Neurotoxicity: PCBs

Polychlorinated biphenyls (PCBs) are industrial chemicals that were produced in large quantities from the 1920s through 1979 for use as insulators, lubricants, capacitors, and coatings in electrical transformers (ATSDR 2001). There are 209 congeners, or different types, of PCB’s. PCBs have been linked to many health impacts, including neurodevelopmental toxicity.

Of the 209 congeners of PCBs, 13 are similar to dioxin compounds in structure and toxicity (these are known as dioxin-like), while the other congeners have different structures and toxicity mechanisms (CDC 2005). On a molecular level, dioxin-like PCB congeners can bind to the aryl hydrocarbon (Ah) receptor in the body and move into the cell nucleus, influencing transcription of several hormones and growth factors, which can cause a multitude of different effects (GBPSR 2000). Non-dioxin-like PCBs can interfere with thyroid hormone function, and some congeners alter normal brain neurotransmitter levels (GBPSR 2000).

Although PCBs were banned in the U.S. in 1979, their persistence in the environment makes them a continuing environmental health concern, particularly for infants and children. Since their ban, PCB levels have decreased; however due to their environmental persistence, PCB’s are still widely found in fish in Michigan in the majority of water bodies sampled (MDCH 2010). This section will briefly summarize PCB exposures and associated health effects, present leading policy practices from other states, and recommend steps to minimize childhood PCB exposure in Michigan.

Michigan Highlights

Exposure Data

PCB contamination through the state is extensive. Based on data from the Michigan Department of Environmental Quality (MDEQ), PCBs have been found to be the most ubiquitous contaminant in Michigan’s waterways.

Study results also indicate that all 97 Great Lakes connecting channel miles have elevated concentrations of PCBs in the water column (MDEQ 2006). These PCB levels contribute to the high number of fish deemed unfit for consumption in Michigan’s 140,000 acres of lakes or impoundment areas (MDEQ, 2006) PCB monitoring has also been conducted on 19,646 of Michigan’s perennial river miles; these data show that 100% of the monitored river miles do not meet the PCB Water Quality Standards (WQS) (MDEQ 2006).

A large cohort study of Lake Michigan residents (enrolled in 1980) was conducted in order to determine whether there was an association between body burden of PCB’s and fish consumption from Lake Michigan fish. The cohort consisted of both fish eaters and non-fish eaters. Initial cohort enrollment was established between the years 1979-1982, just after the halt of mass production of PCBs in the US. Initial serum PCB levels were obtained and revealed much higher exposure levels for fish eating individuals (mean = 21.4 parts per billion) in comparison to non-fish eating individuals (mean = 6.6ppb) (Humphrey et al. 2000).

Policy

To reduce health hazards posed to children by exposure to PCBs, Michigan should strongly consider:

• Appropriation of more funds for the advisory. Funding would allow for updated toxicological information in the fish advisory and a better-informed trigger level for PCBs. This information has not been re-evaluated for at least 10 years because of a lack of funding.
• More widespread distribution of the advisory (Michigan Family Fish Consumption Guide), including distribution of printed copies to local public health departments, pregnant women, and sports fisherman at the time of receiving a fishing license.
• Public education campaigns about healthy fish consumption, especially among pregnant women, women of childbearing age, and children.
• Appropriation of funding to the MFCMP for testing of additional fish species, fish samples, and water bodies, and for testing of dioxin-like PCBs.
• Post advisories in appropriate languages at highly trafficked fishing spots where contamination is a concern.
• Expansion of the current PCB fund to include any contaminated area, not just silos.
• Better monitoring at disposal sites and removing remaining sources of PCB capacitors and transformers, mimicking efforts in Maine and Minnesota.
• Ban on the incineration of materials with PCBs as seen in California
• Stricter policies for PCB disposal and removal from capacitors, as seen in New York, New Jersey, and Wisconsin.

Background Information

Sources and Types of PCBs

Each PCB congener has a slightly different chemical structure and toxicity. Because PCBs are highly persistent and do not readily break down in the environment, they remain a concern today despite being banned in the U.S. in 1979. PCBs can reside in the air for long periods of time, resulting in deposition far from the primary source. In water, a small amount of PCBs may dissolve, but most will bind to soil particles, sediment, or organic tissue. This is due to the lipophilicity of PCBs, the “fat-liking” property of the compounds that allow them to easily dissolve in fats or oils, but not in water. Because PCBs readily bind to lipids, concentrations of the chemicals can increase with higher trophic levels through a process known as biomagnification; the result is that organisms at the top of food chains, such as humans, typically have much higher body burdens than organisms at lower trophic levels. (ATSDR 2001)

PCBs are no longer produced in the United States due to their persistence in the environment and toxicity to animals and humans (ATSDR 2001). However, reservoirs of PCBs in older electrical transformers still in use remain a potential source of PCB release to the environment. PCBs also still exist in landfills and hazardous waste sites with potential environmental releases through volatilization or groundwater contamination (GBPSR 2000). Approximately 500 million pounds of PCBs have been dumped in landfills and waterways (Nadakavukaren 2000). There are significant reservoirs of PCB contamination in Michigan waterways and sediments. Areas with high PCB concentrations in soils and sediments are ongoing sources of PCB releases to the ambient environment. PCBs can enter the atmosphere from volatilization from areas where PCB’s have been stored, disposed, or spilled (EPA 2000). Additionally, incineration of PCB-containing products and PCB formation during production processes also contribute to atmospheric PCB concentrations (EPA 2000).

Neurotoxicity and PCBs

Of the 209 congeners of PCBs, 13 are similar to dioxin compounds in structure and toxicity (these are known as dioxin-like), while the other congeners have different structures and toxicity mechanisms (CDC 2005). On a molecular level, dioxin-like PCB congeners can bind to the aryl hydrocarbon (Ah) receptor in the body and move into the cell nucleus, influencing transcription of several hormones and growth factors, which can cause a multitude of different effects (GBPSR 2000). Non-dioxin-like PCBs can interfere with thyroid hormone function, and some congeners alter normal brain neurotransmitter levels (GBPSR 2000).

Both animal and human studies have linked PCB exposure to neurodevelopmental impacts. For example, monkeys exposed to levels of PCBs commonly found in human breast milk showed impaired learning and performance skills, as well as the inability to inhibit inappropriate responses. The monkeys had PCB levels in their blood similar to that of the general population (2-3 ppb) (GBPSR 2000). Rats exposed to PCBs prenatally showed reduced visual discrimination, changes in activity level, and impaired learning, even at low maternal doses of PCBs (GBSR 2000).

Many human studies have demonstrated an association between prenatal PCB exposure and neurodevelopmental effects. For example, a longitudinal human study completed in Michigan examined the neurodevelopmental impacts of prenatal PCB exposure, much of which was through maternal consumption of contaminated fish. The study followed 313 mothers in four maternity hospitals in Western Michigan beginning in 1980. Of the 313 women, 242 had eaten at least 11.8 kg of fish from Lake Michigan over the previous six years (Jacobson 2002). This study showed that prenatal PCB exposure (as measured through umbilical cord serum, maternal serum, and breast milk) was significantly associated with lower verbal IQ scores. According to Jacobson’s 2002 article, “adverse effects of prenatal PCB exposure on verbal IQ were observed in the top 16.8% of the sample, although poorer reading comprehension was observed at somewhat lower exposure levels.” Further, the 2002 analyses showed that prenatal PCB exposure at or above 1.25 µg/g was associated with a tripling of the incidence of poor performance in the low-normal range (defined as performance of more than 1 standard deviation below the mean). Although the children performing in that range were not more likely to require special education services, it can be assumed that they had to struggle to keep up in a normal classroom, given their low IQ and reading scores (Jacobson 2002). Depending on the benchmark criteria used to assess risk, the authors calculated that between 10 and 75% of the Michigan cohort would have been considered at risk for adverse outcomes (Jacobson 2002). This human exposure study illustrates that a sizable portion of Michigan children are at risk of adverse health outcomes from prenatal PCB exposure.

In addition to the Michigan study, several other studies in North Carolina, New York, and the Netherlands have all shown negative associations between prenatal PCB exposures and neurodevelopmental outcomes. The North Carolina study found that higher fetal PCB exposures were associated with lower scores on infant psychomotor development tests (Gladen, Rogan 1991). The New York study found that newborn children born to mothers who ate fish from Lake Ontario that were contaminated with PCBs showed abnormal reflexes and startle responses and decreased visual recognition (Lonky et al, 1996).

Between 1973 and 1991, the Michigan Department of Community Health conducted three surveys to assess PCB and DDE serum concentrations in Michigan anglers. This study collected data from 168 offspring who were born after 1968 and had maternal exposure information. The results indicated a reduced birth weight for the offspring of mothers who had a PCB concentration ≥25 µg / L (Karmaus 2004). This group, however, was comprised of only seven observations and therefore further study is necessary to confirm these findings.

Prenatal exposures have also been associated with adverse impacts on memory and attention that persists into the pre-teen years (Jacobson, Jacobson 1996), as well as adverse effects on central nervous function. The adverse effects associated with lower-level exposures include decreased intelligence, impaired memory, and decreased attention span and appear permanent and irreversible (Tilson et al. 1990; Yu et al. 1991). Similar effects have not been seen following exposure to PCBs during infancy and childhood, however, suggesting a window of vulnerability to PCBs for the developing brain in utero (Landrigan et al. 2005).

Childhood Exposure to PCBs

Because PCBs accumulate in fatty tissues and are highly persistent, the major route of exposure to PCBs is through ingestion of contaminated food, particularly those sources at the top of the food chain (GBPSR 2000). The main dietary sources of PCBs are beef, pork, dairy products, and fish - especially sport-fish caught in contaminated lakes or rivers (ATSDR 2001). Figure 1 shows the levels of PCBs in the U.S. found in various food sources.

Figure 1. Measured levels of PCBs* in food samples collected in five regions in the U.S. (Schecter 2001). The abbreviation ppt refers to parts per trillion.

*Measurements are of total di-ortho PCBs, which are useful markers of total PCB contamination in human blood.

Children can also be exposed to PCBs as a result of current and/or past maternal exposures. PCBs and their metabolites can cross the placenta and expose the developing fetus (Soechitram et al. 2004). Infants are also exposed through breast milk (GBPSR 2000). Breast milk contains among the highest levels of PCBs of any human tissue because of the high fat content of the milk and lipophilicity of the PCBs. Nursing infants are exposed to a substantial portion of their total lifetime doses of PCBs during their first few months of life (GBPSR 2000). Researchers suggest that the best way to reduce maternal transfer of PCBs to the next generation is not to avoid breastfeeding, but rather through “enforcement of strict regulations for PCB and dioxin discharge and by reducing consumption of animal products and processed foods in all ages (Patandin 1999).”

Nationwide Exposure Data

Polychlorinated biphenyls readily concentrate in aquatic ecosystems, being taken up by smaller organisms and increasing at higher trophic levels in the food chain; as such, populations that consume fish from certain contaminated areas may be at an increased risk of exposure through ingestion (ATSDR, 2001). While PCB exposure is a concern in Michigan—due to contamination of the Great Lakes and numerous smaller lakes and rivers, the problem is one that affects the rest of the United States, as well. States retain the right and responsibility to issue fish advisories. (EPA 2007a). Over the last decade, states have been issuing an increasing number of PCB advisories as they acknowledge the potential threat PCB exposure may pose to human health. In 2005, state advisories for all contaminants covered 38% of the nation’s total lake acreage and 26% of its total river miles. Between 2004 and 2006, the number of locally-issued fish advisories due to risk of PCB contamination increased from 873 to 1,023 (EPA 2007a). Four states have statewide freshwater advisories for PCBs, and seven other states have PCB advisories for their coastal waters (EPA 2007a). Ten states added new advisories for PCBs in 2005 and 13 states in 2006 (EPA 2007b). Across the U.S. there were 4,652,648 lake acres and 118,904 river miles under advisory for PCBs in 2005, which increased to 4,699,936 lake acres and 132,228 river miles under advisory in only one year (EPA 2007b).

Monitoring contaminant concentrations in human fluids or tissues, such as blood or urine, can provide a useful snapshot of overall exposure in a population. Concentrations of PCBs in pregnant women have been declining since the ban in 1979 (Yang et al. 2009). However, certain PCBs were still detected in 99 to 100% of pregnant women in a recent study released in 2011 (Woodruff, 2011). Children also continue to have measurable levels of PCB’s in their bodies, and to be exposed to PCBs. In the Centers for Disease Control and Prevention (CDC) Third National Report on Human Exposure to Environmental Chemicals, PCBs were monitored in a representative sample of the US population (CDC 2005). The results suggest that children age 12-19 carry some PCBs in their bodies. Specifically, PCB 126 was detected in 10% of the 12-19 year-olds tested between 1999 and 2000 (CDC 2005). Multiple PCB congeners were found in children age 12-19 tested in 2001 and 2002 including: PCB 52 (10%), PCBs 138 &158 (10% each), PCB 153 (25%), and PCB 180 (10%) (CDC 2005).

Michigan Exposure Data

PCB contamination through the state is extensive. Based on data from the Michigan Department of Environmental Quality (MDEQ), PCBs have been found to be the most ubiquitous contaminant in Michigan’s waterways. Of 83 stream and river water samples collected from 58 locations throughout the state between 2002 and 2004, all but one sample exceeded the human health benchmark water value for PCB’s of 0.026 ng/L (as established by MDEQ’s Rule 57). The study results also indicate that all 97 Great Lakes connecting channel miles have elevated concentrations of PCBs in the water column (MDEQ 2006). These PCB levels contribute to the high number of fish deemed unfit for consumption in Michigan’s 140,000 acres of lakes or impoundment areas (MDEQ, 2006) PCB monitoring has also been conducted on 19,646 of Michigan’s perennial river miles; these data show that 100% of the monitored river miles do not meet the PCB Water Quality Standards (WQS) (MDEQ 2006).

Sediments are known to be a major PCB sink. Due to incomplete data, measurements of PCB quantities in Great Lakes sediments are unavailable. The EPA has noted the persistence of PCBs in Great Lakes sediments may continue to present a human health and ecological risk (EPA 2003).

Atmospheric deposition of PCBs plays a dominant role in how PCBs move through the Lake Michigan ecosystem. According to the Lake Michigan Mass Balance Study, atmospheric transport and deposition of PCBs contributed about 82% of the total PCB load to Lake Michigan (EPA 2000).

Due to the extensive contamination of Michigan’s waterways with PCBs, along with the highly persistent and lipophilic nature of the compounds, it is not surprising that there is also significant contamination of Michigan’s fish with PCBs, leading to the potential for human exposure in Michigan. Out of 189 water bodies listed in the 2007 Michigan Fish Advisory, 133 had species of fish contaminated with PCBs (MDCH 2007). The 2010 advisory showed a similar pattern (MDCH, 2010). These species include: bass, carp, catfish, suckers, trout, walleye, and others. For many of these contaminated species, the MDCH advisory suggests restrictions for women and children. For some fish, such as catfish or carp from the Kalamazoo River, there are advisories against anyone in the general population consuming the fish.

According to the 2005 Michigan Toxic Release Inventory (TRI) Summary Report, over 118,000 grams of PCBs were released in Michigan in 2005 (MDEQ 2005). This amount increased by more than 150% to almost 300,000 grams by 2006 (Table 2). In 2009, more than 700,000 pounds of PCB’s were sent to Michigan landfills (RTKN, 2009)

According to the MDEQ Part 201 Site List, there are 175 reported sites with PCB contamination in Michigan (MDEQ 2008). The sites are located throughout the state, in areas including Bay City, Flint, Kalamazoo, Jackson, and Detroit. For over 20 of these sites, no action had been taken yet to begin to address the contamination as of August 2009, and only 17 of the sites were undergoing remediation.

A large cohort study of Lake Michigan residents (enrolled in 1980) was conducted in order to determine whether there was an association between body burden of PCB’s and fish consumption from Lake Michigan fish. The cohort consisted of both fish eaters and non-fish eaters. Initial cohort enrollment was established between the years 1979-1982, just after the halt of mass production of PCBs in the US. Initial serum PCB levels were obtained and revealed much higher exposure levels for fish eating individuals (mean = 21.4 parts per billion) in comparison to non-fish eating individuals (mean = 6.6ppb) (Humphrey et al. 2000). This value is considerably higher than the more current general population PCB blood levels, which are in the range of 2-3 ppb (GBPSR 2000). The cohort was reevaluated between 1993-1995 and once again demonstrated significantly higher PCB exposure in the fish-eating individuals (mean serum PCB level was 14.26 ppb) than in non-fish eating individuals (mean serum PCB level of 4.56 ppb), with both groups having mean values of PCB blood levels higher than the general population. (Humphrey et al. 2000).

Fish Advisories

Given the ubiquity of PCB’s in Michigan’s environment, and the critical role that fish play in providing an exposure pathway, this section provides additional details on Michigan’s fish advisories.

The Michigan Department of Environmental Quality (MDEQ) Water Bureau completes an annual fish testing study to determine toxicant levels in various types of fish, and the Michigan Department of Community Health (MDCH) issues the advisories. For PCB’s the MDCH uses the Food & Drug Administration guidelines of 2.0 parts per million (ppm) PCBs for the general population. The MDCH advises the general population to eat no more than 1 meal per week when concentrations in more than 10% of the samples from a particular species of fish of a given length range exceed the trigger level. In addition, the MDCH advises the general population against eating any fish when concentrations in 50% or more of the samples exceed the trigger level (MFCMP 2006). For women of childbearing age and children under 15 years of age, they advise limits of one meal per week for fish with 0.05ppm PCBs, one meal per month of fish with 0.2ppm, six meals per year of fish with 1.0ppm, and no consumption of fish with PCB concentration of greater than, or equal to, 1.9ppm or more.

Despite the human health risks posed by elevated PCB levels in Michigan, Kory Groetsch, toxicologist at the MDCH, explains that "the MDCH currently spends zero state dollars toward toxicology and distribution of the Fish Advisory" (Groetsch 2008). However, using grant dollars, MDCH has been able to conduct some water body specific health education and outreach. “Each year approximately 40 water bodies (includes sections of rivers) are sampled. Typically two species per water, one top predator (walleye or smallmouth bass or northern pike) and one bottom feeder (typically carp)” Given the large number of lakes and rivers, and the importance of fish as a source of exposure in Michigan, greater testing in the waters of the State would likely be helpful. Further, some limited wild game testing near highly contaminated waters may also be useful.

Policy Summary and Analysis

Michigan Policy Highlights

1. The Michigan legislature established the “polychlorinated biphenyls contamination fund” to clean silos contaminated with PCBs (MCL § 288.454) but by statute, Michigan limits itself to federal regulations (as stated in the Toxic Substances Control Act) in PCB cleanup (MCL § 324.20120a).
2. Michigan’s $38 million fund for environmental cleanup and remediation programs was exhausted on Oct. 1 2008 without new funding sources. This fund provided financial support for PCB remediation, including the Michigan Department of Environmental Quality’s efforts in the Kalamazoo River to remove PCB contaminated soil (Kalamazoo Gazette 2008).
3. A plan to ask voters in 2008 to approve a $1.3 billion bond to clean up polluted sites failed. “Without bond money, the next largest source of funding for contaminated-site cleanups is unclaimed bottle deposits, which have provided about $10 million a year to the $95 million-a-year program” (Kalamazoo Gazette 2008). The Michigan Environmental Council hopes to place a 3/8 cent sales tax dedicated to environmental programs on the ballot in 2012 (UPI 2010). An EPA bankruptcy settlement with Millennium Holdings, LLC, resolves environmental liabilities at 23 sites and facilities nationwide, including Allied Paper/Portage Creek/Kalamazoo River Superfund Site (EPA 2010).

Analysis and Policy Highlights from Other States

1. While the primary focus of state remediation policy is requiring polluters to remediate sites of pollution through legal action, many states have statutorily established cleanup funds that include, or specifically deal with, remediation of PCB contamination (see Florida Statutes § 376.3071, Minnesota Statute § 123B.51, Ohio Revised Code § 3734.122, Oregon Revised Statutes § 466.045). Michigan did have a clean up fund that includes PCBs but that fund is defunct.
2. Minnesota requires all schools to develop PCB removal plans as part of their mandatory school health and safety plans (Minn. Stat. § 123B.57). Michigan does not have a policy to specifically address PCB contamination at schools.
3. Oregon’s Department of Environmental Quality is authorized to undertake PCB monitoring of hazardous waste generators and disposal sites, and Wisconsin authorized the Department of Natural Resources to develop regulations regarding analyzing PCBs and developing sites for their disposal (ORS § 466.195, Wis. Stat. § 299.45).
4. Iowa and Kansas include PCBs in their definition of “hazardous materials” that are exempt from a statute of limitations in civil suits, permitting those harmed by PCBs to take legal action against polluters (Iowa Code § 614.1,K.S.A. § 60-3303).
5. Maine and Minnesota are attempting to remove PCB containing capacitors and transformers from use (38 M.R.S. § 419-B, Minn. Stat. § 115A.9561)

Evaluation and Recommendations

The state legislature should provide the DEQ supplemental funding at the very least to allow the DEQ to continue with its clean-up efforts, especially in regard to PCB contaminated sites where this contamination poses a health threat. Lawmakers should also make a ballot proposal for DEQ funding a top priority. Michigan should consider legislation to expand the current PCB fund to include any contaminated area, not just silos. In addition, the state should consider better monitoring at disposal sites and removing remaining sources of PCB capacitors and transformers. The State should establish a goal of remediating PCB sites to the point that all fish advisories for PCB’s can be removed.

Michigan Policy Highlights

1. Michigan bans the disposal of PCBs (as defined by federal statute, 40 CFR section 761.3) in public landfills, as of 2004 (MCL § 324.11514). Previously, however, the disposal of solid or liquid waste resulting from the use of PCBs or any item with a PCB concentration of 100ppm or higher was prohibited, except when it complied with Michigan Department of Environmental Quality regulations (MCL § 324.14704).
2. Proposed legislation would ban the incineration of PCB containing materials. However, this legislation did not pass both chambers and is not law.

Analysis and Policy Highlights from Other States

1. States have instituted a number of mechanisms to deal with PCB disposal and management. A number of states (California, Connecticut, Maryland, and Texas) include PCBs in their statutory definition of “hazardous” materials or waste, which state agencies have wide latitude in regulating and remitting (Cal Health & Saf Code § 25122.7, Conn. Gen. Stat. § 22a-115, O.C.G.A. § 46-11-3, HEALTH-GENERAL Annoted Code of Maryland § 13-1501, § 260.396 R.S.Mo., Tex. Health & Safety Code § 361.003).
2. California bans the incineration of PCB-containing materials (Cal Health & Saf Code § 25208.4) while other states limit it or have notification requirements for PCB incinerating facilities (Conn. Gen. Stat. § 22a-469a, Idaho Code § 39-115, Burns Ind. Code Ann. § 13-17-10-1, Minn. Stat. § 116.38, N.C. Gen. Stat. § 14-284.2) and Minnesota requires monitoring emissions from PCB incineration facilities (Minn. Stat. § 116.84).
3. Many states have issued regulations regarding PCB disposal sites, the prevention of the recycling or the disposal of PCBs into the normal waste stream, or requirements for legal PCB disposal. New Jersey and Wisconsin restrict the disposal of dredged materials that contain PCBs (N.J. Stat. § 13:19-33, Wis. Stat. § 289.54). New Jersey prohibits dumping dredged material that contains PCBs into the Atlantic. Wisconsin allows for the disposal of lower-concentration PCB-contaminated dredged material in solid waste disposal facilities, but requires that a public meeting be held first to hear remarks from residents.New York requires the removal of PCB-containing capacitors before vehicles are crushed (NY CLS ECL § 27-2303).

Evaluation and Recommendations

Michigan has recently improved their PCB disposal policy by banning disposal in public landfills. However, to better protect Michigan’s children from possible PCB exposures, the state should enact a ban on the incineration of materials containing PCBs, Michigan should also pass stricter policies for PCB disposal and removal from capacitors.

Michigan Policy Highlights

1. The Michigan Department of Community Health (MDCH) issues a statewide fish consumption advisory (Michigan Family Fish Consumption Guide) for fish contaminated with PCBs and other toxins. The advisory extends to all five Great Lakes, Lake St. Clair, and most sampled rivers.
2. The Michigan Department of Agriculture (MDA) uses data from the MDEQ Water Bureau studies to regulate sale of commercial catch.

Analysis and Policy Highlights from Other States

1. Recent studies indicate that there are low levels of awareness about fish advisories among women of childbearing age (Park, Johnson 2006). In Michigan, there was very limited distribution of the 2010 Advisory, and funding to print and widely distribute this advisory has not been adequate or available for many years. Therefore, it is reasonable to conclude that many residents are not aware of the potential health risks from consumption of some fish. Currently, the advisory is distributed only on the MDCH website. Since 1999, the MDCH did not have funding to distribute the fish advisory with fishing licenses to sports fisherman, local public health departments, or pregnant women. Hard copies of the Fish Advisory dried up with funding after 2003. Formerly, the advisory was provided to each fishing license applicant. Access to the internet is required to view the advisory, and may not be available for many subsistence anglers. MDCH has done some outreach, beyond posting the advisory on its website, with grant funds from the U.S. EPA or CDC (Bohr 2008). Michigan should pursue policies that properly fund the Department to provide advisories to vulnerable populations, communities known to be regularly fishing, and fishing license applicants. The State should further require widespread distribution of the Advisory among health professionals, and also engage in public education campaigns about healthy fish consumption, especially among pregnant women, women of childbearing age, and children. Further, the State should post the advisories in appropriate languages at highly trafficked fishing spots where contamination is a concern.

Evaluation of the PCB Advisory

1. The advisory uses the same guidelines as the U.S. FDA (chlorinated organics), Great Lakes states, and the U.S. EPA (total PCB trigger) on limiting consumption of PCB contaminated fish.
2. The Fish Contaminant Monitoring Program, in their 2008 Annual Report found that PCB concentrations were equal to or higher than the trigger levels (in fish) for women and children in 15 out of 17 locations sampled (88%), and that the MDCH has issued advisories on only 13 of those 15 locations. The report found PCB levels higher than general population trigger levels in one location sampled. A general population advisory is present at that location. The FCMP recommends adding or expanding advisories at 7 sites and additional monitoring at 5 water bodies, while recommending easing advisories at 5 other sites (MFCMP 2008).

Evaluation and Recommendations

Michigan should pursue policy that requires widespread distribution of the Michigan Family Fish Consumption Guide in both print and electronic versions in a way that demonstrably reaches target populations. The State should also engage in public education campaigns about healthy fish consumption, especially among pregnant women, women of childbearing age, and children. The Michigan legislature should fully fund development and distribution of the advisory and testing of additional fish species, fish samples, and water bodies, and statutorily strengthen the guidelines for issuing advisories. In addition, the MFCMP should have adequate funding to begin testing dioxin-like PCBs (co-planer PCBs). This would double the cost of dioxin testing, but co-planer PCBs can almost double the effective concentrations of dioxin in fish species. The MDCH should also implement any FCMP recommendations that have not yet been implemented.

Summary of Recommendations for PCB Policy in Michigan

To reduce health hazards posed to children by exposure to PCBs, Michigan should strongly consider:

• Appropriation of more funds for the advisory. Funding would allow for updated toxicological information in the fish advisory and a better-informed trigger level for PCBs. This information has not been re-evaluated for at least 10 years because of a lack of funding.
• More widespread distribution of the advisory (Michigan Family Fish Consumption Guide), including distribution of printed copies to local public health departments, pregnant women, and sports fisherman at the time of receiving a fishing license.
• Public education campaigns about healthy fish consumption, especially among pregnant women, women of childbearing age, and children.
• Appropriation of funding to the MFCMP for testing of additional fish species, fish samples, and water bodies, and for testing of dioxin-like PCBs.
• Post advisories in appropriate languages at highly trafficked fishing spots where contamination is a concern.
• Expansion of the current PCB fund to include any contaminated area, not just silos.
• Better monitoring at disposal sites and removing remaining sources of PCB capacitors and transformers, mimicking efforts in Maine and Minnesota.
• Ban on the incineration of materials with PCBs as seen in California
• Stricter policies for PCB disposal and removal from capacitors, as seen in New York, New Jersey, and Wisconsin.

References

Agency for Toxic Substances and Disease Registry (ATSDR). Polychlorinated Biphenyls Fact Sheet. February 2001. http://www.atsdr.cdc.gov/tfacts17.pdf

Bohr, Joseph. Aquatic Biologist, Water Bureau, Michigan Dept. of Environmental Quality. Phone conversation with Genevieve Howe, July 31, 2008.

Center for Disease Control and Prevention, Dept. of Health and Human Services (CDC). Third National Report on Human Exposure to Environmental Chemicals. July, 2005.

Gladen BC, Rogan WJ. 1991. Effects of Perinatal Polychlorinated Biphenyls and Dichlorodiphenyl Dichloroethene on Later Development. Journal of Pediatrics 119:58-63.

Greater Boston Physicians for Social Responsibility (GBPSR). In Harm’s Way: Toxic Threats to Child Development. May, 2000.

Groetsch, Kory. 2008. Toxicologist of Michigan Department of Community Health. Email Correspondence between Kory Groetsch and Beth Kerwin. July 23, 2008.

Groetsch, Kory. 2008. Toxicologist, Michigan Department of Community Health. Phone conversation between Kory Groetsch and Beth Kerwin. April 29, 2008.

Humphrey H et al. 2000. PCB Congener Profile in Serum of Humans Consuming Great Lakes Fish. Environmental Health Perspectives 108:167-172.

Jacobson JL, Janisse J, Banerjee M, Jester J, Jacobson SW, Ager JW. 2002. Benchmark Dose Analysis of Prenatal Exposure to Polychlorinated Biphenyls. Environmental Health Perspectives 110:393-398.

Jacobson J, Jacobson S. 1996. Intellectual Impairment in Children Exposed to Polychlorinated Biphenyls In Utero. New England Journal of Medicine 335:783-9.

Kalamazoo Gazette. Michigan Department of Environmental Quality official says environmental cleanup bond lacks enough lawmaker support to be voted on this year. By, Alex Nixon. June 24, 2008. http://blog.mlive.com/kzgazette/2008/06/michigan_department_of_environ_3.html

Landrigan, Philip J., Maida Galvez, and Joel Forman. “Children’s Environmental Health.” Environmental Health: From Global to Local. Howard Frumkin Ed. San Francisco: Jossey Bass, 2005.

Lexis Nexis. Legislative Database.

Lonky E, Reihman J, Darvill T, et al. Neonatal behavioral assessment scale performance in humans influenced by maternal consumption of environmentally contaminated Lake Ontario fish. Journal of Great Lakes Research 22(2): 198-212.

Michigan Department of Environmental Quality (MDEQ). 2007 Toxic Chemical Release Inventory: Summary Report. www.michigan.gov/documents/.../deq-ess-tri-summaryrpt-07_266665_7.pdf

Michigan Department of Environmental Quality (MDEQ). 2006 Toxic Chemical Release Inventory: Summary Report. http://www.michigan.gov/documents/deq/deq-ess-tri-summaryrpt-06_217182_7.pdf.

Michigan Department of Environmental Quality (MDEQ). 2005 Toxic Chemical Release Inventory: Summary Report. www.michigan.gov/documents/deq/deq-ess-tri-summaryrpt-05_192281_7.pdf

Michigan Department of Environmental Quality (MDEQ), Water Bureau. Water Quality and Pollution Control in Michigan: 2006 Section 303(d) and 305(b) Integrated Report. February 2006. http://www.deq.state.mi.us/documents/deq-wb-integrated2006draft.pdf

Michigan Department of Environmental Quality (MDEQ). Part 201 Site List. 2008. http://www.deq.state.mi.us/part201ss/sites.jsp?qby=county&county=all&city=&pollutant=220&source=null&submit=Submit

Michigan Fish Contaminant Monitoring Program (MFCMP). 2008 FCMP Report. http://www.michigan.gov/deq/0,1607,7-135-3313_3686_3728-32393--,00.html accessed March 1, 2011.

Nadakavukaren, A. Our Global Environment: A Health Perspective. Fifth Edition. Waveland Press, Inc. Prospect Heights, Illinois. 2000.

Park, S. and M.A. Johnson. 2006. Awareness of Fish Advisories and Mercury Exposure in Women of Childbearing Age. Nutrition Reviews; (I)250–256.

Patandin S, Dagnelie PC, Mulder PGH, et al. 1999. Dietary exposure to polychlorinated biphenyls and dioxins from infancy until adulthood: A comparison between breast-feeding, toddler, and long-term exposure. Environmental Health Perspectives 107(1): 45-51.

Right to Know Network (RTKN). 2009. TRI Summary. http://www.rtknet.org/db/tri/tri.php?database=tri&reptype=f&reporting_year=2009&first_year_range=&last_year_range=&facility_name=&parent=&combined_name=&parent_duns=&facility_id=&city=&county=&state=MI&zip=&naics=&primall=&corechem=n&casno=001336363&casno2=&chemname=&detail=-1&datype=T&rsei=y&sortp=D&sum_expand=ABCNMHZP

Schecter A, Cramer P, Boggess K, Stanley J, Päpke O, Olson J, Silver A, Schmitz M. 2001. Intake of dioxins and related compounds from food in the U.S. population. Journal of Toxicology and Environmental Health Part A 63(1):1-18.

Soechitram SD, Athanasiadou M, Hovander L, et al. 2004. Fetal exposure to PCBs and their hydroxylated metabolites in a Dutch cohort. Environmental Health Perspectives 112(11): 1208-1212.

Tilson HA, Jacobson JL, Rogan WJ. 1990. Polychlorinated biphenyls and the developing nervous system: cross-species comparisons. Neurology and Teratology 12:239-248.

United States Environmental Protection Agency (EPA). 2010. Department of Justice, EPA Reach Bankruptcy Settlement with Lyondell. www.epa.gov/region5/sites/kalproject/pdfs/kalproject_fs_201005.pdf

United States Environmental Protection Agency (EPA). 2009. Region 4 Superfund. Allied Paper/Portage Creek/Kalamazoo River.

http://www.epa.gov/R5Super/npl/michigan/MID006007306.htm.

United States Environmental Protection Agency (EPA). 2007a. National Listing of Fish Advisories General Fact Sheet: 2005/06 National Listing. http://www.epa.gov/waterscience/fish/advisories/2006/index.html.

United States Environmental Protection Agency (EPA). 2007b. National Listing of Fish Advisories Technical Fact Sheet: 2005/06 National Listing. http://www.epa.gov/waterscience/fish/advisories/2006/tech.html.

United States Environmental Protection Agency (EPA). 2000. Lake Michigan Lakewide Management Plan. Chapter 5: Lake Michigan Stressor Sources and Loads. chapter 5.pdf http://www.epa.gov/lakemich/lmlamp2000/LM%20chapter%205.pdf.

United States Environmental Protection Agency (EPA). 2003. Post Remediation Sediment Sampling On the Raisin River Near Monroe, Michigan Final Results from 2001-2002 Survey: PCB Chemistry, Caged Fished and Bioaccumulation Results. http://www.epa.gov/glnpo/sediment/raisin/index.html

United Press International (UPI). 2010. Michigan’s Toxic Cleanup Funds Dwindling. http://www.upi.com/Top_News/US/2010/12/12/Michigans-toxic-cleanup-funds-dwindling/UPI-91631292196655/

Woodruff TJ, Zota AR, Schwartz JM 2011. Environmental Chemicals in Pregnant

Women in the US: NHANES 2003-2004. Environ Health Perspect doi:10.1289/ehp.1002727

Received: 15 July 2010; Accepted: 10 January 2011; Online: 14 January 2011

Yang RY, Jain RB, Wolkin AF, et al. Serum concentrations of selected persistent organic pollutants in a sample of pregnant females and changes in theri concentration during gestation. Environmental Health Perspectives 177:1244-1249.

Yu M, Hsu C, Gladen BC, Rogan WJ. 1991. In utero PCB/PCDF exposure: relation of developmental delay to dysmorphology and dose. Neurology and Teratology 13:195-202.