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Aroclor-1260 (a PCB) and mercury were reported at concentrations of potential public health concern. Interpreting the public health significance of these results is difficult because whole fish rather than edible tissue homogenates were analyzed. Using whole fish homogenates can overestimate or underestimate the contaminant concentrations to which people may be exposed depending upon where the contaminant accumulates in the fish. PCBs are fat soluble; thus, using a whole fish homogenate may overestimate the concentration to which a person eating the fish might be exposed. Conversely, mercury concentrates in muscle tissue; thus, using a whole fish homogenate may underestimate the concentration to which a person eating the fish might be exposed.  


  1. Based on available information, TDH could not determine the necessity for a fish consumption advisory, i.e., ingestion of fish from Ponds 22 and 24 pose an indeterminate public health hazard. Whole fish homogenates were used to determine contaminant concentrations in these fish. To issue a fish consumption advisory, the TDH Seafood Safety Division (SSD) requires that contaminant concentrations be obtained from the edible portions of the fish. Although TDH cannot use these data to issue a consumption advisory we are concerned with the concentrations of mercury found in the fish. Generally, concentrations such as these are found in much larger predator species.


  1. We have recommended that the EPA contact the TDH SSD to coordinate follow-up sampling of fish from these ponds. Additionally, we recommend that the TDH and the EPA review available environmental information to determine the need for sampling fish tissue from Pond 25, a pond that appears contiguous with Pond 24.


The TDH has prepared this consult under a Cooperative Agreement with the Agency for Toxic Substances and Disease Registry (ATSDR). TDH has included the following information in accordance with ATSDR's Child Health Initiative.

ATSDR's Child Health Initiative recognizes that the unique vulnerabilities of infants and children demand special emphasis in communities faced with contamination of their water, soil, air, or food. Children are at greater risk than adults from certain kinds of exposures to hazardous substances emitted from waste sites and emergency events. They are more likely to be exposed because they play outdoors and they often bring food into contaminated areas. They are shorter than adults, which means they breathe dust, soil, and heavy vapors close to the ground. Children are also smaller, resulting in higher doses of chemical exposure per body weight. The developing body systems of children can sustain permanent damage if toxic exposures occur during critical growth stages. Most importantly, children depend completely on adults for risk identification and management decisions, housing decisions, and access to medical care.

TDH did not have adequate information to evaluate the risks to children from the fish sampling data provided. Additional fish sampling has been recommended.

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