Human Health Focus Group
Oregon Fish Consumption Rate Project
November 14, 2007
10:00a.m. to 4:00p.m.
The following notes are a summary of issues that are intended to point out future actions or issues that may need further discussion at upcoming meetings. These notes are not intended to be the “record” of the meeting, only a reminder for the group.
The following Focus Group Members were present for all or part of the meeting:
Pat Cirone (former EPA employee), Elaine Faustman (on phone, UW), Dave McBride (WDH), Sue MacMillan (URS), Joan Rothlein (OHSU)
Also Present: Becky Chu (EPA), Kathleen Feehan (CTUIR), Nancy Judd (on phone, Windward Environmental consultant), Jordan Palmeri (DEQ), Mary Lou Soscia, (EPA), Deb Sturdevant (DEQ)
Donna Silverberg and Robin Gumpert, DS Consulting
EQC Debrief
The Human Health Focus Group (HHFG) debriefed the October 17th EQC special session on the FCR project. They inquired as to whether quantitative FCR numbers were expected of them, per a question asked by one of the Commissioners. DEQ responded that DEQ is responsible for gathering information in response to Commissioner questions, and that not all the questions asked directly of the HHFG would need to be answered. The group was prepared to discuss and try to resolve many of the technical/substantive issues today.
FCR Technical Report
Jordan Palmeri told the group that he planned to continue refining the draft HHFG report based on the group members’ input today and hoped to finalize the draft at the December 17 HHFG meeting. The HHFG findings will be presented at the next public workshop (Feb/March 2008) and will be used, among other pieces developed through this public process, to inform FCR option recommendations to the EQC. He noted that EQC members are expected to attend the next public workshop.
One of the HHFG members noted that in order to respond to iterations of the report, at least 10 days is needed to review and provide input. The group acknowledged the challenge DEQ staff has in writing a report on behalf of six different experts with unique perspectives. The time constraint in completing the report was noted as an additional challenge. Given this, the group agreed the report needs to be transparent and objective in describing the findings, as well as the weaknesses and strengths of the different documents reviewed and including the information that was available and used to reach any conclusions.
HHFG members provided general suggestions and principles for refining the report:
• A technical editor is needed to assist Jordan with graph/visual editing of the report.
• If the HHFG feels they can support a joint recommendation for a ‘scientifically defensible’ or ‘substantiated’ FCR option, they should do so, so long as they clearly explain the rationale behind their recommendation. (Everyone agreed with this comment.)
o Any “Findings” of the HHFG need to be agreed upon by all members.
• The report should reflect the HHFG perspective, not DEQs—and should continue to include information that is presented to staff by HHFG members.
• The group provided revisions to the format of the report.
o ACTION: DS Consulting will provide a revised Table of Contents for Jordan to use in formatting the report, based on today’s discussion.
Jordan shared a list of seven unresolved questions/issues from comments shared on the report. The bullets indicate discussion and suggestions for how to address the issues in the report.
Question 1: How should we consider the additional FCR surveys?
• Develop a literature list of relevant information that could be considered in making policy choices about a FCR – including those pieces that were not reviewed by the HHFG. This is important to include if this is going to be the Administrative Record for DEQ’s final rule.
• Provide the table of surveys reviewed followed by a bibliography of additional relevant surveys.
• Include recent relevant data and do not separate the new information from the 9 surveys we previously ranked.
o HHFG members will review the most current bibliography list from Pat Cirone to help determine which are the most relevant studies and how to fold these additional pieces into the report. Joan and Dave offered to provide assistance on this.
Question 2: Consumer only data
• Outline the strengths and uncertainties of using ‘consumer only’ data vs. ‘consumers and non-consumers’. Qualify the HHFG use of consumer-only data per discussion today, and delete the sentence that this is an ‘overestimate’.
• Consider that the actual rate of fish consumption could be higher if there were no fish advisories or a depletion of fish resources. Consider whether FCR surveys were done pre- or post- fish advisories.
o ACTION: Dave will share reference information on this.
Question 3: Survey rankings and relevancy
• Discomfort exists among HHFG members with “the way we ranked our surveys”, so a suggestion was made not to provide rankings. All agreed to remove the rankings.
• Discuss quality (robustness) of information and level of relevancy to the state do not call it a ranking. Include criteria for quality, e.g. peer reviewed. Each study should have an explanation of quality and relevancy, and ultimately answer the question: Should DEQ rely on this study or not?
Question 4: What quantitative comparisons does the group want to make about the data, if any?
• As a first cut, Pat Cirone and Joan Rothlein will pull together a table/matrix of FCR choices and include narrative to qualify the numbers chosen. The goal is to develop a table of simple recommended values.
• A comment was made that since the HHFG chose not to look at differences among various human populations, they should compare high, medium and low consumers. Any comparisons they can make will be helpful to DEQ.
Question 5: Relative Source Contribution
• Becky Chu shared an abstract of a survey regarding juvenile freshwater exposure that suggested that both freshwater and marine exposure is important and should be acknowledged in the report. Jordan will quote this article in reference to discussion on marine species.
o ACTION: Becky offered to share the full article with HHFG members.
• Regarding O’Neil’s report: Elaine shared that O’Neil suggested using caution in using her work relative to RSC discussions.
• Currently marine species are not included in the FCR or RSC and should be included somewhere.
• Should RSC be part of this group’s report? Consensus was reached that salmon should be included in the FCR, but the group did not reach consensus on how to include all marine species. DEQ will continue to rely on EPA’s default guidance for marine species, which is 20%.
• It was suggested that information from permits, fishing revenues, and other boating catch and sales information could be used to gather ‘disappearance data’ to inform the marine species question.
• The report will include the following language about marine species:
“The HHFG looked and could not find any scientific data that supports use of the RSC for marine fishes except for the national survey. However, because Oregonian’s eat marine fish, the panel believes that marine fish should be included in the State’s FCR. As such, the HHFG encourages the State to continue looking for and then consider this data as it becomes available”.
• What data did Maine and New York rely on for including marine species in their FCR? What was their rationale? If possible, Becky said she would try to share information on this with the HHFG. What is CA doing? Joan said she would provide info on this if she finds it.
Question 6: Toxicity and Risk
• Suggest showing relationships between potent and benign carcinogens and toxic non-carcinogens and not toxic non-carcinogens, using specific examples instead of “pollutant A and pollutant B”.
• No extensive background piece on toxicity is needed. Include slides from Pat and Sue’s presentation at the public workshop as an appendix to the report.
Question 7: Any other caveats/limitations to acknowledge in the report?
• Best available science was used, and findings were based on professional judgment/expertise of the group.
• In the executive summary, acknowledge the focus of the group’s work as it relates to FCR, where the information came from, and how the information was selected. Also share what the group chose NOT to focus on and why—as well as the dates the group worked/reviewed data (i.e. between ___(date) and ___(date), 2007).
• Recognize the limitations of any study.
• Focus more on describing the process used and less on the limitations of the studies.
Wrap-Up
In closing, additional commitments were made to help the group move toward finalizing the report:
• DS Consulting will send the HHFG’s message to DEQ about the importance of allowing Jordan enough time to focus on finishing their report over the next month if the state plans to rely on the report for its administrative record. This will require Jordan’s time plus additional technical editing support if this is going to be included in the state’s Administrative Rule.
• Re: studies--Each HHFG member will give his/her opinion about the relevancy of each study to OR as well as the quality of each study and whether or not it should be relied upon.
• Pat and Joan will work on a table and visuals to share with the group asap (eventually this is hoped to be a simple visuals with recommended values).
• Jordan will share the next draft of the report with the HHFG by December 7.
• HHFG members will do their best to get the information promised to Jordan in time for him to fold it in to the December 7 draft. (Jordan requested rankings on the table first.)
• The group will re-convene on December 17 to continue refining/finalizing the report.