An open letter to:

Heather Moritz, LEHS
Director, Environmental Health Division
St. Mary’s County Health Department
April 19, 2021

Dear Ms. Moritz,

Thank you for getting back to me. I know how busy you must be. I applaud the St. Mary’s County Health Department’s response to the Covid pandemic. My wife, Nell and I are both doubly vaccinated. Thank you for that!

Last February, after receiving test results from the University of Michigan’s Biological Laboratory confirming astronomical levels of PFAS in St. Inigoes Creek, I sent a simple question to the St. Mary’s County Health Department asking if it was OK for my daughter, who may become pregnant, to eat the seafood from St. Inigoes Creek where we live in St. Mary’s City. I asked for a simple yes or no answer.
I received the following response from  Kathy Brohawn, Environmental Program Manager, State of Maryland:

“Currently there are no known thresholds for natural waters or oyster tissue for PFAS.  Maryland Department of Environment (MDE) does not currently have any advisories for contaminants in oysters. The only known PFAS thresholds are associated with drinking water, where the risk of exposure is greatest.  The Environmental Protection Agency (USEPA) is currently researching the issue and MDE looks for their guidance related to sampling (surface waters and fish or shellfish tissue) and standard/approved methods, as well as considering a threshold for advising the public. MDE does not have any additional information regarding PFAS levels in surface waters or oysters at this time.”

Apparently, the state says its OK to eat the seafood here.

The number one source of PFAS in our bodies is from the food we eat, especially the seafood. The European Food Safety Authority says 86% of the PFAS in our bodies comes from food and most of that comes from seafood caught from contaminated waters. Also, many states are developing guidelines because of the lack of direction and leadership of the EPA. Maryland lags far behind.
In the spring last year, I tested seafood from the creek and found these levels of PFAS: oysters – 2,070 ppt; crab – 6,650 ppt; and rockfish – 23,100 ppt.

See the analytical results from Eurofins, here:—st-marys.html

In September 2020, MDE released a report entitled “St. Mary’s River Pilot Study of PFAS Occurrence in Surface Water and Oysters.” (PFAS Pilot Study)  that analyzed the levels of per-and poly fluoroalkyl substances (PFAS) in seawater and oysters. Specifically, the PFAS Pilot Study concluded that although PFAS is present in tidal waters of the St. Mary’s River, the concentrations are “significantly below risk based recreational use screening criteria and oyster consumption site-specific screening criteria.”

The data released by the MDE showed levels of 13.45 ng/l in the St. Mary’s River near Webster Field. The maximum permissible level for PFAS in the European Union is .13 ng/l in seawater.  The levels in the St. Mary’s River are 103 times the European limit.

While the report makes these broad conclusions, the analytical methods and basis for the screening criteria used by MDE are questionable, resulting in a misleading of the public, and providing a deceptive and false sense of safety. I teamed up with one of the nation’s top chemical patent attorneys to write this piece calling out MDE

A meal of baked rockfish may weigh 8 ounces or 227 grams.  If the filet of the fish contains 23,100 ppt of PFAS chemicals, that’s 23.1 parts per billion, which is the same as 23.1 nanograms per gram.  So, 23.1 ng/g x 227 g = 5,244 ng of PFAS chemicals.  EFSA says adults in the EU weighing 150 pounds (68 kilos) can “safely” consume 300 nanograms per week (ng/wk) [68 x 4.4] of PFAS chemicals. (Actually, they can’t “safely” consume any of the toxins.)  EFSA, against the advice of many public health officials, has set a Tolerable Weekly Intake at 4.4 nanograms per kilogram of body weight for PFAS chemicals in food. One meal of St. Mary’s River rockfish containing 5,244 ng of PFAS is 17 times greater than the European weekly limit for an individual weighing 150 pounds. Fish caught near large military bases routinely contain hundreds of thousands of parts per trillion of the substances. One fish near an air force base in Michigan contained nearly 10 million ppt. The firefighting foams used by the military are causing the contamination.

These “forever chemicals” never break down and bioaccumulate in our bodies. They are linked to liver, kidney, testicular, and breast cancer. In the tiniest amounts they are known to cause fetal abnormalities and contribute to the likelihood of a host of childhood diseases like ADHD and asthma. Recent studies suggest PFAS levels in our blood are likely to cause dreadful Covid outcomes.

The Navy recently disclosed that 84,757 ppt of the deadliest variety of PFAS were detected in the groundwater at Webster Field, just1,800 feet from our beach. This is 1,200 times over the federal suggested guideline of 70 ppt for groundwater. This makes our little paradise one of the most contaminated places in the nation.
Allow me to restate my question from last year. My daughter, who is now 29, may soon become pregnant with our first grandchild. Is it OK for her to eat the oysters, crabs, and rockfish? Is it OK for us?

The Navy will be holding an online meeting open to the public scheduled for April 28th, from 6:00 pm to 7:00 pm. Could you ask these questions for us?

Thank you,
Pat Elder
St. Mary’s City, MD