Office of Science and Technology
Office of Water
U.S. Environmental Protection Agency
Washington, DC

v.	j	2>
AUG 6 iS9S
Dear Colleagues:
The U.S. Environmental Protection Agency is pleased to
announce the availability of the document titled Guidance for
Assessing Chemical Contaminant Data For Use in Fish Advisories
Volume III: Overview of Risk Management. The purpose of the
document is to provide an overview on risk management options for
reducing health risks associated with the consumption of
chemically contaminated fish and shellfish. Characteristics
which may be considered when choosing risk management options,
such as resources available for program development, feasibility
and efficacy of options development, and the impacts of various
options on target populations (e.g., on nutrition, economics,
traditional activities, communities, risk) are discussed. A
structure for organizing information on options and
characteristics is provided. Templates are included to enable
risk managers to organize their information to evaluate needs and
to identify the optimal group of options.
Volume 3 is part of the USEPA's series of guidance documents
that have been under development over the past several years.
The purpose of the four volume set of documents has been to
provide guidance to professionals- responsible for assessing the
health risks associated with exposure to chemical contaminants in
noncommercial fish and shellfish. Volume 1; Fish Sampling and
Analysis, First Edition (EPA 823-R-93-002) and Second Edition
(EPA 823-R-9S-007) were released in September 1993 and September
1995, respectively. Volume II: Risk Assessment and Fish
Consumption Limits (EPA 823-R-94-004) was published in June 1994,
with a Second Edition planned for FY97. Volume IV: Risk
Communication (EPA 823-R-95-Q01) was published in March 1995.
The series of documents is being developed cooperatively with
Native American Tribes and State, Federal, . and Local Government
Agencies. All four of these documents should be used together,
as no single volume addresses all of the topics necessary for
developing risk-based fish consumption advisories.
RacycIuURocycIaM* • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Po3t consumer)

Copiesxr&f Volume III; Overview of Risk Management (or the
other Volumes) may be obtained by writing to the U.S.
Environmental Protection Agency, National Center For
Environmental Publications and Information, 11029 Kenwood Road,
Cincinnati, Ohio, 45242, or calling 513-489-8190. For questions
related to the development or use of this series of documents,
please call Jeffrey Bigler (202) 260-1305 of the USEPA Fish
Contamination Program.
We appreciate your continued, interest in EPA's activities
related to chemical contaminants in fish.
Tudor T. Davies
Cffice of Science and Technology

State, local, and federal agencies currently use various methods to estimate
risks to human health from the consumption of chemically-contaminated, non-
commercial fish. A 1988 survey, funded by the U.S. Environmental Protection
Agency (EPA) and conducted by the American Fisheries Society, identified the
need for a standardized approach to evaluating risks and developing fish
consumption advisories to provide comparable advisories across different
jurisdictions {RTI, 1990). Four key components were identified as critical to the
development of a consistent risk-based approach: standardized practices for
sampling and analyzing fish, standardized risk assessment methods,
standardized procedures for making risk management decisions, and
standardized approaches to risk communication (RTI, 1990).
To address concerns raised by the survey respondents, EPA has developed a
series of four documents designed to provide guidance to state, local, regional,
and tribal environmental health officials responsible for issuing fish advisories.
The documents are designed as guidance only and do not constitute a
regulatory requirement. The documents are:
Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories
Volume /.* Fish Sampling and Analysis
Volume //.* Risk Assessment and Fish Consumption Limits
Volume III: Risk Management
Volume IV: Risk Communication
It is essential that all four documents be used together, since no single volume
addresses all of the topics involved in the development of risk-based fish
consumption advisories.
Fish contamination has become a recognized health hazard in some areas in
recent years. While most fish provide an excellent source of nutrition, some

fish are sufficiently contaminated to generate health risks (e.g., Minamata
disease in Japan). The responsibility for safeguarding the public from
contaminated fish is shared by different agencies in the United States. Federal
agencies such as the United States Food and Drug Administration (FDA)1 have
responsibility for advisories regarding commercial fish, EPA, the Department
of Energy, and the United States Fish and Wildlife Service, are also involved in
managing and monitoring waterbodies, controlling pollutant releases, and
managing clean up and remediation efforts that impact fish contaminant
concentrations. Responsibility for safeguarding the public against effects of
contaminants in non-commercial fish falls to state, local, and tribal agencies
and groups. The overall objective of this series is to provide guidance to these
agencies and groups regarding the development of fish advisories for non-
commercial fish.
The field of risk management, as it deals with fish advisories, is a relatively new
and evolving area. A few states have long-standing advisory programs;
however, written evaluations of these programs were not available for the most
part. Consequently, there is limited information available from which to draw
conclusions or guidance regarding management strategies. Examples of types
of advisories were obtained from ongoing advisory programs. Advisory
program staff were consulted regarding their experiences with various
management approaches. Due to the information constraints, this document
provides an overview of risk management rather than detailed and highly
specific guidance. Numerous state and local advisory programs have recently
been developed, and it is anticipated that additional information will be available
in future editions of this volume.
A variety of options exist for managing health risks through fish advisories.
Options for limiting consumption of contaminated fish range from approaches
requiring limited resources to resource-intensive approaches such as the
development of quantitative health-based advisories. This document presents
various options that may be used in fish advisory programs, with a discussion
of the types of information and resources required and their advantages and
disadvantages. A discussion is included of specific characteristics that may be
considered when developing a fish advisory program, including: contaminant
and risk levels, resources available for program development, the feasibility and
efficacy of the options, and the anticipated impacts of various options on target
populations (e.g., on nutrition, economics, traditional activities, communities,
risk). A structure for organizing information on options and characteristics is
provided and a tiered approach to developing fish advisories is discussed.
Templates are included to enable risk managers to organize their information to
1 See the Glossary for definitions of abbreviations and selected terms.

evaluate needs and to identify the optimal group of options and consumption
limits for their area.
The risk management approach discussed in this volume includes a discussion
of critical decisions required to carry out sampling and analysis, risk
assessment, and advisory program development. This highlights for the risk
manager those decisions that may have a significant impact on risk estimates
and the corresponding advisories. The uncertainties inherent in these decisions
are also discussed.
Environmental justice is discussed in this volume because contaminated fish
may be consumed in greater quantities by minorities and low-income
populations in many areas of the United States. These groups are often
subsistence fishers (fishers who rely substantially on fish they catch as a food
source) and may be simultaneously exposed to the pollutant found in their fish
via other sources as well (in other foods, air, and water). Subsistence fishers
live in urban environments, where high pollution levels often have obvious
industrial or other sources, as well as in rural areas, where water or soil
contamination may occur via long-range transport or from non-point sources.
While health concerns are often the focus of fish advisory development this
document also provides information on health benefits of fish consumption and
the economic and social impacts of various advisory strategies. Information on
the benefits of fishing and fish consumption are provided to enable risk
managers to evaluate the potential impacts of advisories; however, information
on these topics is limited, often location-specific, and dependent on local
characteristics. Quantitative cost-benefit analysis is not discussed in this
volume; however, qualitative information on health benefits of fish and limited
fishing revenue data are included. Information is also provided on potential
societal impacts meriting consideration, such as traditional dietary patterns and
religious and social traditions that rely on fishing and fish consumption.
Although these types of impacts cannot be quantified or adapted to a balance
sheet approach, they merit consideration in the development of advisories. The
social, economic, and health impacts of advisories will vary depending upon the
characteristics of the local population, and use of local information is
A theme carried through this document is to utilize local information and
participation where possible and to involve all potentially impacted parties in the
decision-making process. It is hoped that the evaluation of potential impacts of
fish advisories and broader public participation in decision-making will provide
all affected parties access to policy making, and result in well-founded and
widely accepted fish advisories.

1.1	Overview and Objectives			 1-1
1.2	Series Summary	 1-3
1.3	Volume III Contents 			 1-6
1.4	Methods and Sources . . 				 1-8
1.5	Underlying Assumptions 	 1-8
1.6	Critical Decisions 	 1-10
1.7	Environmental Justice		 . . 			 1-16
2.1	Overview ..............			 2-1
2.2	Program Goals	 2-2
2.3.	Options for Limiting Consumption 				 2-3
2.3.1	No action 				2-8 Feasibility and Efficacy	 2-8
2.3.2	Fish Consumption Advisories	 2-10	General Fish Consumption Advisories ... 2-10	Feasibility and Efficacy . 		 2-12	Quantitative Advisories 	 2-13	Feasibility and Efficacy	 2-18
2.3.3.	Catch and Release 	 2-22 Feasibility and Efficacy	 2-23
2.3.4.	Fishing ban 	 2-25 Feasibility and Efficacy 			2-26
2.3.5 Summary 		 2-28
2.4.	Outreach and Education	 2-31
2.5.	Federal Programs and Additional Resources	 2-31

3.1	Overview 				3-1
3.2	Nutrition 	.:		 . 3-1
3.2.1	Basic Nutritional Needs			 3-1
3.2.2	Health Benefits of Fish Consumption 		 3-2
3.3.	Cultural and Societal Impacts	 3-7
3.3.1.	Traditional Activities		 3-7
3.3.2.	Dietary Patterns		 .. 3-11
3.3.3.	Use Taking and Mobility ............. 3-12
3.4.	Economic Impacts of Fishing Advisories	 3-12
3.4.1.	Methods for Estimating Costs Resulting
from Fish Advisories	 3-13
3.4.2.	Recreational Fishing and Tourism 	.. 3-15
3.4.3.	Subsistence Fishing and Food Costs ..... 3-17
3.4.4.	Costs Associated with Property Values ... 3-17
3.4.5.	Benefits Associated with Health Advisories 3-18
3.5.	Legal and Treaty Rights			 3-20
3.6.	Summary				 3-20
4.1.	Overview	 4-1
4.2.	Qualitative Comparisons of Health Risks and Options
Impacts			' 4-1
4.3.	Selection of Options		 4-3
4.4.	Levels of Protection 		 		 4-9
4.5.	Level of Program Effort and Funding		 4-12
4.6.	Program Evaluation and Modification 	 		 4-13
4.7.	Summary . 				 4-13

Table 1-1 Activities Related to the Development of Fish Advisories
and Risk Management and Volumes in the Series Containing
Discussions of Three Activities		 . 1-5
Table 1-2 Critical Decisions 	 1-11
Table 2-1 Options for Fish Advisory Programs	 2-6
Table 2-2 Comparison of EPA and Sample State Fish Consumption
Advisories	 2-15
Table 2-3 Feasibility and Efficacy of Risk Management Options . . . 2-29
Table 2-4 Template for Risk Management Options	 2-30
Table 2-5 Environmental Statutes and Programs Potentially Relevant
to Fish Contaminants 	 2-33
Table 2-6 Hotlines and Other Resources for Federal Programs
Relevant to Fish Advisories 	 2-37
Table 3-1 Nutrient Values for 3.5 oz Fish Fillet	 3-2
Table 3-2 Examples of Values Reported for Recreational Fishing . , 3-16
Table 3-3 Template for the Impacts of Risk Management Options . 3-22
Table 4-1 Information Summary on Organizational Factors, Impacts,
and Benefits: Template			 4-4
Table 4-2 Tiered Approach to Fish Advisories	 4-7
Table 4-3 Template for the Summary of Advisory Levels 	 4-11
Figure 1-1 Series Summary: Guidance for Assessing Chemical
Contamination Data for Use in Fish Advisories 	1-7

This report was prepared by the U.S. Environmental Protection'Agency
Office of Water, Fish Contaminant Section. The EPA Work Assignment
Manager for this document was Jeffrey Bigler, who provided overall project
coordination as well as technical assistance and guidance. EPA was
supported in the development of this document by Abt Associates Inc.
under the direction of Project Manager Kathleen Cunningham, Ph.D. All fifty
States and Territories were provided an opportunity for review and comment
on this document. In addition, preparation of this guidance document was
facilitated by the efforts of numerous Workgroup members listed below.
These individuals, representing EPA Headquarters, EPA Regions, State and
Federal Agencies, Native American groups, and advocacy groups, provided
technical information, reviews, and recommendations in the preparation of
this document. Participation in the review process does not imply
concurrence by the individuals with all concepts and methods described in
this document.
Peer Review and Workgroup Members
Jeffrey Bigler Chairman, U.S. EPA - Headquarters, Office of Water
External Peer Review
The following State Representatives provided an external peer review of this
document. Their insightful comments are greatly appreciated.
Gerald Pollack	California
Randall Manning	Georgia
Dierdre Murphy	Maryland
Elaine Krueger	Massachusetts
Pamela Shubat	Minnesota
John Hesse	Michigan
Greg Denton	Tennessee
Denise LeFlamm	Washington

Federal Agencies

Milton Clark
EPA - Region V

Howard Zar
EPA - Region V

Edward Ohanian
EPA - Headquarters,
Dennis Borum
EPA - Headquarters,
Thomas Armitage
EPA - Headquarters,
Richard Hoffmann
EPA - Headquarters,
Kevin Tlngley
EPA - Headquarters,
Edward Gardetto
EPA - Headquarters,
William Farland
EPA - Headquarters,
Research and
Penny Fenner-Crisp
EPA - Headquarters,
Ann Lindsay
EPA - Headquarters,
Clarice Gaylord
EPA - Headquarters,
Janice Cox
Tennessee Valley Authority

Gregory Cramer

Gunnar Lauenstein
National Oceanic and Atmospheric Administration
Other Organizations
Ann Watanabe
John Banks
Ed Fairbanks
Neil Kmiacik
Orrin Williams
Lee Whittig
Wayne Schmidt
Columbia River Inter-Tribal Fish Commission
Penobscot Nation
Native American Fish and Wildlife Society
Great Lakes Indian Fish and Wildlife Commission
People for Community Recovery
National Fisheries Institute
National Wildlife Federation

acute exposure
acceptable risk
exposure at a relatively high level over a short period
of time (minutes to a few days). (This is defined in
IRIS as 24 hours or less; however, sources consulted
utilized exposure periods of up to a few days.
Consequently, the more encompassing definition is
appropriate in reading this document.)
the maximum level of individual lifetime carcinogenic
risk considered "acceptable" by risk managers.
state, local, and tribal agencies and groups who have
responsibility for managing risks associated with fish
contamination are referred to as agencies in this text.
These may include departments of environmental
protection or health, tribal councils, and other types of
regulatory and governing groups.
Agency for Toxic Substances and Disease Registry,
U.S. Dept. of Health and Human Services, Public
Health Service.
body weight of an individual, expressed in kilograms
cancer potency
(often used interchangeably with slope factor) the
slope of the dose-response curve in the low-dose
region used with exposure to calculate the estimated
lifetime cancer risk. Often expressed as risk per one
milligram of exposure to the toxic chemical per
kilogram body weight per day (mg/kg-d). Usually is
calculated using the upper 95% confidence limit on the
linear term in the linearized multistage (LMS) model.
chronic exposure multiple exposures occurring over an extended period
of time, or a significant fraction of the lifetime

developmental toxicity adverse effects on the developing organism resulting
from exposure prior to conception, during prenatal
development, or postnatally up to the time of sexual
exposure limits
relationship between the exposure to an agent and
changes in aspects of the biological system, apparently
in response to that agent.
refers to the degree to which a fish advisory program
obtains compliance with advisories on the part of fish
response measure in a toxicity study (e.g., liver
damage, developmental toxicity, cancer).
United States Environmental Protection Agency.
a daily limit on exposure based upon health and
toxicity data, which the reader may calculate, using
the study data provided in this or other sources
refers to the match between the human, material, and
financial resources required by an agency to carry out
a program and the requirements of the program.
United States Food and Drug Administration.
refers in this document to non-commercial fish from
estuarine and fresh water sources, unless otherwise
number of new cases of a disease within a specified
kilogram, one thousand grams (103), equivalent to
2.205 pounds (avoirdupois).
milligrams, one thousandth (103) of a gram.
milligrams exposure per kilogram body weight of the
exposed individual per day.

capable of inducing changes in genetic material {e.g.,
recreational fishers
Reference Dose (RfD)
non-commercial and non-subsistence fishers.
Synonymous with sport fishers in this document.
estimate (with uncertainty spanning perhaps an order
of magnitude) of a daily exposure to the human
population (including sensitive subgroups) that is likely
to be without an appreciable risk of adverse non-
carcinogenic effects during a lifetime. Units are mg/kg-
the probability of injury, disease, or death under
specific circumstances.
see cancer potency. (Not to be confused with safety
factor approaches used in non-cancer analyses.)
sport fishers
non-commercial and non-subsistence
fishers. Synonymous with recreational fishers in this
subsistence fishers
refers in this document to be people who rely on non-
commercial fish as a major source of protein.
dose or exposure below which a significant adverse
effect is not expected.

1.1 Overview and Objectives
The objective of this volume is to provide state, local, and tribal agencies with
risk management guidance for developing fish advisories. Fish contamination
has been recognized as a potential health hazard in recent years. While most
fish provide an excellent source of nutrition, some fish are sufficiently
contaminated to cause health problems (e.g., Minamata disease in Japan).
The field of risk management, as it deals with fish advisories, is a relatively new
and evolving area. Although a few states have long-standing advisory
programs, written evaluations of these programs are generally not available.
Consequently, limited information is available from which to draw conclusions
or guidance regarding management strategies. Examples of types of advisories
were obtained from ongoing advisory programs. Advisory program staff were
consulted regarding their experiences with various management approaches.
This document therefore provides an overview of risk management rather than
detailed and highly specific guidance. EPA will provide more detail on the
experiences and recommendations of state and local programs in future editions
of this volume.
This risk management volume is part of a series that provides information on:
•	identifying and quantifying fish contamination,
*	evaluating risks associated with contamination,
*	managing those risks, and
•	communicating risk information and protective strategies to the public.
Various agencies have responsibility for issuing fish advisories and preventing
fish contamination. State, local, and tribal agencies have primary responsibility
for safeguarding the public against effects of contaminants in non-commercial
fish.1 Federal agencies are responsible for commercial fish and for activities
1 State, local, and tribal agencies are referred to as "agencies" in this
document and include groups responsible for managing risks associated with
fish contamination. These may include departments of environmental

related to preventing fish contamination. The United States Food and Drug
Administration (FDA)2 is responsible primarily for developing advisories
regarding commercial fish. The United States Environmental Protection Agency
(EPA), the Department of Energy (DOE), and the United States Fish and Wildlife
Service are also involved in managing and monitoring waterbodies, controlling
pollutant releases, and clean-up and remediation efforts that impact fish
contaminant concentrations (see Section 2.5).
This volume addresses factors to be considered in both the development of
advisory programs and the establishment of health-based fish advisories. This
process is complex due to the variety of factors involved:
•	the type of contamination,
•	the level of contamination,
•	local fish consumption practices,
•	local population characteristics, and
•	resources available for an advisory program.
The various options for limiting consumption of contaminated fish can be
tailored to fit local characteristics and needs. These options range from
approaches that require limited resources and have limited effectiveness (e.g.,
general advisories), to more resource-intensive and effective approaches (e.g.,
quantitative advisories). This document presents various options that may be
used in fish advisory programs and discusses their strengths and weaknesses.
Other relevant characteristics like resources available for program development,
risk levels, and economic and cultural impacts, are also discussed. Templates
for organizing information on options and characteristics are included.
Agencies currently employ a range of methods to estimate risks to human
health from consumption of chemically-contaminated fish. Results of a 1988
survey of such methods, funded by the U.S. Environmental Protection Agency
(EPA)3 and conducted by the American Fisheries Society, indicated the need
for a more consistent approach to assessing risks from contaminated fish.4
protection or health, tribal councils, and other types of regulatory and governing
2	See the Glossary for definitions of abbreviations and selected terms.
3	Throughout this document the abbreviation EPA will be used to represent
the U.S. Environmental Protection Agency.
4	In this document, fish refers to non-commercial fish from estuarine and
fresh water sources.

The four key components identified as critical in a risk-based approach to
developing fish consumption advisories were:
•	standard practices for sampling and analyzing fish,
•	standardized risk assessment methods,
•	standard procedures for making risk management decisions, and
•	standardized approaches to risk communication.
To address concerns raised by the survey, EPA is developing a series of four
documents to provide guidance to agencies issuing fish advisories for non-
commercial fish (i.e., self-caught fresh water and estuarine fish). These four
volumes comprise the Guidance for Assessing Chemical Contamination Data for
Use in Fish Advisories:
Volume I: Fish Sampling and Analysis (EPA, 1993a),
Volume II: Development of Risk-Based Intake Limits (EPA, 1994a),
Volume III: Overview of Risk Management, and
Volume IV: Risk Communication (EPA, 1994c).
Supplements to Volume II have also recently been released. These provide
information regarding exposure assessment, including fish consumption
patterns, risk characterization, and mapping. The four volumes and the
supplements should be used together, since no one volume provides all the
necessary information to evaluate and make decisions regarding the issuance
of fish consumption advisories. While these volumes are designed to provide
guidance to agencies developing fish advisory programs, they do not constitute
a regulatory requirement. To provide further information, EPA recently
developed the National Listing of Fish Consumption Advisories data base,
available from the Office of Water on five disks in a PC format.
1.2 Series Summary
To provide guidance on using a human health risk-based approach to determine
both the level of the advisory and the most appropriate type of advisory, this
series presents the following features:
•	methods to assess contaminant levels in fish tissues,
•	methods to evaluate population risks for specific groups, waterbodies,
and geographic areas;

discussion on identifying target populations, with information on
especially susceptible subpopulations;
descriptions of various risk management options for fish advisory
programs, with the experiences of agencies that have utilized the
factors that may be considered in selecting program options and
protection levels, including organizational factors such as feasibility and
efficacy, and the impacts of various options on target populations (e.g.,
on nutrition, economics, traditional activities, communities, and risk);
methods for organizing information on risk, options impacts, and target
populations' characteristics.
methods of risk communication
Table 1.1 provides more specific information on the major activities covered in
the documents in this series. All the activities carried out in the process of
developing fish advisories and managing risks associated with contaminated
fish are listed in the table. Volume I provides guidance on developing a
sampling and analysis program to characterize the nature of the fish
contamination distribution in waterbodies throughout an area. Volume II
provides an overview of risk assessment, chemical-specific risk values, and
methods for calculating meal intake limits. It also provides the groundwork for
a population risk evaluation. Volume HI, this document, provides information
on selecting and implementing various options for reducing risks associated
with contaminated fish consumption. This document focuses on fish
advisories, although other related activities are discussed. Volume IV provides
guidance on methods for communicating risk information and for evaluating the
target audience for risk advisories to determine the best approach for
communicating risk.

Table 1.1. Activities Related to the Development of Fish Advisories and Risk Management and Volumes in the Series Containing
Discussions of These Activities

Sampling and
Risk Assessment
Calculate Health-
Evaluate Options
Select Appropriate


Based Intake Limits

Risk Management


1 .concentration
1. individual risks
1. health-based
1. potential options
1. identify options

in fish tissue
(V. 2)
consumption limits
and administrative
that are optimal for a

(V. I)
2. population and

Major functions are listed in the first row. The data or conclusions generated
by each step are listed below the activities, along with the volume in which the
activities are discussed. Some related activities relevant to fish advisories but
beyond the scope of this series are listed in the final row. As Table 1.1 shows,
the development of advisories depends on the collection of appropriate data in
the early stages of program development and proceeds through analysis (risk
assessment) to decision-making (risk management).
1.3 Volume III Contents
Figure 1.1 shows how Volume III fits into the overall series and lists the major
categories of information provided. This volume covers topics necessary for
decision-making to manage risks related to chemically contaminated fish. The
sequential order of the sections follow the anticipated sequence of activities to
be carried out in developing a risk management program.
Section 2 contains a discussion of various options for limiting contaminated fish
consumption. Federal roles and activities are identified. Regulatory and other
options for state, local, and tribal governments are presented with discussions
of the organizational features of each option. Some anecdotal information is
provided on the experiences of various agencies in implementing different
program options.
Section 3 provides information on the potential impacts of limiting
consumption, including social, economic, cultural, and nutritional impacts,
costs, feasibility, legislative and political constraints, and other factors. The
impacts vary depending on the specific circumstances of an area and the
population of concern.
Section 4 contains a discussion of methods for comparing health risks
associated with consumption to impacts of limiting consumption. It provides
schematics for organizing information on a site-specific basis regarding various
risk management options, their applicability to an area, and attributes and
requirements for their implementation. A tiered approach to developing fish
advisories is discussed. Templates are included to help risk managers organize
their information to evaluate needs and to identify the optimal group of options
and consumption limits.
Section 5 contains a list of references consulted and cited.

Figure 1.1 Series Summary: Guidance for Assessing Chemical Contamination
Data for Use in Fish Advisories

rปซ t hi ~
Risk Management
' *1 i\ "

\	l\
2. Options for limiting
3. Impacts of limiting
4. Decision-making regarding
fish advisory options
Supplement to Risk Assessment:

1.4 Methods and Sources
This document was developed using information from a variety of sources:
•	State documents related to the development and implementation of fish
advisories were consulted. These sources provided data on existing
programs and, in some cases, comments on their efficacy.
•	Staff members of some agencies and tribal groups with long-standing
programs were consulted regarding their experiences and recommendations.
Due to the recent development in many states of extensive advisory
programs, limited information on management strategies exists. Future
editions of this volume are expected to contain additional information on
program development processes and strategies.
•	Government publications and journal articles were consulted for information
on scientific issues including nutrition and economics.
•	Government documents and programs were consulted for information on
mapping methods (e.g., GIS mapping), regulatory roles of various agencies,
and information on existing programs designed to address pollution
prevention and waterbody remediation.
•	Workgroup members6 and other experts from state, local, tribal, and federal
governments, academic institutions, and advocacy groups were contacted
by phone, and provided both information about their current programs and
experiences and ideas for future activities.
1.5 Underlying Assumptions
Risk management for any environmental program requires numerous staff and
management decisions. The decision-making process is aided by
comprehensive information on both the nature of the problem to be addressed
and the characteristics and implications of options for remediation. The
6 Work on this document was guided by a workgroup of experts on fish
contamination issues. Their names and affiliations are listed in the
Acknowledgements section in the front of this volume. This group reviewed
the outline and drafts of the document, and made numerous comments and
recommendations on the content.

approach to risk management described in this volume is based upon underlying
assumptions regarding decision-making in the public sector:
Chemical contamination of fish may pose health risks. These risks are
dependent on the nature and severity of the contamination and the
characteristics of the exposed population. Risk estimation is a developing
science that cannot predict precise effects in individuals or populations.
Consequently, uncertainty exists regarding the type and extent of health
risks. Risk estimates can be used, however, with other relevant
information, to make decisions regarding fish advisory programs.
The goal of developing fish advisories is to minimize the health risks to fish
consumers as well as minimize any negative effects of restricting
consumption. When fish contamination levels pose sufficiently elevated
health risks (determined on a local basis), agencies may elect to take
restrictive action to protect public health. Because many risk reduction
options are associated with some negative impacts, decision-makers must
also consider potential impacts on all affected parties.7 These impacts
include social, cultural, economic, health, and any other impacts associated
with options for reducing risks.
Most options for reducing risks will require trade-offs between risk reduction
and social, economic, and other costs. Decision-making to select options
is primarily a policy activity rather than a scientific one. Consequently, it is
beneficial to make such decisions with input from all affected parties.
Each agency and exposed population has unique characteristics, resources,
strengths, goals, and constraints. Consequently, there is no one best
approach to developing and implementing fish advisory programs. Each
agency should design a program based upon the unique characteristics of
its contamination problem, populations at risk, and affected parties. EPA
does not recommend specific target intake limits or risk levels for
contaminants. It also does not recommend using FDA action levels for site-
specific fish consumption advisories.
The ultimate goal of a fish contamination risk reduction program is to return
waterbodies to a condition in which fish are no longer contaminated at a
level that will pose unacceptable risks to human health. While remediation
of contaminated water is beyond the scope of this document, it is briefly
7 Affected parties may include fish consumers, individuals whose livelihood
or lifestyle are dependent on non-commercial fishing, and individuals whose
land use or value are related to non-commercial fishing.

discussed in Section 2.5, which contains a listing of federal programs that
may provide assistance.
1.6 Critical Decisions
Both science and policy are components of a fish advisory program. In the
policy arena, decisions are required to establish and achieve policies and goals.
Decisions are also required to conduct risk assessments and determine how
science will be used in establishing policies. Many elements of risk assessment
involve significant uncertainty (e.g., animal to human extrapolations,
differences in susceptibility over a lifespan, the effects of exposure to a mixture
of contaminants). Although some scientific data on these topics exist, they are
rarely definitive. Under these circumstances, the decisions that transcend
current scientific knowledge may be considered policy decisions, and both
policy and scientific experts should participate in the decision-making process
to arrive at the best choice. Scientists may be able to best describe the
uncertainties and some alternatives, while policy makers may bring non-
scientific issues to bear and consider potential impacts of decisions on a
broader level.
In this document (and in others in the series) many issues that are decision
points can be found in phrases like "readers may wish to...," where the reader
may determine the best course of action. Minor decisions may be related to
the use of specific resources (e.g., a particular laboratory method, a set of
toxicological information sources). These decisions are expected to have a
relatively minor impact on overall program activities and efficacy. Alternatively,
critical decisions (or groups of decisions) are those that may have a significant
impact on the target population, their level of risk or protection, and program
Table 1 -2 lists critical decisions in risk management for a fish advisory program,
along with the section in which they are addressed. As stated above, the four
volumes in the series Guidance for Assessing Chemical Contamination Data for
Use in Fish Advisories are designed to be used together, although they address
different topics regarding fish advisory development. Volume III, addressing
risk management, provides an overview of the critical decisions made
throughout the fish advisory development process. Relevant discussions also
appear in other volumes in the series (e.g., decisions regarding sampling and
analysis [Volume I], risk assessment [Volume II], and risk communication
[Volume IV]). The critical decisions listed in Table 1-2 are discussed briefly in
this section, and in more depth in subsequent sections of this volume.

Table 1-2. Critical Decisions
Nature of Decision (Category)
Section of Volume

III or Volume

1. sampling and analysis
Vol. I
2. population risk estimation (risk assessment)
Vol.II Supplement A

consumption rates - subpopulation selection

non-fish exposure - air, water, soil,

occupational, non-fish food sources

risk values - RfDs, cancer potency values,

other values

3. selection of target populations or risk levels
Vol.II Supplement A
4. risk management options under consideration
5. consideration of positive and negative
3, 4.2

6. selection of most appropriate risk management

7. level of protection afforded by advisories
4.4 and Vol. II
Supplement A
carcinogenic effects - acceptable risk level

non-cancer effects - value selected as


8. level of program effort and funding
9, program evaluation and modification

Category 1. Sampling and Analysis
Decisions regarding sampling and analysis are discussed in Volume I. These
decisions include sampling location, frequency, the chemicals analyzed, and
those levels and frequency of occurrence that trigger the decisions to issue
advisories. In most cases, it is neither economically feasible nor necessary
to sample and analyze all waterbodies. When sampling has not been
conducted previously, no scientific information is available on which to base
sampling decisions. Consequently, sampling and analysis decisions may be
based on policy or on the likelihood of contamination (e.g., using TRI data,
the presence of Superfund sites, or clusters of environmentally-related
Category 2. Population Risk Estimation.
Methods for calculating population risk require risk assessors to combine
information on consumption patterns, contaminant levels, and risk values
(e.g., RfDs) to obtain an overall estimate of risk for various population
subgroups.8 These methods are described in Supplements A and B to
Volume II. Risk assessment used to establish risk-based fish advisories
incorporates many decisions that involve policy considerations because they
transcend current scientific knowledge. Examples of these decisions include
choosing a health endpoint among many credible endpoints, and the degree
of safety incorporated in risk values and subsequent risk estimates.
A range of values for the inputs used in risk calculations are discussed in
Volume II. The exposure and toxicity values used affect the outcome of risk
estimates. Risk estimates, in turn, are often used to determine the
appropriate course of action, the population groups or geographic areas
requiring action, and the fish advisory levels.
Critical decisions include the type of consumption data used (e.g., survey
data collected locally, "average" consumption values from various studies,
"high-end" estimates from studies), the location and nature of contaminant
sampling {which may depend on available resources), the sources of
concurrent exposure to the same contaminants considered, the risk values
used to estimate risk, and the level of protection afforded by the advisory.
8 EPA is currently reviewing risk assessment methods for carcinogens and
non-carcinogens, information will be provided on any new recommended
approaches (e.g., the benchmark dose approach, non-linear cancer
extrapolation, categorical regression) in future editions of this series.

Decisions on these factors involve policy rather than science and should be
considered by risk managers in developing an overall fish advisory program.
Category 3. Target Populations and Risk Levels.
Identifying target populations is a critical decision, because it may determine
which groups will be the focus of risk reduction activities. This decision
may be linked to those regarding sampling locations and groups to be
considered in selecting consumption data {either through surveys or based
on previous studies in the literature). If a risk-based approach is taken to
population selection, targeted populations will be those groups identified
following a risk assessment as having unacceptably high risk levels.
Decisions are also required to determine the breadth of the population to
protect through advisories. Choosing members of the fish consuming
population who eat an average (50th percentile) amount of fish versus those
who consume larger amounts (i.e., at the 80, 90, or 99th percentiles) is a
policy rather than a scientific decision.
The selection of unacceptable and acceptable risk levels are significant
policy decisions and may involve evaluating various assumptions underlying
the risk estimates. Risk managers may choose to focus on a particular risk
level for carcinogens {e.g., one in one million) or specific types of risks (e.g.,
developmental, cancer, organ-specifictoxicity to susceptible subpopulations)
as being of critical importance. Others may focus on particular communities
or population groups at risk. These decisions are very important because
they may determine levels of protection, who is protected, and the scope
and nature of fish advisory programs.
Considerable trade-offs exist in many cases between maximizing public
protection and minimizing an advisory's negative impacts. If the goal is to
protect 99% of the population, including the highest consuming individuals
in a high-consumption population group, advisories will be much more
prevalent (and any negative impacts more pronounced) than if a program
were to target the average consumer's behavior. However, focusing on
average exposure and risk levels may not protect the high-risk populations
who need to obtain information that they can use to protect their health.
Category 4. Options Under Consideration
Risk managers determine which program options are under consideration in
a fish advisory program (e.g., posting notices, catch and release, restricting
waterbody access). From this set of options a subset is usually identified
that will actually be employed. The decision to consider all possible

strategies for risk reduction is important because it provides wide latitude
in addressing the needs of target populations. Very restrictive options, such
as restricting waterbody access, are rarely employed in practice.
In many areas, risk managers may choose options to reduce fish-related
risks under a specific set of constraints. For example, agencies responsible
for tracking contaminant levels in fish may not have the regulatory authority
to restrict fishing access. In most areas, however, the health department
has authority to restrict access in cases where a clear and present danger
to the public exists. In many cases, budgetary constraints may curtail
significantly the number and types of risk management options available.
Because the options have differing potentials for reducing risk, limiting the
types of available program options may affect the risk reduction potential of
a program significantly.
Category 5. Consideration of Positive and Negative Impacts
Recommending limitations in fish consumption involves tradeoffs with
respect to health, recreation, economics, community and traditional
activities, personal interests, and other perceived benefits of fish
consumption. Although risk managers are encouraged to consider all risks
and impacts in some way, managers may elect to focus on one or a few of
the potential risks or impacts. The types of options and the strength of the
advisories recommended will depend on how various population groups and
their risks are evaluated and upon the impacts that are considered most
important. Deciding how to prioritize and balance the risks and impacts
involved wiii have a pronounced effect on fish advisory programs.
Category 6. Selection of Most Appropriate Options
Selecting appropriate fish advisory program options from those that have
been considered is obviously a critical decision in developing a program.
Although this decision appears to be the most important one, it generally
corresponds to individual or community risk levels and characteristics. The
various decisions that have been made up to this point regarding
consumption rates, sampling and analysis, selection of risk values, treatment
of non-fish exposures, and consideration of impacts, all contribute
significantly to the basis for selection and the ultimate choice of appropriate
options, target populations, and protection levels.
Category 7. Level of Protection
Risk managers may choose from various risk values {RfDs and cancer
potencies) to establish consumption limits. These values may generate

consumption limits that vary by orders of magnitude for a single
contaminant, especially when cancer-based and non-cancer-based values are
compared. In addition, targeted acceptable risk levels are used in setting
limits for carcinogens. Decisions regarding risk values can have a
substantial impact on consumption advisories and on potential risks to the
Carcinogenic Effects - Acceptable Risk Levels
Cancer risks are evaluated based upon an assumed relationship between
exposure and lifetime risk as defined in the cancer potency values for each
target analyte. Risk managers determine the level of risk (e.g., one in one
million) that is acceptable. This decision enables them to select appropriate
exposure level. The acceptable level of risk can be determined by the needs
and goals of the target population, the decision-makers, or, under ideal
circumstances, by joint discussions between the two groups. Meal
consumption limits provided for the carcinogenic target analytes in Volume
II are listed for three cancer risk levels: one in ten thousand, one in one
hundred thousand, and one in one million. The method used to calculate the
values is presented in Volume II so that alternative risk levels can be
Non-cancer Effects - Value Selected as Benchmark
The potential for non-carcinogenic effects can be evaluated by comparing
exposures to a Reference Dose (RfD) or some other benchmark of a "safe"
exposure level. Volume II presents the RfDs developed by EPA, along with
a summary of toxicological information for the 23 target analytes. In the
summary data, recent study results are presented for some analytes
regarding developmental, neurological, and other types of toxicity. Risk
managers may choose which benchmark value they consider most
appropriate for their target population of concern. In some cases, more than
one value may be selected for various population subgroups (e.g., children,
women of reproductive age).
Category 8. Level of Program Effort and Funding
As noted above under Section 4 (Selection of Most Appropriate Options),
financial constraints may affect the choice of options for developing a fish
advisory program. Financial and other resource factors (e.g., staff,
materials, access to information) also affect the methods used to implement
options, how extensively they are implemented throughout an area, and
ultimately how effective the programs are.

Category 9. Program Evaluation and Modification.
Program evaluation and modification are important activities to be
considered even in the initial planning of a program. Reviews of a program's
design are necessary to determine how effective it is: who it is reaching,
whether their behavior has changed, and whether the target population
requires additional information. Program evaluation also enables the risk
manager to determine how the program might be altered to better address
its goals. Accordingly, flexibility is vital so that necessary modifications can
be made both in the initial design and over time as needs change. The
decision to include these elements in a program design will help provide for
the long-range success of a fish advisory program.
This document provides an overview of a wide variety of risk management
options and their potential utility and impacts. State, local, and tribal risk
managers are urged to review the various options and to include all interested
parties in the decision-making process in order to develop the best possible
programs for their areas.
1.7 Environmental Justice
This document reflects EPA's policy regarding environmental equity and justice.
The President's Executive Order {Feb 11, 1994), Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations,
specifically directs federal agencies to identify and address disproportionately
high adverse human health or environmental effects on minority and low-
income populations and workers.9
Environmental justice is particularly relevant to the work discussed in this
document because contaminated fish may be consumed in greater quantities
by minorities and low-income populations in many areas of the United States.
These groups often comprise subsistence fishers and may be simultaneously
exposed to the same or similar acting contaminants in air, water, and other
foods. This exposure may occur both in an urban environment, where high
pollution levels often have obvious industrial or other sources, and in less
developed areas, where water or soil contamination may occur via long-range
transport or from non-point sources.
9 Readers are encouraged to review Executive Order 12898 in its entirety.

Many specific recommendations of the executive order address program
coordination and activities tracking at the federal level. Additional
recommendations may be useful to state, local, and tribal governments for
better addressing environmental justice issues. These include the following:
•	promote the enforcement of all health and environmental statutes in areas
with minority populations and low-income populations;
•	ensure greater public participation;
•	improve research and data collection relating to the health and environment
of minority populations and low-income populations;
•	identify differential patterns of natural resources consumption among
minority populations and low-income populations; and
•	identify multiple and cumulative exposures.
The executive order contains some specific recommendations regarding
subsistence consumption of fish and wildlife that may also be relevant for
state, local, and tribal governments:
•	collect, maintain, and analyze information on the consumption patterns of
populations who rely principally on fish and/or wildlife for subsistence (urban
and rural);
•	communicate to the public the risks of those consumption patterns;
•	provide guidance reflecting the latest scientific information available
concerning methods for evaluating the human health risks associated with
consuming pollutant-bearing fish or wildlife. Consider such guidance in
developing policies and rules;
•	translate crucial public documents, notices, and hearings relating to human
health or the environment for limited English-speaking populations; and
•	ensure that public documents, notices, and hearings relating to human
health or the environment are concise, understandable, and readily
accessible to the public.
These recommendations to federal offices are generally covered by the caveat
that such activities should be carried out whenever practicable and appropriate.
While these are potentially useful and necessary activities, this information does
not constitute a requirement for state, local, and tribal governments, although

the values espoused are useful for consideration. If additional assistance is
needed on environmental justice issues and strategies, readers may wish to
U.S. EPA Office of Environmental Justice
401 M. St. S.W.
Washington, D.C.
phone: (202) 260-6357
This guidance document addresses concerns regarding environmental justice
through the variety of mechanisms discussed below. A major focus of risk
management is to evaluate and reduce risks to the most highly exposed
individuals or population groups. With respect to fish contaminants, these
people are often subsistence fishers, although in some areas they may be
primarily sport fishers.
Highest consuming or most susceptible subgroups of concern include
subsistence fishers, pregnant women, children, groups with poor nutritional
status, and individuals with certain pre-existing health problems. Volume II
provides substantial toxicological information regarding susceptible subgroups
on a chemical-specific and chemical class-specific basis. Information is also
provided on characteristics of population subgroups that may cause them to be
generally more susceptible to chemical exposures. These subgroups, such as
women of reproductive age and children, may be targeted for special efforts in
advisory programs (discussed in this volume). Specific methods for calculating
advisories tailored to children of various ages and other subgroups are
presented in Volume II and discussed further in this document.
The discussions of exposure assessment in Volume II and its Supplements
include information regarding fish consumption patterns of highly exposed
minority groups such as Asian and Native American communities. The results
of numerous recently completed studies show higher consumption rates among
these groups than among the general fisher population.
Studies have indicated that highly polluted areas contain disproportionate
numbers of minority and low-income populations. To avoid an unsafe exposure
level, groups exposed to the same or similar-acting contaminants in media other
than fish may require lower consumption limits than if their exposure occurred
only through fish. To address this concern, this volume contains information
regarding methods for estimating total exposure including air, water, soil, food,
and workplace exposures. This information, important for any groups exposed

through multiple media, is particularly relevant for groups who reside in highly
polluted areas, such as industrialized urban areas and near hazardous waste
Throughout this text, readers are reminded of aspects of the risk management
process that may involve public participation. Encouraging participation by
traditionally-disenfranchised groups may improve fish advisory program
implementation and efficacy. Decisions on the type of risk reduction programs
to be established in a community, the pursuit of remediation efforts, and the
level of acceptable risk for a community requires community participation to be
the most effective. Discussions of critical decisions in this volume emphasize
the value of community member participation and the need for information
regarding affected communities.
The potential community, societal, and economic impacts of risk management
fish advisory options are discussed in this volume. Subsistence fishers and
some other fisher groups consume higher quantities of non-commercial fish;
Consequently, they are at greater risk of negative nutritional, economic, or
community impacts if their fish consumption is reduced. The negative impacts
of consumption reductions are discussed in Section 3. Numerous
representatives of Native American, Asian American, urban fishers, rural
fishers, and other groups were contacted to obtain their ideas regarding the
various options for reducing risks associated with contaminated fish
consumption {see the expert source list under Acknowledgements in the front
of this document).
Many individuals consulted from community and tribal groups requested
information regarding environmental remediation and pollution prevention be
included in this volume. These groups frequently expressed the sentiment that
the ultimate goal should be to improve environmental quality so that fish
advisories are no longer necessary. This has been EPA's goal since its
inception and has been shared by many state, local, and tribal programs. In
response to these requests, information was collected from a variety of federal,
state, tribal, and other sources regarding rights and responsibilities in
environmental remediation and pollution prevention. The information
summarized in Section 2 provides a road map through various offices at the
federal level responsible for remedial action and pollution prevention.
Information on federal activities and responsibilities may provide both risk
managers and affected groups with the ability to evaluate ongoing efforts,
obtain additional information, and participate in determining future activities
where necessary. Because state, regional, local, and tribal programs vary
considerably, a summary of their activities was beyond the scope of this

The environmental justice activities at the federal level are being accelerated as
the need to evaluate and address inequities in environmental contamination and
health risks is recognized. The approach outlined in this series is designed to
assist state, local, and tribal governments in evaluating risks for both the
general population and subgroups, allocating resources based on risk levels, and
providing more healthful alternatives for all their citizens. EPA welcomes
recommendations regarding these issues and approaches to addressing
environmental justice.

2.1 Overview
A variety of options exist for limiting consumption of contaminated fish. This
section provides a,description of options commonly employed to reduce fish
contamination risks. The focus of this section is on evaluating the options from
the perspective of the agency responsible for fish advisories. Some
considerations discussed in this section include:
•	the feasibility of program implementation — the match between the
human, material, and financial resources available to an agency and
those required to carry out a program; and
•	the efficacy of various options — the degree to which a program obtains
compliance with advisories on the part of fish consumers.
Information on the experiences of some' actual programs are presented,
including the relative success or failure of some options, difficulties in
implementation, and other aspects of developing programs. Section 3 provides
additional information on this topic with a focus on how options impact the
target population or area: economically, socially, culturally, and nutritionally.
No single approach is appropriate for all circumstances. Each location and
population of concern vary and require programs designed to address specific
local needs and resources. In addition, agencies vary in the resources available
to develop programs. EPA does not recommend one or a small group of
options as preferable. Rather, they suggest that decision-makers consider all
relevant information and choose those options that best serve the needs of fish
consumers in their areas.
In evaluating how to approach fish contamination problems, it may be useful
for state, local, and tribal risk managers to review the roles and responsibilities
of the federal government. The responsibilities of the federal government
regarding commercial fish are presented to clarify the distinction between
federal oversight of commercial fish versus non-federal responsibilities for non-
commercial fish.
Information on remedial responsibilities and activities of the federal government

that may impact fish contamination are discussed at the end of this section to
provide additional information on options for reducing contaminant exposures.
The discussion includes federal statutes and regulations that may be used to
address fish contaminants {directly or indirectly). Sources of additional
information on laws and activities related to air, soil, food, and water pollution,
and hazardous waste are provided, including hotline numbers at EPA.
2.2 Program Goals
Program goals include the overall objectives of a fish advisory program. They
may include a description of geographic areas and populations to be addressed,
the targeted reduction in exposure and risk, and other objectives related to
contamination reduction. Goals will typically be defined by the specific
characteristics of a contamination problem in an area. The goals may depend
on the scope of the programs required. The program scope is defined in terms
of the number of people who must be reached and the degree of efficacy-
required to achieve an acceptable level of risk. Goals such as full compliance
by all pregnant women may be more stringent when risks are high. The
efficacy requirements of a program may depend on how critical it is that the
targeted populations comply with recommended changes in their consumption
The goals an agency establishes, along with the need for effective advisory
programs and subsequent resource requirements, are linked directly to the
scope of the contamination problem in terms of risk and numbers of people
exposed. In general:
elevated exposure	—>	more restrictive	—> greater resource
and risks	advisories	requirements
The staffing and other resource requirements of a fish advisory program are
contingent on the program goals.
When risks are anticipated to be high, significant effort may need to be
invested to ensure widespread compliance with recommendations. Information
may need to be disseminated through various media and with significant
support {e.g., a hot line number, local presentations, press releases, fact
The exposure and risk levels are determined through sampling and analysis
programs {discussed in Volume I) and risk assessment {discussed in Volume II
and in Supplements 1 and 2 of this volume). These sources provide guidance
on obtaining and using fish contamination data with consumption pattern

information to estimate exposure. From this information, risks are estimated
for various population subgroups, which are then evaluated for advisory
program need. Methods used to map affected populations and other relevant
information are provided in Supplement C to Volume II.
Program goals may also reflect the objective of minimizing an advisory's
negative on targeted populations and areas. These negative impacts are
discussed in Section 3 and include economic, cultural, nutritional and other
potential impacts that may result from fish consumption restrictions.
Program goals are usually constrained by available resources. Because
resources are often limited, risk managers must decide who has the greatest
need to be reached and what level of program activity will be directed at each
of the targeted populations.
2.3. Options for Limiting Consumption
This section focuses on aspects of fish advisory programs directly related to the
agency's activities. Options and their feasibility and efficacy are described from
the agency's point of view. The feasibility of an option depends on the
requirements of an option in relation to the resources of an agency. To
evaluate this, it is useful to consider various factors including:
•	staffing,
•	costs of materials and facilities,
•	already-existing program materials,
•	inter- and intra-agency support, and
•	other considerations.
The requirements of individual fish advisory program options merit separate
evaluations to determine program feasibility. Such evaluations are often
qualitative because it is usually not possible to precisely quantify the scope,
level of professional involvement, and expenditure of resources for each option.
As indicated above, federal agencies have significant responsibilities for
commercial fisheries. States, local governments, and tribal agencies (referred
to collectively in this section as agencies) have primary responsibility for non-

commercial fishing. These responsibilities may be carried out through various
departments, including those of:
•	environmental protection,
•	health,
•	fisheries, or
•	other public agencies or governing units.
A fish advisory program may be part of a larger program responsible for other
related activities including education, pollution prevention, clean-up of
contaminated waterbodies, etc. In some areas the health department may be
responsible for determining fish advisory levels while the department of
environmental protection may implement the programs at the local level and be
responsible for enforcement. During new program development, decision-
makers may wish to determine those agencies best able to enact program
components and allocate responsibilities accordingly.
An option's resource requirements will depend significantly on the scope of the
contamination problem and the programs goals. Resource requirements will
also depend on the extent to which agencies can use existing information
sources and the resources of related agencies or groups performing similar
activities. The level of effort and costs required can be reduced somewhat
•	careful targeting of sampling and analysis programs,
the use of consumption limits provided in Volume II,
•	obtaining population data from census data bases, and
•	identifying readily available sources for other needed information.
Cooperation between health and environmental agencies, community groups,
local colleges and universities with relevant program areas, and local health
professionals may reduce resource requirements for developing advisories and
disseminating information. For example, the state of New Hampshire has
involved community groups in the collection of fish samples, thereby saving the
state staffing and transportation costs.
Some aspects of program development, such as planning, require time and
expertise primarily from within the agency, although support from local
professionals may also be sought in this area. Establishing an advisory group
of volunteers with expertise in related fields may provide an inexpensive
method to gain local support and obtain necessary information. Under most
circumstances, involving the local target population will provide essential
information and facilitate cooperation in the establishment of effective
programs. Although this is easier for local programs to carry out, state

programs may also encourage local involvement coordinated through local
governments, health departments, school departments, or community groups.
Detailed studies have not been conducted on the resource requirements or
efficacy of fish advisory options across programs and states. Consequently,
much of the information in this section has been obtained through
conversations with state, local, and tribal staff, and other affected parties.
Program reports were also reviewed. Although most information provided
below is site specific and frequently anecdotal in nature, we have attempted to
include information that has overall relevance to option evaluation and is not
specific to single areas and groups. We welcome comments and information
on the options discussed in this volume and recommendations for other options
to be considered. Most of the data on and about options for reducing health
risks associated with consuming contaminated fish have been developed
relatively recently. An exchange of information on this topic will provide a
more complete basis for decision-making in the future.
Table 2-1 provides a list of options for limiting consumption of contaminated
fish. Options are arranged according to the type of activity and in order of the
severity of restriction (e.g., limiting a catch is listed before banning fishing).
The options fall into four main categories of activities: no action, development
of fish advisories, catch and release restrictions, and fishing bans. Within these
categories, a spectrum of activities may be carried out.
The options considered in fish advisory program development are critical to the
nature of the final program. A limited number of options can be considered by
those developing new programs. Decision-makers must consider any specific
constraints that restrict their choices before considering the advantages and
disadvantages of the various options. Risk managers may be operating under
some constraints regarding their options for reducing fish-related risks, or they
may have wide latitude in establishing programs. For example, some agencies
may have the authority to restrict fishing access if sufficient risks can be
demonstrated. In other areas, options may be limited to notification and
education. Options may also be limited by budgetary or other conditions. The
choice of which options to consider is one of the critical decisions noted in
Section I.
Restricting the options from which a program may choose may
significantly affect the risk reduction capabilities of a program because
the options have differing potentials for reducing risk.

Table 2-1. Options for Fish Advisory Programs
No action
Fish consumption advisory

* General guidance

• Quantitative guidance

• Voluntary

• Mandatory
Fishing ban

• Voluntary

• Mandatory
Anticipated impacts of the options including those on nutrition, local culture,
and the economy are discussed in Section 3. A methodology for considering
adverse impacts of options in contrast to benefits of fewer health risks is
discussed in Section 4.
Because fish contamination, local conditions, and population characteristics are
unique to each area, risk managers may choose to implement different policy
options for different waterbodies within the same Jurisdiction. Consequently,
risk managers may want to consider a variety of options under different
circumstances. The use of various options allows programs to be tailored to
local needs and, ultimately, to be most effective. Many states have used a
variety of strategies to address fish consumption, depending on specific area
characteristics. The approach taken in Washington State illustrates this point.

Example; Washington State
The state of Washington has experienced a steady decline in salmon runs
over the past fifty years, but a notable and sharp decrease over the last
few decades. These recent declines have resulted in a wide variety of
fishing restrictions posted throughout the region for management of fish
stocks. For example, some waters are closed completely to fishing
certain species whose population is endangered. Other waters are catch
arid release only for both management and public health concerns.
Others are open but with strong peer pressure by increasingly
knowledgeable fishers, including sportfisher associations, environmental
groups and tribal organizations, to selectively harvest fish that are out-
competing the native species most valued for recreational and cultural
With the increased visibility of declining runs, individuals have become
more receptive to the need for management strategies protecting the
long-term harvest of preferred species. Familiarity with management
restrictions designed to allow fish stock regrowth has also made
individuals more responsive to restrictions due to public health concerns.
Strong emphasis was placed on using restrictions as an interim step for
managing fish contamination hazards among community representatives
consulted on this issue. They emphasized that preventing water
contamination in the first place should be the primary goal (Coombs,
1994; Cole, 1994; Watanabe, 1994).
Although fishing restrictions in this case were employed to allow fish stock
regrowth, similar strategies can be employed to limit exposure to contaminated
Many tribal affiliates have indicated that some options for limiting the
consumption of contaminated fish would be unacceptable. Fishing bans and
catch and release restrictions are contrary to the fishing-based cultures of many
of these communities. Both sport fishing organizations and the sport fishing
public may also be opposed to certain options that limit access to fishing
grounds. Further details about these concerns are discussed in Section 3.
Fish advisory programs, while existing for many years in some areas, are a
relatively new undertaking for many risk managers. The options discussed
below may prove effective in some areas and not in others. Their success or
failure may depend on numerous factors discussed in this and subsequent
sections. Because programs can evolve over time, they should change as

better ways are found to reach their goals arid as circumstances and
populations change. Risk managers may wish to test the efficacy of multiple
advisories and determine which strategies use resources most effectively and
are most appropriate for various audiences. (This is discussed in Volume IV:
Risk Communication.) By maintaining a flexible approach to developing or
modifying programs, risk managers are best able to respond to the changing
needs of the populations they serve.
2.3.1 No action
The least resource-intensive action for agencies to undertake it to having no
fish consumption policy. Under this option, agencies allow unlimited fish
consumption, issue no health warnings, permit fishing, and, if necessary,
consider discoveries of adverse human health impacts on an individual basis.
This option should be considered when contamination and health risk data
indicate that no action is required. The "no action" option is not recommended
as a strategy to conserve resources unless sampling and analysis data are
available that indicate this is an appropriate approach. Feasibility and Efficacy
A policy of no action may be most appropriate in areas of consistently low
fishing activity and low contamination (as determined by a sampling and
analysis program). A brief review of the sampling results in relation to the
screening values provided in Volume I may indicate minor or minimal risk.
Exercising this option in areas with limited fishing activity in the absence of
sampling and analysis data may pose health risks to local fishers if high
contamination levels exist. Volumes I and II both provide information on how
risk managers may evaluate the likelihood that contamination exists (e.g.,
proximity of the waterbody to industrial sources, agricultural run-off, known
contaminated areas). Long-range transport from industrialized areas to non-
industrialized areas is known to occur with mercury contamination and with
other contaminants. Consequently, risk managers should consider obtaining
sampling data for all waterbodies where fishing occurs. If the data indicate low
or no contamination in some areas, less frequent sampling may be planned for
those areas.
In areas of high fish contamination, particularly where adverse health effects
are likely to occur, having no policy may incur significant risks to fishers and
their families and has the potential to confuse and anger the public. It also
minimizes public awareness of fish contamination and related issues (e.g.,
water pollution risks) (NY DEC, 1985).

Example: Midwest High-Risk Fishing Population
In one midwestern state, community groups are aware of the fish
contamination problem in their areas. In a substantially contaminated
area, the director of a large community organization was consulted for
this document regarding fish advisories. Waterbodies in this urban area
are surrounded by industry, landfills and transportation routes. Runoff
from agricultural lands also eventually reaches the waterbodies, and both
runoff and air emissions from numerous other point and non-point
sources are discharging into the water.
The director indicated that the state and city have not put up signs at
major community fishing sites. The advisories are not distributed or
available to either the fishing or consuming population (each is a distinct
population) through means that are readily accessible to area
communities. Advisory information, provided by the state with fishing
licenses, is not readily accessible to the low-income minority fishers,
who typically do not obtain licenses primarily for economic reasons. The
director also noted that a large low income black population fishes the
polluted waters, and the catch is distributed widely through local (illegal)
fish markets and shared with extended family, friends, and neighbors.
The director felt that signs were not posted because the agencies were
concerned about panicking the community. The community perceives,
however, the lack of regulatory attention as a reflection of the agency's
indifference to their well being.
Further consultation with state staff on this issue indicated that the state
develops advisories based on a widespread sampling program. Elevated
contaminant levels had been detected in the areas of concern and signs
were posted in the past. This practice was discontinued due to extreme
displeasure from local park authorities. Although additional information
was not available from park authority personnel, the attraction that this
area has for many tourists and seasonal fishers, both of whom contribute
substantially to the local economy, may have played a role in the no-
posting policy.
As this example illustrates, the lack of effective action in this case may
minimize costs and certain negative advisory impacts (e.g., discouraging
recreational fishers). Conversely, it generates an entirely new set of problems
that may undermine the fundamental attitudes towards, and trust of,
governmental agencies on the part of affected communities. Inattention to
these types of problems may lead community members and leaders to the

conclusion that their health and other concerns are not a priority for local
agencies and political leaders.
In general, a "no action" policy maximizes fish consumption and its associated
nutritional and other benefits {see Section 3). It also minimizes costs and effort
required by governmental bodies and requires no specific governmental
structure, planning, or empowerment. Local circumstances will determine the
advisability of this option. If strong business interests are tied to maintaining
current fishing levels, a "no action" policy may have significant support from
the business community and, consequently, to some politicians and agency
staff. Alternatively, if the affected populations in contaminated areas are
environmentally aware and health conscious, such a policy may incur
substantial risk to the agency. It is not recommended that agencies base their
choice of options solely on political factors, although, in reality, they are usually
considered. Risk managers may want to consider potential health risks and
benefits as primary considerations in determining whether the option of "no
action" is appropriate for a water body.
2.3.2 Fish Consumption Advisories
Fish consumption advisories are designed to reduce risks to fish consumers by
providing information that will lead them to voluntarily restrict their fish
consumption to healthy levels. The advisories provide information to the public
warning of potential health hazards associated with consuming contaminated
fish. These advisories generally include qualitative guidance on minimizing risk,
and may or may not provide specific meal consumption guidelines. The
advisories may take many forms, from posting warnings near waterbodies, to
booklets and public service announcements. The various ways to communicate
fish advisories are discussed in Volume IV on risk communication. The
following discussion covers two major categories of advisories: general
advisories, which provide non-quantitative information, and quantitative
advisories, which provide specific meal consumption limits. Information on
advisories developed by agencies nationwide may be of interest to risk
managers. A summary of all current advisories was recently compiled by EPA:
National Listing of Fish Consumption Advisories, on five disks in a PC format.
They can be obtained from EPA's Office of Water. General Fish Consumption Advisories
General fish consumption advisories provide qualitative guidance on reducing
risk through selective fishing, preparation, and cooking techniques. Specific
information may be provided on the safest or most hazardous species and sizes
of fish to consume. For example, smaller, younger fish within a species tend
to be less contaminated than older, larger fish. Numerous state fish advisories

recommend keeping smaller fish for eating and releasing larger fish. For those
individuals choosing to consume larger fish, recommended practices often
include eating smaller meals and freezing part of the catch to space meals out
overtime (ND DOHCL, 1992, MO DOH, 1993).
Other information related to specific species or categories of fish may be
conveyed. For example, prey species tend to be less contaminated with
bioaccumulative contaminants than predatory fish, and lean species tend to
have fewer fat-soluble contaminants than fatty species (See Supplement A).
The North Dakota fish advisory recommends eating more prey species like
perch, sunfish, and crappie than large predator species like walleye or northern
pike (ND DOHCL, 1992). Using guidance regarding fish species and size, risk
managers may encourage fishers to practice selective fishing or catch-and-
release fishing to decrease their probable dose of fish contaminants.
Information on where fish contaminants are found in the fish body may also be
provided. Studies have indicated that exposure to certain fish contaminants
may be decreased by proper trimming and cooking techniques. Supplement A
to Volume II discusses studies in detail. Several states include discussions of
these techniques in their fish advisories, as well as diagrams indicating
appropriate fish tissues to be trimmed (s.f., MN DOH, 1992, MO DOH, 1993).
Some also list particular species for which trimming is recommended. New
York, for example, suggests trimming fatty tissues from smallmouth bass,
brown trout, lake trout, coho salmon, and striped bass (NY DEC, 1985). They
also advise not eating "grossly diseased fish" or fish liver.
Advisories may contain specific health information regarding contaminants,
such as a description of adverse effects known or suspected of being
associated with contaminants, along with recommendations to limit
consumption. Risk managers may elect to provide information regarding the
benefits of fish consumption (discussed in Section 3) with information
regarding health risks. Qualitative or quantitative information on health risks
may be appropriate, depending on the audience and goals of the program.
Section 5 in Volume II contains a description of potential health effects,
including developmental toxicity, neurotoxicity, and other types of organ
toxicity. EPA risk values and a breakdown of especially susceptible subgroups
in the population are provided in the same section for each target analyte.
Risk managers may provide a synopsis of potential health risks in the form of
a "fact sheet" to give the consumer the most complete information available
regarding contaminants to which they are being exposed. General qualitative
descriptions of potential health effects, similar to those in many community
"Right to Know" programs, may be included. Volume IV provides additional
guidance on methods to communicate risk-related information.

Fish advisory information may be provided to the general fishing population if
risks are expected to be widespread. When risks are known to be greater for
some subpopulations, more specific guidance may be given to these groups.
For example, if mercury is known to exist at levels posing risks to children and
women of reproductive age, advisories may be designed specifically to reach
these audiences. Information may be disseminated to health care providers,
schools, agencies issuing fish permits, etc., as well as to fish consumers, to
facilitate distribution and provide resources for explaining potential impacts of
consumption. When planning fish advisory programs risk managers may want
to consider the requirements that may be placed on their staff if consumers call
for clarification or additional information.
Fish advisories may also be of a very general nature and simply recommend
that certain waterbodies be avoided or the fish taken from them be limited.
Limiting overall fish consumption by some segments of the population may be
recommended, without providing specific information on waterbodies,
seasonality, or other issues discussed above. Feasibility and Efficacy
General advisories may be the least resource- and labor-intensive option for
limiting exposure to fish contaminants, depending on the scope of the program
and the type of information conveyed. Consequently, a general fish advisory
program may be appropriate if resources are extremely limited. The
development of this type of advisory may or may not require agencies to obtain
site, consumer, or fish species-specific information, depending on the type of
information the agency wishes to convey. If a program targets a small group
or provides only very general information through limited sources, the advisory
program may be relatively inexpensive and have limited staff requirements.
Alternatively, programs providing substantial information through a variety of
media to a large number of subpopulations will require more resources.
The efficacy of general advisories depends in large part on adequate education
and outreach to fish consumers. Alliances with other local and state agencies
and community groups may facilitate information distribution. Many states
currently issue the fish advisories with fishing licenses to fishers who apply for
the permits; this is another useful mechanism for disseminating information.
Volume IV contains guidance on risk communication, including different
strategies spanning a range of resource requirements.
General advisories may be most useful in cases where risks from eating
contaminated fish have been and are expected to continue to be relatively low.
In these cases, general health advisories provide information allowing
consumers to make decisions regarding exposure to fish contaminants. In low

risk situations, inappropriate decisions by consumers on how much fish to eat
do not generally pose a significant hazard. However, misinterpretation could
be hazardous to fishers who consume very large quantities of fish. Conversely,
general guidance regarding fish preparation is less subject to misunderstanding
on the part of the consumer, and may be useful under appropriate
circumstances. Where contamination data indicate that risks from consuming
even small amounts of fish are relatively high, general health advisories may be
insufficient to protect consumers from developing adverse health effects. Quantitative Advisories
In addition to the type of information provided in the general advisories
described above, risk managers may also develop advisories containing specific
information regarding meal consumption limits. Quantitative fish consumption
advisories provide fish consumers with site-specific, species-specific, and
sometimes size-specific (within species) information on the maximum amount
of fish that can be safely consumed within a given time period.
The introduction to a fish consumption advisory may describe the contaminants
found in local sport fish, where the contaminants accumulate in fish tissues,
and methods for minimizing exposure to these contaminants (MN DOH, 1992,
GLSFATF, 1993). Specific fish consumption advice follows in a descriptive
narrative or in a table and/or map (s.f., NY DEC, 1985, MN DOH, 1992, MO
DOH, 1993). As discussed under general advisories, above, information may
also include:
*	types of health risks associated with elevated consumption,
•	groups within the population who are at particular risk and why (as
discussed under general advisories above),
*	sources of additional information, and
•	recommended food preparation methods.
Most states issuing advisories now use a risk-based approach. The EPA method
described in detail in Volume II of this series uses a risk-based approach to
calculate the recommended meals per month, based on contaminant level and
the risks associated with each target analyte. Advisory levels have been
calculated for all target analytes for various meal sizes (4 ounces to 16 ounces)
and for adults and children. Methods are provided to also make adjustments
for various body sizes and for different assumptions regarding toxicity and meal
State fish consumption advisories currently vary widely in the complexity of the
information provided and in the methodology used in their development.
Missouri's and Minnesota's state fish consumption advisories are described

below for illustrative purposes. In addition, details from a number of state fish
consumption advisories are given in Table 2-2 below. As Table 2-2 shows,
many states have developed a tiered approach providing different advisories for
various population subgroups. Subgroups considered in these advisories have
•	short-term recreational fishers,
•	seasonal fishers,
•	long-term fishers,
•	subsistence fishers,
•	general adults,
•	young children,
•	women of childbearing age,
•	pregnant or nursing women, and
•	children under certain ages.
Agencies may wish to consider the characteristics of their target populations
to determine how best to structure their consumption advisories, based on risks
to various subgroups and potential impacts of fish consumption restrictions.
Example: Missouri's Fish Advisory
Missouri's proposed fish advisory provides the simplest advice of the
four state fish advisories listed in Table 2-2. It gives general guidance on
fish consumption over wide regions of the state, and only mentions
specific species and waterbodies where they represent exceptions to this
advice. Consumption advice is based on two broad groups of fish; fatty
fish (catfish, carp, buffalo, drum, suckers, and paddlefish), and non-fatty
fish (bass, sunfish, crappie, and walleye). Advice is given for three
consumption rate categories: no restrictions, eat only one pound per
week or less, and do not eat any fish. Pregnant women and children are
advised to consume "less" contaminated fish than general adult fishers
(MO DOH, 1993).

Table 2-2, Comparison of EPA and Sample State Fish Consumption Advisories
Great Lakes
New York
North Dakota
Consumption categories;
0.5 through 17
meals per month
1 through 10
meals per 10
1 or 2 1/2-lb*
0.5, 1, or 2
1 meal/yr
General adults:
<.1 Ib/wk
Pregnant or
nursing women
and young
children: <1
<, One 1/2-lb
meal* per
One 1/2-lb
1 through 6
1 through 4
No consumption

Table 2-2. Comparison of EPA and Sample State Fish Consumption Advisories
Targeted fisher populations
By exposure
vacation fishers
fishers: eat non-
commercial fish
regularly 10
Seasonal fishers:
eat non-
commercial fish
regularly 10
days to 3 mo/yr
fishers; eat non-
commercial fish
regularly 3
mo/yr or more

fishers: eat
fish regularly 1-
3 wks/yr
fishers: eat
fish regularly 3
wks to 3 mo/yr
Annual fishers:
eat non-
commercial fish
regularly 3
mo/yr or more

seasonal fishers
By sensitivity to
General adults
General adults
General adult
General adult
General adult
adverse health

Young children

Young children

and women of
Pregnant or
Women of
Women who

Women of

nursing women
are pregnant,

childbearing age

and young
age, infants,
and children
under 15
or plan to
pregnant, and
children under
the age of 15

Table 2-2, Comparison of EPA and Sample State Fish Consumption Advisories
Information contained in consumption guidelines
to sensitive
Two broad
1,	low-fat fish
and trout
2.	fatty fish
by fjsh length?
by location?
Yes, broadly
Includes map?
Sources: GLSFATF, draft 1993; MN DOH, 1992; MO DOH, 1993; ND DOHCL, 1992; NY DEC, 1985.
* Meal size of 1/2 lb is scaled to a 150 lb (70 kg) person.
b Although the Great Lakes Sport Fish Advisory Task Force doesn't have separate consumption guidelines for different fisher
populations, it has based its advisory on several adverse health endpoints (reproductive, neurologic, immunologic and cancer) and
on the most sensitive populations, in an effort to be protective of the sensitive populations while providing an extra margin of safety
to less sensitive sport fish consumers (GLSFATF, 1993).

Example: Minnesota's Fish Advisory
Minnesota's fish consumption advisory represents the most complex
advisory of those examined. Consumption guidelines are given in tables by
specific waterbodies, fish species, and fish lengths (in five-inch
increments).1 Separate guidance is given for fisher populations with
varying exposure periods (vacation, seasonal, and year-round fishers) and
sensitivities to adverse health endpoints (general adults versus women of
childbearing age and children). In addition, advisories indicate the
contaminants on which the consumption advice is based.
Minnesota's advisories employ simple symbols (e.g., squares and circles)
and various degrees of shading to incorporate a substantial amount of
information into a readable format.
While detailed advisories can provide specific guidance on the most appropriate
consumption for each waterbody and population group, the approach may have
drawbacks for some population groups, particularly if information is conveyed
primarily in written form. Kathy Bero of the Lake Michigan Federation (Bero,
1994) noted that advisories providing detailed information will not necessarily
reach the urban fishers who may have low literacy rates or inadequate English
skills. This population also includes many people who are at or below the
poverty level and fish to supplement their food supply, not merely for
recreation. Overly-complicated advisories are less likely to be followed very
carefully by these particularly high risk populations (personal communication
with Kathy Bero, 1994). In addition, some fishers do not obtain fishing
licenses, particularly those who are economically disadvantaged.
Consequently, fish advisory information distributed with fishing licenses may
not reach these fishers. Feasibility and Efficacy
Although fish consumption advisories require more time and resources than
general health advisories to develop, they also provide consumers more site-
1 Providing fish consumption limits by fish length is more expensive
because of the additional sampling and analysis required. Greater accuracy is
provided, however, since fish contamination within species is often correlated
with fish size and length.

and species-specific information and give specific quantitative guidance. They
are less likely than general advisories to be misinterpreted regarding the "safe"
levels of consumption, and provide consumers with specific consumption goals.
A variety of types of information are required to develop quantitative advisories:
•	contamination in edible fish tissues (obtained from sampling and analysis
programs discussed in Volume I);
•	cancer potencies and/or Reference Doses (or other risk values) of the
contaminants of concern (see Volume II);
•	local non-commercial fish preparation and meal consumption patterns
obtained from local surveys if possible (see Supplement A to Volume II);
•	average body weights of non-commercial fish consumers (see Volume II);
•	contributions to exposure from other sources such as air, water, and
other foods (see Supplement A to Volume II).
Various information sources exist for most of the data required to develop fish
advisories. While collecting all of the above data may not be feasible for many
programs, combining existing data sources and local information may enable
well-targeted programs to be conducted with relatively limited resources. For
agencies wishing to obtain the maximum guidance from EPA, thereby
minimizing their staffing requirements, the approach described below uses the
information contained in this series to develop quantitative fish advisories. It
is still recommended, however, that some local information be collected
regarding fish contamination and consumption patterns.
As discussed above, Volume II provides a detailed description of how to
calculate risk-based consumption limits and includes meal consumption limit
tables for the 23 target analytes. Information is also provided on methods for
calculating consumption limits for multiple species diets and for multiple
contaminant exposures. The information in Volume II may be used in
conjunction with contamination data from local sampling programs and local
fish consumption surveys (or the consumption data provided in Supplement A)
to select appropriate consumption limits. The consumption limits may then be
used with other types of information such as benefits of fish consumption
(discussed in Section 3) and other potential impacts of limiting consumption on
the population to establish health advisories.
If risk managers choose to use the meal intake limits listed in Volume II, they

should consider that these limits were not modified for exposure to other
sources of the same contaminants (due to the highly variable nature of such
exposures). Estimating total exposure and relative source contributions are
discussed in Supplement A of this volume. Adjustments to intake limits should
be made based on local exposure conditions and take into account all likely
sources of contamination. If non-fish source contributions are not considered
in areas with contaminants in other media, fish consumers may be exposed to
unsafe total exposures even though the fish exposures alone may not pose
risks. Risk managers may choose to focus on the most highly exposed
individuals, or average exposures to non-fish sources.
Note that while exposure reductions can theoretically be made in any
contaminated media, fish consumption may be the only source that can be
readily reduced. It may not be possible to reduce air or water contaminant
levels quickly, while fish advisories have the potential for rapid exposure
reduction in a population. Because fish consumption may contribute
significantly to overall exposure for some population groups, modified
consumption patterns may reduce overall exposure considerably.
Risk assessors and managers may develop highly specific meal consumption
limits. The choice of what information to convey and to whom is a decision to
be made based on the target population's information needs. Presenting
various levels of information has advantages and disadvantages. Missouri's
fish consumption advisory, as discussed above, has the advantage of being
sufficiently straightforward and general so that a fisher could readily memorize
the information it contains. In addition, the recommendations are based in part
on regional hydrology and fish species characteristics; individuals fishing in
areas for which no advisories are available could use this information to
potentially lower their exposure. Because the meal consumption advice is
written in simple prose, the advisory may also be more readily used by non-
native English speakers who might not understand how to use more complex
One agency has reported that advisories must reduce a great deal of
information into a concise, understandable format without losing the technical
basis for the recommended dietary consumption (ND DOHCL, 1991). As the
authors of North Dakota's fish consumption advisory warned, "advisories
containing extensive details for consumption advice can be overwhelming...and
become impractical if ignored by the public" (ND DOHCL, 1991).
More complex advisories, such as the Minnesota advisory described above,
provide more information that fish consumers may use to maximize their
benefits from eating fish while minimizing their risk of developing adverse
health effects. The Minnesota advisory program uses extensive site- and

species-specific data, as well as up-to-date toxicological data and methodology
so that the accuracy of consumption recommendations is expected to be high.
The advisory's complexity, however, may make it less readily memorized or
generalized to new areas, and it may confuse fishers not accustomed to
interpreting tables. To address this concern, Minnesota also provides brochures
using a simpler format and are very accessible to any literate population. The
Minnesota advisory program reflects a significant time investment in the
development of advisories conveying a large amount of information in a
readable format and different types of advisories.
Risk managers may have to choose the type of information to communicate to
the public and select the most relevant information to include (i.e., an advisory
which uses an average meal size). Risk managers may wish to consider
developing advisory materials with varying levels of detail so that materials can
be provided to groups according to their level of interest and understanding (see
risk communication discussed in Volume IV).
As voluntary activities, fish consumption advisories may be more readily
supported by the public than mandatory advisory programs (i.e. prohibiting
fishing in an area). The efficacy of quantitative fish consumption advisories is
determined by the extent to which:
•	the advisories accurately reflect local conditions and potential health
risks, and
•	non-commercial fish consumers use them appropriately.
Even when fish consumption advisories portray health risks accurately, non-
commercial fish consumers may not follow the advisories if they are not readily
available, too difficult to follow, and/or ignored. Effective risk communication
is critical to making this (or any voluntary policy option) work.
In summary, the resources required to develop quantitative fish consumption
advisories are greater than those required to develop more general health
advisories, and often require expertise in quantitative and health areas.
Resources needed for public education will probably be similar to those for
general advisories; however, quantitative information may require more
explanation by staff and require more detailed risk communication efforts. As
noted above, the extent to which resources outside a program can be used in
developing and maintaining it may have a significant impact on the resources
required and on the feasibility of conducting various aspects of a program. A
program's efficacy will depend on the effort directed at outreach and the
appropriateness of the materials for the target audience.

2.3.3. Catch and Release
Catch and release programs have been used in some areas to address concerns
regarding health risks of contaminated fish for sport fishers. A catch-and-
release fishing policy allows fishers to catch fish as a recreational activity, but
encourages or requires them to release the live fish once they have caught
them. As part of this policy, risk managers may additionally choose to:
•	require a special permit to catch-and-release fish, or
•	allow catch-and-release fishing only in a supervised tournament setting.
Example: New York's Catch and Release Program
Catch and release programs have been used in New York State where
sampling and analysis programs indicate that fish in specific waterbodies
are sufficiently contaminated so as to pose a public health threat if
consumed at all. A report from the New York State Department of
Environmental Conservation (NY DEC) suggests that risk managers may
chose to recommend or enforce zero consumption, though still allowing
catch-and-release fishing or fishing for trophies (NY DEC, 1985).
According to NY DEC, fishers generally accept and respect the intent of
enforced catch-and-release regulations New York State has promulgated
for species management purposes, especially when contrasted with
outright fishing bans. However, their state report indicates that such
strategies require both agency and fisher efforts and cooperation:
Enforcement [of fishing bans] is difficult at best, and
enforcement of catch and release fishing is not expected to
be much more successful. Since a high percentage of fishing
activities take place in remote areas, the effectiveness of
enforced catch and release fishing is highly dependent on
considerable peer pressure and self-policing. (NY DEC, 1985).
One potential variation on this option would be to require fishers to obtain state
fishing permits for catch-and-release fishing. This practice allows risk managers
an opportunity to provide educational materials when the permits are issued,
thereby ensuring that fishers are fully aware of up-to-date health advisory
information. The likelihood that fishers will comply with the catch-and-release
regulations therefore increases. This option would have the same public health

objectives as catch-and-release fishing without a special permit, but would
increase the knowledge of people fishing legally. Requiring a permit would,
however, add an administrative burden to both authorities and the public (NY
DEC, 1985).
Another variation on this option is to allow fishing in highly contaminated
fisheries only at structured tournaments. The agency would then have an
opportunity to inform every registered angler of the health risks of eating
contaminated fish, making enforcement of catch-and-release fishing much
easier (NY DEC, 1985). This policy would likely require regulation to be
effective, since it mandates that fishers join tournaments and pay a fee to fish.
The policy significantly favors both competitive tournament fishing and fishers
belonging to organized tournament-oriented fishing organizations over fishers
who do not meet tournament fishing criteria. Such restrictions could have the
effect of placing private organizations in the position of managing a public
resource (NY DEC, 1985). The NY DEC expressed the concern that:
Many [anglers] would consider a tournament-only regulation as an
unacceptable, unreasonable, and unfair attempt to satisfy special
interest groups. This would promote and aggravate violations to
the law and would reduce the credibility of the Department as to
its professional, unbiased implementation of sportfishing
regulations (NY DEC, 1985).
Still, this policy may be preferable to a total fishing ban in highly contaminated
non-commercial fisheries. Feasibility and Efficacy
The efficacy of voluntary catch-and-release options depends on the degree to
which effective risk communication and education has taken place. It will also
depend on the impact of non-governmental factors, such as traditional
activities, economics, and nutritional needs (see Section 4). While quantitative
and general fish advisories seek to limit consumption, catch-and-release
programs are designed to eliminate consumption (of at least some species from
some sources). This option may provide too great a hardship or disruption in
lifestyle for some fishers and may, therefore, not be accepted for reasons
beyond the control of many fish advisory programs. These types of
constraints, often related to negative program impacts, are discussed in detail
in Section 3.
Effective use of catch-and-release programs involves extensive public education
to ensure that fishers both understand the underlying rationale for such policies

and recognize their own interests in supporting such a program. If fishers do
not see the utility of the restrictions, they are unlikely to comply and are likely
to incur health risks from consuming highly contaminated fish.
Voluntary Programs.
The feasibility of voluntary catch-and-release options is similar to that of the
quantitative fish advisory program. Fewer resources are required by catch-and-
release programs to develop and communicate complex fish consumption limits
than by quantitative fish advisory programs. On the other hand, more
resources may be required to convince fishers of the importance of avoiding
fish consumption. With a greater change in behavior required by this option,
risk communication activities may require greater effort.
Involuntary Programs.
The characteristics of voluntary catch-and-release programs described above
are applicable to involuntary programs. In addition, involuntary programs
require labor-intensive activities and physical barriers (e.g., fences).
Enforcement staffing and access restrictions are critical to this type of program.
The extent of enforcement and related activities will largely determine both the
efficacy and costs associated with such a program. The feasibility of these
options depends on the availability of human and other resources to carry out
the required activities. Due to the highly resource-intensive nature of these
options, they may be most appropriate in very limited areas, but would probably
be too resource-intensive for large or numerous waterbodies. An involuntary
catch-and-release program will likely have greater resource demands than
general advisory programs or voluntary catch-and-release programs. The
specific requirements will depend on the goals and scope of the program.
The need for an involuntary catch-and-release program may be greatest where
cultural or economic factors create significant pressure to continue fishing but
not necessarily fish consumption, and contamination levels pose significant
health risks.
The efficacy of involuntary catch-and-release options depends on both
education and enforcement. Even highly intensive enforcement actions
probably cannot limit access to waterbodies completely. Consequently, the
degree to which fishers understand and agree with efforts to limit consumption
and risks will have an impact on the effectiveness of a program.
As noted above, negative impacts of such restrictive programs may be
significant. The feasibility and efficacy of both the voluntary and involuntary
programs may be affected by factors that will mitigate the negative effects.

These might include the proximity of other safe fishing sources, easy access
to other sources of inexpensive food (e.g., supplementation with food
programs), and coordinating program activities with local people to maintain
community and traditional activities. These issues are discussed more fully in
Section 3.
2.3.4 Fishing bah
This document focuses on fish advisories, which entail voluntary compliance
with recommended practices. In determining the most appropriate course of
action regarding fish contamination problems, however, some risk managers
may choose to consider a ban on fishing in highly contaminated areas. This
policy is discussed briefly in this document because it may be a component of
an overall fish advisory program or an essential activity necessitated by
Fishing bans have regulatory aspects and generate issues not considered in
detail in this series. Consequently, readers may wish to consult other sources
and discuss fishing bans with risk managers who have implemented this type
of action.
A fishing ban may involve banning fishing through closing waterbodies to
fishing and/or banning the possession of contaminated fish. A fishing ban, in
this discussion, is distinct from a fish advisory in that restrictions on fishing are
not voluntary. In a fish advisory, risk managers may recommend no
consumption based on health risks and other considerations. This information
would be handled, as other fish advisory information is handled, through risk
communication activities. In the case of a fishing ban, fishing would be
prevented through some active means. A variety of options may be exercised
to implement this type of policy including restricting access to contaminated
waterbodies, posting signs and levying fines when fishing occurs, or providing
monitoring restricted of waterbodies to prevent fishing from occurring.

Example; Fishing Bans in New York, Missouri, and Massachusetts
The New York DEC, for example, uses fishing bans to close recreational
fisheries when they ascertain with 95 percent statistical certainty that
contaminant levels exceed guidelines for the target contaminant (e.g.,
PCBs). Once a fishery is closed, New York requires that sampling and
analysis data show significant decreases in contamination before they will
reopen it, in order to prevent confusion arising from frequent opening and
closing of the same fishery. Risk managers might also choose not to
reopen a fishery until contamination levels decrease to the point that fish
are once again safe to eat, since some fishers may mistake a catch-and-
release policy for an indication that they can safely consume the sport fish
(NY DEC, 1985).
Missouri has also used fishing bans. They recently changed their advisory
in a certain waterbody from a total ban to unlimited consumption based on
several years of sampling and analysis data. Massachusetts has also
implemented total fishing bans in heavily contaminated fishing areas.
These bans applied to both commercial and non-commercial fishing.
The authority required to enforce such a policy may require enabling
legislation. Health officials in Massachusetts used the authority given to
the health department to prevent the public from imminent hazard as legal
justification for taking restrictive action. Due to the justifications they
presented for their actions, a legal challenge to their actions was not
successful. Most health departments have similar authority and are
required to take action when information is received regarding imminent
hazard to the public. Feasibility and Efficacy
Banning fishing entirely where significant risks to human health exist is the
most effective way to limit consumption of highly contaminated non-
commercial fish (NY DEC, 1985). The feasibility of such an action depends
largely on intensive use of human and other resources in the restricted areas
and will be affected significantly by educational efforts and resulting public
attitudes. The resource requirements are obviously greater if contamination
occurs in a large water body or in a number of areas.
The New York DEC has found that both the general public and non-commercial
fishers in particular do not widely support sport fishing bans as a means to
protect public health. Because non-commercial fishing is a largely self-regulated

activity, government intrusion is resented and enforcement is difficult and very
staff-intensive. The New York DEC proposed the option of prohibiting the
possession of contaminated fish in 1985 and found an overwhelmingly negative
response among anglers toward a ban on the possession of contaminated fish
(NY DEC, 1985).
Fishing bans are not advisable when they are used to simplify more complicated
quantitative data for high risk populations. In many instances, although the
communication of advisory information is complicated, individuals relying on
fish as a basic nutritional and economic food source are not being shut out
completely through the advisory process, as they are with fishing bans. The
trust that can be established between community groups and regulatory
agencies is already tenuous. Placing a ban on fishing when some fish
consumption can be considered safe severely inhibits fishers' willingness to
trust the agencies' recommendations in other arenas.
Risk managers may determine that some fish species are highly contaminated
within a single waterbody while others are safe to eat. Many states, including
Connecticut, New York, and Rhode Island, have enforced a closed fishery for
striped bass. Increased problems may arise, however, if large fisheries shared
by more than one state or province are covered by conflicting policies.
The efficacy of a ban on fishing depends on both the level of effort regarding
enforcement and education and on local circumstances that affect the fishers
interest in and ability to comply. As noted for the catch-and-release options
above, negative impacts of such restrictive programs may be significant and
include economic and nutritional hardships as well as disruption of community
or traditional activities. Both feasibility and efficacy may be positively affected
by features in the program's design that mitigate the negative impacts of
restrictions. These features might include the proximity of other safe fishing
sources, easy access to other sources of inexpensive food {e.g.,
supplementation with food programs), and the coordination of program
activities with local people with regard to maintaining community and traditional
activities. These issues are discussed more fully in Section 3.
Although fishing bans would usually be viewed as actions of last resort, only
to be used in areas where fish are highly contaminated and the risk of adverse
health effects is great, risk managers may choose this or a similar policy that
aims to provide maximum assurance against consumption of contaminated non-
commercial fish.

2.3.5 Summary
Fish consumption policies differ in efficacy, feasibility, and/or economic costs.
Table 2-3 summarizes some functional aspects of implementing the options
discussed in the preceding section. These aspects include relative costs, staff
requirements, anticipated efficacy, and whether regulatory authority is required.
As noted above, this section includes only a discussion of issues surrounding
the feasibility and efficacy of implementing these policies. Often, the feasibility
and efficacy of an option is limited by the budget and/or staffing available to
risk managers. Some policies, such as quantitative fish consumption
advisories, require significant initial resources for the sampling and analysis
program but may not require substantial staffing to implement. Others, such
as fishing bans, require substantial ongoing staffing to be effective.
The ranges of feasibility and efficacy listed in Table 2-3 reflect the differing
levels of effort that could be employed by risk managers for any given policy,
depending on the goals and scope of the programs. For example, a catch-and-
release fishing policy may require few resources and have little effect if the risk
communication is limited to posting. Conversely, the same policy may require
substantial resources for patrolling and public outreach and be much more
effective in reducing risk. Intensive efforts to prevent consumption of highly-
contaminated non-commercial fish may be prohibitively expensive, both to the
authorities upholding the policy and to local economies supported by fishing.
Conversely, attempts requiring very little resource expenditure may provide
such limited information or reach so few individuals that many fishers may
unknowingly consume dangerous quantities of contaminated sport fish.
Table 2-4 provides a template that risk managers can use to enter information
regarding the various options under consideration. The options discussed in
this section are all listed in the template; however, it is assumed that risk
managers may consider only some of these options or may consider others that
are not listed. Risk managers may consider the resources available to their
programs, as well as the likely outcome, in terms of likelihood of accomplishing
program goals, to define the potential options for their programs. The potential
impacts of these options on target populations and other groups external to the
agency also play a critical role in defining the best options and the success of
a program. These impacts are discussed in the next section.

Table 2-3 Feasibility and Efficacy of Risk Management Options2
Risk Management Options
Regulatory Authority
Risk Reduction
No action required
low to moderate
to high
to high
moderate to high
moderate to
Catch and
low to
low to
low to high
low to high
low to high
Fishing ban
to high
low to
low to high
low to high
low to high
2 The information provided on the options is based on a program of average scope and with moderate
efficacy requirements. If a program is very large or small or if the program requires a very high level of
compliance (efficacy) the resource requirements and efficacy will be correspondingly modified.

Table 2-4 Template for Risk Management Options
Risk Management Options
Regulatory Authority
Risk Reduction
No action .



Catch and


Fishing ban



2.4. Outreach and Education
Outreach and education are critical components of any program designed to
limit contaminated fish consumption. In most cases risk reduction strategies
will use guidance and advisories rather than regulatory approaches.
Consequently, the implementation of programs will rely heavily on effectively
communicating to the public both what the recommended actions are
(consumption limits, fish preparation methods, etc.) and why these actions are
important to consumers.
Various approaches for carrying out risk communication activities are discussed
in Volume IV in this series: Risk Communication. The volume contains
information on evaluating the nature of the population of concern and their
characteristics, a variety of strategies for effectively reaching the population
with clear information using various media (newspaper, schools, etc), and
methods for evaluating a communication program's effectiveness. Readers are
urged to consult this volume in planning their fish advisory programs.
2.5 Federal Programs and Additional Resources
In response to requests from state, local and tribal and community group staff
consulted for this project, information is provided in this section which can be
used to address remediation concerns. The overall goal of many agencies is to
have waterbodies and fish that are sufficiently contaminant-free that advisories
are no longer necessary. Efforts are ongoing at all levels of the government to
address this goal through cleanup efforts, pollution prevention and restrictions
on the entry of toxic materials into waterbodies. Although it is beyond the
scope of this document to list location-specific programs underway, this section
provides a summary of various federal laws and programs relevant to fish
The applicability of the information provided in this section will depend on the
source of the pollutants found in fish. For example, in cases where long-range
transport is causing mercury deposition, the Clean Air Act is relevant (a
summary of the laws is provided below). Where the pollutant sources are local
industrial discharges, however, the Clean Water Act is appropriate. Areas
adjacent to hazardous waste sites may fall under Comprehensive Emergency
Response, Clean-Up and Liability Act (Superfund). Pesticide contamination may
fall under the above acts; in addition, the Federal Pesticide, Insecticide, and
Rodenticide Act requires regulation of pesticides in a manner that does not pose
unreasonable health or environmental risks. The Community Right to Know Act
may be used to obtain information regarding local sources of pollutants.

Agencies and departments outside EPA are involved in various areas that may
impact the extent of fish contamination. The Agency for Toxic Substances and
Disease Registry (ATSDR) is involved with assessing the public health concerns
from hazardous waste sites. The Army Corps of Engineers, a division of the
Department of Defense, is involved with the dredging of contaminated
sediments in conjunction with the EPA; contaminated sediments are of concern
to consumers of bottom fish, and resuspension of contaminated sediments may
pose hazards to consumers of all fish in the area. In addition, the Department
of Energy is also involved in clean-up efforts that may directly or indirectly
affect the concentrations of fish contaminants in areas of concern.
A variety of programs within these and other federal agencies are currently
involved in regulating releases, cleaning up waste sites, and monitoring the
release of toxic materials. Most federal agencies involved in this type of work
have regional offices which can respond to questions regarding specific local
problems. Staff of the regional offices work directly with state environmental
and health agencies. Many also work with local, tribal, and community groups
to address contamination problems. Table 2-5 contains a listing of relevant
statutes and programs with a brief description of the purpose and function of
the regulations. This table can be consulted to determine which agencies are
most likely to have responsibility for a particular pollutant source.
Table 2-6 contains a listing of hotline numbers and other resources staffed by
EPA or EPA contractors. Staff on these lines can provide state, local, and tribal
risk managers information on government programs, send written materials,
and provide referrals to other staff within agencies who can address specific
or local questions. General information, applicable on a national level, regarding
federal regulations, guidelines, and programs, is available through national
information clearinghouses maintained by offices within federal agencies. The
following section summarizes applicable federal statutes and regulations that
address releases of toxic materials, clean-up of contaminated waterbodies,
sediments, and land sites, and targeted maximum levels of pollutants in various
Risk Managers are also encouraged to fully explore the local, state, tribal, and
regional resources available through agencies, advocacy groups, industry
groups, universities and other groups. These groups often have ongoing
grants, privately funded activities, and other resources which may be of
assistance to fish advisory programs.

Table 2-5. Environmental Statutes and Programs Potentially Relevant to Fish
Statute and Program Descriptions
Clean Air Act
The CAA was enacted in 1970, with revisions in both 1977 and
1990, was designed "to protect and enhance the nation's air
resources." the CAA has several key provisions used to protect
air quality, it establishes National Ambient Air Quality. Standards
for primary and secondary air pollutants, developed State
Implementation Plans to give states the responsibility for achieving
these standards, and provided technology based emission
limitations for regions that are not in attainment.
Clean Air Act Amendments
The 1990 amendments to the CAA resulted in a number of
changes, including specific provisions to address acid rain and the
phase-out of chlorofluorocarbons (CFCs), added technology-based
regulations of toxic air pollutants.
The CAA and its Amendments may be of interest to resource
managers who are concerned about long-range pollutant transport
into waterbodies that are frequently fished.
CERCLA Comprehensive Emergency Response, Clean-Up and Liability Act
Superfund was enacted In 1980 to provide funding and
enforcement authority for cleaning up thousands of hazardous
waste sites in the United States and responding to hazardous
substance spills in all media. Base funding for these activities
comes from specialized taxes on petro and chemical industries,
crude oil, and vehicle manufacturers. A revolving fund was also
established, making responsible parties liable for the complete
costs. Hazardous substances include those indicated in any of the
other major federal statutes, and action is triggered by the non-
permitted release of any concentration of a listed substance.
Superfund was re-authorized in 1986 by the Superfund
Amendrrients and Re-authorization Act (see SARA).

CWA	Clean Water Act
The CWA, originally created in 1972 as the Federal Water
Pollution Control Act until renamed and amended in 1977, was
designed to restrict both the degradation of water resources by
the discharge of pollutants and the transport of pollutants through
waterways. In 1987, extensive amendments were added to
remediate waters that exceeded minimum discharge standards to
assure water quality. A wide spectrum of water-related issues are
covered through the CWA for numerous chemicals. In addition,
this act relies on the application of best practicable technology for
water treatment. It also provides a permit mechanism to regulate
the volume and nature of discharges, relying on technology-based
effluent limitations on point sources (best available technology for
toxics and best conventional technology for other compounds)
and water-quality effluent limitations if water quality is not
maintained. Though never specifically mentioned, wetlands (and
consequently both fresh and estuarine fish nurseries) have also
been interpreted as protected under the Clean Water Act because
they are an integral water resource and a key mechanism for
retarding the transport of pollutants through the waterways.
EEO	Environmental Equity Office
This office was created in the early 1990s to address the concern
that environmental hazards were more likely to be found in socio-
economically disadvantaged communities than in more affluent
communities. The EEO primarily encourages every office and
division of EPA to address issues of environmental equity within
the context of existing contracts and projects, and does not
sponsor as many projects directly that deal with the equitable
distribution of risk.
EO	Executive Order on Environmental Justice
Executive Order 12898 was issued by President Clinton on
February 11, 1994, to address environmental justice in minority
populations and low-income populations. Within this order, he
specifically ordered that all agencies take the principles of
environmental justice into consideration when creating regulations.
Notably, one issue mentioned directly was his concern for
subsistence and recreational fishers who may be consuming
contaminated fish.

EPCRA Emergency Planning and Community Right-to-Know Act
The Right-to-Know Act was enacted as a freestanding provision
of the 1986 Superfund Amendments, and is also known
independently as SARA Title HI. This act was designed to force
states and local communities to develop plans for responding to
unanticipated releases; to require notification to local, state, and
federal authorities of the release of certain substances beyond a
developed reportable quantity {threshold value) determined for
hazardous chemicals based on their physical and toxic
characteristics; and to require all industries to maintain and submit
to local, state, and federal authorities Material Safety Data Sheets
on all chemicals of concern.
FCP	Fish Contamination Program
This program, run out of EPA's Office of Water, provides guidance
to states, tribes and local agencies for the development of fish
advisories. This group maintains the National Listing of Fish
Advisories and managed the development of this guidance series.
FIFRA	Federal Insecticide Pesticide and Rodenticide Act
This act requires balancing risks and benefits. EPA is required to
register, or license, pesticides on the basis of data that is
adequate to demonstrate that their use, according to label
directions, will not cause unreasonable adverse effects on people
or the environment. Data are required on a wide range of health
effects (e.g., cancer, reproductive effects) and effects on wildlife,
fish, and plants, including endangered species. In addition, EPA
is responsible under Federal Food, Drug, and Cosmetic Act
(FFDCA) for setting tolerances (maximum permissible residue
levels) for residues in food or feed, for those pesticides whose use
involves food or animal feed crops. EPA is also required to
establish safe use practices and to release information obtained on
the health and ecological effects of pesticides to the public, on
request (with the exception of confidential business information).
RCRA	Resource Conservation and Recovery Act
RCRA was created in 1976 to treat, store and dispose of all
hazardous waste to minimize the present and future threat to
human health and the environment. RCRA imposes full life cycle
management controls on hazardous waste by regulating the
generation, transport, treatment, storage and disposal of risky
chemicals. Subtitle I specifically addresses underground storage
tanks, an area of particular concern.

SARA Superfund Amendments and Re-authorization Act
Significant revisions were made to the Superfund regulations in
1986, expanding the scope of the coverage and requirements, but
not altering the intentions of the original act. SARA Title 111 was
also created at this time as a freestanding provision also known
as EPCRA, in the wake of the Union Carbide hazardous waste
disaster in Bhopal, India. SARA Title III addresses the need for
communities to have contingency plans for hazardous
emergencies and grants rights to the public to know what hazards
they might face from industry (including transport and disposal) in
their communities {see EPCRA).
TSCA Toxic Substances Control Act
TSCA was created in 1976 to evaluate the potential hazards form
chemical substances through manufacturer testing and may
impose restrictions in use, storage, transport or disposal of
chemicals accordingly. Three classes of chemicals have been
regulated in accordance with TSCA: asbestos, polychlorinated
biphenyls (PCBs), and chlorofluorocarbons (CFCs).

Table 2-6; Hotlines and Other Resources for Federal Programs Relevant to Fish Advisories
hotlines / resources available
drinking water
•	FCP	EPA's Fish Contamination Program, c/o the Office of Water, (202) 260-7301, provides guidance to the states for
developing fish consumption advisories. This group also maintains the National Listing of Fish Advisories,
•	CWA	EPA's Office of Water, (202) 260-5700, will direct callers with questions about the CWA and any component of
it (e.g., questions regarding MCLs for specific chemicals) to appropriate EPA offices.
•	SDWA	Safe Drinking Water Hotline, (800) 426-4791, helps individuals who are interested in testing their drinking water,
interpreting the results from a state laboratory, water treatment and filters, some general information about possible
sources of unsafe drinking water and general information about the SDWA. Weekdays, 9:00 am through 5:30 prn,
EST, except federal holidays.
Ground Water and Drinking Water Resource Center, (202) 260-7786, in EPA's Office of Water, offers publications
and referrals.
•	CAA	Air RISC Hotline, (919) 541-0888, provides extensive information regarding the CAA/CAAA, has general
•	CAAA	information, source-specific trends (e.g., if a particular region that has high fish contamination is heavily populated
•	EPCRA by pulp and paper mills, general information on that industry's emission trends are available), and information on
the criteria pollutants (particulate matter, volatile organic chlorides, nitrous oxides, sulfur oxides, and carbon
Additional resources offered through the Air RISC Hotline:
Office of Visibility and Ecosystems, (919) 541-0877, focusses on visibility- generally considered a measure
of particulate natter (primarily heavy metals and residual organics caught up by the other suspended
compounds) and ecosystem health.

Table 2-6: Hotlines and Other Resources for Federal Programs Relevant to Fish Advisories
media / focus
statutes / offices
hotlines / resources available
hazardous waste
Carol Jones, (919) 541-5341, contact for tribal air issues.
Technology Transfer Network Bulletin Board System, modem access: (919) 541-5742, has extensive
information regarding CAA rules, EPA guidance documents and activities.
EPCRA Hotline, (800) 535-0202, responds to questions about accidental air releases under CAA ง112(r).
Weekdays, 8:30 am to 7:30 pm, EST, excluding federal holidays.
RCRA/CERCLA/EPCRA Hotline, (800) 424-9346, provides general information on these acts, addresses site-
specific concerns on superfund sites and emergency response and accidental release sites, and provides information
regarding RCRA's underground storage tanks rules. Weekdays, 8:30 am to 7:30 pm, EST, excluding federal
EPCRA Hotline, (800) 535-0202, responds to questions regarding the emergency planning and right-to-know
regulations. Weekdays, 8:30 am to 7:30 pm, EST, excluding federal holidays.
TSCA Hotline, (202) 554-1404, addresses questions relating to TSCA standards and provides general information
as necessary on the primary chemicals regulated under these standards (asbestos, PCBs and CFCs). Weekdays, 8:30
am to 4:30 pm, EST, excluding federal holidays.
risk communication
environmental equity * EO 12898
National Pesticide Telecommunications Network, (800) 858-7378 (general public); or (800) 858-7377 (medical and
governmental personnel). This service provides a variety of information concerning pesticides, ranging from
product information, recognition and management of pesticide poisonings, toxicological profiles, health and
environmental effects and cleanup and disposal procedures. Weekdays, 8:00 am to 6:00 pm, CST.
Risk Communication Hotline, (202) 260-5606, is primarily designed to address hazardous waste communication,
but some of their information may be useful in other contexts.
Environmental Equity Office Hotline, (800) 962-6215, will address equity concerns and refer callers to the
appropriate offices for additional support.

Table 2-6: Hotlines and Other Resources for Federal Programs Relevant to Fish Advisories
media / focus	statutes / offices	hotlines / resources available
general environmental		 Access-EPA (202) 260-2080: The EPA's Public Information Center provides non-technical information and
information from EPA	referrals about drinking water, air quality, pesticides, Superfund and other environmental topics. Access-EPA can
also be reached via e-mail at
Army Corps of		 Department of Defense, general information, (703) 545-6700.
Engineers activities
Department of Energy		 Department of Energy, general information, (202) 586-5000.
Fish, and Wildlife		 Department of the Interior, general information, (703) 358-1700.
Services activities
Agency for Toxic		 ATSDR or the Centers for Disease Control, general information, (404) 639-6304.
Substances and Disease
Registry activities

3.1	Overview
There are positive and negative impacts of fish advisory programs which merit
consideration when developing new programs or modifying existing ones.
Options for limiting fish consumption are seriously considered only when
sampling and analysis data indicate that fish consumers may be at risk. In
addition to the obvious benefits of reducing health risks, there are other positive
and negative impacts of fish advisories that may affect either the entire
population or a subgroup of the population in an area. For example, posting
fish advisories may be beneficial in educating people about the hazards of a
water body, leading to less swimming, water use, and attention to the need for
clean-up. Alternatively, posting may reduce the availability of fish as a dietary
component or component of a traditional ceremony, and may jeopardize the
livelihood of small businesses reliant*on fishing activities. Under most
circumstances, consumption advisories will have both positive and negative
effects on individual consumers and their communities. These effects should
be considered by decision-makers in developing a fish advisory program.
This section explores some of the potential impacts of various options for
limiting fish consumption on groups and activities EXTERNAL to the governing
body. Affected groups may include the target population or communities and
individuals that serve them (e.g., fishing equipment stores). The impacts are,
for the most part, site specific. Whether they should be a consideration in
decision-making, and the extent of their impact, will depend on local conditions
including the population, economy, social and cultural features, and other
factors. Consequently, in reviewing this information the reader is urged to
evaluate the information in light of the characteristics of the contaminated
3.2	Nutrition
3.2.1 Basic Nutritional Needs
Fish consumption is generally beneficial because it provides a good source of
protein and vitamins. Although fish composition varies, a 3.5 ounce fillet

generally provides the nutrients listed in Table 3.1 {larger fillet may be
consumed in practice). The protein content of fish is high in relation to the fat
content of most fish species (Anderson, et al, 1972). The nutritional
components of fish will vary depending on the method of preparation, storage,
and what portion of the fish is consumed and varies by species.
Table 3-1.
Nutrient Values for 3.5 oz Fish Fillet
98 - 236
15 -29 grams
6 - 260 milligrams
190-414 milligrams
0.7 - 2.2 milligrams
vitamin A
30 - 1050 I.U.
vitamin B:

0.02 - 0.16 milligrams
0.07 - 0.27 milligrams
1.9 - 13.3 milligrams
Taken from Anderson et al., 1972. Table 1.
U.S. FDA has provided recommended dietary allowances for vitamins and
minerals that can be compared to the above information to determine the
contribution fish may make for various age groups and with different portion
sizes {NRC, 1989). Although vitamin and mineral supplements are readily
available at a relatively low cost, individuals who reduce their dietary intake of
these essential nutrients from fish will not necessarily obtain supplements or
consume other foods with these nutrients. More problematic is the access to
high quality protein for many people with limited incomes. For some low
income populations who rely on subsistence fishing for dietary protein, fish
consumption is an essential part of their diet and an economic necessity.
3.2.2 Health Benefits of Fish Consumption
In addition to fulfilling basic nutritional needs, eating a diet rich in fish may also
convey several health benefits. Restrictions in the amount or type of fish
consumed may negatively impact the health of individuals who had been
benefiting from fish consumption. Whether or not a negative impact will occur

depends on what other foods are substituted for the fish. Substitutions may
include other types of fish, or non-fish sources of protein.
impacts of restricted consumption depend on whether or not the consumers
were benefiting from consuming fish in a manner that can or will not be
replicated by other foods. The many human studies showing positive effects
of fish consumption focus primarily on fish diets versus traditional western
diets that may be high in salt, cholesterol, and saturated fats. The impact of
switching from a fish-intensive diet to another "healthy" diet is less well
understood. The following discussion identifies specific benefits that may be
derived from fish or fish constituent (e.g., fish oil) consumption. When
reviewing this information, risk managers may wish to consider the health
status of target populations, their likely substitutions for fish, and how a fish
advisory program can minimize the adverse impacts of fish consumption
Benefits of fish consumption have been identified in human epidemiological
studies that compared the health status in fish consuming populations with
those in populations consuming little or no fish. Many studies that identified
these benefits have focused on the ingestion of fish oil; however, some have
evaluated consumption of all edible portions of fish. The array of demonstrated
benefits includes decreased cardiovascular disease, a reduction in blood
pressure in hypertensive and non-hypertensive individuals, reduced risk of colon
cancer and breast cancer, several benefits to diabetic patients, decreased pain
from arthritis, and a decreased incidence of asthma attacks in asthmatics. In
addition to epidemiological studies, animal research has also found associations
between fish or fish oil and health benefits. The discussion below focuses on
the findings of the human studies.
Cardiovascular Disease Reduction
More information is available on the association between fish and
cardiovascular disease than between fish and other diseases. Studies have
shown beneficial effects from eating fish oils, ranging from decreased coronary
heart disease (CHD) mortality to decreases in blood pressure and decreased
serum lipids.
Mortality from CHD has been shown to be low in many fish-eating populations
and in clinical studies on the effects of eating fish and fish oils. Eskimo and
Japanese populations who eat large amounts of fish have been shown to have
low incidence of CHD and CHD mortality (Kromhout, 1993). These results may
be due in part, however, to the relatively low amount of saturated fats in the
diets of these populations. Saturated fats are considered a risk factor in CHD

and a diet with low levels is associated with a lower than average risk of heart
Prospective studies on the individual level are important to more accurately
determine the correlation between fish consumption and CHD mortality. A 20-
year prospective study on 852 men in the Netherlands found that CHD
mortality {independent of other CHD risk factors) was inversely related to the
amount of fish consumed (Kromhout, et al.r 1985). Three other cohort studies
showed similar results (Shekelle et al., 1985; Norell et al., 1986; Dolecek and
Grandits, 1991). An intervention trial in Wales of 2,000 patients supports the
results of the observational studies that have shown associations between fish
consumption and reduced mortality (Burr et al., 1989). In this study, patients
who were recovering from heart attacks and who ate at least two portions of
fatty fish per week reduced their mortality by one third compared to patients
who received advice on fat or fiber but did not consume fish biweekly. Other
research in populations that generally consumed large amounts of fish,
however, has demonstrated no association between fish consumption and
mortality {Kromhout, 1993). This failure to find an association may be due to
lack of a control group of individuals who do not consume fish.
Omega-3 fatty acids1 have beneficial impacts on health, but the concentrations
of these beneficial chemicals in fish tissue varies by fish species. Fish oil has
been shown to reduce blood pressure {Kromhout, 1993), although the dose
required for this effect has not been determined. In one study, mildly
hypertensive men who received 50 ml fish oil (equivalent to 15 grams of
omega-3 fatty acids) a day for four weeks had significantly lower blood
pressure during the treatment period than they did at the beginning of the study
(Knapp and Fitzgerald, 1989). Men who ingested either 39 grams omega-6
fatty acids from safflower oil, a mixture of oils representing the average U.S.
diet, or a 10 ml dose of fish oil (omega-3 mg equivalent not provided) exhibited
no decrease in blood pressure. The blood pressure of those receiving the high
dose of fish oil returned to pre-study levels after the subjects stopped taking
the oil. One study in which individuals ate fish in quantities that may represent
normal daily intake values by the general population (1.2 grams of omega-3
fatty acids/day) showed that blood pressure was lowered after 8 months of the
regimen (Simopoulos, 1991). Changes in physiology related to hypertension
have also been noted in human studies. Twenty patients who had high levels
of fatty acids at the outset of the study were given a diet containing fish oil,
which consisted of about 20 to 30 percent of each patient's diet. Over the
four-week diet, the patients exhibited decreases in cholesterol, fatty acid, and
1 Omega-3 fatty acids are found in fish oil.

very low-density lipoprotein levels (Phillipson, et al., 1985). Several other
clinical studies have shown fish oils to lower serum lipids (Dattilo, 1992).
Diabetic Svmotom Reduction
Recent evidence suggests that fish oil may benefit diabetic patients. Ingestion
of cod-liver oil for eight weeks by diabetic patients resulted in a variety of
effects: decreased permeability of blood vessels to macromolecules such as
lipoproteins, reduced blood pressure, increased amount of high density
lipoproteins, and decreased amounts of very-low density lipoproteins and
triglycerides (Jensen et al., 1989). In contrast, olive oil resulted in no
significant decrease in either blood pressure or blood vessel permeability, and
the subjects' levels of very-low density lipoproteins and triglycerides increased.
The decreased vascular permeability seen in the patients eating fish oil may
prove beneficial because it prevents the progression of diabetic nephropathy by
decreasing permeability to albumin. Long-term studies need to be undertaken
to determine whether this mechanism actually occurs. Other studies on insulin-
dependent and non-insulin-dependent diabetes patients have shown small
increases in blood glucose, glycosylated hemoglobin, plasma total cholesterol,
LDL cholesterol, and serum apo B associated with fish oil ingestion
(Simopoulos, 1991).
Arthritic Symptom Reduction
McVeigh (1990) reviewed research on the effects of fish oil on arthritic
patients. In one study of 49 patients, those given fish oil for six months had
decreased morning stiffness, pain, and fatigue. The effects were dose related,
with higher doses of fish oil resulting in greater improvement. These results are
corroborated by other studies demonstrating similar beneficial effects to
arthritic patients ingesting omega-3 fatty acids from fish oil (McVeigh, 1990).
Asthmatic Svmotom Reduction
Nine asthmatic patients treated with fish oil lipid capsules had significantly
fewer asthmatic episodes than eight patients taking placebos {Arm et al.,
1989). It has been suggested that fish oil may confer anti-inflammatory
effects, which leads to the observed decreases the severity of symptoms in
both arthritic and asthmatic patients.

Cancer Risk Reduction
The protective effects of eating fish may extend to reducing the risk of getting
certain cancers. A study of 88,751 nurses found that those nurses with a daily
consumption of fish or chicken had lower risk of getting colon cancer than
those with a lower consumption rate (Willett et al., 1990). Other research has
shown that fish may reduce the risk of breast, colon, pancreas, and prostate
cancers {Simopoulos, 1991).
The research described above indicates that fish may convey significant health
benefits for those with certain medical conditions, as well as the general
population. Some health experts believe that the health benefits outweigh the
risks associated with fish contaminants (e.g., Kimbrough, 1991). EPA is not
indicating an acceptance of or agreement with the study results by reporting
these studies. Agencies may wish to review the studies in more detail to
determine the applicability of their results to the risk management process.
There is not yet sufficient information to determine precisely what levels of fish
consumption are associated with specific health benefits. However, the
positive benefits of fish consumption may be considered when evaluating the
trade-offs between various risk management options. An evaluation of the
benefits and risks of fish consumption, which may include careful consideration
the levels of contamination, risks associated with contaminants, potential
benefits to fish consumers, and the availability of alternative economically
feasible food supplies and their associated risks.
It would also be useful to have information regarding the health risks associated
with alternative forms of protein that would replace the fish formerly consumed
by fishers who alter their dietary habits based on advisories. Information exists
on many of the pesticides, preservatives, and drugs used in the production,
processing, and preservation of meats, dairy products and vegetarian
alternatives. Conversely, no comprehensive data exist on the overall risks and
benefits associated with these products. It is beyond the scope of this
document to evaluate such risks. When establishing fish advisories risk
managers may wish to consider that alternatives to fish also may be associated
with risks.
Under ideal circumstances, contaminants in fish will be eliminated through
better environmental controls. Until that time, regulatory limits and advisories
based on an evaluation of risks and benefits should provide the fish consumer
with sufficient information to reap the benefits of eating fish while avoiding
unsafe exposures to contaminants.

3.3 Cultural and Societal Impacts
While decision-makers often focus on the risks and benefits of various policy
decisions or the feasibility and cost of programs, affected populations often
perceive decisions and programs from the point of view of impacts on their
lives or effects on their communities.2 To be appropriately designed and
effective, risk evaluations and programs to reduce risk must take into
consideration the needs and perceptions of the community being exposed.
These impacts should also be considered when decision-makers are evaluating
trade-offs between different program options and establishing consumption
In most cases there will be trade-offs for individuals and communities if
restrictions in fish consumption are advised. This section provides a discussion
of potential impacts on social and cultural aspects of individuals and
communities. The information obtained in this section was obtained primarily
from discussions with members of Native American, Asian American, African
American, and Hispanic communities and sport and urban fishers groups. State
and federal workgroup members with information on cultural impacts were also
consulted. Formal surveys were not conducted for this document;
consequently, the information provided represents a summary of what was
learned through conversations with a range of individuals and does not reflect
a representative sampling of fisher groups or government agencies. Readers
are urged to submit information for future revisions to EPA's Fish
Contamination Program.
3.3.1 Traditional Activities
Fishing and fish consumption are a part of the traditional activities of many
groups. These range from Native Americans who employ fish in religious and
secular ceremonies to urban fishers who engage in sport fishing activities
during specific seasons as a part of their social activities. The importance of
these activities to the communities and participants is significant and cannot
be quantified in the same way that risks or dollars lost on tourism are
quantified. The value of these activities to individuals and groups may vary
from something that is a pleasant intermittent pastime to an essential part of
2 Communities in this context refers to a group of people who share similar
cultural patterns and who consider themselves to be member of the same
societal group. A community may be a tribe, ethnic group, small town or part
of a city. Subpopulations within the community may be identified to obtain
groups who have similar activities, susceptibilities and needs.

a long-standing culture and personal identity. The effects of imposing fishing
restrictions on individuals and groups merit evaluation prior to taking any
significant action.
The cultural and spiritual practices of subsistence fishers may be affected by
fishing advisories. One population most affected are Native Americans, where
traditions have been built around fishing and sharing the catch for centuries
(EPA, 1994b). Native American groups have used fish in their traditional
religious activities over many centuries. While the wide diversity of beliefs
among the hundreds of tribes in the United States makes generalizations
regarding their beliefs inappropriate, nature plays a large role in the religious
beliefs and activities of many tribes. Those tribes near large waterbodies, such
as the Great Lakes and Atlantic and Pacific Oceans, have often used particular
types of fish to symbolize characteristics or ideas. The fish are used in
ceremonial meals, and the catching of fish may also be a part of the traditional
The Columbia River Inter-Tribal Fish Commission (CRITFC), composed of four
tribes that fish along the Columbia River Basin, has been involved in evaluating
fish contamination and its various impacts on the tribes. In their report on the
results of their studies, they preceded all technical information with a statement
under tribal health:
"Fish is not Just a major food source for tribal members,
it is the essence of the tribes' cultural, economic and
spiritual well-being."
(CRITFC, 1994).
Such a statement placed in a position of prominence in the report indicates the
importance of fish to these tribes.
Many tribal affiliates have explained that at least two of the options for limiting
the consumption of contaminated fish, outright bans and catch and release
programs, would be completely inconsistent with the cultures relying on fishing
for subsistence and cultural sense of self (Watanabe, 1994; Kmiecik, 1994;
Coombs, 1994; Cole, 1994; Dellinger, 1994; Walker, 1994). To those who are
a part of a culture defined by the societal relationship to fishing (and providing
for themselves) and concepts of efficient living, fish advisories are especially
troubling. Restrictions on fishing rights have also been perceived by some
individuals as passing the negative impacts of contaminated waters from the
polluters who should be responsible for cleaning the waters to socio-
economically disadvantaged communities or clusters of individuals with little

political clout. Fishing represents the integration of family with community
responsibility. Families spend time together fishing, and communities try to
maintain interests in the harvests and management of both anadromous and
resident fishes. These acts and that of preparing fish for use when the fishing
season slows down and the anadromous fish have left provides a sense of
community (Cole, 1994; Coombs, 1994).
For many of these tribes that rely on fishing as a major part of their economic
and nutritional base, fishing advisories are an apparent sign of disrespect to
their communities and cultures. They perceive the message that those
responsible for the unhealthy water contaminant levels are not required to clean
the water to a level that is safe to consume the fish, and are viewed by the
external decision-makers (i.e., government) to be more important than the
individuals that choose to supplement their diets with fish (Watanabe, 1994;
Cole, 1994).
Specific ceremonial uses of fish, such as the First Fish ceremonies to celebrate
the first fish of the seasons, are vital to the maintenance of cultures living off
the land and water. Such ceremonies may require consuming parts of the fish
not typically consumed, or having everyone who is present consume parts of
the fish, including nursing mothers and children. For example, the First Fish
ceremony among the tribes of northern California includes the consumption of
the entire fish while returning the bones back to the river (Coombs, 1993;
Walker, 1 994). The Objibwa (Chippewa) of the upper Great Lakes region,
another community that depends upon fish as a food source and an important
economic base, have a well documented history of fishing cultures, including
subsistence and commercial fishing. Extra fish are distributed among crew
members and the extended family for labor compensation as part of cultural
ritual and tradition (Dellinger, 1993).
People for Community Recovery, an African American urban community
organization in Chicago, has raised up additional concerns. Many of the
waterways in urban stretches are not visibly posted with any advisories,
although advisories have been released for those areas by the State. These
areas are used by numerous subsistence fishers who supply fish to their
immediate and extended families and supplement their incomes by selling the
fish they catch to the local community. These fishers often do not pick up the
sportsfisher guides available (typically via fish license distributors) and may be
unaware of the potential health hazards from eating fish from these waters.
Consequently, these particular fishers are unlikely to know the particulars of the
fish advisories released by the State, and the consumers are even more unlikely
to have been informed of the health advisories. Fish bans or catch and release
recommendations may not be a realistic risk management option in these

communities, and enforcement would be extremely difficult. The current
practice of no postings, however, has left many urban fishers feeling that their
health is being compromised because they are not considered to be a valued
part of the community.
Posting as much information as possible in a brief format, including types and
quantities of fish that are safe to eat, is most important to them. Two main
concerns that affect urban African American populations in this area, which
could be addressed through fish advisory and local community programs, are
the existence of informal fish markets and communication of safe preparation
techniques. In both of these instances, the individuals eating the fish may not
have been made aware of which types and quantities of fish are safe to eat.
Although many African Americans have been switching to cooking methods
that reduce the amount of fat, the preferred method is still frying a skin-on fillet
or deep frying the whole gutted fish. Of the preferred fish to consume, several
species are bottom fish such as catfish and buffalo fish, although increasingly
many of these are farm raised. These individuals typically require the fish as
a part of their diet and as a supplemental or primary form of income necessary
for their family (Williams, 1994). Although advisory information may not
change all of the fishers' behavior, the information will allow them to make
their own informed decisions.
Even when advisories are posted, fishers may ignore the warnings. The
Hudson River Sloop Clearwater (HRSC) environmental group conducted a
survey of individuals who supplement their diet and income with fish from the
Hudson. An ad-hoc interview of individuals fishing the river after the survey
found that some anglers think the fishing advisories are "a big fairy tale." There
is a strong belief among some fishers that if the fish "look okay", or if fishers
are "still alive," then no problems exist (HRSC, 1994). Such beliefs are a
testament to the need for advisory postings that first are available to everyone
and, more importantly, are explained clearly so that individuals who are
purchasing or receiving fish can make educated decisions about the quantity
to consume.
Sport fishers also form an informal community that may provide support and
essential relaxation for those who participate. For many this activity may be
their primary hobby and their outlet to escape the stresses of everyday life. For
many, fishing is a social activity. Even non-fishers participate in the festival-like
atmosphere that surrounds some fishing periods, such as the smelt runs in
Chicago. Other subpopulations where fishing and/or fish consumption are an
important part of the culture and traditions include some Asian American
communities, and long-time subsistence and commercial fishing communities
such as Chesapeake Bay fishers (EPA, 1994b).

Many people have participated in sports fishing activities over their lifetimes
and it is not uncommon to see many generations spending time together
fishing. As with Native American impacts, the importance of fishing to sports
fishers and to their communities should be considered carefully when evaluating
fish advisory actions. Cultural and spiritual values are extremely difficult to
quantify. Nonetheless, states should consider the effect that restricting a
fishery will have on these values when deciding whether or not to issue a fish
Although the value of traditional activities to communities cannot be quantified
in dollars, the importance of fishing and fish consumption to these communities
may be great. A high value may be placed on the ability to fish in traditional
fishing areas and to obtain food from nature. Both direct restrictions of fishing
and less intrusive fish advisories may also have strong implications for
communities with respect to the degradation of lands and waters that they hold
sacred. For these groups in particular, remediation of contaminated waters and
fish may be an especially high goal. In some cases, moving the fishing grounds
to other locations or limiting fish consumption to minimize risk may seem far
less appropriate than it would seem to fishers with differing attachments to the
land. The cultural implications of programs should be considered carefully in
designing risk reduction programs. Input from targeted populations may be
especially important in cases where traditional ways will be disrupted by such
Supplement A in Volume II has a detailed discussion of some specific groups
of subsistence fishers' dietary patterns. It also provides information regarding
the importance of fish both as a food source and in their cultural lives. This
section should be consulted for additional information on the topic.
3.3.2 Dietary Patterns
Nutritional advantages offish consumption were discussed in an earlier section,
but specific health benefits are not the only issue related to dietary restrictions
such as fish advisories. In many cultures within the U.S., particularly Asian
American and Native American groups, fish consumption is a long-standing
tradition, with recipes passed from generation to generation. Other groups also
have dietary traditions making extensive use of fish. As noted above, fish are
an important component of the diet of many urban and rural poor, as well as
those who fish for sport rather than economic necessity. Restrictions in fish
consumption may provide a hardship to those who have spent years cooking
in familiar ways. It may be difficult or impossible to substitute ingredients for
fish, and the taste may not be palatable to those accustomed to traditional fish

If substitutions are made for fish, the replacements may be less healthy (see
the health benefits section, 3.2) and may not be financially practical for
subsistence fishers. Many alternative western foods are higher in saturated
fats, salt, and other undesirable components. Considering the potential impacts
on the dietary patterns of targeted populations is encouraged in developing fish
advisory programs.
3.3.3 Use Taking and Mobility
People who have property that has traditionally entitled them to fish may suffer
significant negative impacts from fish advisories (commercial issues are
discussed in the following section). These individuals may be owners of
property where they have carried out recreational or subsistence fishing, or
tribal members with treaty rights to waterbodies. Such people may feel that
restrictions, particularly involuntary restrictions, on fishing are an infringement
on their property rights. Native American groups have characterized such
activities as use taking in a legal sense.
Fishers who have the option of using alternate waterbodies without advisories
(or with less stringent advisories) are not affected in the same way as those
who have specific rights regarding shore line or water property. Aside from any
commercial valuation, property owners may feel that the value of their property
to themselves is severely diminished if the fish are contaminated to an extent
requiring fish advisories.
3.4 Economic Impacts of Fishing Advisories
States should keep in mind that the imposition of fish advisories may result in
various social costs. For example, fish advisories may decrease the values of
properties abutting affected waterbodies used for fishing. The cost of obtaining
food containing high quality protein may increase for subsistence fishers who
must find alternative protein sources. The magnitude of these costs will
depend on the species of fish affected, the degree of fishing (sport and
subsistence) taking place before or after the advisory, the quantity of fish tissue
consumption allowed post-advisory, and the effect of ingesting contaminated
fish tissue on sensitive subpopulations such as children. These social costs can
be defined as the negative impact of fish advisories on human society. When
evaluating whether or not to issue a fish advisory, however, these social costs
must be weighed against the social benefit of reducing adverse effects to
human health.
In general, social costs and benefits can take several forms. They can include

impacts on goods and services with clearly defined markets such as commercial
fisheries. Alternatively, they can include impacts on items that society cares
about but are not traded on markets such as contaminant-free water. Finally,
other social costs and benefits may have components that can be valued
through market transactions and other components for which a dollar value is
cannot be set by the marketplace. Adverse health effects are a good example
of this situation. While health effects can lead to losses in productivity and
wages that are easily monetized, they will also lead to pain and suffering,
which are more difficult to value.
This section focuses on the three categories of social costs and benefits
associated with fish advisories. These categories are:
•	Costs Associated with Fishing - includes potential economic losses to
the recreational fishing industry, costs to anglers, price increases of
protein sources for subsistence fishers, and diminished cultural values.
•	Costs Associated with Property Values -- includes potential losses in land
value to land owners abutting a river reach where a fish advisory is in
•	Health Benefits from Contaminant Reductions - includes potential
benefits of reductions in contamination of fish ingested by recreational
and subsistence fishers and their families.
This section is not intended to provide in-depth guidance on how to estimate
social and economic costs and benefits, nor should it be viewed as inclusive of
all possible social costs and benefits associated with fish advisories. Rather,
it is intended to give states an idea of the types of costs and benefits they
should consider and how they might be estimated in the development of fish
advisories. In addition, some examples of possible costs and benefits are
provided. Note that the values presented in this section can not necessarily be
applied to a particular situation without further data collection and analysis.
Because fish advisories are site-specific, analyses of costs and benefits should
be carried out on a case-by-case basis.
3.4.1. Methods for Estimating Costs Resulting from Fish Advisories
Recreational, subsistence, and cultural values must be considered when
evaluating the economic and social costs associated with fish advisories. Each
of these values could be reduced significantly due to the imposition of a fish
advisory. To estimate the loss to each of these categories, the value derived
by each must first be established. While the market value for commercially

caught fish (i.e. price/lb) is easily established, fully capturing the cost of non-
market goods such as recreational and subsistence fishing is more complex and
difficult. Several approaches can be used to estimate values for non-market
goods including but not limited to the travel cost, contingent valuation, and
expenditure methods. These methods are summarized briefly below:
Travel Cost Method
The travel cost method (TCM) uses information on the costs that people incur
to travel to and use a particular site to estimate a demand curve for that site.
The method assumes that people who live X miles from a recreation site and
who face time and travel costs in getting to the site would use the site just as
frequently as people X + h miles from the site when faced with an admission
fee to the site equal to the additional time and travel costs associated with the
distance h. From this assumption and observations regarding the frequency of
use of different groups, a demand curve for the site can be traced out. The
demand curve is then used to estimate the "consumer surplus" associated with
the use of the site: in other words, the value that consumers receive from the
site over and above the costs that they incur in using it. Consumer surplus is
an estimate of the net benefits of the resource to the people using that
resource. For example, if the resource is a recreational fishing site, the method
can be used to value the recreational fishing experience (EPA, 1994b).
Contingent Valuation
In the contingent valuation (CV) method, surveys are conducted to elicit
individuals' willingness-to-pay (WTP) for a particular good, such as a fishery or
clean water. CV is more broadly applicable than TCM. Like the TCM, it can
be used to estimate consumer surplus associated with recreational fisheries, but
it can also be used to estimate less tangible values such as how much people
care about a clean environment.
Expenditure Method
This method estimates the value of a non-market good based on total
expenditures related to that good. For example, in the case of recreational
fishing, total trip expenditures and equipment expenditures can be used to
estimate the value of fishing to the angler. Although expenditures are an
indicator of the value of the fishing experience, they do not reflect the net
benefit associated with the experience (i.e., consumer surplus) as do the TCM
and CV methods. If a fishery were to be shut down, recreational fishers would
recoup what they would have spent on travel, equipment and other items.
Their consumer surplus, however, would be lost. Although consumer surplus

is a better measure of the economic value of recreational fisheries than simply
expenditures, both are presented in this guidance document because states
may be able to estimate expenditures more readily than they are able to
undertake a TCM or CV analysis.
States may want to undertake more than one type of analysis as a check for
consistency between the results of different methodologies. States should be
careful not to double count fishing values, however, by adding the results of
individual analyses.
3.4.2 Recreational Fishing and Tourism
To estimate recreational fishing values, states may want to use one of the
methodologies listed above. To undertake these analyses, states will need to
collect information including but not limited to: numbers of fishing days per site
per year, distances traveled by anglers per recreational fishing site, and
recreational fishing-related expenditures per angler per site. States that wish
to estimate fishing values using these approaches should contact the Office of
Water in their EPA Region or at Headquarters as well as economics
departments at state universities for further assistance. If conducting such
analyses is not possible, states should at least qualitatively describe the
possible impacts to recreational fishing of issuing a fish advisory.
Studies of economic value of recreational fishing have been conducted in many
sites throughout the US over the past 30 years. To assist states, Table 3-2
summarizes and compares examples of reported recreational fishing day values
based on travel cost methods, contingent valuation methods or expenditures.
In 1991, freshwater fishers took an average of 13 trips each and fished an
average of 14 days each (United States Fish and Wildlife Service (FWS), 1993).
During this period, fishers spent an average of $596 each on trip and
equipment expenditures, or approximately $41 per fishing day {FWS, 1993).
These expenditures where divided between items such as: food, lodging,
transportation, rods, reels, tackle boxes, camping equipment, boats, fishing
licenses, and fishing magazines.
For the purpose of this comparison, all values have been normalized to 1992
dollars. For example, the $41 average expenditures per day in 1991 becomes
$42 per day in 1992. As Table 3-2 indicates, the fishing day values range from
$16 to $69 per day, with a mean of about $38 per day.

Table 3-2. Examples of Values Reported for Recreational Fishing
Type of Value
Value (1992$)
Mean benefit/day of anadromous fishing
Walsh et al.
1988 (in EPA
Mean benefit/day of warm-water fishing
Walsh et al.
1988 (in EPA
Mean benefit/day of cold-water fishing
Walsh et al.
The information provided in Table 3-2 should not be considered to be
representative of all recreational fisheries. These values, therefore, should not
simply be applied to a river reach where a fish advisory is under consideration.
Rather, these values are meant to illustrate the relative value of certain types
of fisheries and expenditures made on fishing in the US.
States may also want to develop their own approaches to estimating
recreational fishing values, particularly where time and budget are limiting
constraints. For example, the Arkansas Game and Fish Commission estimated
the loss of fishing expenditures due to mercury-related fish consumption
advisories based on decreases in fishing license purchases in counties where
mercury advisories were issued. The decrease in licenses was multiplied by the
average number of trips an angler takes per year, and by the average per-trip
expenditures (EPA, 1994b). '
States should also keep in mind that recreational fishers may have alternative
sites that they would visit if a fish advisory were issued on a particular river
reach. As such, the value assumed to be lost due to a fish advisory must be
adjusted to account for the value (probably lower, or the fishers would be
fishing there in the first place) of the substitute site. Similarly, .anglers may just
catch and release fish from waterbodies with advisories in effect, which would
also have the effect of lowering the value of the fishing experience. Finally,
states should consider the probability that some fishers may ignore the
advisory, presumably resulting in increased health costs.
3.4.3	Subsistence Fishing and Food Costs
The impact of fish advisories to subsistence anglers may be more significant
than to recreational anglers due to higher fishing days and consumption rates.
This value, however, is not captured in the available recreational or commercial
fisheries data. Because subsistence fishers and their families may rely on the
fish they catch as their primary protein source, states should consider the cost
to subsistence fishers and their families to switch to a more expensive protein
source. As a rough approximation, states will need to estimate an average cost
difference between fish and alternative protein sources and apply this
difference to an estimate of kg/day consumed per person. In addition, states
should consider the extent to which nutritional value is simply lost if substitute
foods are not purchased.
3.4.4	Costs Associated with Property Values
Society places a premium on certain amenities associated with property (e.g.
size of lot, proximity to waterfront, scenic views, etc) evidenced by price

differentials among properties with varying degrees of these amenities. Where
an amenity is degraded, landowners are likely to experience a reduction in their
property value. As such, owners of land adjacent to waterbodies where fish
advisories are in effect may experience a decline in property value. One
common approach to evaluating the impact of changes in a particular attribute
to total value is the hedonic price technique. This technique is a method for
estimating the implicit price of the characteristics differentiating closely related
products in a product class. Hedonic pricing is based on the observation that
a market good can be represented as a bundle of characteristics that describe
the good; for example, a house can be described in terms of lot size, square
footage of the house, number of rooms, proximity to an amenity such as
waterfront, and any other number of features. In principle, if there are enough
models with different combinations of features, an implicit price relationship
can be estimated giving the price of any model as a function of its various
characteristics. For example, by observing how the selling price of the house
varies with, say, proximity to waterfront, the implicit value of proximity to
waterfront can be determined (Freeman, 1979). If the quality of the water in
a waterbody is degraded to the point where a fish advisory is issued, the
implicit value of the proximity to waterfront variable is expected to decrease3.
States should consider this cost as part of the total cost when establishing fish
advisories. States may want to describe potential rather than quantified
impacts to property values, however, since using the hedonic price technique
requires detailed time series and cross-sectional data on property values and
attributes and regression analysis.
3.4.5 Benefits Associated with Health Advisories
Although fish advisories will create costs, they may result in monetary benefits
in the form of reduced adverse health effects to society. As such, it is
important for agencies to consider both potential costs and benefits when
issuing fish advisories. Consumption of contaminated fish can cause health
problems, particularly for sensitive subpopulations. For example, infants are
more susceptible to certain pollutants, (e.g., mercury, lead) than adults. In
addition, populations that consume more fish than the general population (e.g.,
sport fishers, subsistence fishers, and their families) may be at greater risk.
Establishing fish advisories should therefore reduce these adverse health
effects; however, this has not been scientifically established. States should
also keep in mind that, to the extent that these groups are not aware of fishing
3 Other effects that influence changes in total value would have to be
addressed in any analysis undertaken by states.

advisories or are unwilling to observe them, the benefits of issuing a fish
advisory may be minimized.
Cost of Illness Approach
To estimate the benefits of fish advisories, risk managers should first consider
the economic impact of adverse health effects. Where adverse health effects
are avoided due to a fish advisory, this impact can then be considered a benefit
of the fish advisory. There are two methods for measuring the economic value
of health effects. One, the "cost-of-illness" (COI) approach, measures the
effects of illness that are directly observed in the marketplace, such as lost
wages and medical costs. To use COI, states would have to collect data on
the number of individuals, by subpopulation, expected to require a particular
type of medical care, the medical cost of each treatment scenario, and the
expected lost wages per affected individual. For an example of the COI
approach, states can refer to an EPA document titled The Medical Costs of Five
Illnesses Related to Exposure to Pollutants (EPA, 1992d).
Willingness to Pay Approach
The second approach measures the total value of health effects by estimating
an individual's willingness-to-pay (WTP) to avoid them. The WTP approach
should include the cost of illness, but also includes other less tangible costs
such as pain and suffering. This approach provides a more complete estimate
of the economic value of health effects than does the COI approach, but it is
more difficult to use because costs such as pain and suffering are not valued
in the marketplace. Two methods can be used to measure WTP. In the first,
the contingent valuation (CV) method, surveys are conducted to elicit people's
willingness to pay to avoid a particular health effect such as cancer. In the
second, information available on the monetary tradeoffs people make between
income and health risks is used. For example, people in occupations with a
higher risk of death than other occupations generally command a higher wage,
all other factors being equal. Similarly, people pay for items such as car air
bags that reduce the risk of death. Dividing the wage premium for a risky job,
or the cost of risk-reducing products, by the change in risk yields an estimate
of the "value of a statistical life." This value represents an aggregation of small
changes in risk across a population, rather than the value of the life of a
particular individual (EPA, 1994b).
Life Valuation
The literature on the value of a statistical life is well developed. Based on a
survey of this literature, values can range from $2 million to $10 million (1992

dollars) (EPA, 1989; Violette and Chestnut, 1983, 1986). These values,
however, will be useful to states only in cases where fish advisories are
expected to avoid fatal effects (such as cancer) associated with the
consumption of contaminated fish. Where fatal effects are possible, an
estimate can be made of the number of deaths expected.
Illness Valuation
Some limited information is available on the value of nonfatal effects like
nonfatal injuries, bronchitis, hospital visits, and respiratory symptom days.
These effects, however, may not be relevant to the types of health effects
typical of fish consumption. Other effects, such as decreased IQ can result in
costs to society and other opportunity costs that states may choose to
incorporate into their assessments. States interested in pursuing either the COI
or WTP approach should contact the Office of Water at EPA Headquarters in
Washington, D.C., as well as economics departments at state universities for
further assistance.
3.5 Legal and Treaty Rights
The legal and treaty rights of individuals and groups with respect to land and
activities can have a direct bearing on the authority of agencies to act regarding
fish contamination. Interference or alteration of these rights may also be a
significant consideration when evaluating program impacts. To the extent
possible, fish advisory programs should be designed to minimize negative
impacts on the rights of both the populations at risk and any other persons who
have rights with respect to the waterbodies and land under consideration.
Consequently, legal and treaty rights must be evaluated and interpreted when
developing fish advisory programs. More detailed information on the legal
aspects of this issue are beyond the scope of this document. State, federal,
local, and tribal laws may govern in this area and it may be advisable to obtain
legal counsel when such issues arise.
3.6. Summary
Numerous impacts of fish advisory programs on individuals, communities and
local economies are possible. A brief overview of some categories of these
impacts has been provided in this section. Risk managers and policy makers
are encouraged to discuss various options for controlling fish consumption with
community members and leaders to obtain a comprehensive understanding of
the impacts likely to occur as a result of the options under consideration. This

type of information gathering will also be an opportunity to discuss various
aspects of risk and fish contamination. Such discussions provide a mechanism
for educating both policy makers and community members regarding the issues
surrounding fish contamination problems and potential resolutions. Readers are
encouraged to review Volume IV: Risk Communication regarding various
aspects of communicating risks to the public.
The various fish advisory options, discussed in Section 2, have varying
potentials for impacting community relations, tourism, property values,
individual actions, traditional practices, and health. The extent of these
impacts will depend on specific characteristics of the populations affected by
fish advisories and the nature of the fish advisory program. Consequently, local
information, combined with specific plans regarding fish advisories, are needed
to evaluate the relative advantages and disadvantages of various options.
Table 3-3 provides a template for entering information regarding impacts of
limiting consumption. This template is similar to the one provided in Section
2, allowing risk managers to enter critical information to be used to compare
various options. The options discussed in this section are all listed in the
template; however, the risk manager may choose to consider only some of
these options or may add other others which are not listed.
Risk managers may elect to enter some indicator of impacts in the various cells
{e.g., low, moderate, high), estimated costs (where applicable), number of
people affected, or some other method of indicating the magnitude of an
impact. The type of information entered will depend on what data is available
and what would prove most useful to the decision-making process. Although
information is not likely to be available on the costing of benefits resulting from
reduced illness associated with contaminant exposure, the column is provided
for the reader's convenience.

Table 3-3. Template for the Impacts of Risk Management Options
Risk Management Options
Cultural Impacts
Economic Impacts
Benefits of
Dietary Patterns
Fishing &
Fishing &
Food Costs
No action

Fish consumption
General guidance


Catch and release


Fishing ban


4 Benefits are associated with reduced risks. These can be determined from risk assessment results (see Table 2-9) and from associated health
information provided in Volume DL Entries may consist of quantitative information, such as the number of people who will not be at risk as a result
of a program, or qualitative indicators of effects. Risk managers may also want to add a column for corresponding reductions in the benefits of fish
consumption (as discussed at the beginning of this section).

4.1. Overview
This section contains a discussion of methods for comparing the characteristics
of various management options to select the most appropriate options and
levels of protection based on program goals, available resources, and local
conditions. A discussion of both data organization and decision-making, as well
as one of qualitative comparisons of risk, organizational features, and impacts
are presented. Also addressed are decisions required for program design. The
focus of this section is on qualitative comparisons among options, although the
use of quantitative information is encouraged. Many factors, such as cultural
and other social impacts, cannot be quantified, or easily compared to
quantitative risk or economic data.
Templates are provided that can be used by risk managers to organize
information on option characteristics. These templates utilize information
discussed in other sections of this volume (e.g., risk levels, options), issues
related to prioritizing impacts are discussed along with methods for program
evaluation and modification.
4.2. Qualitative Comparisons of Health Risks and Options Impacts
The information discussed in other sections and volumes should be used to
evaluate overall advantages and disadvantages of various program options.
The information includes:
•	organizational impacts including feasibility and efficacy (Section 2),
•	societal impacts including nutritional, cultural, and economic impacts
(Section 3), and
•	population risk characterization (Supplement B in Volume II).

The information can also be used to prioritize activities. It is suggested that the
planning and evaluations for fish advisories be carried out on a site-specific
basis whenever feasible- As discussed previously, local population
characteristics and impacts on local traditions and economies may vary
considerably from one area to another.
Various types of information are required for decision-making. Some may be
of a quantitative nature (e.g., risks associated with current consumption
patterns, the estimated costs of various program activities, staffing
requirements, impacts on property values). The quantitative values may be
best estimates; however, this type of predictive information often contains
significant uncertainty and should be considered accordingly. Most information
collected for a fish advisory program will likely be of a qualitative nature {e.g.,
potential cultural impacts on targeted populations, nutritional impacts).
Some form of risk characterization is also assumed to have been generated,
although it may not be precise and should be considered a rough estimate even
when detailed analyses have been carried out. (Risk characterization is
discussed in Supplement B.) Federal risk assessment methods were designed
primarily to provide a means to establish exposure limits (e.g., for drinking
water standards) and generate protective rather than predictive estimates.
Consequently, the risk estimates should be considered an indication of
maximum risk rather than a precise predictor of actual risk. As discussed
previously, risk reduction through implementation of fish advisory programs are
characterized as "benefits" for purposes of discussing advantages and
disadvantages of various options. Benefits are those cases or people who
would have been affected that were not affected as a result of reductions in
their consumption of contaminated fish.
A wide variety of risk management options have been considered in this
document. The selection of which options to consider for inclusion in a fish
advisory program is a critical decision. Risk managers may have wide latitude
in establishing fish advisory programs or they may be operating under a specific
set of constraints regarding their options for reducing fish-related risks.
Restricting access to waterbodies or banning fishing may not be an option in
areas where no regulatory authority is held by the overseeing fish
contamination problems. (In most areas, however, the health department will
have authority to restrict access in cases where a clear and present danger to
the public exists.)
Significant constraints on program options may also be imposed by budgetary
or other conditions. Because the options have differing potentials for reducing
risk, restricting options may affect a program's risk reduction potential

significantly. The full spectrum of risk management options should be
considered prior to selecting a particular subset of activities. This approach
enables risk managers to review the advantages and disadvantages of all
possibilities with other interested parties, so that the final decisions may be
considered objective and fully thought through.
Table 4-1 provides a template for organizing information on the various
impacts, resource needs, and benefits of program options. This template
provides only a small amount of space for information entry in any category.
Indicators of effect may be used instead of long narrative descriptions;
alternatively, risk managers may use this template as a model to modify
according to their needs. Information should be organized by water body
and/or targeted population. One set of data could be generated for each
subpopulation, allowing decisions to be made more easily on a site-specific
basis. This method is recommended because the characteristics of each group
may differ.
Restriction of fish consumption involves tradeoffs with respect to health,
recreation, economics, community and traditional activities, and personal
interests and other perceived benefits of fish consumption. Risk managers are
encouraged to consider all risks and impacts in some way; however, managers
may elect to focus on one or a few of the potential risks or impacts. The types
of options and the degree of restrictiveness than a fish advisory program
recommends will depend, in part, on the way in which various population
groups and their risks are evaluated and upon the impacts considered most
important. Decisions regarding how risks and impacts are prioritized and
balanced will have a pronounced effect on fish advisory programs. Involvement
of all affected parties in the evaluation and decision-making process is highly
4.3. Selection of Options
Risk managers, in concert with other policy makers, scientific and health
advisors, and community members, will recommend the most appropriate
options for dealing with fish contamination. In large programs, such as state
programs, an array of options may be chosen corresponding to specific

Table 4-1. Information Summary on Organizational Factors, Impacts and Benefits: Template1
Cultural Impacts
Health Benefits
No action

Fish advisories


Catch and release


Fish ban


1 TWs template is for entry of information in any form which is useful to risk managers. This may be descriptive or
quantal information, such as high, medium and low, or quantitative information such as number of staff required, costs of
programs, etc. It is not anticipated that governing bodies will have detailed information on all categories included; however,
this template may be used to organize the inforamtion which has been collected.

contamination characteristics, risk, targeted populations, and resources. It is
assumed in this document that most decisions will involve the use of general
or quantitative fish advisories in areas where contamination is known to exist
at levels posing significant population risks. As discussed in Section 2,
however, determining what level of risk is significant is an agency decision, and
will affect the scope and nature of fish advisory programs.
The selection of appropriate fish advisory options is obviously a critical decision
(as defined in Section 1) in program development. While this appears to be the
most important decision, it usually will be based upon information gathered
regarding individual or community risk levels and characteristics. This
information, in turn is dependent on previous decisions regarding consumption
rates, sampling and analysis, risk value selection, target population
identification, evaluation of non-fish exposures, and consideration of impacts.
These factors have been discussed in previous sections of this document and
are summarized in Table 1 -1. Because all previous decisions contribute to the
basis for option selection and determination of protection levels, it is suggested
that risk managers review these initial decisions prior to making the final
decisions discussed in this chapter.
It is useful to evaluate whether previous decisions were health conservative or
not; whether they took into account all or some of the population; whether
they focused on average, high end, or bounding exposure and risk values; and
.other factors. Such information can be used when evaluating options and
advisory levels to arrive at appropriate choices. If conservative assumptions
were used in previous decisions, there may be less concern that compliance
with advisories be strictly adhered to. Alternatively, if average values were used
and sensitive populations were not targeted, non-compliance with advisories
could have significantly greater adverse effects.
In selecting specific fish advisory options, risk managers may want to consider
carefully which strategies are likely to be most effective for the populations
which are to be served. This group is typically made up of several populations
near various waterbodies and may require separate evaluation of each case.
Information on the likelihood that a group will benefit from a particular approach
can be inferred from the data collected on cultural, economic, and nutritional
impacts. In addition, any other anecdotal or local information with a bearing
on this type of decision should be considered. Such decisions are not
necessarily based solely on objective data, and may require a familiarity with
and sensitivity to the targeted population.
Practical considerations regarding sample quantitation limits are also relevant.
Some contaminants may not be quantifiable at levels which are as low as those

indicated as optimal by health risk data. For example, quantifying the
concentrations may not be possible at levels yielding a cancer risk of one in one
million. This practical constraint may be important in establishing a realistic
advisory. In some cases it may necessitate the acceptance of a higher level of
risk than would be chosen based solely on health considerations. Flexibility in
the program design will allow for modifications in advisories over time in
keeping with more sensitive assays likely to be developed in the future.
Risk managers may elect to base option selection largely on risk. An example
of this type of approach follows:
•	A governing body could elect to take no action when cancer risks were
less than one in one million and the concentrations were significantly
less than the RfDs for non-carcinogens.
•	General advisories could be developed when cancer risk levels were in
the range of one in one hundred thousand to one in one million and the
RfDs were not exceeded but were approached.
•	Quantitative advisories could be developed for carcinogens with risk
levels greater than one in ten thousand but less than one in one
thousand and when the RfDs were exceeded by a factor of up to ten.
•	Fishing bans and/or catch and release programs (either voluntary or
involuntary) could be used when cancer risks exceeded on in one
thousand and RfDs were exceeded by a factor greater than 10.
This tiered approach provides a spectrum of activities to deal with negligible to
serious risks. This is only an example; risk managers may decide to structure
their programs quite differently. Decisions should be made in the context of
previous decisions and include considerations of whether previous decisions
were sufficiently health conservative. As discussed throughout this document,
decisions should also take into consideration the characteristics and needs of
local affected communities.
The tiered approach is an overall strategy that may be applicable to all areas
within a governing body's jurisdiction. It is risk-based and its application to
specific waterbodies and populations requires risk information. Consequently,
risk calculations may be carried out (see Supplement B in Volume II) requiring
contamination data, consumption patterns, risk values, and body weight data.
Table 4-2 provides a template that risk managers may use to organize

Table 4-2. Tiered Approach to Fish Advisories
Risk Level



Other Considerations



information for a tiered approach to risk reduction. Note that both cancer risk
and non-cancer risk entry cells are provided. The advantages and
disadvantages of selecting various values for the parameters used in this table
are discussed throughout this text.
This approach is especially sensitive to decisions regarding consumption
patterns and risk values. Contamination data are obtained through sampling
and so not subject to alterations. Body weight data, while important, will
usually not alter final results significantly. For example, the use of a 60 kg
body weight for women will result in an "allowable" level of contamination
which is only 15 percent lower than that for a 70 kg man. Approaches based
on children's body weights may have a more substantial impact. Consumption
patterns may vary widely within and among populations. The rate of 6.5 g per
day is less than one tenth that observed in many studies of subsistence fishers,
some of whom consume considerably more than 100 grams per day. For
example, a recently completed study in the Great Lakes found that the average
fisher consumed 360 grams per day (GLIFWC, 1994). Selecting a consumption
rate is therefore a critical factor in establishing where fish advisories are needed
and the nature of the advisory programs. It may be advisable to develop
criteria based on different consumption rates for populations with widely
varying consumption patterns.
Risk values are also a critical parameter in making decisions regarding advisory
programs. Supplement B discusses the importance of selecting an appropriate
health endpoint (e.g., developmental, systemic, non-carcinogenic) and its
potentially significant impact on the level of contamination considered to pose
unacceptable risks. As the discussions of individual chemical contaminants in
Volume II demonstrate, many contaminants are associated with numerous
different types of toxicity that may be exhibited at different levels of exposure.
Recent developmental toxicity, neurotoxicity, or immunotoxicity data may
indicate that risk occurs at lower levels of exposure than those indicated by
previous liver and kidney toxicity studies. (The organ that is most sensitive will
vary by chemical.) The use of the most sensitive endpoint will result in a more
conservative approach to health protection.
Carcinogenic toxicity has in the past often yielded the most health-conservative
exposure limits, especially when coupled with a low level of "acceptable" risk
such as one in one million. Decision-makers may elect to choose a non-cancer
health endpoint or a less stringent level of acceptable risk. For some chemicals
there may be alternatives to choose from regarding risk endpoints and values
varying by orders of magnitude. The decisions will affect the scope and nature

of a fish advisory program and the level of protection afforded the public
substantially. Careful consideration of the advantages and disadvantages of
the decisions regarding risk parameters is strongly encouraged.
Table 4-2 contains separate entry areas for other considerations that decision-
makers may feel are important. These may include specific concerns regarding
special sensitivities or types of effects that risk managers may feel justify an
alternative approach. An example of this might be when new toxicity data
become available. Under these circumstances, risk assessors may provide a
new analysis that is used in developing fish advisories. An example is provided
by mercury, which has been carefully evaluated by some states and
subsequently stringent guidance was developed. Evidence of mercury toxicity
is provided in human studies and causes serious effects in offspring of exposed
women and exposed infants, as discussed in Volume II. These factors have led
some risk managers to approach this chemical more aggressively than other
contaminants. Risk managers may also elect to address other developmental
toxins with greater conservatism due to concerns regarding exposures of
pregnant women. Significant toxicity data gaps, the existence of known highly
sensitive individuals in a population, or other predisposing factors such as poor
nutritional status may lead risk managers to vary their options selections.
4.4. Levels of Protection
When fish advisories are considered necessary, risk managers will determine
the level of protection in a fish advisory to be afforded targeted populations.
Risk managers may choose from various risk values (e.g., RfDs and cancer
potencies, locally generated values) to establish consumption limits. These
values will result in consumption limits varying by orders of magnitude,
especially when cancer-based and non-cancer-based values are compared. In
addition, targeted "acceptable" risk levels are used in setting limits for
carcinogens. Decisions regarding risk values can have a substantial impact on
consumption limitation policies and on potential risks to the population.
This is discussed in some detail in Supplement B of Volume II.
The consumption limits, listed in Volume II, provide different levels of
protection from carcinogenic risk, ranging from one in ten thousand to one in
one million upper bound lifetime likelihood of cancer. Consumption limits
corresponding to these different risk levels in risk multiples of 10 are provided;
however, the methodology to calculate consumption limits for other risk levels
is also described, and can be used when appropriate. Cancer risks are
evaluated based upon an assumed relationship between exposure and lifetime
risk as defined in the cancer potency values for each target analyte. Risk

managers determine what level of risk is acceptable (e.g., one in ten thousand,
one in one million), which enables them to identify a particular exposure level
as acceptable. The acceptable level of risk can be determined by the needs and
goals of the target population, the decision-makers, other affected parties, or,
under ideal circumstances, by joint discussions between the various impacted
groups and agency staff.
Consumption limits based on non-carcinogenic effects typically use an RfD or
other benchmark approach to determine a "safe" exposure level. The potential
for non-carcinogenic effects can be evaluated by comparing exposures
quantitatively to a Reference Dose (RfD) or some other benchmark of a "safe"
exposure level (Supplement B in Volume II). Volume II provides the RfDs
developed by EPA, along with a summary of toxicological information for the
23 target analytes. It also includes discussions of recent study results for most
analytes regarding developmental, neurological and other types of toxicity. As
discussed in Volume II, risk assessors may elect to use the EPA RfDs or review
of the toxicological literature and develop their own exposure limits, based upon
which values they consider most appropriate for their target populations. In
some cases, more than one value may be selected for various subgroups of the
population (e.g., children, women of reproductive age).
Table 4-3 provides a template to be used to list the selected values for
contaminants in a particular waterbody, or which are of concern to a particular
population. If a population fishes from more than one waterbody it may be
advisable to include all chemical exposures in one evaluation so that similarly
acting chemicals can be identified. The template includes entry areas for a
variety of population subgroups and for various body weights of children. Risk
managers may decide to refine their advisories to this level, or may determine
that one general advisory is sufficient.
Consumption limits are provided in Volume II and offer various options from
which to choose. Consumption limits for children are based on one body
weight in Volume II; however, methods for calculating consumption limits for
other body weights are also provided in that volume. Adult consumption limits
are based on a 70 kilogram body weight for the general population and for
women. Risk assessors and managers may determine that their female
population of reproductive age has a different average body weight, or that a
lower than average body weight should be used to provide a more health
conservative values. Methods for calculating new consumption limits (or
modifying the limits provided in the tables listed in Volume II) are also provided.

Table 4-3. Template for the Summary of Advisory Levels
Children's Advisory


Decisions regarding the establishment of fish intake limit levels are at the
discretion of the agency issuing fish advisories. The federal agencies, including
EPA and FDA, who provide information and support in this area, do not have
regulatory authority over non-commercial fish. Agencies are encouraged to
establish limits which are most appropriate for their target populations in the
context of local needs and characteristics.
4.5. Level of Program Effort and Funding
As discussed in Section 2, programs utilizing similar options (e.g. quantitative
fish advisories) may differ substantially due to differing levels of effort and
funding. Financial constraints may be moderate or severe, depending on the
financial circumstances of the agency. These constraints affect the manner in
which options can be implemented and may be a consideration in selection of
an option as discussed in Section 2. The level of program effort and funding
is a critical decision which is often beyond the scope of the risk manager. Risk
managers may wish to maximize the available resources through cooperative
activities with other agencies carrying out similar work, community groups with
similar goals, or health or environmental organizations having similar interests
(this is briefly discussed in Section 3).
Discussions of organizational structures and staffing for fish advisory programs
are beyond the scope of this document. There are numerous public
management guidebooks, however, providing information on effective and
efficient management structures and program design that could maximize the
effectiveness of a fish advisory program regardless of its size (Ga wthrop, 1984;
Koteen, 1989; Bryson, 1988 and 1992; Frederickson, 1980; Vasu, 1990;
Campbell, 1988; Gilbert, 1983; Association for Public Policy Analysis and
Management, 1982; Carr, 1990). Readers are urged to consult these sources,
as well as states and other groups that have set up fish advisory programs, to
identify approaches that can be used to meet their goals using available
A significant consideration in evaluating the type of fish advisory program that
can be set up using a particular resource allocation is the overall population to
be served. This population is typically made up of several sub-populations near
various waterbodies, that may have different consumption patterns, risks, and
likelihood of compliance with advisories. Within the constraints imposed by
available resources, risk managers must determine which groups are in the
greatest need of services and how those groups will best be served. Moderate
services may be provided to a larger number of groups, or especially high-risk
groups may be targeted for intensive efforts. The utilization of all types of

information previously discussed in this document may be helpful in determining
the best approach to this type of resource allocation problem. Consultation
with affected parties is also encouraged, because they may have strategies for
accessing other resources to address program goals.
4.6. Program Evaluation and Modification
When a fish advisory program is being designed or modified, risk managers may
want to consider inclusion of a component that involves program evaluation
and modification. These activities are often not considered in the initial
planning of a program, but an efficacy review in a program can help managers
determine how effective it is (who it is reaching, whether their behavior has
changed, whether the target population wants additional information, etc) and
how the program might be altered to better address its goals. This type of
activity can be carried out informally through contacting local participants and
members of the targeted population routinely, or may be more formally
designed to sample effectiveness randomly through surveys or some other
Incorporating flexibility into fish advisory programs is important so that
necessary modifications can be made both in the initial design and over time as
needs change. The decision to include these elements in a program design is
one the risk managers should consider carefully to provide for the long-range
success of a fish advisory program. The decision to include these components
in a fish advisory program is considered critical because it may have a
substantial impact on a program's long-term success.
4.7. Summary
This section has provided methods for organizing and considering information
regarding risk, organizational issues, and impacts of fish advisory options. Risk
managers and others involved in the decision-making process may need to
utilize information from a variety of sources to gain an overall sense of who
needs to be served by fish advisory programs and how to best design a
program. As with any public undertaking, all problems and issues cannot be
anticipated. Consequently, program flexibility is necessary to ensure long-term
effectiveness. By broadly considering the characteristics of the target
populations, however, risk managers will be better able to design programs
appropriately (this is also addressed in Volume IV: Risk Communication). When

decisions are made and programs are designed with participation from
representatives of targeted populations, valuable insights into the community
are gained and the opportunities for a successful program are increased.
The Agency recognizes that there is much valuable information that can be
obtained through the experiences of people in the field who are working on the
development of fish advisory programs. EPA welcomes contributions from
these people. Future versions of this document will benefit from information
which readers submit.

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