Our mission is to protect the habitat of Puget Sound tidelands from the underregulated expansion of new and intensive shellfish aquaculture methods. These methods were never anticipated when the Shoreline Management Act was passed. They are transforming the natural tideland ecosystems in Puget Sound and are resulting in a fractured shoreline habitat. In South Puget Sound much of this has been done with few if any meaningful shoreline permits and with limited public input. It is exactly what the Shoreline Management Act was intended to prevent.

Get involved and contact your elected officials to let them you do not support aquaculture's industrial transformation of Puget Sound's tidelands.

Governor Inslee:

Tuesday, February 16, 2016

WDFW Investigation Reveals Contaminants Filtered and Retained by Shellfish in Puget Sound

What is filtered and retained by
Puget Sound's filter feeders?
"long-banned pesticides, flame retardants, toxic metals
 and other human-caused contaminants
are creeping into all parts of Puget Sound."
"one oyster, one mussel, one bite of fish at a time"
Washington's Department of Fish and Wildlife's (WDFW) continues to expand awareness of pollutants in Puget Sound's waters in an expanded program with results first published in the 2011/2012 Mussel Watch Phase 1". As it was noted in the 2012 Quality Assurance Plan:
"... expanded spatial distribution and additional mussel monitoring sites are needed to address regional questions regarding the fate, transport, and effects of chemical contaminants in the Puget Sound’s nearshore urbanized waters." 
(sample locations from 
2/19/2013 progress report)

Did I want to know that?
Building on the 2010/2011 Mussel Watch program, the implementation of the expanded program was designed to create a "...more regionally-focused, nearshore contaminant status and trends monitoring program in Puget Sound." While current results will not be known until 2017, program implementation results from 2012 were reported by WDFW in 2013. In that "Field Summary and Progress Report", four highly carcinogenic compounds (PAHs, PCBs, PBDEs, and DDTs) were found in mussels tested. As would be expected, the highest levels were found in the most urbanized areas (Elliott Bay, Salmon Bay, Commencement Bay, and Sinclair Inlet near Bremerton). However, as the Puget Soundkeeper noted in November:
"All four carcinogens were found in every mussel sample, regardless of location."

 ""I don't eat shellfish anymore," [Maradel Gale said.
"Not since I've been doing this."

There's more carried by the tides throughout the Puget Sound basin than algae and bacteria.
While current agency programs attempt to limit illnesses contracted from naturally occurring bacteria (e.g., various strains of vibrio) and naturally occurring toxic algae (e.g., diatoms producing domoic acid), there has not been a long term program tracking industrial pollutants in the nearshore environment where shellfish are harvested from and eaten. Chemicals entering Puget Sound's waters, through urban runoff and industrial activities, both current or past, exist throughout the basin being filtered and retained by shellfish. And as was noted in the Kitsap Sun article:
[Agencies] don't routinely test for metals, petroleum hydrocarbons and other substances that cause problems slowly, accumulating in the body in low dosages. 

Meanwhile, down on the farm the Department Of Ecology, EPA moves to impose water quality rules DOE cannot
Tribal rights include “..not only a right to take those fish, but necessarily include an attendant right to not be exposed to unacceptable health risks by consuming those fish.” (from EPA's 9/14/2015 proposed rule, part III. Necessity Determination for Washington)
At the same time as WDFW is reporting carcinogens in mussels tested throughout Puget Sound, the Department of Ecology is in a tug-of-war with the Environmental Protection Agency over what the average amount of seafood consumed is and what should be tested. After years of being unable to determine what the average amount of seafood consumed per day should be and what should be tested, the EPA told the Department of Ecology it had waited long enough and was now developing rules which DOE was unable or unwilling to, publishing in the Federal Register, September 4, 2015, the proposed rules. As far back as 2013 the EPA was telling DOE it was concerned about its lack of progress, writing in a letter dated June 21, 2013:
"The best available science includes evidence of consumption rates well above 6.5 grams per day among high fish consumers and shows that the human health criteria currently currently in effect for Clean Water Act purposes in Washington are not sufficiently protective."
Father knows best. He just can't make up his mind.
In a letter from tribal members to the EPA regarding DOE's lack of motivation, they wrote as recently as December 23, 2015, to encourage the EPA to do what DOE was unable or unwilling to, saying:
"The state of Washington has avoided, deferred, and delayed adoption of revised water quality standards that would safeguard public health for high fish consuming groups including tribes. The state has attempted to trade off a more protective fish consumption rate [175 g/day] for a less protective standard [6.5 g/day]  for cancer risk. EPA has given the state multiple opportunities to develop and adopt revised human health criteria. We have no confidence that the state of Washington will adopt more protective water quality standards in the next 12 months, if at all, and urge you to promulgate the EPA’s proposed rule without further delay."
Trust us - we know better than the EPA what's good for the state. Did Flint, Michigan?
"Ecology is in the best position to develop human health criteria (HHC) for the state of Washington." DOE to EPA, December 2015
It was not until February 3 DOE agreed fish consumption rate assumptions were too low and called for comments on new water quality standards. However, they noted they did not agree with EPA on standards for industrial pollutants or time frames to control discharges, stating on their website calling for comments:
"EPA's draft rule [being imposed on the state due to inaction] contains stringent limits for PCBs and arsenic, and adds a new limit for methyl mercury that will be difficult for Washington dischargers to meet. Our new draft rule would maintain the current standards, as proposed in our initial rule, for PCBs. Criteria for mercury would remain under federal regulation. Arsenic would align with the federal Safe Drinking Water Act standard." [fish consumption rates were raised to 175 g/day]
Do you really want to know?

In the end shellfish are only as safe to eat as the regulations you make controlling what flows into the water and they filter out of it.
Puget Sound's waters are a state-wide treasure. Seafood taken from Puget Sound, whether shellfish or fish, should be safe to eat in both the short and long term, and consumption rates safety is based off of should be realistic. The EPA has told Washington their regulations are weak. Results from the Mussel Watch program confirm mussels - and all other filter feeders - retain what is being discharged into those waters. Those chemicals are not being adequately monitored in seafood consumed and DOE has agreed their assumed consumption levels are far below what it should be, but does not want to implement new regulations any time soon. Until the state finds the political will to act, Ms. Gale's advice on not eating shellfish harvested from Puget Sound is something for everyone to consider.

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