Report Summary

Report Contents

Risk Assessment
Review and Analysis

Feasibility Study
Review and Analysis

Proposed Cleanup (Action) Levels for
the Fox River and
Green Bay

Literature Cited

Complete Report
for easy printing

Report PDF File

About Dr. Foran

Dr. Foran's CV (PDF)

Human Health:

• The cancer rate due to PCB contaminated fish consumption is approximately equal to the cancer rate experienced by individuals who smoke 2 or 3 packs of cigarettes a day.

• This risk is 100 to 1000 times greater than cancer risks commonly determined to be “acceptable” by state and federal agencies.

• This risk is 10 times greater than cancer risks that trigger stringent regulation of pollutant sources by the U.S. EPA.

• These consumers also face a variety of non-cancer health risks at high rates.

• 14,000 recreational anglers are highly exposed to PCBs in the Fox River and Green Bay system. In addition, 12,000 low income or minority individuals are highly exposed.  Assuming the recreational anglers expose one more family member to fish consumption at the same rate, this means roughly 40,000 individuals are highly exposed to PCB health effects, an enormous population at risk.

• Waterfowl hunters also face significant health risks.

• The Assessment underestimates Human Health Risk in several ways:

 
1.  The true high-end fish consumption rates for recreational and high-intake fish consumers are more than 2 times greater than “high-end” rates chosen in the Assessment.

2.  The Assessment uses a PCB “reduction factor” of 50% based on an inaccurate assumption that individuals practice appropriate cleaning and cooking procedures.

3.  The Assessment does not account for the cumulative risks for individuals who eat both fish and waterfowl, and who are also PCB exposed through recreation activities and occupation.

4.  The Assessment inappropriately declares that negative epidemiological studies prove or conclude that PCBs don’t cause human cancer.  Human epidemiological studies typically lack adequate power to identify adverse effects in populations at low frequencies or levels..

5. The Assessment does not address the potential for, and in some cases, evidence for synergism.  (The compounding effects of 2 types of chemicals acting together.)


As a result of these weaknesses, the actual health risks are likely to be 3 to 4 times greater than the risks presented in the Assessment.

• Wildlife are also seriously harmed by PCBs.   Significant ecological risks occur at virtually all levels of biological organization and for all assessment/measurement endpoints throughout the Fox River/Green Bay system.

• In virtually all cases (except insect-eating birds), wildlife health risks have been confirmed by field observations.

• The Assessment ignores the impact of multiple stresses (disease, temperature, habitat alteration, and many others) which can make wildlife more vulnerable to PCB toxicity.

According to the Assessment, if the PCB levels are over 1 ppb (which equals only .001 ppm) in the sediments, this could lead to fish PCB contamination which exceeds the “acceptable” cancer risk of 1-in-a-million for high-intake fish consumers.

Despite this finding, the governments propose a cleanup target in the sediments of 1 ppm, which is 1,000 times higher than the level they admit could exceed the “acceptable” cancer risk.

• The plan should strengthen the stated “Remedial Action Objectives” to

1.  Achieve surface water quality criteria without qualification

2.  Eliminate rather than reduce transport of PCBs

• It is disturbing and inappropriate that action levels necessary to achieve even the weaker objectives were not considered in the selection of cleanup options for the Bay, apparently due to cost and technology concerns. 

• Cleanup technologies may change considerably in the next few years; therefore the plan should evaluate all action levels needed to achieve objectives, even to levels as low as .125 ppm PCBs. Current cost estimates should not prevent a full cleanup evaluation.

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