HHFG report review (3/21/08 Draft)
Remaining issues
EDITS FROM HHFG per 3/25/08 meeting
• Introduction: Delete added comment ‘that the HHFG felt would be important to consider’.
1) Chapter III, Section 1.
a. PC made a suggestion to summarize the studies and put the details in an appendix. Both CTUIR and EF agreed with the suggestion. I hesitate to make this change because this is the most detailed and technical section of the report. I think the details show the depth of consideration the HHFG used for these surveys. Additionally, there are multiple references used and the only reference to Appendix 1 would end up being in an appendix itself. Leave it as is.
2) Chapter III, Section1(a). Do the pros and cons of 24hour recall surveys need to be spelled out more clearly? End sentence under Utility at ‘estimates’ (delete “which enhances…”) and pick up paragraph at ‘Although the raw data were not available for re-analysis…
3) Chapter III, Section1(b). Short term data collection efforts need to be addressed.
• Delete ‘Collecting data over such a short time period means variability in individuals is not captured. Replace with ‘However, in a large survey…..” (Jordan/Joan have specific language for this piece).
• Delete ‘The mean consumption rates may be skewed…’ and start a new paragraph with ‘Including non-consumer data in a FCR can lead to misleading fish consumption values. Exposure assessments….”
4) Chapter III, Section 1(d).
a. Does the HHFG want to weigh in on how they think outliers should be treated versus just documenting how the outliers were treated in each study?
• Sentence that begins ‘Finally, the analysis…’, change to ‘The analysis did not exclude any data. The rationale given by staff for including high consumption values or “outliers” (any value greater than three standard deviations from the mean) was that the Suquamish staff assisting with the survey were familiar with the individuals eating those large quantities and that the consumption rates …”
5) Chapter III, Section 1(d)
a. Should we expand upon the “Relevance” of the Suquamish data by stating something similar to the Tulalip relevance such as, “There are patterns of high consumption in Pacific Northwest Tribes regardless of species consumed or origin of the fish.” Under “Relevance”, final bullet, include language from the Toy et al study.
6) Chapter III, Section 1(f)
a. E.Faustman comment on how much Oregon seafood is distributed statewide. I don’t understand this comment. Disregard, this comment was misplaced.
7) Chapter III, Section 1(g)
a. Add peer reviewed results to Columbia Slough report? I spoke to the author of the report and she said it was only internally reviewed by the City of Portland and had no external peer review. Do we want to mention this? Yes note that it was not externally reviewed.
8) Chapter III, Section 1(h).
a. CRTFC Reevaluation. Why are we not relying upon the data? It’s stated that it’s a master’s thesis and was not peer reviewed. However, J. Rothlein said, I don’t agree with this last comment. I spoke with Bill Lambert, PhD who was on the student’s committee. As being submitted for a masters thesis, this report was carefully reviewed by the three professors on the student’s committee. Perhaps critiqued more than often found in the journals, but not by “outside” reviewers.
• Under Utility, sentence starting ‘This study was a re-evaluation…’ add ‘and was regarded as useful.’
• Remove sentence ‘Although…’ and add to Relevance section, CRITFC (1994) survey data and is a published master’s thesis from the OHSU Dept. of Health. There are no changes…’
9) Chapter III, Section 2(b)
a. The changes to the 3rd paragraph no longer represent the point being referenced by (OEHHA, 2001). I agree with the last sentence but I don’t understand why “large numbers of individuals” being surveyed would make a 2-day dietary recall more representative of long term consumption. I understand why multiple time periods and different seasons would help the certainty but I’m still hung up on 2-day recalls using the reported data and assuming that rate of consumption for every day of the year. I think we should remove the reference and just say what the HHFG thinks about the issue. Let’s discuss.
• True up language with new language in Chapter 3 Section 1(b) re: 24-hour recall. In middle of third paragraph, start new paragraph with ‘The data for individual consumers were then assumed….’
• Don’t cite (OEHHA, 2001).
• Add to that sentence ‘However, if large numbers are included and the survey covers more than a one-time period or season, it can be more representative of consumption patterns.’
10) Chapter III, Section 2(d)
a. CTUIR comment. A line was added commenting that the CRITFC questionnaire did not included other species. From my review of the questionnaire, there are specific fish species that are mentioned and then an open ended question about any other fish consumed. How should we treat this? Add to sentence ‘They did not report eating any specific shellfish or pelagic…’
11) Chapter III, Section 2(3)
a. Ranges of FCRs section. How does the HHFG like the narrative explaining the rationale for the extracted/filtered Table 2
• Move to Conclusions Section.
Refinements will be made to first paragraph. Initial edits included: Paragraph one should read: Table 1 (located in Section X) lists information on the entire set of fish consumption surveys that were considered and reviewed by the HHFG. Table 1 is divided into two main sections: 1) The nine surveys that were subject to an in-depth review by the HHFG; and 2) other national and international surveys that considered FCRs. Data was grouped by gender and age or by the type of fish consumed. Table 2 provides ranges of fish consumption rates from the five surveys the HHFG determined were the most useful for selecting a fish consumption rate for water quality criteria. The surveys were chosen using the criteria outlined in Chapter III, Section 1 of this report. Each of the 5 surveys was determined to be “useful” because the quantitative results can be relied upon as good estimates of fish consumption for the population surveyed. Since there are multiple statistics that can be presented from these 5 surveys (many are presented in Table 1), the HHFG applied step-wise decisions to narrow the data to the most useful range of fish consumption rates. Table 2 represents the results of the HHFG process for filtering the data. The decisions and the rationale for filtering the data are outlined below:
1) Use only the 5 surveys that were considered useful because the quantitative results can be relied upon as good estimates of fish consumption for the population surveyed. Those 5 surveys are listed below:
o A Fish Consumption Survey of the Umatilla, Nez Perce, Yakama, and Warm Springs Tribes of the Columbia River Basin (CRITFC, 1994)
o A Fish Consumption Survey of the Tulalip and Squaxin Island Tribes of the Puget Sound Region (Toy et al., 1996)
o Fish Consumption Survey of the Suquamish Indian Tribe of the Port Madison Indian Reservation, Puget Sound Region (Suquamish, 2000)
o Asian and Pacific Islander Seafood Consumption Study (Sechena et al., 1999)
o Estimated Per Capita Fish Consumption in the United States (EPA, 2002)
2) Consider only those data based on adult consumption. The HHFG recognizes that fish consumption rates for children and women of child bearing age are also extremely important. However, the fish consumption rates for children are less than adult fish consumption rates because children are smaller and often eat less fish. So, the use of adult fish consumption rates should be protective of children who consume fish. The HHFG does recognize that the overall protectiveness of water quality criteria for children is not only dependent upon the FCR used, but also the body weight and toxicity values used, which were not subject to review in the FCR Project. The single study that provides fish consumption rate data for breast-feeding women (CRITFC 1994) provides values that are similar to and less than the CRITFC fish consumption rates for whole population, and so the HHFG did not feel it was necessary to include the fish consumption rate study for breast-feeding women in the final group of fish consumption rate studies.
3) Consider data from “all” seafood sources. In some surveys, the respondents report on the source of the fish they consume. Sources can include self harvested, store bought, and restaurant bought. There are many restaurants and stores that may sell local fish in addition to fish that come from out of state waters. There was no way to distinguish the source of the fish if it was restaurant or store bought. Therefore, data from “all” seafood sources were considered.
4) Consider the data from anadromous and resident fish and shellfish species. Although the HHFG has chosen to include consumption of salmonid species in fish consumption rate recommendations, deep ocean species (within 3 nautical miles of the Oregon coast) would be included. Please note that all studies considered in this review did not include deep ocean fish such as tuna, … The single exception is the EPA 2002 study of the U.S. general population, which provides fish consumption rates that include anadromous and resident finfish and shellfish from fresh, estuarine, and marine environments.
5) Consider consumer only data. The HHFG believes that studies based only on fish-consuming populations are relevant in choosing a representative fish consumption rate.
The fish consumption rate values shown in Table 2 were obtained from results of the five useful surveys listed above and identified in the Conclusions section of this report. The HHFG has opted to present a range of statistical values for each of the five studies: the mean fish consumption rate value, the median fish consumption rate value, and the 75th, 90th, 95th, and 99th percentile fish consumption rate values. The means ranged from 63 g/d to 214 g/d. The 90th percentiles ranged from 113 g/d to 489 g/d. Please refer to Table 2 for the complete ranges. The HHFG provided observations from the range they developed (in Table 2). They are as follows:
• (Elaine and the HHFG will provide a summary, which may include): The range of means are X to X greater than the current FCR.
• Mean overlaps
• Range overlaps
• 99th percentile is the highest for the US general population.
• 3 studies are within 10% of the 99th percentile estimates.
• The range is not large.
12) Chapter III, Section 2(f)
a. Population based estimates. WAIT FOR PC comments and review section later. Include or exclude section?
• HHFG needs to discuss this – options include removing the section altogether, including Pat’s edited version, or some new version. They will send final language to Jordan by noon on Friday.
13) Chapter IV, Section 1
a. I have deleted CTUIR insertions on NY and ME and have not included the “should not utilize the entire RfD” sentence.
• Put them back in as examples. Perhaps move to specific section on ‘Marine Species and Pacific Salmon in the FCR’. (See next bullet)
14) Chapter IV, Section 5
a. CTUIR comment. Did Jordan capture the HHFG discussion on marine fish accurately?
• Include definition of “marine” and move discussion of marine fish up to first section in Chapter IV.
• Needs revisions – Jordan talk with HHFG.
15) Chapter IV, Section 5
a. CTUIR and Sue M comment. Review sentence, “Doing this may incorrectly attribute marine fish as contributors of certain pollutants that are not likely to be in their tissue, and thus not contributing to the overall risk of the consumer”
• Delete.
16) Chapter V, Section 1
a. EF comment. Do we need to clarify the q1* is the 95% CL on the risk slope?
• Remove q1* and put CSF (cancer slope factor) into equation.
• Under Section 2 Cancer Risk, second paragraph: Remove q1* reference and replace with CSF.
• Sentence starting at ‘incremental’: Change to ‘would be at 10 times higher cancer risk’. (Delete six extra incidences value).
17) Conclusions
a. Review each conclusion to attain HHFG consensus
• Needs work – HHFG will provide a new Conclusions section that incorporates their Range of Rates, Table 2, and Observations.
TO DO:
• Reference EPA letter sent by Jordan (Tonya)
• Finish and place Table 2 (filtered rates) in report (Jordan) : Replace all blank and NA boxes with ‘Not available’.
• Complete Table 1 (Jordan) (Same)
• Merge/replace Elaine’s write up w/PC comments (Jordan) (May be deleted/reworded – HHFG will let Jordan know by Friday at noon)
• Add additional tables from PC edits of EF write up (Jordan) (Same)
• Write excutive summary (Jordan)