BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols
Posted by Alexander Higgins - July 25, 2010 at 7:04 pm - Permalink - Source via Alexander Higgins Blog
Loading ...As the Huffington Post points out in its post “Gulf Fisheries Opened: Safe Or BP Politics, PR and “Sock Puppetry?” the Federal Government has decided to open over 26,000 square miles of the Gulf of Mexico affected by the BP Gulf Oil Spill.
Dr. Jane Lubchenco, NOAA Administrator, announced the re-opening of a substantial portion of the southeast section of the closed fishing area in Gulf of Mexico federal waters at a press conference on Thursday. NOAA reopened 26,388 square miles of Gulf waters to commercial and recreational fishing at 6 p.m., EDT Thursday. This opening was decided upon after “consultation with the FDA and under a re-opening protocol agreed to by NOAA, the FDA, and the Gulf states,” Lubchenco said.
At its closest point, the area to be reopened is about 190 miles southeast of the Deepwater/BP well-head, and the area where the majority of fishing will occur is about 220 miles from the well-head, along the west Florida shelf.
This is a notable development, coming on the heels of Senator Barbara Mikulski’s (D-Maryland) July 15 hearings on BP’s use of almost 2 million gallons of dispersants on the oil released from the April 20 explosion of the Macondo well-head in the Mississippi Canyon oil field. Mikulski’s hearing raised many questions regarding oversight, accountability and reliability of scientific data.
The bottom line for those who don’t like to do a lot of reading is the fish samples that NOAA has collected from the area it has chosen to reopen are contaminated.
NOAA Seafood Samples For 7/22 Fisheries Reopening
That means that thousands of people who chose to eat seafood from the Gulf of Mexico could die because the Federal Government has decided that in the grand scheme of things economic considerations are far more important than a few thousands of people dying.
As if it weren’t already bad enough that the Government is misleading the public about the safety of public beaches and lying about water samples to save BP billions the Government has now decided to implement a variety of methods including sidestepping protocols and has implementing a variety of methods to skew the test data used to justify the reopening the waters to fishing.
- Protocol requires that there be no oil on the surface or in the water column but the Federal Government has chosen to reopen the waters based solely on based on visual observations of no oil on the surface. It has not conducted any testing to confirm the surface and the water column are free of oil. Since it has already been proven there are huge plumes of methane and oil in the water column NOAA should confirm the waters are oil free by testing for the presence of hydrocarbons and has not done so.
- The protocol calls for the collection and testing of at least 10 samples of each species from the most common fishing grounds. Instead NOAA has chose to perform sampling at selected locations in two main areas that are not representative of the entire area to be reopened. Furthermore it has collected only one or two samples for most of the 12 species of fish it has chosen to test.
Even if NOAA chose to follow its own guidelines guidelines they are only adequate in ensuring the safety of seafood during a surface spill. Those guidelines do not take into account that in a Deepwater spill as little as two percent of the oil and almost none of the methane released in this spill may have actually made it to the surface.
As can clearly can be seen in the deepwater oil spill plume simulation below very little oil actual makes it to the surface and the rest remains submerged in the water column. In the open ocean a little bit of wave action can disperse the oil on the surface making it invisible to the naked eye while the plume remains submerged.
Deepwater Oil Spill Plume Simulation
Furthermore while NOAA claims there has been no visual observations of oil within the area to be reopened in the last 30 days many other sources tell us there has been oil in the area.
ROFFS BP Gulf Oil Spill Tracking Map For June 24 to June 27th with WOM (Water Oil Mixture) Outlined
Besides violating protocol by reopening of the closed fishery areas is based on “visual observations” of no oil on the surface instead of actually testing for oil in the water column NOAA has not followed the established protocol for testing the seafood.
NOAA tested only 52 samples of fish taken from only very few locations within the area that was previously closed and even then it performed only one or two tests on most species not the 10 samples per species from each of the most popular fisheries as the protocol requires.
NOAA’s Seafood Sample Locations Are Not Representative Of The Entire Area Being Reopened.
NOAA BP Gulf Oil Spill Fishery Reopening Fish Contamination Sample Locations
BP Gulf Oil Spill Fisheries Reopened Inset
Just to be clear to show how sparse the NOAA samples are I wrote this application to show the locations that the actual NOAA fish samples were taken from and to show the results of each of the tests.
Using that application here is a break down of the samples NOAA tested showing just how inadequate the fish testing was and the clear violation of the protocol requiring 10 samples of each species be tested from all of the popular fishing locations in the area to be reopened.
Only 2 Grey Tilefish Samples Tested, Both From The Same Location
Only 1 Amberjack Sample Tested
Only 2 Red Grouper Samples Tested, Both From The Same Location
Only 1 Escolar Sample Tested
Only 3 Snowy Grouper Samples Taken, All In The Same Area
Only 2 Yellow Mouth Grouper Samples, Both In The Same Area
Only 1 Queen Snapper Sample Tested
Only 5 Blackfin Tuna Samples Tested
24 Yellowedge Group Samples Tested, Both In The Same Area
On top of the protocols the Government is sidestepping a number of questionable methodologies have been used to justify reopening the water to fishing.
- NOAA has chosen to use a risk of cancer threshold of 1 in 100,000 were many toxicity guidelines call for 1 in a million. Such a low threshold could potentially lead to thousands of cancer cases.
- The guidelines only consider the risk of cancer from contamination and fail to include risk assessments for other chronic illnesses that can be caused by oil and dispersants such as internal hemorrhaging , kidney failure, and damage to other internal organs.
- The decision to reopen the waters was done with out any testing for the neurotoxin pesticide dispersant Corexit that BP has been spraying into the Gulf. To be fair the Government is not testing any seafood harvested from the Gulf for exposure to Corexit. On the other hand NOAA has admitted that Corexit may be in Gulf Seafood.
- The Government only requires that 70% of the seafood tested to pass the smell and taste test for oil meaning that 30% of the seafood can contain oil odors or flavors and still pass the test.
- The protocol allows for samples from multiple fish to be combined into a single sample for testing. While this may allow for an accurate statistical analysis of the risk of cancer to the entire population it does not ensure that the fish are not contaminated.
Test Protocols allow for samples from different fish to be combined into single sample. This allows contaminated fish to enter the market that would otherwise fail testing if samples were not allowed to be combined.
Sample Level of Contamination Fish #1 1 part million (FAIL) Fish #2 0 parts million Fish #3 0 parts million Fish #4 0 parts million Fish #5 0 parts million Fish #6 0 parts million Fish #7 0 parts million Fish #8 0 parts million Fish #9 0 parts million Fish #10 0 parts million Failure Level 1 Part per million Average of All Samples .1 Part per million Result Pass Using the hypothetical table above 10 different fish are combined into a single sample.
If the tissue from different fish weren’t allowed to be combined the first fish would caused the entire sample to fail.
However by mixing the single contaminated fish with 9 non contaminated fish the test results are lowered and the sample passed because the average of the entire group is used.
Another way to think of it is you have a classroom of 10 kids and for each kid that fails a test one person will die.
While the average test score of the whole class gives a good statistic on how many people will die we could prevent all deaths by not allowing any students to fail.
- Instead of establishing a raw baseline for contamination and reporting the level of contamination measured in parts per million the Government has used variety of statistical methods to skew the test results. The only number the Government provides from the test result is called called level of concern or LOC and even that number is is “adjusted” using a “toxic equivalency factor”. The final LOC is then calculated using a number of variables including “the risk level”, the average consumer body weight, “the averaging time (i.e. life expectancy)”, “a unit conversion factor”, “cancer slope factor”, “the average daily amount of seafood consumed”, “assumed exposure duration”.
- With the risk factor being within 1 in 100,000 risk for cancer threshold for some one with a body weight of 176 lbs anyone who weighs less, has other factors that decrease life expectancies or eats more than “the average daily amount of seafood consumed” the risks of cancer are much higher.
Here is the NOAA advisory of the fishery openings.
BP Oil Spill: NOAA Re-opens Previously Closed Portions of the Gulf of Mexico to Commercial and Recreational Fishing
Effective July 22, 2010 at 6 p.m. eastern time (5 p.m. central time), NOAA will reopen 26,388 square miles (68,345 sq km) of area it had previously closed to commercial and recreational fishing in the Gulf of Mexico in response to the BP/Deepwater Horizon oil spill. All commercial and recreational fishing including catch and release is prohibited in the remaining closed area; however, transit through the area is allowed.
NOAA BP Gulf Oil Spill Fishery Reopening
The closed area now measures 57,539 sq mi (149,026 sq km) and covers about 24% of the Gulf of Mexico exclusive economic zone. Before the southern area was re-opened, 83,927 miles (217,371 sq km), or roughly 35% of federal waters of the Gulf, were closed to fishing. NOAA will continue to evaluate the need for fisheries closures based on the evolving nature of the spill and will re-open closed areas as appropriate.
The re-opened area was originally closed as a precaution, because light oil sheen that had been observed in the northeastern Gulf was projected to enter the loop current and move south. Since mid-June, NOAA data has shown no oil in the area, and United States Coast Guard observers flying over the area in the last 30 days have also not seen any oil. Trajectory models show the area is at a low risk for future exposure to oil. NOAA collected 52 samples of fish from this area, including commercially and recreationally important species. Sensory testing showed no detectable oil or dispersant odors or flavors in the samples, and the results of chemical analysis were well below levels of concern.
NOAA continues to work closely with the U.S. Food and Drug Administration and the states to ensure seafood safety, by closing fishing areas where tainted seafood could potentially be caught, and assessing whether seafood is tainted or contaminated to levels that pose a risk to human health. NOAA and FDA are working together to sample seafood from inside and outside the closure area, as well as dockside- and market-based sampling.
The closed area is bounded by rhumb lines connecting, in order, the following coordinates:
North latitude West longitude At state/federal line 85o 29′ 28° 23′ 85° 55′ 28° 19′ 85° 30′ 27° 00′ 85° 30′ 27° 00′ 86° 23′ 27° 39′ 89° 50′ 27° 35′ 90° 33′ 28° 36′ 91° 08′ 28° 36′ 91° 32′ 28° 58′ 91° 40′ 29° 31′ 93° 36′ At the state/federal line 93° 30′ Follow the state/federal water line easterly to beginning point
NOAA gave the following justifications for re-opening the fishing areas in a letter to the EPA, FDA and other relevant Government organizations.
Decision
In accordance with the Protocol for Interpretation and Use of Sensory Testing and Analytical Chemistry Results for Re-Opening Oil-Impacted Areas Closed to Seafood Harvesting (the Re-opening Protocol) (see attachment 1), and after an extensive consultation between the FDA and NOAA, we have concluded that approximately 26,388 square miles, or 11 percent of Federal waters in the Gulf and 32 percent of the current closed area, of the current federal fishery closed area will be re-opened, the hatched area on the map of the closed area (see attachment 2). The area to be re-opened (Area A) lies southeast of the area bounded by the coordinates: 28°19’0″N / 85°30’0″W, 27°0’0″N / 85°30’0″W, and 27°0’0″N / 86°23’0″W.
Background
From May 18 through June 02, 2010, Area A was progressively closed to fishing as a precautionary measure. Surveillance of the area observed reflections on the surface of the water in Area A from around May 18 through June 15, 2010. The reflections may have been from light sheen, algal blooms, sargassum, or other naturally occurring water features. In addition, offshore trajectory forecasts at that time projected that oil might be pulled into the loop current and quickly spread through this area. We now have evidence that the oil in the vicinity of Area A actually became entrained in a circular current in the middle of the Gulf and remained there. Oil never spread through Area A because in early June the loop current shifted far to the south and has not shifted back to the north through the center of the Gulf. The last confirmed sighting of oil in Area A occurred on June 15th. NOAA data demonstrating the absence of oil in Area A since June 15th has been further corroborated by the United States Coast Guard (USCG) based on observations from over flights they have performed since then. In accordance with the Re-opening Protocol, NOAA conducted sampling in the portions of Area A most likely to be fished. All of the samples met the safety requirements contained in the Re-opening Protocol.
Discussion
We have determined that the four specific re-opening criteria in the re-opening protocol are met in this case.
- Low threat of exposure – We have reviewed the most recent data and confirmed by visual observation and aerial reconnaissance that Area A is currently free of sheen on the surface. We have confirmed with NOAA and the USCG that there is no surface sheen in Area A as a result of the Deepwater Horizon incident, and that there has been none in the area for more than 30 days.
- Evaluation of oil movement – An analysis by NOAA’s trajectory modeling experts shows that Area A is at a low risk or threat to be exposed to future re-oiling based on present conditions. We have confirmed this with NOAA’s trajectory modelers, and reviewed their analysis of the overall oil and ocean conditions. We have concluded that there is a low risk or threat that Area A will be exposed to future re-oiling based on present conditions.
- Assessment of seafood contamination by sensory testing – In accordance with the methodology and procedures set forth in the re-opening protocol, NOAA analysis of samples taken from the proposed reopening area found no detectable oil or dispersant odors or flavors during sensory analysis.
- Assessment of seafood contamination by chemical analyses – In accordance with the methodology and procedures set forth in the re-opening protocol, NOAA analysis of samples taken from the proposed reopening area for chemical analysis were found to be well below the levels of concern contained in the re-opening protocol.
In summary, a small portion of the proposed reopening area may have been lightly oiled, however, the vast majority of the area was never oiled, and the entire area has been oil free for more than 30 days. NOAA collected and tested finfish samples from the area from June 23 through July 5, 2010, with the last group of samples completing testing on July 14, 2010. The sampling was concentrated in areas where fishing is most likely to occur. These samples have all undergone the required sensory and chemical analysis and all the samples have passed in accordance with the safety criteria in the Re-opening Protocol. Attachment 3 provides a map showing the location of the samples collected. Attachment 4 provides the testing results for both the sensory and chemical analysis.
Conclusion
Area A was closed primarily as a precautionary measure due to the occurrence of lightly patches of sheen within the area; the potential of oil to spread rapidly throughout the area, which did not occur; and concerns that the loop current might play a role in the transport of oil through Area A during the late May to mid-June timeframe. The loop current, however, did not in fact transport oil through Area A.
All samples tested from Area A were well within the established public safety levels of concern in the Re-opening Protocol, with no detectable odors or flavors of contamination, and all testing was done in accordance with the Re-opening Protocol.The fisheries in the area with commercial or recreational significance are primarily pelagic highly migratory species such as tuna, marlin, and mahi mahi (dolphinfish), as well as reef fish such as grouper and porgy. Scientific studies from previous spills indicate that these finfish quickly metabolize and eliminate the harmful chemicals (polycyclic aromatic hydrocarbons) that could taint or otherwise contaminate seafood, as noted in attachment 5, the memo from Dr. John Stein Deputy Director of the Northwest Fisheries Science Center.
Therefore, NOAA and FDA agree that based on the oil-free surface conditions of the area now, and the successful results of the sensory and chemical testing, Area A, the hatched area shown in attachment 2, should be re-opened to commercial and recreational fishing.
The protocols violated by NOAA for reopening fishing waters affected by an oil spill are outlined below.
Oil contamination presents two kinds of risks: the presence of petroleum taint that renders seafood unfit for human consumption, and the presence of polycyclic aromatic hydrocarbons (PAHs) that are chemical hazards. Federal government and state agencies therefore close oil-contaminated harvest areas for health reasons.
Oil-contaminated seafood is adulterated if the contamination is perceivable by olfaction (taint), or in the absence of taint, chemical analysis determines that the level of PAHs in it exceeds FDA levels of concern. Consequently, after an oil spill, seafood suspected of oil contamination can only be brought into interstate commerce when it passes both sensory testing for petroleum taint, and chemical analysis for PAHs.
To date, available information indicates that the dispersants being used to combat the oil spill do not appear to accumulate in seafood and therefore, there is likely little public health concern from them due to seafood consumption. However, as per this protocol, sensory testing and further work to identify component compounds in known exposed fish will be conducted for dispersants.
The purpose of this protocol is to specify how the results of sensory testing and chemical analyses will be used in re-opening seafood closure areas. The principles of the protocol are as follows:
Generally:
- The closure of a fishery assumes a worst case scenario, and is intended to protect seafood consumers until the safety of the seafood can be established.
- Area re-opening will be based on an acceptable reduction of the threat of seafood exposure to oil contamination, and analyses that assure the safety and
wholesomeness of the seafood.- Once seafood samples from an area pass sensory testing, area samples must also pass chemical analysis for PAHs before that fishery may be re-opened.
- Re-openings may be fisheries specific.
- Opening boundaries will be based on results of analyses (sensory and chemical) that demonstrate the product is untainted and safe for human consumption.
Specific Re-opening Criteria:
- Low threat of exposure – Threat of exposure will be based on past observations and the status of the spill and conditions.
- Evaluation of oil movement – Confirmation that the closure area is free of sheen on the surface by visual observation and/or aerial reconnaissance, or the presence of oil in the water column through visual observation or water testing.
- Assessment of seafood contamination by sensory testing – Determine if the seafood is contaminated by tissue collection and sensory testing. The acceptable condition is that all specimens must pass sensory testing conducted by a NOAA-FDA expert sensory panel or a NOAA-FDA trained panel of state assessors.
- Assessment of seafood contamination by chemical analyses – Chemical analyses are performed on samples that pass sensory assessment to confirm that PAH concentrations are below the applicable FDA levels of concern for human health. Final determinations may take into consideration what is known regarding relevant background information for specific harvest areas.
…
For a closed fisheries area to be considered for re-opening, the following criteria must be met (these criteria are based on past oil spill information and ensure a high confidence level that the seafood is not tainted by oil:
- A minimum of seventy percent (70%) of the expert assessors must find NO detectable petroleum or dispersant odor or flavor from each sub-sample. If any sub-sample fails, the sample location fails.
- All contiguous stations or sample locations must pass for an area to open.
If the area passes the sensory test then samples will undergo chemical analyses. Samples must then pass chemical analyses for PAHs before the area may re-open.
Criteria for Chemical Analyses
For crabs specifically, a sample of edible muscle from a minimum of ten (10) individuals, of legal size if available, should be collected from each sampling location. Tissue samples from individual crabs will be combined to make separate composite samples of the muscle tissue. For all other seafood, a sample of edible tissue from a composite (of at least 200 grams) from a minimum of 10 or more individuals collected at or near the locations specified is required. All samples should be collected from sites selected as commonly used fishing grounds or normally harvestable molluscan shellfish bed.
Levels of Concern (ppm)
Chemical1 (Shrimp and Crabs)
13 g/day(Oysters)
12 g/day(Finfish)
49 g/dayBasis Naphthalene 123 133 32.7 Non-cancer EPA RfD2; 80kg bw Fluorene 246 267 65.3 Non-cancer EPA RfD2; 80kg bw Anthracene/Phenanthrene 1846 2000 490 Non-cancer EPA RfD2; 80kg bw Pyrene 185 200 49.0 Non-cancer EPA RfD2; 80kg bw Fluoranthene 246 267 65.3 Non-cancer EPA RfD2; 80kg bw Chrysene 132 143 35.0 Cancer 0.001 BaP equivalent3 Benzo(k)fluoranthene 13.2 14.3 3.5 Cancer 0.01 BaP equivalent3 Benzo(b)fluoranthene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Benz(a)anthracene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Indeno(1,2,3-cd)pyrene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Dibenz(a,h)anthracene 0.132 0.143 0.035 Cancer 1.0 BaP equivalent3 Benzo(a)pyrene 0.132 0.143 0.035 10-5 Cancer risk = (0.110 μg/person/day)(78/5 yr)3
Here are the Government protocols for reopening waters affected by the BP Gulf Oil Spill for fishing.
PROTOCOL FOR INTERPRETATION AND USE OF SENSORY TESTING AND ANALYTICAL CHEMISTRY RESULTS FOR RE-OPENING OIL-IMPACTED AREAS CLOSED TO SEAFOOD HARVESTING
INTRODUCTION
The U.S. Food and Drug Administration (FDA) operates a mandatory safety program for all fish and fishery products under the provisions of the Federal Food, Drug and Cosmetic Act, the Public Health Service Act and related regulations. Actions and criteria discussed in this protocol should be followed in addition to the provisions already in place. The National Oceanic and Atmospheric Administration (NOAA) has the authority to close and open Federal waters for seafood harvest and operates the Seafood Inspection Program providing the agency seafood safety and quality expertise. After an oil spill has occurred, Federal and State agencies are faced with the issue of determining when the seafood from the previously contaminated area may once again be safe for harvest and human consumption. NOAA Office of Response and Restoration (OR&R) publication entitled Managing Seafood Safety after an Oil Spill1 provides agencies guidance in such situations. This guidance and other input from both NOAA and the FDA have been used in consultation with the Environmental Protection Agency (EPA) and the Gulf Coast States to establish this protocol. This protocol is applicable to the re-openings of commercial and recreation fisheries in both federal and state waters.
In establishing this protocol it is important to understand the following principles:
- • NOAA and the FDA are working with other federal and state agencies to protect consumers from adulterated and unsafe seafood, while minimizing undue economic burden on any impacted seafood industries.
- • Once oil or chemical contaminants are visually observed on the surface, it is recommended that the fishery be closed until free of sheen, and subsequent testing has been completed to confirm that seafood from affected areas are wholesome and safe for human consumption and use in animal feed.
- • After the initial fishery closure, the best approach for determining the safety and acceptability of seafood from oil-contaminated areas is one that involves organoleptic analysis of products (i.e. sensory testing) followed by chemical analysis.
- • Fishery closure areas also include areas that NOAA projects will have surface oil and a precautionary buffer zone around known contaminated waters to account for uncertainty. After confirming through subsequent evaluation that oil did not enter an area, the area may be re-opened without subjecting seafood samples to evaluation under this protocol. This protocol is an added layer of protection being applied to seafood only in areas known to have been contaminated.
Oil contamination presents two kinds of risks: the presence of petroleum taint that renders seafood unfit for human consumption, and the presence of polycyclic aromatic hydrocarbons (PAHs) that are chemical hazards. Federal government and state agencies therefore close oil-contaminated harvest areas for health reasons.
Oil-contaminated seafood is adulterated if the contamination is perceivable by olfaction (taint), or in the absence of taint, chemical analysis determines that the level of PAHs in it exceeds FDA levels of concern. Consequently, after an oil spill, seafood suspected of oil contamination can only be brought into interstate commerce when it passes both sensory testing for petroleum taint, and chemical analysis for PAHs.
To date, available information indicates that the dispersants being used to combat the oil spill do not appear to accumulate in seafood and therefore, there is likely little public health concern from them due to seafood consumption. However, as per this protocol, sensory testing and further work to identify component compounds in known exposed fish will be conducted for dispersants.
The purpose of this protocol is to specify how the results of sensory testing and chemical analyses will be used in re-opening seafood closure areas. The principles of the protocol are as follows:
Generally:
- 1. The closure of a fishery assumes a worst case scenario, and is intended to protect seafood consumers until the safety of the seafood can be established.
- 2. Area re-opening will be based on an acceptable reduction of the threat of seafood exposure to oil contamination, and analyses that assure the safety and wholesomeness of the seafood.
- 3. Once seafood samples from an area pass sensory testing, area samples must also pass chemical analysis for PAHs before that fishery may be re-opened.
- 4. Re-openings may be fisheries specific.
- 5. Opening boundaries will be based on results of analyses (sensory and chemical) that demonstrate the product is untainted and safe for human consumption.
Specific Re-opening Criteria:
- 1. Low threat of exposure – Threat of exposure will be based on past observations and the status of the spill and conditions.
- 2. Evaluation of oil movement – Confirmation that the closure area is free of sheen on the surface by visual observation and/or aerial reconnaissance, or the presence of oil in the water column through visual observation or water testing.
- 3. Assessment of seafood contamination by sensory testing – Determine if the seafood is contaminated by tissue collection and sensory testing. The acceptable condition is that all specimens must pass sensory testing conducted by a NOAA-FDA expert sensory panel or a NOAA-FDA trained panel of state assessors.
- 4. Assessment of seafood contamination by chemical analyses – Chemical analyses are performed on samples that pass sensory assessment to confirm that PAH concentrations are below the applicable FDA levels of concern for human health. Final determinations may take into consideration what is known regarding relevant background information for specific harvest areas.
ANALYSIS
- 1. NOAA sensory testing protocol reviewed by FDA2, 3.
- 2. When sensory tested samples are acceptable, verify sensory testing outcomes with chemical analyses performed using the NOAA PAH method4.
ADDITIONAL INFORMATIVE DATA
Additional investigation protocols may be designed and used to assess water and sediment contamination, toxicity testing, ecological injury and other environmental parameters. These investigations are not directly related to or considered a part of this protocol, but can be extremely informative in the overall determination process. Data from these investigations will be reviewed prior to making any decisions to re-open an area or a fishery and may be the basis for requiring additional sampling/analysis as per this protocol. For example, sediment chemical data from fishery areas may be used to identify contaminant “hot spots.” Water column data, toxicity test results and other data, required of BP or generated by federal (e.g. EPA) or state agencies, are among the various data that may be considered for any re-opening determination.
Water analysis for PAHs may be used to gain an understanding of the effectiveness of the containment and cleanup of the spill. Toxicity testing of water column or sediment samples for oil and dispersant related contaminants can also provide important insights on impacts to other biota. Such water analysis should be performed on representative samples of the affected water column. In addition water and tissue analysis may be used to determine any residual concentration of the dispersants used. The necessary sampling criteria will be based on many factors including the area of the closure, depth of the water within the closure, and sites and species considered for re-opening of harvest areas or fishery. With regard to inshore fisheries such as molluscan shellfish, sediment samples may also be analyzed.
Surveillance of fisheries should be conducted in response to identified “hot spots” or other relevant changes in environmental conditions (e.g., increases in PAH levels in water or seafood) if warranted, based on the protocol defined.
RE-OPENING PROCESS
NOAA, in consultation with FDA, will review the data generated as a result of the implementation of this protocol in federal waters, evaluate the accuracy and quality of the data and assess compliance with the agreed criteria. Based on this assessment NOAA may re-open federal waters subject to the closure. NOAA and FDA will coordinate with State agencies for the re-opening of State commercial waters to ensure orderly and appropriately enforced re-openings. No partial re-openings will be allowed which are unenforceable, i.e., requiring harvesters to segregate their catch and discard catch from fisheries that remain closed.
Sensory testing based on NOAA Technical Memorandum NOS OR&R 9: Guidance on Sensory Testing and Monitoring of Seafood for Presence of Petroleum Taint Following an Oil Spill2 will be utilized. A panel of ten expert assessors from NOAA and/or the FDA, and state agencies if available, will conduct sensory testing. Samples will be examined by organoleptic methods both in the raw and cooked states. If samples from a particular fishery pass sensory testing within a defined sampling area, chemical analyses will be performed on representative samples from that same fishery and area4. If chemical analyses pass the risk based assessment criteria for the species in question, that zone will be considered for re-opening. If samples from an area fail sensory testing a determination will be made as to when retesting will occur taking into consideration the conditions of the fishery and the failure results.
SELECTION OF TARGET PAHs and LEVELS OF CONCERN
Most petrochemical products such as diesel oil and crude oil contain aromatic components: mono-, bi-, and polycyclic aromatic hydrocarbons. Well-established liquid chromatography (LC)/fluorescence detection (FD) and gas chromatography (GC)/mass spectrometry (MS) methods are used to separate and quantify these contaminants in seafood.
PAHs are abundant in our environment; in addition to sources from petrochemical products they are generated by nearly all pyrolytic processes including forest fires, char-grilled and smoked meat, and fuel combustion in automobiles. Crude petroleum is composed of a complex mixture of many hundreds of compounds. Most of the compounds are volatile, and evaporate to produce the pungent odor of petroleum. Others are less volatile and persist in the environment (e.g. formation of tar balls or sink to the bottom). The PAHs in petroleum mixtures are of greatest concern for human health because of their persistence (i.e. lower evaporation rates), and their potential for toxic or carcinogenic effects. The subset of 12 PAHs and their alkylated homologues selected for critical analysis in the Deepwater Horizon Spill (Table I) are among the most studied PAHs in petroleum mixtures. These compounds have been found to reflect the potential for toxic or carcinogenic effects of the mixture of compounds present in crude petroleum5 based on experience with previous oil spills (e.g. North Cape Oil Spill, 1996, Rhode Island).
Most seafood risk assessments conducted after oil spills in the U.S. have followed an approach used by the FDA in 1990 after the Exxon Valdez oil spill in Prince William Sound, Alaska6, 7. This approach uses a set of calculations to determine seafood (harvested for human consumption) PAH tissue concentrations, expressed in benzo[a]pyrene (BaP) equivalents (μg/kg), above which an appropriate, conservatively estimated upper-bound risk level for cancer is exceeded. Levels of concern for non-cancer risks are also evaluated. The values for several variables in these calculations can be adjusted on a case-by-case basis, depending on seafood consumption rates of the exposed population, average body weight of the exposed population, estimates of exposure time for a particular spill, and the cancer risk level deemed appropriate. This approach to calculating seafood advisory levels has been used after several other oil spills, including the North Cape spill in Rhode Island, the Julie N spill in Maine, the Kure spill in California, and the New Carissa spill in Oregon.
The level of appropriate risk is the maximum level of individual lifetime carcinogenic risk that is considered appropriate by risk managers. The relative risk level to be used for low dose cancer risk calculations is 1 x 10-5. This implies that exposure to PAH in seafood below a specified tissue concentration, at a defined consumption rate, and over a defined exposure period would yield a lifetime cancer risk of no greater than 1 in 100,000. A risk level of 1 x 10-5 was used in the risk assessment conducted by the State of Maine for the Julie N oil spill and the State of Alaska for the Kuroshima oil spill1.
Depending upon levels of petrogenic PAHs accumulated by aquatic species, consumption of petroleum contaminated fishery products may pose a health risk to seafood consumers. The risk is considered higher for high-level consumers of fishery products. These concerns necessitate consideration of consumption rates for high-level consumers of fish, shrimp, crab and oysters. FDA uses the 90th percentile of national consumption data from the National Health and Nutrition Examination Survey (NHANES) for fish, shrimp, crab and oysters for calculating risk of PAH exposure in high-level consumers of seafood products. To determine an appropriate fish consumption rate for high-level consumers, FDA adjusted the 90% meal size to account for the number of meals eaten by a 90th percentile consumer.
Table I shows the criteria for re-opening based upon non-cancer risks and a 1 x 10-5 cancer risk for different PAHs. For the non-cancer evaluation (naphthalene, fluorene, anthracene, phenanthrene, pyrene, and fluoranthene) the EPA Integrated Risk Information System (IRIS) reference dose (RfD) values were used8-13. For the cancer evaluation (chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benz(a)anthracene, indeno(1,2,3-cd)pyrene, dibenz(a,h)anthracene, and benzo(a)pyrene), the EPA IRIS BaP equivalence (BaPE) values were used14. The EPA IRIS cancer slope factor for BaP was also used. As discussed above, 90th percentile consumption values were used for generating calculations for average daily consumption rates of shrimp and crabs, oysters and finfish for consumers only. For generating cancer risk values, exposures are assumed to last for 5 years.
Recent results from PAH chemical analysis of finfish (grouper, red snapper and red drum) collected by NOAA from the unaffected Dauphin Island area in early May 2010 show PAH concentrations to be below the levels of concern shown in Table I. An evaluation of PAH chemical analysis data collected by the NOAA mussel watch program showed that in 2007-2008 average concentrations were below FDA levels of concern in oysters in commercially harvestable areas.
Final determinations for opening oil spill affected fisheries and areas may take into consideration available PAH background level data and assumptions on duration of exposure.
Criteria for Sensory Testing
A minimum of 6 sub-samples per species (3 sub-samples for oysters) from each sample location in the area under consideration for re-opening must be tested. A sub-sample will consist of an individual organism for legal size finfish and multiple organisms for shrimp and shellfish, depending on the intact animal type (e.g. 3 to 6 blue crabs, 6 oysters, 0.4 – 0.5 lb shrimp). The samples will be evaluated by a panel of a minimum of 10 expert assessors in the raw and cooked state. Samples will be evaluated first for raw odor, then cooked odor, then cooked flavor in that order. If at any time the analyst finds detectable petroleum or dispersant, the analyst will not further evaluate the sample.
For a closed fisheries area to be considered for re-opening, the following criteria must be met (these criteria are based on past oil spill information and ensure a high confidence level that the seafood is not tainted by oil):
- • A minimum of seventy percent (70%) of the expert assessors must find NO detectable petroleum or dispersant odor or flavor from each sub-sample. If any sub-sample fails, the sample location fails.
- • All contiguous stations or sample locations must pass for an area to open.
If the area passes the sensory test then samples will undergo chemical analyses. Samples must then pass chemical analyses for PAHs before the area may re-open.
Criteria for Chemical Analyses
For crabs specifically, a sample of edible muscle from a minimum of ten (10) individuals, of legal size if available, should be collected from each sampling location. Tissue samples from individual crabs will be combined to make separate composite samples of the muscle tissue. For all other seafood, a sample of edible tissue from a composite (of at least 200 grams) from a minimum of 10 or more individuals collected at or near the locations specified is required. All samples should be collected from sites selected as commonly used fishing grounds or normally harvestable molluscan shellfish bed.
Contaminant Levels in Fish and Shellfish Tissue that Pose No Significant Risk
The safety of commercial seafood is generally determined by comparison of tissue contaminant concentrations to FDA levels of concern. Risk-based criteria to establish the safety of commercial or recreational fish and shellfish following an oil spill were developed using standard FDA and EPA risk assessment methods, as described below.
Cancer Risk
In order to interpret the cancer risk for individual PAH compounds likely to be found in the Gulf of Mexico light crude petroleum, the carcinogenic activity relative to benzo(a)pyrene (BaP) is estimated as a toxicity equivalency factor (TEF)8. TEFs for chrysene, benzo[k]fluoranthene, benz[a]anthracene, indeno[1,2,3-cd]pyrene, benzo[b]fluoranthene, and dibenz[a,h]anthracene are 0.001, 0.01, 0.1, 0.1, 0.1, and 1 respectively. Tissue concentrations of PAHs other than BaP are multiplied by their respective TEF and added to the tissue concentration of BaP to determine the BaP equivalent (BaPE) concentration. The BaPE concentration is considered the most valid measure of the carcinogenic potency of a complex mixture of PAH compounds. For the purpose of this risk assessment, substituted alkylated homologues of the above PAHs will be summed with the parent compound and multiplied as a single value by the appropriate TEF.
The following equation was used to determine the public health levels of concern (LOC: in μg/g or mg/kg = ppm wet weight) for carcinogenic PAH compounds (BaPE) potentially found in seafood:
LOC (BaPE) = (RL x BW x AT x CF)/(CSF x CR x ED)
Where LOC is the level of concern; BaPE is the benzo(a)pyrene equivalency; RL is the risk level; BW is the average consumer body weight; AT is the averaging time (i.e. life expectancy); CF is the unit conversion factor; CSF is the cancer slope factor of BaP; CR is the consumption rate (the daily amount of seafood consumed); and ED is the assumed exposure duration.
The following specific factors and assumptions were used in the above equation:
- • Risk Level (RL): Risk-based criteria were selected to prevent consumers from being exposed to the carcinogenic components of crude petroleum in doses that exceed a RL of 1×10-5 (1 in 100,000). This RL is within the acceptable range of risks (1×10-4 to 1×10-6) used by the FDA and EPA in regulatory criteria for food and drinking water15 and is provided as an example of an acceptable risk level in the U.S. EPA Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories16.
- • Body Weight (BW): The average adult body weight for these calculations, 80 kg, was adopted from the most recent CDC National health Statistics Report17.
- • Averaging Time (AT): The averaging time for these calculations, 78 yr, was adopted from the most recent CDC National Health Statistics Report18.
- • Conversion Factor (CF): Unit conversion factor (1000 μg/mg).
- • Cancer Slope Factor (CSF): Also known as a Cancer Potency Factor): The upper-bound estimate of the probability that an individual will develop cancer over a lifetime as a consequence of exposure to a given dose of a specific carcinogen. For the purpose of this risk assessment, U.S. EPA current CSF for benzo[a]pyrene of 7.3 (mg/kg-day)-1 was adopted (U.S. EPA, 1994)
- • Consumption Rate (CR): Consumption rates for shrimp & crab (13 g/day), oysters (12 g/day), and finfish (49 g/day) were adopted from 2005-2006 NHANES data for high level (90th percentile) seafood consumers adjusted for consumption frequency. To determine an appropriate fish consumption rate for high-level consumers, FDA adjusted the 90% meal size to account for the number of meals eaten by a 90th percentile consumer1:
1 For 90th percentile consumption values, data from the 2005-2006 NHANES two day recall survey were used. To determine the average daily rate for these consumers, the 2005-2006 30 day recall survey was used to determine frequency of seafood meals by 90th percentile consumers.
[meal frequency /30 days in month] x meal size = grams seafood per day
Where:
Meal frequency = 9.1 meals per month for finfish; 2.9 for oysters; and 4.4 for shrimp/crab
Days per month = 30
Meal size = 160 g for finfish; 120 g for oysters ; 90 g for shrimp/ crab
Grams seafood/day = 49 g for finfish; 12 g for oysters; and 13 for shrimp/crab
- • Exposure Duration (ED): The exposure duration was assumed to be 5 yr. This is a conservative estimate of the potential retention period of Deepwater Horizon oil contaminants in Gulf seafood.
Calculation of the Public Health Levels of Concern for Carcinogenic PAHs (BaPE) in Seafood:
Applying the specific factors and assumptions to the equation above results in the following LOC for BaPE in finfish:
[(1x10-5)(80 kg)(78 yr)(1000 µg/mg) / [7.3 (mg/kg-day)-1(49g/day)(5 yr)] = 0.035 µg/g or ppm BaPE
Applying the specific factors and assumptions to the equation above results in the following LOC for BaPE in shrimp/crabs:
[(1x10-5)(80 kg)(78 yr)(1000 μg/mg)] / [7.3 (mg/kg-day)-1(13 g/day)(5 yr)] = 0.132 µg/g or ppm BaPE
Applying the specific factors and assumptions to the equation above results in the following LOC for BaPE for oysters:
[(1x10-5)(80 kg)(78 yr)(1000 μg/mg)] / [7.3 (mg/kg-day)-1(12 g/day)(5 yr)] = 0.143 µg/g or ppm BaPE
Non-Cancer Risks
Non-cancer risks were determined for anthracene, phenanthrene, fluoranthene, fluorene, naphthalene, and pyrene. For the purpose of this risk assessment, substituted homologues of the above PAHs will be summed with the parent compound and compared to the appropriate toxicity criterion. The following general equation was used to set the public health protective level of concern (μg/g or mg/kg = ppm wet weight) for these compounds potentially found in seafood:
LOC = (RfD)(BW)(CF)/CR
Where RfD is reference dose; BW is the body weight (kilograms); CF is the conversion factor (1000 μg/mg); and CR is the consumption rate (the daily amount of fish or shellfish consumed).
The following specific factors and assumptions were used in the above equation:
- • Reference Dose (RfD): An estimate of daily human exposure to a chemical that is likely to be without significant risk of adverse effects during a lifetime, in mg/kg/day. RfDs for selected PAH compounds were obtained from the U.S. EPA’s Integrated Risk Information Service (IRIS) database (accessed June, 2010; see references for specific chemicals).
- • Body Weight (BW): The average adult body weight for these calculations, 80 kg, was adopted from the most recent CDC National Health Statistics Report15.
- • Conversion Factor (CF): Unit conversion factor (1000 μg/mg).
- • Consumption Rate (CR): Consumption rates for shrimp & crab (13 g/day), oysters (12 g/day), and finfish (49 g/day) were adopted from 2005-2006 NHANES data for high level (90th percentile) seafood consumers adjusted for consumption frequency as described above.
Using the above equation and assumptions, the non-cancer public health levels of concern for individual PAHs were calculated and are presented in Table 1.
The PAH levels of concern in Table I are based upon seafood consumption rates derived from 90th percentile, seafood consumers only, data from the 2005-2006 NHANES survey adjusted for consumption frequency. FDA and NOAA are taking this approach to ensure protection for the diverse US population as fisheries are re-opened. This approach may not necessarily affect a particular state’s local and state-wide fish advisories or a state’s determination regarding the opening or closing of state waters. As appropriate, states should use the best-available, relevant, state-specific data to make local and state-wide determinations. The PAH levels of concern, and factors for their derivation, were developed specifically for the unprecedented Deepwater Horizon Oil Spill event, and will not necessarily be applicable after all fisheries closed due to oil contamination are re-opened for safe harvest. Levels of concern and other factors for any subsequent oil spill event would be independently evaluated based on case-specific information.
Table I
Levels of Concern
Chemical1 Levels of Concern (ppm) Basis 13 g/day (Shrimp and Crabs)
12 g/day (Oysters)
49 g/day (Finfish)
Naphthalene 123 133 32.7 Non-cancer EPA RfD2; 80kg bw Fluorene 246 267 65.3 Non-cancer EPA RfD2; 80kg bw Anthracene/Phenanthrene 1846 2000 490 Non-cancer EPA RfD2; 80kg bw Pyrene 185 200 49.0 Non-cancer EPA RfD2; 80kg bw Fluoranthene 246 267 65.3 Non-cancer EPA RfD2; 80kg bw Chrysene 132 143 35.0 Cancer 0.001 BaP equivalent3 Benzo(k)fluoranthene 13.2 14.3 3.5 Cancer 0.01 BaP equivalent3 Benzo(b)fluoranthene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Benz(a)anthracene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Indeno(1,2,3-cd)pyrene 1.32 1.43 0.35 Cancer 0.10 BaP equivalent3 Dibenz(a,h)anthracene 0.132 0.143 0.035 Cancer 1.0 BaP equivalent3 Benzo(a)pyrene 0.132 0.143 0.035 10-5 Cancer risk = (0.110 µg/person/day)(78/5 yr)3 1 Includes alkylated homologues, for example C-1, C-2, C-3, C-4 napthalenes, fluorenes, anthracenes, fluoranthenes, pyrenes and chrysenes. Alkylated homologues are assumed to have similar toxicities to the parent compounds.
2With respect to the Basis:
Chemical RfD x Body Wt. x CF/ Intake Naphthalene: (0.02 mg/kg/day x 80 kg x 1000 µg/mg) / Intake (g/day) Fluorene: (0.04 mg/kg/day x 80 kg x 1000 µg/mg) / Intake (g/day) Anthracene: (0.30 mg/kg/day x 80 kg x 1000 µg/mg) / Intake (g/day) Pyrene (0.03 mg/kg/day x 80 kg x 1000 µg/mg) / Intake (g/day) Fluoranthene (0.04 mg/kg/day x 80 kg x 1000 µg/mg) / Intake (g/day) 3Criteria are based on a one-in-a-one hundred thousand increase in the lifetime (78 yr) upper bound cancer risk adjusted to account for exposures which are expected to last 5 years (78/5 yr). For any sample containing, chrysene, benzo(k)fluoranthene, benzo(b)fluoranthene, benz(a)anthracene, indeno(1,2,3-cd)pyrene, dibenz(a,h)anthracene or benzo(a)pyrene, the sum of the individual ratios of the detected levels to the levels of concern cannot exceed 1.
Cancer risk-based criteria:
Chemical [(RL x BW)/CSF x (AT/ED)]/[Intake x TEF] Chrysene [0.110 µg/p/day x (78/5 yr)] / [Intake (g/day) x 0.001] Benzo(k)fluoranthene [0.110 µg/p/day x (78/5 yr)] / [Intake (g/day) x 0.01] Benzo(b)fluoranthene [0.110 µg/p/day x (78/5yr)] / [Intake (g/day) x 0.1] Benz(a)anthracene [0.110 µg/p/day x (78/5yr)] / [Intake (g/day) x 0.1] Indeno(1,2,3-cd)pyrene [0.110 µg/p/day x (78/5 yr] / [Intake (g/day) x 0.1] Dibenz(a,h)anthracene [0.110 µg/p/day x (78/5 yr)] / Intake (g/day) Benzo(a)pyrene [0.110 µg/p/day x (78/5 yr)] / Intake (g/day) References:
1. Yender, R., Michel, J., and Lord, C. (2002). Managing Seafood Safety after an Oil Spill. Seattle: Hazardous Materials Response Division, Office of Response and Restoration, National Oceanic and Atmospheric Administration. 72 pp. Available: http://response.restoration.noaa.gov/book_shelf/963_seafood2.pdf
2. Reilly, T.I., and York, R.K. (2001) Guidance on Sensory Testing and Monitoring of Seafood for Presence of Petroleum Taint following an Oil Spill. NOAA Technical Memorandum NOS OR&R 9. Seattle: Office of Response and Restoration, National Oceanic and Atmospheric Administration. 109 pp.
3. Yender, R. (2003). Improving Seafood Safety Management after an Oil Spill. In: Proceedings of the 2003 International Oil Spill Conference. 8 pp. Available: http://www.iosc.org/papers/IOSC%202003%20a416.pdf
4. Sloan, C.A., Brown, D.W., Pearce, R.W., Boyer, R.H., Bolton, J.L., Burrows, D.G., Herman, D.P., and Krahn, M.M. (2004). Extraction, Cleanup, and Gas Chromatography/Mass Spectrometry Analysis of Sediments and Tissues for Organic Contaminants. U.S. Dept. Commer. NOAA Tech. Memo. NMFS-NWFSC-59, 47 pp.
5. Bolger, M. and Carrington, C. (1999). Hazard and Risk Assessment of Crude Oil in Subsistence Seafood Samples from Prince William Sound: Lessons learned from the Exxon Valdez. In L. Jay Field et al. (eds.). Evaluating and Communicating Subsistence Seafood Safety in a Cross-Cultural Context: Lessons Learned from the Exxon Valdez Oil Spill. Pensacola: Society of Environmental Toxicology and Chemistry. Pp. 195-204.
6. Bolger, M., Henry, S.H., and Carrington, C.D. (1996). Hazard and Risk Assessment of Crude Oil Contaminants in Subsistence Seafood Samples from Prince William Sound. Proc. EXXON VALDEZ Oil Spill Symposium, S.D. Rice, R.B. Spies, D.A. Wolfe, and B.A. Wright (eds.). American Fisheries Symposium Vol. 18, pp. 837-843.
7. Bolger, M. and Carrington, C. (1999). Estimation of Risk Associated with consumption of Oil-Contaminated Fish and Shellfish by Alaskan Subsistence Fishermen using a Benzo[a]pyrene Equivalency Approach. In L. Jay Field et al. (eds.). Evaluating and Communicating Subsistence Seafood Safety in a Cross-Cultural Context: Lessons Learned from the Exxon Valdez Oil Spill. Pensacola: Society of Environmental Toxicology and Chemistry. Appendix 3: Report of the Quantitative Risk Assessment Committee, Center for Food Safety and Applied Nutrition, U.S. food and Drug Administration, 9 August 1990, pp. 295-304
8. U.S. EPA. 1993. Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons. United States Environmental Protection Agency, Office of Research and Development. July, 1993. Washington DC.
9. U.S. EPA. 1998. Integrated Risk Information System. Online at: http://www.epa.gov/iris/subst/0436.htm. Naphthalene (CASRN 91-20-3). Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
10. U.S. EPA. 1990. Integrated Risk Information System. Online at: http://www.epa.gov/ncea/iris/subst/0435.htm. Fluorene (CASRN 86-73-7)/
Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
11. U.S. EPA. 1993. Integrated Risk Information System. Online at: http://www.epa.gov/ncea/iris/subst/0445.htm. Pyrene (CASRN 129-00-0). Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
12. U.S. EPA. 1993. Integrated Risk Information System. Online at: http://www.epa.gov/ncea/iris/subst/0434.htm. Anthracene (CASRN 120-12-7). Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
13. U.S. EPA. 1993. Integrated Risk Information System. Online at: http://www.epa.gov/ncea/iris/subst/0444.htm. Fluoranthene (CASRN 206-44-0). Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
14. U.S. EPA. 1994. Integrated Risk Information System. Online at: http://www.epa.gov/iris/subst/0136.htm. Benzo[a]pyrene (BaP) (CASRN 50-32-8). Database maintained by the Office of Health and Environmental Assessment. U.S. Environmental Protection Agency Environmental Criteria and Assessment Office, Cincinnati, Ohio. Accessed June 10, 2010.
15. U.S. EPA. 1998. Draft Water Quality Criteria Methodology Revisions: Human Health, Notice. Fed. Reg. 63(157):43755-43828. Available: http://www.epa.gov/fedrgstr/EPA-WATER/1998/August/Day-14/w21517.htm
16. U.S. EPA. 2000. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 2. Risk Assessment and Fish Consumption Limits. 3rd Ed. EPA 823-B-00-007. Washington, DC: U.S. Environmental Protection Agency. Available: http://www.epa.gov/fishadvisories/advice/volume2/v2cover.pdf
17. McDowell MA, Fryar CD, Ogden CL, Flegal KM. Anthropometric Reference Data for Children and Adults: United States, 2003–2006. National Health Statistics Reports; no 10. Hyattsville, MD: National Center for Health Statistics. 2008.
18. Heron MP, Hoyert DL, Murphy SL, Xu JQ, Kochanek KD, Tejada-Vera B. Deaths: Final data for 2006. National vital statistics reports; vol 57 no 14. Hyattsville, MD: National Center for Health Statistics. 2009.
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Since the government has made it abundantly clear that they're lying about the safety of the Gulf waters, those who choose to fish them and those who choose to eat the produce are giving their implied consent to their own murder, and that of others."Fine kettle of fish." Don't suppose there'll be any labeling on Gulf produce, identifying it as post-BP Gulf, either…….
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[...] This post was mentioned on Twitter by Kieran G., Alexander Higgins. Alexander Higgins said: BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols http://bit.ly/9DhIt9 [...]
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[...] the rest of this great post here Comments (0) Posted in Oil Spill [...]
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Except from Riki Ott’s book Sound Truth and Corporate Myths:
Exxon scientists slanted their own studies
with under-powered designs so their studies would not detect oil
spill effects. Choices in study design ensured pre-determined conclusions.
Many of the common tricks used by Exxon scientists are
described by Huff. For example, one trick was to improperly preserve
samples to reduce concentrations of aromatic hydrocarbons
(Chapter 12). Another was to average data to erase distinct differences
between oiled and unoiled areas (Chapters 12, 13).Another
was to selectively report data—or to simply omit the most damaging
data—to hide oil spill effects (Chapters 13,14). Another was to collect
a small number of samples with a physically tiny sampling device
to blur differences between oiled and unoiled areas (Chapter 13).
Another was to mismatch control and oil sites—again to blur oil
effects (Chapter 13).Examples abound.
Exxon counted on seemingly small nuances in study design to
pull off its magician’s act of making the Sound appear to have fully
recovered within a couple years after the spill—abracadabra!
Without samples that accurately represented the larger whole—
whether that “whole” was beach ecology, seabird communities, sea
otters populations, or something else—Exxon’s studies reveal little
about the true nature of the Sound.
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I could not believe it when I watched a FOX news reporter in a boat with a father and his children in Slidell, Louisiana and the reporter said they were fishing and EATING the fish! The reporter did NOT even QUESTION that! Lisa Jackson (EPA) is, I believe, from N.O. I wonder if she feels any guilt that her actions lead to a very high chance that children are ingesting COREXIT?
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[...] doutes sur l’état du poisson qui sera servi dans toutes les assiettes du Golf du Mexique. (Lire l’analyse d’Alexander Higgins) Cette entrée a été publiée dans Uncategorized. Vous pouvez la mettre en favoris avec ce [...]
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[...] the rest of this great post here Comments (0) Posted in BP News [...]
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[...] this article: BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing … Share and Delight [...]
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[...] BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols – Alexander Higgins Blog Posted on 07/26/2010 by katy BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols [...]
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[...] BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols [...]
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After the "IXTOC GUSHER", it took over 10 years, for the fish to come back to 'normal numbers'. Over 70% of the fishing was lost!
Over 2 million gallons of corexit was used, to disperse 145+ million gallons of Crude Oil.
I'm sure, with these numbers, that the Feds don't want to be seen, "taking those jobs away"… (Best become; VEGAN!)
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[...] Gulf news: Toxic rain across America for ‘Core Exit’ Gulf fishing waters reopened despite lack of testing required by federal protocols NY Times: Will Bacterial Plague Follow Crude Oil Spill Along Gulf [...]
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[...] BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols [...]
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[...] government also ignored its own protocols for opening fishing waters affected by the BP Gulf Oil Spill a move that puts millions at risk for becoming sick and developing long term chronic health affects [...]
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[...] The PublicShrimp Covered In Oil Found In BP Gulf Oil Spill Waters Being Opened For Fishing : on BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal ProtocolsShrimp Covered In Oil Found In BP Gulf Oil Spill Waters Being Opened For Fishing : on Feds [...]
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[...] In fact the federal government has decided to violate its own protocols and reopen BP Gulf Oil Spill wishing waters based on “visual observation…. [...]
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[...] BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocols [...]
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[...] New York Beach Massive Fish Kills Stretch From New Jersey to Massachusetts | Before It's News on BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal Protocolsvoyager seven on How To Cross The US Mexico Border IllegallySister bluebird on Fisherman Forced To [...]
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[...] Them and NOT BP Liable For Contaminated BP Gulf Oil Spill Seafood | Alexander Higgins Blog on BP Gulf Oil Spill Fishing Waters Reopened Despite Lack Of Testing Required By Federal ProtocolsGreg on Michele Obama Tells Barack Swimming In Gulf Is Not A Good Thing; Obamas Swim Inland And [...]