Search

Abstract: Buchanan et al. assert that our recent fish ingestion risk assessment for a section of the Lower Passaic River (LPR) (Urban et al., 2009) utilizes inappropriate ingestion rates and is inconsistent with state and USEPA guidelines and risk assessment procedures, and therefore underestimates the human health risks associated with angler exposure along this stretch of the river. However, they fail to support these assertions with evidence; indeed, in a recent response to similar allegations, we demonstrated that the utilized ingestion rates are, in fact, the most appropriate for this parameter (Urban et al., 2010). Our reliance on data from a comprehensive, independently validated, peer-reviewed, and site-specific creel angler survey (CAS) in order to define fish and crab ingestion rates for this region of the LPR is fully compliant with USEPA guidelines. In fact, the crab ingestion survey and risk assessment cited by Buchanan et al. as evidence of crabbing activity and crab ingestion for this region was less comprehensive than the CAS in question, was not overseen by an independent panel, has yet to be peer-reviewed, and does not provide any activity or consumption data for this section of the LPR. Contrary to the implications of Buchanan et al., our effort provides a transparent, comprehensive, and scientifically legitimate human health risk assessment of fish ingestion for the lowest 6miles of the LPR. Thus we adamantly disagree with the characterization and assertions put forth by Buchanan et al., and stand by the conclusions presented in Urban et al. (2009) and defended in Urban et al. (2010). [Copyright &y& Elsevier]

Abstract: Mugdan et al. have criticized certain aspects of the approach and general conclusions of our recently published fish ingestion risk assessment for the lower Passaic River (Urban et al., 2009), asserting that they are inconsistent with the United States Environmental Protection Agency''s risk assessment guidelines we reference in our paper. Specifically, they assert that the excess cancer risk and health hazard results calculated as a part of our analyses underestimate the potential health risk posed to lower Passaic River anglers who actually consume their catch due to the fish ingestion rates we utilized in our analysis and our lack of inclusion of a crab ingestion pathway. While there clearly are differences between our risk assessment and the one conducted by the USEPA, this is not at all surprising given that their assessment reflects a typical screening-level risk assessment while that described in our paper reflects a more detailed site-specific risk assessment. In developing our exposure scenarios and assumptions, we considered and incorporated the available site-specific information in both deterministic and probabilistic quantitative risk frameworks in an effort to provide a sound and realistic human health risk assessment that quantitatively accounts for much of the variability and uncertainty typically inherent in such estimates. Although it is understandable that Mugdan et al. are compelled to defend the effort and conclusions put forth by USEPA Region 2 in its 2007 draft human health risk assessment of the lower Passaic River, the site-specific lower Passaic River human health risk assessment presented in Urban et al. (2009) was conducted according to USEPA guidelines, underwent peer review, and is, in fact, consistent with Superfund guidance and accepted principles of risk assessment. [Copyright &y& Elsevier]

Abstract: presented a human health risk assessment for the Lower Passaic River that very narrowly defines fish consumption, ignores crab consumption, and is not consistent with current NJ or EPA risk assessment procedures and guidance. The restrictively defined consumption then leads to inappropriate conclusions on the risk of eating fish from this highly contaminated estuarine river. The paper underestimates angler exposure to contaminated fish, does not evaluate exposure to contaminated crab, and underestimates the cancer risks and non-cancer health hazards associated with these exposure pathways. The New Jersey Department of Environmental Protection along with the NJ Department of Health and Senior Services issues fish and crab consumption advisories for all state waters; these advisories should be followed for the Passaic River and surrounding waters: http://www.state.nj.us/dep/dsr/FishSmartEatSmartNJ.org. [Copyright &y& Elsevier]

Abstract: presented a human health risk assessment for the Lower Passaic River that is not consistent with the United States Environmental Protection Agency (USEPA) risk assessment guidance for Superfund cited in the article, because it is based on a fish ingestion rate that underestimates angler exposure to contaminated fish, does not evaluate exposure to contaminated crab, and underestimates the cancer risks and non-cancer health hazards associated with these exposure pathways. USEPA recommends that people follow the health advisories for the Lower Passaic River, available online at http://www.state.nj.us/dep/dsr/2009FishAdvisoryBrochure.pdf. [Copyright &y& Elsevier]