(Puget) Sound Science

The current debate surrounding Washington State's sediment cleanup and water quality standards provides another example of regulated industry calling for "sound science" in environmental regulation, yet working to undermine it. Industry has worked to delay updates to water quality standards based on the most recent scientific studies, despite the fact that the current standards are based on decades-old data and don't adequately protect human health. Most recently, industry has sought to weaken any forthcoming standards by misrepresenting scientific studies of contamination in Puget Sound and other marine waters and its impact on salmon. When agencies set standards limiting toxic pollution in our waters, they aim to protect humans exposed to these toxics by eating fish. Fish consumption is the primary route by which people are exposed to a host of toxic contaminants, including PCBs, dioxins, and mercury. Washington's current water quality standards enlist a "fish consumption rate" (FCR) based on surveys of people's fish consumption practices back in 1973-74. Although more recent survey data have existed for some time, the state's Department of Ecology has declined to update its standards, even though its FCR of 6.5 grams/day - just one fish meal per month - grossly understates contemporary consumption rates for Washingtonians, including members of the fishing tribes, the Asian and Pacific Islander community, and others. An increase in the FCR would mean more protective environmental standards. Industry, for its part, has weighed in with calls to retain the current FCR - hardly an embrace of the state of the science. In recent public comments, industry has taken the tack of gutting the FCR. They have argued that people's intake of salmon ought to be excluded from the FCR, on the theory that salmon, which are anadromous (i.e., they spend a portion of their lifecycles in freshwater and saltwater environments), obtain their contaminant body burden outside of waters of regulatory concern. If salmon are getting their contaminants elsewhere, this argument goes, Washington ought not seek pollution prevention or cleanup from industries within its jurisdiction. Because salmon comprise a considerable portion of Washingtonians' fish intake, to exclude salmon from the FCR would be to decrease significantly the protectiveness of the environmental standards.