Over the past few years, the International Joint Commission (IJC) has implemented its new approach, adopted in April 1996, toward Annex 2, Remedial Action Plan (RAP) and Lakewide Management Plan (LaMP) activities. A principal component of this approach involves proactively conducting Status Assessments to evaluate progress under Annex 2 of the Great Lakes Water Quality Agreement (GLWQA). This evaluation tool allows the IJC to more effectively fulfill its role of reviewing progress and assisting in implementing the GLWQA without waiting for RAPs or LaMPs to be submitted by the Parties for review and comment. Two Status Assessments-the Detroit River Area of Concern (AOC) and the St. Marys River AOC-were completed within the 1997-99 priority cycle. Findings from these Status Assessments and other initiatives are presented below.
Human Health Considerations in Lakewide Management Plans and Remedial Action Plans
One of the principal requirements of any Stage 1 LaMP for Critical Pollutants is the definition of the threat to human health or aquatic life. Toward this and other needs, major research efforts funded largely by the Agency for Toxic Substances and Disease Registry and Health Canada have been conducted in the Great Lakes basin. Table 1 outlines findings from ten such studies that have been conducted in the Basin. Accordingly, considerable data exist to define the threat to human health posed by the exposure to Critical Pollutants through the consumption of environmentally contaminated Great Lakes fish or wildlife. For additional information on defining the threat to human health see the Indicators Section on fish consumption advisories and the Science Advisory Board (SAB) section on LaMPs.
As a basis for addressing this issue, LaMPs need to identify and assess the extent of human populations in their basins that are particularly susceptible to health risks from toxic substances and initiate measures to alleviate those risks that fall within the purview of LaMPs. In its review of the Stage 1 Lake Superior LaMP [http://www.ijc.org/php/publications/html/lslamp.html], the IJC (1996) notes "few data are presented linking exposure to specific Critical Pollutants to threats to human health . . ." The IJC, in its review comments on this Stage 1 LaMP further states "The document submitted to the Commission relied heavily on information available from previously published RAPs, which by definition, do not focus on open lake waters . . . most RAPs, to date, have not focused explicitly on human health concerns and as a result neither does the Stage 1 Lake Superior LaMP." For reasons which remain unclear, a primary LaMP requirement [definition of the threat to human health . . .] outlined in Annex 2 of the GLWQA remains unmet for the Lake Superior LaMP. In its Ninth Biennial Report on Great Lakes Water Quality (IJC 1998a), the IJC notes "Although one LaMP requirement is to define the threat to human health posed by Critical Pollutants, in the more than six years of LaMP development this generally has not yet occurred."
The lack of data in regard to the implications of persistent toxic substances on human health has also been a concern in the RAP process. In the report (IJC 1998b) Beacons of Light: Successful
| Lake Michigan fisheaters cohort | PCB levels in breast milk and maternal serum correlate with consumption of contaminated fish. | Humphrey 1983 |
| Native Americans (Mohawk) in New York State | Mean serum PCB levels in men was 5.4 parts ppb (max. 31.7 ppb), versus 5-7.7 ppb in the general population (Jensen 1989). Serum PCB levels were positively related to the number of fish meals consumed per year and increasing age. | Fitzgerald et al. 1996 |
| Elderly cohort of Lake Michigan sport anglers | PCBs, DDE, and mercury levels were significantly higher in high fisheaters. High fisheaters presented disproportionately higher body burden levels of PCBs and DDE than low fisheaters in each age group, i.e., 50-59, 60-69. | Schantz et al. 1996 |
| Pregnant women who consumed Lake Ontario fish | Women in the high-fish-consumption group ate an average of 2.3 salmon or trout meals per month for an average of 16 years. | Lonky et al. 1996 |
| Pregnant African-American women who consumed Lake Michigan fish | Women were exposed to PTSs via fish consumption during most of their reproductive years. Seventy-five percent were less than 26 years of age and consumed lake fish for more than 15 years. | Waller et al. 1996 |
| Reproductive age (18-34) Lake Michigan sport anglers | Approximately 50% ate 1 to 12 sport-caught meals in the past year, and 20% consumed 13 to 24 meals. Fish consumption was greater in males than females, with some males consuming 49 or more fish meals per year. | Courval et al. 1996 |
| Charter boat captains, their spouses, and Great Lakes anglers | Serum levels of dioxin, furans, and coplanar PCBs vary by gender, and fish species predict coplanar PCBs and furan body burden levels but not dioxin. | Falk et al. 1997 |
| Asian origin sport anglers on the St. Lawrence River | Bangledeshi fisheaters consumed an average 46.8 sport fish meals and Vietnamese fisheaters ate 40.7 meals, considerably less than the average 57 sport fish meals eaten annually by native Quebecers. | Shatenstein et al. 1997 |
| 3,751 individuals from five Canadian Great Lakes Areas of Concern (AOC) | Individuals are consuming species for which local guidelines do not exist, preparing fish in different ways, and eating fish more frequently than in current recommended guidelines. | Cole et al. 1997 |
| Canadian fishermen from the St. Lawrence River basin | Mercury intake exceeded acceptable daily doses for the most contaminated fish species. PCBs estimated intake was 10 to 100 times lower than the daily acceptable dose. | Gauvin et al. 1997 |
Adapted from Johnson et al. 1998.
Strategies Toward Restoration in AOCs [http://www.ijc.org/php/publications/html/beacon/beacon.html], the IJC comments that it is important to place cleanup costs in perspective by better defining the health benefits that can be derived from the remediation of contaminated sediment. The IJC recommends "human health information being developed for LaMPs be incorporated as appropriate into the RAP development process." It is noted that this information should provide considerable justification for many needed remedial actions. Of particular concern, to the IJC, are susceptible human populations consuming sport-caught fish within various AOCs. For example, the Status Assessment (IJC 1999) of restoration efforts in the St. Marys River Area of Concern [http://www.ijc.org/php/publications/html/stmarys/status.html] states "While undertaking this status assessment, the IJC found no evidence of specific outreach [communication] programs directed at the most impacted subset of the AOC's population, the Native American/First Nation population."
In its review of the Nipigon Bay Stage 2 RAP (IJC 1998c) [http://www.ijc.org/php/publications/html/nipigon/stage2rev.html], the IJC states "The Stage 2 RAP does not evaluate the benefits that would be derived by First Nations from the restoration and protection of the beneficial uses that historically existed, including a range of economic and health implications." In the case of the Nipigon Bay RAP, no discussion of consequences to the First Nations' fishers who were historically dependent on the now impaired fishery [impaired through loss of habitat and degraded fish populations] is provided. Thus, it will be difficult if not impossible to discern any benefits that may accrue to First Nations through restoration of the fish population. If benefits are not readily visible, it is difficult to justify aggressive and costly remedial activities. The lack of suitable information precludes a reasoned choice from among the alternative actions that are available for possible implementation. This difficulty does not, however, mean that economically significant impacts to the human and natural environment have not occurred.
The IJC and its SAB have applied considerable resources and efforts toward enhancing LaMP and RAP personnel's access to pertinent information on the human health effects of consuming environmentally contaminated Great Lakes fish [see SAB discussion. These efforts have included a September 1997 workshop conducted in Cleveland, Ohio and a February 1999 SAB meeting held in Windsor, Ontario. To date, LaMPs have not adequately identified susceptible human populations in their respective lake basins. As a result, the threat to human health posed by Critical Pollutants has not been well defined in any LaMP. Consequently, despite numerous relevant studies, limited human health information exists in LaMPs that can incorporated, as previously recommended by the IJC, into RAPs. If available, this information would serve to better justify remedial activities in AOC restoration efforts and to better identify and inform susceptible populations.
Suitable Comparison of Remedial Options in AOCs
The failure to identify susceptible human populations has made it difficult for RAP participants to discern human health risks that exist due to the consumption of environmentally contaminated fish. Hence, it is difficult to perceive benefits that may be derived from reducing these risks through remediation of contaminated sediment [see Water Quality Board discussion], a major contributor to the environmental contamination of Great Lakes' fish. This information should be considered important regarding the selection of appropriate remedial strategies, including the recognition that active mitigation measures may be required. Otherwise, it may be easier to accept a no or low-cost [caretaker] approach to remediation. Flawed decision-making could result from the failure to examine a full range of possible alternative actions or the failure to define environmental benefits including the enhancement of human health conditions foregone through selection of a no- remediation alternative.
In an era of Parties' funding and program cutbacks, there exists an institutional preference for the no or low-cost [caretaker] alternative. Alternative plans should be formulated in a systematic manner in order to assure public consultation and selection of the most desired action. Usually, a number of alternatives can be identified early in the planning process and become more refined through additional development and subsequent iterations (U.S. Water Resources Council 1983). An interdisciplinary approach including, as needed, human health professionals is necessary to ensure that possible alternative actions can adequately address previously defined environmental problems. To date, human health benefits and human health benefits foregone in the case of no-remediation alternatives have not been adequately addressed. This is particularly true in the cases of AOCs with existing contaminated sediment problems but with no obvious funding mechanisms.
Public Consultation and Participation
Public consultation is an ongoing requirement in regard to actions taken pursuant to Annex 2 of the GLWQA. This requirement is not reduced once the Parties begin the selection and implementation of appropriate remedial actions. On the contrary, engaging the knowledgeable public in this ongoing process can enhance the timely implementation of locally-acceptable remediation alternatives. Public acceptance of planned remedial measures including the no-cost [caretaker] alternative is critical to the viability of any selected action. In particular, consultation with the more susceptible subset of the population is necessary before any proposed action can be judged acceptable. In some cases, such as the Nipigon Bay AOC, this needed consultation does not appear to be occurring.
The Status Assessment (IJC 1997a) of the Detroit River Area of Concern also notes [http://www.ijc.org/php/publications/html/detroit.html] this problem of inadequate citizen involvement and consultation, to the detriment of progress under the RAP and the required public commitment to it. The status assessment states "There is too little public awareness or acceptance of the need to restore uses in the Detroit River." The St. Marys River Status Assessment likewise examines public consultation concerns and determines "Numerous lead agency staffing changes and an apparent lack of oversight have contributed to problems regarding consultation with the public." The IJC recommends "Give immediate priority to revitalizing public consultation activities in the AOC . . . with a view to generating and sustaining community understanding and support of the goals for AOC restoration." The IJC (1997b) [http://www.ijc.org/php/publications/html/21ste.htm] notes "U.S. and Canadian citizens have come to expect an opportunity to speak and to be heard . . . the parties will be challenged to develop and employ mechanisms that provide for meaningful public participation." Nowhere is this more true than in the ongoing RAP and LaMP implementation efforts.
References
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