 

# Analysis

I. Benefits associated with eating fish and shellfish

The most recent guidance from the American H eart Association (AHA) recommends eating fish, particularly fatty fish (e.g., salmon, anchovy, he rring), at least two times per week (AHA 2012). The following sections describe why fish and she llfish are recommended as an important part of

the diet.



### A. Seafood as a high quality protein source

Fish is a good source of high quality protein th at is not high in saturated fat (USDA 2010; AHA 2012). Saturated fats have a chemical makeup in which the carbon atoms are saturated with hydrogen atoms and are typically so lid at room temperature. Eati ng foods that contain saturated

fats raises the level of choleste rol in the blood. High levels of bl ood cholesterol increase the risk of heart disease and stroke. Many foods high in sa turated fats are also high in cholesterol.

Shellfish contain more cholestero l than most types of fish, but are very low in saturated fat (AHA 2012). A significant proportion of dietary fish intake is comprised of protein (Undeland et al. 2009). Fish proteins are c onsidered easily digestible and ar e rich in essential amino acids (the building blocks of proteins) (review in Costa 2007). Essential amino acids are those that cannot be made by the body and must be supplied in the diet.



### B. Seafood as a source of essential fatty acids

Omega-3 (n-3 polyunsaturated) fatty acids (n-3 PFAs) are essentia l fats that the body needs to function properly but cannot make on its own. Humans must get n-3 PFAs from foods. The n-3 PFAs that are particularly important in human nutrition include: alpha-linoleic acid (ALA), eicosapentaenoic acid (EPA), docosapentaenoic acid (DPA), and docosahexaenoic acid (DHA) (review in Mahaffey et al. 2011). EPA and DH A are important for human neurological development. These two n-3 PFAs play a role in: (1) cell membrane fo rmation, integrity, and functions; (2) functioning of br ain, retina, liver, kidney, adrenal glands, and gonads; and (3) local hormone production for the regulation of blood pressure and immune and inflammatory

responses.

Humans can synthesize some of their requirement for long-chain PFAs from ALA (a short-chain PFA), but generally not in the amounts sufficien t to meet dietary needs (review in Mahaffey et al. 2011). Fish is rich in the very long-chain n-3 PFAs EP A and DHA. Fish and shellfish acquire these PFAs by consuming algae (or other fish). Certain fatty fish (e.g., salmon, herring, sardines, mackerel) are also high in n-3 PFAs (Tab le 1). Some that are low in fat (e.g., trout and shrimp) are also good sources of n-3 PFAs.Technical Issue Paper July 20, 2012 Page 3 Table 1. Frequency of consumption rank and
concentrations of n-3 PFAs

Rank Species EPA + DHA (mg/100g fish)*
1 Shrimp 390
2 Tuna (all, average) Tuna canned – light (skipjack) Tuna canned – white (albacore) Tuna fresh – Bluefin (7 kg) Tuna fresh – Skipjack (3 kg) Tuna fresh – Yellowfin (5-20 kg) 630
128 – 270**

862 1,173 – 1,504**

256 – 328**
100 – 120**
3 Breaded fish products 0.26
4 Salmon 1,590

5 Crabs 36

6 Catfish 280

7 Other fish 54
8 Scallops 270

9 Lobster 360

10 Clams 240

11 Cod 240
12 Oysters 350

13 Other shellfish 310

14 Flatfish 15

15 Unknown fish 53

16 Pollock 260

17 Mussels 350

18 Trout 580

19 Haddock 180
20 Crayfish 380

21 Perch 300

22 Sardines 980

23 Swordfish 580
24 Bass (freshwater) 640

25 Sea bass 490

26 Pike 140
27 Mackerel – except King King mackerel 1,790

401

28 Shark 220
29 Walleye 530
30 Porgy 210

Source: Adapted from Mahaffey et al. 2011 *100 grams is equivalent to a 3.5-ounce serving ** range shown is raw vs. cookedPage 4 July 20, 2012 Technical Issue Paper 

### C. Seafood as a source of nutrients (vitamins and minerals)

Many Americans do not eat the variety and amou nts of foods necessary to supply needed nutrients (USDA 2010). Seafood supp lies a number of these essent ial vitamins and minerals, including: vitamins A, B3, B6, and B12, and D, and the minerals calcium, iron, selenium, and zinc (summarized from USEPA a nd TERA 1999; USDA 2010, others).

a. Vitamins

Vitamin A (retinol, retinal, retinoic acid) is a fa t-soluble vitamin that is critical for vision, growth, bone development and maintenance, a nd immune function, among others. In general,

fish is a better source of Vitamin A than b eef, pork, or chicken, and higher-fat fish species

contain more of this vitamin than lower-fat species. Some foods, su ch as milk, are fortified with

this vitamin.

Vitamins B3 and B6 are water soluble – they mu st be supplied daily in the diet because the body stores these vitamins only briefly. Vitamin B3 (niacin, nicotinic acid, and nicotinamide) is involved in hydrogen transfer reac tions and deficiency in the diet causes a condition called Pellagra, which is characterized by diarrhea, de rmatitis, and dementia. Vitamin B6 exists as

several different chemical structures that serv e as important co-enzymes in various chemical reactions in the body that are i nvolved predominantly in metabolism. Deficiency in Vitamin B6 is very rare in the United States. Vitamin B12 is important in normal func tioning of the brain and nervous system and for the formation of blood. It is produced by microorg anisms in animals and does not occur naturally in plant foods. Defici encies of Vitamin B12 generally occur if absorption from food is impaired. Sport-caught fish (salmon, trout, channel catfish) are excellent

sources of this vitamin.

Vitamin D is a fat-soluble vitamin that occurs na turally in several forms and can be synthesized in the skin when sun exposure is adequate. Vi tamin D acts like a ster oid hormone, controlling blood levels of calcium to affect bone, kidney, an d intestinal tissues. Deficiency of Vitamin D

leads to bone demineralization and a condition ca lled osteomalcia (in ch ildren it is called rickets). Fish is among the best food sources of this vitamin. Some foods, such as milk and some packaged orange juices, are fo rtified with this vitamin.

b. Minerals

Calcium is necessary for bone health as well as nerve transmission, constriction and dilation of blood vessels, and muscle contraction. Low calcium intake is associated with low bone mass and risk of bone fractures. Dairy pr oducts provide about one-half of dietary calcium in the United States. Fish with soft bones (walleye, bass, and yellow perch), small fish eaten whole (sardines, smelts), and canned fish with bones (salmon) can contribute substantial amounts of calcium to

the diet.

Iron is an essential part of many proteins and enzymes, incl uding the proteins involved in oxygen transport (hemoglobin, myoglobin). It is also important in ma ny enzyme oxidation/reduction reactions. Iron deficiency is the most common nu tritional deficiency in the United States The heme form of iron, which is the most readily ab sorbed form, can be found in animal foods (meat fish). Seafood is a good source of heme iron.Technical Issue Paper July 20, 2012 Page 5 Selenium, an essential nutrient, is present in the cells of all mammals. When bound to certain proteins, selenium acts as an antioxidant by deto xifying free radicals. Sele nium must be supplied through dietary sources. Seafood and organ meats su ch as liver are the best sources of dietary

selenium.

Zinc is part of many enzymes and deficiencies can cause stunted growth and delayed sexual maturation. In general, foods rich in protein are also good sources of zinc. Insufficient zinc levels are common in North America, particul arly in vegetarians and adult women.



### D. Seafood consumption and improved health outcomes

Seafood consumption is linked with improvements in health conditions including cardiovascular disease, arthritis, and cancer. The following sections summarize re views of the published evidence regarding the various health benefits of seafood consumption. Where the evidence to support a link between seafood c onsumption and a specific health benefit is considered preliminary and further research is needed (e.g., w ith treatment of mood diso rders), this is noted

in the review for that condition.

There has been a tremendous amount of research in to the health benefits of seafood consumption in recent years. A Google Scholar® search 3 of scientific literature using the keywords seafood +benefits +risk +review and limiting the results of the search to the last two years turned up over 2,700 articles and reports. McManus et al. (2010) provide a recent overview of health benefits from seafood consumption, although this is aimed toward benefits in the elderly. For this issue paper, the McManus et al. (2010) review was used as the basis for most of the discussions of health benefits and was augmented usi ng primary literature and other reviews.

a. Cardiovascular disease/stroke

Over 81 million Americans (37 percent of the pop ulation) have cardiovascular disease (CVD) (AHA 2010). Major risk factors fo r CVD include high levels of blood cholesterol and other lipids, type 2 diabetes, hypertension (high blood pressure), metabolic syndrome, obesity, physical inactivity, and tobacco use. Hypertensi on affects 34 percent of Americans and is a major risk factor for heart disease, stroke, c ongestive heart failure, and kidney disease.

From McManus et al. 2010: “Strong evidence exis ts supporting the assertion that fish intake significantly contributes to the maintenance of heart health, protecting against cardio-vascular diseases, particularly ischemic stroke. Even a small amount of fish can provide a protective health effect for seniors. For example, 1 to 2 se rves a week of oily fish (sardines, salmon, trout)

is associated with a reduced ra te of hospitalization and mortalit y, with the highest evidence for

older women.”

Consumption of 1 to 2 fish meals per week lowers the relative risk of mortality from coronary heart disease (CHD) by 20 to 30 percent (Costa 2007) . In fact, moderate ev idence indicates that consumption of about 8 ounces of seafood per week is associated with reduced cardiac deaths among individuals with and without pre-exis ting CVD (AHA 2010). DHA a nd EPA in the diet likely reduce the risk of fatal CHD by reducing cardiac arrhythmias (Har ris et al. 2009). An

3 http://scholar.google.com/Page 6 July 20, 2012 Technical Issue Paper arrhythmia is a problem with the rate or rhythm of the heartbeat – too slow, too fast, or with an irregular rhythm. A review by Dórea (2008) found tw o studies indicating that the cardiovascular benefits of fish are due not only to the n-3 PFAs but also to the fish proteins. Even short-term DHA + EPA consumption (> 1 to 2 g/day) favorably affects many physiological measures of cardiovascular risk including blood pressure, resti ng heart rate, triglyceri de levels, and possibly heart rate variability (Harris et al. 2009). Other reviews have concluded that n-3 PFAs alone do not have a clear effect on total mortality or co mbined CVD events and that positive effects were only seen when taking into account fish-based st udies (Undeland et al. 2 009). This suggests that other, non-n-3 PFA compounds in fish contribute to cardio-protec tive and neuro-protective value of fish consumption. For example, Vitamin D insufficiency has been related to CVD, and

reduced Vitamin D status has been associated with several CVD risk factors including blood pressure and body-mass index.

Djoussé et al. (in press) conducted a meta-analysis 4 of cohort studies that evaluated the association between fish consumption or n-3 PFA and heart failure. The authors retained seven prospective studies conducted in the United States (four studies) or Europe (three studies) with 176,441 participants in whom 5,480 incident hear t failures occurred. The average duration of follow-up in the studies was 13.33 y ears. The analysis found that higher fish consumption and a higher dietary or plasma concentration of EP A/DHA were each associated with about a 15 percent lower risk of heart failure compared w ith the lower exposure cate gory (i.e., those who ate less fish or had less EPA/DHA in their plasma). The authors noted that their conclusions were

based on a rather small number of observati onal studies (albeit wi th a large number of individuals when combined), and stressed that th e findings need to be confirmed with a large

randomized trial.

Dekelbaum and Calder (2012) discuss reviews and meta-analyses favorable to n-3 PFAs in lowering the risk for CHD and myoc ardial infarction (heart attack), in contrast to some recent

clinical trials that found no or very little benefit from EPA and DHA. These experts concluded that, although the results of recen t trials have been mixed, “it seems safe and sensible to follow

the American Heart Association’s recommendations th at all adults eat fish (especially fatty fish)

at least twice a week...” Eussen et al. (2011) theorized th at recent failures of secondary prevention trials to demonstrate a beneficial effect of n-3 PFAs on cardiovascular outcomes may be due to the growing use of statin drugs sinc e the mid-1990s. When the patients in one of those trials (the Alpha Omega Trial) were divided into statin-users and statin non-users, it was found that statins modify the effects of n-3 PFAs on majo r cardiovascular events (fatal cardiovascular diseases, non-fatal myocardial infarction, non-fata l cardiac arrest , non-fatal stroke and cardiac interventions) after myocardial infarction. In statin users, supp lementation with n-3 PFAs had no effect. In the statin non-users, n-3 PFA suppl ementation (EPA-DHA plus ALA) had 54 percent fewer major cardiovascular events than those on placebo.

Evidence for effects on stroke is mixed. Meta-a nalyses indicate a 30 pe rcent lower risk of

ischemic stroke with fish intake of ≥ 1 meal/week compared with < 1 meal/month (Harris et al. 2009). Ischemic stroke involves blockage of th e arteries leading to the brain caused by

4 A meta-analysis is a study in which the results of other studi es, all published on the same topic, are combined so as to gain more information regarding the shared area of inquiry; the larger size of the pooled data lends more evidence to any conclusion s that are drawn.Technical Issue Paper July 20, 2012 Page 7 artherosclerosis and thrombosis (Undeland et al. 2009). The mechanisms protecting against

ischemic stroke are believed to be the same as those for CHD.

b. Arthritis

Rheumatoid arthritis is a chroni c inflammatory autoimmune diseas e of the joints and bones. The n-6 PFA arachidonic acid is the precursor of in flammatory compounds (eicosanoids), which are

involved in rheumatoid arthritis. The n-3 PFA s EPA and DHA decrease the arachidonic acid

content of cells involved in autoimmune responses, decreasing th e production of the inflammatory eicosanoids (summary in Miles an d Calder 2012). In a case control study, Rossell et al. (2009) found that the risk for developing rheumatoid arth ritis was 20 percent lower for those who consumed oily fish one to seven ti mes per week compared to those who never or seldom consumed oily fish. These research ers found no effect of n-3 PFA supplements on

incidence of rheumatoid arthritis.

Studies in Japan and of Eskimos ha ve suggested that consumption of oily fish reduces the risk of rheumatoid arthritis (review in Lahiri et al. 2012) . Miles and Calder (2012) reviewed the results of 23 randomized controlled studies of patients w ith rheumatoid arthritis and found evidence “for a fairly consistent, but modest, benefit of ma rine n-3 PFAs on joint swelling and pain, duration of morning stiffness, global assessments of pa in and disease activity, and use of non-steroidal anti-inflammatory drugs.”

Greater intake of Vitamin D is also associated with lower risk for rheumatoid arthritis and improvement in rheumatoid arthritis patients (U ndeland et al 2009). Vita min D could have an immunosuppressive role in these effects, but mo re research is needed (Undeland et al. 2009). A more recent review by Lahiri et al. (2012) found th at the effect of Vita min D deficiency, with respect to rheumatoid arthritis, remains unclear.

c. Cancer

McManus et al. (2010) state that “high fish intake has been asso ciated with significantly reduced

risk of ovarian and colorectal cancer. Furt hermore, findings from a recent United Kingdom Women’s Cohort Study of 35,372 wo men supports the assertion that postmenopausal women who consumed fish experienced a significantly reduced risk of breast cancer when compared with red meat consumers, indicating reduced risk in older women who prefer fish as a primary protein source to the exclusion of red meat. High level evidence supports fish consumption as protective in reducing the risk of prostate and lung cancers in males. Increased consumption of seafood also confers protection against the deve lopment of esophageal cancer in males aged 45 years and older in large populati on-based studies.” A systematic review by Gerber (2012) found that there is increasing evidence suggesting a reduced risk of br east cancer associated with longchain PFAs from fish consumption. In a cohort study of women who had been diagnosed with early stage breast cancer, Patters on et al. (2011) found that women with higher intakes of EPA and DHA from food had an approximately 25 per cent lower risk of additional breast cancer events compared to women in the group with the lowest intake. These women also had a dosedependent reduced risk of all- cause mortality. EPA and DHA inta ke from supplements, however,

was not associated with breast cancer outcomes in this study.Page 8 July 20, 2012 Technical Issue Paper Undeland et al. (2009), summar izing the benefits of seaf ood consumption, stated that

observational studies 5 on fish consumption have shown prot ection for risk of digestion tract cancers (oral cavity and pharynx, esophagus, stom ach, colon, and rectum) and also for ovary, pancreas, larynx, and endometr ial cancers. Prospective 6 and case-control 7 studies, however,

either do not show an association between fish inta ke and cancer risk, or only show reduced risk at high fish intake levels. Harri s et al. (2009) states that th e preponderance of evidence for anticarcinogenic effects of EPA + DHA is weak de spite persuasive data from animal models and cultured tumor cell lines. However, a review and meta-analysis of fish consumption and prostate cancer risk that found no strong ev idence of a protective association between fish consumption and prostate cancer risk did s how a significant 63 per cent reduction in pros tate cancer-specific mortality (Scymanski et al. 2010). Cockbain et al . (2012) reviewed the re search to date on n-3

PFAs and colorectal cancer and found that there is growing epidemiological, experimental, and

clinical evidence that n-3 PFAs have anti-colorectal cancer activity and that they may play a role in primary prevention as well as treatment of colo rectal cancer and advanced metastatic disease. A meta-analysis of 22 prospectiv e case studies and 19 case-control studies by Wu et al. (2012) found that fish consumption decreased colorect al cancer incidence by 12 percent. However, a review by Gerber (2012), indicated that evidence is too limited to draw firm conclusions on the effect of long-chain n-3 PFA s and colorectal cancer.

d. Macular degeneration

n-3 PFAs are found in photoreceptor outer segmen t membranes and are a potentially important nutrient for eye health (Lim et al. 2012). Depl etion of DHA may impair retinal function and influence the development of a condition known as age-related macula r degeneration (AMD) (Souied 2012). AMD is a deterioration or breakdo wn of the eye’s macula and is a common eye condition among people age 50 and older. The macula is the part of the eye that provides sharp, central vision needed for seeing objects clearly. AMD is a leading cause of vision loss in older adults. Cardiovascular disease is a system risk factor for AMD and cardiovascular risk factors such as hypertension have been linked with AMD (Lim et al. 2012). As noted above, intake of seafood and n-3 PFAs can improve cardiovascular health.

In a European study, consumption of oily fish at least once per week reduced the risk of neovascular AMD by one-half comp ared with consumption less th an once per week (review in Souied 2012). Recently, a cohort study of fema le medical professionals (over 38,000 with average age of 54) found regular consumption of DHA and EPA and fish was associated with significantly decreased risk of incident AMD and may be of be nefit in primary prevention of AMD (Christen et al. 2011). Women who consumed one or more servings of fish per week, compared with those who consumed less than on e serving per month, had a relative risk of AMD of 0.58. According to the review by Souied (2012 ), the growing body of evidence shows that the regular consumption of oily fish or a higher in take of n-3 PFAs is associated with a 30 to 50

5 An observational study draws inferences about the possible effe ct of a treatment on subjects, where the assignment of subjects into a treated group versus a control group is outside the control of the investigator.

6 An analytical study designed to determine the relationship betwe en a condition and a characteristic shared by some members of a group.

7 An analytical study which compares individuals who have a specif ic disease ("cases") with a group of individuals without the disease ("controls").Technical Issue Paper July 20, 2012 Page 9 percent risk reduction in the o ccurrence or progression of AMD. However, Souied (2012) also noted that the majority of evidence is observation al and further research involving cohort studies

and randomized clinical trials is needed.

e. Cognitive function

According to McManus et al. (2010), “omega-3 PUFAs in seafood play an important role in neurological structure and f unction. Docosahexaenoic acid ( DHA), a long-chain marine PUFA found in seafood, is a catalyst for the slowing of early stage progression of dementia. Further study is expected to shed light on how DHA poten tially prevents the neurological damage that

results from dementia.” The review further st ates that “research from marine and human epidemiological studies suggest that ‘higher fish consumption is a ssociated with better cognitive function in later life’, enabli ng resistance to cognitive declin e. Recent evidence strongly associates a dietary profile in which fish features prominently, with lower risk of developing Alzheimer’s disease (AD) and maintaining c ognitive function. Evidence increasingly supports the assertion that marine source omega-3 PUFAs in fish play a role in delaying onset and arresting the progression of AD, though further studies are needed to investigate the mechanism

involved.”

The EPA and DHA review by Harris et al. (200 9) found that the available evidence for protective effects of long-chain PFAs from fish on the risk of dementia is promising but limited. Epidemiological evidence is positive for benefits of just one fish meal pe r week on the risk of Alzheimer’s disease, dementia, and cognitive decline. Animal eviden ce supports a protective relationship of n-3 PFAs on neurode generation of the brain with aging, and several studies in progress in the United States and Europe should shed more light on this relationship. Cunnane et al. (2012) note that the negativ e results of clinical trials with DHA supplements do not agree with the largely protect ive link of fish and DHA that is s een in prospective epidemiological

studies. In a review that incl uded seven studies of the effect s of supplements containing longchain n-3 PFAs (LCP), Dangour et al. (2012) found that only one identified any potential benefits on cognitive function. These authors conclude that “Whether this lack of evidence results from insufficient thought into designing studies of appr opriate size and duration, or

whether it relates to the selection of st udy populations who may benefit most from n-3 supplementation, such as those with low n-3 LCP status at study entry, or finally whether it suggests that despite the epidemiological a nd mechanistic evidence n-3 LCP supplementation does not affect cognitive function, remains open to question.”

f. Hearing loss

Gopinath et al. (2010) found an inverse association between hi gher intakes of long-chain n-3 PFAs and regular weekly consumption of fish a nd hearing loss. Higher di etary intake of longchain n-3 PFAs was associated with a 24 percent decreased risk of developing incident hearing loss. Regular consumption of fish in the diet wa s negatively associated wi th the 5-year incidence and progression of hearing loss in olde r adults. These data suggest that n

− 3 fatty acids and fish

have a role in maintainin g healthy auditory function.

g. Depression/mood

According to McManus et al. (2010), “intake of omega-3 PUFA rich seafood is linked to increased dispositional optimism in the elderly, a nd has, in some long term studies, been linkedPage 10 July 20, 2012 Technical Issue Paper to reduced depression, with a recent meta-analytic review of polyunsaturated fatty acid levels in patients with depression concl uding that ‘n-3 polyunsaturated fa tty acids play a role in the pathogenesis of depression’. Therefore, omega- 3 PUFA rich seafood could benefit individuals suffering from depression. Further research on the possible role of seafood consumption in moderating depression is required for th ese findings to be substantiated.”

Hegarty and Parker (2011) reviewed the eviden ce implicating marine n-3 PFAs in the etiology [causes or origin] of depressive and bipolar di sorders and the e ffect of n-3 PFA supplementation

in the treatment of those diso rders. The authors focused primarily on studies conducted within the previous 5 years, and found the followi ng: (1) the evidence s uggests a contributory etiological role of n-3 PFA deficiency to depres sive and bipolar disorders; (2) a growing body of evidence implicates inflammatory processes in th e etiology and/or progre ssion of depression; (3) n-3 PFAs play a role in modulating the n-6 PFA derived pro-inflammatory molecules and are able to suppress the expression of a wide vari ety of inflammatory genes; (4) a recent metaanalysis concluded that levels of EPA, DHA, and total n-3 PFAs are significantly lower in depressed patients compared to controls; (5) tria ls of EPA-rich n-3 PFA supplements were more effective in treating depressive symptoms than DHA-rich preparations ; and (6) an increasing number of trials do not support n-3 PFA supplem entation as an effective treatment for major depressive disorder or postna tal depression. Hagarty and Parker (2011) concluded that more research focusing on EPA-rich supplements is warranted and that, even with many questions remaining, two fish servings per week would be recommended with supplementation for those with depressive or bipolar diso rders. They believe it is possi ble that n-3 PFA supplementation may be of benefit for mood disorders but that research has not yet es tablished the right dose and/or the right constituent ratio. A review of the effects of n-3 PFA supplementation on behavior and neuropsychiatric diso rders by Ortega et al. (2012) found that most of the existing studies do not meet the requirements to elucidate the effect of n-3 PFAs, for example, by failing to control for dietary intake.

h. Osteoporosis

McManus et al. (2010) state that “seafood is a rich source of both calcium and Vitamin D, important bone-building micronutrients. Vitamin D ri ch seafood can play an important role in the maintenance of bone mineral density as people age. Potential reduced sun exposure and an increased requirement of Vitamin D in olde r people underpins the need for high quality,

bioavailable Vitamin D. Seniors also have a re duced capacity to ‘synthesize provitamin D3 in skin and to hydroxylate vitamin D3 in kidneys. It is widely recognized that a diet high in oily fish prevents vitamin D deficiency; and commo nly consumed, affordable sources of seafood such as Australian salmon and silver perch contain more than double the recommended daily intake of Vitamin D in a 150 g serve. A 150 g se rve of Australian Salmon will also deliver more than half the recommended daily intake of calci um. Calcium requirements increase with age and seafood presents rich serves of calcium combined with optimal amounts of Vitamin D to aid its absorption, protecting bone mineral density (BMD).

Loss of calcium through urinary ex cretion is of concern to bone health. Evidence is emerging showing lower fractures and higher bone mineral density with the consumption of adequate levels of calcium rich, high protein seafood. This may be due to increased intestinal absorption, which negates the impact of urinary excretion. Wh en calcium and vitamin D intake is adequate, dietary protein at moderate leve ls is beneficial to total body BMD particularly for seniors.Technical Issue Paper July 20, 2012 Page 11 Seafood is a good source of calcium, vitamin D, and protein [and] therefore can favorably

contribute to BMD.”

However, according to a review by Orchard et al. (2012), a small number of epidemiological studies investigating the relati onship of fish consumption or dietary n-3 PFA consumption to fracture risk have yielded mixe d results. For example, in a study of post-menopausal Chinese women, high intake of sea fish was associated with greater bone mass and lower osteoporosis risk, especially those consumi ng more than 250 grams of seafood per week (Chen et al. 2010). But in a study of elderly Japanese women, consum ing fish 3 to 4 times per week was associated with decreased risk of hip fract ure but eating more than 4 fish meals per week did not improve relative risk (summary in Orchar d et al. 2012). Orchard et al. (2012) conclude d that “there is a need for further large scale inve stigation of the differential e ffects of various n-3 PFAs in relation to skeletal outcomes, particularly fracture.”

i. Recent Research

The following summaries do not represent the results of an exhaustive liter ature search, which is outside the scope of this review, but are articles of interest th at were found when searching for recent reviews on the benefits of seafood consump tion. These articles are too new to have made it into the review papers th at were published recently.

Gopinath et al. (2011) inves tigated the associat ion between dietary intakes of PFA (n

- 3, n

- 6 and

α -linoleic acid), fish and the prevalence of chronic kidney disease (CKD). Due to the antiinflammatory properties of PFA, it has been s uggested that they may protect against kidney damage in adults. These researchers found that an increased dietary in take of long-chain n

- 3 PFA and fish reduced the prevalence of CKD. Therefore, a diet rich in n-3 PFA and fish could have a role in maintaining he althy kidney function.

In a case-control study of maternal dietary patterns and congenital heart defects, a dietary pattern characterized by the high intake of fish and seafood was associated w ith a reduced risk of congenital heart defects in offspring (Obermann- Borst et al. 2011). Based on these findings, the researchers suggested further i nvestigation in a randomized inte rvention trial was warranted.

Changing human dietary patterns in the last 100–150 years have given rise to an imbalance in the dietary ratio of n-6 and n-3 PFAs (review in Cand ela et al. 2011). This ratio used to be around 1– 2:1 but in Western diets is now as high as 20–30: 1. n-3 PFA intake is much lower today due to factors such as decreased fish consumption while n-6 PFA intake is higher due to factors such as increases in n-6 rich grains and vegetable oils. Although n-6 a nd n-3 PFAs exert opposing effects on inflammatory activity (n-3 PFAs reduce infl ammation), high n-6:n-3 ratios have not been correlated with high inflammatory marker levels. So me researchers point to the need to decrease n-3 PFA intakes while others call for increasing n-3 PFA intakes to mediate the imbalance in the

ratio. Beneficial effects on asthma (an inflammatory disease) have been seen at ratios of 5:1 with

adverse effects seen at ratios of 10:1 (review in Candela et al. 2011). With re gard to cancers, a high n-6:n-3 ratio was associated with increase d prostate cancer risk in a recent study (Williams et al. 2011).Page 12 July 20, 2012 Technical Issue Paper 

## II. Risks associated with eating fish and shellfish

Risks associated with eating fish and shellfish include the risk fr om chemical contaminants (fish and shellfish) and pathogens or biot oxins (generally in shellfish).

According to the U.S. Environmental Prot ection Agency (USEPA) 2010 listing of fish consumption advisories (USEPA 20 11), all 50 states have fish c onsumption advisories in place to protect their residents from the potential health risks of eati ng contaminated fish caught in local waters. As of 2010, 42 percent of the na tion’s total lake acreage and 36 percent of the

nation’s total river miles were under advisories . There were consump tion advisories for 33 different environmental pollutants in the United States in 2010—a total of 4,598 fish consumption advisories were in effect. Thr ee pollutants—methylmercur y, PCBs, and dioxins— were responsible for nearly 90 percent of the advi sories. These contaminants accumulate in fish tissue at concentrations many times higher than c oncentrations in the water and can persist for years in sediments. Fish consumption advisories are designed to “avoid” risks from consuming different contaminated fish. For example, the me trics of advice prescribes meal frequency and size to reduce exposures to mercury or other fish contaminants. All states, except Nebraska, offer meal frequency advice in terms of fish meal s to avoid per week, month, year or some combination thereof (Scherer et al. 2008).

Some shellfish species feed by taking in larg e volumes of water and filtering out the food particles (WDOH 2012). These filter-f eeding species, such as oyste rs, clams, and mussels, can accumulate natural biotoxins as well as pathogens (e.g., norovirus, fecal coliforms, and vibrio) in their edible tissues. The Washington Department of Health (WDOH) She llfish Program monitors for biotoxins such as paralytic shellfish poison an d domoic acid in shellf ish and closes harvest areas when levels pose a threat to public health. The Shellfish Pr ogram also classifies shellfish growing areas, monitors marine water for pollu tion, licenses and inspects commercial growers, and provides recreational harveste rs with information about wher e, when, and what type of shellfish are safe to harvest. Washington State shellfish consumers can minimize their risks of becoming ill from shellfish biotoxins and pat hogens by avoiding raw shellfish (proper cooking kills pathogens although it does no t neutralize biotoxins) and comply ing with shellfish harvesting

restrictions when the Shellfis h Program closes harvest areas. This issue paper focuses on chemical contaminants in seafood and so pathoge ns and biotoxins are no t discussed further.



### A. Brief summary of po tential health effects

Toxic contaminants enter Washington’s ecosyst ems via water (e.g., river or stream inputs, industrial discharges, stormwater runoff), the atmosphere, and in th e bodies of migrating organisms. Some chemicals in the environmen t pose an immediate health threat. Others gradually build up in the environment and, in humans, can cause disease long after exposure. Contaminants in sediment and water may accumu late in fish and shellfish through processes

called bioaccumulation and bioconcentration. Bio accumulation is the accumulation of chemicals in the tissue of fish or shellfish through re spiration, ingestion, or direct contact with contaminated water, sediment, and pore water in the sediment. Bioconcentrat ion is the process of accumulation of water-borne chemicals by fish or shellfish through non-dietary routes. Some contaminants are biomagnified up the food chain. This occurs when the tissue concentration increases at each trophic level in the food chain when there is effi cient uptake of the contaminantTechnical Issue Paper July 20, 2012 Page 13 but slow elimination. Hydrophobic chemicals—thos e that adhere to or ganic particles in sediments—tend to be bioaccumulative. Two type s of contaminants that may occur in seafood are metals and organics. These are described below.

a. Metals

Metals include essential trace elements required for human health, such as zinc and copper, and those without any known human dietary need, su ch as lead and mercury. Many metals, even those considered essential in the diet, can be toxic at high enough dos es. Some metals are widespread in the environment due to natural pr ocesses (e.g., arsenic) but have increased locally or globally due to human activities (Eisler 2000) . Metals contamination occurs throughout the state from a variety of sources su ch as industrial releases, deteri oration or wear of roofing and other materials, batteries, pain ts, and dyes. Methylmercury, an organic form of mercury, is

included in a class of contaminants termed Persistent Bioaccumulative Toxics (PBTs). 8 PBTs are of concern because they resist degradation, bi oconcentrate from the environment (e.g., water, sediments) into organisms, and may biomagnify up food chains (PSAT 2007).

b. Organics

Organic contaminants are natural or manmade ch emicals that include several PBTs: dioxin and dioxin-like compounds (polychlorin ated-dibenzo-p-dioxins [PCDDs], polychlorinated-dibenzofurans [PCDFs], and polychlorinated biphe nyls [PCBs]), polycyclic aromatic hydrocarbons (PAHs), and organochlorine pesticides (e.g., chlordane, DDT).

PAHs are a group of organic chemicals that have a fused ring structure of two or more benzene rings, and are formed during the incomplete combustion of organic materials. PAHs are ubiquitous in nature, largely as the result of natu ral processes such as forest fires and microbial synthesis. Anthropogenic sources of PAHs incl ude vehicle exhaust; manufacturing of coal tar pitch and asphalt; petroleum refining; and ope n burning (Eisler 2000 and others). The largest sources of PAHs in Washington are wood burni ng stoves and fireplaces. Other major sources include creosote-treated wood, ve hicles, leaks and improper dispos al of motor oil, and small engines (e.g., lawn mowers and garden equipment) . PAHs in fish and shellfish are a result of

contamination of water and sediment while PAHs in livestock (e.g., beef) are from consumption of contaminated pasture and ve getation. PAHs may accumulate in shellfish but generally do not biomagnify because most are readily metaboli zed by other species such as fish and humans (Eisler 2000).

Dioxin-like compounds include PCDDs, PCDFs, and certain P CBs. PCDDs and PCDFs have

natural sources but are also created and are c onsidered unwanted impurities in some industrial processes and products such as pesticides (Eisler 2000). Common sources of dioxins in Washington State include waste incinerators, pulp mills, industrial processes, and backyard burn barrels. PCBs are a group of 209 synthetic organi c chemicals that were used as insulating and cooling agents in the electric ity generating industry, and that had a number of other industrial applications (e.g., as additives to caulks and pa ints to improve durability). The production and

8 Two metals (cadmium and lead) are considered PBT metals of concern in Washington State (Washington Administrative Code 173-333) but these metals are not always analyzed in seafood ti ssue samples and do not often appear in articles and reports regarding PBTs in seafood in Washington.Page 14 July 20, 2012 Technical Issue Paper sale of PCBs was banned in the United States in the late 1970s, but these compounds have persisted in the environment in soils, sedi ments, and organisms. Dioxins and PCBs bioaccumulate and biomagnify in the food chain.

c. Primary chemicals of concern in Washington fish and shellfish

Fish and shellfish in Washington State have been exposed to pollutants discharged into waters including sewage, pulp and paper industry wa stes, petroleum products, heavy metals, and synthetic organic chemicals (e.g., pesticides, PCBs). Accidental spills of dangerous materials and past business practices have contaminated land and waters. In 2006, WDOH reviewed Puget Sound fish tissue data from the Washington Departme nt of Fish and Wildlife to determine which contaminants have the potential to cause public health concern (WDOH 2006). The following chemicals were detected in 10 perc ent or more of the samples: al pha chlordane, arsenic, benzyl alcohol, copper, DDT and degrad ation products, DEHP, mercury, a nd PCBs. Of these chemicals, only PCBs and mercury were detected with suffi cient frequency and at high enough levels that

WDOH believed an assessment of health risk was warranted at that time. WDOH did not include

shellfish in the risk assessment. Some shellf ish are known to accumulate PAHs due to their inability to metabolize these compounds. Theref ore, because shellfish may be a significant source of PAHs for shellfish consumers, PAHs were included in this Tec hnical Issue Paper. Note that the Puget Sound Assessment and Monitoring Program did not analyze tissues for PCDDs or PCDFs. However, data from the fish and sh ellfish studies in the Ecology Environmental Information Management Database indicate that these chemicals are found in Washington State fish and shellfish. This Technical Issue Paper focuses on the health risks associated with mercury, PAHs, dioxins/furans, and PCBs.



### B. Adverse health effects associated with primary contaminants of

concern

a. Mercury

Mercury and mercury compounds have no known biological function an d their presence in biological organisms is undesirable and potenti ally hazardous (review in Eisler 2000). Most atmospheric mercury is in elemen tal or inorganic forms while the mercury in water, soil, plants, and animals is generally in organic forms. Bacter ia in the environment c onvert inorganic mercury to organic forms such as methylmercury. Meth ylmercury is considered the most hazardous mercury compound due to its high stability, its li pid solubility, and its ability to penetrate membranes in living organisms. Methylmercury can bioconcentrate in organisms and biomagnify up food chains. Organic mercury can cross the blood-brain barrier 9 and the placenta. For all organisms tested, early developmental stages we re the most sensitive to mercury poisoning, and organic forms were more toxic th an inorganic forms. Mercury is not concentrated in fat but is associated with protein and therefore in anim al-based foods it is f ound in the meat/fillet.

9 The blood-brain barrier is a semi-permeabl e membrane that allows some materials to cross but prevents ot hers from crossing; it protects the brain from foreign subst ances, protects the brain from hormones and neurotransmitters from other parts of the body, and maintains a constant environment for the brain.Technical Issue Paper July 20, 2012 Page 15 Mercury is a known teratogen ( causing birth defects), mutage n (causing DNA mutations), and carcinogen (review in Eisler 2000 ). Mercury can adversely aff ect reproduction, growth and development, behavior, blood serum chemistry, motor coordination, visi on, hearing, histology,

and metabolism at low concentrations. In severa l studies, high maternal exposure to mercury during pregnancy have been associated with impaired child cognitive development and achievement of developmental milestones as measured by various te sts including language, motor skills, and intelligence (O ken et al. 2008; Cabelli et al. 2009; review in FAO/WHO 2010).

b. Arsenic

Arsenic is bioconcentrated but does not bioma gnify in food chains (Eisler 2000). Therefore,

arsenic concentrations are usua lly low in most organisms. Ex posure to inorganic arsenic is generally from contaminated drinking water (WDOH 2009). Arsenic in food sources including seafood is generally in organic forms, primarily arsenobetaine. Arsenobetaine is very stable; after ingestion, it is rapidly excr eted unchanged in the urine (summary in Vahter 1994).

Acute or subacute exposure to arsenic com pounds can cause appetite loss, reduced growth, hearing loss, dermatitis, blindness, degenerativ e changes in the kidney and liver, cancer, chromosomal damage, birth defects, and death (review in Eisler 2000). Chronic exposure to arsenic compounds is associated with liver, kidn ey, and heart damage, hearing loss, brain-wave abnormalities, and impaired resistance to viral infection. However, the probability of chronic poisoning from continuous ingestion of small doses is rare due to the body’s ability to detoxify and excrete arsenic rapidly.

In mammals, inorganic arsenic compounds are mo re toxic than organic arsenic compounds, and trivalent species (As +3 ) are more toxic than pentavalent (As +5 ) species (review in Eisler 2000). Ingestion of inorganic arsenic in creases the risk of cancer of the skin, lungs, bladder, and kidneys. Early developmental stages are the most sensitive to arse nic. Inorganic arsenic can cross the placenta and produce mutagenic, teratogenic, and carcinogenic effects in offspring. However, at environmentally relevant levels and routes of exposure, humans are not at risk of birth defects

from arsenic.

c. PAHs

Exposure to PAHs may occur thro ugh the lungs, stomach, or skin. Of these pathways, dietary intake is a major source of exposure fo r PAHs (Diggs et al. 2011). Chr onic exposure can cause dermatitis and hyperkeratosis. Benzo(a)pyrene is considered to be one of the most toxic PAH compounds and is

the PAH with the most available health effects data. The USEPA classifies benzo[a]pyrene as a probable human carcinogen based on multiple studies with rats and mi ce. According to a Joint Food and Agriculture Organization of the United Natio ns (FAO) / World Health Organization (WHO) Expert Committee report (WHO 2006), 13 PAHs are clearly carcinogenic and 15 PAHs are genotoxic in experimental animals. Cancer associ ated with exposures to PAH containing mixtures occurs mainly in the lung (inhalational exposure) and skin (dermal exposure). Ingestion of PAHs has been associated with esophag eal cancer (Diggs et al. 2011).

d. PCDD/Fs

Dioxin-like compounds (referred to hereafter as dioxins) include PCDDs, PCDFs, and PCBs. Dioxins and furans are discussed here, while P CBs are discussed below. Dioxins affect thePage 16 July 20, 2012 Technical Issue Paper immune system and cause dermal and hepatic (liv er) toxicity, a variety of endocrine (hormone) effects, and cancer (summary in Birnbaum and Fenton 2003; others). The embryo and fetal stage of development may be especia lly susceptible to dioxin eff ects (Birnbaum 2005). Dioxins are tumor promoters that cause tumors to grow and enhance the incidence and multiplicity of tumors at multiple sites in the body. Dioxins are pers istent, accumulating and lasting in the body for years. For maternal to offspring exposure to dioxins (e.g., through placenta and breast milk), the majority, if not all, of the effects are associated with in utero exposure (Birnbaum 2005). Nursing leads to greater infantile expos ure through the breast milk, but this does not have long-term effects on the adult body burden.

The mechanism of action for dioxin effects on verteb rate species is through activation of the aryl hydrocarbon receptor (Ah-receptor) (White and Birnbaum 2009). The Ah-receptor is believed to play key roles in development, aging, hypoxia, and circadian rhyt hms. Laboratory test animals that are missing the Ah-receptor 10 are not healthy, which highlights that the receptor and its controlled activation are necessary for well-bein g (summary in Tuomisto and Tuomisto 2012).

Experiments with animals have shown dioxin to be a multi-site carcinogen, but there is limited evidence for the carcinogenicity of dioxin in human s at environmentally re levant concentrations, and this issue is extremely cont roversial. Epidemiological studie s of dioxin exposures and effects are complicated by the fact that everyone has some exposure to dioxins and to other chemicals, and carry body burdens of a suite of chemical s. Recently, Boffetta et al. (2011) conducted a critical review of the epidemiol ogic studies on human exposures to 2,3,7,8-tetrachlorodiobenzo- p

dioxin (TCDD) and cancer and concl uded that “recent epidemiological evidence falls far short of conclusively demonstrating a causal link between TCDD exposure and cancer risk in humans.” This finding is mirrored in the review by Tuom isto and Tuomisto (2012) who concluded that “Occupational cohorts with the highe st exposures imply that there is a small risk of all cancers combined, but it is difficult to pinpoint the conf ounding effect of the main chemicals. Studies after major accidents do not unequivocally conf irm this risk. The risks to populations at the

current dioxin levels 11 seem trivial if present at all.”

e. PCBs

Similar to dioxins, PCBs are lipophilic and move through the placenta and into milk (review in Santerre 2008). The USEPA has classified PCBs as a probable human carcinogen (USEPA 2012). Only a few PCBs are structurally similar to dioxin and therefore are considered to be

dioxin-like in their toxic effect s (i.e., toxicity mediated by in duction of the Ah-receptor). The non-cancer effects of PCBs may include: immune system suppre ssion, reproductive effects such as reduced birth weight, neurolog ical effects such as learning de ficits and changes in activity, and endocrine effects such as changes in thyr oid hormone levels (USEPA 2012). The different health effects of PCBs may be interrelated, as alterations in one system may have significant implications for the other regulatory systems of the body. PCBs and dioxins are rarely found in environmental and biological samples in the abse nce of one another (White and Birnbaum 2009).

10 Animals that are bred specifically without the receptor to study drug toxicity and the biological function of the receptor.

11 Emphasis added.Technical Issue Paper July 20, 2012 Page 17 

## III. Comparison of health benefits and risks

This section describes the metrics used in evalua ting the risks associated with contaminants and presents comparisons of health benefits to ri sks of seafood consumption. The risk assessments are presented by date order, with the most recent described first.



### A. Metrics for evaluating risks

Contaminants can cause a variety of health e ffects including cancer and non-cancer health

effects. The metrics used to evaluate risks fr om contaminants differ depending on if the toxic endpoint is cancer or not cancer (e.g., neurotoxicity, immunotoxici ty). The following paragraphs, modified from USEPA and TERA (1999), describe the most commonly used metrics for these two types of endpoints.

Cancer slope factors are estimates of risk that are derived from dose-response data from laboratory animal or human epidemiology studie s. Traditionally, a linearized multi-stage model has been used to extrapolate from what is obser ved at high experimental concentrations to lower environmental exposure levels. This cancer potency is estimated as the 95 percent upper confidence limit of the slope of the dose-respons e curve in the low dose region. This is an upper estimate of risk and the actual risk may be mu ch lower or even approach zero. USEPA proposed revised cancer guidelines in 1996 and additiona l proposed guidance in 1998, which recommend that the mode of action be considered. The gui dance recommends that a linear extrapolation

should be used if the chemical is believed to ac t via a genotoxic mode of action, if the mode of action is expected to be linear at low doses, or (as a default) if no mode of action data are available. The guidance also recommends that a non-linear approach to extrapolation to low

doses should be used when sufficient in formation on mode of action warrants.

For non-cancer endpoints, a reference dose is iden tified at which one would not expect to see adverse effects in a population (i ncluding sensitive subgroups). A single estimate of a “safe” dose

is identified from animal or hum an data, using the No Observed Adverse Effect Level (NOAEL). This is divided by uncertainty factors to accoun t for extrapolation from animals to humans, variability in the human population, and deficiencies in the database of studies on the substance. The resulting reference dose (RfD) is defined as “an estimate (with uncertainty perhaps spanning an order of magnitude) of a daily exposure to the human populati on (including sensitive subgroups) that is likely to be wit hout an appreciable risk of dele terious effects during a lifetime.”



### B. Risk/Benefit Comparisons

a. FAO/WHO (2011)

In January 2010, the FAO and WHO convened a Jo int Expert Consultati on on the Risks and Benefits of Fish Consumption (FAO/WHO 2011). Th e tasks of the Expert Consultation were to

review data on levels of nutri ents (long-chain n-3 PFAs) and two chemical contaminants (methylmercury and dioxins) in a range of fish speci es and to compare the health benefits of fishPage 18 July 20, 2012 Technical Issue Paper consumption and nutrient intake with the health risks associated with co ntaminants present in

fish 12

.
After reviewing the literature, the Expert Consultation decided to compare the effects of (1) prenatal exposure to long-chain n-3 PFAs (E PA and DHA) and methylme rcury on child IQ and (2) exposure to long-chain n-3 PFAs and dioxins on mortality. The rationale for this choice was based on the common health end-points and rela tively robust evidence to establish dose– response relationships from multiple cohort studies.

Using data on over 75 species of fish and shellfish, the Expert Consultation classified the content of n-3 PFAs (as EPA + DHA) by total mercury c ontent and by dioxin content (as total TEQs) (Tables 2 and 3). The resulting matrices we re produced using t hose classifications:

Table 2. Classification of th e content of EPA plus DHA by total mercury content in 96 finfish and shellfish species

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/gMercury x ≤ 0.1 μ g/g Fish: butterfish; catfish; cod, Atlantic; cod, Pacific; croaker, Atlantic; haddock; pike; plaice, European; pollock; saithe; sole; tilapia Shellfish: clams; cockle; crawfish; cuttlefish; oysters; periwinkle; scallops; scampi; sea urchin; whelk Fish: flatfish; John Dory; perch, ocean and mullet; sweetfish; wolf fish Shellfish: mussels; squid Fish: redfish; salmon, Atlantic (wild); salmon, Pacific (wild); smelt Shellfish: crab, spider; swimcrab Fish: anchovy; herring; mackerel; rainbow trout; salmon, Atlantic (farmed); sardines; sprat Fish liver: cod, Atlantic (liver); saithe (liver) Shellfish: crab (brown meat)

0.1 < x ≤ 0.5

μ g/g Fish: anglerfish; catshark; dab; grenadier; grouper; gurnard; hake; ling; lingcod and scorpionfish; Nile perch; pout; skate/ray; snapper, porgy and sheepshead; tuna, yellowfin; tusk; whiting Shellfish: lobster; lobster, American Fish: bass, freshwater; carp; perch, freshwater; scorpion fish; tuna; tuna, albacore Shellfish: crab; lobster, Norway; lobsters, spiny Fish: bass, saltwater; bluefish; goatfish; halibut, Atlantic (farmed); halibut, Greenland; mackerel, horse; mackerel, Spanish; seabass; seabream; tilefish, Atlantic; tuna, skipjack Fish: eel; mackerel, Pacific; sablefish

0.5 < x ≤ 1 μ g/g Fish: marlin; orange roughy; tuna, bigeye Fish: mackerel, king;

shark Fish: alfonsino Fi sh: tuna, Pacific

bluefin

x > 1 μ g/g Fish: swordfish

12 The U.S. Food and Drug Administration published a draft repor t on the benefits and risks of food consumption in .January 2009. The FAO/WHO Expert Consultation reviewed that draft repo rt and incorporated some of the analyses in their assessment.Technical Issue Paper July 20, 2012 Page 19 Table 3. Classification of the content of EPA + DHA by dioxin content in 76 finfish and shellfish species

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/gDioxins x ≤ 0.5 pg TEQ/g Fish: anglerfish; catshark; cod, Atlantic; grenadier; haddock; hake; ling; marlin; orange roughy; pollock; pout; saithe; skate/ray; sole; tilapia; tuna, bigeye; tuna, yellowfin; tusk; whiting Shellfish: cockle; clams; crawfish; cuttlefish; periwinkle; scallops; scampi; sea urchin Fish: flatfish; John Dory; perch, ocean and mullet; shark; sweetfish; tuna,

albacore Fish: redfish; salmon, Pacific (wild); tuna, skipjack

0.5 < x ≤ 4 pg TEQ/g Fish: catfish; dab; gurnard; plaice, European Shellfish: lobster; oysters; scallops; whelk Fish: scorpion fish; swordfish; tuna Shellfish: mussels; squid Fish: alfonsino; goatfish; halibut, Atlantic (farmed); halibut, Greenland; mackerel, horse; salmon, Atlantic (wild); seabass;

seabream Fish: anchovy; herring; mackerel; mackerel, Pacific;

rainbow trout (farmed); salmon, Atlantic (farmed); tuna, Pacific bluefin Shellfish: crab (brown meat)

4 < x ≤ 8 pg TEQ/g Shellfish: crab, spider Fish: sardines; sprat

x > 8 pg TEQ/g Fish: bluefish Fi sh: eel Fish liver: cod, Atlantic (liver); saithe (liver)

For the risk-benefit comparisons, the Expert Consu ltation created matrices for the calculations of (1) the effects on child IQ as a result of the mo ther consuming one, two, four, or seven servings of fish per week with different n-3 PFA and met hylmercury concentrations (Table 4), and (2) the effects on mortality as a result of consuming one, two, four, or seven servings of fish per week

with different n-3 PFA and dioxin concentrations (Table 5). The matrices for the effects of methylmercury show estimates of changes in IQ. In the calculation, IQ point s are lost as a result of methylmercury exposure and gained as a resu lt of n-3 PFA. Positive numbers in green show where the net effect on IQ is positive—the gain in IQ points (using the upper bound estimate) is greater than the loss; negative numbers in red show where the net effect on IQ points is negative. Cells where the net effect is negative are shaded. The matrices for the effects of dioxins show the

net of estimates of lives lost as a result of dioxin exposure and liv es saved (due to reduction in coronary heart disease) as a re sult of n-3 PFA exposure. Where th e net effect is positive (lives gained is greater than lives lost) this is repres ented by positive, green numb ers. Shaded cells with negative numbers represent estimates of where the net effect is negative—lives lost are greater

than lives saved.Page 20 July 20, 2012 Technical Issue Paper Table 4. Estimated changes in child IQ resulting from maternal consumption of fish with different methylmerc ury and EPA plus DHA contents a

(a) One serving per week (3.5 ounces per week, or 14.3 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Methylmercury x ≤ 0.1 μg/g 0.05 +0.68 +2.0 +4.3 +5.7

0.1 < x ≤ 0.5 μg/g 0.3 +0.3 +1.6 +3.9 +5.3

0.5 < x ≤ 1 μg/g 0.75 –0.43 +0.9 +3.2 +4.6

x > 1 μg/g 1.5 –1.5 –0.2 +2.1 +3.5

(b) Two servings per week (7 ounces per week, or 28.6 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Methylmercury x ≤ 0.1 μg/g 0.05 +1.3 +4.0 +5.6 +5.6

0.1 < x ≤ 0.5 μg/g 0.3 +0.6 +3.3 +4.9 +4.9

0.5 < x ≤ 1 μg/g 0.75 –0.8 +1.9 +3.5 +3.5

x > 1 μg/g 1.5 –3.2 –0.5 +1.1 +1.1

(c) Four servings per week (14 ounces per week, or 57.1 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Methylmercury x ≤ 0.1 μg/g 0.05 +2.8 +4.0 +5.5 +5.5

0.1 < x ≤ 0.5 μg/g 0.3 +1.2 +3.9 +3.9 +3.9

0.5 < x ≤ 1 μg/g 0.75 –1.6 +1.1 +1.1 +1.1

x > 1 μg/g 1.5 –6.2 –3.5 –3.5 –3.5

(d) Seven servings per week (25 ounces per week, or 100 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Methylmercury x ≤ 0.1 μg/g 0.05 +4.9 +5.3 +5.3 +5.3

0.1 < x ≤ 0.5 μg/g 0.3 +2.1 +2.5 +2.5 +2.5

0.5 < x ≤ 1 μg/g 0.75 –2.8 –2.4 –2.4 –2.4

x > 1 μg/g 1.5 –10.9 –10.5 –10.5 –10.5

a Fish serving size was estimated to be 100 g. Ratio of DHA to EPA + DHA was assumed to be 0.67. Maternal body weight was assum ed to be 60 kg. IQ points gained from DHA exposure was estimated using the coefficient of 4 IQ points for 100 mg of DHA intake. Th e maximum positive effect from DHA was estimated at 5.8 points. Yellow shaded cells represent the estimates where the net effect on child IQ, using the upper-bound estimate for methylmercury, is negative.Technical Issue Paper July 20, 2012 Page 21 Table 5. Estimated changes in mortality per million people from consuming fish with different dioxin and EPA plus DHA contents a

(a) One serving per week (3.5 ounces per week, or 14.3 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Dioxins x ≤ 1.0 pg/g 0.2 +4,500 +12,450 +26,150 +39,750

1.0 < x ≤ 4.0 pg/g 2.5 +3,950 +11,900 +25,600 +39,200

4.0 < x ≤ 8.0 pg/g 6.0 +3,150 +12,100 +24,800 +38,400

x > 8.0 pg/g 20.0 –250 +7,700 +21,400 +35,000

(b) Two servings per week (7 ounces per week, or 28.6 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Dioxins x ≤ 1.0 pg/g 0.2 +9,000 +24,900 +39,700 +39,700

1.0 < x ≤ 4.0 pg/g 2.5 +7,900 +23,800 +38,600 +38,600

4.0 < x ≤ 8.0 pg/g 6.0 +6,200 +22,100 +36,900 +36,900

x > 8.0 pg/g 20.0 –400 +15,500 +30,300 +30,300

(c) Four servings per week (14 ounces per week, or 57.1 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Dioxins x ≤ 1.0 pg/g 0.2 +18,010 +39,610 +39,610 +39,610

1.0 < x ≤ 4.0 pg/g 2.5 +15,800 +37,400 +37,400 +37,400

4.0 < x ≤ 8.0 pg/g 6.0 +12,500 +34,100 +34,100 +34,100

x > 8.0 pg/g 20.0 –800 +20,800 +20,800 +20,800

(d) Seven servings per week (25 ounces per week, or 100 g/day)

EPA + DHA

x ≤ 3 mg/g 3 < x ≤ 8 mg/g 8 < x ≤ 15 mg/g x > 15 mg/g

Median 2 5.5 11.5 20Dioxins x ≤ 1.0 pg/g 0.2 +31,570 +39,470 +39,470 +39,470

1.0 < x ≤ 4.0 pg/g 2.5 +27,700 +35,600 +35,600 +35,600

4.0 < x ≤ 8.0 pg/g 6.0 +21,900 +29,800 +29,800 +29,800

x > 8.0 pg/g 20.0 –1,400 +6,500 +6,500 +6,500

a Fish serving size was estimated to be 100 g (3.5 ounces). Mean population body weight was assumed to be 60 kg. The numbers of lives lost from dioxin exposure was estimated using upper-bound estimates of risk. Estimates of the numbers of lives saved were due t o reduction in coronary heart disease risk from EPA + DHA intake. Th e maximum positive effect from EPA + DHA was estimated to occ ur at 250 mg/day. Positive green numbers occur wher e lives saved due to EPA + DHA is greater than lives lost to di oxin. Yellow shaded cells with a red number represent the estimates where the net effect is negative; lives lost are greater than lives saved.

Note that none of the fish species ev aluated by FAO/WHO fell into the maximum dioxin/minimum n-3 PFA category where risk was greater than benefit (see Table 3), andPage 22 July 20, 2012 Technical Issue Paper relatively few fish species fell into the mercury range where risk was greater than benefit (see Table 2).

It should be noted that Tables 4 and 5 assume a serving size of 100 grams (3.5 ounces). A study by Smiciklas-Wright et al. (2002) estimated mean and 90 th percentile fish meal size for general population adults using data gathered in the 1994–1996 USDA continuing survey of food intakes by individuals. The average amount of finfis h (other than tuna) per eating occasion was 114 grams; males, age 40 to 59, had the highe st meal size, with a mean of 130 grams (4.6 ounces) and a 90 th percentile value of 243 grams (8.6 oun ces). Studies of recreational fishers have reported average meal sizes up to 376 grams (13.3 ounces; Burger et al. 1999), while

studies of Native American tribal fish consumers also report meal sizes significantly larger than 100 grams.

Concentrations of mercury and di oxins in finfish and shellfish collected in Washington State during the last 10 years are summarized in another Technical Issue Paper ( Chemical Contaminants in Dietary Protein Sources ). Average mercury concentrations range from 0.011 to 0.24 μg/g (11 to 240 μg/kg) in Washington stat e finfish, and from 0.0074 to 0.067 μg/g (7.4 to 67 μg/kg) in Washington stat e shellfish. Mean dioxin TEQs 13 range from 0.054 to 1.7 pg/g in Washington State finfish; mean concentrations in shellfish ra nge from 0.080 to 6.1 pg/g. These concentrations indicate that consumption of seafood results in a ne t health benefit.

For example, maternal consumption of 25 ounces per week (or about three 8-ounce servings per week) of seafood contaminated with methylmerc ury at 0.24 μg/g (the high end of the average concentration in Washington state finfish) would be expected to result in a net increase in child IQ. An estimated 5.4 IQ points would be gained due to DHA exposure, compared to a loss of up to 3.3 IQ points due to methylmercury exposure (Table 4).

Similarly, consumption of 25 ounces per week (o r about three 8-ounce servings per week) of

seafood contaminated with dioxins /furans at a concentration of 1.7 pg/g TEQ (the high end of the average dioxin concentration in Washington state fi nfish) would be expected to result in a net increase in health benefits. An estimated 31,900 lives would be saved due to a reduction in coronary heart disease, compared to a loss of up to 4,200 lives due to dioxin toxicity, for each million people exposed (Table 5).

The Expert Consultation 14 summarized a large body of info rmation available on the health

benefits and risks associated w ith fish consumption including:

 Consumption of fish provides energy, protei n, and a range of othe r important nutrients, including the long-chain n-3 pol yunsaturated fatty acids (lon g-chain n-3 PFAs). Optimal health benefits can be maximized by consuming fish with higher long-chain n-3 PFA content and lower methylmercury content. The risk of coronary heart di sease mortality is significantly increased by not eating fish.

13 The TEQ calculation is for dioxin and furan compounds only and does not include dioxin-like PCB congener data, which were not available for marine fish in the Ecology EIM database.

14 Some of the statements taken from the Expert Cons ultation have been edited here for clarity or brevity.Technical Issue Paper July 20, 2012 Page 23  The benefits of fish consumption, demonstrated in numerous studies across a wide range of populations, reflect the su m of benefits and risks from all of the constituents in the fish.

 Based on observed dose-response relationships and other factors, it is ve ry unlikely that the benefits of fish consumption are explained to any large extent by the replacement of less “healthy” foods with fish. If this were the case, however, it would still represent a causal effect of fish consumption.

 Among the general adult population, consumption of fish, particularly fatty fish, lowers the risk of mortality from coronary heart disease. There is an absence of probable or convincing evidence of risk of coronary heart disease a ssociated with methylmercury. While convincing evidence that high dioxin exposur e increases the risk of cancer, there is cu rrently insufficient evidence that typical levels of dietary dioxins (such as seen in fish and other dietary sources)

increase the risk of cancer. Potential cancer risks associat ed with dioxins are well below established coronary heart disease benefits from fish consumption.

 When comparing the benefits of long-chain n-3 PFAs with the risks of methylmercury among women of childbearing age, maternal fish consumption lowers the risk of suboptimal neurodevelopment in their offspring compared w ith the offspring of women not eating fish in

most circumstances evaluated.

 At levels of maternal exposure to dioxins (fro m fish and other dietary sources) that do not exceed the provisional tolerable monthly intake (PTMI) of 70 pg/kg body weight 15
established by Joint Expert Council (for PCDDs, PCDFs, and coplanar PCBs), neurodevelopmental risk for the fe tus is negligible. At levels of maternal exposure to dioxins (from fish and other dietary sources) that ex ceed the PTMI, neurodevelopmental risk for the fetus may no longer be negligible.

 Among infants, young children, and adolescents, th e available data are currently insufficient to derive a quantitative framework of the hea lth risks and health be nefits of eating fish. However, healthy dietary patterns that include fish consumption and are established early in life influence dietary habits and health during adult life.

FAO/WHO note that other biologica l endpoints have been used to measure dioxin risks that are more conservative than the gross endpoint of mo rtality. For example, various studies in human populations have examined the asso ciation of gestational and/or lactational exposure to dioxins

and non-dioxin-like PCBs with neurobehavioral development. A problem inherent in these

studies is that dioxin s and PCBs (including dioxin-like and non-dioxin-like PCBs) coexist with each other (and with a host of other contaminants ) in biological systems. Therefore, the relative contribution of the various contaminant compon ents to developmental toxicity cannot be

delineated.

For methylmercury, other measures of developmen tal effects besides IQ have been used in various studies, but the Expe rt Consultation chose to use IQ based on the common health endpoint for methylmercury and DHA+EPA exposure and because the dose-response relationships from multiple cohort studies had been established by multiple meta-analyses.

15 By comparison, the USEPA RfD for 2,3,7,8-TCDD is 0.7 pg/kg/day, or roughly 210 pg/kg/month assuming a 30-day month.Page 24 July 20, 2012 Technical Issue Paper b. Tsuchiya et al. (2008–2009)

Japanese and Korean populations in Washington State consume fi sh at higher rates than the national average. The University of Washington’s Institute for Risk Analysis and Risk Communication and the Washingt on State Department of Hea lth conducted a longitudinal study 16 examining the mercury exposure in women of childbearing age in these populations (Tsuchiya et al. 2008a,b, 2009). The study populati ons included 106 Japanese and 108 Korean women of childbearing age (18 to 45) who resided in the Puget Sound area of Washington for at

least 6 months.

The women provided hair samples along with urin e, blood, and toenail samples, and completed a food-frequency questionnaire that was open en ded and spanned fish consumption over the previous year. The fish consumption survey was based on surveys previously conducted for

several other Pacific Northwest fish-consuming populations (triba l surveys and Sechena et al., 1999). The food frequency questionnaire was a valid ated dietary tool used and developed by the

Fred Hutchinson Cancer Research Center and was self administered by the participants of this study. As part of the fish dietar y survey, participants were prov ided a pictorial fish booklet containing pictures with names of various fish species comm only consumed by Japanese and Koreans and seafood commonly found in the Paci fic Northwest. Interview questions included frequency of consumption and servings sizes (based on fish models of fish steaks, fillets, sushi pieces, and shellfish samples). Also, participants we re asked if they consumed any other fish not

listed in the fish booklet.

The Japanese cohort was interviewed three times and the Korean cohort twice over a 14-month period. Participants that returned for second and third visits were admi nistered dietary recall surveys spanning the 2-week period prior to the date of the vis it. Data were obtained for 106, 90, and 85 Japanese individuals on the first, second, and third visits, respectively. The Korean group had 108 individuals participate on the first visit with 63 returning a second time. Mercury fish

tissue concentrations were determined from fi sh commonly consumed by Japanese and Korean communities in the Puget Sound area from local Asian grocery stores. Analysis was conducted on skinless edible portions consisting of steaks or fillets.

Both Japanese and Korean respondents from this survey consume almost the same amounts of finfish (mean fish consumption of 60 grams/da y for Japanese and 59 grams/day for Korean). Also, this similarity in fish consumption for Ja panese and Koreans is reflected in the finfish consumption distribution with 95 th percentiles being 159 grams/day for Japanese and 147 grams/day for Koreans. Differences in amounts of total fish consumption for these two fishconsuming populations are due to the Koreans consuming nearly 70 percent more shellfish on a daily basis (22.7 grams/day/pers on) compared to the Japanese (13.5 grams/day/person). The mean total fish consumption for Japanese (73 gr ams/day) and Koreans (82 grams/day) is almost

identical to the 95 th percentile estimates from CSFII a nd NHANES national fish dietary data.

Table 6 provides the fish species consumed (perce nt of total fish consumption) for the Japanese population. The list of fish species most consum ed by the Japanese group did not change much over the course of the study.

16 Longitudinal studies make repeated observations or take r epeated measurements of the same variable(s) over time.Technical Issue Paper July 20, 2012 Page 25 Table 6. Fish Species Most Consumed (>4 percent of total) for Japanese Population

Species Fish Tissue Mercury Concentrations (μg/kg) Percent of total consumption Visit 1 (n=106) Visit 2 (n=90) Visit 3 (n=85)

Salmon 72 29.0 28.0 36.3

Mackerel 40 9.1 18.1 10.6

Black Cod 97 6.5 4.5 2.6 Squid 39 5.6 5.5 3.1 Light Tuna (Canned) 127 5.0 4.8 8.3

Halibut 216 4.4 0.6 3.3

Ahi 185 4.2 4.3 6.7

Cod 115 1.2 8.7 5.5

Total 65 75 76 Mean individual fish intake (grams/day 59.5 33.7 31.3

Adapted from Tsuchiya et al. 2009, Table 1.

Table 7 provides the mercury inta kes (mercury fish tissue concen trations for species consumed) for the Japanese population.

Table 7. Fish Species with Greatest Merc ury Intake (>5 percent of total) for Japanese Population Species Fish Tissue Mercury Concentrations (μg/kg) Percent of total mercury for species consumed Visit 1 (n=106) Visit 2 (n=90) Visit 3 (n=85)

Salmon 72 17.0 25.0 32.0 White (Albacore) Tuna (Canned) 361 8.7 5.7 2.8

Halibut 216 7.9 1.6 8.7

Ahi 185 6.5 9.7 15.1 Light tuna 127 5.3 7.3 12.8

Black cod 97 5.3 5.3 3.2 Red snapper 221 3.8 5.3 3.4

Mackerel 40 3.0 8.8 5.1

Cod 115 1.1 12.2 7.8

Total 59 81 91 Mean individual estimate mercury intake (μg/day) 7.2 2.7 2.5

Adapted from Tsuchiya et al. 2009, Table 2.

Table 8 provides the fish species consumed (perce nt of total fish consumption) for the Korean population.Page 26 July 20, 2012 Technical Issue Paper Table 8. Fish Species Most Consumed (>4 percent of total) for Korean Population

Species Fish Tissue Mercury
Concentrations (μg/kg) Percent of total consumption Visit 1 (n=108) (all participants) Visit 1 (n=63) (subsample) Visit 2 (n=63) (subsample) Squid 39 23.0 21.2 10.2

Mackerel 40 12.0 13.1 16.4

Yellow croaker 53 11.0 13.1 15.4

Salmon 72 9.1 8.2 7.8

Flounder/sole 147 6.3 6.0 9.1 Light tuna (Canned) 127 5.6 4.7 12.2

Black cod 97 4.8 5.3 0.5

Pike mackerel 30 4.3 4.6 5.1

Pollack 22 3.5 4.1 4.4

Ahi 185 2.9 2.3 4.4

Total 83 83 86 Mean individual fish intake (grams/day 59.1 71.7 29.1

Adapted from Tsuchiya et al. 2009, Table 3. For the Koreans, the average estimated mercury e xposures for the first visit were 5.3 μg/day (for all 108 participants) and 5.1 μg/day (for the subsam ple of 63 participants) (Table 9). The average estimated mercury exposure for the second visit was 2.6 μg/day. There was a significant difference in total fish consumption estimates between those participan ts who returned for a second visit and those who did not. However, the pe rcentage that each speci es contributed to the total fish consumption estimates was similar between visits.

Table 9. Fish Species with Greatest Merc ury Intake (>5 percent of total) for Korean Population

Species Fish Tissue Mercury Concentrations (μg/kg) Percent of total mercury for species consumed Visit 1 (n=108) (all participants) Visit 1 (n=63) (subsample) Visit 2 (n=63) (subsample) White (Albacore) tuna (Canned) 361 14.0 12.7 15.2

Flounder/sole 147 10.0 12.6 14.5 Squid 39 10.0 11.8 4.2 Light tuna (Canned) 127 7.9 8.6 17.0

Salmon 72 7.4 8.5 6.1

Yellow croaker 53 6.4 9.9 9.1

Ahi 185 4.9 6.0 9.1

Mackerel 40 4.5 7.5 6.6

Total 65 78 82 Mean individual estimate mercury intake (μg/day) 5.3 5.1 2.6

Adapted from Tsuchiya et al. 2009, Table 4.Technical Issue Paper July 20, 2012 Page 27 At the time of the first visit, ov er half of the Japanese particip ants were overexposed to mercury, based on hair-mercury levels exceeding the es tablished RfD of 1.2 mg/kg. For the Koreans, approximately 13 percent of the participants were overexposed to mercury. This is because the average mercury content of the species consumed was lower in this group. Japanese participants who were overexposed had three times higher hair mercury levels and had fish consumption rates1.5 to 2 times higher than those not overexpos ed. Overexposed Korean participants had hair mercury levels 2.3 to 3 times higher than t hose not overexposed. For both cohorts, those not overexposed consumed fish at a rate of 40–60 grams/day. After the first-year inte rviews were completed, participants were given education mate rials and advised to switc h to alternative fish species with lower mercury concentrations. However, the fish species respons ible for most of the mercury body burden in both populations did not change over time.

The researchers also estimated n-3 PFA intake for the study participants. This was done using

DHA+EPA concentrations availabl e in the literature for each species consumed, and then deriving DHA+EPA intake values for each participan t using their species-sp ecific intake rates. Figure 1 shows n-3 PFA intake plotted ag ainst hair mercury concentrations.

Figure 1. n-3 PFA intake and mercury exposure (hair-mercury) compared to the mercury RfD and recommended daily allowance of DHA=EPA

Source: Modified from Faustman 2011, based on Tschuyia et al. 2008a.

Note that some participants exceeded the me rcury RfD and still did not meet the recommended

dose for n-3 PFAs. The authors conclude that bo th mercury and n-3 PFA content of fish are important in developing consumption guidan ce. In addition, the study found a 100 percent difference in the fish intake between the open- ended and 2-week recall surveys and that thePage 28 July 20, 2012 Technical Issue Paper open-ended survey data better represented mercur y intake as determined from hair mercury

concentrations.

c. Institutes of Medicine (2007)

The National Oceanic and Atmospheric Administra tion, which regulates U.S. marine fisheries, asked the Institutes of Medicine (IOM) of th e National Academies to convene a committee to

examine the scientific evidence on the nutritio nal benefits and risks from seafood. The IOM committee was charged to:

 identify and prioritize adverse health effect s from both naturally occurring and introduced toxicants in seafood;

 assess evidence on availability of specific nutrien ts in seafood compared to other food sources;

 determine the impact of modifying food choices to reduce intake of naturally occurring and

introduced toxicants on nutrient intake and nutritional status within the U.S. population;

 develop a decision path for U.S. consumers to balance their seafood choices to obtain nutritional benefits while minimizing exposure risks; and

 identify data gaps and recommend future research.

The IOM committee concentrated on issues affe cting marine species and published its final report in 2007 (Nesheim and Yaktine 2007).

For the benefit/risk analysis, the IOM committee evaluated changes in benefits and risks associated with changing consumption patterns th at may occur as a result of guidance providedto consumers regarding fish consumption. The IOM committee examined the impact of foodchoice trade-offs involving calorie s, saturated fat, EPA/DHA, se lenium, and iron. Contaminants evaluated, due to availability of data, were methylmercury, di oxins, and dioxin-like compounds. This information was used to develop guidance on seafood consumption tailored to four distinct population groups (Figure 2): ( 1) females who are or may become pregnant or who are breastfeeding; (2) children up to age 12; (3) adolescent males, adult males, and females who will not become pregnant; (4) adult males and female s who are at risk of cardiovascular disease.

Seafoodhealthfacts.org, a joint project of Oregon State Univ ersity, Seafood Consumer Center, Cornell University, and the Universities of Ca lifornia, Delaware, Florida, and Rhode Island, modified one of the sample public risk comm unication graphics from the IOM report when it created a seafood health reference guide fo r healthcare providers (Seafoodhealthfacts.org, undated). The Seafoodhealthfacts.org figure includ es the FDA action level for mercury, which puts the mercury content of the various seafood species into context (Figure 3). This figure shows estimated n-3 PFA intake (as EPA + DHA) in a 3-ounce serving of fish against the average mercury levels for each species. Those species considered to be low risk for mercury exposure are colored green. Yellow species have high average merc ury levels that exceed or approach the FDA action level of 1 part per m illion (ppm, or mg/kg) and should be avoided by sensitive groups (women who may become pre gnant, pregnant and breastfeeding women, and young children) according to recommendations by se veral groups (USFDA, USEPA, IOM, etc.). The blue colored species (canned albacore t una) is considered a good source of n-3 PFAs but consumption should be limited due to mercury levels in this species.Technical Issue Paper July 20, 2012 Page 29 Figure 2. Decision pathway representing th e balance between benefits and risks associated with seafood consumption

Source: Nesheim and Yaktine 2007Page 30 July 20, 2012 Technical Issue Paper Figure 3. EPA+DHA and mercury cont ent in representative seafood portions

Source: Seafoodhealthfacts.org.Technical Issue Paper July 20, 2012 Page 31 d. Mariën and Patrick (2001)

In 2001, the Washington State Department of Health conducted a methylmercury exposure analysis for five populations of fish consumers in Washington: freshwater recreational anglers, saltwater recreational anglers, and members of the Tulalip, Squaxin Island, and Suquamish Indian Tribes. Fish-consumption data for freshwat er recreational anglers we re taken from anglers fishing at Lake Roosevelt. This lake is borde red by two tribal reserv ations (Coleville and Spokane) and is visited by over 1 million people annually. Data for saltwater anglers were obtained from surveys of Puget Sound anglers, including both shores ide anglers and boating anglers. Fish consumption rates for the three tribes were obtaine d from surveys. Mercury data were obtained from existing datasets for the fi shery that each specific population was using.

The authors calculated a Tolerabl e Daily Limit (TDI) to compare to esti mated methylmercury intakes determine if any the five consumpti on groups were at risk for overexposure to methylmercury. The TDI represents the daily intake of methylmercury that is unlikely to cause any

adverse health effects. The WDOH TDI was based upon the results of three long-term cohort studies of the neurological effects in children whose mother s were exposed to methyl mercury in their diet – the Faroe Islands, New Zealand, and Seychelles Islands studies. The TDI developed by WDOH fell within the range of values from 0.035 to 0.08 microgram per kilogram of body weight per day (μg/kg/day). Note that the upper end of this range is close to the USEPA RfD of 0.1 μg/kg/day.

Freshwater Anglers

The daily intake of mercury for walleye, kokanee, rainbow trout, and smallmouth bass was calculated as the product of the number of meals per month when that species was consumed, the usual number of fillets consumed at a meal, the average weight of a fillet of that species, and the average fish tissue mercury concentration for th at species. The total daily intake was then estimated for each person by summing the estimated intakes due to each of the four species. This value was then converted to units of μg/kg/da y assuming an average a dult body weight of 70 kg. Of the 343 individual anglers surv eyed, most (298 individuals, or 87 percent) had estimated mercury intake levels below the upper bound of the TDI. Nearly all of the individuals exceeding

the TDI were adult males over th e age of 50, who are not considered a pop ulation of concern (women of childbearing age). Assuming the spou ses of these more highly exposed older males had similar intakes and were of similar age, they also would not re present a population of

concern.

Saltwater Anglers

For saltwater anglers, populations with the highest consumption ra tes for a particular fish were categorized and mercury intake levels for each population were calculated. Estimated daily mercury intake for Puget Sound shore anglers ranged from about 0.002 μg/kg/day (tomcod and Pacific Hake) to as high as 0.023 μg/kg/day (Pacif ic cod). Boat angler consumption data were calculated for individuals consuming fish fr om three locations in Puget Sound. Estimated mercury intake for the boat a nglers ranged from 0.003 μg/kg/day (rock sole) to 0.0095 μg/kg/day (Pacific cod). Total mercury intake levels for a ll fish species among both shore and boat anglers was less than the TDI even though the intake calculations assumed fish were consumed throughout the year. Species availability for most species is not year round due to fishing regulations that restrict when certain species can be caught. Th e authors separately evaluatedPage 32 July 20, 2012 Technical Issue Paper mercury exposure for anglers consuming salmon using tissue data that had been unavailable when the original surveys were conducted. Us ing median values for coho and Chinook salmon (0.04 and 0.1 mg/kg, respectively), intake valu es were calculated as 0.02 and 0.09 μg/kg/day, respectively. Anglers consuming Chinook at rates greater than 0.8 g/kg/day would have exposures slightly exceeding the TDI.

Tulalip, Squaxin, and Suquamish Tribes

For the tribal exposures, the 90 th percentile fish consumption ra te for each category (anadromous, pelagic, bottom) and species of fish were co mbined with Washington Department of Wildlife median mercury fish concentrations to de termine intake levels (Table 10). Salmonid consumption was the primary cause for intake va lues exceeding the TDI. The TDI was exceeded by 8 to 14 percent of the Tulalip Tribe populatio n and 10 to 25 percent of the Squaxin Island Tribe population when consuming salmon only. Th e percent of the Suquamish Tribe population exceeding the TDI could not be determined from the available data although 25 percent of the surveyed population was at or above the TDI.

Table 10. Estimated mercury intake from fish consumption for Tulalip Tribes, Squaxin Island Tribe, and Suquamish Tribes

a Intake values are based on the assumption that the fish type consumed from a particular group (anadromous, pelagic, bottom) is of one type only (provided in fourth column).

b Data with footnote ‘b’ not included in this revised version of the table.

c Consumption value based on 86 th percentile rate for anadromous fish category.Technical Issue Paper July 20, 2012 Page 33 The authors concluded that most of the individuals within the Tulalip Tribe could reduce their mercury intake below the TDI by consuming other anadromous fish as alternatives to Chinook (e.g., coho, chum, sockeye, steelhead, or pink salmon). Squaxin Island and Suquamish tribe members could also reduce their mercury inta ke by consuming salmonids other than Chinook.

Another recommendation was that the Suquamish Tribe indivi duals that were consuming elevated quantities should reduce their intake of these species. The authors also noted that background mercury levels present in salmon were resulting in populations being exposed to mercury above the TDI.

e. USEPA/TERA (1999)

The USEPA and Toxicology Excellence for Risk Assessment (TERA) summarized what was

known about health benefits and risks from fish consumption in a report published in 1999. The report compared the possible health risks of consuming contaminat ed fish while considering the potential health benefits lost by not eating fish, and proposed a framework for comparing the benefits and risks quantitatively.

Benefits described by the USEPA/TERA report in cluded discussions of th e beneficial protein, fatty acid profiles, and nutrients provided by fi sh and the various studies to date on CHD and heart attack, and other health e ndpoints which have been described in detail in Section II. At the time, however, the authors believed further study was needed to resolve whether fish consumption provided significant protection ag ainst CHD or heart attack. Contaminants considered included DDT (an organochlorine pes ticide now banned in the United States) and its metabolites, methylmercury, dioxin, PCBs, chlord ane (an organochlorine pesticide now banned in the United States), and chlorpyr ifos (an organophosphate pesticide).

The USEPA/TERA report concluded that consuming uncontaminated fish (or at least fish that are smaller, younger, or in general less contamin ated) may provide health benefits, but without the potential health risk s associated with contamination. Be fore eating any contaminated fish, consumers should consider fish supplies from cleaner water bodies, eating smaller, less contaminated fish, and cooking and cleaning met hods that reduce contaminants. The eating of

such “cleaner” fish rather than more contaminat ed fish would maximize the net benefit of fish consumption. However, better estimations of benef its were needed for th e general population and its sensitive subgroups and that be tter risk information is needed on the chemicals that commonly contaminate fish. The data gaps identified were sufficiently large so as to prevent any definitive conclusions from the study or any overall recommendations rega rding existing fish consumption advisory programs of the United States or ot her countries. The author s believed further study was needed to confirm and extend these preliminary findings.Page 34 July 20, 2012 Technical Issue Paper 

# Conclusions

For those who consume meats, replacing meats with vegetable alternatives (e .g., beans) or fish is one strategy to replace saturate d fats with monounsaturated fats and reduce cholesterol (Lichtenstein et al. 2006; USDA and USDHHS 2 010). Increasing seafood consumption of most species will lead to increased n-3 PFA intake an d reduced risk for major health conditions such cardiovascular and coronary heart disease. Health benefits associated with consumption of fish, particularly fatty fish such as salmon, are well documented.

While exposures to methylmercury and persistent organic pollutants may have negative human health impacts, there are consider able uncertainties about estimate s of these health risks to the general population at levels pr esent in commercially obtained seafood (Nesheim and Yaktine 2007).

High rate fish consumers such as certain et hnic groups (Japanese, American Indian) can accumulate mercury levels that approach or ex ceed reference doses (Tsuchiya et al. 2008a,b).

However, Mahaffey et al. (2008) suggest that data on methylmercury and n-3 PFA concentrations seafood can be used to guide the se lection of individual fish and shellfish species that are higher in n-3 PFA and low in methyl mercury content (see Figure 2), thereby reducing mercury exposure. Further, the risks from li pophilic compounds can be reduced by trimming fat, using cooking methods that reduce fat such as broiling, and by eating a variety of species.

A recurrent theme in recent reviews and analyses is that reducing fish consumption can negatively impact the health status of vulne rable populations (Dórea 2008). The evidence suggests that the fetus and infants may be am ong the principal beneficiaries from certain

nutrients in seafood. Few data are available about the extent to which beneficial components of seafood, such as selenium and omega-3 fatty ac ids, might mitigate risks associated with contaminants in seafood (Nesheim and Yaktine 2007).

Where there are local instances of excessively hi gh levels of contaminants such as PCBs in recreationally caught fish, it is important that consumers, especially those in sensitive populations, consult with their local health depa rtment before consuming locally caught fish.Technical Issue Paper July 20, 2012 Page 35 

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# Technical Issue Paper



# Chemical Contaminants in Dietary Protein Sources

# Technical Issue Paper



# Chemical Contaminants in Dietary Protein Sources

July 20, 2012

Toxics Cleanup Program

Washington State Department of Ecology

Olympia, WashingtonTechnical Issue Paper July 20, 2012 Page i 

# Table of Contents

Page

List of Figures and Tables..................................................................................................... .......... ii Figures........................................................................................................................ ............... ii

Tables ........................................................................................................................ ................ ii

Acronyms & Abbreviations ...................................................................................................... ..... iv

Introduction .................................................................................................................. ....................1

Analysis....................................................................................................................... .....................2

I. Sources of dietary protein .................................................................................................... 2

II. Contaminants of interest ...................................................................................................... 6

A. Metals ........................................................................................................................ .....6

B. Organics ...................................................................................................................... ...6

C. Relative contribution of di et to overall exposure ...........................................................7

D. Relative contribution of each type of protein source .....................................................9

E. Sensitive subpopulations ..............................................................................................17

III. Contaminant concentrations in dietary protein sources .....................................................17

A. Fish and shellfish — Washington St ate contaminant concentrations ..........................17

B. Other protein sources (meat, eggs, dairy) ....................................................................25

Summary ....................................................................................................................... .................29

References .................................................................................................................... ..................30



## Appendices

Appendix A. Contaminant Data Tabl es Supporting Figures 6, 7, and 9

Appendix B. Washington State Contaminant Da ta Summarized from the EIM DatabasePage ii July 20, 2012 Technical Issue Paper 

# List of Figures and Tables

Figures

Page

Figure 1. U.S. per capita meat consumption (h istorical and forecast to 2021) ..........................2

Figure 2. Annual per capita fish and shellfish consumption in the United States (pounds) ......3

Figure 3. Relative contribution of inorgani c arsenic exposure by source ..................................8

Figure 4. Sources of U.S. average daily intake of PCDD/PCDF/PCB TEQs ............................9

Figure 5. Total and inorganic arsenic concentrations of select ed protein sources (from data in Yost et al. 2004) ............................................................................................10

Figure 6. Sources of dietary inorganic arsenic for ch ildren 1 to 6 years (% contribution) ......11

Figure 7. Upper bound PAH15 concentrations (μg/kg) by food group ...................................13

Figure 8. Percent of total daily benz o(a)pyrene intake in a c ontrol group of 228 subjects ......14

Figure 9. Exposure pathway for PCDD/PCDF/PCB TEQ intakes from protein sources (percent contribution by source) ...............................................................................15

Figure 10. Mean PCB concentration in Chinook salmon fillets .................................................18

Figure 11. Mean PCB concentration in adult Ch inook salmon returning to Puget Sound (in-rivers versus marine waters*)..............................................................................18

Figure 12. Total PAHs in Washington Stat e mussels (μg/kg dry weight) .................................21

Figure 13. Total mercury concentrations in Washi ngton State mussels (μg/kg dry weight) .....22

Figure 14. PCBs in large fish from Wash ington State lakes and rivers .....................................23

Figure 15. PCBs (μg/kg) in fish from Puget Sound compared to other common food

sources.......................................................................................................................2 4



## Tables

Page

Table 1. Protein and fat content of se lected protein food sources ............................................4

Table 2. Benzo(a)pyrene in animal-based protein sources .....................................................12

Table 3. Levels of marker PCBs in composite meat samples (ng/g ww or LOD) ..................16

Table 4. Levels of marker PCBs in composite fish samples (ng/g ww or LOD) ....................16

Table 5. Levels of marker PCBs in composite da iry and egg samples (ng/g ww or LOD) ....16Technical Issue Paper Ju ly 20, 2012 Page iii Table 6. Average PCBs in Chinook salmon from in -river versus marine areas of the Puget Sound basin .....................................................................................................19

Table 7. Maximum concentration of contaminants de tected in fish and shellfish sampled at Fidalgo Bay in Anacortes, Washington ................................................................20

Table 8. Mean total PCB concentrations for fish from the Spokane River, Spokane, WA ....20

Table 9. Summary of PCB data (μg/kg wet weight ) in hake and pollock from seven Puget Sound Basins...................................................................................................25

Table 10. Concentration of total mercury in chic ken feed and the di fferent tissues of boiler chickens (μg/kg) .............................................................................................25

Table 11. Mean total and total inorganic arseni c concentrations in foods (μg/kg wet weight) ......................................................................................................................2 6

Table 12. Concentrations of PAHs in milk fr om western U.S. locations (ng/kg)* ..................27

Table 13. TEQ concentrations of CDD/CDFs and PCBs in milk (pg/kg) ................................27

Table 14. Mean TEQs of 17 PCDD/Fs and 4 dioxin-like PCBs in U.S. meats (ng/kg lipid) ...28

Table A-1. Sources of dietary inorganic arsenic for ch ildren 1 to 6 years (% contribution) ........2

Table A-2. Lower bound and upper bound PAH15 concen trations (μg/kg) by food group .........2

Table A-3. Estimated TEQ intake from dietary protein sources ...................................................3

Table B-1. Contaminant concentrations in selected Washington State freshwater fish ...............3

Table B-2. Contaminant concentrations in select ed Washington State invertebrates ...................4

Table B-3. Contaminant concentrations in select ed Washington State marine/anadromous

fish........................................................................................................................... ....6

Table B-4. Mercury concentrations (μg/kg) in selected Washington State fish ...........................8

Table B-5. Mercury concentrations (μg/kg) in selected edible Washington State

invertebrates ................................................................................................................9

Table B-6. Dioxin TEQ concentrations (ng/kg) in selected Wa shington State fish and

invertebrates ..............................................................................................................10

Table B-7. PCB concentrations (total congeners, μg/kg) in selected Washington State

freshwater fish and shellfish .....................................................................................12Page iv July 20, 2012 Technical Issue Paper 

# Acronyms & Abbreviations

ATSDR Agency for Toxic Substances and Disease Registry

CDD chlorinated dibenzo- p -dioxin

CDF chlorinated dibenzofuran DHHS U.S. Department of Health and Human Services EIM Ecology Environmental Information Management (database) Ecology Washington State Department of Ecology FAO Food and Agriculture Organization

MTCA Model Toxics Control Act n-3 PFA Omega-3 polyunsaturated fatty acid

NMFS National Marine Fisheries Service PAH polycyclic aromatic hydrocarbon PCB polychlorinated biphenyl PCDD polychlorinated dibenzo- p -dioxin PCDF polychlorinat ed dibenzofuran pg/g picogram per gram TEQ toxic equivalent TSD Fish Consumption Rates Technical Support Document USDA U.S. Department of Agriculture USEPA U.S. Environmental Protection Agency USFDA U.S. Food and Drug Administration WDOH Washington Department of Health WHO World Health OrganizationTechnical Issue Paper July 20, 2012 Page 1 

# Introduction

Ecology received comments on the draft Fish Consumption Rates Technical Support Document (TSD) (Ecology 2011), which noted that other protei n sources, such as beef, chicken, pork, and dairy products, may contain contaminants that w ould be considered to po se unacceptable health risks under the Model Toxics Control Act (MTC A). Some reviewers re quested that the TSD address the potential health risk if people eat less fish. Others suggested that the TSD should include some information regarding the contaminan t concentrations in Washington State fish and

shellfish.

This Technical Issue Paper summarizes contamin ant concentrations in animal protein sources (meat, eggs, dairy products, seafood), including co ntaminant data for Washington State fish and shellfish collected within the past 10 years, and discusses the relative contribution of dietary protein sources to human exposures associated with these contaminants. It is a targeted examination of the issues raised by review comments received on the draft TSD, and was prepared within a limited time frame. Therefore, it may not include all available information on this subject.

The health benefits and risks associated with consuming seafood are reviewed in Technical Issue Paper: Health Benefits and Risks of Consuming Fish and Shellfish . That Technical Issue Paper also describes the toxicity of the major contam inants commonly found in fish and shellfish.Page 2 July 20, 2012 Technical Issue Paper 

# Analysis

I. Sources of dietary protein

Protein in the diet provides a s ource of calories and amino acids that assist in building and preserving body muscle and ti ssues (USDA and DHHS 2010). Prot ein is found in both animal and plant foods. Animal sources include seafood, meat, poultry, eggs, and milk and other dairy products. Plant sources of protei n include beans, peas, nuts, s eeds, and soy products. Table 1 summarizes protein and fat content for common anim al food sources, which are the focus of this Technical Issue Paper.

Over the past three decades in the United States, per capita consumption of chicken has increased, beef consumption has decreased, and po rk consumption has remained fairly stable (Figure 1). Consumption of all three meat cat egories decreased somewhat over the period 2005 to 2011. Per capita fish consumption in the United States has increased slightly in the last decade, but as of 2010, fish and shellfish consum ption is at about the level of the late 1980s (Figure 2). Per capita consumption of fish and sh ellfish is much lower than the consumption of chicken, beef, or pork.

Figure 1. U.S. per capita meat consumption (historical and forecast to 2021)

Source: USDA 2012Technical Issue Paper July 20, 2012 Page 3 Figure 2. Annual per capita fish and she llfish consumption in the United States (pounds)

Source: NMFS 2011Page 4 July 20, 2012 Technical Issue PaperTable 1. Protein and fat contentof selected protein food sourcesFoodServingMeasureWeight(g)Protein(g)Total FatFatty AcidsCholesterol(mg)Saturated(g)Monounsaturated (g)Poly-unsaturated (g)MeatsBeef, ground 83% lean (broiled)3 oz8522145.56.10.571Beef, roast lean only (oven cooked)3 oz8523114.24.50.368Lamb, leg, lean only (roasted)3 oz852472.32.90.476Pork, loin chops, lean only (broiled)3 oz852672.53.10.570Pork, cured bacon, cooked3 slices19693.34.51.116Pork, cured ham, lean (roasted)3 oz852151.62.20.547PoultryChicken, breast meat, skinless (roasted)half-breast862730.91.10.773Chicken, drumstick, skinless (roasted)1 drumstick441220.70.80.641Chicken, liver (simmered)1 liver20510.40.30.2126Turkey, dark meat (roasted)3 oz852462.11.41.872Turkey, ground (cooked)1 patty8222112.842.684Turkey, light meat (roasted)3 oz852530.90.50.759SeafoodsCrab, king (moist heat cooked)3 oz851610.10.20.545Fish, cod (cooked dry heat)3 oz852010.10.10.340Fish, flatfish, flounder/sole (cooked dryheat)3 oz852110.30.20.558Fish, rockfish (cooked dry heat)3 oz852020.40.40.537Fish, salmon, sockeye (cooked dry heat)3 oz852391.64.5274Fish, salmon, Chinook (smoked)3 oz851640.81.70.820Fish, tuna, light, canned in water, drained3 oz852210.20.10.326Mollusks, clams (raw)3 oz851110.10.10.229Technical Issue Paper July 20, 2012 Page 5FoodServingMeasureWeight(g)Protein(g)Total FatFatty AcidsCholesterol(mg)Saturated(g)Monounsaturated (g)Poly-unsaturated (g)Mollusks, oyster (raw)6 medium84620.60.30.845Shrimp, canned, drained solids3 oz852020.30.20.6147Dairy Products and EggsButter, salted1 tbsp14.2trace127.23.30.431Cheese, cheddar1 oz287962.70.330Cheese, cottage (2% low fat)1 cup2263142.81.20.119Cheese, mozzarella part-skim, lowmoisture1 oz28853.11.40.115Cheese, ricotta, part skim milk1 cup246281912.15.70.676Milk, 2% reduced fat1 cup244852.91.40.218Yogurt, plain low fat8 oz2271242.310.114Egg, whole1 large50651.61.90.7213Modified from Gebhardt and Thomas 2002http://www.ars.usda.gov/SP2UserFiles/Place/12354500/Data/hg72/hg72_2002.pdfThe serving sizes used in this table are generally standardized units of measure and may not represent the portion of food a person actually eats on one occasion.tbsp = tablespoon; oz = ounce;Page 6 July 20, 2012 Technical Issue Paper 

## II. Contaminants of interest

A. Metals

For the purposes of this Technical Issue Paper, the two metals of interest include mercury and

arsenic.

a. Mercury

The presence of mercury and mercury compounds in biological organisms is undesirable and potentially hazardous (Eisler 2000). Mercury is wide spread in the environment due to natural and anthropogenic releases. Inorganic mercury is co nverted to the organic form methylmercury by bacteria. Methylmercury is the primary form of mercury in fish and shellfish tissues. Methylmercury is of concern due to its negative health effects (described in Technical Issue Paper: Health Benefits and Risk s of Consuming Fish and Shellfish ), and its ability to biomagnify in food chains in aquatic environm ents. It is most concentrated in larger and long-lived predatory species such as sharks and tuna.

b. Arsenic

Arsenic is a relatively common elem ent present in air, water, soil, plants, and all living tissues (Eisler et al. 2000). Natural sources of arsenic are geologic, and some rocks and soils have naturally high arsenic content. Large quantities of arsenic-cont aining compounds (arsenicals) are

released into the environment as a result of industrial and agricu ltural activities. Low levels of arsenic are commonly found in foods. Organic forms of arsenic may be transformed into organic forms by bacteria, fungi, algae, and plants. The pr imary organic form is arsenobetaine, which is rapidly excreted in the urine and generall y considered non-toxic (ATSDR 2007). Arsenic (primarily the inorganic forms of arsenic) is of concern due to its negative health effects (described in Technical Issue Paper: Health Bene fits and Risks of Consuming Fish and Shellfish ).



### B. Organics

Organic contaminants of interest that occur in foods include polycyclic aromatic hydrocarbons (PAHs) and dioxin-like compounds —polychlorinated dibenzo- p -dioxins (PCDDs), dibenzofurans (PCDFs), and biphenyls (PCBs).

a. PAHs

There are thousands of PAH compounds, and thes e compounds are ubiquitous in nature, largely as a result of natural processes such as fore st fires and microbial synthesis. Anthropogenic sources include vehicle exhaust, manufacturing of coal tar pitch and asphalt, petroleum refining, and open burning. The largest sources of PAHs in Washington are wood burning stoves and fireplaces. Other major sources include creoso te-treated wood, vehicles, leaks and improper disposal of motor oil, and small engines (e.g., la wn mowers and garden equipment). PAHs have been detected in animal and plant tissues, sedime nts, soils, air, surface water, drinking water, industrial effluents, river wate r, well water, and groundwater. PAH concentrations in marine

clams and mussels tend to be hi ghest in industrialized areas. PAH levels in fish and most crustaceans, however, are usually low because these organisms can rapidly metabolize PAHs.Technical Issue Paper July 20, 2012 Page 7 Therefore, while most aquatic organisms rapidly accumulate PAHs from the ambient medium (water, sediments), PAHs show little tendenc y to biomagnify because most are rapidly metabolized (Eisler 2000). PAHs are of concern because several PAHs are carcinogenic, mutagenic, or teratogenic to fish and other aquatic life, amphibians, birds, and mammals, including humans.

b. Dioxins

Dioxin-like compounds include PC DDs, PCDFs, and certain PCBs (discussed below). The term

dioxins refers to 75 congeners of PCDD and 135 congeners of PCDF (F iedler 1998). PCDD/Fs enter the environment naturally through forest fires or volcan ic activity (Eisler 2000). Human sources include municipal incinerators, pulp and pa per mills that use chlorine for bleaching, and aerial application of some types of pesticides. (PCDDs are trace impurities and their presence in

manufactured chemicals is not intentional or desired.) PCDD/Fs are found as mixtures of individual congeners in environmen tal matrices such as soil, sediment, air, and plants and lower animals (Fiedler 1998). Dioxins are of concer n due to their toxici ty (described in Technical Issue Paper: Health Benefits and Risk s of Consuming Fish and Shellfish ) and ability to bioaccumulate and biomagnify in food chains.

c. PCBs

PCBs are a group of 209 synthetic organic chemical s that were used as insulating and cooling agents in the electricity generating industry, and that had a number of other industrial applications (e.g., as additives to caulks and pa ints to improve durability). The production and

sale of PCBs was banned in the United States in the late 1970s, but these compounds have persisted in the environment in so ils, sediments, and organisms. PCBs are of concern due to their toxicity (described in Technical Issue Paper: Health Bene fits and Risks of Consuming Fish and Shellfish ) and ability to bioaccumulate and biomagnify in food chains.



### C. Relative contribution of diet to overall exposure

a. Mercury

Dietary intake is the most important source of non-occupational exposure to mercury (ATSDR 1999). The other major source of mercury body bur den is inhalation of elemental mercury volatilized from dental amalgams. Other sources ar e ingestion of drinking water, inhalation of vapors, medical treatments (e.g., mercury compounds used as preservatives in vaccines), and

even some cosmetics and tattoo inks. Individual s living in the vicinity of former primary production or mining sites or current secondary production sites, chloralkali plants, pulp and paper mills, coal-fired power plants, or other fac ilities where mercury is released (e.g., municipal waste incinerators), or hazardous waste site s may be exposed to mercury through several exposure pathways, including inhalation, dermal, and oral exposures. Individuals living near municipal and medical waste inci nerators, power plants fired by fossil fuels (particularly coal fired plants), or hazardous wast e sites may inhale vapors or pa rticulates contaminated with mercury from ambient outdoor air.Page 8 July 20, 2012 Technical Issue Paper b. Arsenic

Estimates of inorganic arsenic intake in the U. S. adult population identified drinking water and food as the two largest sources (Figure 3) (Meac her et al. 2002; CDC 20 09). Dietary exposure to inorganic arsenic occurs naturally and is unavoidable. Due to the relatively high use of water in the preparation of food, individuals in regions wi th higher arsenic concentrations in water likely also have higher dietary intake of inorganic arsenic (Yost et al. 2004) . Background arsenic in drinking water in the United States vari es by region, depending on local geology.

Figure 3. Relative contribution of i norganic arsenic exposure by source

c. PAHs

Food is the major contributor to total intake of PAHs in the general population, with smaller contributions from water and air (FAO/ WHO 2006). Smokers and people exposed occupationally will have additional exposures to PAHs. For smokers, the PAH intake from smoking may be of similar magnitude to intake from the diet (European Food Safety Authority 2008). Most foods contain 1 to 10 μg total PAHs /kg fresh weight. Cer eals and cereal products are major contributors of PAHs to the diet in many countries due to the high consumption rates of these foods. Vegetable fats and oils are also major contributors due to the high PAH concentrations in this food group. PAHs form directly during food processing (drying and smoking) and cooking (grilling, ro asting, frying). Grilled and ba rbequed foods can have high PAH levels; smoking and barbequing fish and m eats increases total PAH content by up to 100-

fold. PAHs form on or near meat surfaces rath er than the interior; therefore, foods cooked without being exposed to smoke do not show sign ificant levels of PAHs (Kazerouni et al. 2001). Some population groups may have higher intakes of PAHs, for example, people who regularly cook food over open fires or barbeques (ATSDR 1995).Technical Issue Paper July 20, 2012 Page 9 d. Dioxins

Inhalation, water consumption, soil ingestion, de rmal contact, and vegetable fat ingestion contribute only a small percentage of overall exposure to dioxins (Birnbaum 2005). Figure 4

shows the relative contributions of dietary and other sources to dioxin toxic equivalents (TEQs). In the U.S. Environmental Protection Agency (USEPA) Dioxin Reassessment, dose estimates (that included the dioxin-like compounds PCBs as well as PCDD/Fs) were provided for inhalation, soil ingestion, soil dermal contact, water ingestion, and for 10 food ingestion categories including beef, pork, poultry, other meats (game, lamb, unidentified meat in casseroles, etc.), eggs, milk, dairy, marine fish, freshwater fish, and vegetable oils (Lorber et al. 2009). The dose estimates were dominated by inge stion of animal food products (beef, pork, poultry, other meats, dairy, eggs, milk, and fish), which comprised 93 percen t of total exposures.

Figure 4. Sources of U.S. average daily intake of
PCDD/PCDF/PCB TEQs

Source: Birnbaum 2005



### D. Relative contribution of each type of protein source

a. Mercury

The U.S. Food and Drug Administ ration (USFDA) Total Diet Study found that nearly all of the mercury in the U.S. diet comes from meat, fis h, and poultry, with fish and shellfish being the principal source (Mahaffey 2009). Methylmercury in fish is the primary route of organic mercury acquisition in humans (Dórea 2008). A United Ki ngdom dietary study found that fish supplied most of the mercury in the average diet (25 percent); in that study, mercury concentrationsPage 10 July 20, 2012 Technical Issue Paper ranged from less than 5 μg/kg in meat, eggs, and m ilk, up to 54 μg/kg in fish (Ysart et al. 1999). However, the use of fishmeal in farm animal f eeds is likely to impact human foods by increasing exposure to methylmercury (Dórea 2008). Research ers in Sweden found that mercury in animal products raised on fish meal can correlate with ha ir mercury levels (a wi dely used biomarker of fish consumption) in non-fish eaters (review in Dórea 2008). [N ote that SAIC attempted to acquire published paper(s) with th e metals data from the Total Diet Study but only found papers estimating intake by source; the papers did not include the actual ra nges found in the food products that were used to es timate intakes (e.g., Gunderson 1995).]

b. Arsenic

Fish and shellfish contain the highest concentrati ons and are the largest dietary source of arsenic, generally in organic forms (Yost et al. 2004; ATSDR 2007). As noted in Technical Issue Paper: Health Benefits and Risks of Consuming Fish and Shellfish , organic forms such as those found in seafood are generally considered non-toxic. Yost et al. (2004) presented total and inorganic

arsenic concentrations for animal -based protein sources (Figure 5; data supporting this figure are presented in Table 11). While salt water fish and shrimp had total arsenic concentrations greatly exceeding those of other sources, the inorganic arse nic concentrations of all of the sources were small and within one order of magnitude of each other. Inorganic arsenic was not detected in

tuna or milk.

Figure 5. Total and inorganic arsenic concentrations of selected protein sources (from da ta in Yost et al. 2004)Technical Issue Paper July 20, 2012 Page 11 Yost et al. (2004) examined intake of inorganic arsenic in children ages 1 to 6 years and found that fish and shellfish contributed less than 1 pe rcent of the daily dietar y intake (Figure 6, data table presented in Appendix A). Meat and poultry c ontributed slightly more (just over 1 percent) and dairy products another 14 percent. Young childr en were investigated because they are often considered to be a sensitive sub-population that is vulnerable to arsenic exposures from soil and subject to higher exposures on a body weight basi s. Inorganic arsenic wa s specifically evaluated

because it is considered the most toxicol ogically significant. Grain and grain products contributed nearly 50 percent of the inorgani c arsenic in the diet of young children. Of the animal protein sources, dairy products contribut ed the most inorganic arsenic (14 percent), followed by meat and poultry (1.2 percent), eggs (0.5 percent), and then fish/shellfish (0.1 percent).

Figure 6. Sources of dietary inorgani c arsenic for children 1 to 6 years (% contribution)

c. PAHs

Kazerouni et al. (2001) measured concentrations of benzo(a)pyrene in 200 food items. Table 2

summarizes some of the results for animal-b ased protein sources. Cooking method greatly

affected the concentration of benzo(a)pyrene in foods, with gr illed foods generally containing more than broiled or fried foods and very well -done grilled meats containing more than medium

or well-done meats.Page 12 July 20, 2012 Technical Issue Paper Table 2. Benzo(a)pyrene in animal-based protein sources

Food Cooking

Method Portion Size (g) Concentration (μg/kg)* ng/portion Hamburger Oven-broiled - very well 85 0.01 0.8 Hamburger Grilled - medium 85 0.09 8.0 Hamburger Grilled – well 85 0.56 48 Hamburger Grilled - ve ry well 85 1.52 129 Steak Oven-broiled - very well 112 0.01 1.0 Steak Grilled - very well 112 4.86 544 Chicken, boneless Oven-broiled - very well 96 0.48 46
Chicken, boneless Grilled - well 96 0.39 37
Chicken, boneless Grilled - very well 96 0.40 38 Crab Not given 38 0.1 3.8

Perch fillet Grilled - well 85 0.19 16
Pork chops Oven-broiled - well 112 0.01 1.0
Pork chops Pan-fried - well 112 0.01 1.0

Butter NA 10 ND ND Cheese, cottage NA 113 0.07 8.0
Eggs NA 100 0.03 3.0
Milk, whole NA 244 0.02 5.0
Yogurt,
flavored/frozen NA 227 0.18 41

Modified from Kazerouni et al. 2001 *ND = not detected; limit of detection was 0.005 μg/kg

The European Food Safety Authority (2008) rece ntly presented data for 15 priority PAHs (PAH15) in food samples taken throughout Euro pe. The PAHs included: benz(a)anthracene, benzo(b)fluoranthene, benzo(j)fluoranthene, benzo(k)fl uoranthene, benzo(ghi)perylene, benzo(a)pyrene, chrysene, cyclopenta(cd)pyrene, dibenz(a,h)anthracene, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene, dibenzo(a,i)pyrene, di benzo(a,l)pyrene, indeno(1,2,3-)pyrene, and 5- methylchrysene. The highest concentrations we re reported for processed fish, molluscs, and smoked molluscs (Figure 7; data presented in Appendix A).Technical Issue Paper July 20, 2012 Page 13 Figure 7. Upper bound PAH15 concen trations (μg/kg) by food group

Modified from European Food Safety Authority 2008

WDOH evaluated the PAH8 data in the European Food Safety Authority study (White 2012) and

estimated that PAHs in shellfish could account for up to 20 percent of the PAH intake for a shellfish consumer’s diet. PAH8 priority P AHs included the followi ng carcinogenic compounds: benz(a)anthracene, benzo(b)fluoranthene, be nzo(k)fluoranthene, benzo(ghi)perylene, benzo(a)pyrene, chrysene, dibenz(a,h)anthracene, and indeno(1,2,3-)pyrene.

In a total daily diet intake study, Kazerouni et al. (2001) found that barb ecued meats contributed the most benzo(a)pyrene, followed by dairy produ cts, and non-barbecued meats (Figure 8). 0 5 10 15 20 25 30 35 40

Barbequed

meat Grilled

meat Other meat Smoked

meat Fresh fish Processed

fish Smoked

fish Molluscs Smoked

molluscsUpperBoundofPAH15concentration(μg/kg)Page 14 July 20, 2012 Technical Issue Paper Figure 8. Percent of total daily benzo(a)pyrene intake in a control group of 228 subjects

Source: Kazerouni et al. 2001

d. Dioxin

Dougherty (2000) estimated that fish and shellfish c ontributed nearly 90 perc ent of the dioxins in the average U.S. consumer’s diet while beef c ontributed less than 10 pe rcent. More recently, Lorber et al. (2009) estimated the total TEQ contributions of dioxin-like compounds (including dioxin-like PCBs) from meat, seafood, egg, and da iry products in the diet (Figure 9; data presented in Appendix A). This was achieved usin g average contaminant c oncentrations in foods and food consumption rates. The contribution to TEQs fr om fish in the diet, as calculated by Lorber et al. (2009), was less than 32 percent.Technical Issue Paper July 20, 2012 Page 15 Figure 9. Exposure pathway for PCDD/P CDF/PCB TEQ intakes from protein sources (percent contribution by source)

“Other pathways” includes: consumption of water, inhalation of air, ingestion of soil, dermal contact, and vegetable fat intake

.

e. PCBs

Dougherty (2000) estimated that fish and shellfish contributed nearly 100 percent of the PCBs in the average U.S. consumer’s diet. However, Sc hecter et al. (2010), us ing samples of 31 foods

collected in 2009 from a market-b asket survey, calculated that meat sources contributed more than seafood, dairy, eggs, and vege table products combined to daily dietary intake of PCBs (data for animal sources provided in Tables 3, 4, and 5). This may have been due to the relative quantities consumed, because PCBs were found in fish at similar con centrations (and with additional PCB congeners) than in meats. Each of the 209 PCB congeners has been assigned a congener number (e.g., PCB-52, whic h is 2,2’,5,5’-tetr achlorobiphenyl). The specific congeners analyzed by Schecter et al. ( 2010) are denoted by their congener number in the tables below. Note that the representative PCBs were not dete cted in any meats except hamburger, in any fish except salmon and canned sardines, or in any dairy products or eggs. Resear chers in Japan (Hirai et al. 2004), however, found that ex posure of farm animals to coplanar PCBs through fish meal is an important source of PCBs in meat and mil k. Variations in feed-g rass concentrations of coplanar PCBs were insufficient for explaining levels of these congeners in meat and milk. When fish meal was included in modeling calc ulations, the predicted congener profile came

close to actual measurements. 31.5

19.4 16.2 10.7 7.8 6.9 4.3 2 Fish

Beef

Dairy

Other pathways

Milk

Eggs

Other meat

Poultry

Modified from Lorber et al. (2009)Page 16 July 20, 2012 Technical Issue Paper Table 3. Levels of marker PCBs in co mposite meat samples (ng/g ww or LOD)

Marker Hamburger Bacon Turkey Sausages Ham Chicken

breast Roast beef Lipid
Content (%) 21.7 36.1 2 23.9 4.3 4.7 4.6

PCB-52 ND (0.1) ND (0.09) ND (0.04) ND (0.1 ) ND (0.05) ND (0.05) ND (0.04)

PCB-101 ND (0.4) ND (0.3) ND (0.1) ND (0.4) ND (0.2) ND (0.2) ND (0.1)

PCB-118 ND (0.2) ND (0.1) ND (0.06) ND (0.2) ND (0.07) ND (0.08) ND (0.09)

PCB-153 1.2 ND (0.4) ND (0.2) ND (0.5) ND (0.2) ND (0.3) ND (0.2)

PCB-138 ND (0.7) ND (0.4) ND (0.2) ND (0.6) ND (0.2) ND (0.3) ND (0.2)

PCB-180 0.21 ND (0.10) ND (0.04) ND (0.1) ND (0.04) ND (0.06) ND (0.05)

ww = wet weight; ND = not detected; LOD = level of detection

Table 4. Levels of marker PCBs in co mposite fish samples (ng/g ww or LOD)

Marker Salmon Canned

tuna Fresh catfish
fillet Tilapia Cod Canned

sardines Frozen fish

sticks Lipid
Content (%) 11.9 14.8 11.6 1.6 0.3 10.3 10.3

PCB-52 0.28 ND (0.06) ND (0.1) ND (0. 09) ND (0.07) 0.28 ND (0.06)

PCB-101 0.51 ND (0.2) ND (0.3) ND (0.3) ND (0.2) 0.67 ND (0.2)

PCB-118 0.43 ND (0.07) ND (0.2) ND (0.1) ND (0.1) 0.8 ND (0.09)

PCB-153 1.21 ND (0.3) ND (0.5) ND (0.4) ND (0.3) 1.83 ND (0.3)

PCB-138 0.93 ND (0.3) ND (0.5) ND (0.3) ND (0.2) 1.8 ND (0.3)

PCB-180 0.44 ND (0.06) ND (0.1) ND (0. 07) ND (0.06) 0.49 ND (0.07)

ww = wet weight; ND = not detected; LOD = level of detection

Table 5. Levels of marker PCBs in com posite dairy and egg samples (ng/g ww or LOD)

Marker Butter American

cheese Other

cheese Whole milk Yogurt Cream
Cheese Eggs Lipid
Content (%) 91.4 25.3 30.1 3.8 2.9 34 2.9

PCB-52 ND (0.2) ND (0.1) ND (0.09) ND (0.05) ND (0.03) ND (0.08) ND (0.05)

PCB-101 ND (0.2) ND (0.3) ND (0.3) ND (0.2) ND (0.08) ND (0.02) ND (0.1)

PCB-118 ND (0.1) ND (0.2) ND (0.2) ND (0.07) ND (0.04) ND (0.02) ND (0.08)

PCB-153 ND (0.5) ND (0.4) ND (0.4) ND (0.2) ND (0.1) ND (0.04) ND (0.2)

PCB-138 ND (0.5) ND (0.4) ND (0.4) ND (0.2) ND (0.1) ND (0.04) ND (0.2)

PCB-180 ND (0.1) ND (0.1) ND (0.10) ND (0.05) ND (0.03) ND (0.09) ND (0.05)

ww = wet weight; ND = not detected; LOD = level of detectionTechnical Issue Paper July 20, 2012 Page 17 

### E. Sensitive subpopulations

There are two types of populations that may be considered as sensitive populations when considering contaminant exposures: those that are exceptionally sensitive to a particular contaminant and those who may receive greater e xposure to a contaminant due to age, gender, health status, genetic di fferences, and lifestyle ch oices such as diet.

Native tribes and other ethnic groups may eat fish/shellfish at rate s significantly higher than most consumers. For example, Korean and Japanese Americans in the Puget Sound region have seafood consumption rates that are among the highe st in the nation (Tsuch iya et al. 2008). As discussed in the TSD, many Native Americans in Washington State also consume more seafood than the national average. A mercury intake biom etric study by Tsuchiya et al. (2008) found that one in two persons in the Japanese community was overexposed to methylmercury based on their diet and evidence from biological samples an alyzed for mercury content. The Korean community, however, had about one in ten pers ons who exceeded the reference dose, even though total seafood consumption was about the same as the Japanese cohort. While both populations consumed a large amount of seaf ood, their species preferences (e.g., Japanese consumed more salmon and the Koreans consumed more squid) influenced their mercury

exposure.

Children are unique in their contaminant exposur es for many reasons. They drink more fluids, eat more food, and breathe more air per kilogram of body weight, and have a larger skin surface in proportion to their body volume than do adults. Their diets often differ from that of adults. Nutritional requirements change with age: from placental nourishment to breast milk or formula

to the diet of older children w ho eat more of certain types of foods than adults. Behavior and lifestyle differences also influence a child’s contaminant exposure. Children crawl on the ground, put things in their mouths that an adult would not, and sometimes eat inappropriate things such as dirt or paint chips. Children may also spe nd more time outdoors than adults. As one example, children drink more milk on a per body weight basis than do adults . This significantly increases their exposures to milk-borne cont aminants compared to adults.

The developing fetus and young children are also sensitive subpopulations because they are more susceptible to the toxic effects of some contam inants such as methylmercury. Therefore, women of childbearing age, pregnant or nursing wo men, and young children are considered sensitive populations for neurodevelopmental risks from exposure to contaminants in foods. As FAO/WHO (2010) note, these same groups are also sensiti ve populations for neurodevelopmental risks fr om not consuming fish.



## III. Contaminant concentrations in dietary protein

sources

A. Fish and shellfish — Washington State contaminant

concentrations

The following tables and figures present cont aminant concentrations in Washington State seafood. Where available, data were selected that reflect different regions of th e state. Due to the industrial development preval ent around Puget Sound, there ar e myriad studies of seafoodPage 18 July 20, 2012 Technical Issue Paper contamination from this region. Coastal areas (e .g., Figures 10 and 11) and eastern Washington data (Spokane River in Table 8) are also represented in this T echnical Issue Paper. Other data were selected because they showed regional co mparisons of contaminant concentrations (e.g., Figure 14).

Appendix A provides tables of mercury, total P CBs, and dioxin TEQ concen trations that were summarized from data taken from the Ecology Environmental Information Management (EIM) database. The EIM data included marine, anadro mous, and freshwater sp ecies, and statistical summaries pooled the data by the ecologica l group and tissue type sampled. Additional information on background levels of PCBs and di oxins in Washington State freshwater fish is available in Ecology Publicati on No. 10-03-007 (Ecology 2010). Data analyzed in that report

that were included in the EIM database are c ontained within the statistical summaries in Appendix A. The tables and figures in this sect ion represent a subset of the contaminant data available for different regi ons of Washington State.

Figure 10. Mean PCB concentration in
Chinook salmon fillets

Source: O’Neill and West 2009 Figure 11. Mean PCB concentration in adult Chinook salmon returning to Puget Sound (in-rivers versus marine waters*)

Source: O’Neill and West 2009 Error bars represent standard error around the means. *”In-river” samples were taken from fish collected in the rivers noted, whereas “marine” samples were taken from fish collected in marine waters of the central or south Puget Sound, as noted.Technical Issue Paper July 20, 2012 Page 19Table 6. Average PCBs in Chinook salmon from in-river versus marine areas of the Puget Sound basinLocationTypePugetSoundbasinLocationNfNfa%SWA1NsPCBs*(μg/kg)%LipidsFishAge(years)SW Age(years)Length(mm)In-riverNorth Nooksack River 133120 3.3 28 37 3.45 3.6 2.5 741North Skagit River 125114 3.5 29 40 4.83 4.1 2.6 816Central Duwamish River171 159 12.6 65 567.34 3.8 2.4 763South Nisqually River92 90 5.6 20 41 3.76 3.4 2.3 732South Deschutes River113 77 0.0 34 59 1.74 3.9 2.4 789All in-river sites 634 5605.9 176 49 4.82 3.8 2.4 770MarineCentral Central sound60 60 76.7 12 86 5.74 2.8 1.3 599South South sound 69 68 2.9 16 69 4.15 3.5 2.3 747All marine sites 129128 37.5 28 76 4.83 3.2 1.9 683Total All sites 763688 11.8 204 53 4.82 3.7 2.3 758Modified from O'Neill and West 2009* wet weight basisNf= number of salmon collected; Nfa = number of fish in the sample whose age was estimated (i.e., “aged fish”); %SWA1 = percentage of aged fish that spent one winter in saltwater; Fish Age =average age of the fish in the sample;SW Age = average salt water age of sample; length is the average length of the fish in the samplePage 20 July 20, 2012 Technical Issue Paper Table 7. Maximum concentrat ion of contaminants detect ed in fish and shellfish sampled at Fidalgo Bay in Anacortes, Washington

Chemicals Contaminant maximum concentration (ppm)

Horse
Clams Manila Clams Bent nose
Clams Macoma
Clams Starry

Flounder English
Sole

Arsenic total 2.82 3.14 3.84 n/a 1.35 3.1 Mercury 0.009 0.03 0.02 n/a 0.071 0.0077
Total Dioxin TEQ 7.0E-8 1.2E-7 7.6E-7 6.9E-7 1.75E-7 1.68E-7

Red Rock Crab Dungeness Crab

Tissue Other* Hepatopancreas Tissue Other* Hepatopancreas Arsenic total 5.95 4.69 7.31 10.47 6.81 6.54 Mercury 0.058 0.026 0.060 0.088 0.051 0.049
Total Dioxin TEQ 1.8E-7 1.53E-6 6.57E-6 1.44E-7 5.82E-6 1.05E-5

Source: WDOH 2010 Health Consultation for Fidalgo Bay

Total Dioxin TEQ – sum of dioxin/furans toxic equivalent (TEQ)

PPM – parts per million, na – not available

* Other soft tissues (viscera)

Table 8. Mean total PCB concentrations for fish from the Spokane River, Spokane, WA

Location Species Total mean PCBs (μg/kg, ww)
Fillet samples

Plante Ferry Rainbow Trout 55

Mission Park Rainbow Trout 153

Mission Park Mountain Whitefish 234

Ninemile Rainbow Trout 73

Ninemile Mountain Whitefish 139 Upper Long Lake Mountain Whitefish 43
Upper Long Lake Brown Trout 130 Upper Long Lake Smallmouth Bass 37 Lower Long Lake Mountain Whitefish 76 Lower Long Lake Smallmouth Bass 67
Whole body samples Stateline Largescale Sucker 56 Plante Ferry Largescale Sucker 122 Mission Park Largescale Sucker 1,823 Ninemile Bridgelip Sucker 69 Upper Long Lake Largescale Sucker 327 Lower Long Lake Largescale Sucker 254

Source: WDOH 2007; ww - wet weightTechnical Issue Paper July 20, 2012 Page 21 Figure 12. Total PAHs in Washington State mussels (μg/kg dry weight)

Source: Puget Sound Action Team 2007.Page 22 July 20, 2012 Technical Issue Paper Figure 13. Total mercury concentrations in Washington State mussels (μg/kg dry weight)

Source: Puget Sound Action Team 2007.Technical Issue Paper July 20, 2012 Page 23 Figure 14. PCBs in large fish fr om Washington State lakes and rivers

Source: Hardy and McBride 2004

KOK=kokanee, SMB=smallmouth bass, NP=northern, pikeminnow, MW F=mountain whitefish, RT=rainbow trout, CT=cutthroat trout.Page 24 July 20, 2012 Technical Issue Paper Figure 15. PCBs (μg/kg) in fish from Puget Sound compared to other common food sources

Samples include fish from Puget Sound and results are reported in micrograms per kilogram sampled. Commercial foods were sample d as part

of the U.S. Food and Drug Administration’s total diet study and market-basket survey. In most cases, data are limited by small sample sizes.

Source: Puget Sound Action Team 2007Technical Issue Paper July 20, 2012 Page 25 Table 9. Summary of PCB data (μg/kg wet weight) in hake and pollock from seven Puget Sound Basins

Pacific Hake Walleye Pollock

Σ PCBs Str. Juan

de Fuca Strait of Georgia Hood
Canal Whidbey

Basin Elliott Bay Main

Basin South
Sound Hood
Canal Elliott Bay Main

Basin

n a 3/3 3/3 10/10 10/10 11/11 12/12 3/3 3/3 1/1 4/4

min 2.7 3.4 9 29 29 23 32 6.9 120 11

max 6.6 6.6 38 67 72 68 34 8.4 120 26

mean 4.2 5.3 15 44 45 33 33 7.6 nc 15

10th %. 2.7 3.4 9 30 30 24 32 6.9 nc 11

Median 3.3 5.7 10 41 44 28 33 7.4 nc 12

90th % 6.6 6.6 33 65 67 52 34 8.4 nc 26

a Number of samples with detected values/number of samples analyzed

“nc” indicates statistics that were not calculated because there were fewer than three detected values

In cases where no analyte was detected, the minimum (min) and maximum (max) values are presented as “<” the average limit of qu antitation for that analyte.



### B. Other protein sources (meat, eggs, dairy)

Very little information was avai lable regarding contaminant c oncentration in other protein sources in Washington State. Ther efore, this section summarizes available data from various

U.S. and international sources.

a. Mercury

As described above, the U.S. Total Diet Study fo und that nearly all methylmercury in the U.S. diet is from fish and shellfish (Mahaffey 2009), but concerns have been raised about the potential

for fish meal to increase contaminant levels in farm animals (Dórea 2008). This may be less of a concern for beef and cow’s milk, however, beca use cows can demethylate methylmercury in the rumen and therefore absorb less mercury (ATSDR 1999). A study conducted in Pakistan (Shah et al. 2010) showed mercury uptake in chicken tissues from mercury in the chicken feed (Table 10).

Table 10. Concentration of total mercury in chicken feed and the different tissues of boiler chickens (μg/kg)

Poultry
farms Feed Age groups Chicken tissues (weeks) Leg Breast Liver Heart

Farm-1 15.1 ± 0.77 1–3 3.24 ± 0.23 3.49 ± 0.26 4.94 ± 0.49 3.27 ± 0.32

4–6 2.66 ± 0.36 2.93 ± 0.22 3.55 ± 0.51 2.19 ± 0.26

Farm-2 12.8 ± 0.36 1–3 2.87 ± 0.21 2.59 ± 0.34 3.98 ± 0.38 2.84 ± 0.41

4–6 2.15 ± 0.17 2.47 ± 0.21 3.43 ± 0.37 2.50 ± 0.41

Farm-3 16.5 ± 0.25 1–3 2.47 ± 0.14 3.86 ± 0.09 5.54 ± 0.33 2.93 ± 0.24

4–6 2.14 ± 0.23 2.53 ± 0.26 4.34 ± 0.49 2.27 ± 0.32

Farm-4 12.2 ± 0.61 1–3 2.14 ± 0.23 2.79 ± 0.26 4.04 ± 0.49 3.17 ± 0.32

4–6 1.57 ± 0.21 2.11 ± 0.34 3.28 ± 0.38 2.44 ± 0.41

Farm-5 8.57 ± 0.47 1–3 1.97 ± 0.21 2.11 ± 0.34 3.28 ± 0.38 2.44 ± 0.41

4–6 1.27 ± 0.14 1.86 ± 0.09 2.54 ± 0.33 2.13 ± 0.24

Modified from Shah et al. 2010

*dry weight basisPage 26 July 20, 2012 Technical Issue Paper b. Arsenic

Inorganic arsenic concentrations appear to o ccur in a relatively narr ow concentration range across protein types, as shown by the data from Yost et al. (2004) (Table 11).

Table 11. Mean total and total inorga nic arsenic concentrations in foods (μg/kg wet weight)

Food Mean Total Arsenic Mean Total Inorganic

Arsenic 3 Meat and Poultry

Beef 51.5 0.39 J

Chicken 86.4 0.89 J

Pork 13.5 0.67 J

Seafoods

Freshwater finfish 160 1.0 J Saltwater finfish 2,356 0.55 J Shrimp 1,890 1.9 J

Tuna 512 1.0 U Dairy products and Eggs

Milk 1,2 2.2 1.0 U

Butter 1.8 1.17 J Eggs 20 0.98 J

Modified from Yost et al. 2004

1 both whole and skim milk were analyzed; results combined and applied to all milk products

2 As3+ concentration was 0.18 μg/kg J

3 Where no arsenic was detected (after blank-correcting), one-half the value of the method detection limit was given with a U des ignation. When the concentration of arsenic in food (after blank-correcting) was detected above the blank concentration but below the method d etection limit, the value was given a J designation. Undetected samples have been included at one-half of the detection limits. All averaged va lues were computed as follows: (1) If one or more, but not all, values to be averaged were non-detected, 50 percent of the detection limi t(s) was used in calculating the average concentration and (2) Mean values have a U or a J qualifier if all values used to calculate the mean we re U or J qualified, respectively.

c. PAHs

As shown in Table 2 and described in Sec tion 2.3.2, PAHs in protein sources are highly influenced by cooking methods. Schaum et al. (2003) evaluated cow’s milk samples from locations across the United States for PBTs including PAHs. The PAHs analyzed were acenaphthylene, anthracene, benzo(a)pyrene, fluo rene, naphthalene, phenanthrene, and pyrene (Table 12). Acenaphthene and benzo(a)pyrene were not detected in any samples analyzed by Schaum et al. (2003).Technical Issue Paper July 20, 2012 Page 27 Table 12. Concentrations of PAHs in milk from western U.S. locations (ng/kg)*

PAH July 2000 January 2001 Acenaphthylene 44.6 39.8

Anthracene ND 40.8 J

Fluorene 57.6 J 127.2
Naphthalene 947.1 882.3

Phenanthrene 431.0 640.8 Pyrene 98.9 151.2

Modified from Schaum et al. 2003

West locations included: Portland, Tacoma, Spokane, Sacramento, San Francisco, Las Vegas, and Honolulu

Data from the original paper was in ng/L, which is roughly equivalent to ng/kg (density of milk is about 1.003)

Detected PAHs only; acenaphthene and benzo(a)pyrene were not detected in any samples from any locations in the study

d. Dioxins/PCBs

Table 13 presents the dioxin concentrations in milk samples taken across the United States. The Far West location included samples from Wa shington, Oregon, California, and Hawaii.

Table 13. TEQ concentrations of CDD/ CDFs and PCBs in milk (pg/kg)

CDD/CDF PCB Total a Composite

location July

2000 January

2001 Mean b July

2000 January

2001 Mean b Mean b
New England 12.85 8.89 10.87 9.53 8.29 8.91 19.78

Mid-Atlantic 11.67 14. 21 12.94 14.37 8.3 11.34 24.28

South Central 17.53 19. 14 18.34 6.93 9.57 8.24 26.59

North Central 20.48 10. 35 15.42 11.36 7.13 9.25 24.66

West Central 17.94 18. 59 18.27 5.31 5.16 5.24 23.5

Southwest 13.27 6.21 9.74 6.71 6.29 6.5 16.24

Far South 18.13 35.82 26.98 8.07 7.59 7.83 34.81

Far West 22.5 13.2 17.85 8.8 8.33 8.57 26.42

Modified from Schaum et al. 2003

CDD/CDF = chlorinated dibenzo- p -dioxin/ chlorinated dibenzofuran

Data from the original paper was in pg/L, which is roughly equivalent to pg/kg (density of milk is about 1.003)

a This is the sum of the CDD/CDF seasonal mean and the PC B seasonal mean.

b Average of summer and winter concentrations.Page 28 July 20, 2012 Technical Issue Paper Table 14 presents dioxin (PCDDs, PCDFs, plus a subset of four dioxi n-like PCB congeners) concentrations (as mean TEQs) in uncooked meat samples from the United States.

Table 14. Mean TEQs of 17 PCDD/Fs an d 4 dioxin-like PCBs in U.S. meats (ng/kg lipid)

Contaminant beef

N = 139 pork

N = 136 chicken

N = 151 turkey

N = 84 mean PCDD/F TEQ 0.55 (0.51) 0.14 (0 .04) 0.12 (0.04) 0.36 (0.34) mean dioxin-like-PCB* TEQ 0.11 (0.11) 0.02 (0.01) 0.05 (0.05) 0.25 (0.25)

Adapted from Huwe et al. 2009 *PCBs analyzed were the coplanar congeners 77, 81, 126, and 169Technical Issue Paper July 20, 2012 Page 29 

# Summary

Contaminants occur in many food sources and for so me, food is the major contributor to intake in the general population (i.e., those not expos ed occupationally). Mercury, arsenic, PAHs, dioxins, and PCBs all have food as the major source of intake.

 Over the past three decades, per capita chicken has increased, beef consumption has decreased, and pork and seafood consump tion has remained fairly stable.

 In the United States, fish and shellfish ar e the primary dietary source of mercury and arsenic (organic forms). Shellfish may cont ribute significantly (~20 percent) to the PAH

intake for shellfish consumers.

 Inorganic arsenic (generally considered to be the more toxic form) is present in low concentrations in most animal-based protein sources, but dietary intake is largely from cereals, water used in cooking, vegeta bles, and fruits and fruit juices.

 Nearly all of the dietary intake of mercury in the United States comes from animal-based protein sources, with fish and shellfish bei ng the principal sources . PAH concentrations in foods are largely influenced by cooking methods.

 Dietary intake studies show dioxin TEQs come largely from animal-based protein sources, with fish contributing r oughly one-third of total TEQs.

 If fish and shellfish consumption increases in the future, exposure to methylmercury

could increase. Actual increas es would depend on the species consumed, as some contain higher average concentrations of merc ury (for more on this topic, see Technical Issue Paper: Health Benefits and Risk s of Consuming Fish and Shellfish ).

Direct comparison of contaminant concentrations in dietary protein sour ces is difficult due to variations in the way these data are presented in the literature. Concentr ations are presented as wet weight or dry weight, cooke d or uncooked, lipid-normalized or total, and using a variety of units. Data were collected during different tim e periods, in different locations, and using different analysis methods.Page 30 July 20, 2012 Technical Issue Paper 

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# Appendices

Appendix A. Contaminant Data Tables Supporting Figures 6, 7, and 9Page A-2 July 20, 2012 Technical Issue Paper Table A-1. Sources of di etary inorganic arsenic for children 1 to 6 years (% contribution)

Exposure Pathway Percent
Contribution Fruits and fruit juice 20.9

Fish & Shellfish 0.1 Dairy products 14 Meat & poultry 1.2 Water used in cooking 4.1 Eggs 0.5 Grain & grain products 47.3 Condiments, fats, oils 0.5 Vegetables & vegetable products 6.3 Legumes, nuts, seeds 1

Modified from Yost et al. 2004

Table A-2. Lower bound and uppe r bound PAH15 concentrations (μg/kg) by food group

Food Group N Lower Bound Upper Bound
Barbequed meat 31 12.18 12.48

Grilled meat 21 11.27 11.77

Other meat 49 0.96 1.43

Smoked meat 167 2.97 3.61

Fresh fish 6 0.19 2.82

Processed fish 29 31.9 33.86

Smoked fish 153 3.51 4.03

Molluscs 167 19.57 20.14

Smoked molluscs 11 18.23 18.65

N: number of samples

PAHs analysed included: benz(a)anthracene, benzo(b)fluorant hene, benzo(j)fluoranthene, benzo(k)fluoranthene, benzo(ghi)perylene, benzo(a)py rene, chrysene, cyclopenta(cd )pyrene, dibenz(a,h)anthrace ne, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene, dibenzo(a,i)pyrene, dibenzo(a, l)pyrene, indeno(1,2,3-)pyrene and 5-methylchrysene.

Processed fish included fish canned in oil.Technical Issue Paper July 20, 2012 Page A-3 Table A-3. Estimated TEQ intake from dietary protein sources

Exposure Pathway PCDD/PCDF/PCB TEQ Intakes (pg/day) 1 Percent
Contribution

Fish 10.9 31.5

Beef 6.7 19.4
Dairy 5.6 16.2

Other sources 2 3.7 10.7

Milk 2.7 7.8
Eggs 2.4 6.9

Other meat 3 1.5 4.3
Poultry 0.7 2.0

Total: 34.5 --

Modified from Lorber et al. (2009)

Notes:

1. Non-detects set at zero

2. Other sources included consumption of water, air inhalation, ingestion of soil, soil dermal contact, and vegetable fat intak e 3. Other meats included game, lamb, and other unidentified meats.Page A-4 July 20, 2012 Technical Issue Paper This page purposely left blank for duplicate printing.Technical Issue Paper July 20, 2012 Page B-1 

## Appendix B. Washington State Contaminant Data
Summarized from the EIM Database

The following tables of mercury, total PCBs, a nd dioxin TEQ concentrati ons were summarized from data taken from the Ecology Environmenta l Information Management (EIM) database. The

EIM data included marine and fr eshwater species. Statistical summaries pooled the data by marine vs. freshwater, species type, and ecol ogical niche (deposit feeding vs. filter feeding shellfish, pelagic vs. demersal fish vs. salmoni ds, etc.). Further breakdown of the data was by tissue type analyzed (e.g., whole body vs. fillet fo r fish, muscle vs. hepatopancreas for crabs). Data included in the summary statistics were restricted to samples collected within the last 10 years. PCB congeners were summed to create Total PCB values; however, not all possible congeners were analyzed in every samp le. Species were grouped as follows:

Anadromous

Bull trout (can also occur as a freshwater species)

Chinook salmon

Coho salmon Cutthroat trout (can also o ccur as a freshwater species) Steelhead (can also occur as a fr eshwater species [rainbow trout]) Sockeye salmon (can also occur as a freshwater species [kokanee]) White sturgeon (can also occu r as a freshwater species) American shad (this may be a freshwater occurring species too) Pacific lamprey

Freshwater

Salmonids (if EIM data a ssigned FW, then kept FW)

Brook trout Brown trout (aka German brown trout) Cutthroat trout (can also occu r as an anadromous species) Rainbow trout (can also occur as an anadromous species [steelhead]) Kokanee (can also occur as an an adromous species [sockeye salmon]) American shad (usually an anadromous species)

Lake trout

Mountain whitefish

Lake whitefish Pygmy whitefish

Smelt

Bass

Largemouth bass

Smallmouth bass

Other freshwater fish

White sturgeon (can also occur as an anadromous species)Page B-2 July 20, 2012 Technical Issue Paper Northern pike Walleye Northern pikeminnow Black crappie Bluegill Pumpkinseed

Peamouth Rock bass (sunfish family) Yellow perch

Burbot Bridgelip sucker Common carp Grass carp

Brown bullhead

Channel catfish Largescale sucker

Unidentified sucker

White sucker

Marine Demersal

Arrowtooth flounder

Butter sole English sole

Flathead sole

Pacific dover sole

Pacific sand sole

Pacific sanddab

Pacific slender sole

Rock sole Speckled sanddab Starry flounder

unidentified flounder

Other Marine Fish

Lingcod Pile perch Shiner perch Striped seaperch

Invertebrates

Bivalves – deposit feeding: maco ma clam, “unidentified” clams Bivalves – filter feeding: softshell, Manilla, horse, littleneck, Asiati c, geoduck, and butter clams; blue mussels, Pacifi c oysters, Kumomoto oysters

Bivalves – freshwater: As iatic (Corbicula) clam Crabs: Dungeness, rock, graceful Crayfish: Pacific signal crayfishTechnical Issue Paper July 20, 2012 Page B-3 Table B-1. Contaminant concentrat ions in selected Washington State

freshwater fish

Count Minimum Maximum Mean

BASS

Fillet, skin on

dioxin TEQ (ng/kg) 35 0.028 0.57 0.18
mercury (μg/kg) 403 20 1,800 234
PCB, Sum of Congeners (μg/kg) 20 0.25 25 6.5
Fillet, skin off

mercury (μg/kg) 115 26 790 240

FRESHWATER SALMONID

Fillet, skin on

dioxin TEQ (ng/kg) 12 0.081 1.0 0.40
mercury (μg/kg) 60 17 250 93
PCB, Sum of Congeners (μg/kg) 49 0.29 384 25
Fillet, skin off

mercury (μg/kg) 1 64 64 64 Whole Organism

PCB, Sum of Congeners (μg/kg) 66 0.94 450 35

OTHER FRESHWATER FISH

Fillet, skin on

dioxin TEQ (ng/kg) 84 0.032 11 0.44
mercury (μg/kg) 265 11 1,900 187
PCB, Sum of Congeners (μg/kg) 31 0.044 611 41
Fillet, skin off

dioxin TEQ (ng/kg) 9 0.21 1.1 0.49
mercury (μg/kg) 12 17 410 152
PCB, Sum of Congeners (μg/kg) 1 2.4 2.4 2.4
Whole Organism

dioxin TEQ (ng/kg) 22 0.14 0.65 0.38
mercury (μg/kg) 24 24 290 160
PCB, Sum of Congeners (μg/kg) 12 28 253 97

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsPage B-4 July 20, 2012 Technical Issue Paper Table B-2. Contaminant concentrat ions in selected Washington State

invertebrates

Count Minimum Maximum Mean
BIVALVE, DEPOSIT FEEDER

Whole organism, not shell

dioxin TEQ (ng/kg) 24 0.02 20 1.7

BIVALVE, FILTER FEEDER

Muscle

dioxin TEQ (ng/kg) 12 0.016 0.16 0.1
mercury (μg/kg) 34 5 33 11
Whole organism, not shell

dioxin TEQ (ng/kg) 73 0.015 1.6 0.2
mercury (μg/kg) 197 3.2 82 9.2
Whole organism, not shell, not gut

dioxin TEQ (ng/kg) 13 0.017 0.35 0.1
mercury (μg/kg) 72 3.6 61 18

Skin

mercury (μg/kg) 20 1 36 7.4

Viscera, abdominal and thoracic

dioxin TEQ (ng/kg) 5 0.055 0.099 0.1
mercury (μg/kg) 77 4 74 20

Gut ball

dioxin TEQ (ng/kg) 4 0.17 0.44 0.3
mercury (μg/kg) 2 45 48 47

FRESHWATER BIVALVE

Whole organism, not shell

dioxin TEQ (ng/kg) 29 0.41 5.6 1.2
mercury (μg/kg) 25 5 16 9.4

CRAB

Muscle

dioxin TEQ (ng/kg) 46 0.027 0.74 0.2
mercury (μg/kg) 26 20 70 43

Muscle, visceral

dioxin TEQ (ng/kg) 9 0.028 0.38 0.2
mercury (μg/kg) 9 31 110 67
Whole organism, not exoskeleton

dioxin TEQ (ng/kg) 7 0.14 1.5 0.6
Whole organism, not exoskeleton, not gut

dioxin TEQ (ng/kg) 10 0.011 0.3 0.1
Hepatopancreas

dioxin TEQ (ng/kg) 54 0.18 41 6.1
mercury (μg/kg) 22 20 220 55Technical Issue Paper July 20, 2012 Page B-5 Table B-2. Contaminant concentrat ions in selected Washington State

invertebrates

Count Minimum Maximum Mean

CRAYFISH

Whole organism, not exoskeleton, not gut

PCB, Sum of Congeners (μg/kg) 1 0.87 0.87 0.9

SHRIMP

Whole organism

dioxin TEQ (ng/kg) 6 0.16 0.34 0.2
mercury (μg/kg) 6 23 50 37

SEA CUCUMBER

Muscle, somatic

mercury (μg/kg) 18 16 88 32

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsPage B-6 July 20, 2012 Technical Issue Paper Table B-3. Contaminant concentrat ions in selected Washington State
marine/anadromous fish

Count Minimum Maximum Mean

ANADROMOUS FISH

Fillet, skin on

dioxin TEQ (ng/kg) 107 0.044 4.6 0.37
mercury (μg/kg) 136 5.8 610 103
Fillet, skin off

mercury (μg/kg) 2 37 54 46
Whole organism

dioxin TEQ (ng/kg) 17 0.51 1.5 0.78
mercury (μg/kg) 35 29 100 54
Whole organism, not fillets

mercury (μg/kg) 10 22 41 33

MARINE DEMERSAL FISH

Fillet, skin on

mercury (μg/kg) 43 5 130 37
Fillet, skin off

dioxin TEQ (ng/kg) 25 0.086 1.0 0.34
mercury (μg/kg) 28 20 190 78

Muscle

dioxin TEQ (ng/kg) 35 0.011 0.36 0.054
mercury (μg/kg) 3 10 40 23
Whole organism

dioxin TEQ (ng/kg) 27 0.071 1.7 0.50
mercury (μg/kg) 50 5 56 17
Whole organism, not shell

dioxin TEQ (ng/kg) 26 0.023 0.30 0.077
mercury (μg/kg) 23 4 27 11
Whole organism, not fillets

dioxin TEQ (ng/kg) 16 0.16 1.2 0.66

Viscera, abdominal and thoracic

dioxin TEQ (ng/kg) 20 0.029 0.18 0.088

Skeleton

mercury (μg/kg) 8 18 62 38

OTHER MARINE FISH

Fillet, skin on

dioxin TEQ (ng/kg) 2 0.084 0.092 0.088
mercury (μg/kg) 4 40 97 69
Whole organism

mercury (μg/kg) 25 10 30 22Technical Issue Paper July 20, 2012 Page B-7 Table B-3. Contaminant concentrat ions in selected Washington State
marine/anadromous fish

Count Minimum Maximum Mean

Whole organism, not fillets

dioxin TEQ (ng/kg) 2 0.14 0.17 0.16
mercury (μg/kg) 2 56 220 138

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsPage B-8 July 20, 2012 Technical Issue Paper Table B-4. Mercury concentrations (μg/kg) in selected Washington State

fish

Count Minimum Maximum Mean

FRESHWATER FISH

BASS

Fillet, skin on 403 20 1,800 234
Fillet, skin off 115 26 790 240

FRESHWATER SALMONID

Fillet, skin on 60 17 250 93
Fillet, skin off 1 64 64 64

OTHER FRESHWATER FISH

Fillet, skin on 265 11 1,900 187
Fillet, skin off 12 17 410 152
Whole organism 24 24 290 160

MARINE/ANADROMOUS FISH

ANADROMOUS FISH

Fillet, skin on 136 5.8 610 103
Fillet, skin off 2 37 54 46
Whole organism 35 29 100 54
Whole organism, not fillets 10 22 41 33

MARINE DEMERSAL FISH

Fillet, skin on 43 5 130 37
Fillet, skin off 28 20 190 78

Muscle 3 10 40 23
Whole organism 50 5 56 17
Whole organism, not shell 23 4 27 11

Skeleton 8 18 62 38

OTHER MARINE FISH

Fillet, skin on 4 40 97 69
Whole organism 25 10 30 22
Whole organism, not fillets 2 56 220 138

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsTechnical Issue Paper July 20, 2012 Page B-9 Table B-5. Mercury concentrati ons (μg/kg) in selected edible Washington State invertebrates

Count Minimum Maximum Mean

BIVALVE, FILTER FEEDER

Muscle 34 5 33 11
Whole organism, not shell 197 3.2 82 9.2
Whole organism, not shell, not gut 72 3.6 61 18

Skin 20 1 36 7.4

Viscera, abdominal and thoracic 77 4 74 20

Gut ball 2 45 48 47

FRESHWATER BIVALVE

Whole organism, not shell 25 5 16 9.4

CRAB

Muscle 26 20 70 43

Muscle, visceral 9 31 110 67
Hepatopancreas 22 20 220 55

SHRIMP

Whole organism 6 23 50 37

SEA CUCUMBER

Muscle, somatic 18 16 88 32

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsPage B-10 July 20, 2012 Technical Issue Paper Table B-6. Dioxin TEQ concentrations (ng/kg) in selected Washington State

fish and invertebrates

Count Minimum Maximum Mean

FRESHWATER FISH

BASS

Fillet, skin on 35 0.028 0.57 0.18

FRESHWATER SALMONID

Fillet, skin on 12 0.081 1.0 0.40

OTHER FRESHWATER FISH

Fillet, skin on 84 0.032 11 0.44
Fillet, skin off 9 0.21 1.1 0.49
Whole organism 22 0.14 0.65 0.38

MARINE/ANADROMOUS FISH

ANADROMOUS FISH

Fillet, skin on 107 0.044 4.6 0.37
Whole organism 17 0.51 1.5 0.78

MARINE DEMERSAL FISH

Fillet, skin off 25 0.086 1.0 0.34

Muscle 35 0.011 0.36 0.054
Whole organism 27 0.071 1.7 0.50
Whole organism, not shell 26 0.023 0.30 0.077
Whole organism, not fillets 16 0.16 1.2 0.66

Viscera, abdominal and thoracic 20 0.029 0.18 0.09

OTHER MARINE FISH

Fillet, skin on 2 0.084 0.092 0.09
Whole organism, not fillets 2 0.14 0.17 0.16

INVERTEBRATES 292 0.011 41 1.5
BIVALVE, DEPOSIT FEEDER

Whole organism, not shell 24 0.020 20 1.7

BIVALVE, FILTER FEEDER

Muscle 12 0.016 0.16 0.056
Whole organism, not shell 73 0.015 1.6 0.22
Whole organism, not shell, not gut 13 0.017 0.35 0.14

Viscera, abdominal and thoracic 5 0.055 0.099 0.068

Gut ball 4 0.17 0.44 0.27

FRESHWATER BIVALVE

Whole organism, not shell 29 0.41 5.6 1.2Technical Issue Paper July 20, 2012 Page B-11 Table B-6. Dioxin TEQ concentrations (ng/kg) in selected Washington State

fish and invertebrates

Count Minimum Maximum Mean

CRAB

Muscle 46 0.027 0.74 0.16

Muscle, visceral 9 0.028 0.38 0.19
Whole organism, not exoskeleton 7 0.14 1.5 0.62
Whole organism, not exoskeleton, not gut 10 0.011 0.30 0.080
Hepatopancreas 54 0.18 41 6.1

SHRIMP

Whole organism 6 0.16 0.34 0.21

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculationsPage B-12 July 20, 2012 Technical Issue Paper Table B-7. PCB concentrations (to tal congeners, μg/kg) in selected Washington State freshwater fish and shellfish

Count Minimum Maximum Mean

FRESHWATER FISH

BASS

Fillet, skin on 20 0.25 25 6.5

FRESHWATER SALMONID

Fillet, skin on 49 0.29 384 25
Whole organism 66 0.94 450 35

OTHER FRESHWATER FISH

Fillet, skin on 31 0.044 611 41
Fillet, skin off 1 2.4 2.4 2.4
Whole organism 12 28 253 97

INVERTEBRATES

CRAYFISH

Whole organism, not exoskeleton, not gut 1 0.87 0.87 0.9

Data provided by Laura Inouye, Washington Department of Ecology,

- queried from the Environmental Information Management Database

- limited to the most recent 10 years (2002 - 2012)

- non-detects not included in calculations

# Technical Issue Paper



# Salmon Life History and Contaminant Body Burdens

# Technical Issue Paper



# Salmon Life History and Contaminant Body Burdens

July 20, 2012

Toxics Cleanup Program

Washington State Department of Ecology

Olympia, WashingtonTechnical Issue Paper July 20, 2012 Page i 

# Table of Contents

Page

List of Figures and Tables..................................................................................................... .......... ii Figures........................................................................................................................ ............... ii

Tables ........................................................................................................................ ................ ii

Acronyms & Abbreviations ...................................................................................................... ..... iii

Introduction .................................................................................................................. ....................1

Analysis....................................................................................................................... .....................2

I. Salmon life history review ...................................................................................................2

A. Summary of life history info rmation in the draft TSD ..................................................2

B. Summary of additional li fe history informati on from TSD comments ..........................2

C. Enhanced summary of Puget Sound sa lmonid life history strategies ............................3

II. Salmonid body burdens......................................................................................................16

A. Summary of salmonid body burden information in the draft TSD ..............................17

B. Summary of salmonid body burden informa tion from the draft TSD comments ........17

C. Salmonid body burden accumulations by life stages, rates, and location ....................19

III. Can salmonid contaminant body burden be at tributed to a specific location? ..................31

Summary ....................................................................................................................... .................34

References .................................................................................................................... ..................36Page ii July 20, 2012 Technical Issue Paper 

# List of Figures and Tables

Figures

Page

Figure 1. Mean and SEM total PAHs detected in juvenile Chinook salmon tissue composites .................................................................................................................... 21

Figure 2. Mean concentrations of total PCBs (n g/g wet weight and ng/g lipid) in whole bodies of juvenile Chinook salmon from th e Lower Columbia River and Estuary ......24

Figure 3. Mean concentrations of total DDTs (ng/ g wet weight and ng/g lipid) in whole bodies of juvenile Chinook salmon from th e Lower Columbia River and Estuary ......24

Figure 4. Mean PCB concentration in Chinook salmon fillets ....................................................28

Figure 5. Mean PCB concentration in adult Chi nook salmon returning to Puget Sound (inrivers versus marine waters) .........................................................................................28

Figure 6. Concentration of PCBs, DDTs, and hexach lorobenzene in six herring populations from Puget Sound and the Strait of Georgia .................................................................31



## Tables

Page

Table 1. Estimated body burdens of persistent or ganic pollutants in returning adult

Chinook salmon and Chinook smolts ...........................................................................29Technical Issue Paper Ju ly 20, 2012 Page iii 

# Acronyms & Abbreviations

DDT dichlorodiphe nyltrichloroethane DEHP di-2-ethylhexyl phthalate DNA deoxyribonucleic acid DPE dialkyl phthalate ester Ecology Washington State Department of Ecology EDC endocrine disrupting chemical FAC fluorescent aromatic compound FCR fish consumption rate HCH hexachlorocyclohexane LDW Lower Duwamish Waterway PAH polycyclic aromatic hydrocarbon PBDE polybrominated diphenyl ether PBDE polybrominated diphenyl ether PBT persistent bioaccumulative toxics PCB polychlorinated biphenyl PCDD polychlorinated dibenzo- p -dioxin PCDF polychlorinat ed dibenzofuran PCN polychlorinated napthalene PFC perfluoroalkyl compound POP persistent organic pollutant PSAMP Puget Sound Assessment and Monitoring Program SaSI Salmonid Stock Inventory TEQ toxic equivalent tPAH total polycyclic aromatic hydrocarbon tPCB total polychlorinated biphenyl TSD Technical Support Document WDFW Washington Department of Fish and WildlifePage iv July 20, 2012 Technical Issue Paper This page purposely left blank for duplicate printing.Technical Issue Paper July 20, 2012 Page 1 

# Introduction

The Washington State Department of Ecology (E cology) received many and divergent comments about including or excluding salmon from the default fish consumption rate for Washington State fish-consuming populations. Consideratio n of salmon consumption depends on several different technical- and policy -related factors, including salm on life cycle, salmon chemical contaminant body burden, and Native American treaty reserved rights. New technical information and policy-related questions were pr ovided to Ecology to further evaluate issues related to the consumption of salmon.

This Technical Issue Paper integrates inform ation provided in the public review comments on the salmon life cycle and survival strategies with the information currently in the draft Fish Consumption Rates Technical Support Document (TSD). This integration and analysis considers, in part, where salmon contaminant body burdens are obtained in relation to the salmon life cycles and survival strategies. This Technical Issue Paper also exam ines factors that may affect decisions to include or exclude consumption of salmon in site-specific sediment risk management and cleanup decisions. It is a target ed examination of the issues raised by review comments received on the draft TSD, and was prepar ed within a limited time frame. Therefore, it may not include all available information on this subject.Page 2 July 20, 2012 Technical Issue Paper 

# Analysis

This section presents a review of salmon life history, a summary of literature on where and when salmonids obtain contaminant body burdens, and an assessment of the ad equacy of currently available information to support site-specific sa lmon consumption criteria or advisories. Each topic includes a brief summary of the informa tion presented in the draft TSD, followed by a summary of the public comments received on that topic. The analysis then provides further

reviews or information summ aries for additional clarity on each technical topic.



## I. Salmon life history review

The draft TSD, specifically Appendix E, provi des background information about the life cycle and survival strategies of those salmonids that both occur in Washingt on State waters and are consumed in quantity by its resi dents. Reviewers of the draft TSD provided very few comments with respect to new or missing life history information. Rather, comments largely focused on where and when body burdens are accumulate d in a given salmon’s life. Body burden

accumulation is discussed in the next section of this Technical Issue Paper. However, in an effort to provide additional species-specific information, a summary of available information comparing life histories is included here. While th is section is not an exha ustive literature review for Pacific Northwest salmonids, it is a suitable summary for salmonid li fe history comparison that provides a foundation for the follo wing section on salmonid body burdens.



### A. Summary of life history information in the draft TSD

Appendix E of the draft TSD provides background information about the life cycle and survival strategies for Chinook, coho, pink, sockeye, and chum salmon, as well as st eelhead and cutthroat trout (Ecology 2011). The draft TSD Appendix E tables provide a general overview of the

salmonids reviewed. Table E-1 of the draft TS D summarizes general rearing habitats and migrational behaviors, while Tables E-5 a nd E-6 provide summary information on seasonal occurrence, habitat use, and the range of life expectancy for each of the seven salmonids. Tables E-7 through E-10 provide creel data for freshwater and marine systems. Lastly, Tables E-11 through E-13 provide Salmonid Stock Inventor y (SaSI) summaries, including stock-specific status for salmonids occurring near the Port A ngeles Harbor and adjacent areas. SaSI is the Washington Department of Fish and Wildlife’s (WDFW) standardized, uniform approach to identifying and monitoring the status of Washington’s salmonid stocks.



### B. Summary of additional life history information from TSD

comments

Very little new information on the life history of salmonids was provided in comments received on the draft TSD. However, one reviewer (NCASI 2012) referred to Fresh et al. (2005) for a summary of juvenile salmonid life history strategies. Even though th is table provides a different display of available life hist ory information, it was technicall y consistent with the tables provided in Appendix E of the dr aft TSD. However, one of the important points noted in their comments was that Chinook salmon not only displa y more residency, but, as they mature,

Chinook salmon tend to eat more fish than other salmon. This point is relevant for the followingTechnical Issue Paper July 20, 2012 Page 3 sections of this document that discuss the re gional and species-specific differences between salmon in their uptake of toxins.

Additionally, a few other comments received (W eyerhaeuser 2012; Nippon Paper 2012) referred to their support of the 2003 AMEC paper titled Evaluation of the Fish Consumption Rate Selected by Oregon DEQ for the Devel opment of Ambient Water Quality Data . This paper, when referring to salmonid bioaccumulation in the Columbia River basin, stated that “most anadromous species spend only a small fraction of their lifetime in the Columbia River,” with the majority accumulated in marine habitats. While this is true for some species, or some “types” of species, this is an oversimplification due to the complex life history strate gies of salmonids. For a more-detailed description of sa lmonid life histories and general periods of occurrence, please refer to the following section titled Enhanced summary of Puget Sound salmonid life history strategies

.
Although the draft TSD was not intended to be a comprehensive review of the variable life history strategies of all Paci fic Northwest salmonids, by watershed, and the degrees by which these differences could play a role in body burden accumulation, these comments do indicate that some additional life history summary would be helpfu l in this process. In an effort to more fully describe these differences, a slightly more compre hensive review of these life history strategies is provided in the following sections.



### C. Enhanced summary of Pug et Sound salmonid life history strategies

This summary is not intended to be an exhaus tive literature review for Pacific Northwest salmonids, but rather a summary of relevant information to aid in the interpretation of contaminant body burdens and other issues discusse d in subsequent sections of this Technical Issue Paper. It is not intended to provide a comp rehensive review of habitat requirements, such as dissolved oxygen, stream depth/velocity, temper ature, or turbidity, and the potential effects these may have on salmonid life stages. Seven species of salmonids were br iefly reviewed in the draft TSD (Chinook, coho, sockeye, chum and pink salmon, and steelhead and cutthroat trout).

Due to their relative ab sence as a human food resource compar ed to the other salmonids, this Technical Issue Paper does not include a life hist ory review summary for cutthroat trout (similar to the previous exclusion of bull trout in the draft TSD).

Although each of the six species reviewed here are salmonids, their life history strategies can vary substantially. Table E-1 of the draft TSD indicates, for thes e six species, whether juveniles rear in rivers, estuaries, or la kes. It also indicates the genera l areas of migration: nearshore, continental shelf, or mid-oceanic. Table E-5 of the draft TSD provided additional life history detail for a variety of salmonid species, includi ng general life expectan cy. Additionally, Table E-6 provides a summary of the complex differences in habitat use for r earing and spawning life stages of the various Pacific Northwest salm onids. However, even with species-specific differences in their life histories, an aspect that each of these salmonids have in common is that they are anadromous. That is, they hatch from eggs in fresh water, mature in marine waters, then return to fresh water as adults to spawn. What follows is a more detailed species-specific summary than was provided in the draft TSD. Know ledge of where fish hatch, rear, migrate, and forage is important to understand how each of th ese species may differ in their accumulation of toxic body burdens.Page 4 July 20, 2012 Technical Issue Paper When information is too voluminous for inclusion, the reader will be referred to the source for further review. For example, in 2002 WDFW updated the SaSI report by cla ssifying the status of 489 Washington State salmonids and steelhead stoc ks (WDFW 2002). These SaSI status reports, along with other references, were briefly re viewed for general st ock-specific background information. For a detailed description of the data and summaries of these salmonid stocks, please see the WDFW SaSI web page ( http://wdfw.wa.gov/fish/sasi/ ).

Some of the life history questions that aros e during the draft TSD review process include seasonal occurrence, habitat use, distribution, foraging, and life expectancy. Relative to more resident species such as perc h and starry flounder, salmonids have large and highly variable distributions over their lifespan; occurrence and habitat use are a f unction of the needs of a given lifestage. However, even range and age at out-m igration can be highly variable within a given species (e.g., steelhead and coho ju veniles, and resident Chinook). Relative to fish species that are much longer lived such as English sole, sp iny dogfish, white sturgeo n, sablefish, yelloweye rockfish, and rougheye rockfish, estimated to live as long as 22, 75, 104, 114, 121, and 205 years, respectively (Love 1996; Berkeley et al. 2 004), salmonids have short life spans, generally living from 2 to 6 years. In addition, compared to other bony fish species, salmonids have very large eggs. This provides the de veloping embryos and al evins with sufficien t food resources to survive until they begin foraging as fry. However, egg size is highly vari able between salmonids. This difference is important as body burden of li pophilic toxins can be transferred from adult salmon to their young via the fatty content of the eggs. The species-specific life history information that follows is intended to supplem ent the information previously provided in the draft TSD. For an in-depth summary of Chinook salm on life histories, please refer to Myers et al. (1998), Healey (1991), and Qui nn (2005), among many others.

a. Chinook Salmon

Chinook salmon ( Oncorhynchus tshawytscha ) is the largest of the Oncorhynchus species, typically reaching 8 to 10 kg, although Chinook salmon have been documented in excess of 45 kg (Healey 1991; Quinn 2005). Resident Puget Sound Chinook salmon, however, are typically

on the smaller end of this scale. Chinook salmon occur throughout the nort heastern coast of the Pacific Ocean, and are considered one of the most sought afte r of the salmon species by commercial and tribal fishermen, spor t anglers, and human consumers.

Due to their relatively large size, Chinook salmon generally spawn in larger rivers or streams than other salmonids (Healey 1991; Quinn 2005). Chinook salmon can be highly variable between and within given watersheds. They have various in-migration (e.g., spring versus fall) and out-migration (e.g., ocean-type versus stream -type) times that can vary within a given system, stock, or run of fish (WDFW 2002; H ealey 1991; Myers et al . 1998; Duffy 2003, 2009; Duffy et al. 2005; Redman et al. 2005; Qui nn 2005). Spring Chinook typically produce streamtype juveniles, whereas fall Chinook typically produce ocean-type juveniles (Quinn 2005). In general, Chinook salmon adults re turn to their natal streams in spring and fall where they can hold for several months prior to spawning (W DFW 2002; Quinn 2005). With some exceptions, for Chinook populations in the state of Wash ington, ocean-type Chinook occur within Puget Sound and the lower Columbia River tributaries, while spring-type Chinook occur in tributaries further up the Columbia River (Myers et al. 1998).Technical Issue Paper July 20, 2012 Page 5 The life history habits of juvenile Chinook sa lmon vary widely, and a full understanding and

classification of these differences is still in progress (Redman et al. 2005). For this summary, a four strategy classification of behavior in em erging Chinook salmon is described here, with one strategy for stream-type, and thre e strategies for ocean-type.

Egg

Chinook salmon have the largest eggs compared to the other Pacific Northwest salmonids, ranging from 210 to 420 mg (Allen and Hassler 1986; Beacham and Murray 1993). The eggs of Puget Sound Chinook stocks are larger eggs of Chinook that occur in most other watersheds (Myers et al. 1998). Adult ocean-type Chinook salm on, which are generally larger in size than stream-type Chinook, also appear to produce larger eggs (Myers et al. 1998). As a result of the relatively larger eggs, Chinook fry are also rela tively large upon emergen ce, averaging 33 to 37 mm in length and ranging from 0.12 to 0.47 gram (H ealy 1991; Myers et al . 1998; Quinn 2005).

Fry

After emergence, stream-type Chinook spend a y ear or more in the river before migrating downstream (Healey 1991; Myer s et al. 1998; Duffy 2003, 2009; Duffy et al. 2005; Quinn 2005). Once entering the marine environment, stream-type Chinook spend very little time in the estuaries before migrating toward coastal wate rs (Duffy 2003, 2009; Duffy et al. 2005). Oceantype fry display a very different type of behavior. Myers et al. (1998) summarized literature documenting three distinct phases of ocean-type juveniles migrating to marine habitats. One phase, or strategy, is the immediate type that mi grates to the ocean soon after yolk resorption at 30 to 45 mm in length. During years of poor envi ronmental conditions, another behavioral phase may occur, with ocean-type juveniles remaini ng in fresh water for a year, although this is relatively uncommon. The most comm on behavior for ocean-type fry migrants is to migrate to marine habitats at 60 to 150 days post-hatching, or as fingerling migrants, migrating downstream in the late summer or autumn of their first ye ar. Emergent Chinook fry in freshwater habitats, like fry of other Pacific salmonids, depend on shaded nearshore habitat with slow-moving currents, where they forage on drift organism s, including insects and zooplankton (Healey 1991). In general, ocean-type parr (the freshwater stage of juvenile salmon, which usually occurs in the first one to two years of life) usually migrate to estuarine area s from April through July with some variability (peak out-migration occurring from May to early July), becoming smolts (juveniles that have transitioned from fresh wa ter to salt water) soon after entering marine waters. Duffy et al. (2005) found that wild ocean-type Chinook out-migrate to Puget Sound waters from March to July, while hatchery Chinook occupy nearshore Puget Sound waters soon after release and in pulses from May to June. Once reaching the marine environment, they then spend a few weeks or longer rearing in the estuary (Duffy 2003, 2009; Duffy et al. 2005).

Juvenile

Due to their longer residence time in freshwat er systems prior to out-migration, stream-type Chinook are much larger, averaging 73 to 134 mm, than ocean-type Chinook upon reaching the estuary (review in Myers et al. 1998). Entering the estu ary at a larger size allows spring-type juveniles to move offshore more quickly th an ocean-type juveniles (Healey 1991).

Growth rates of juvenile Chinook salmon are de pendent on the most abundant and available food resources. Ocean-type juveniles can grow at a fast er rate than stream-typ e individuals when foodPage 6 July 20, 2012 Technical Issue Paper is not limited (review in Myers et al. 1998). However, Duffy (2009) found that insects, a staple for stream-type juveniles, can provide a higher caloric content, and therefore promote faster growth than other food resources such as d ecapod larvae when food resources are equally abundant. Upon entering marine habitats, hatchery-p roduced smolts occur at a larger size than do their wild counterpart (Duffy 2009). Once reachi ng the marine waters of Puget Sound, juvenile ocean-type Chinook occupy nearshore habitats from April to June, before shifting to more offshore habitats from July to September (Du ffy 2009). Estuaries are extremely important for foraging and nearshore-migrating juvenile salmon (Simenstad et al. 1982; Simenstad and Cordell 2000). Further, juvenile salmonids do not limit thei r use of estuarine hab itats to their natal estuaries, as juvenile salmonids have also been found to enter and utilize non-natal estuaries during their marine nearshore migration (Shaffer et al. 2008). Duffy (2009) found that the size of ocean-type juveniles immediatel y prior to this offshore movement was strongly related to survival. By early fall, it was presumed that juvenile Chinook salmon in Puget Sound either migrate towards the Pacific Ocean or to deep er waters of Puget Sound (Duffy 2009). Coastal rearing populations of juvenile Chinook salmon are largely pisciv orous (fish eating), but also consume euphausiids, amphipods, copepods, pter opods, and cephalopods (Brodeur 1990).

Subadult

Once reaching the ocean, Chinook salmon are distributed in both coastal and offshore waters (Quinn 2005). In the ocean, ocean-type Chinook ar e distributed along coastal waters, whereas stream-type can be found offshore and throughout the central Pacific (Heal ey 1991; Myers et al. 1998). The diet of oceanic maturing Chinook consis ts mainly of squid, with fish, euphausiids, and pteropods also present (Brodeur 1990). Thos e salmonids that mature and occur within coastal waters have a diet primarily composed of fish, with euphausiids, decapod larvae, and cephalopods also present (Brodeur 1990). Salmonid s mature in oceanic and coastal waters from 1 to 6 years, although 2 to 4 year s is more typical, before retu rning to their natal streams to spawn (Myers et al. 1998).

Adult

Mature adult Chinook salmon can re turn to their natal streams months in advance of spawning; however, both spring-run and fall- run fish begin spawning in th e fall (Quinn 2005). Within much of the Puget Sound region, adult fall-run Chinook salmon start entering estuarine and riverine waters as early as August and begin spawning in their natal rivers and streams from midSeptember to November, but this can continue through January (Myers et al. 1998; Quinn 2005). Spring-run Chinook salmon enter Puget Sound and Columbia River waters in April and May, although spawning does not begin until August and September (Myers et al. 1998). Upon entering these freshwater systems, ocean-type adu lts are larger than spring-type adults. It has been postulated that this is in part due to th e additional 3 to 5 months longer that ocean-type adults remain in the marine environment prior to entering their natal streams (Myers et al. 1998; Duffy 2003, 2009; Duffy et al. 2005). It is likely that both of th ese factors play a role in the larger size of ocean-type adults.

Fat Content of Chinook

Fat content between salmonid stocks within a given system can vary substantially between years, seasons, sexes, and runs. Seasonal abundance of food in the ocean can alter size at entry as well as fat content upon entry. Within the Klamath River, Hearsey (2011) found that spring ChinookTechnical Issue Paper July 20, 2012 Page 7 salmon, entering rivers months in advance of spawning, had much higher overall fat content compared to fall-run Chinook. However, due to thei r long period of freshwat er residence prior to spawning, upon spawning, fall-run fish generally had a higher overall fat content. Hearsey (2011) found that male and female Chinook genera lly had the same fat content upon entry, but the females had a much lower fat content by the time spawning occurred. This is attributed to females using their fat reserves (muscle lipids and triacyglycerol de posits) during upstream migration and gonadal development of the eggs. Lipi d content is an important factor as lipophilic contaminants can occur at higher numbers in these fish. Then as the female converts this energy during gonadal development, the fatty eggs fr om females with higher body burdens receive

maternal transferred contaminants at elevated levels.

b. Coho Salmon

Like other salmonids in Wa shington State, coho salmon ( Oncorhynchus kisutch ) are hatcheryreared and released throughout the state. Although some of the cite d literature reviews hatcheryreleased fish, this life history summ ary is intended to focus primarily on natural spawning or wild fish behaviors.

Along the northeastern coast of the Pacific, coho salmon range from Monterey Bay, California, to Point Hope, Alaska, and the Aleutian Islands (Laufle et al. 1986). Coho salmon typically reach 3.5 to 4.5 kg (Sandercock 1991), although they have been documented to reach as many as 14 kg (Laufle et al. 1986). Sandercock (1991) found that adult coho returning to British Columbia waters ranged from 53 to 67 cm (21 to 26 in ches). For populations in and around Washington State, returning adult coho salmon are generally 3-year-olds, and spend approximately 18 months

in fresh water and 18 months in marine habi tats (Sandercock 1991). A small percentage of sexually mature males ( jacks ) return to fresh water to spawn after only 5 to 7 months in the ocean. Compared to Chinook salmon, coho tend to spawn in smaller stream s of modest gradient (Quinn 2005).

In general, coho salmon do not have the broad varia tion in life history habits that occurs in other salmonids such as Chinook and sockeye salmon a nd steelhead. With some variation, adult coho salmon generally return to their natal streams to spawn in fall (Laufle et al. 1986; Sandercock 1991; Quinn 2005). After emerging, the fry generally remain within freshwater streams for a year or two before migrating downstream. A more detailed summary of the life history characteristics of coho salmon is provided below. For a more detailed, in depth summary of coho salmon life histories, please refer to Laufle et al. (1986), Sandercock (1991), and Quinn (2005), among others.

Egg

For coho salmon populations, there is considerab le variation in egg size within and among populations (Fleming and Gross 1990). In gene ral, longer female body length within a population resulted in a larger egg produced. Al ong the Pacific coast, coho salmon have been shown to have a significant ne gative relationship between lati tude and egg size (Fleming and Gross 1990). In other words, all other factors equa l, coho salmon in California have larger, albeit fewer, eggs than those in Puget Sound, which are larger than those in systems further north. In general, coho salmon eggs within Washingt on State range from 160 to 295 mg, depending onPage 8 July 20, 2012 Technical Issue Paper location, and from 4.5 to 6.0 mm in diameter (Fleming and Gross 1990; Laufle et al. 1986; Quinn 2005).

Fry

Following hatching, coho alevin do not emerge fro m the gravel until 2 to 3 weeks after hatching (Laufle et al. 1986). Emergence has been detected from March to July (Laufle et al. 1986). Coho salmon fry are approximately 30 mm upon emerge nce (Quinn 2005). Alth ough some fry migrate to marine waters soon after emergence, the majority disperse both up- and downstream, remaining in streams to rear as juveniles fo r one to two years before migrating downstream (Laufle et al. 1986; Quinn 2005). Following emerge nce, coho fry begin feeding on a variety of insects, including dipterans, ephemopterans, a nd plecopterans (Laufle et al. 1986). Fry that are not displaced (washed out) by freshe ts grow larger, reside longer, and establish territories within their natal freshwater systems (Sandercock 1991). Over-wintering habita ts, particularly offchannel flood plain habitats, are critical for growth and survival of young coho salmon.

Juvenile

While residing in freshwater streams, the matu ring juvenile coho diet progressively includes larger prey items to sustain their growth. At this stage their diet begins to include crustaceans and fish, including co-occurring salmoni ds (i.e., pink and chum salmon) (Laufle et al. 1986). In fact, when co-occurring with other similar-sized juvenile salmonids, juvenile coho are more aggressive and outcompete other salmonids, including juvenile Chinook, for food resources (Laufle et al. 1986; Sandercock 1991). As a result, juvenile coho grow at a faster rate than cooccurring salmonids of other spec ies. Both age and size of juve nile coho salmon are believed to be triggers for downstream migration (Laufle et al. 1986). Within th is region, coho smolts typically leave fresh water and migrate to marine habitats to enter the smolting process in the spring (April to June) (Sandercock 1991). Once en tering marine waters, coho smolts spend little time rearing in estuaries, instea d migrating toward coastal waters (Quinn 2005). Juvenile, adult,

and subadult coho diets in marine waters tend to vary with fish size and coastal region occupied. Juvenile coho diets, while occurring in nears hore sublittoral habitats , primarily consist of decapod larvae, euphausiids, amphipods, polychaetes , and crustaceans (Fre sh et al. 1981, as summarized by Laufle et al. 1986; Quinn 2005; Sandercock 1991). Juvenile and subadult coho occurring further offshore generally consume decapod larvae, euphausiids, amphipods, and fish (principally herring) (Fresh et al. 1981, as summarized by Lauf le et al. 1986; Brodeur 1990).

Subadult

Although some coho salmon move to offshore waters , typically subadults continue to feed and

mature in these coastal wate rs of the northeast Pacific (Quinn 2005). An additional group appears to rear in the Strait of Georgia, and possibly Puget Sound (Laufle et al. 1986). For those coho that move offshore, this migration appears to begin in July and August (Laufle et al. 1986). Coho captured in oceanic waters tended to ha ve diets dominated by fish and squid, although euphausiids, amphipods, and pteropods were also present (Brodeur 1990). The majority of coho originating from Washington streams migrate to coastal waters off Oregon and Washington, with low numbers occurring in Oregon and British Colu mbia waters (Laufle et al. 1986). Very few Washington coho appear to migrat e to Alaskan coastal waters (L aufle et al. 1986). Both subadult and adult coho salmon usually occu r in the top 10 meters of ma rine water, except when these surface waters become too warm (Laufle et al. 1986).Technical Issue Paper July 20, 2012 Page 9 Adult

Young adult coho occurring offshore of the Columbia River are generally larg er than their Puget Sound conspecifics, which may be due in part to their preying almost exclusively on fish (i.e., anchovy, surf smelt, whitebait smelt, herring, and juvenile Chinook and rockfish), although diets of mature coastal coho can also include euphaus iids, crab larvae, amphipods, and squid (Laufle et al. 1986; Brodeur 1990). While some adult ma le coho salmon return after spending only one summer at sea, the majority of coho return after spending two, a nd sometimes three, summers at sea (Laufle et al. 1986; Quinn 2005). There are so me run timing differences between coastal and inland Washington stocks of coho salmon, but adults begin returning to es tuaries and outlets of their natal streams from July to September (Laufle et al. 1986). Except for earlier arriving jacks, sexually mature adults migrate up natal streams and rivers from August to November and spawn from November to December, and occasionally as late as February or March (Laufle et al. 1986; Sandercock 1991). In general, coho spawn in streams and small rivers that have relatively fast flow (Laufle et al. 1986; Sandercock 1991; Quinn 2005).

c. Sockeye Salmon

This section describes the general life hist ory of anadromous forms of sockeye salmon ( Oncorhynchus nerka ); it does not describe life history patterns of land-locked sockeye salmon,

known as kokanee. Mature adult sockeye salmon are small relativ e to other species in this region, reaching weights between 2 and 4 kg (4.4 and 8.8 lbs) (Quinn 2005). Along the coast of the northeast Pacific Ocean, sockeye salmon populat ions range from the Sacramento River in California to the Arctic (Burgner 1991). Within the state of Washington, a number of stocks exist including Lake Pleasant, Ozette Lake, Lake Washington, Baker Lake, and a few runs in the Columbia River drainage includ ing Lake Wenatchee. Sockeye salmon have one of the most diverse patterns of life history among Pacific No rthwest salmon species. For example, age at outmigration to marine systems fr om their natal streams not only varies between systems, and within systems, but can vary among related indivi duals. As a result, the summary presented here is considered a general overview of sockeye salmon life histories, not an all-inclusive review.

Sockeye salmon migrate from marine waters to natal freshwater systems in the summer months. Many times these systems include a nursery lake , in which juveniles rear and adults may hold prior to spawning. Adult sockeye salmon return to Lake Washington from June through August, with peaks from mid-June to mid-July (Newe ll 2005). When conditions are right, the adults migrate to suitable spawning habitat to dig a ne st (redd) and spawn. In some systems sockeye salmon spawning can occur on lake beaches, inlets or outlets of lakes, and in outwash fans of lake tributaries (Gustafson et al. 1997). For an in-depth summary of sockeye salmon life histories please refer to Pauley et al. (1989), Bur gner (1991), and Gustafson et al. (1997).

Egg

The number of eggs produced by a female sockey e salmon is relatively high (averaging 3,500), yet sockeye salmon produce some of the smallest eggs of the Pacific salmon (5.3 to 6.6 mm in diameter) (Pauley et al. 1989). As a result, wh en sockeye fry emerge, they are also small, averaging 26 to 29 mm (Quinn 2005). Lake Washington sockeye salmon eggs hatch approximately 51 to 124 days after fertiliza tion. Hendry et al. (1998) found that incubation duration is strongly linked to water temperatur es, with eggs incubating in warmer (12.5°C) waters hatching in less than half the time as those incubating in colder water (5°C).Page 10 July 20, 2012 Technical Issue Paper Fry

The hatched alevin then take an additional 24 to 60 days to emerge from the gravel as fry, with warmer temperatures reducing th e time for emergence. Sockeye salmon emerge as fry generally in April or May (Pauley et al. 1989), with some va riability associated with temperature. As might be expected, fry length and weight have been found to be positively correlated with egg weight (Hendry et al. 1998). While there is some variability with post -emergent behavior (Gustafson et al. 1997), after emergence, fry generally migrat e toward a lake that they will use as a nursery (and will migrate either upstream or downstream to reach a lake). However, some forms will

remain in the natal stream for a portion of their rearing. Regarding their entry into marine waters,

two types of sockeye salmon occur: the ocean-type (or sea-type ) that migrates to marine waters in the first year of their life, and the stream-type that may rear in rivers and lakes for a year or more before migrating to marine habitats (Gustafson et al. 1997).

Juvenile

Once entering a lake system, juvenile sockey e begin preying upon available zooplankton and insect larvae. Juvenile sockeye in Washington generally migrate from their nursery lakes to marine habitats in March and continuing thr ough June, with peak out-migration occurring in April and May (Appendix C-5 in Gustafson et al . 1997). Upon entering marine waters, estuarine use by juvenile sockeye salmon (smolts at this point) is limited, although some ocean-type sockeye may use these habitats before migrating toward coastal waters. Once entering salt water, juvenile sockeye salmon migrate no rthward to the Gulf of Alaska in coastal waters, but then by autumn move away from coasta l habitats and use offshore waters for growth to maturation (Gustafson et al. 1997). In offshore marine wate rs, sockeye juveniles tend to disperse and not form defined schools (Burgner 1980, as cited in Pauley et al. 1989).

Subadult

Sockeye spend 2 to 4 years at sea before retu rning to their natal sy stems to spawn (Burgner 1991; Quinn 2005). Sockeye have long gill rakers to allow foraging on a variety of plankton species while in the ocean. As there is some dietary overlap between sockeye and pink salmon while at sea, during even-numbered years, when pink salmon abundance is relatively low, maturing sockeye salmon that migrated to th e Bering Sea saw their diet of euphausiids, copepods, fish, and squid increase (Davis et al . 2005). For all years, and many regions, larger sockeye tended to have greater proportions of fi sh and squid in their di et (Brodeur 1990; Davis et al. 2005). For sockeye populations off the Oregon and Washington coasts, larval fishes (Osmeridae) and euphausiids can be dominant pr ey resources (Brodeur 1990). In other nearby regions, amphipods, copepods, and euphausiids were dominant (Brodeur 1990). As these fish reach maturity, they begin their return migrations from offshore and coastal waters towards the

estuaries and river mouths of their natal river, streams, and lakes.

Adult

Upstream migration of sockeye st ocks is highly variable depe nding on region and other factors, such as day length and water temperature (Burgn er 1991). Adult sockeye salmon return to Lake Washington from June through August, with peak s from mid-June to mid-July (Newell 2005); however, these fish delay spawning until fall. Upon returning to these systems, reproductively mature adults average between 2 and 4 kg (4.4 and 8.8 lbs) (Quinn 2005). However, asTechnical Issue Paper July 20, 2012 Page 11 reproductive sockeye that enter these systems exhibit little or no f eeding behavior, some reduction in size may occur prior to their upstream migration to sp awn in the fall. Within Lake Washington there are variations in sockeye salmon breeding beha vior. Some of the returning adults hold deep in the lake fo r up to six months before spawni ng in the Cedar River that flows into the south end of the lake (Newell 2005). Ot her smaller populations, those that spawn in

tributaries that flow into the north end of the la ke or on the lake’s beaches, spawn at different times (Newell 2005). This is believed to be a strategy for maximizing the survival of eggs, alevins, and fry as spawning tim ing is correlated with emergen ce timing, and therefore the best environmental conditions to optimize survival for the next generation (Brannon 1987, as cited in Newell 2005).

d. Chum Salmon

Chum salmon ( Oncorhynchus keta ) have the broadest distribu tion of all salmonid species (Pauley et al. 1988) and range along the Northeast Pacific coast from Monterey Bay, California, to the Arctic Ocean (Pauley et al. 1988; Salo 1991; Johnson et al. 1997). Similar to pink salmon, adult chum salmon prefer to spawn in the lower reaches of their natal streams (Pauley et al. 1988; Quinn 2005). Chum salmon produce larger e ggs than do the smaller sockeye and pink salmon (Beacham and Murray 1993; Quinn 2005). Similar to pink salmon or ocean-type Chinook, juvenile chum migrate from their fr eshwater redds to ma rine waters almost immediately after emergence (Pauley et al. 1988; Salo 1991; Johnson et al. 1997; Quinn 2005).

Chum salmon generally live 3 to 5 years and are relatively large compared to other salmonids, second only to Chinook; chum typically averag e 3.6 to 6.8 kg (8 to 15 lbs) (Salo 1991; Quinn 2005) and records indicate they can attain weights of up to 20.8 kg (46 lbs) (Johnson et al. 1997). Adult chum lengths typically av erage 53 to 79 cm (21 to 31inche s), although they have been reported to reach sizes in excess of 108 cm (42.5 in) (Johnson et al. 1997). What follows is a summary by lifestage for chum salmon, with a focus on those populati ons that occur in Washington State. For an in-depth summary of chum salmon life hi stories please refer to Pauley et al. (1988), Salo (1991), a nd Johnson et al. (1997).

Egg

Female chum salmon lay between 900 and 8,000 eggs (Pauley et al. 1988) that range in weight from 248 to 349 mg (Beacham and Murray 1993). Thes e eggs are extremely sensitive to changes in the environment, with a high degree of mortality (up to 90 pe rcent) in the developing eggs (Pauley et al. 1988). Depending on environmental c onditions, the eggs hatch to become alevins 50 to 130 days later. The alevins remain in the gravel another 30 to 50 days, until their yolk sac is absorbed (Pauley et al. 1988). Having depleted the energy stores in their yolk sacs, alevins emerge from the gravel as fry in the spring (Pauley et al. 1988).

Fry

Emerging fry are relatively large, ranging from 32 to 38 mm (Quinn 2005). While their time in freshwater is limited, these fry re ly on aquatic insects as their pr imary food resource after their yolk-sac is absorbed. Most chum salmon fry spe nd only a few days to a few weeks rearing in fresh water before migrating toward marine ha bitats from March to May (Pauley et al. 1988; Salo 1991; Johnson et al. 1997; Quinn 2005). A mu ch smaller number of fry may rear in freshwater streams but migrate to marine waters by the end of their first summer. Chum salmon utilize estuarine habitats for a few more weeks before migrating to coastal, then offshore waters.Page 12 July 20, 2012 Technical Issue Paper Once reaching marine habitats, chum salmon form dense schools as they rear in nearshore habitats (Pauley et al. 1988; Sa lo 1991). The Hood Canal shoreline is said to serve as a nursery and rearing habitat for a signifi cant portion of all chum salmon originating from Washington State rivers (Pauley et al. 1988). While in this environment, chum fry stay in very shallow,

nearshore habitats and consume a number of epibenthic invert ebrates, including gammaridean amphipods, harpacticoid copepods, cumaceans, and mysids (Pauley et al. 1988). This environment not only provides them with a readily available food resource, but also protects them from larger predators such as cutthroat tr out. Most chum fry ente r estuaries by June and leave them by mid to late summer.

Juvenile

By the time chum fry leave estuaries and begi n moving to coastal waters, size becomes a key

factor for their survival. Chum salmon that enter these waters when they are less than 55 mm are less likely to survive than larger juveniles (Pauley et al. 1988). For those fish that remain in estuaries through the summer, more typical sizes are 150 to 225 mm (Pauley et al. 1988). At this size juvenile chum generally begin to move to offshore neritic habitats, feeding on euphausiids, calanoid copepods, hyperiid amphipods, larvaceans , and fish larvae (Simenstad and Kinney 1978). A number of age 2 chum salmon do occur w ithin Puget Sound waters (Pauley et al. 1988), although the absence of age 3 chum suggests that all chum salmon spend time rearing in the Pacific Ocean (Pauley et al. 1988).

Subadult

Once reaching coastal waters, the juvenile chum disperse and ar e widely distributed. Dietary studies of chum salmon along the British Columb ia coast vary, with dominant food items of younger, maturing chum salmon including amphi pods, euphausiids, pteropods, and fishes (Brodeur 1990). As chum grow larger and mature, th eir diet shifts to larg er prey items, including amphipods, euphausiids, and crustac eans, but also an increase in squid and fishes (Brodeur 1990). In general, chum salmon originating from Washington streams and ri vers, and rearing in the open ocean, do not return as mature adul ts until age 3 or 4 (Pauley et al. 1988).

Adult

Chum salmon can be reproductively mature as 3, 4, or 5-year-old fish (P auley et al. 1988). In some systems, chum salmon are the last of th e salmon to migrate upstr eam to spawn (Pauley et al. 1988). While most systems support only a summer and fall run of returning adult chum, Puget Sound rivers produce early (mid-August – October), normal (November – December), and

late (January – March) runs (Pau ley et al. 1988). In systems su ch as Hood Canal, chum salmon migration and spawning times are separated by up to a month, resulting in summer-run fish (spawning in early September to mid-October) a nd fall-run fish (spawning in early November to late December) (Johnson et al. 1997). Even thoug h data are limited, coastal runs of chum salmon occur in October and November, with spawning ta king place as late as December (Johnson et al. 1997).

As with other salmonids, adult chum may mill at a river’s mouth, or estuary, for a period before initiating their upstream migration (Johnson et al. 1997). Once beginning their upstream migration, adult chum no longer continue to feed (Pauley et al. 1988). Chum salmon survival is limited once they enter fresh water. Studies have indicated that, once ente ring fresh water, adultTechnical Issue Paper July 20, 2012 Page 13 chum may die within 11 days but may survive as long as a month (Paule y et al. 1988). Although chum salmon in Washington State generally spawn in the lower portions of ri vers and streams, in some systems, such as the Skagit River, chum salmon migrate 170 km or more (Hendrick 1996, as cited in Johnson et al. 1997). After the female digs out a redd, and lays somewhere between 900 and 8,000 eggs that are immediately fertilized by a male, the pair defends the redd(s) until eventually dying in the following days.

e. Pink Salmon

Pink salmon ( Oncorhynchus gorbuscha ) are the most abundant sa lmon along the coast of the

northeast Pacific Ocean and are al so the smallest at maturity (Bonar et al. 1989; Heard 1991; Quinn 2005). Mature adult pink salmon are approx imately 1.0 to 2.8 kg (2.2 to 6.2 lbs) when they return to their natal streams to spawn (Bonar et al. 1989; Heard 1991; Quinn 2005). Pink salmon only live for 2 years, with very little vari ability. In systems south of the Fraser River, most pink salmon adults return to their nata l streams in odd years (B onar et al. 1989; WDFW 2002; Quinn 2005). Twelve of the thirteen pi nk salmon populations in Washington spawn only in odd years, with an additional even-year popula tion occurring in the Snohomish River (Hard et al. 1996). Pink salmon are more abundant in the northern river systems (e.g., Nooksack, Skagit, Stillaguamish, and Snohomish Rivers) than in southern river systems (e.g., Puyallup and Nisqually Rivers) (Hard et al . 1996). Though less abundant, popul ations also occur in Hood Canal (e.g., Hamma Hamma, Duckabush, and Dosewallip s Rivers) and the Strait of Juan de Fuca systems (e.g., upper Dungeness, lower Dungeness , and Elwha Rivers) (Hard et al. 1996).

As pink salmon adults spawn near river mouths , and fry migrate downstream immediately after emergence, this salmon species spends the least amount of time in fresh water (Bonar et al. 1989; Heard 1991). Although some smaller coastal and Colu mbia River runs occur, within Washington State two of the rivers supporti ng the largest pink salmon runs are the Snohomish and Puyallup. These two rivers support commercial netting and s port fishing, activities that occur in marine, estuarine, and freshwater portions of the respective systems.

Within four to six weeks of en tering estuaries, the adults go th rough a transformation, with the males developing a large hump on their backs, enlarged heads, and the development of large teeth (Bonar et al. 1989; H eard 1991). The hump in male pink salmon is so pronounced compared to other salmonids it has re sulted in the species being nicknamed humpies . Following spawning, the vast numbers of spawned out pink salmon begin to die off, with dead and dying adult pink salmon littering the banks and shallows . A variety of predators and scavengers (e.g., eagles, bears, and gulls) utili ze this readily availa ble food resource (Heard 1991). The remaining carcasses decay, with their bodies providing nutrients in the nearby downstream vicinity of their spawning grounds. A summary description of the lif e history characteristics of pink salmon is provided below. For an in-depth summary of pi nk salmon life histories please refer to Bonar et al. (1989), Heard (1991), and Quinn 2005)

.

Egg

The eggs produced by pink salmon are smaller (a bout 6 mm in diameter) than other larger salmonid species (Bonar et al. 1989; Quinn 2005). Depending on the region and in-stream temperatures, fertilized pink eggs can take from five to eight months before fry emerge and migrate downstream (Heard 1991). Accounting for so me variability between years and systems,Page 14 July 20, 2012 Technical Issue Paper pink salmon eggs laid in August to October ge nerally hatch between late January and early March (Hard et al. 1996). Newly ha tched alevin remain in the gr avel for a few weeks utilizing their yolk sac. These alevin can average 21.3 mm in length.

Fry

With some variability, pink salmon fry emerge fr om the gravel primarily in March and April (Hard et al. 1996). Once the yolk sa c is depleted, the alevins emerge as fry some 41 to 64 days (average 52 days) post-hatching. These newly emer ged fish range from 29 to 33 mm long with an average length 31.5 mm (Heard 1991; Quinn 2005). There is very little or no freshwater rearing as pink salmon fry migrate seaward upon emergence from the gravel, and so their downstream migration also occurs in Marc h and April (Hard et al. 1996). Pink salmon originating from Puget Sound and Hood Canal stream s and rivers appear to use nearshore areas extensively for early rearing duri ng their first few weeks of entry into marine habitats (Jewell 1966, as cited in Hard et al. 1996) . While little is known about th eir behavior as the fry are exiting Puget Sound proper, Hiss (1994, as cited in Hard et al. 1996) found th at fry occurrence in Dungeness Bay (near Sequim) peaked in April and they were gone by late May. These fish ranged in length from 35 to 75 mm. Findings su ggest that most out-migrating pink salmon enter the open ocean by late summer or early fall (Hard et al. 1996). However, like some Chinook and coho, a small portion of the pink salmon population appears to adopt residency in Puget Sound for the marine phase of the life cycle (Hard et al. 1996).

Juvenile/Subadult

Pink salmon fry migrate so rapidly to the sea, and so little is known about the juvenile and subadult behavior at sea, that for pink salmon th e juvenile and subadult lif e history categories are combined. Once reaching estuarine and marine ha bitats, pink salmon migrate toward the open ocean within the first couple of months. By Se ptember the majority of pink salmon migrate hundreds of miles out in the open sea to grow and mature (Hartt and Dell 1986, as cited in Hard et al. 1996; Bonar et al. 1989; Heard 1991). Stomach contents of ocean-caught pink salmon were found to include fish, amphipods, euphausiids, pteropods, salps, squid, crustacean larvae, chaetognaths, and polychaetes (Bona r et al. 1989; Brodeur 1990; P earcy et al. 1984). They spend approximately eighteen months rearing in the open ocean before their eastward migration to their natal streams and rivers (B onar et al. 1989; Heard 1991).

Adult

Adult pink salmon begin migrating toward the rive r mouth of their natal stream from June to September, with peaks in some systems, such as the Snohomish, in the month of August (Heard 1991; Hard et al. 1996). Most pink salmon retu rning to Washington rivers and streams are believed to travel east through the Strait of Ju an de Fuca, with some additional use of the Johnstone Strait/Strait of Georgi a corridor (Hard et al. 1996). On ce reaching their natal streams, adult pink salmon, in general, do not migrate fa r upstream, preferring to spawn within a few miles of the estuary. However, in the Snohomish River pink salmon spawn as far upstream as the Sultan River (approximately 23 miles), in the P uyallup River primarily above 12.5 river miles, and in the Nisqually River main stem between river mile 22 and 40 (Hard et al. 1996). In Washington and southern British Columbia, spawni ng generally occurs from August to October (Hard et al. 1996). Adult pink salm on spawn in dense numbers near riffles with clean gravel, anTechnical Issue Paper July 20, 2012 Page 15 activity that takes from one to eight days (Heard 1991). After sp awning the adults aggressively defend their respective redds until they eventually die, 11 to 21 days later (Heard 1991).

f. Steelhead

Steelhead ( Oncorhynchus mykiss ) range from central California to the Bering Sea and Bristol Bay, Alaska (Pauley et al. 1986). This species can occur as both anadromous (steelhead) and resident (rainbow trout) fish (P auley et al. 1986). This brief life history summary focuses on naturally spawning, or wild , steelhead populations, and not the re sident rainbow tr out or hatchery produced stock of either form. A significant di fference between steelhead and salmon is that steelhead, in fresh water, can maintain a life hist ory as rainbow trout, and steelhead can be repeat spawners. Adult spawners of e ither steelhead or rainbow trou t can produce either, or both, freshwater or anadromous juveniles (Qui nn 2005). The discussion below focuses on the anadromous, or steelhead, form of the species.

Comparing the size of an average steelhead to a given salmon species needs to take into account the age of a given steelhead. Un like some of the larger salm onids that die after spawning, steelhead can return to spawn in multiple years. As a result, stee lhead can spawn up to four times and have been documented to live as long as 8 or 9 years (Pauley et al. 1986). Because steelhead grow larger in the productive marine environment, fish that stay in these habitats longer are typically larger. Studies investig ating this have found that steelh ead range in size from 47 cm (18.5 inches) for a 1-year saltwater resident to 88 cm (34.6 inches) for a 4-year saltwater resident (Maher and Larkin 1954, as cited in Pauley et al. 1986). Steelhead ar e prevalent throughout streams and tributaries of the Puget Sound and Colu mbia River (Pauley et al. 1986). Both winter and summer steelhead types, or races, occur w ithin Washington State streams and rivers.

Typically adult steelhead return to streams and rivers in the wint er or summer and spawn in the spring and summer, with fry emergi ng in just a few weeks. Upon emergence, steelhead typically

rear in the freshwater streams and rivers betw een 1 and 3 years. Following their downstream migration to marine waters, these fish rear a nd mature in the ocean for 1 to 3 years before returning to freshwater systems as adults to spawn (Pauley et al. 1989; Quinn 2005). Because steelhead can be repeat spawners, the age and si ze of returning adults varies considerably. A summary description of the life history characteris tics of steelhead is provided below. For an indepth summary of steelhead life hi stories please refer to Pauley et al. (1986) and Quinn (2005).

Egg

Steelhead eggs are typically smaller than salmon eggs, with size varying based on maternal size and body condition. Though timing for egg laying and hatching varies between river systems and temperature conditions, eggs of both summer- and wi nter-run fish begin to hatch from April to June, 4 to 7 weeks following adult spawning. Alev ins emerge soon after, rapidly absorb their yolk, and are free swimming within 3 to 7 days (Pauley et al. 1986). These newly emerged fish are active foragers on microscopi c organisms, moving toward insects and larger prey items as they grow.

Fry

By the summer of their first year, steelhead fry are consuming bottom-dwelling aquatic and terrestrial insects (Pau ley et al. 1986). As they continue to grow, young steelhead fry becomePage 16 July 20, 2012 Technical Issue Paper parr. Steelhead parr can remain in fresh water fr om 1 to 4 years, although 2 to 3 years is more common. Steelhead parr actively forage from spri ng to fall but become relatively inactive during winter months (Bustard and Narv er 1975, as cited in Pauley et al . 1986). It is at the parr stage that steelhead begin their downstream migration toward marine habitats.

Juvenile

Juvenile steelhead migrate downstream typically in spring (although this can be from January to July) of their second, third, or fourth years in fre shwater habitats, finally entering marine waters and becoming smolts. Size at smoltification in steel head has been correlated with survival. Small steelhead entering marine habitats do not surv ive long. Ideally a steelhead smolt should be at least 14 to 16 cm (5.5 to 6.3 inches) to survive this critical period (P auley et al. 1986). Once entering estuaries, juveniles migrate toward co astal waters for a short period before moving offshore and into the open ocean. While in the oc ean, juvenile steelhead diet shifts again and includes amphipods, euphausiids, a variety of fis h, and squid (Pauley et al. 1986; Brodeur 1990).

Subadult

While in the ocean, subadult steelhead grow rapidly. However, upon entering the ocean, instead of forming schools they disperse widely. As a result, little is known about their distribution in marine habitats, other than distribution confor ming between the 5°C isotherm to the north and the 15°C isotherm to the south (Pauley et al. 1986 ). Subadult steelhead diet while in the ocean appears to vary between regions, which may be a factor of available food resources. For those fish that occur off Oregon and Washington, cephal opods represent nearly 80 percent of the diet with fish representing only 10 percent (Brodeur 1990). Similar aged steel head in the Gulf of

Alaska had diets that consisted of 63 percent fish and 31 perc ent squid (Brodeur 1990). Although Columbia River summer-run steelhead generally only spend one summer in the ocean, other stocks, including winter-run, spend up to 4 year s in the ocean, although 2 to 3 years is more common (Pauley et al. 1986).

Adult

Stream-maturing (summer) adult steelhead typica lly enter rivers from August to September, remain in the river through fa ll and winter, then spawn the fo llowing spring (Pauley et al. 1986; Quinn 2005). Ocean-maturing (winter) steelhead in Washington return during March to April and may spawn within a month of entering fresh water (Pauley et al. 1986; Busby et al. 1996, as cited in Quinn 2005). Returning adu lt steelhead rarely eat and grow little if at all once entering fresh water to spawn (Maher and Larking 1954, as cited in Pauley et al. 1986). Unlike salmon, steelhead do not die after spaw ning and can spawn up to four times, although two to three is more common (Pauley et al. 1986). As a result, post-spawn adult steelhead migrate back toward

marine habitats within a relativel y short period of time after spawning.



## II. Salmonid body burdens

Over the course of a given salmonid lifespan, thes e fish occupy a variety of habitats that meet specific needs for each lifestage. As they grow fr om one lifestage to the next, and move from one habitat type to the next, their growth is ba sed on the available food resources (Healey 1991, Quinn 2005; Duffy 2009). During each period of growth, each lifestage has the potential toTechnical Issue Paper July 20, 2012 Page 17 accumulate environmental toxins. This section re views and summarizes the information provided in the draft TSD, and the comments received on the draft TSD. Finally, this section includes a summary review of salmonid body burden accumulation. This review refers back to the life history summaries described above in an effort to determine whether it may be appropriate to attribute body burden accumula tion to specific sites.



### A. Summary of salmonid body bu rden information in the draft TSD

The draft TSD was written to address human c onsumption of fish and not the biology of Washington State salmonids. However, some e xplanation of salmonid lif e history and general region of body burden accumulation is warrant ed. Appendix E of the draft TSD, titled The Question of Salmon , summarized the life cycle and survival strategies of selected Washington

State salmonids.

Appendix E acknowledges that, by the year 2000, an estimated 58 percent of all salmon

consumed worldwide was farmed salmon. Howe ver, the draft TSD indicated people of Washington State not only consume more salmon than other populations, but much of this salmon comes directly from wild-caught resource s in the Pacific Northwest region. As a result, accumulation of body burden by non-farmed salmonids in Washington State is relevant when evaluating human health risks associated with consumption of the resource.

The Appendix E section titled Salmonid Contaminant Body Burden summarizes the role that salmonids play in the distribution of bioaccu mulative pollutants. Appendix E acknowledges that “Pacific salmon exposure to PBTs, and PCBs in part icular are, in part, contingent on migratory patterns, residency time in Puget Sound, proximity of the salmon to contaminated sediments, waste sites, and different behavior and dietary patte rns as the fish mature.” Included in this summary is the finding of O’Neill et al. (1998) “...that chinook and coho salmon accumulate most of their PCB body-burden in the marine wa ters of Puget Sound and the ocean, and because chinook salmon live longer and stay at sea longe r than coho salmon they accumulate higher PCB

concentrations in their muscle ti ssues.” Further, more than 98 pe rcent of the final body weight of most salmon is attained at sea. Appendix E ci tes the finding of O’Neill et al. (2006) that coastal migrants (coho and ocean-type Chinook) have greater body burdens than do more oceanic migrants (chum, pink, and sockeye). Further, this study found that resi dent Chinook, which tend to be ocean-type, fall-run fish, were found to have 2 to 6 times the amount of polychlorinated biphenyls (PCBs) as non-residents, and 5 to 17 ti mes the polybrominated diphenyl ether (PBDE) burden. A final point made in Appendix E with re spect to regional variations in accumulation is

that tributaries in the far southe rn reaches of Puget Sound lengthen the time that these fish occur in the Sound. This is due to greater distances from natal streams to the ocean for both outmigrants and in-migrants.



### B. Summary of salmonid body bu rden information from the draft
TSD comments

Public review comments on the draft TSD represen ted a wide range of positions with respect to where and when in a salmon’s life cycle it accu mulates significant portions of its toxic body burden, and how this information should be incor porated into the draft TSD. These comments

are summarized below.Page 18 July 20, 2012 Technical Issue Paper One reviewer (Yakama 2012) noted that salmon ha ve been shown to acquire contaminants in waters that are under Washington State jurisdicti on. They pointed out that accumulations occur

within fresh waters of the Columbia River for juveniles during their out-migration (LCREP 2007) and in estuarine and inland marine wate rs of Washington (O’Neill 2011, as cited in Yakama 2012).

Another reviewer (Exponent 2012) pointed out the draft TSD Appendix E appeared to support the conclusion that, for most salmon, body burde n of bioaccumulative chemicals (e.g., PCBs, toxins, mercury) derives mostly from ma rine waters. They noted that “Washington waters/sediments may contribute to body burde n depending on the species, run, chemical, life cycle characteristics, and range of environmental physical charact eristics,” and concluded that “variability, dominated by a l ack of significant contribution, ar gues for evaluating the situation on a site-specific basis with the excl usion of salmon being the default.”

A few comments received on the draft TSD (W eyerhaeuser 2012; Nippon Paper 2012) referred to their support of the 2003 AMEC paper titled Evaluation of the Fish Consumption Rate Selected by Oregon DEQ for the Devel opment of Ambient Water Quality Data and this paper’s

relevance to the reviewed draft TSD. One of the points made by the AMEC (2003) document with respect to freshwater and estuarine occurrin g fish was that “If there is a permitted discharge to a freshwater body, the consumption of estuarine fi sh and shellfish is like ly to be irrelevant. Similarly, if there is a discharge to an estuarine area, the freshwater fish upstream will likely not

be affected. Thus the inclusion of rates of cons umption of freshwater an d estuarine finfish and shellfish is a very conservative assumption fo r these specific applications” (page 5).

The AMEC (2003) paper called in to question the inclusion of anadromous fish, which are consumed by Columbia River Tribal members at rates of three times higher than resident fish species, according to the CRITF C (1994) fish consumption su rvey. They noted that many juvenile Chinook salmon in the Columbia River spend several months in the system before migrating to a marine feeding area, and that when they return as adults after 2 to 6 years, they generally do not feed during their upstream spawning migratio n, and therefore do not reach equilibrium with the surrounding environment. In other words, though potentially occurring within a discharge area, migratory fish species such as Chinook salmon do not occur in any sitespecific region for a sufficient length of time to achieve equi librium with regulated compound

concentrations in the associated water column.

One reviewer (NCASI 2012) provided extensive co mments, citing many of the same references that were cited in the draft TSD. They point out that different species a nd different runs of the same salmon species have very different life hi story strategies and will accumulate body burdens to differing degrees. They state th at literature supports the pos ition that the major fraction of persistent bioaccumulative toxic (PBT) burden ca rried by adult salmon originates from the open

ocean. Their comments noted that resident P uget Sound Chinook, with higher body burdens, are an exception as they do not utilize open ocean ha bitats. Due to this difference, they noted that “...it might be appropriate to asse ss risk to select Puget Sound re sidents as a separate activity, and inclusion of salmon in an FCR [fish consump tion rate] used in such a risk assessment may well be warranted.” However, due to the large differences in life history, the reviewer felt that it is inappropriate to lump all species together as salmon , and should instead apportion numbers between salmon species. Their conclusion was th at, based on the information provided above,Technical Issue Paper July 20, 2012 Page 19 the consumption of salmon should be excluded fro m any state-wide default fish consumption

rate.



### C. Salmonid body burden accumul ations by life stages, rates, and

location

This section includes a summary of the detailed techni cal literature review comments provided by one specific reviewer, and an additional lite rature review concerning salmonid body burden accumulation conducted during preparation of this Technica l Issue Paper.

a. NCASI review comments (Should salmonid body burden be included as part of the fish consumption rate?)

A key question asked by a number of reviewer s of the draft TSD was whether salmonid body burden accumulation is sufficiently understood to be included as part of the default fish consumption rate. One reviewer in particul ar, NCASI (2012), provided a summary of their

literature review on where salmonids accumulate PB T chemicals. A summary of their review is included here, as well as an expanded review of additional literature, to further understand what the current knowledge is for th e rate of uptake, locations where uptake occurs, and those salmonid species and life stages for whic h this information is available.

The NCASI (2012) comments include a table taken from Fresh et al. (2005), that compared the life history variations for six Washington State salmonid species (NCASI [2012] cited the Fresh paper as NOAA 2005). NCASI (2012) comments stated that... “These differences are potentially significant in that they may lead to differe nces in the mass (burden) of the chemical contaminants (e.g., PBT chemicals) ultimately accum ulated by the salmon, and in the fraction of

this ultimate burden accumulated in freshwater vs. saltwater.” Section I.C of this Technical Issue Paper was prepared to provide an even great er understanding of wh at those life history differences are, where these six salmonid species occur at given stages of their life, and the principal food items consumed during each life stage. This Technical Issue Paper is not an exhaustive summary, but one th at allows for comparison on an appropriate scale.

NCASI (2012) stated that, taken to the extreme, the life history differences of these salmonids imply that each run of each salmonid should be evaluated independently to determine where contaminants are accumulated. They further stated that this comparison ma y not be necessary, as the work of O’Neill et al. (1998), West and O’Neill (2007), and O’Neill and West (2009) indicated that the open ocean is the dominant pathway for PBT chemical uptake by salmonids. The NCASI review provided addition al references that are included to show that the majority of

contaminant burden in anadromous fish occurs in marine systems and not freshwater systems. A final, albeit very notable, distinction made in their review was the finding by O’Neill et al. (1998) that indicated a greater uptake of PBTs in Chinook, in both Puget Sound proper and its tributaries, relative to other salm onids. Findings such as this are like ly attributable to two factors: (1) resident Puget Sound Chinook ar e generally ocean-type (rearing in marine waters rather than extensive periods in fresh wate r), and (2) they eat more fis h, including contaminated herring stocks, as a part of their food resource than other salmonids.Page 20 July 20, 2012 Technical Issue Paper b. Summary of investigations concerning salmonid body burden accumulation

There is growing evidence in the literature that Puget Sound fish, including salmonids, are experiencing biological effects at tributable to contaminant expos ure (McCain et al. 1990; Stein et al. 1995; Landahl et al. 1997; O’Neill et al. 1998; West and O’Neill 2007; O’Neill and West 2009; Hope 2012). Although there is evidence that adult salm on returning to spawn in Washington waters have elevated body burdens of these contaminants, the origin of these contaminants is of central importance for resour ce management and risk reduction. What follows is a summary of selected papers that inve stigated body burden accumulation in salmonids.

Juvenile accumulation

In situ biomonitoring of caged, juvenile Chinook salmon ( Oncorhynchus tshawytscha ) in the Lower Duwamish Waterway (Kelley et al. 2011):

Kelley et al. (2011) conducted a series of 8 to 10 days in situ caged fish exposure studies in the Lower Duwamish Waterway (LDW) each July, over a 4-year period (2004–2007). Juvenile ocean-type Chinook salmon ( Oncorhynchus tshawytscha ) were obtained as eggs or fry from the University of Washington hatche ry and reared at the NOAA Fisheries marine lab in Mukilteo, WA. They were raised in fres hwater and acclimated to seawater in June of each year. The exposure period was chosen to be well below previous studies, indicating that residence time in these waters for naturally occurring juvenile Chinook tends to be much greater (ranging from 1 week to 2 months). Among other investigativ e methods, they used fluorescent aromatic compounds (F ACs) in Chinook salmon bile to evaluate the relationship between contaminated sediment and ecological r eceptors for fish caged in the LDW. At each caged fish location they collected sediment and water sample data.

Their findings indicated that biomarkers am ong field-exposed Chinook were greater than

those in control sites. In f act, deoxyribonucleic acid (DNA) a dduct analysis indicated there were significant differences between the test su bjects and the controls, with the exception of 2007 data, a period when in-water contaminant le vels were at their lo west. Further, tissue body burden of yearly mean and the standard error of mean (SEM) polycyclic aromatic hydrocarbon (tPAHs) were signif icantly different during the 2 005 study period when some of the highest tPAHs were detected in water sa mples (Figure 1), which happened to coincide with the only time total PCBs (tPCBs) were detected in water samp les. The findings of Kelley et al. (2011) indicated that juvenile Chin ook, occurring for a rela tively short period of

time in a contaminated estuarine environmen t, can experience elevated contaminant body burden. Similar conclusions were reported by other authors, indicating that contaminant accumulation by salmonids can occur within fres hwater and estuarine systems (Giesy 1999; Meador et al. 2002; Hardy and McBride 2004; Se thajintanin et al. 2004; Fresh et al. 2005; Johnson et al. 2007; Yanagida 2012).Technical Issue Paper July 20, 2012 Page 21 Figure 1. Mean and SEM total PAHs detected in

juvenile Chinook salmon tissue composites

Source: Kelly et al. 2011 Studies of uptake, elimination, and late effects in Atlantic Salmon ( Salmo salar ) dietary exposed to di-2-ethylhexyl phthalate (DEHP) during early life (Nor man et al. 2007):

Norman et al. (2007) investigated the uptake, elimination, and late effects in Atlantic salmon of hatchery origin where juveniles were exposed to orally administered, and food contaminated with, di-2-ethylhexyl phthalat e (DEHP). They found diet was the major route for uptake of lipophilic compounds. In addition, they found that for this compound and its metabolite, salmon were able to excrete the compounds, with body burden concentr ations approaching background within one week of exposure. The expos ure levels in this study demonstrated that dietary exposure to DEHP could temporaril y increase body burden, but if no longer exposed

can excrete DEHP to levels more consistent with background, and have no latent effects on growth or survival to adulthood. However, they did find that repeated exposure to very high

doses that did not allow the fish to retu rn to background levels could alter gonadal development in males.

In situ biomonitoring of juvenile Chinook salmon ( Oncorhynchus tshawytscha ) using biomarkers of chemical exposures and effect s in a partially remediated ur banized waterway of the Puget Sound, WA (Browne et al. 2010):

Browne et al. (2010) investigated the contamin ant effects of Duwamish Waterway PAHs and PCBs on caged juvenile Chinook salmon using in situ biomonitoring and molecular biomarker analysis. In July 2007, approximately 20 pre-sm olt Chinook were placed in four cages for eight days at adjacent sites in the Duwamish. Bo th subject and control fish were of hatchery origin. Hatchery-maintained control reference Chinook were not fed because juvenile fish caged in the Duwamish system have limited acces s to prey in the water column and do not feed. Biomarkers were compared to control cages of fish at an upstream hatchery. Prior toPage 22 July 20, 2012 Technical Issue Paper cage placement, sediment samples were collected and analyzed at the selected cage locations. High concentrations of total PAHs in sediments were detected at one site, whereas two other sites had relatively low concentrations. Waterbor ne PAHs at all of the sampling sites were relatively low (<1 ng/L). Sedime nt PCBs at the sites ranged from a low of 421 ng/g to 1,160 ng/g, and there were no detectable waterborne PCBs at any of the sites (detection limit = 10 ng/L).

Browne et al. (2010) found no significant differe nces (<0.05) in biomarker gene expression in the Duwamish-caged fish relative to c ontrols, although there wa s a pattern of gene expression suppression at the most heavily P AH-enriched site. The lack of a marked perturbation of mRNA biomarkers was consiste nt with relatively low levels of gill PAHDNA adduct levels that did not differ among caged reference and field fish. Browne et al. (2010) found that there was low bioavailability of sediment pollutants for experimentally caged juvenile Chinook. Their conclusion was th at these findings were potentially reflecting low waterborne exposures occurring at contam inated sites within the Duwamish waterway that have undergone partial remediation.

However, a limitation of the Browne et al. ( 2010) study may be duration of exposure. As the majority of Chinook populations in Puget Sound ar e ocean-type, fall-run fish, they generally enter estuaries at a smaller size and stay fo r a longer period than would spring type Chinook. A critical reviewer of this paper may propos e an exposure period more consistent with naturally occurring pre-smolt Chinook to dete rmine if the findings of no significant

difference of PAHs and PCBs would stand.

Contaminant exposure in outmigrant juvenile sa lmon from Pacific Northwest estuaries of the United States (Johnson et al. 2007a):

Johnson et al. (2007a) investigated c ontaminant uptake in out-migrant juvenile salmon in the Pacific Northwest, including concentrations of PCBs, DDTs, PAHs and organochlorine pesticides in tissues and prey of juvenile Chinook and coho salmon fr om selected estuaries

and hatcheries in the U.S. Pacific Northw est. Subyearling Chinook were collected using beach seines from five Washington and seve n Oregon bays and estuaries from 1996 to 2001. To ensure field sampling captured wild fish instead of hatchery-rear ed fish, the authors attempted to collect fish from field sites prior to releases from hatcheries or other programs. The few hatchery fish that were captured in be ach seines were not included in their analyses. Additional specimens were collected from hatche ries. Juvenile coho were collected from two Washington and three Oregon estuaries in 1998. In addition to tissue tes ting, bile metabolites

and stomach contents were evaluated.

Johnson et al. (2007a) found that Chinook salm on had the highest whole body contaminant concentrations, typically 2 to 5 times higher than coho salmon from the same sites. Believed to be a function of high lipid content, ha tchery Chinook body burdens of PCBs and DDTs were higher than estuarine Chinook salmon. Of the twelve estuaries where sampling occurred, concentrations of PCBs were hi ghest in Chinook salmon from the Duwamish Estuary, the Columbia River, and Yaquina Bay. Each of these systems had fish exceeding the 2,400 ng/g lipid NOAA threshold for adverse h ealth effects on fish. No significant

differences were observed in PCB concentra tions in coho salmon between sampling sites, though sample size was small.Technical Issue Paper July 20, 2012 Page 23 Johnson et al. (2007a) found DDT concentrations in juvenile Chinook were highest in the Columbia River and Nisqually Estuary. PAH metabol ites concentrations in bile were highest in Chinook captured in the Duwamish Estuary and Grays Harbor. When coho and Chinook salmon collected from the same sites were compared, ∑ DDT concentrations were much lower

in coho salmon . As PCBs, PAHs, and DDTs were consiste ntly present in stomach contents at

concentrations correlate d with contaminant body burdens from the same sites, it is believed

that contaminants in estuarine food res ources contribute to out-migrant body burden.

Persistent organic pollutants in outmigrant j uvenile Chinook salmon from the Lower Columbia Estuary, USA (Johnson et al. 2007b):

Johnson et al. (2007b) investigated exposure to several persistent organic pollutants (PAHs, PCBs, DDTs, and other organochlorine pesticid es) in out-migrant juvenile fall Chinook salmon in the Lower Columbia River. They also evaluated the potential for adverse effects on salmon and the estuarine food web. Three regions were chosen for the collection of whole body and gut content samples: Columbia River estuary, Longview, and the confluence of the Willamette and Columbia Rivers. Approximate ly 30 juvenile Chinook were collected via

beach seine in the summers of 2001 and 2002. A dditional fish were captured using a purse

seine in the Columbia River es tuary. Chinook captured included a mix of both hatchery and naturally spawned fish. Once captured, fish we re sacrificed for whole body and gut content analysis. The entire stomach content was collected post-mortem.

Johnson et al. (2007b) found average whole body concentrations of PCBs in juvenile Chinook ranged from 1,300 to 14,000 ng/g lipid (Figure 2). Average whole body concentrations of DDT were extremely high, ranging from 1,800 to 27,000 ng/g lipid (Figure 3). Whole body PCB and DDT conc entrations tended to be asso ciated with fish size, not distribution by river mile. The authors conclude d that this finding was a correlation with estuarine residence time, as larger fish require d longer residence time. With respect to prey items collected from gut contents, PCBs, DDTs, and PAHs were all found in salmon stomach samples, indicating that prey is a source of e xposure. The authors conc luded that since whole body contaminant concentrations were poorly correlated with nearby sediment concentrations, pelagic as well as benthic sources are important in determining salmon exposure. The findings of Johns on et al. (2007b) indicate that concentrations of DDTs and

PCBs are elevated in out-mi grant juvenile Chinook salmon in the Lower Columbia River, relative to salmon from undevelope d Pacific Northwest estuaries.Page 24 July 20, 2012 Technical Issue Paper Figure 2. Mean concentrations of total PCBs (ng/g wet weight and ng/g lipid) in whole bodies of juvenile Chinook salmon from the Lower Columbia River and Estuary

Source: Johnson et al. 2007b

Figure 3. Mean concentrations of tota l DDTs (ng/g wet weig ht and ng/g lipid) in whole bodies of juvenile Chinook salmon from the Lower Columbia River and Estuary

Source: Johnson et al. 2007bTechnical Issue Paper July 20, 2012 Page 25 Adult uptake and transfer of contaminants

Lipid reserve dynamics and magnification of persis tent organic pollutants in spawning sockeye salmon ( Oncorhynchus nerka ) from the Fraser River, British Columbia (Kelly et al. 2007):

Though accumulations of salmonid body burdens can and do occur during freshwater and estuarine occurrence of salmonids, the re lative proportion of total adult body burden accumulated during juvenile stages has been questioned by some authors (O’Neill and West 2009). Kelly et al. (2007) invest igated spawning sockeye salmon in the Fraser River. From June to October of 2001, they collected return ing adult fish from as far downstream as 10 km, and as far upstream as approximately 1,200 km. Unfortunately, their complete methodology was not included in the paper, tho ugh their target analytes included PCBs and polychlorinated dibenzo- p -dioxins (PCDDs) and polychlorin ated dibenzofurans (PCDFs). Their study found that the Fraser River is no t a major source of sockeye salmon body burden accumulation of PCBs and PCDD/PCDFs, and that marine food sources and pathways are the important factors of persistent organic pollutants (POPs) in re turning adults. However, other important findings were that magnification of to xics occurs during the development of eggs. Findings showed a three-fold increase of lipid toxic equivalents (TEQs) in eggs from openocean samples to those taken during spawning. This suggests that lipid reserve depletion during upstream migration can increase PCB and PCDD/PCDF concentrations in eggs as the adult fish prepare to spawn.

Kelly et al. (2007) conclude by noting that ot her globally distributed dioxin-like compounds and/or endocrine disrupting chemicals (EDCs) such as polychlorinated napthalenes (PCNs), polybrominated diphenyl ethers (PBDEs), he xachlorocyclohexanes (HCHs), endosulfans, dialkyl phthalate esters (D PEs), and perfluoroalkyl co mpounds (PFCs) are undoubtedly present in tissues of these salmon. Should ma gnification and maternal transfer of these compounds also occur during spawning, toxicologi cal impacts would affect returning adults and early life stage development. Unlike legacy pollutants such as PCBs and PCDD/PCDFs, many of these other current use chemicals of concern can be extensively discharged into urban/agricultural receiving waters such as the Fraser River. Future research should, therefore, focus on accumulation patterns and th e cumulative and/or synergistic effects of PCBs, PCDD/PCDFs, and other EDCs of emer ging concern on the reproductive health and population dynamics of Pacific salmon.

Acquisition of polychlorinated biphenyls (PCBs) by Pacific chinook salmon: An exploration of various exposure scenarios (Hope 2012):

Hope (2012) used models to examine 16 differe nt scenarios to identify where Oregon State water quality standards in place for the protectio n of human health might be effective at reducing PCBs in adult fall Chinook salmon. Mo del scenarios assumed a 130-day juvenile residency in fresh water, 50-da y juvenile residency in estu aries, and adult fall Chinook returning after three to four winters in the ocean (1,860 days). A simplified summary of what Hope (2012) applied includes a bioenergetic s model and a bioaccumulation model with estimates of prey consumption rates to estimate contaminant levels in a given fish on a given day at a given location. The model scenarios a ssumed that prey of adult salmonids included 20 to 60 percent herring, a s ubstantial PCB source for adult Chinook. However, it was not

clear if the various model scenarios took into account the region-sp ecific differences inPage 26 July 20, 2012 Technical Issue Paper herring PCB burdens described by West et al. (2008). While acknowledging that interpreting models must be done with caution, Hope (2012) concludes that his model scenarios suggest a limited ability of the Oregon water quality stan dards to meet the expectation of reducing contaminant loadings in anadromous species (in this case fall Chinook).

Marine distribution, life history traits, and the accumulation of polychlorinated biphenyls in Chinook salmon from Puget Sound, Wa shington (O’Neill and West 2009):

One of the most important papers for understanding body burden accumulations of Chinook salmon in Puget Sound is O’Neill and West (2009). They focused on three primary objectives; (1) compare PCB levels from Puget Sound Chinook salmon with other West Coast populations, (2) evaluate whether PCB accumu lation mainly occurred in the freshwater or marine habitats, and (3) quantify the relative importance of fish age, fish size (fork length), lipid content, and saltwater age (the number of winter s spent in salt water) on PCB concentration. Maturing and subadult Chi nook salmon were sampled in August and September from 1992 to 1996. Muscle samples (t otal of 204) were collected from 763 individual Chinook. Only a portion of the fish sa mpled were of naturally spawning runs, with hatchery fish representing 98 percent of fish that migrated to salt water as yearlings (30 percent of the total fish sampled). As a result , a comparison of PCB levels between hatchery and wild fish was not possible. An aroclor anal ysis of the tissues was the selected method.

Though varying widely among samples, average c oncentration of PCBs measured in samples

of skinless muscle tissue from subadult and maturing Puget Sound Chinook salmon was 53 ng/g fish tissue, which was three to five times higher than average concentrations reported for adult Chinook salmon from six other popula tions on the West Coast of North America (Figure 4) (O’Neill and West 2009). Chinook sa mples collected in the south and central portions of Puget Sound had the highest average concentrations (Figure 5). Rivers in the northern portion of Puget Sound, while still averaging approximately 40 ng/g, had the lowest concentrations of the seven separate groups w ithin the Puget Sound sampling area (Figure 5). Although the proportion of Chinook that are caught in Puget Sound relative to the other six regions was not represented, estimates have indi cated that approximately 14.5 percent of the Oregon and Washington commercia l Chinook landings were fr om Puget Sound, with TreatyIndian landings ranging from 72 to 95 percen t of Puget Sound-caught Chinook salmon from 1991 to 2005 (O’Neill 2006). It is important to not e that these estimates do not include sportcaught Chinook.

When comparing regions of body burden accumu lation, the analysis of O’Neill and West (2009) indicated that, even in the most highl y PCB-contaminated river draining into Puget Sound, the Duwamish River, the vast majority (>96 percent) of PCB accumulation occurred in the marine environment, with little freshw ater contribution. They note that these findings are not surprising, given that Ch inook salmon typically gain 99 pe rcent of their total mass in marine habitats. They further estimated that yearling out-migrants (pos sibly stream-type fish) would acquire a similar percentage (>98.7 percent) of their total mass in marine habitats.

O’Neill and West (2009) found wide variati ons in contaminant burden for Puget Sound Chinook, suggesting that behavioral differences varied consider ably among individual Puget Sound Chinook salmon. Variation may be related to fish size, and diet sh ifts that occur with size. They suggest that two mechanisms appear to be at work here: (1) growth dilution ofTechnical Issue Paper July 20, 2012 Page 27 PCB associated with the additi on of weight accumulated by older fish, and (2) a reduction in dietary PCB inputs associated with feeding on cl eaner prey resources offshore for these older

Chinook.

That the variation of contaminant burden w ithin Puget Sound is region-specific is an indication that there may be minimal straying, or some geographic is olation that occurs, between north and south sound resident Chinook. Because the pelagic food web in Puget Sound is more heavily contaminated than that in the coastal waters (West et al. 2008), resident Puget Sound Chinook salmon, particularly those that occur w ithin inner Puget Sound (an urbanized basin), experience a much more contaminated environment than non-resident populations. The urbanization of the inner Sound and the extended reside nce in these waters for Chinook originating from South Sound tributar ies contributes to the findings that fish residing and feeding in central and southern Puget Sound probably would be exposed to higher PCB levels than fish feeding in northern areas of the sound.

In an investigation of inland marine herring st ocks, a substantial porti on of subadult and adult Chinook salmon diets, West et al. (2008) found that Pacific he rring from central Puget Sound are more highly contaminated with PCBs th an those from northern Puget Sound and the southern Strait of Georgia. As a result, O’Neil l and West (2009) conclude that the wide range of PCB levels observed for Puget Sound Chinook salmon reflects their degree of residency

and distribution while feedi ng within the inland marine waters. Although the authors concluded that Puget Sound Chinook PCB burdens appear to be a function of duration of residency and distribution while f eeding within the inland marine waters, they also stated that

behavioral differences of indivi dual fish with respect to diet , overwintering, and movement

within the inland marine wate rs was not fully understood.

As indicated by O’Neill et al . (2006) and Cullon et al. ( 2009), the body burden of Puget Sound salmonid populations has implications fo r populations utilizing these fish as a substantial portion of their diet. Although these studies focused on the effects salmonid body

burdens would have on southern resident killer whale populati ons, the findings can be used

as an indicator of health risks associated with the consumption of contaminated food resources from Puget Sound waters.Page 28 July 20, 2012 Technical Issue Paper Figure 4. Mean PCB concentration in
Chinook salmon fillets

Source: O’Neill and West 2009 1 Figure 5. Mean PCB concentration in adult Chinook salmon returning to Puget Sound (in-rivers versus marine waters)

Source: O’Neill and West 2009 Error bars represent standard error around the means.

Persistent organic pollu tants in Chinook salmon ( Oncorhynchus tshawytscha ); implications for

resident killer whales of British Columbia and adjacent waters (Cullon et al. 2009):

In a study designed to investigat e the effects of contaminated food resources for Southern Resident Killer Whales, Cull on et al. (2009) measured POP concentrations in Chinook salmon ( Oncorhynchus tshawytscha ). A total of nine smolts and 24 adult Chinook were collected in 2000 and 2001 over an area ranging fr om Johnstone Strait to southern Puget Sound, at the Deschutes hatcher y. Adult Chinook were collected from the central Strait of Georgia, whereas Washington fish were collected at the mouth of the Duwamish River and at a Deschutes River hatchery. Once collected, samp les were prepared and analyzed for stable isotope analysis, contaminant an alysis, and lipid determination. Scale analysis showed that

all but three of the adu lt Chinook appeared to migrate to ma rine waters in their first year.

1 Science Panel requested finding out what percentage of the total number of Chinook salmon consumed is represented by each of t hese seven regions. This information was requested from both authors of O’Neill and West (2009). Mr West suggests Ms. O’Neill is the most appropriate respondent. Ms. O’Neill is out of the country until approximately July 2012, but was able to respond in brief. She stated that this may be available with sufficient time to coordinate with the CTC, PFMC, and WDFW for the relevant publications, then create a s ummary.Technical Issue Paper July 20, 2012 Page 29Table 1. Estimated body burdens ofpersistent organic pollutants in returning adult Chinook salmon andChinook smoltsSource: Cullon et al. 2009Page 30 July 20, 2012 Technical Issue Paper Based on their analysis, Cullon et al. (2009) concluded that 97 to 99 percent of PCBs, PCDDs, PCDFs, dichlorodiphenyltrichloroethan e (DDT), and hexachlorocyclohexane (HCH) in returning adult Chinook were acquired during their time at sea, not in fresh water or estuaries (Table 1). However, it is important to note that the sample size for this investigation, considering th e large area investigated, wa s very limited. Additionally, although the samples originated from both hatche ry and wild-caught fish, the study’s results did not differentiate between the two types (possibly due to limited sample size). An interesting finding was that even though they were found to have lower lipid concentrations, Chinook collected further south had higher PO P concentrations than Chinook sampled in

more northern areas.

Thirty years of persistent bioaccumulative toxi cs in Puget Sound; Time trends of PCBs and

PBDE flame retardants in three fi sh species (West and O’Neill 2007):

West and O’Neill (2007) were interested in evaluating Puget Sound PCB tissue concentration trends in English sole, Paci fic herring, and coho salmon. They combined, screened for comparable methodologies, and analyzed P uget Sound Assessment and Monitoring Program (PSAMP) data that had been coll ected over a 30-year period. As the needs of this issue paper are for salmonid accumulations, a review of the English sole is not presented. However, as herring are an important food resource for salmonids in Puget Sound, their summary is included. Data were regionally organized into North, Central, and South Puget Sound. The analysis of PCB concentrations in herring s howed that northern Puget Sound fish had much

lower concentrations than those in central a nd southern portions of the sound. Concentrations of PBDEs in Pacific herring were roughly one-hal f to one-third of their PCB concentrations,

with concentrations from 2001 to 2006 of centr al Puget Sound herring ranging from 40 to 85 ng/g wet wt., total PBDEs. The authors note th at there was no apparent time trend in any stock, as early data were very limited.

The summary review by West and O’Neill (2007) of historic data indicated that PCBs in muscle tissue of coho salmon in central Puge t Sound decreased over time from over 200 ng/g wet weight in one composite sample from 1975 to 86 ng/g in 1987, and generally less than 50 ng/g in the 1990s. Data were not presented for coho occurring in southern or northern portions of the sound. In comparison to coho, Paci fic herring from central and southern Puget Sound stocks have remained nearly three times that of coho salmon from central Puget Sound. No species analyzed were found to have a reduction in PCBs from 1990 through 2005. West and O’Neill (2007) hypothesized that th e lack of a declining trend in PCBs over the past 15 years is the re sult of biotic recycling of PCBs through the food web.

Spatial extent, magnitude, and patterns of persiste nt organochlorine polluta nts in Pacific herring ( Clupea pallasi ) populations in Puget Sound (USA) and Stra it of Georgia (Canada) (West et al. 2008):

West et al. (2008) investigated the geographic distribution and magnitude of three POPs in three Puget Sound populations and three Strait of Georgia popul ations of Pacific herring. Their summary on herring is included due to th e herring’s importance as a food resource for selected species of adult salmonids. Methods included mid-water trawls from 1999 to 2004, collecting a total of 1,055 pre- spawn herring for all locations combined. They found Puget Sound herring were 3 to 9 times more contamin ated with PCBs, and 1.5 to 2.5 times moreTechnical Issue Paper July 20, 2012 Page 31 contaminated with DDTs, than Strait of Geor gia herring (Figure 6). The authors concluded, considering the distinct differences between th e populations, that the st ocks appeared to be isolated from each other geographically, allowing for the environmental exposure to contaminants to be regionally expressed. Therefore, although herring represent a mobile source of POPs, they appear to stay regionally isolated. This is re levant to Puget Sound salmonid populations as heavily burdened P uget Sound herring are a notable source of bioavailable POPs in the Puget Sound food we b, and their regional distribution may have a corresponding regional effect on their predators, including resident Puget Sound Chinook.

Figure 6. Concentration of PCBs, DDTs, and hexachlorobenzene in six herring populations from Puget Sound and the Strait of Georgia

Source: West et al. 2008



## III. Can salmonid contaminant body burden be attributed to a specific location?

A central question related to site-specific consumption is: can a salmonid’s body burden be attributed to a location in which it occurs for a specific time in its life?Page 32 July 20, 2012 Technical Issue Paper The life history strategies of different salmon sp ecies, and runs within given salmon species, are highly variable. Life history vari ation between salmonids begins at a very early age. Slight differences occur between species due to the time it takes for a given egg to hatch, with prehatching duration differences affected by enviro nmental conditions, as well as species-specific differences. In general, eggs take some number of weeks to hatch, and th e alevins remain in the gravel for a few more weeks until they consume th eir yolk sac reserves. It is at emergence from the gravel where life history pa tterns begin to vary substantia lly between and within species. Some salmon, such as pink, chum, and ocean-t ype Chinook salmon, migrate downstream within the first few weeks, with some exceptions. Ot her species, such as stream-type Chinook, coho, and sockeye salmon and steelhead, remain in freshwat er streams or rivers to rear for 1 to 3 years before migrating toward marine habitats.

The differing behavior within species (e.g., stre am-type vs. ocean-type Chinook) illustrates how difficult it is to make generalizations, even with in a given salmonid species. Estuarine rearing is also highly variable between and within salmonids, with some species and types rearing for prolonged periods in these habitats, while others spend a few days to a few weeks during their shoreline out-migration. Salmonid fo od resources are also very diffe rent, which is likely a life history strategy that allows co -occurring species to partiti on the available resources and minimize direct competition. Some salmonids, both as juveniles and adults, use available planktonic food resources, some use epibenthic re sources, while others as they grow larger are mainly piscivorous. Age at maturity varies be tween species; some species (pink salmon) reach maturity at age 2 with little variation. Other spec ies are much more variable, reaching maturity at ages 3, 4, 5, or even 6 years of age (e.g., Chinook and chum).

A few salmonids (Chinook, coho, and pink) that or iginate from Puget Sound show some form of residency behavior (Laufle et al. 1986; Duffy 2003, 2009; Duffy et al. 2005). All or portions of these runs and/or stocks remain in Puget Sound waters for rearing and maturing, never migrating to coastal or open-ocean waters. However, likely because their residency forms are less abundant than their ocean-going forms, much less is know n about possible reside nt coho and pink salmon than resident Puget Sound Chinook. While non- resident Chinook may gain as much as 98 percent of their total weight while in the ocean (Quinn 2005), re sident Chinook complete their entire life from egg to returning adult in their natal stream and Puget Sound. Therefore, body

burden accumulation for resident Chinook salmon may be an indicator of environmental conditions within Puget Sound.

Due to widely varying life histories, most not ably the regions where salmonids occur and their dietary preferences, it is not appr opriate to group all salmonids into a single category to serve as site-specific indicators for contaminants. In f act, as a number of authors indicate, almost all salmonids accumulate the vast majority of thei r body burden at sea; accumulation at juvenile life stages in freshwater and estuar ine habitats contributes a very limited proportion of the total accumulation. There is some regional potential, however, for resident Puget Sound Chinook

salmon.

It is not surprising that O’ Neill and West (2009) found great er than 96 percent of PCB accumulation in Puget Sound Chinook occurred in ma rine habitats. Even more noteworthy, when taking into account the life history of these fis h, is the finding of O’Neill and West (2009) that Puget Sound Chinook have three to five times hi gher PCB concentrations than those of other west coast populations. Considering that the ma jority of salmonids or iginating in Puget SoundTechnical Issue Paper July 20, 2012 Page 33 are ocean-type, meaning they rear only for a short time in fresh water before migrating to

estuarine and marine hab itats, the total mass of a returning resident adult Chinook is primarily obtained in Puget Sound marine habitats. In a ddition, Puget Sound Chinook return to their natal streams to spawn having spent fewer years in marine habitats than some Chinook populations elsewhere. Therefore, Puget Sound resident Chinook salmon spend less time accumulating contaminants than many other populations , yet have a higher total body burden.

Another factor potentially releva nt to this topic, briefly mentioned by a few authors but not investigated in detail, is the lack of understanding of whethe r there was a threshold response effect on juvenile salmonids exposed to contaminan ts while in freshwater and estuarine habitats. It is possible that the subadu lt and adult salmonids sampled fo r body burden analysis were those fish that did not experience behavioral and physiological abnormalities, post-exposure, that

would have reduced their survival to adulthood. In other words, subadult and adult fish sampled may not be entirely representative of the naturally occurring j uvenile population.

O’Neill and West (2009) showed that there is re gional variation within Puget Sound waters and

resident Chinook in more urbanized waters ha ve greater body burdens. These findings suggest that a relationship does exist between contamin ants and body burden in these fish. Nonetheless, due to their transient nature, these fish will pr obably not be able to serve as site-specific indicators. However, a more complete unders tanding of their duration of residency and distribution while feeding within specific regi ons of the inland marine waters may enable resident Puget Sound Chinook to serve as re gion-specific indicators in the future.Page 34 July 20, 2012 Technical Issue Paper 

# Summary

A review of the literature on northeast Pacific Ocean salmon body burden accumulation found that there were very few invest igations of the origin of steel head body burden and contaminants compared to other salmonids. However, given that steelhead can live many more seasons in marine environments than other co-occurring salmonids, with multiple freshwater entries for spawning, it would stand to reason that st eelhead may have an even higher body burden accumulation than these other species. Although other salmonids along the west coast and in Puget Sound have lower body burden concentra tions of contaminants, Puget Sound Chinook salmon have elevated PCB levels that appear to correlate with specific regions within Puget Sound. Nearly 22 percent of the maturing and su badult Chinook salmon samples collected from Puget Sound by Meador et al. ( 2002) had PCB concentrations above an effects threshold identified for salmonid fishes (i.e., 2,400 ng/g lip ids), which included endpoints such as reduced growth, altered enzyme and hormone levels, and increased mortality.

O’Neill and West (2009) summarized that the most contaminated Puget Sound Chinook salmon in their investigation, believed to be Puget Sound residents, had concentrations comparable to Baltic Sea Atlantic salmon. Only Great Lakes sa lmon had higher concentrations of PCBs in North America, where Chinook salmon and coho sa lmon populations in the early 1990s were 20 to 30 times more contaminated with PCBs than the Puget Sound Chinook salmon investigated by O’Neill and West (2009). It is alarming that Puget Sound Chinook spend fewer years in marine habitats than many othe r salmonids, have a lower fat conten t in which lipophilic contaminants can be stored than spring-run Chinook, yet have much higher body burdens of PCB contaminants. These observations suggest that the food web within Puget Sound has a much higher concentration of PCBs than other ri vers and estuaries in this region.

To understand where, when, and how salmonids accu mulate their body burden, it is important to first note their life history, summarized in Section I, Salmon Life History . Regional occurrence is important: where do salmon occur over what portion of their life, and what are they doing in a given region that contributes to contaminant uptake (principall y, what are the salmon eating and where are these prey residing (i.e., getting thei r exposure)?). While there are many differences between salmonids originating from Washington State streams and rivers, salmonid diet and where subadults/adults occur while they are maturi ng appear to be the most important factors. The dietary resource of a maturing salmon when it is maximizing growth (by mass) appears to be the principal factor for its eventual total body bu rden. That does not mean that salmonids do not accumulate toxins as fry or smolts, as various au thors have shown this occurs. However, relative to the total body burden by the time a salmon reach es a harvestable size, juvenile contaminant uptake does not appear to be a significant factor.

Salmonid diet is important to consider when st udying the uptake of contaminants because some salmonids prey on food resources higher up the food chain than others , increasing the total biomagnification. For example, a large portion of the pink and sockeye salmon diet is composed of planktonic invertebrates. By the time these shor t-lived prey become food resources, they have not lived long enough, or consumed a sufficient nu mber of other prey items, to increase their potential for toxic loads. However, the larg er species, notably coho and Chinook, will consume prey items higher on the food chain (e.g., Osmeri dae and Clupeidae), increasing their exposureTechnical Issue Paper July 20, 2012 Page 35 risk. Maturing Chinook salmon, more than any other salmonid, is the most piscivorous. The diet

of a subadult or adult Chinook salmon includes a substantial amount of fish species, herring (planktivores) in particular. F eeding higher on the food chain ma y take advantage of a higher caloric resource, but it also means prey items ha ve lived longer (2 to 3 years) and consumed more organisms. As a result, prey resources such as herring have been exposed to more contaminants and have an elevated body burden (West et al. 2008). For those salmonids preying on herring stocks in Puget Sound and the Strait of Georgia, the volume and origin of their food resources exposes them to the highest risk.

Studies have shown that the region in which a salm onid occurs during its growth from juvenile to subadult to adult is the most important factor for origin of contaminants in a given fish. For those salmonids that mature at sea, at least 96 per cent of their POP body burden has been described as originating from oceanic waters. Studies have also shown that salmonids with the greatest burden are those that mature in polluted waters. Alt hough some very small numbers of coho and pink salmon may not migrate to oceanic waters, the st ock of greatest note is the resident Puget Sound

Chinook. A number of authors showed that tissue analysis of this stock has a much higher body burden than ocean-migrating stocks. In addition, resident Puget Sound Chinook originating from southern Puget Sound tributaries have gr eater burdens than those to the north.

As noted above in Section III, the life histories of salmonids are too variable between and within species and the habitats they uti lize to be used for site-specifi c evaluation. Ocean-maturing fish accumulate the vast majority of their body burden while at sea. However, for resident Puget Sound Chinook there does appear to be a correl ation between salmon body burden and region of

occurrence within th e inland marine waters. Though the life history of these fish does not make them ideal candidates to serve as site-specific indicators, further understanding of their regionspecific differences and origin of burden may enab le them to serve as region-specific indicators

in the near future.Page 36 July 20, 2012 Technical Issue Paper 

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