UW SRP comments on EPA's Plan for Institutional Controls

a red salmon underwater

The UW SRP shares comments on EPA's "Institutional Control Implementation and Assurance Plan for Seafood Consumption in the Lower Duwamish Waterway Superfund Site"

For each Superfund site across the country, the U.S. Environmental Protection Agency (EPA) is required to establish a plan for "institutional controls" to protect the public from exposure to contamination. In EPA's language, Institutional Controls are "non-engineered instruments, such as administrative and legal controls, that help minimize the potential for human exposure to contamination and protect the integrity of the remedy."

Recently, EPA released a draft plan developed by Public Health-Seattle & King County titled "Institutional Control Implementation and Assurance Plan for Seafood Consumption in the Lower Duwamish Waterway Superfund Site." Most of the plan focuses on limiting human consumption of the most highly-contaminated resident seafood from the river. It was developed with input from a Community Steering Committee representing the Latinx, Vietnamese, and Cambodian communities who fish in the Duwamish River most commonly.

The UW SRP provided a formal letter commending Public Health-Seattle & King County for developing "a comprehensive and ambitious" plan with a focus on community-based planning and "deep commitment to environmental justice principles."

The UW SRP also made three concrete suggestions for strengthening the plan. These were: 1. to include strategies for limiting health risks from PCB-contaminated salmon as well as resident fish; 2. to move a portion of the burden of protecting people from contaminated seafood from affected fisher communities to the entities responsible for polluting the river; and 3. to expand public review of the plan to the broader fishing community.

The finalized Institutional Control Implementation and Assurance Plan for Seafood Consumption in the Lower Duwamish Waterway Superfund Site is available here. The full text of UW SRP's comments is available here.