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Recommendations

No Safe Level of PFAS 

The science around PFAS health impacts is rapidly evolving. In June 2022, EPA established new drinking water health advisories for four PFAS chemicals. These health advisories indicate the level of drinking water contamination below which adverse health effects are NOT expected to occur. In this new guidance the maximum levels for two PFAS (PFOA=.004ppt and PFOS=.02ppt) are more than 1,000 times lower than Michigan’s current drinking water standards. In practical terms, this effectively means there is no safe level for these PFAS chemicals in the environment. Therefore, any detectable level of PFOS in water would still be too high. These very low EPA recommended levels are far below what current testing can detect. 

How do these drinking water advisories relate to Michigan’s fish consumption guidance? Though we consume fish and water differently, we believe the levels in the fish guidelines should be lowered to keep pace with the emerging science on safe drinking water levels. 

The Michigan Department of Health and Human Services (MDHHS) has established fish consumption levels between 9 to 299 parts per billion PFAS—nearly a million times higher than the new EPA drinking water health advisories. The consumption recommendations range from six meals per year to 16 meals per month and are based on age, high-risk groups, and different population’s consumption patterns. However, even with a recommended consumption range, we believe the MDHHS current fish consumption guidance values are too high and do not reflect the emerging science exemplified in the new EPA drinking water guidelines. 

While the EPA does not have health advisory levels for fish consumption, the state of Michigan declares DO NOT EAT fish consumption advisories if PFOS are found at greater than 300 parts per billion level in fish. But, fish advisories are not keeping up with the evolving science on PFOS and the current levels are still too high for fish advisories to be lifted on the Huron River. 

Recommendations for Anglers 

Restrictive fish consumption advisories can be disruptive to cultural and traditional relationships with the waters, fish and wildlife. What’s more, eating fish is a good source of protein and omega 3s and can lead to reduced heart disease, lower blood pressure and other health benefits. However, fish consumption advisories allow anglers to make informed decisions in order to balance the risks and benefits of consuming fish that contain PFAS and other toxins. Fish consumption advisories are voluntary guidelines and are not enforceable.  

  • Anglers planning to consume fish from the Rouge or Huron River should follow the Michigan Department of Health and Human Services’ guidance listed in their Eat Safe Fish Guide 
  • If possible, explore alternative Michigan rivers and lakes where contaminant levels in fish are lower 
  • If local fish are too toxic to consume, explore alternative sources of protein and omega 3s (olive oils, eggs, leafy greens, nuts and seeds) 
  • For anglers continuing to consume fish that contain PFAS, try to limit exposure to PFAS commonly found in consumer products (nonstick cookware, waterproof gear, food packaging, etc.)

Recommendations for Michigan Regulatory Agencies 

Department of Environment, Great Lakes and Energy (EGLE)

  • Establish science-based PFAS standards for fish and wildlife.
  • Increase PFAS testing for whole fish, not just filets that humans consume, in order to consider the impacts on fish-eating wildlife. 
  • Support wider species studies on PFAS health impacts to understand broader ecological impacts (including more fish, birds, reptiles, amphibians, and mammalian species.) 

Department of Health and Human Services  (DHHS) 

  • Increase consumption advisory signage in heavy fishing areas along the Huron and Rouge Rivers. 
  • Create a Riverwalkers program for the Rouge River. 
  • Include other PFAS chemicals in addition to PFOS in the Eat Safe Fish Advisory.
  • Increase the Eat Safe Fish Advisory’s accessibility for people, such as creating an interactive website or an app for a smartphone.  

Recommendations for the Michigan Legislature 

  • Take a proactive stance and prevent future pollution in Michigan fisheries, water, and wildlife by regulating new chemical threats to ecosystems. 
  • Prohibit the sale of all PFAS-containing products except when no safer alternative exists.
  • Regulate PFAS as a class of chemicals rather than just regulating the commonly-found PFAS chemicals. This will prevent new toxic PFAS chemicals from replacing already banned chemicals. 
  • Hold polluters financially responsible for cleaning up PFAS pollution, including mitigation and PFAS destruction, specifically in wastewater treatment plants.  
  • Create better regulations for common PFAS dischargers: wastewater treatment plants, firefighting foam, tanneries, paper mills, etc. 
  • Eliminate a major need for PFAS to be used as a mist suppressant in chrome plating facilities by banning hexavalent chromium statewide. 
  • Encourage research into disposal and destruction technology for PFAS, especially for wastewater treatment plants 
  • Require products containing PFAS to list this on the label

Take Action 

  • Share this information with people who fish 
  • Become involved in the Great Lakes PFAS Action Network 
  • Join the Michigan PFAS Action Response Team’s Citizen Advisory Workgroup 
  • Let your elected officials know you are concerned about PFAS 
  • Get involved in your local watershed council