Considerations and challenges in support of science and communication of fish consumption advisories for per- and polyfluoroalkyl substances
Authors: Petali Jonathan Michael , Pulster Erin L. , McCarthy Christopher , Pickard Heidi M. , Sunderland Elsie M. , Bangma Jacqueline , Carignan Courtney C. , Robuck Anna , Crawford Kathryn A. , Romano Megan E. , Lohmann Rainer , von Stackelburg Katherine 
Published: May 2024

Federal, state, tribal, or local entities in the United States issue fish consumption advisories (FCAs) as guidance for safer consumption of locally caught fish containing contaminants. Fish consumption advisories have been developed for commonly detected compounds such as mercury and polychlorinated biphenyls. The existing national guidance does not specifically address the unique challenges associated with bioaccumulation and consumption risk related to per- and polyfluoroalkyl substances (PFAS). As a result, several states have derived their own PFAS-related consumption guidelines, many of which focus on one frequently detected PFAS, known as perfluorooctane sulfonic acid (PFOS). However, there can be significant variation between tissue concentrations or trigger concentrations (TCs) of PFOS that support the individual state-issued FCAs. This variation in TCs can create challenges for risk assessors and risk communicators in their efforts to protect public health. The objective of this article is to review existing challenges, knowledge gaps, and needs related to issuing PFAS-related FCAs and to provide key considerations for the development of protective fish consumption guidance. The current state of the science and variability in FCA derivation, considerations for sampling and analytical methodologies, risk management, risk communication, and policy challenges are discussed. How to best address PFAS mixtures in the development of FCAs, in risk assessment, and establishment of effect thresholds remains a major challenge, as well as a source of uncertainty and scrutiny. This includes developments better elucidating toxicity factors, exposures to PFAS mixtures, community fish consumption behaviors, and evolving technology and analytical instrumentation, methods, and the associated detection limits. Given the evolving science and public interests informing PFAS-related FCAs, continued review and revision of FCA approaches and best practices are vital. Nonetheless, consistent, widely applicable, PFAS-specific approaches informing methods, critical concentration thresholds, and priority compounds may assist practitioners in PFAS-related FCA development and possibly reduce variability between states and jurisdictions. Integr Environ Assess Manag 2024;20:1839–1858. © 2024 The Author(s). Integrated Environmental Assessment and Management published by Wiley Periodicals LLC on behalf of Society of Environmental Toxicology & Chemistry (SETAC).

Key Points

Fish consumption advisories (FCAs) for per- and polyfluoroalkyl substances (PFAS) present unique scientific and public health policy challenges. The evolving information about PFAS toxicology and mixture effects presents a challenge for risk assessment and risk communication. Sampling for PFAS FCAs requires consideration of chemical, biological, and environmental features that can influence data quality. While FCAs are specific to the United States, these PFAS-specific challenges are relevant for other forms of risk assessment, management, and communication.