Water Resources

Lummi Seafood Consumption Study

Lummi Seafood Consumption Study

The Water Resources Division conducted the Lummi Seafood Consumption Study in 2012 to quantify the amount of seafood that is eaten by enrolled members of the Lummi Nation. This study was conducted with the anticipation that the results would be used to support the development of water quality standards for both the Lummi Nation and Washington State. Fish consumption is one variable used to develop human health-based water quality criteria/standards that are adopted by tribal and state governments under the Clean Water Act. The amount of fish and shellfish (seafood) consumed represents the exposure to toxins and therefore the risk to human health.

Pursuant to Section 518 of the CWA, the Lummi Nation applied to the Environmental Protection Agency (EPA) for eligibility to administer the water quality standards program in March 1995. The EPA determined the Lummi Nation's eligibility to administer the water quality standards program in March 2007. The Lummi tribal water quality standards were approved by the Lummi Nation in August 2007 and by the EPA in September 2008. These adopted and approved standards are based on a fish consumption rate of 142.4 grams per person per day, which was the EPA default value for subsistence communities.

Until November 2016, the Washington State water quality standards were based in part on a fish consumption rate of 6.5 grams/day. In 2016, the EPA issued a final rule (link to fact sheet and/or federal register notice) revising certain federal human health criteria that were devised in part by including an increased fish consumption rate of 175 g/day. This rate accounts for local data, reflects input from tribes in Washington, and protects fish consumers downstream in Oregon, where the state has also used a FCR of 175 g/day to derive its human health criteria.

The 2012 Lummi Seafood Consumption Study resulted in an average Lummi seafood consumption rate of 4.73 grams per kilogram per day (g/kg/day) or approximately 383 grams per day (g/day) (0.84 pounds per day [lb/day] or 13.5 ounces per day [oz/day]) for all seafood consumed. The Lummi Nation has begun a review of its water quality standards that is targeted for completion in 2017 and will be using the results of this survey and the EPA final rule for the review and any updates.

The report and associated documents are available in Available Documents.

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Available Documents

There are 10 documents currently available in the Lummi Seafood Consumption Study portion of the website.