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Fish Consumption Rate

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Additional writing by Brett VandenHeuvel, Matt Krogh and Chris Wilke

Washington State may be called the Evergreen State, but the state's rich heritage of fish and shellfish is critical to our economy, culture and health. From tribal subsistence fishing in Eastern Washington to a thriving shellfish industry in Puget Sound; from sport fishing on the mighty Columbia River, to legendary steelhead trout of the Olympic Peninsula, fish and those who thrive on them are as much a part of Washington as all our fir trees and glaciers combined.

But there is a hidden danger in these fish, and right now we have the opportunity to make sure that fish and shellfish are healthy for future generations to eat.

Even a quick glance at our state's water quality standards for toxic pollution shows a gross inequality between the weak limits on toxic pollution and the strong value of we place on serving fish for our families. Washington currently has some of the weakest limits on toxic pollution in the nation, in part because we use a low estimate of how much fish people eat every day.

The problem is this: in a state where people have subsisted primarily on salmon and seafood for thousands of years, the state assumes people only eat a cracker-sized portion of fish per day. 6.5 grams, to be exact.

Why does a low fish consumption estimate matter? Because each of our pollution control regulations is tied to human health, and the human health threshold for cleanup or control is tied to the consumption rate.

According to Washington State Department of Health toxicologist David McBride, who spoke in Spokane, WA at a water quality conference earlier this year, "Our current discharge standards don't protect you. Washington uses one of the lowest fish consumption rates in the nation to set water quality standards, but we have some of the highest fish-consuming populations in the nation."

So who exactly are these populations at risk of high toxics in fish? Washington State is home to a culturally-diverse set of populations who value and regularly eat locally-caught fish, including Native American tribal members, Asian and Pacific Islanders and other ethnic populations. Then there are the high numbers of commercial and recreational fishermen, and finally just your average citizen looking for the health benefits of adding fresh local fish to one's diet. These are all people who consume a substantial amount of fish and shellfish in Washington.

But Washington assumes that people only eat 6.5 grams per day, the so-called "fish consumption rate." Anyone who eats more is out of luck. The way this plays out is the higher the estimated fish consumption rate used by the State in making regulations, the stronger the clean water and toxic cleanup standards we will have. Washington's fish consumption rate, which is more than 20 years old, is among the least protective in the nation -- bizarre for a state not only known for being environmentally progressive, but deeply economically tied to the fishing industry and its celebrated waters.

All of this is changing, if slowly, thanks to public pressure. Our southern neighbor, Oregon, took important steps last year by adopting a higher fish consumption rate and stronger standards. And Washington's Department of Ecology (Ecology) wants to make good on an agency goal to address the woefully under-protective toxic pollution limits in Washington. Ecology officials are currently reviewing fish consumption levels and deciding where to draw the line on the fish consumption rate and how much toxic pollution can be discharged into our waterways.

After extensive public and tribal input, the State of Oregon recently established the nation's most protective fish consumption rate at 23 meals per month -- based off of the determination that a lot of people regularly consume local fish. This set in motion the Oregon Department of Environmental Quality adopting tougher pollution discharge standards to reduce toxics flowing into coastal bays, lakes and streams. According to the AP, the Oregon standards rank among the nation's most rigorous for water quality. Washington must complete a similar process if we are to do justice to the fish-filled watery border we share with our southern neighbor.

As they say though, the devil is in the details. Pollution dischargers have proposed extensive loopholes to undermine the effectiveness of any new standards. A new fish consumption rate won't mean much if the resulting regulations are full of loopholes that prevent any real protection of water quality.

Wrapped up in work to address the actual fish consumption rate number is Ecology's work on rulemaking for both water quality standards and sediment management standards. The dischargers have asked Ecology to development "regulatory flexibility" measures even before the new pollution-reducing limits are set. (Yes, "regulatory flexibility" is a euphemism for loophole.) Because of dischargers' requests, Ecology is now moving forward with rules that would make it easier to discharge pollution at levels that violate state water quality standards, including pollutants such as mercury and PCBs.

In response, Waterkeepers Washington, the four licensed Waterkeeper Alliance organizations in the state of Washington (Spokane Riverkeeper, Columbia Riverkeeper, Puget Soundkeeper Alliance and North Sound Baykeeper) have urged Ecology to act in the public interest and stand strong against attempts to create loopholes in laws designed to protect human health and the environment.

If that sounds a little backwards and odd it's because it is. Naturally, Ecology is facing fierce opposition from industry groups that want to maintain the status quo. Last year, Waterkeepers Washington and other conservation groups sent a letter to Ecology urging the department to act swiftly to protect public health. So far, Ecology's action has been anything but "swift."

In a time when special interests continually seek to undermine federal and state environmental regulations that protect the air we breathe, the water we drink, the fish we eat and the land and wildlife we value, it is important for states to stay strong in protecting the health of their populations. A robust and accurate fish consumption standard that protects fish consumers -- without unnecessary regulatory loopholes -- will help to accomplish this goal.

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