Examining Fish Consumption Advisories Related to Mercury Contamination in Canada
Prepared by: MaryEllen Wood and Luke Trip, Environment Canada,
351 St Joseph Blvd, Hull, Quebec, K1A 0H3
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Summary
The purpose of this report is to examine the procedures taken by the federal, provincial, and territorial governments when issuing fish consumption advisories with a focus on mercury contaminants. Mercury contamination in fish is a concern because it is a toxic substance that bioaccumulates in the fish tissue. This is a concern for humans who consume fish on a regular basis because elevated levels of mercury in fish tissue may have serious implications on human health, especially for the development of unborn and young children.
The findings of this report clearly indicate that there is not a consistent and uniform procedure for assessing, addressing and maintaining fish consumption advisories. The procedures taken within each province differ between all ten provinces, along with different procedures for the territories. The affected federal departments also have their own procedures for dealing with contaminant consumption advisories.
Although fish is an important part of a nutritional diet, there are also possible negative effects on human health when consumption exceeds recommended guidelines. Therefore, it is surprising that inconsistencies exist on issuing fish consumption advisories. A recommendation for this problem is to establish a consistent and uniform methodology which each province and territory along with affected federal departments can undertake when assessing and issuing fish consumption advisories. Such a program could be initiated through the establishment of a federal/provincial/territorial fish consumption advisory working group, perhaps established under the auspices of the Canadian Council of Ministers of the Environment.
Table of Contents
1.0 Introduction
2.0 Procedure for Issuing Fish Consumption Advisories
- 2.1 Fish Monitoring and Testing
- 2.2 Responsibilities
- 2.3 Issuing Advisories and Informing the Public
3.0 Provincial and Federal Procedures in Issuing Fish Consumption Advisories
- British Columbia
- Alberta
- Saskatchewan
- Manitoba
- Ontario
- Quebec
- New Brunswick
- Nova Scotia
- Prince Edward Island
- Newfoundland
- Yukon Territory
- Northwest Territories
- Nunavut
- Health Canada
- Indian and Northern Affairs Canada
- Canadian Food Inspection Agency
4.0 Conclusions
5.0 Recommendations
6.0 References
Canada is renowned for its many clean and pristine lakes and rivers which attract local and recreational fishers to enjoy and consume the many fish species they catch. There is a growing concern that the fish in many of these lakes and rivers have been exposed to elevated levels of mercury. Mercury is a natural occurring element in the environment. Levels of mercury pollution have however increased since industrialization through increased human activities. The problem with elevated mercury levels is that mercury is a toxic substance, and exposure to increasing levels may cause serious health problems. Human health concerns range (for example) from acute mercury poisoning causing nausea, numbness, and tunnel vision to chronic exposure which can lead to neuro behavioral changes, and learning difficulties.
The concern for fish is that mercury entering the environment can be converted to methylmercury, a highly toxic, persistent and bioavailable form. It is easily taken up by small organisms like plankton and algae, which are then consumed by the next trophic level in the food chain. These toxic levels bioaccumulate in the fish tissue as the fish ages and consumes more fish and ultimately affecting human health when fishers catch and eat their fish. Methylmercury takes a relatively long time to be eliminated so affected fish attain toxic levels.
In order to prevent high levels of exposure to mercury the federal, provincial and territorial governments have placed fish consumption advisories on individual species, lakes and in some cases on entire regions. The objective of this report is to describe how these fish consumption advisories are established across the county and how are they issued to the public. This report creates a summary document of all the federal, provincial, and territorial roles, responsibilities and procedures related to fish advisories and in particular those advisories dealing with mercury contaminants. This report will examine whether fish monitoring and testing programs exist, who is responsible for the program, who issues the advisories and how the public is informed about this advisories. As well, specific recommendations are made based on the findings described above.
The actual monitoring and testing for contaminants in fish is usually done at the provincial level. There are numerous government departments who share in the responsibility for fish consumption advisories. These departments follow acts and regulations set by federal and provincial governments. The federal government relays the policies and regulations to the provinces, who implement and work at the appropriate levels to monitor and test for contaminants. Specific fish monitoring and testing programs for mercury currently exist in some provinces while others have had testing done in the past, but are not now engaged in a routine program. In some provinces the industries conduct the testing, and submit their findings to the appropriate provincial department for assessment. There is a growing trend to utilize independent researchers, either hired by a provincial department or an industry representative studying on their own, to perform the monitoring and testing of contaminants in fish.
The Canadian government has established a process that involves its own key stakeholders, in this case its Health Canada, Indian and Northern Affairs Canada, the Canadian Food Inspection Agency, Fisheries and Oceans Canada and Environment Canada. They all follow established roles which are set out by acts, regulations or departmental mandates. Health Canada has a strong role in fish consumption advisories because it establishes the standards for the amount of mercury that humans may consume without adverse health effects. Indian and Northern Affairs Canada has a significant role in overseeing that the northern communities of Canada are aware of the health hazards of consuming traditional foods which may have higher levels of mercury. The Canadian Food Inspection Agency, an autonomous regulatory body responsible to Agriculture and Agri-Food Canada, deals with the commercial inspections of fish products before they are sold on the Canadian market. Fisheries and Oceans Canada has given the responsibility to maintain the inland fisheries to the provinces.
The provinces have the responsible to perform monitoring and testing programs which include collecting fish samples from a variety of lakes and rivers, analyzing the fish samples for contaminants, issuing fish consumption advisories if needed and informing the public of these advisories. Responsible provincial departments include health, environment and fisheries. As mentioned early some provinces have given the responsibility to the industry to collect and analyze the fish samples. Provincial departments are to be notified by the industry with the results if contaminant levels indicate a health concern maybe in question. Provincial departments are not alone in turning to industry for assistance. The Canadian Food Inspection also places the responsibility upon the industry to analyze contaminant levels in fish. CFIA does perform routine audits of industries, their roles and responsibilities are further described later in this report.
Health Canada has made recommendations for fish consumption relating to mercury levels. Using these recommended guidelines, most provinces have established their own fish consumption guidelines which maybe published through their provincial angler guides. Throughout Canada the responsibility for issuing an advisory differs by jurisdiction. In some provinces it is the health department, others it is the department of environment. Most often the provincial department that issues the advisory is also responsible for informing the public. There are annual publications by some provinces which have routine testing, and other provinces which have conducted testing in the past resulting in an advisory which still remains in effect. In the territories, Health Canada usually issues an advisory, but the local health department is responsible for communicating the concerns to the affected community.
The following pages include flow charts and descriptions of each of the responsible agencies showing the procedures taken for issuing a fish consumption advisory.
In the province of British Columbia there are a variety of agencies and sources of information on contaminants which generate fish consumption advisories or other fish harvesting restrictions. While there is a specific program in place for assessing Dioxin/Furan levels in fish at B.C.'s coastal pulp mills, there is no general program to assess contaminant levels in the many lakes and streams of B.C. If mercury were determined to be a problem, similar steps would be followed as outlined in the flow chart. Currently, there are three mercury consumption warnings published in the 2000-2001 Freshwater Sport Fisheries Regulations Synopsis (B.C. Fisheries). These warnings are for mercury levels in bull trout and Dolly Varden from Williston Lake and in lake trout from Pinchi Lake. Normal consumption is not a significant hazard to human health but high consumption may be. The third mercury warning is issued for Jack of Clubs Lake where lake trout over 45 cm may contain elevated mercury levels and to limit consumption. At the time the warning for Jack of Clubs Lake was issued, the Ministry of Agriculture, Food and Fisheries was not involved. The advisory was issued due to mercury contaminant detected through sampling by B.C. Environment, Environment Canada, provincial and federal health. Based on these sampling result and after consultation with provincial health, the advisory was inserted into the Freshwater Sport Fisheries Regulations Synopsis. These warnings were issued due to past mining activities which resulted in high levels in fish. These mines have now been closed for several years (B.C. Ministry of Enviroment, Land, and Parks, April 2001). Elevated mercury levels at Williston Lake was issued due to damming. The B.C. Ministry of Health did issue a general advisory against consuming fish liver about 7 years ago and it still remains in effect (B.C. Ministry of Health, April 2001). For more information on freshwater fishing in British Columbia consult the Freshwater Sport Fisheries Regulations Synopsis or contact the Department of Environment or B.C Ministry of Health.
Alberta Fish and Wildlife published in 1991 a document titled Mercury Contamination in Fish. The document describes the health hazards of mercury and provides fish consumption guidelines for those waters in which mercury-contaminated fish have been found. People who consume the fish species from the waters listed are advised to follow these guidelines: women of child-bearing age and children under the age of 15 should not eat these fish, and others should not eat more than one meal of these fish per week (Alberta Environment, 2001). Along with the mercury advisory, Alberta Fish and Wildlife has issued a Dioxin and Furan Contamination in Fish document. For more information on either of these advisory contact the appropriate Regional Office of the Fish and Wildlife Division in Alberta.
Alberta Health and Wellness (AHW) has prepared a draft document entitled A Process for Evaluating Fish Advisories in Alberta. This document outlines the procedure recommended by the province of Alberta so that industries likely to influence waters frequented by fish can assess these influences. The framework for the evaluation begins with the industry preparing a Science Assessment Document which addresses their manufacturing performances, fish sampling and analysis techniques, and risk assessment protocols. The industry evaluates the types of manufacturing near target locations, which types of chemicals are discharged into the rivers and lakes, the technological changes in manufacturing processes and monitoring of the environment. The industry collects fish samples and analyses them in their own facilities using standard protocol and accepted Quality Assurance/Quality Control (QA/QC) criteria. Finally, the industry looks at a risk assessment, which is the development of a risk-based consumption model. Using Health Canada's Tolerable Daily Intake (TDI) and comparing the calculated consumption limits with the estimated consumption rates by local residents, results are interpreted and presented with recommendations to Alberta Health and Wellness. A Science Advisory Committee is formed with experts in health risk assessments, toxicology, biology and chemistry to review the science assessment document.
They then validate and interpret the results and provide advice and recommendations to the Public Health Advisory Committee (which includes representation from Alberta Health and Wellness, Regional Health Authorities and Alberta Environment). This committee in turn makes recommendations to the Provincial Health Officer (PHO) who would issue/revise/remove a fish consumption advisory if required. Alberta Health and Wellness also ensures that the advisory is listed in the provinces sport fishing guidelines through direct communication with Alberta Environment (Alberta Health and Wellness, April 2001). For further details concerning human health advisories please contact Alberta Health and Wellness.
Saskatchewan Environment and Resource Management (SERM) monitoring is focused in Saskatchewan on popular recreational fishing areas, commercially fished lakes, and waters near known or suspected sources of pollution Testing is done by provincial Health Labs. An assessment of the results would be undertaken and low levels of mercury in predator species would indicate that no further study needs to be undertaken. High levels would trigger a more intense sampling program.
A « Contaminants-in-Fish Committee » is composed of representatives from the provincial Departments of Environment and Resource Management as well as Health. They work together to develop recommendations for consumption based on data collected and recommendations from the World Health Organization. Guidelines are updated annually with new data.
SERM publishes Mercury in Fish: Update to Guidelines for Consumption, which is updated annually and similar to those of Ontario and Manitoba. The levels described are based on mercury levels found in fish from specific lakes, the size(length) of the fish, and the duration of time fish are eaten. Fish with an average mercury concentration of less than 0.5 ppm may be eaten in unlimited amounts. Mercury levels between 0.5-1.0 ppm have a « level 1 » advisory, mercury levels between 1.0-1.5 ppm have a « level 2 » advisory. Mercury levels above 1.5 ppm have a « level 3 » advisory. SERM advises that no one should eat fish with mercury concentrations higher than 1.5 ppm, and children and pregnant women should not eat fish containing mercury in excess of 0.5 ppm (SERM, 1999).
Within SERM, the Fishing and Wildlife Branch issues an Annual Saskatchewan Anglers' Guide which has regulations for recreational fishing. Information placed in the anglers guide regarding mercury is limited, no lake specific data is provided, only a short note indicating that SERM monitors some lakes for mercury levels in fish. For more details on mercury contaminants obtain a copy of Mercury in Fish: Update to Guidelines for Consumption, through local SERM office.
The Manitoba Department of Environment, recently changed to the Department of Conservation, began monitoring mercury levels in fish from various water bodies in 1978. The Water Branch (formerly the Environmental Quality Branch) is responsible for monitoring major waterways in southern Manitoba around locations in or near industrial areas, urban centers, agricultural zones and reservoirs. This monitoring is done by the Water Quality Management Section and assessments for Manitoba consumption guidelines follows recommendations from Health Canada and the World Health Organization. The findings of this monitoring program where published in 1992 in a document entitled Mercury In Fish & Fish Consumption Guidelines. However, this department terminated extensive mercury monitoring in 1992 because most data from 1978-1992 indicated that mercury concentrations were not increasing and appeared to be fairly stable or even slightly decreasing in some areas (Manitoba Conservation, February 2001). In the development of a specific fish advisory, the Department of Conservation would coordinate with Manitoba Health and appropriately inform the public.
The department recommends anglers to follow fish consumption restrictions outlined in Mercury In Fish & Fish Consumption Guidelines before consuming sport fish from Manitoba's waters. The consumption guide indicates that fish in the unrestricted consumption category may be consumed freely. Children under 15 and women of child-bearing age are recommended to restrict their consumption to this category. Consumption restrictions for the general population depend upon the mercury level in the fish, how much fish is consumed and the length of time over which fish are consumed. The department has divided limited consumption of fish into two separate categories. « Group 1 » has mercury concentrations between 0.5 to 1.0 g/g. For short term consumption, which is stated as one week, anglers can eat about 10 meals. Long term consumption, fish consumed throughout the year, should be limited to about one meal per week. « Group 2 » has higher mercury concentrations between 1.0 to 1.5 g/g. The short term consumption is reduced to about 7 meals per week, and long term consumption is limited to about one small meal per week. No consumption is recommended for fish with mercury concentrations greater than 1.5 g/g (Manitoba, 1992).
The Fisheries Branch annually publishes the Manitoba Angler's Guide to inform anglers of regional and provincial regulations. Information concerning mercury could be distributed through this avenue. For more details concerning mercury contaminants contact the Water Branch, Department of Conservation.
In the Province of Ontario the Ministry of the Environment (MOE) and the Ministry of Natural Resources jointly collect fish samples from the numerous lakes and rivers in Ontario. Fish tissue samples are analyzed for a wide variety of organic and inorganic contaminants including mercury, PCB's, mirex, DDT, and dioxins. The analyses are performed on lean, dorsal, skinless, boneless muscle tissue of the fish at the MOE's lab in Toronto. Recommendations for fish consumption are determined by using Health Canada's Tolerable Daily Intake (TDI) criteria. Health Canada periodically provides updated guidelines. A proportion of the TDI is allocated to the consumption of sport fish. In many cases it is 100%. 100% of the methyl mercury guideline is allocated to fish consumption because fish represent the only major source of methyl mercury. MOE issues recommended fish consumption guidelines through the biennial publication of the Guide to Eating Ontario Sport Fish (Ontario MOE, February 2001). Consumption advisories for sport fish are calculated such that "No one shall exceed their tolerable daily intake (over a one month period) for any contaminant in sport fish if they follow the advice in the Guide". Calculations are based on an average adult body weight of 60 kg and a meal size of 227 g. Smaller individuals are expected to consume smaller meals and larger individuals, larger meals (Ontario MOE, March 2001).
The Guide to Eating Ontario Sport Fish advises women of childbearing age and children under 15 years of age to eat only those fish represented in the 2001-2002 Guide to Eating Ontario Sport Fish by a clear fish symbol and to consume no more than four meals per month of these fish. All other categories of fish caught in Ontario should not be consumed by these sensitive individuals. This advisory does not apply to the remainder of the population (Oatario MOE, March 2001). For more details on individual fish consumption pick up a Guide at the closest MOE or MNR office or on the internet at www.ene.gov.on.ca. To obtain further information on results in the Guide contact the Sport Fish Contaminant Monitoring Program, Ministry of the Environment by phone at 1-800-820-2716 or e-mail at sportfish@ene.gov.on.ca.
In the Province of Québec the « Ministère de l'Environnement du Québec » and « Société de la faune et des parcs du Québec » are responsible for jointly collecting fish species. Hydro-Québec is also analyzing fish samples from northern Quebec at their own private facilities. The « Ministère de l'Environnement du Québec » does analyzing and testing of the fish tissue samples and send the results to « Ministère de la Santé et des Services Sociaux » where data is evaluated for the toxicity. The « Ministère de la Santé et des Services Sociaux » uses the following as recommended fish consumption guidelines for mercury for the general population: 8 meal per month <= 0.5 mg/kg, 4 meal per month 0.5 -1.0 mg/kg, 2 meal per month 1.0 -1.5 mg/kg, 1 meal per month > 1.5 mg/kg. The « Ministère de l'Environnement du Québec » and Ministère de la Santé et des Services Sociaux have advised that women of child-bearing age and children should choose to avoid consumption of predatory fish like walleye, northern pike, and smallmouth bass (Ministère de l'Environnement du Québec, March 2001). For consumption guidelines the general public should consult the public documentation, Guide de Consommation du Poisson de Pêche Sportive en eau douce. For more information contact the « Ministère de l'Environnement du Québec ».
New Brunswick's Department of Natural Resources and Energy performed a couple of studies during 1995-1997 in conjunction with New Brunswick's Health and Wellness, Environment, and Fisheries and Oceans to determine the mercury levels in freshwater species of New Brunswick. There has not been routine testing since these study, however, from this study the New Brunswick Department of Health and Wellness issued a province wide advisory. This advisory was due to the potential of acquiring increased levels of mercury by consuming fresh water fish caught or harvested in most of New Brunswick's lakes and rivers. The department cautions women of child bearing age, and children under eight years old, to avoid consuming most species of fresh water fish in New Brunswick to reduce their risk of elevated levels of mercury. The advisory is issued for most freshwater fish caught in New Brunswick and includes brook trout, lake trout, landlocked salmon, smallmouth bass, perch, fresh water cusk, pickerel, striped bass and catfish, but excludes Atlantic salmon.
The department advises women of child bearing and children to limit consumption of brook trout measuring less than 29 cm (12 in) to one meal per month, and avoid consumption of all other species including brook trout measuring 29 cm or more. In New Brunswick pregnant women should avoid consumption of all fresh water fish noted in this advisory. There is no restriction on consuming brook trout under 29 cm for the general population. However, consumption of brook trout measuring 29 cm and more should be limited to one meal per week, and all other fresh water fish listed should be limited to one meal every two weeks for the general population (New Brunswick, February 2001).
An occasional meal which exceeds the guidelines should have no adverse health effects. Fish from commercial trout ponds and aquaclture operations are considered safe to eat, for inquirers about commercially sold products contact the Canadian Food Inspection Agency (CFIA). New Brunswick Department of Health and Wellness communicates with the Department of Natural Resources and Energy to publish the health consumption advisory in the Angling Regulation and Licence Information booklet. For further details on guidelines for fresh water species contact New Brunswick Public Health Services.
The Nova Scotia Departments of Health, Environment and Labour, and Fisheries and Aquaculture collaborate on the issue of fish consumption advisories. Traces of mercury have been detected in certain species of freshwater sport fish so these departments have worked together, using Health Canada's guidelines for mercury consumption to issue a province wide Fish Consumption Advisory (Nova Scotia, February 2001). The fish consumption advisories recommend that children under eight, pregnant women and nursing mothers limit their consumption to brook trout less than 25 cm (11 in.) in length and rainbow trout, and white perch. Along with the mercury advisory, Nova Scotia has issued a Polychlorinated Biphenyls (PCBs) advisory. For further information on either of these advisories please contact Nova Scotia Department of Environment, Environmental Health Section.
The Department of Fisheries and Oceans and Environment Canada are responsible for tidal waters and any subsequent advisories for consumption of fish from marine waters.
The Province of Prince Edward Island has recently conducted studies through the Department of Fisheries, Aquaculture and Environment to examine the levels of mercury in provincial freshwater fish species. Studies were conducted in 1998 and again in the summer of 2000. Test results where analyzed at the Environment Canada labs in Moncton, New Brunswick. Test results for both 1998 and 2000 where below Health Canada guidelines, so, at present PEI has not issued a fish consumption advisory (PEI, February 2001). For changes, or more information regarding freshwater fishing contact PEI Fish and Wildlife Division, Department of Fisheries, Aquaculture and Environment.
In the Province of Newfoundland fish samples from hydroelectric reservoirs are monitored for mercury on a rotational basis by the Department of Fisheries and Oceans Canada (DFO) in partnership with Newfoundland and Labrador Hydro. Mercury testing is only one of many contaminants being tested in Newfoundland's freshwater fish species. Analyzing fish samples are conducted at the Canadian Food Inspection Agency (CFIA) Laboratory in St. John's, this lab was formerly a government lab, but is now an arm's length agency. Samples are also sent to Phillips Analytical Laboratory in Montreal and is privately owned, not all analyzing is performed at these laboratories, however, they are used frequently. Once data has been analyzed, and if it suggests a health concern, DFO will forward the data to Health Canada for a Health Risk Assessment. Health Canada will forward the results of the assessment to DFO and, in the event a consumption advisories is needed, the matter is then discussed with the appropriate proponent who is ultimately responsible for advising the public. DFO assists in the nature in which the public is notified, this could included local newspaper notices, signs posted along roads, near reservoirs, or public information sessions (Newfoundland, March 2001).
At present there is no ongoing program to assess atmospheric deposition of mercury in natural lakes, however DFO will be conducting a program on natural lakes in northern Labrador under the UQAM collaborative research network (COMERN) over the next 5 years. Historical information on Hg in fish flesh in natural lakes is available from acid rain lake surveys conducted in insular Newfoundland (1982) and Labrador (1983) (Newfoundland, March 2001). For more information regarding this program or freshwater fish consumption please contact the Department of Fisheries and Oceans.
The Territorial Government of Yukon has established a procedure for issuing health advisories for contaminant fish and informing the public of these advisories. The Department of Indian Affairs and Northern Development (DIAND) collects and analyzes the fish samples. When requested by DIAND, YTG Fisheries will help with sampling. The results are forwarded to the Yukon Contaminants Committee (YCC) which decides whether or not additional assessment is needed. They may send the data to Health Canada for a Human Health Risk Assessment or further asses the data themselves. These results are then forwarded to the Yukon Government Department of Health, which in turn informs the Yukon Contaminants Committee, Health and Social Services (H&SS) and Renewable Resources (RR). Health and Social Services, together with the Ministry of Health will issue a health advisory related to fish consumption and informs the public through different avenues such as posting notices and community meetings (Yukon Territory, April 2001). Renewable Resources also publishes the document Fishing Regulations Summary which is another avenue in which the public is informed on fishing regulations. For more information concerning fish consumption advisories please contact Health and Social Services of the Yukon Government.
The Government of the Northwest Territories have several methods of distributing information to the public when there is a concern related to contaminant fish. Informally, the Department of Fisheries and Oceans (DFO) has releases results to communities even before Health Canada has had a chance to issue consumption advisories if they are necessary. The reason for this release is to allow the communities to decide whether or not they should seek advice on their own and thereby work to speed up the process. DFO now formally releases the data to the NWT Environmental Contaminants Committee (NWTECC), and Health Canada. However because there is often a timelag in getting advisories issued, some aboriginal organizations have requested this early release of raw data. DFO does not provide any explanation of human health issues. The community representatives are advised to contact GNWT Health and Social Services or their local health board if they have concerns. The field collector or the researcher will also notify GNWT Health and Social Services at this time, so they can be prepared to respond to concerns from the community. DFO deals with study results and the health of the fish, GNWT Health and Social Services addresses human health concerns. DFO tries to meet with community organizations along with a representative from GNWT Health and Social Services. GNWT Health and Social Services is very interested in presenting information on both benefit and risks of fish consumption (Northwest Territory Region, March 2001).
An important note to observe is that GNWT Health and Social Services, and not Health Canada have the mandate to deliver contaminated related advisories in the NWT. NWTECC reviews data from researchers to alleviate pressure on Health Canada. When NWTECC receives individual data a sub-committee is formed with representation from GNWT Health and Social Services, DIAND, the researcher, and a representative from the affected region. Together they determine whether data should go to Health Canada for further assessment, send raw data back to community immediately, should researcher present raw data or wait for accompanying information, and when or if an advisory is received, a similar team meets to discuss the risk/benefit analysis, and what other information should accompany the advisory (nutritional, social, cultural) and when should everyone go back to present full results (Northwest Territory, March 2001). For additional information contact GNWT Health and Social Services, or NWT Environmental Contaminants Committee.
The Government of Nunavut does not have a specific program for fish sampling in Nunavut for mercury or any other contaminant. The Department of Fisheries and Oceans as well as other agencies are able to collect and analysis fish tissues on a case-by-case basis. If a problem arises dealing with a contaminant the Nunavut Health and Social Services is responsible for issuing consumption advisories. They will inform the public of an advisory with the assistance of DFO through public information sessions, signs posted near water shores, and local newspapers (Nunavut, April 2001). The Northern Contaminants Program (NCP) looks at contaminants in the North, but has not focused on fish from Nunavut in the last couple of years. The Nunavut Environment Contaminants Committee (NECC) has indicated a willingness to participate in the process of public advisory, but has not yet gone through with it because there have been no advisories issued for mercury levels in fish. Overall, the process described for the Government of the Northwest Territories is the blueprint NECC would like to adopt to Nunavut since it gets the information to the appropriate people early in the process. At the present there is no formal procedure set out which has routine sampling and monitory of freshwater fish in Nunavut (Nunavut, DIANA, April 2001). Programs and protocols have been discussed for future implementation, but have yet been finalized. For more information contact Nunavut Environment Contaminants Committee or Nunavut Health and Social Services.
Health Canada assesses the potential risk to Canadians dietary exposure to toxins in foods through Health Risk Assessments. It's Your Health Food Chemical Contaminants - Assessing Health Risks (Health Canada, October 1991) is a public document that outlines the appropriate steps in performing a health risk assessment. The Tolerable Daily Intake (TDI) is the quantity of toxicity of the chemical contaminant or its capacity to cause harm to humans who consume on a daily basis, for a lifetime, with reasonable assurance that their health will not be threatened. TDI for a contaminant in humans is usually based on studies undertaken on laboratory species. Researchers establish a level of exposure to the chemical such that there are no adverse effects demonstrated, then this level is divided by a safety factor to derive the TDI. Next, the Probable Daily Intake (PDI) is assessed. This is done by first identifying all foods that may contain the substance, secondly, a knowledge of the intake of those particular food by the general population, indigenous populations, and particular groups considered to be at risk. Thirdly consideration of other potential sources of exposure (air and water) to the contaminant. Once both TDI and PDI is determined, a comparison of the two is done, if the PDI exceeds the TDI, various risk management options may be considered. These include; establishing guidelines or legally-binding tolerances for the toxic substance; restricting the sale or distribution of a food or foods obtained from an area identified as the source of the contamination; recommending or issuing advisory notices about consumption of contaminated foods. In adopting any of these options, careful consideration would be given to assessing whether the nutritional benefit of a food outweighs any measure to restrict consumption of a staple in the diet. In the case that the contaminant is proven to be a carcinogen, a risk management option will try to reduce exposure to as low a level as reasonably achievable. At the current time Health Canada's guidelines for mercury are issued at 0.5 parts per million (ppm), expressed as total mercury in the edible portion of the flesh. Health Canada has temporarily lowered the maximum tolerable daily intake for methylmercury recommended for small children and women of child-bearing age while it awaits the results of a long-term international study into the effects of mercury.
Exemption of certain fish, especially predatory species, can accumulate high levels of mercury in their flesh. Swordfish, shark species and fresh and frozen (not canned) tuna are exempted from the Health Canada guideline. Consumption of fish species mentioned above should be limited to a maximum of one meal per week by all consumers. Consumption by children and women of child-bearing age should be further limited to a maximum of once per month. It was agreed in the past that these species could be exempt from the guideline based on the fact that they are specialty items unlikely to be consumed at a frequent rate (Health Canada, January 2001). Development of the advice and conveying it to stakeholders followed a reevaluation of the pTDI for methyl mercury and establishment of a reduced pTDI for women of child-bearing age and children (0.2 g/kg b.w./day) compared with the pTDI for the general population (0.47 g/kg b.w./day). Revision of the advice about the 0.5 ppm mercury guideline articulated above for these sensitive groups was not considered necessary at the time, although a further restriction of the frequency of meals of species exempt from the guideline was issued (Health Canada, February 2001). For more information in Health Risk Assessments and contaminant guidelines please contact the Health Protection Branch of Health Canada.
Indian and Northern Affairs Canada has a program called the Northern Contaminants Program (NCP) which is working to reduce and, wherever possible, eliminate contaminants in traditional harvested foods, while providing information that assists informed decision making by individuals and communities in their food use. The diagram entitled Protocol for Contaminants Health and Harvest Information Release in the Yukon, Northwest Territories and Nunavut (INAC, 2001) outlines a protocol for release of health information that was developed for the three territories. It is well known that traditional/country foods are the major source of contaminant exposure to humans (with the exception of cadmium from cigarettes). NCP data, which measure contaminant levels in a food source and which suggest that there may be a concern to human health, are submitted to Health Canada for a Health Risk Assessment. There are four main activities, described below, under this protocol:
i) Validation/Verification of Data - Contaminant data that suggest that a risk assessment may be needed, are forwarded by the NCP project's initiating department or organization or a Management Committee representative to the NCP's Quality Assurance/Quality Control
(QA/QC) Officer for quality verification, as needed. The data are also sent to DIAND-HQ to ensure that they are aware that the health assessment process has been initiated. In cases where the QA/QC procedures for the laboratory that carried out the analyses are unknown, then the data would be forwarded to the QA/QC Officer for quality verification. In cases where the specific laboratory is currently taking part in the NCP's QA/QC program, it may not be required that the data be forwarded to the QA/QC Officer for verification. In either case, re-analyses of the samples may be required. This is usually done after consultation with the initiating organization, the QA/QC Officer, a territorial health representative, Health Canada, DIAND and the NCP Management Committee, as necessary.
ii) Screening Process - The contaminants data are forwarded by the initiating department or organization to the applicable Territorial Contaminants Committee (TCC membership includes a
territorial health official) for screening. The TCC determines if the data submitted warrant
the conduct of an official Health Risk Assessment. If the data do not warrant a health
assessment, then the TCC may still decide to release the data to the public through a number of communication methods (step iv below - information dissemination). For example, the TCC may issue a press release indicating that recent contaminant data for a specific food species does not pose a health concern to consumers. In cases where a health risk assessment is warranted, then the data are submitted to Health Canada by the TCC. In both cases, the data and results of the TCC's screening are forwarded to DIAND-HQ which in turn forwards the information to the NCP Management Committee, for their information. In some cases, the TCC, in consultation with Health Canada and DIAND-HQ, may determine that there is insufficient information to proceed with a human health risk assessment at that time and may request that further sampling and analyses be conducted. This may require further funding and therefore may require submission of a proposal to be reviewed and approved by the NCP Management Committee.
iii) Health Assessment Process - A health risk assessment is carried out by Health Canada. When available, applicable human dietary information is used in the assessment. A health risk assessment is a calculation that compares the amount of contaminant in a food to the amount of contaminant that is known to be safe or will have no negative effect. Concern is for the amount
of contaminants that people accumulate over a lifetime from eating traditional/country food. Therefore, health officials calculate an amount of that food that people could safely eat for the rest of their lives, with no apparent risk of effects. The calculation is usually reported as a "Recommended Maximum Weekly Intake" (RMWI). Health Canada, in consultation with the TCCs and DIAND-HQ may determine that there is insufficient information to proceed with a human health risk assessment at that time and may request that further sampling and analyses be conducted. This may require further funding and therefore may require submission of a proposal to be reviewed and approved by the NCP Management Committee.
iv) Information Dissemination - The results of the health risk assessment are forwarded by Health Canada in the form of a letter of recommendations to the applicable TCC. The TCC determines the applicability of the HC recommendations to Northerners and then in turn devises a communication plan for the release of the information. The TCC ensures that the method of information release is culturally-sensitive and is available in a form that is understandable by the applicable communities. This is done with significant input from the northern Aboriginal organization representatives that sit on the TCCs. Depending on the significance of the risk assessment results, the information may be released through a number of methods including a press release, community meetings and individual face-to-face meetings. The territorial chief medical officers of health, in association with the regional Aboriginal organizations and Health Canada, have the lead in ensuring that people receive the appropriate information. The results of the health risk assessment and the method of public release are carried out in full consultation with DIAND-HQ. All information is forwarded by HC and the TCCs to DIAND-HQ which in turn forwards the information to the NCP Management Committee.
The attached diagram entitled Recommended Process for Contaminants Health and Harvest Information Release in Nunavik and Labrador (INAC, 2001) outlines a recommended process for the release of contaminants health information that was developed for Nunavik and Labrador. It relates to stage 4: Information Dissemination only of the previous diagram describing the protocol for release of health information in the territories. A brief description of the process for Nuanvik and Labrador is provided:
The results of a human health risk assessment are forwarded by the originating and assessing organization to the Director of Public Health (DPH), Nunavik Regional Board of Health and Social Services (NRBHSS). In the case of an assessment within the Northern Contaminants Program, the results are forwarded by the appropriate NCP participating agency to the Director of Public Health, NRBHSS. As needed, the DPH consults with advisory groups (such as Nunavik Nutrition and Health Committee concerning foodborne risks) or other regional authorities in Nunavik (e.g. Makivik concerning faunal data) or experts outside the region to discuss specific items.
The DPH devises a communication plan for releasing the information and ensures the methods of dissemination is culturally sensitive, and available in a form that is understandable, accessible (linguistically and otherwise), and meaningful to the affected communities and individuals. The release is made either through the NRBHSS or through another regional authority. The methods of public release methods used include press releases, radio phone-in shows, community meetings, face to face consultations and various forms of print media.
In Labrador, the results of a human health risk assessment that directly affect Labrador Inuit are forwarded by the originating and assessing organization to the Labrador Inuit Association (LIA) and relevant provincial authorities, where appropriate. In the case of an assessment within the Northern Contaminants Program, the results are forwarded by the appropriate NCP participating agency to LIA. LIA, in consultation with the Labrador Inuit Health Commission (LIHC), prepares a communication plan for releasing the information to Labrador Inuit and ensures method(s) of dissemination is culturally sensitive and available in a form that is understandable, accessible (linguistically and otherwise), and meaningful to the affected communities and individuals. The methods of communicating this information include press releases, radio phone-in shows, community meetings, face to face consultations and various forms of print media.
For health advisories affecting the general population of Labrador, the results of the human health risk assessment are forwarded by the originating organization, or participating NCP agency directly to Health Newfoundland and the Health Labrador Corporation (Labrador counterpart of HN). These authorities consult the appropriate provincial government departments, develop the communication plan and disseminate the information in an appropriate manner using various forms of media.
For additional information contact Northern Contaminants Program, Department of Indian Affairs and Northern Development.
The CFIA's mandate is to ensure that safe , wholesome and fairly represented food products are available to Canadian consumers and that products exported from Canada meet safety, minimum quality and other applicable foreign government requirements. The CFIA has been moving to intregration of HACCP principles, or Hazard Analysis Critical Control Point principles into its regulatory programs. HACCP based systems take a preventative approach to food safety by identifying and controlling key hazards in the food production process. Then these potential hazards are prevented from occurring through appropriate monitoring and verification programs at key critical control points. Examples of current HACCP based systems within the CFIA include the Food Safety Enhancement Program (FSEP) for agri-food products; Quality Management Program (QMP) for fish; and the Modernized Poultry Inspection Program (MPIP) (CFIA, 2001).
All establishments in Canada that process fish and seafood for export or inter-provincial trade must be federally registered with the Fish Inspection Program of the CFIA and have developed and implemented a mandatory Quality Management Program (QMP). The QMP, as outlined in the Fish Inspection Regulations, incorporates the principles of HACCP into a regulatory package that includes requirements for safety, wholesomeness, labeling, sanitation and hygiene levels and standards for construction, equipment and operation of the facility. The QMP requirements provide a high level of assurance that fish and seafood products produced in Canada are safe and wholesome to eat.
The QMP is a mandatory program established in 1992, becoming the first mandatory food inspection program based on HACCP principles. Prior to 1992, fish inspection was conducted as a more traditional food inspection program with federal inspectors inspecting fish plants and testing their products. Between 1996 and 1999, the QMP was reviewed and updated with the active participation of the fish processing industry (CFIA, March 21, 2001). For additional information regarding QMP Program and associated regulatory requirements please view CFIA's website at www.cfia-acia.agr.ca
Beginning in 1996, the Fish Inspection group of the CFIA worked with the Industry to develop a similar program for importers, based on the QMP, entitled the Quality Management Program for Importers or the QMPI (CFIA, March 31, 2001). The QMPI is a part of the total Fish Import Inspection Program. A fish importer must be licensed as either a Fish Import Licence Holder ( Basic Importer) or a QMPI. The QMPI includes the option of a Enhanced or Shared inspection regime. Under the voluntary QMPI, the importer chooses to develop and implement a CFIA approved fish import inspection regime. The Enhanced QMPI is responsible for all testing of incoming products using either a CFIA approved private laboratory or a CFIA laboratory for health and safety testing. The Shared QMPI takes on the responsibility for testing for standard analyses, i.e. sensory, labels, weights, container integrity, and the CFIA is responsible for specialised or chemical and microbiological testing.
The CFIA verifies that the Enhanced and Shared QMPI meet regulatory requirements through ongoing CFIA audits of the company system of controls. The CFIA audit evaluates the QMPI system to determine if the company system is effective to ensure acceptable products are imported into Canada. The QMPI audit will consist of a review of the testing regime, product control systems, record keeping and product sampling and testing frequencies and results.
The CFIA conducts all products testing for Fish Import Licence Holders or the Basic Fish Importers. Products are held until released by the CFIA and subject to a defined import testing regime based on type of product , analyses required, and past history of compliance. Where products fail CFIA inspection, the product and packer is placed onto the Import Alert List, and all subsequent products from this packer are subject to 100% mandatory inspection upon importation. Products are not removed from the Import Alert List until 4 shipments are found acceptable, at which point it is removed from the list.
The CFIA can and will take enforcement actions when violations are identified against the applicable Acts or Regulations. These enforcement actions can range from issuance of a formal letter of warning; product action such as detention or seizure; license or registration sanctions; and/or legal action. For more details on the Import Inspection Program consult the Guide to Canadian Regulatory Requirements and Examination Procedures for Imported Fish, (CFIA, August, 2000) available to view on the CFIA website.
The Canadian Guidelines for Chemical Contaminants and Toxins in Fish and Fish Products, (CFIA, March 22, 2001) provide reference information on Canadian regulatory action levels for contaminants and toxins as set out by Health Canada and the CFIA. Mercury contaminants are analyzed for fish products where mercury may be of concern. Some larger species such as shark, and swordfish are subject to consumption advisories, and therefore are not tested on a routine basis. The action level for mercury is 0.5 ppm. Sampling must consist of a minimum of 5 units to represent a lot, analysis may be carried out on a composite of all sample units. A lot of fish will be considered reject if the sample value exceeds the action level. Where fish and fish products are destined for export and exceed Canadian regulatory requirements, but meet foreign government requirements, these fish may be exported under QMP controls.
Canadian Shellfish Sanitation Program (CSSP) is another key Fish Inspection program. The CSSP is unique in that it is jointly administered between the CFIA, Environment Canada and Fisheries and Oceans Canada. Environment Canada is responsible for the classification of overlaying waters to determine their suitability for shellfish harvesting, based on sanitary quality and public health safety. Fisheries and Oceans Canada controls and enforces the harvesting of shellfish from areas which are classified as contaminated or closed (CFIA, CSSP, March, 2001).
For further detail on CFIA's Fish Inspection Program view information available on the CFIA website.
General
The purpose of this report is to examine the relevance and comparability of fish consumption advisories established throughout Canada and how the public is informed about these advisories. Canada has many fish consumption advisories for various contaminants and in particular many are the result of mercury contamination. This report shows that there are numerous levels of government involvement in establishing fish consumption advisories. However, there are no specific programs developed to-date which outline a methodology for coordinating fish consumption advisories related to mercury uniformly across Canada.
Provincial
At the provincial level the system of fish sample collecting, analyzing and testing, forwarding data to other departments and informing the public is a complex system in which there are many people involved and the procedure differs for each province. There is no harmonized testing or monitoring of fish for mercury at the present time. Consequently there is no consistent and uniform procedure for assessing mercury contaminants in fish throughout the ten provinces. In this study it was determined that some provinces may not have an integrated system of communications to exchange information on fish advisories within their various departments and agencies, resulting in discrepancies of both understanding and delivery of an advisory program. Some provincial departments may not initiate testing unless requested to by another sister departments. This points to the need for a more comprehensive monitoring and assessment program to identify problems before human health effects become the problem identifier. Many provinces work on a case-by-case basis or have other general contaminants programs which mercury would fall under. Some provincial testing results are outdated and in need of re-testing. Many of the provinces have turned to the industry to take on the responsibility for sampling and monitoring, however; not all water bodies in a province are being monitored by the industry or by the government designated agencies. This poses a problem with mercury because this substance has the ability to be an air-born and hence travel to and affect remote areas. Also with industry performing sampling and analyzing, there does not appear to be a system of consistent procedures or guidelines that are being followed. This allows for inconsistent results between agencies and provinces. With inconsistent results, re-testing by the province is sometimes needed, prolonging the assessment period and possible exposure to the contaminant in question.
Territorial
The federal government in conjunction with the territorial government is responsible for issuing fish consumption advisories for the three northern territories of Canada. The territories have a strong interest in fish consumption advisories because many of the communities depend on traditional foods such as fish, marine mammals and caribou. Consequently the length of time it takes before an advisory is issued is a serious concern for the territories. This report also noted that not all stakeholders in the northern territory of interest are informed about the sampling and test results, indicating a lack of communication.
Federal
Within each affected federal department there maybe guidelines and regulations on fish consumption, but as an overall process there appears to be little interaction between these departments. They all have their own responsibility related to fish consumption. Like some provinces, certain federal departments have given the responsibility of monitoring and testing to the industry sector which may result in inconsistent results. These inconsistencies, if detected, may require retesting by the industry or the department itself. The time it takes to issue an advisory at the federal level may also be lengthy depending on whether retesting is a priority.
General
The procedure of issuing and informing the public about the hazards of mercury is important to the health of Canadians and the health of future fish species. The conclusions from this report indicate that Canada does not have a uniform procedure for addressing the issue of fish consumption advisories, it is therefore recommended that a consistent and uniform procedure be established across the country.
Provincial
Recommendations for provinces would also include a standardized and uniform procedure which each province could follow in order to have a comparable base of information between jurisdictions. Routine testing is required to be done by the provinces, near sources of known contamination, but as well in remote areas to allow for province-wide coverage of advisory information. Better communications between departments should be improved in order to ensure adequate and timely advice is effectively disseminated. For those provinces which have not established routine mercury monitoring, they could adapt the establish procedures from other provinces. For the provinces which rely on industry data for results, consistent protocols on the procedures used should be established and regular verification should be undertaken. Industry and provincial departments need to follow standardized procedures to prevent inconsistency. This would limit re-testing and less time would be required for the assessment and issuing of a fish consumption advisory.
Territorial
For the territories, distribution of information and results to affected communities is very important. Following established procedures and subsequent new procedures, and including any departments which are or should be involved is key when communicating. The development of procedures may be done by adapting from other territories or provinces to develop the most effective way of issuing an advisory and informing the public.
Federal
At the federal level, it appears that there is a lack of consistent and uniform methodology for assessing, undertaking and advising on mercury contamination in fish. This is apparent both when dealing with inter-departmental communications and when advising the public in general. A project could be developed which would establish effective procedures and guidelines for key stakeholders to follow when dealing with the various federal issues concerning mercury consumption in fish. Communications between departments should be established, and maintained and exchange of information should be on-going perhaps through an inter-departmental fish advisory workgroup which could report to the Canadian Council of Ministers of the Environment. The establishment of consistent and uniform monitoring and testing protocols should be applied to both industries and the federal departments which depend on sound data to make decisions. Federal departments should ensure that regular verification of industry generated data is undertaken.
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Sports Scene Publications, Edmonton Alberta.
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