Fish Consumption Advice for Alaskans
The differences in the two agency’s guidelines are based on the different purposes for which they were derived. Even though the ultimate goal of both agencies is to protect public health, they each approach that goal from different perspectives, entailing different basic responsibilities.
The EPA is a regulatory agency charged with protecting the environment from pollutant-caused degradation. This agency must establish “acceptable” levels of pollution, and manage and enforce their decisions through the issuance of waste discharge permits, punitive actions on violators, and other regulatory mechanisms. These acceptable levels of pollution must be scientifically defensible, and based on potential harm to pollutant receptors such as humans or endangered species. Since the EPA is responsible for controlling the input of pollutants into the environment, it is important for that agency to be conservative, and incorporate adequate safety factors to err on the side of caution. EPA’s over-riding goal is to minimize risk.
In contrast, as public health agencies grapple with the issue of fish consumption advice, public health officials must balance the risks of contaminant exposure against the known benefits of fish consumption. In this task, they must react to environmental pollution that has already occurred, by developing the most appropriate consumption guidance given the circumstances faced in their respective jurisdictions.
In developing fish consumption advice, public health officials maximize public health by finding a balance between two opposing actions that each carry a risk of harm. If the public is encouraged to eat fish, they encounter potential health risks associated with exposure to contaminants. If the public is encouraged not to eat fish, they encounter potential health risks associated with replacement foods that may be of inferior nutritional quality, and the loss of health benefits associated with fish consumption. In this case, Alaska public health officials have reached a balance by adopting a smaller safety factor than the regulatory agency, while still protecting Alaskan fish consumers from being exposed to potentially harmful levels of mercury.
Regulatory agencies have expressed concern that the chronic oral Acceptable Daily Intake of 0.0004 mg/kg body weight/day established by DPH for fish advisory purposes may be used as a justification for higher allowable levels of mercury waste disposal into Alaska’s environment. DPH asserts that this would be inappropriate. The chronic oral Acceptable Daily Intake of 0.0004 mg/kg body weight/day should not be used for regulatory purposes. Instead, the dependence of many Alaska residents on subsistence fish harvests argues for sustained or enhanced protection of Alaska’s environment from mercury pollution relative to national standards. A significant portion of Alaska’s population depends on fish consumption, and Alaskans consume larger quantities of fish than the average American does. We have provided evidence of the types of adverse health effects that could occur if Alaskans were compelled to reduce fish consumption due to contaminant concerns. To maintain clean, healthy fish stocks upon which the health of many Alaskans depend, Alaska must protect its environment from mercury pollution.
Fish Consumption Guidance for the State of Alaska
Based on the decisions of the Alaska Scientific Advisory Committee for Fish Consumption, DPH has developed a series of fish consumption recommendations. These are explained in detail below.
First, DPH used EPA guidance to calculate monthly consumption allowances for Alaska-caught fish5 based on each species’ arithmetic mean mercury concentration. DPH substituted its Alaska-specific Acceptable Daily Intake of 0.4 g/kg body weight/day for EPA’s reference dose of 0.1 g/kg body weight/day and used a meal size of 6 ounces (raw) for adults (Table 8).
Although states consistently limit mercury exposure from fish consumption among women of childbearing age and “young children,” the states and other agencies have inconsistent age cut-offs for “young children”. The concern is that mercury affects the developing brain, and a child’s brain continues to develop at a relatively rapid pace through about age 17 years. However, there are no definitive studies linking low-level