1 Persistent Bioaccumulative Toxics in Fish Tissue Emerging Contaminants and Risks to Tribes Dianne Barton – CRITFC and National Tribal Toxics Council
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Persistent Bioaccumulative Toxics in Fish Tissue Emerging Contaminants and Risks to TribesDianne Barton – CRITFC and National Tribal Toxics Council
National Tribal Toxics Council
• An EPA Tribal Partnership Group started in 2012 with Office of Pollution Prevention and Toxics
• National representation
• Encourage the development of national chemical risk management and pollution prevention program policies and procedures that make use of tribal exposures to improve chemical safety for all populations across Indian Country
• Engagement on Toxic Substances Control Act (TSCA) Risk Evaluations
www.tribaltoxics.org
From Integral Consulting “Compendium of State Regulatory Activities on Emerging Contaminants” May 2016
Per- and Polyfluoroalkyl Substances (PFAS)
• PFAS emerged as a concern in the early 2000s• Man made chemicals used in manufacture for
water/stain/oil resistance and coatings
Aqueous FilmForming Foams –fire-fighting
Food packaging
Stain-resistantFurniture
Non-stick cookware
Concerns with Perfluorinated Compounds• Because of our lifeways, Tribes are more
impacted by environmental toxics than any other group in the U.S.
• Primary focus of efforts on PFAS actions are on drinking water supplies
DoD actions “break the exposure pathway”
PFAS National Leadership Summit May 2018
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Washington Ecology monitoring results indicate that PFASconcentrations can persist in fish tissue and top level predators
PFAS Concentration in Freshwater Fish Fillet – Washington Ecology
Tribal Consumption175 grams/day
Tribes are overloaded with the extensive needs to identify PFAS-contamination and remove or clean up the PFAS-contaminated materials. PFAS persists in the environment, moves through soil, and stays in water. Human exposure to PFAS is most likely from consumption of contaminated water or food.
PFAS removal efficiency of some tribal and community water treatment systems differs from advanced water treatment systems. Additionally, many tribes have members that use untreated water for drinking and other household use. EPA should develop guidance appropriate to tribes and rural small communities on whether PFAS monitoring
EPA must quickly develop and implement risk communication strategies specifically for informing tribal communities of potential health risks from all types of PFAS contaminated or PFAS containing media.
Strategies cannot be limited only to drinking water, but also must consider the natural resources that are impacted by PFAS or PFAS-like chemicals, to include the wild foods and their sources whether on land, in sediment, or in fresh water and salt water, including untreated drinking water, as well as consumer products including food packaging.
Exposure Assessments
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There is a need for exposure assessments of PFAS that specifically considers tribal lifeways and resources in order to protect all sensitive subpopulations
Typical Conceptual Model of Exposure to Conaminants in the Environment
LooksOutdoorsy
ActuallySuburban/RecreationalExposures
Harris & Harper
Pesticides~2000 Chemicals of Active IngredientsRegulated by EPA
Requires experimental data
Drugs, Cosmetics, Food
Additives~2,000 Active Ingredients
Food & Drug Administration
Requires experimental
data
Toxic Substances Control Act
(TSCA) regulatesIndustrial Chemicals
~82,000 ChemicalsAllowed in U.S.
commerce
U.S. Chemical Universe
95%
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From - Bloomberg Environmental October 2, 2018
TSCA reforms – June 22, 2016• Risk evaluation is required to focus on potential
risk to human health and the environment including susceptible subpopulations.
• Significant preemption of state authority to restrict the use of high-priority chemicals.
• States would be able to implement regulations that cover a different scope related to the use or affected populations of a studied chemical.
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Tribes and Amended TSCA
For environmental exposures, tribes may constitute a sentinel of susceptible subpopulation risk
Current TSCA Actions on PBTs• Risk Evaluations of the first ten chemicals
drawn from the 2014 Work Plan List by December 2019– NTTC submitted comments on August 16, 2018
• Expedited Regulatory Action without risk evaluation on 5 PBTs– NTTC submitted comments to Agency peer review
on July 23, 2018
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Cyclic Aliphatic Bromide Cluster (HBCD)
• Primary use (95%) of HBCD is as a flame retardant in rigid foam insulation boards. Past uses include textiles, electronics, refrigerator linings, and adhesives.
• Listed as a persistent organic pollutant under the Stockholm Convention in 2013.
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In 2014, EPA published a DfE report on a butadiene styrene brominated copolymer alternative for building insultation foam
Persistent, Bioaccumulative and Toxic
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From: Screening Assessment Report on HBCD – Environment Canada Health Canada (November 2011)
Current Use
• HBCD production is declining in the US, but products remain in use that will need to be removed, reused, disposed of or recycled.
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Building/Construction Uses Remain
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Central Tendency or Sensitive
Population?
Groundwater not
consideredDo consumption
rates reflect recreation or subsistence?
Burning of construction waste is not considered
“Legacy” products remain in use
From: Problem Formulation for Cyclic Aliphatic Bromides Cluster (HBCD), EPA, May 2018.
High-End of General Population Exposure is not Protective of a Sensitive Subpopulation
• 2010 Exposure Assessment of PBDE
– “unusually high exposures at the high end of the general population” – susceptible sub-population
– 95th percentile 291 ng/g versus mean 31 ng/g in adults – “even the highest dust concentrations might not be able to explain”
– “suggests the possibility that there are other exposures not identified in this assessment”
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Tribal lifestyles are not just the extreme tail of a general population exposure range
*See accompanying Possible Tribal Exposures Scenario Table for further details.
EXPOSURE MEDIA
PATHWAYS
EXPOSURE ROUTES
EFFECTS
Dermal:Absorption/ Adsorption
Ingestion
RISKS:CHRONICACUTECUMULATIVE
AIR:• Air• Vapor• Particulate
MatterDUSTDEPOSITED PARTICULATE MATTERWATER: • Drinking Water• Surface Water• Ground Water
including untreated water
LOCALLY OBTAINED:• Food, • Animal Fats, • Ceremonial
Plants• Water SourcesSOILSEDIMENT
Mouthing
Possible Tribal Exposures Conceptual Model
PERSONAL EXPOSURES• Home Products• Building Supplies• Transportation specific
to the region (ATVs, snow machines, small airplanes, boats, open air vehicles, railroad)
• Boat docks• Children’s products &
toys
Non-industrial use of products
Chemical and Physical Manufacture
Processing
Examples of traditional and
customary sustenance and
activities:
• Gathering, Processing & Consuming: fish, wildlife, including large land and marine mammals, other wildlife including bird and eggs, other marine life, many forms of plants, untreated water
• Steam baths and sweat lodges
• Crafting, jewelry-making, basketry
• Cultural practices like smudging
• Mouthing• Ingestion• Et cetera*
Tribesx 7
Generations
COMMUNITY EXPOSURESDisposal methods:• Unlined landfills and
sewage lagoons• Untreated wastewater• Open burning• Recycling • ReusingBystander
GENETIC SUSCEPTIBILITYGREATER EXPOSURE
Injection
Commercially Available Foods (FDA-regulated)
OCCUPATIONAL EXPOSURES• Products• Processes• Creating Arts,
Crafts, Jewelry, Regalia, Medicine
Non-edible Consumer Products
National Tribal Toxics Council, June 2018
Inhalation
SOURCES
Tribal Lifeways
Draft version as of 06/22/2018
TRIBAL LIFEWAYS
EXPOSURE SCENARIOS
Miigwech