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jscitotenv.2009.03.004)
Science of the Total Environment 408 (2010) 1466–1467
Contents lists available at ScienceDirect
Science of the Total Environment j o u r n a l h o m e p a g e : w w w. e l s ev i e r. c o m / l o c a t e / s c i t o t e n v
Letter to the Editor
Comment on Urban et al. “Assessment of human health risks posed by consumption of fish from the Lower Passaic River (LPR), New Jersey” (2009, doi:10.1016/jscitotenv.2009.03.004) Walter Mugdan ⁎ Emergency and Remedial Response Division, United States Environmental Protection Agency, Region 2, 290 Broadway, New York, New York 10007, United States
a r t i c l e
i n f o
Article history: Received 9 July 2009 Accepted 9 November 2009 Available online 14 December 2009 Keywords: Lower Passaic River Fish ingestion Crab ingestion Risk assessment Superfund guidance
a b s t r a c t Urban et al. (2009) presented a human health risk assessment for the Lower Passaic River that is not consistent with the United States Environmental Protection Agency (USEPA) risk assessment guidance for Superfund cited in the article, because it is based on a fish ingestion rate that underestimates angler exposure to contaminated fish, does not evaluate exposure to contaminated crab, and underestimates the cancer risks and non-cancer health hazards associated with these exposure pathways. USEPA recommends that people follow the health advisories for the Lower Passaic River, available online at http://www.state.nj.us/dep/dsr/ 2009FishAdvisoryBrochure.pdf. Published by Elsevier B.V.
In 2007, the United States Environmental Protection Agency (USEPA) completed a human health risk assessment for the Lower Passaic River (available at www.ourpassaic.org) pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act and Superfund Amendments and Reauthorization Act (CERCLA/ SARA), also known as the Superfund Law. Based on USEPA's analysis, we are compelled to comment on Urban et al. (2009), “Assessment of Human Health Risks Posed by Consumption of Fish from the Lower Passaic River (LPR), New Jersey.” The Urban et al. (2009) study is not consistent with the Superfund Program Guidance cited in the article for three (3) main reasons described below. 1. Urban et al. (2009) selected a fish ingestion rate that underestimates potential exposure Superfund risk assessment guidance, as cited in the article, requires evaluation of the Reasonably Maximally Exposed (RME) individual, which is defined as the highest exposure reasonably expected to occur at the site in the absence of any institutional controls such as consumption advisories (USEPA, 1989). The fish consumption rate for the Lower Passaic River selected by Urban et al. (2009) is 1.8 g/day (less than 3 half-pound meals per year), taken from Ray et al. (2007). This fish consumption rate was calculated by including a large majority of anglers (54 of 61 anglers) who stated
DOI of original article: 10.1016/j.scitotenv.2009.03.004. ⁎ Tel.: +1 212 637 4427; fax: +1 212 637 4393. E-mail address: [email protected]. 0048-9697/$ – see front matter. Published by Elsevier B.V. doi:10.1016/j.scitotenv.2009.11.028
that they did not consume the fish they caught and thus had zero fish consumption from the Lower Passaic River (Ray et al. 2007). Anglers with zero fish consumption are not exposed through a fish consumption pathway and should not have been included in the calculation of a fish ingestion rate for the RME individual. Fish consumption rates provided in Ray et al. (2007) that are based on anglers who consume fish from the Lower Passaic River are 23.95 g/day (estimated) and 28 g/day (maximum). These two values are comparable to the 26 g/day consumption rate for anglers recommended in USEPA's Exposure Factors Handbook (USEPA (1997) [Errata at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=12464], which Urban et al. (2009) rejected because “use of the default values would clearly inflate actual fish consumption” in the Lower Passaic River. 2. Urban et al. (2009) did not evaluate human exposure to contaminated crab Superfund risk assessment guidance cited in the article requires the evaluation of completed exposure pathways under current and future conditions (USEPA, 1989). Urban et al. (2009) did not calculate cancer risks and non-cancer health hazards due to exposure to crab, which is a completed exposure pathway in the Lower Passaic River. Blue crab is contaminated and the New Jersey Department of Environmental Protection (NJDEP) currently prohibits catching and consuming crab from the Lower Passaic/Newark Bay Complex (New Jersey Department of Environmental Protection, NJDEP, 2009). In addition, Burger (2002) and New Jersey Department of Environmental Protection (NJDEP) (2002) have reported consumption of crab in
W. Mugdan / Science of the Total Environment 408 (2010) 1466–1467 Table 1 Comparison of fish consumption pathway cancer risks and non-cancer hazards based on Urban et al. (2009) and USEPA's risk assessment (U. S. Environmental Protection Agency, USEPA, 2007). Fish
Adult Adolescent Young child Combined adult and child
Cancer
Non-cancer
Urban
USEPA
Urban
USEPA
6.4 × 10− 5 Not calculated 3.0 × 10− 4 3.6 × 10− 4
7.0 × 10− 3 2.0 × 10− 3 3.0 × 10− 3 1 × 10− 2
4.27 Not calculated 20.4
64 55 99
Table 2 Comparison of crab consumption pathway cancer risks and non-cancer hazards based on Urban et al. (2009) and USEPA's risk assessment (USEPA, 2007). Crab
Adult Adolescent Young child Combined adult and child
Cancer
Non-cancer
Urban
USEPA
Urban
USEPA
Not Not Not Not
1.0 × 10− 2 4.0 × 10− 3 5.0 × 10− 3 2 × 10− 2
Not calculated Not calculated Not calculated
86 72 140
calculated calculated calculated calculated
the Newark Bay Complex. USEPA's risk assessment found that the cancer risks and non-cancer health hazards from consuming crab are higher than those from consuming fish (USEPA, 2007). 3. Urban et al. (2009) underestimated cancer risks and non-cancer hazards in the Lower Passaic River Urban et al.'s (2009) low fish consumption rate and other exposure assumptions resulted in underestimations of the cancer risks and non-cancer health hazards posed by consumption of fish in the Lower Passaic River. As shown in Tables 1 and 2, Urban et al. (2009) calculated cancer risks and non-cancer health hazards that are less than USEPA's calculated values by more than an order of magnitude. USEPA considers both cancer risks and non-cancer health hazards in determining the need to consider remediation at Superfund sites as outlined in the program guidance. USEPA's goal of protection for cancer risks is 10− 6 and for non-cancer health hazards it is a Hazard Index (HI) = 1. Further, as stated in the National Contingency Plan (USEPA, 1990), acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk
1467
to an individual of between 10− 6 and 10− 4. Urban et al. (2009) concludes: “… measured concentrations of Chemicals of Potential Concern (COPC) are not likely to pose a health risk to people who currently consume fish from the LPR.” This contradicts the health advisories issued by the NJDEP (2009), which specify “do not eat” for fish and “do not eat or harvest” for crab. Urban et al. (2009)'s conclusion also is incorrect in the context of the Superfund Program, even using the results of the Urban et al. (2009) risk assessment. For example, Urban et al. (2009) calculated Hazard Indices of 20.4 and 4.27 for the child and adult respectively, both of which are above the goal of protection for non-cancer health hazards established by USEPA. USEPA is currently evaluating public comment on its Human Health Risk Assessment for the Lower Passaic River. The results of USEPA's evaluation will be made available to the public on the project website, www.ourpassaic.org. USEPA recommends that people follow the health advisories for the Lower Passaic River, available online at http://www.state.nj.us/dep/dsr/2009FishAdvisoryBrochure.pdf. References Burger J. Consumption patterns and why people fish. Environ. Res. Sect. A 2002;90:125–35. New Jersey Department of Environmental Protection (NJDEP). 2009. Fish Consumption Advisories. Fish Smart, Eat Smart — A Guide to Health Advisories for Eating Fish and Crabs Caught in New Jersey Waters. New Jersey Department of Environmental Protection, New Jersey Department of Health and Senior Services, http://www. state.nj.us/dep/dsr/2009FishAdvisoryBrochure.pdf New Jersey Department of Environmental Protection (NJDEP). 2002. Estimate of Cancer Risk to Consumers of Crabs Caught in the Area of the Diamond Alkali Site and Other Areas of the Newark Bay Complex from 2,3,7,8-TCDD and 2,3,7,8-TCDD Equivalents. Prepared by the Division of Science, Research and Technology (April 25). Ray R, Craven V, Bingham M, Kinnel J, Hastings E, Finley B. Human health exposure factor estimates based upon a creel/angler survey of the Lower Passaic River (part 3). J. Toxicol. Environ. Health A 2007;70:512–28. Urban JD, Tachovsky JA, Haws LC, Wikoff Staskal D, Harris MA. Assessment of human health risks posed by consumption of fish from the Lower Passaic River, New Jersey. Sci. Total. Environ. 2009;408(2):209–24. U. S. Environmental Protection Agency (USEPA) 2007. Focused Feasibility Study for the Lower Passaic River, Appendix C. Human Health Risk Assessment. Draft. Available at: www.ourpassaic.org U. S. Environmental Protection Agency (USEPA. Exposure Factors Handbook. Volume II. Food Ingestion Factors. Washington, D.C: U. S. Environmental Protection Agency, Office of Research and Development; 1997. EPA/600/P-95/002Fb. August, 1997. U. S. Environmental Protection Agency (USEPA) 1990. National Oil and Hazardous Substances Pollution Contingency Plan, Final Rule, codified as amended at 40 C. F.R. Part 300. U. S. Environmental Protection Agency (USEPA) 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part A). Interim Final. U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, Washington, D.C. EPA/540/1-89/002. December 1989.
Contents lists available at ScienceDirect
Science of the Total Environment j o u r n a l h o m e p a g e : w w w. e l s ev i e r. c o m / l o c a t e / s c i t o t e n v
Letter to the Editor
Comment on Urban et al. “Assessment of human health risks posed by consumption of fish from the Lower Passaic River (LPR), New Jersey” (2009, doi:10.1016/jscitotenv.2009.03.004) Walter Mugdan ⁎ Emergency and Remedial Response Division, United States Environmental Protection Agency, Region 2, 290 Broadway, New York, New York 10007, United States
a r t i c l e
i n f o
Article history: Received 9 July 2009 Accepted 9 November 2009 Available online 14 December 2009 Keywords: Lower Passaic River Fish ingestion Crab ingestion Risk assessment Superfund guidance
a b s t r a c t Urban et al. (2009) presented a human health risk assessment for the Lower Passaic River that is not consistent with the United States Environmental Protection Agency (USEPA) risk assessment guidance for Superfund cited in the article, because it is based on a fish ingestion rate that underestimates angler exposure to contaminated fish, does not evaluate exposure to contaminated crab, and underestimates the cancer risks and non-cancer health hazards associated with these exposure pathways. USEPA recommends that people follow the health advisories for the Lower Passaic River, available online at http://www.state.nj.us/dep/dsr/ 2009FishAdvisoryBrochure.pdf. Published by Elsevier B.V.
In 2007, the United States Environmental Protection Agency (USEPA) completed a human health risk assessment for the Lower Passaic River (available at www.ourpassaic.org) pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act and Superfund Amendments and Reauthorization Act (CERCLA/ SARA), also known as the Superfund Law. Based on USEPA's analysis, we are compelled to comment on Urban et al. (2009), “Assessment of Human Health Risks Posed by Consumption of Fish from the Lower Passaic River (LPR), New Jersey.” The Urban et al. (2009) study is not consistent with the Superfund Program Guidance cited in the article for three (3) main reasons described below. 1. Urban et al. (2009) selected a fish ingestion rate that underestimates potential exposure Superfund risk assessment guidance, as cited in the article, requires evaluation of the Reasonably Maximally Exposed (RME) individual, which is defined as the highest exposure reasonably expected to occur at the site in the absence of any institutional controls such as consumption advisories (USEPA, 1989). The fish consumption rate for the Lower Passaic River selected by Urban et al. (2009) is 1.8 g/day (less than 3 half-pound meals per year), taken from Ray et al. (2007). This fish consumption rate was calculated by including a large majority of anglers (54 of 61 anglers) who stated
DOI of original article: 10.1016/j.scitotenv.2009.03.004. ⁎ Tel.: +1 212 637 4427; fax: +1 212 637 4393. E-mail address: [email protected]. 0048-9697/$ – see front matter. Published by Elsevier B.V. doi:10.1016/j.scitotenv.2009.11.028
that they did not consume the fish they caught and thus had zero fish consumption from the Lower Passaic River (Ray et al. 2007). Anglers with zero fish consumption are not exposed through a fish consumption pathway and should not have been included in the calculation of a fish ingestion rate for the RME individual. Fish consumption rates provided in Ray et al. (2007) that are based on anglers who consume fish from the Lower Passaic River are 23.95 g/day (estimated) and 28 g/day (maximum). These two values are comparable to the 26 g/day consumption rate for anglers recommended in USEPA's Exposure Factors Handbook (USEPA (1997) [Errata at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=12464], which Urban et al. (2009) rejected because “use of the default values would clearly inflate actual fish consumption” in the Lower Passaic River. 2. Urban et al. (2009) did not evaluate human exposure to contaminated crab Superfund risk assessment guidance cited in the article requires the evaluation of completed exposure pathways under current and future conditions (USEPA, 1989). Urban et al. (2009) did not calculate cancer risks and non-cancer health hazards due to exposure to crab, which is a completed exposure pathway in the Lower Passaic River. Blue crab is contaminated and the New Jersey Department of Environmental Protection (NJDEP) currently prohibits catching and consuming crab from the Lower Passaic/Newark Bay Complex (New Jersey Department of Environmental Protection, NJDEP, 2009). In addition, Burger (2002) and New Jersey Department of Environmental Protection (NJDEP) (2002) have reported consumption of crab in
W. Mugdan / Science of the Total Environment 408 (2010) 1466–1467 Table 1 Comparison of fish consumption pathway cancer risks and non-cancer hazards based on Urban et al. (2009) and USEPA's risk assessment (U. S. Environmental Protection Agency, USEPA, 2007). Fish
Adult Adolescent Young child Combined adult and child
Cancer
Non-cancer
Urban
USEPA
Urban
USEPA
6.4 × 10− 5 Not calculated 3.0 × 10− 4 3.6 × 10− 4
7.0 × 10− 3 2.0 × 10− 3 3.0 × 10− 3 1 × 10− 2
4.27 Not calculated 20.4
64 55 99
Table 2 Comparison of crab consumption pathway cancer risks and non-cancer hazards based on Urban et al. (2009) and USEPA's risk assessment (USEPA, 2007). Crab
Adult Adolescent Young child Combined adult and child
Cancer
Non-cancer
Urban
USEPA
Urban
USEPA
Not Not Not Not
1.0 × 10− 2 4.0 × 10− 3 5.0 × 10− 3 2 × 10− 2
Not calculated Not calculated Not calculated
86 72 140
calculated calculated calculated calculated
the Newark Bay Complex. USEPA's risk assessment found that the cancer risks and non-cancer health hazards from consuming crab are higher than those from consuming fish (USEPA, 2007). 3. Urban et al. (2009) underestimated cancer risks and non-cancer hazards in the Lower Passaic River Urban et al.'s (2009) low fish consumption rate and other exposure assumptions resulted in underestimations of the cancer risks and non-cancer health hazards posed by consumption of fish in the Lower Passaic River. As shown in Tables 1 and 2, Urban et al. (2009) calculated cancer risks and non-cancer health hazards that are less than USEPA's calculated values by more than an order of magnitude. USEPA considers both cancer risks and non-cancer health hazards in determining the need to consider remediation at Superfund sites as outlined in the program guidance. USEPA's goal of protection for cancer risks is 10− 6 and for non-cancer health hazards it is a Hazard Index (HI) = 1. Further, as stated in the National Contingency Plan (USEPA, 1990), acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk
1467
to an individual of between 10− 6 and 10− 4. Urban et al. (2009) concludes: “… measured concentrations of Chemicals of Potential Concern (COPC) are not likely to pose a health risk to people who currently consume fish from the LPR.” This contradicts the health advisories issued by the NJDEP (2009), which specify “do not eat” for fish and “do not eat or harvest” for crab. Urban et al. (2009)'s conclusion also is incorrect in the context of the Superfund Program, even using the results of the Urban et al. (2009) risk assessment. For example, Urban et al. (2009) calculated Hazard Indices of 20.4 and 4.27 for the child and adult respectively, both of which are above the goal of protection for non-cancer health hazards established by USEPA. USEPA is currently evaluating public comment on its Human Health Risk Assessment for the Lower Passaic River. The results of USEPA's evaluation will be made available to the public on the project website, www.ourpassaic.org. USEPA recommends that people follow the health advisories for the Lower Passaic River, available online at http://www.state.nj.us/dep/dsr/2009FishAdvisoryBrochure.pdf. References Burger J. Consumption patterns and why people fish. Environ. Res. Sect. A 2002;90:125–35. New Jersey Department of Environmental Protection (NJDEP). 2009. Fish Consumption Advisories. Fish Smart, Eat Smart — A Guide to Health Advisories for Eating Fish and Crabs Caught in New Jersey Waters. New Jersey Department of Environmental Protection, New Jersey Department of Health and Senior Services, http://www. state.nj.us/dep/dsr/2009FishAdvisoryBrochure.pdf New Jersey Department of Environmental Protection (NJDEP). 2002. Estimate of Cancer Risk to Consumers of Crabs Caught in the Area of the Diamond Alkali Site and Other Areas of the Newark Bay Complex from 2,3,7,8-TCDD and 2,3,7,8-TCDD Equivalents. Prepared by the Division of Science, Research and Technology (April 25). Ray R, Craven V, Bingham M, Kinnel J, Hastings E, Finley B. Human health exposure factor estimates based upon a creel/angler survey of the Lower Passaic River (part 3). J. Toxicol. Environ. Health A 2007;70:512–28. Urban JD, Tachovsky JA, Haws LC, Wikoff Staskal D, Harris MA. Assessment of human health risks posed by consumption of fish from the Lower Passaic River, New Jersey. Sci. Total. Environ. 2009;408(2):209–24. U. S. Environmental Protection Agency (USEPA) 2007. Focused Feasibility Study for the Lower Passaic River, Appendix C. Human Health Risk Assessment. Draft. Available at: www.ourpassaic.org U. S. Environmental Protection Agency (USEPA. Exposure Factors Handbook. Volume II. Food Ingestion Factors. Washington, D.C: U. S. Environmental Protection Agency, Office of Research and Development; 1997. EPA/600/P-95/002Fb. August, 1997. U. S. Environmental Protection Agency (USEPA) 1990. National Oil and Hazardous Substances Pollution Contingency Plan, Final Rule, codified as amended at 40 C. F.R. Part 300. U. S. Environmental Protection Agency (USEPA) 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part A). Interim Final. U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, Washington, D.C. EPA/540/1-89/002. December 1989.