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Bureau of Health Fish Tissue Action Levels

Updated 22001

Following USEPA’s three volume Guidance for Assessing Chemical Contaminant Data

for Use in Fish Advisories EPA 1993 1997 the Maine Bureau of Health uses action

levels as a guide to determine the need for developing fish consumption advisories

Action levels are concentrations of a contaminant in fish tissue below which there should

be negligible risk of toxicity at a consumption rate of one meal a week Action levels

may be developed for seve ral different toxicological endpoints cancer developmental

and other non cancer effects Concentrations of contaminants in fish tissue are

compared to the appropriate action levels When fish tissue concentrations exceed action

levels the development of Fish Consumption Advisories are considered This document

briefly describes the derivation of fish tissue action levels and includes a tabulated

summary of chemical specific fish tissue action levels currently in use by the Bureau of

Health For more details on risk based approaches for developing fish consumption

advisories consult EPA’s three volume Guidance for Assessing Chemical Contamination

Data for Use in Fish Advisories EPA 1993 1997

Derivation of Action Levels for Noncarcinogenic Toxicological Endpoints

Fish Consumption Advisories based on noncarcinogenic toxicological endpoints are set at

a level believed to represent a minimal risk of a deleterious effect from lifetime exposure

even for sensitive subpopulations It is assumed that no ncarcinogenic toxicological

endpoints have a threshold response ie there is a dose below which toxic effects will

not occur Fish Consumption Advisories are set such that total exposure from eating on

average one 8 ounce fish meal per week will result in a daily dose below the threshold

The equation EPA 1997 for determining action levels for noncancer toxicological

endpoints is

FC

RfD BW

AL

Where

AL Action Level mgkg

RfD Reference Dose mgkg day

BW Body Weight kg

FC Fish Consumption Rate kgday

The reference dose RfD is defined by the EPA 1997 as an estimate with uncertainty

spanning perhaps an order of magnitude of a daily exposure level mgkg day for the

human population including sensitive subpopulations that is likely to be without an

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appreciable risk of deleterious effects during a lifetime The value of the RfD is chemical

and toxicological endpoint specific The lower the value of the RfD the more toxic the

substance

USEPA maintains databases of RfDs the Agency has derived over the years USEPA’s

premier database for toxicological data including RfDs is called IRIS Integrated Risk

Information System RfDs listed on IRIS have undergone an Agency wide review and

are viewed as USEPA’s preferred toxicological data RfDs for chemicals not listed in the

IRIS database can sometimes be found in the USEPA’s Superfund Program HEAST

Health Effects Assessment Summary Tables database USEPA’s Office of Pesticide

Programs OPP also maintains a database for RfDs and other toxicological data for

pesticides It is the Maine Bureau of Health’s preference to look first to IRIS as a source

for toxicological data followed by HEAST and OPP listings Absent toxicological data

on IRIS HEAST or OPP databases the Bureau of Health will consider other sources

such as the Agency for Toxic Substances and Disease Registry Minimal Risk Levels or

derive RfDs directly from the primary toxicity data following standard risk assessment

methods as described in USEPA Guidance EPA 1997 Additionally the Bureau of

Health may derive RfDs if existing USEPA RfDs are considered outdated or do not

reflect important new information

The estimated body weight BW of the exposed individual is required in the action level

calculation since the RfD is expressed on a per kilogram body weight basis The

average body weight for adult males and females combined is assumed to be 70

kilograms kg For adult females the average body weight is assumed to be 60 kg

These values are supported by the following sources

EPA’s Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories 1993 recommends a mean body weight of 70 kgs for all adult and a

body weight of 65 kgs for adult females

EPA’s Draft Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories 1999b recommends a mean body weight of 72 kgs for all adult and a

body weight of 65 kgs for adult females It further recommends a value of 64 kgs

for women of reproductive age

EPA’s Exposure Factors Handbook 1999a recommends an adult body weight of

71.8 kgs Body weights for women in various age groups include 65.4 kgs for

women 18 to 75 60.6 kgs for women 18 to 25 and 64.2 for women 25 to 35

The 70 kg adult general population body weight is used for all action level calculations

except for chemicals in which the RfD is based on reproductive or development effects

The 60 kg adult female body weight is used for calculating action levels for reproductive

and developmental toxicants The Bureau of Health plans to review these values when

EPA’s draft guidance becomes finalized

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A fish consumption rate FC of one eight ounce 227 grams meal per week is used to

derive action levels EPA 1997 One fish meal per week is equivalent to an average

daily fish consumption rate of 0.0324 kg day This consumption rate is an upper

estimate of sport fish consumption and is supported by the following sources

EPA’s Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories EPA 1997 recommends a meal size of eight ounces 227 grams as an

average meal size for adults in the general population eating noncommercial caught

fish

This same guidance EPA 1997 also recommends a consumption rate of 0.0065

kg day in calculating action levels but states this value is under review The new

draft guidance EPA 1999b has increased the consumption rate to 0.016 kgday for

recreational fishers They explicitly state however that these are recommended

default rates and when local consumption rate data are available they should be

chosen preferentially

EPA’s Exposure Factors Handbook EPA 1999a recommends a consumption rate of

0.025 kg day as a 95th percentile value for recreational anglers This is based several

individual studies of Maine and Michigan sports anglers Ebert et al 1993 West et al

1989 and West et al 1993

The 95th percentile values from these individual studies range from 0.026 kgday for

Maine anglers Ebert et al 1993 and Chemrisk 1992 to 0.039 kg day for Michigan

anglers West 1989

Based on this data it is judged that a meal size of 0.0324 kg day is conservatively

representative of an upper level fish ingestion rate for Maine recreational anglers

Derivation of Action Levels for Carcinogenic Effects

Fish Consumption Advisories based on cancer effects are set at a level believed to

represent a minimal risk of cancer from a lifetime of exposure The Bureau of Health

estimates a lifetime of 70 years EPA 1993 There is data that suggests the upper bound

estimate of residency for a particular location may be 30 years EPA 1999a however

the same source acknowledges that the majority of moves are less than 100 miles from

the previous residence This suggests that while an estimate of residency may only be 30

years one may still live within commuting distance to favorite fishing sites

Carcinogens are assumed to act in a non threshold manner in that any amount of

exposure to a carcinogen can cause an increase in risk Historically incremental lifetime

risk levels that have received regulatory attention range from 1 in 10,000 to 1 in

1,000,000 EPA 1997 The Maine Bureau of Health has historically based Fish

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Consumption Advisories on a 1 in 100,000 Acceptable Risk Level1 for individual

chemicals

The equation for determining action levels for cancer effects is

FC

RSD BW

AL

Where

AL Action Level mgkg

BW Body Weight kgs

FC Fish Consumption Rate kgday

RSD Risk Specific Dose mgkg day

and

CSF

ARL

RSD

Where

ARL Acceptable Risk Level unitless

CSF Cancer Slope Factor mgkg day 1

Body weight and fish consumption rate are previously defined The acceptable risk level

is defined above as 1 in 100,000

The cancer slope factor CSF is derived by USEPA usually but not always as the 95th

percent upper confidence limit of the low dose linear slope of the dose response curve

and is expressed in units of mgkg day1 The CSF is most often derived from studies of

laboratory animals traditionally by application of dose response models that assume no

threshold for carcinogenic effects ie any dose no matter how small will result in some

risk chemicalspecific and allow for linearity in response at low dose The value of the CSF is

The greater the value of the CSF the greater the carcinogenic potency of the

substance

As with RfDs IRIS is viewed as the primary database for obtaining estimates of cancer

slope factors with HEAST and OPP databases being used in the absence of an IRIS

value As with RfDs CSF’s can be derived using standard EPA 1997 methodologies

1

Acceptable Risk Level is the terminology used by EPA’s Guidance for Assessing Chemical Contaminant

Data for Use in Fish Advisories EPA 1997 Other EPA documentation identifies this as the Incremental

Lifetime Cancer Risk

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Action Levels

The following table identifies current action levels used by the Maine Bureau of Health

for screening evaluations

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Environmental Toxicology Program Maine Bureau of Health

UPDATED 501

FISH TISSUE ACTION LEVELS FOR SCREENING EVALUATIONS Fillet wet weight

Reference

Dose RfD

mgkg d

Cancer Potency

Factor CPF

mgkgd1

Risk Specific

Dose RSD

mgkg d

Cancer

Action Level

NonCancer

Action Level

Chlorinated Biphenyls

Dioxins and Furans ppb ppb

PCBs 2.0 x 10 52 5.0 x 10611 43

Dioxin a 1.0 x 10 914000 7.1 x 10100.0015 0.0019

Polycyclic Aromatic Hydrocarbons PAHs ppb ppb

Benzoapyrene

Equivalence

7.3 1.4 x 1063.0

Acenaphthene 6.0 x 10 2130

Anthracene 3.0 x 10 1648

Fluoranthene 4.0 x 10 286

Fluorene 4.0 x 10 286

Biphenyl 5.0 x 10 2108

Naphthalene 2.0 x 10 243

Pyrene 3.0 x 10 265

Chlorinated Pesticides ppb ppb

Hexachlorobenzene 8.0 x 10 41.6 6.3 x 10614 1728

Heptachlor 5.0 x 10 44.5 2.2 x 1065 1080

Aldrin 3.0 x 10 517 5.9 x 1071.3 65

Mirex 2.0 x 10 4432

Lindane 3.0 x 10 4

1.3 7.7 x 10617 648

Heptachlor Epoxide 1.3 x 10 59.1 1.1 x 1062.4 28

Toxaphene 3.6 x 10 41.1 9.1 x 10620 778

Chlordane Nonachlor 6.0 x 10 51.3 7.7 x 10617 130

Dieldrin 5.0 x 10 516 6.3 x 1071.4 108

DDT 5.0 x 10 40.34 2.9 x 10564 1080

Endosulfan 6.0 x 10 3

12963

Metals ppm ppm

Arsenic inorganic b 3.0 x 10 41.5 6.7 x 1060.014 0.6

Cadmium 1.0 x 10 32.2

Chromium VI 5.0 x 10 33.0 x 1033.3 x 1037 11

Lead c

Manganese 1.4 x 10 1302

Methylmercury

developmental

1.0 x 10 4

0.2

Methylmercury adult

paraesthesia

3.0 x 10 40.65

Nickel 2.0 x 10 243

Selenium 5.0 x 10 311

Silver 5.0 x 10 311

Tributyl Tin Oxide 3.0 x 10 40.6

Vanadium d 3.0 x 10 36

Zinc 3.0 x 10 1648

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RfD reference dose

RSD risk specific dose

CPF cancer potency factor

NB Action levels are the fish tissue concentration that allow a consumption rate of one 8

ounce meal per week for an adult without exceeding either an Rfd or a 105Acceptable Risk

Level

a These are BOH derived values Frakes 1990 scheduled for review upon completion of EPA's

draft health assessment for dioxin

b The action levels are for inorganic arsenic Fish tissue data are usually given as total arsenic

the BOH uses FDA’s 1993 assumption that 10 of the total arsenic in fish is inorganic arsenic

c For lead action level derived by using EPA's IEUBK model for lead with fish 17 of dietary

meal intake 95 prob blood lead 10 _gdL in children

d For vanadium RfD based on ATSDR's intermediate duration MRL

References

ChemRisk 1992 Consumption of freshwater fish by Maine anglers A Technical Report

Portland ME ChemRisk A Division of MeLaren Hart Revised July 24 1994

Ebert E Harrington N BoyleKKnight J Keenan R 1993 Estimating

consumption of freshwater fish among Maine anglers N Am J Fisheries Management

13737 745

EPA 1993 Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories Volume 1 Fish Sampling and Analysis Second Edition Office of Water

Washington DC EPA 823R93 002

EPA 1997 Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories Volume 2 Risk Assessment and Fish Consumption Limits Second Edition

Office of Water Washington DC EPA 823B97 009

EPA 1999a Exposure Factors Handbook Office of Research and Development

EPA600C99001 February

EPA 1999b Guidance for Assessing Chemical Contaminant Data for Use in Fish

Advisories Volume 1 Third Edition DRAFT Office of Water Washington DC EPA

823 R99007 August

Frakes Tetrachlorodibenzop R 1990 Health Based Water Quality Criteria for 2,3,7,8

Dioxin TCDD Final Document November

FDA 1993 Guidance Document for Arsenic in Shellfish Center for Food Safety and

Applied Nutrition January

West PCFlyMJ Marans R Larkin F 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

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20141

West PCFly JM Marans R Larkin F Rosenblatt D 1993 1991 92 Michigan

sport anglers fish consumption study Prepared by the University of Michigan

School of Natural Resources for the Michigan Department of Natural Resources

Ann Arbor MI Technical Report No 6 May

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