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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