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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
17-P-0174
April 12, 2017
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), conducted this review to
evaluate the extent the EPA
ensures that federal, state and
tribal risk communication efforts
protect the public from mercury
contamination through the
consumption of fish. We
focused our evaluation on
determining how effectively fish
consumption advisory
information reached consumers
so that they could make healthy
consumption choices.
Research shows that
consuming fish contaminated
by mercury can lead to
negative health impacts in
humans. The Clean Water Act
(CWA) establishes a goal of
"water quality which provides
for the protection and
propagation of fish, shellfish
and wildlife." The EPA
interprets this CWA goal as
supporting water quality that
provides for the protection of
human health related to the
consumption of fish.
This report addresses the
following EPA goal or
cross-agency strategy:
• Protecting America's
waters.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.aov/oia.
Listing of OIG reports.
EPA Needs to Provide Leadership and Better
Guidance to Improve Fish Advisory
Risk Communications
Without EPA guidance and
assistance, subsistence fishers,
including tribes, will continue to
consume unhealthy amounts of
contaminated fish.
What We Found
Some subsistence fishers, tribes, sport
fishers and other groups consume large
amounts of contaminated fish without
health warnings. Although most states
and some tribes have fish advisories in
place, this information is often confusing,
complex and does not effectively reach those segments of the population.
Fish advisories differ from state to state, between states and tribes, and
across state and tribal borders, which in some cases leads to multiple
advisories with conflicting advice for a single waterbody. In addition,
although the EPA's risk communication guidance recommends evaluations
offish advisories, we found that less than half of states, and no tribes, have
evaluated the effectiveness of their fish advisories. Under the CWA, the EPA
can take a stronger leadership role in working with states and tribes to
ensure that effective fish advisory information reaches all such segments of
the population.
We also found that the EPA has not assessed methyl mercury as proposed in
the agency's published Integrated Risk Information System (IRIS) agendas.
The EPA included methylmercury on its 2012 IRIS agenda for assessment,
and on its 2015 IRIS agenda as a priority for assessment. However, to date,
the agency has not commenced the assessment. Currently, the EPA's 2001
reference dose for methylmercury is an agency-supported value that the
EPA continues to accept for decision-making. Because of its importance in
developing water quality standards, and ultimately fish advisories, the RfD
should be accurate to ensure that effective fish advisory information is
communicated.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA's Office of Water provide updated fish advisory
guidance to states and tribes, work with states and tribes to develop best
practices to evaluate the effectiveness of fish advisories, and develop and
implement methods to ensure tribal members receive current fish advisory
information. We recommend that the EPA's Office of Research and Development
conduct an assessment for methylmercury to determine whether the reference
dose requires updating as proposed in the 2012 and 2015 IRIS agendas. After
receiving responses to our draft report from the two EPA offices, we met to
discuss their comments and our recommendations. Based on the follow-up
discussion and supplemental information provided by both offices, we found that
their corrective actions and milestone dates meet the intent of our
recommendations (Appendix C). All recommendations are resolved.

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