Abstract Title

Session S-03B: Washington Fish Consumption Rate: One Number, Hundreds of Human Health and Environmental Management Decisions, Millions of Consumers

Proposed Abstract Title

Exposed: Asking the Wrong Question in Environmental Regulation

Presenter/Author Information

Catherine A. O'Neill, Seattle University

Keywords

Toxics

Location

Room 608-609

Start Date

30-4-2014 3:30 PM

End Date

30-4-2014 5:00 PM

Description

Environmental standards set a de facto ceiling on the safe ingestion of fish and water, and on the healthful conduct of a host of other human behaviors. Under the Clean Water Act (CWA), water quality standards are set using health- (i.e., risk-) based methods. A risk assessment is premised upon certain assumptions about humans’ exposure to toxic contaminants in their environment. Current exposure assessment methods take a snapshot of people’s consumption of fish and other behaviors, as these are constrained by a degraded present, i.e., when resources are contaminated and depleted. These methods capture contemporary fish consumption at rates that are distorted by “suppression.” As the National Environmental Justice Advisory Council has recognized, “[a] ‘suppression effect’ occurs when a fish consumption rate (FCR) for a given population, group, or tribe reflects a current level of consumption that is artificially diminished from an appropriate baseline level of consumption for that population, group, or tribe.” For tribes in the Pacific Northwest, the forces of suppression have operated for decades and include inundation of tribes’ fishing places; denial of access to harvest sites; depletion and contamination of the fish resource; and the legacy effects of years of prosecution, intimidation, and gear confiscation. As a consequence, contemporary surveys of tribal populations produce FCRs that are artificially low compared to an appropriate, historical- or “heritage-” based baseline – a baseline to which tribes in the United States also have treaty-secured and other legal rights. Current exposure assessment methods effectively undermine tribes’ fishing rights. These methods also undercut the restorative goals of environmental statutes such as the CWA, which were passed when our ecological systems were perhaps at their most ravaged. These methods, moreover, subvert the health-based aims of these statutes. And they subtly assimilate those whose lifeways place them among the most exposed: they effectively present tribal members with the “choice” of conforming their fish intake to current, suppressed levels or consuming fish at more appropriate levels – but along with a stiff dose of toxic contaminants.

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Apr 30th, 3:30 PM Apr 30th, 5:00 PM

Exposed: Asking the Wrong Question in Environmental Regulation

Room 608-609

Environmental standards set a de facto ceiling on the safe ingestion of fish and water, and on the healthful conduct of a host of other human behaviors. Under the Clean Water Act (CWA), water quality standards are set using health- (i.e., risk-) based methods. A risk assessment is premised upon certain assumptions about humans’ exposure to toxic contaminants in their environment. Current exposure assessment methods take a snapshot of people’s consumption of fish and other behaviors, as these are constrained by a degraded present, i.e., when resources are contaminated and depleted. These methods capture contemporary fish consumption at rates that are distorted by “suppression.” As the National Environmental Justice Advisory Council has recognized, “[a] ‘suppression effect’ occurs when a fish consumption rate (FCR) for a given population, group, or tribe reflects a current level of consumption that is artificially diminished from an appropriate baseline level of consumption for that population, group, or tribe.” For tribes in the Pacific Northwest, the forces of suppression have operated for decades and include inundation of tribes’ fishing places; denial of access to harvest sites; depletion and contamination of the fish resource; and the legacy effects of years of prosecution, intimidation, and gear confiscation. As a consequence, contemporary surveys of tribal populations produce FCRs that are artificially low compared to an appropriate, historical- or “heritage-” based baseline – a baseline to which tribes in the United States also have treaty-secured and other legal rights. Current exposure assessment methods effectively undermine tribes’ fishing rights. These methods also undercut the restorative goals of environmental statutes such as the CWA, which were passed when our ecological systems were perhaps at their most ravaged. These methods, moreover, subvert the health-based aims of these statutes. And they subtly assimilate those whose lifeways place them among the most exposed: they effectively present tribal members with the “choice” of conforming their fish intake to current, suppressed levels or consuming fish at more appropriate levels – but along with a stiff dose of toxic contaminants.