Exposed: Asking the Wrong Question in Risk Regulation

Catherine A. O’Neill.

Back in 1973, the tuna industry wanted to know how much fish Americans were eating. After asking 7,662 households to record their daily fish intake, the answer came back: people ate fish, but not very often—about once a month. While tuna purveyors mulled what to do with this information, the U.S. Environmental Protection Agency (EPA) borrowed their dataset. EPA used these data to derive a key variable in the equation for calculating people’s exposure to toxic contaminants in the nation’s waters: the fish consumption rate (FCR). This FCR served as the premise for EPA’s initial volley of water quality criteria in 1980 and, subsequently, for water quality standards across the nation. Even today, several states’ water quality standards are based on this FCR, which assumes that people eat just 6.5 grams of fish per day. That Americans’ fish consumption habits in the early 1970s continue to undergird environmental standards today is remarkable. Families in Washington, Idaho, and Alaska that put fish on the dinner table more than once a month still do so at their peril. Of greater consequence, however, is that EPA’s early attempts to ascertain people’s practices became the template for its reigning method of exposure assessment. This method, however, focuses on the wrong question.

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