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Buchanan et al. assert that our recent fish ingestion risk assessment for a section of the Lower Passaic River (LPR) (Urban et al., 2009) utilizes inappropriate ingestion rates and is inconsistent with state and USEPA guidelines and risk assessment procedures, and therefore underestimates the human health risks associated with angler exposure along this stretch of the river. However, they fail to support these assertions with evidence; indeed, in a recent response to similar allegations, we demonstrated that the utilized ingestion rates are, in fact, the most appropriate for this parameter (Urban et al., 2010). Our reliance on data from a comprehensive, independently validated, peer-reviewed, and site-specific creel angler survey (CAS) in order to define fish and crab ingestion rates for this region of the LPR is fully compliant with USEPA guidelines. In fact, the crab ingestion survey and risk assessment cited by Buchanan et al. as evidence of crabbing activity and crab ingestion for this region was less comprehensive than the CAS in question, was not overseen by an independent panel, has yet to be peer-reviewed, and does not provide any activity or consumption data for this section of the LPR. Contrary to the implications of Buchanan et al., our effort provides a transparent, comprehensive, and scientifically legitimate human health risk assessment of fish ingestion for the lowest 6 miles of the LPR. Thus we adamantly disagree with the characterization and assertions put forth by Buchanan et al., and stand by the conclusions presented in Urban et al. (2009) and defended in Urban et al. (2010). |
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