Alaska Department of Fish and Game Alaska …...Improving and Protecting Alaska's Water Quality 4 Based on dietary survey responses Food diary for a person or household, or Interviews

Alaska Department of Fish and Game Alaska Department of Environmental Conservation

ATCEM 2018

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Improving and Protecting Alaska's Water Quality 2

Presenter

Presentation Notes

Thanks for being here and your interest in this topic. What we’re going to cover today is part of a much larger effort by DEC to update our water quality standards for certain pollutants that could affect human health. This is a project that ADF&G and DEC have been collaborating on for more than three years. Please note that the results presented here today are also provided in paper form in the back of the room. Please note that this presentation does not represent ADF&G or DEC’s opinion on WHAT FCR Alaska should use for regulatory purposes but rather, the process for determining a series of ranges for a variety of consumers of fish.

Outline Purpose of ADF&G/DEC collaborative effort to develop Alaska-

specific fish consumption rates (FCRs) Methods for deriving FCRs Results Application to DEC Human Health Criteria revision effort



Based on dietary survey responses Food diary for a person or household, or Interviews asking people to recall what they ate

Example: Jane eats 8 ounces (serving size) of fish three times per week (e.g., one lunch and two dinners). If you assume this happens every week over the

course of a year Jane’s FCR is 72.65 g/day

What is a fish consumption rate? (FCR)

Presenter

Presentation Notes

Need to start with a couple definitions FCR is the amount of ‘fish’ (pretty broad definition) that a person reports eating during a particular period of time. This is generally converted to grams per day


HHC are Highest concentration of a chemical in surface water not expected to pose a significant risk to human health

What are human health criteria?

Presenter

Presentation Notes

Water quality standards include “criteria” or numeric values that are used for assessment and permitting purposes. Human Health Criteria are set low enough that the amount of a pollutant that may be present in seafood (e.g., fish) will not render fish unsafe to eat, water unsafe to drink, and the consumer will be protected if they were subject to continuous exposure over a lifetime (e.g., 70 years). Fish consumption is often the most direct means of exposure that individuals will have to certain pollutants; the higher the consumption rate, the more stringent the resulting HHC values will be. NOTE: The criteria are not designed to protect the health of fish but rather the health of humans who eat a lot of fish.

Fish Consumption Rates v. Fish Consumption Advisories

A Fish Consumption Rate is used in the HHC process to determine the how much exposure to a pollutant a person may experience through the consumption of fish.

A Fish Consumption Advisory is used to alert people that pollutants have been detected in fish/shellfish at levels that may be unsafe for unlimited consumption.

6Improving and Protecting Alaska's Water Quality

Presenter

Presentation Notes

Water quality standards are used by DEC to try and prevent pollutants from getting into waterways or to assess whether they are present in water at levels of concern. PROACTIVE/Generalized description of a population Consumption advisories are used to alert people that pollutants are in fact present and at levels of concern. REACTIVE/Waterbody or Region Specific

DEC Human Health Technical Workgroup Determined that the ADF&G Division of Subsistence was the best

‘source’ of relevant information

Included harvest data from rural communities across Alaska Included a methodology for deriving fish consumption rates from

harvest data Dataset covers multiple years Includes a broad range of different species consumed by Alaskans.


Presenter

Presentation Notes

The Workgroup took place between 2015 and 2018 and looked at a myriad of issues including fish consumption rates, how they are developed, species to consider, and data limitations. The ADF&G data is Alaska-specific rather than regional or nationwide. This means that the data is considered to be: ‘representative’ of those people who actively include fish as part of their diet. ‘traceable’ as you can go back to the original survey instrument and see the results ‘defensible’ as the methodology has been peer-reviewed and considered by the state to be of use in regulatory programs

Division of Subsistence: Statutory Duties Alaska Statute 16.05.094

lists “duties”1. Research and data

compilation 2. Data reporting and

education 3. Application of study

findings

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Subsistence fishing and processing, Chignik Lake

ADF&G Community Subsistence Information System or “CSIS”

ADF&G used data from 110 Communities

Collected between 2008 and 2015

Considered a range of aquatic species from both fresh and marine waters


Presenter

Presentation Notes

DEC is focusing its attention on the ADF&G dataset because of its size, distribution, and time in existence Data set is fairly large and distributed. Alaska Natives make up ~25-86% of the dataset depending on the region. South Central is the smallest while Western Alaska is the largest.

Methods: Mean Per Capita Use

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𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝑦𝑦′𝑠𝑠 𝑀𝑀𝑀𝑀𝑀𝑀𝐶𝐶 𝑃𝑃𝑀𝑀𝑃𝑃 𝐶𝐶𝑀𝑀𝐶𝐶𝐶𝐶𝐶𝐶𝑀𝑀 𝐻𝐻𝑀𝑀𝑃𝑃𝐻𝐻𝑀𝑀𝑠𝑠𝐶𝐶𝑃𝑃𝑀𝑀𝑃𝑃𝑃𝑃𝑀𝑀𝐶𝐶𝐶𝐶𝑀𝑀𝑃𝑃𝑀𝑀 𝐶𝐶𝑜𝑜 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝑦𝑦′𝑠𝑠 𝐻𝐻𝐶𝐶𝐶𝐶𝑠𝑠𝑀𝑀𝐻𝐶𝐶𝐻𝐻𝐻𝐻𝑠𝑠 𝑈𝑈𝑠𝑠𝐶𝐶𝐶𝐶𝑃𝑃 𝐶𝐶𝐻𝑀𝑀 𝑅𝑅𝑀𝑀𝑠𝑠𝐶𝐶𝐶𝐶𝑃𝑃𝑃𝑃𝑀𝑀

=

Mean Per Capita Use

More precise measure of mean consumption rates, constructed from both harvest and use information

Mean per capita use > Mean per capita harvest

Captures differences among household consumption rates related to cultural food patterns

Methods: Cont.

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Assumes that wild foods are …- Equally distributed among and consumed by all residents of households that report

sharing and using the wild food category- Not exported from or imported into a community- Consumed equally across each day of the year, when expressed as grams per day

Limitations …- The results may be lower/higher than actual consumption by individuals- Data is not age-specific- “High-end” consumers underestimated, “low-end” consumers overestimated

What fish should be included in FCR?

Local freshwater and estuarine

Marine species? Generally not included

What about Salmon & Halibut

Marine mammals

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Things to consider: Which Fish

Ray Troll

Improving and Protecting Alaska's Water Quality

Presenter

Presentation Notes

In general, the FCR does not differentiate between fish caught versus fish bought.

Things to Consider: Fish consumption rates represent many values

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EPA 2016

Improving and Protecting Alaska's Water Quality

Presenter

Presentation Notes

When you’re talking about fish consumption you are generally not talking about a single particular value but rather, a percentile (e.g., 90th). The majority of a population will represent the central tendency while there will be a limited group in the upper bound category. The number will depend on the target population.

Things to consider: Regional Differences

Are FCRs significantly different from one part of the state to another?


Results: FCR Estimates Broken into various percentiles that consider:

Rural Alaska only Region Species Mean (average user) Median (50th percentile of data) 90th-95th (High end consumers)


Results: FCR Estimates Dataset

110 Communities across Alaska Some regions included more communities than others

Results were reviewed by EPA Considered the methodology Potential statistical errors Reproducibility of results (Would EPA come up with the same answer

using the same data?)


Improving and Protecting Alaska's Water Quality 17Source: Tradexlive

227 grams = 8 oz = 0.5 lb

Presenter

Presentation Notes

Reference 1 lb = 454 grams .5 lb = 227 grams or 8 ounces Most salmon filets are between 175 and 250 grams Image ranges from 215 oz to 232 oz

ADF&G FCRs

Includes: • Statewide and Regional

Values• Mean and High

Consumer Values• Species

• Freshwater fish• Marine

Invertebrates (e.g., shrimp, mussel, geoducks, etc)


Statewide values

Presenter

Presentation Notes

This data does NOT consider anadromous species- think about pike, trout, and whitefish. Marine inverts are included because they spend their lives within state waters- mussels, clams, etc

ADF&G FCRs

Includes: • Statewide and Regional

Values• Mean and High

Consumer Values• Species

• Salmon• Freshwater fish• Halibut & Herring• Marine

Invertebrates (e.g., shrimp, mussel, geoducks, etc)


Statewide values

Presenter

Presentation Notes

So- when salmon, halibut, herring are added into the mix RURAL Average use (mean) goes up by 100 g/day or ~150% High End use (90th) goes up by 175 g/day or ~110% 95th goes up by 185 g/day or ~77% FOR REFERENCE 454 g/day = pound of fish per day

Mean FCRs


Column 1 Column 2 Column 3

MeanRegion

Freshwater & Marine Invertebrates (g/day)

Fresh/Marine Invert/Salmon/Halibut/Herring (g/day) Percent Inc.

Column 1 & 2/Seal & Sea Lion (g/day) Percent Inc.

Rural 66.90 165.70 148% 181.2 9%

SE 38.20 179.50 370% 191.7 7%

SC 26.90 129.60 382% 132.7 2%

SW 61.90 198.70 221% 204.2 3%

W 79.90 209.90 163% 225.8 8%

A 93.00 153.30 65% 191.1 25%

Int 49.90 130.20 161% 130.2 0%

Presenter

Presentation Notes

Reference 1 lb = 454 grams .5 lb = 227 grams or 8 ounces Most salmon filets are between 175 and 250 grams

90th Percentile FCRs


90th

Column 1 Column 2 Column 3

Region

Freshwater & Marine Invertebrates (g/day)

Fresh/Marine Invert/Salmon/Halibut/Herring (g/day) Percent Inc.

Column 1 & 2/Seal & Sea Lion (g/day) Percent Inc.

Rural 160.60 336.10 109% 364.88 9%

SE 94.10 337.50 259% 357.6 6%

SC 69.50 255.30 267% 257.9 1%

SW 118.20 354.90 200% 363.1 2%

W 171.30 424.60 148% 455.3 7%

A 261.20 330.70 27% 376.6 14%

Int 127.70 251.00 97% 251 0%

Presenter

Presentation Notes

The bold text indicates the region with the greatest increase when salmon/halibut/herring are included

Interesting points Mean Consumption of freshwater/marine inverts

26 g/d (SC) to 93 g/d (Arctic)

Mean Consumption of fresh/marine/salmon, halibut, herring 130 g/d (SC) to 210 g/d (Western) Percent Increase of 65% (Arctic) to 382% (Southcentral) over

freshwater/marine inverts

Much smaller difference when seal/seal lion consumption is considered


Presenter

Presentation Notes

It’s probably no surprise to anyone that Salmon make up such a large portion of the FCR. Interesting to note the RANGE of values in one region v. another We are highlighting the consumption of seals/sea lions here because those are two species that may reside (and be exposed to pollutants) in state waters during the majority of their lives

Now what? DEC is posting the following documents on the DEC Human

Health Criteria webpage.

ADF&G Fish Consumption Rate Analysis (Nov 2018) DEC Human Health Criteria Technical Workgroup Report EPA-contracted statistical analysis of ADF&G Fish Consumption Rate

Analysis (pending final review)

DEC/ADF&G are not accepting public comments on these documents


Presenter

Presentation Notes

The ADF&G report is simply a statement of the available data. Discussions regarding the methodology and such have been concluded. The TWG report is simply a report on the deliberations and findings- since this is an informative document there are no regulatory actions that will take place. The public had numerous opportunities to weigh in during the deliberative process. EPA statistical analysis was contracted by EPA and is technical in nature. Not appropriate to accept public comment on this doc.

Now what cont. DEC will be posting a list of key questions and potential courses of

action related to the development of human health criteria.

Will be asking for feedback on this document

Species to include Target population (Rural, regional, something else?) Which percentile (Mean, 90th, something else?)


Presenter

Presentation Notes

May be using a web-based tool to accept public comments on our proposed actions but NOT on informative documents Can submit comments via email/writing as well

2019 HHC Efforts DEC will be conducting outreach to discuss key questions

and potential courses of action Statewide webinar(s) In-person public meetings Meetings with key stakeholder groups

DEC plans to commence draft rulemaking efforts in Fall 2019 Outreach and public comment will accompany this effort as

well 2020?


Presenter

Presentation Notes

DEC wants to conduct additional outreach to key stakeholders and interest groups prior to undertaking draft rulemaking

Take away The state recognizes that having an accurate account of Fish

Consumption Rates is important to different stakeholders.

ADEC-Environmental Health conducts fish tissue sampling across the state DHSS testing indicates that most fish have low to no detectable levels of

contamination from pollutants Potential waters of concern are addressed through Fish Advisories.

Alaska has tools available to make water quality criteria more restrictive based on local data on fish consumption.


Questions?

Thank you!


Presenter

Presentation Notes

Let’s take a short break to address any questions you may have

Documents

Alaska Department of Fish and Game Alaska …...Improving and Protecting Alaska's Water Quality 4 Based on dietary survey responses Food diary for a person or household, or Interviews