chemicals to action levels or tolerances established by U.S. FDA (1982, 

 1984). This approach is limited for the following reasons: 



• FDA action levels or tolerances are available for only a few 

 chemicals (mercury, 12 organic pesticides or related degrada- 

 tion products, and PCBs). 



• FDA has not estabhshed regulatory limits for some of the most 

 potent suspected human carcinogens (e.g., 2,3,7,8- 

 tetrachlorodibenzo-p-dioxin) or for some of the common con- 

 taminants in surface waters (e.g., polynuclear aromatic 

 hydrocarbons and most heavy metals). 



• Action levels and tolerances were intended to be used only for 

 regulation of interstate commerce of food products. 



• When setting regulatory limits, FDA and EPA consider 

 economic impacts of food regulation as well as the potential 

 human health risks on a national basis (U.S. FDA 1984). When 

 using action levels or tolerances to interpret bioaccumulation 

 data, investigators implicitly adopt economic policies of the 

 federal agencies responsible for setting the limits. Thus, risk 

 management issues at a national level are not clearly separated 

 from site-specific risk assessments. 



• Action levels and tolerances were developed from a national 

 perspective. They were not intended to protect localized sub- 

 populations of recreational anglers that may consume con- 

 taminated fish or shellfish at a rate substantially above the 

 national per capita average. 



Use of regulatory limits on toxic chemicals in food products established 

 by other countries (Nauen 1983) would suffer from many of the limita- 

 tions listed above for FDA values. Moreover, a concise review of the 

 basis for each of these limits is not available. 



Uses of Risk Assessment 



Risk assessment may be applied to data on chemical residues in fish 

 and shellfish for the following purposes: 



• Identify and rank toxic chemical problems in specific locations 



• Develop environmental criteria or guidelines at the national, 

 state, regional, or local level 



• Develop public information and advisories. 



The first two applications fall within the general category of regulatory 

 decision-making. In this context, one goal of EPA is to define, identify, 

 and set priorities for reducing unacceptable risks. Risk assessment and 

 management provide a framework for balanced analysis of environ- 

 mental problems (e.g., Tetra Tech 1986a) and consistent policies for 

 reducing health risks (e.g., through reduction of toxic pollutant dis- 

 charges and cleanup of polluted areas). 



Risk assessment can be used to identify and rank environmental 

 problems in several ways. First, contaminated sites can be ranked 

 according to the relative risks associated with consuming fish and 



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