FISH CONSUMPTION RATE PROJECT

HUMAN HEALTH FOCUS GROUP MEETING

May 9, 2007

Notes Prepared by Patti Howard

Columbia River Inter-Tribal Fish Commission

TAKE HOME MESSAGES

1.  DEQ has publicly stated that the fish consumption rate will increase. EQC has the ability to disapprove an increase.

2.  The human health criteria must be protective of beneficial uses. Beneficial use in this context is fishing for ingestion of those fish. It is not for protection of commercial fishing.

3.  The Planning Group needs to identify the most important technical questions to focus on as our primary responsibility is to provide information to the EQC for increasing the fish consumption rate. Identification of those questions is needed in order for the Focus Group to compile the appropriate body of scientific information.

4.  The fish consumption data question is central to our discussion and obtaining those fish consumption numbers is where the focus group can help.

5.  There is an abundance of new information on fish consumption rates including regional, national, and global data for consideration. The absence of Oregon specific fish consumption data for the general population may not be an impediment for increasing the fish consumption rate.

6.  The 17.5 grams per day is not based in reality.

7.  The specific fish species included in the fish consumption rate may have more of an impact on this project than the fish consumption rate itself.

8.  We appear neutral on the public health component of this process and should address public health impacts including the benefits.

9.  What is a reasonable workload to ask of the Focus Group given the current time frame?

TASKS

1. A request was made by focus group members that reference materials be sent to them. Jordan was identified as the point person for those reference materials. Specific materials mentioned during the meeting included:

Table of the human health criteria OR used in their recent triennial review, include references,

Chronology of those criteria with references to updates, and

The re-analysis of the 1994 CRITFC fish consumptions study (Patti).

2. A summary of the May 9, 2007 focus group meeting will be compiled by the Planning Group and sent to the Focus Group for their review.

3. The Planning Group will re-phrase the questions/goals asked of the Focus Group.

TOPICS OF CONVERSATION

Project History

1. Clarification is needed on what is meant by a ‘range of options.’ Focus group members indicated that they did not want a repeat of the previous TAC process.

2. Focus Group members requested background information on the regulatory chronology of and references for the criteria used by OR in the recently revised human health criteria.

3. EQC directed DEQ to obtain information on the fish consumption rate for the general population.

4. EQC indicated that OR needs a higher fish consumption rate to better protect the population.

Communication

1. The Planning Group needs to clarify what they asking of the focus group in order for the focus group to know the type scientific information needed to address those questions/requests.

2. It is important to consider the word choice and phrasing used in public and focus group documents.

Fish Focus group recommends that the Planning Group use fish (estuarine), shell fish, and crustaceans as the correct phrasing for this project.

Workshop What does that term mean?

Economic Impacts of Raising the Fish Consumption Rate That workshop appears focused on the economic impacts but neutral on public health impacts.

Raising (see above) the word ‘raising’ can be interpreted to mean farmed fish.

3. There is a need for clarity in what the Planning Group is asking of the Focus Group. More detail on the what, where, and when was requested by members of the Focus Group.

Focus Group Goal(s)

1. Focus group members asked why the planning group did not include the following question: ‘What is a scientifically defensible fish consumption rate for this region?’ as the goal for this project. Focus group members suggested that: a) the fish consumption data question is central to our discussion, and obtaining those fish consumption numbers is where the focus group can help; and b) the question of a scientifically defensible fish consumption rate is easier to answer than Goals 1 and 2 as presented in the ‘Goals of the Human Health Focus Group’ hand out.

2. The Planning Group clarified the rationale behind Goals 1 and 2 as originally presented to the Focus Group. Goal 1 presents a theoretical perspective on how changing the fish consumption rate protects public health. Goal 2 presents the real world situation where fish tissue contaminants exists and asks whether those fish tissue contaminants present a public health risk to current fish consumers.

3. The Planning Group asked whether the Goals 1 and 2 as originally presented to the Focus Group, could be answered within the context of the goal proposed by the Focus Group. The Focus Group indicated that it is possible to generally address Goals 1 and 2.

Clean Water Act Water Quality Standards and Goals 1 and 2

1) Focus Group: Is clean water important and why? What does clean water mean for the fish consumption rate discussion?

2) Focus Group: A frequent question of the public is whether the fish are safe to eat.

3) EPA: Water quality criteria are established to protect uses, as a goal for the water body. Uses for this project are fishing and consumption of those fish.

4) Risk in a water quality context vs. risk in a public health context???????????

5) Focus Group suggested an approach whereby the water quality standards goal as measured by fish consumption rate, is related to public health. That is, the criteria equation could be calculated for example chemicals and fish consumption rate combinations to address the relationship between public health risk and fish consumption.

6) Explain the context for the fish consumption rate number. Does it reflect global, national, or regional patterns?

7) The Focus Group indicated that the parameters built in to the criteria equations (e.g., assumptions, uncertainties, strengths and weaknesses) should be explained.

8) Can 1 through 7 be accomplished in the time frame allotted for this focus group? One focus group member indicated that Goal 2 could not be answered.

Fish Consumption Rate

1. The focus group asked if the presumption is to raise the fish consumption rate. EPA and DEQ staff answered in the affirmative.

2. There is an updated regional, national, and international context for fish consumption. A lot of new information exists. Some members indicated the desire for the conversation to reflect the global role of fish consumption.

3. Some focus group members suggested the need for discussion on the assumptions behind published and unpublished fish consumption rate numbers.

4. The applicability of the USDA fish consumption rate study numbers for purposes of Clean Water Act water quality standards was raised.

5. The 17.5 grams per day as not in the realm of reality.

6. The focus group review of the scientific literature needs to acknowledge how the various fish consuming populations for a given fish consumption rate assessment were defined. A population may not represent the cultural differences between cultures.

7. The role of census data for fish consumption rates was raised.

Issues that Impact Fish Consumption Rate

1. The question of how to portray the robustness and consistency of the science to inform the fish consumption rate discussion across the state was raised (implications for the type of fish consumed such as shell fish and other fish).

2. The inclusion of anadromous fish will impact how the focus group reviews the population of fish consumers.

3. The contaminant range across fish species is huge and will potentially impact the EPA guidance????

4. Relative source contribution is a potential issue.

5. The decision on which fish species are in or out may have more of an impact on this project than the fish consumption rate itself.

Process

1. Meetings: Planning Group members will take notes during the Focus Group meetings. The Planning Group will summarize the meeting notes and distribute those notes to the Focus Group for their review. The Focus Group will be given approximately one week to review the meeting summaries. Once the meeting notes are approved they will be posted??????? One conference call and two in face meetings are scheduled between now and the July public meeting???

2. Product 1 Issue Paper: The Planning Group will draft an issue paper that reflects the Focus Groups discussions and recommendations. The issue paper will be reviewed by the Focus Group. The issue paper will include an option(s) to present to the EQC and the scientific rationale (i.e., why it is protective) for that option. The issue paper will seek to document scientific opinion rather than a consensus.

3. Product 2 Presentation: The Focus Group is asked to give a presentation at the July public workshop.

4. Focus group members indicated that it is important to distinguish between the policy and technical issues.

5. The concept of a ‘sign on’ vs. presentation of scientific data in the issue paper was discussed.

Meeting Participants

Jordan P. (ODEQ)

Deb S. (ODEQ)

Patti H. (CRITFC)

Becky L. (EPA)

Kathleen F. (CTUIR)

Ken. K. (OR DHH)

Elaine F. (UOW)

Susan Mc. (URS)

Pat C. (Independent)

Dave M. (WA DHS)

Joan R. (OHSU CROET)

Liz Carr (WA DHS)