Aboriginal Health Risk Assessment

Prepared for:
Aboriginal Health Risk Assessment

of Mercury in Bull Trout Harvested
from the Crooked River,
British Columbia
March 2015
The worlds leading sustainability consultancy
West Moberly First Nations
Aboriginal Health Risk Assessment of

Mercury in Bull Trout Harvested from the
Crooked River, British Columbia
March 2015
Project #0276885-0006
Citation:
ERM. 2015. Aboriginal Health Risk Assessment of Mercury in Bull Trout Harvested from the Crooked River,
British Columbia. Prepared for West Moberly First Nations by ERM Consultants Canada Ltd.:
Vancouver, British Columbia.
ERM
ERM Building, 15th Floor
1111 West Hastings Street
Vancouver, BC
Canada V6E 2J3
T: (604) 689-9460
F: (604) 687-4277
ERM prepared this report for the sole and exclusive benefit of, and use by, West Moberly First Nations.
Notwithstanding delivery of this report by ERM or West Moberly First Nations to any third party, any
copy of this report provided to a third party is provided for informational purposes only, without the
right to rely upon the report.
EXECUTIVE SUMMARY
TEK of the West Moberly provided the basis for the assessment of risk to human health due to
consumption of Bull Trout from the Crooked River system. Given the connectivity of the Crooked
River system to the Williston Reservoir where a fish advisory is in place due to mercury, there was
concern that mercury concentrations in fish harvested from this river system would also be elevated.
Therefore, a preliminary quantitative HHRA focused on mercury was done to determine what, if
any, risk there is to human health due to consumption of Bull Trout from the Crooked River system.
The HHRA followed standard Health Canada guidance. The preliminary HHRA focused on First
Nation consumers, including consideration of traditional practices and consumption patterns.
Traditional practices related to fish consumption may include attendance at Fish Camps. Fish
Camps are periods of time in the late spring or early summer where people gather together and a
number of Bull Trout are harvested. Fish may be either consumed immediately or taken home for
later consumption. Fish harvested by attendees of the Fish Camps are kept for personal
consumption throughout the year, distributed to other family or community members, or potentially
used for trade or sale to others in accordance with the cultural mode of life. Fish may be consumed
by people of all ages and both genders, either fresh (i.e., freshly caught or from the freezer), or dried
(e.g., smoked or otherwise dried).
Samples of Bull Trout (n = 57) from the Crooked River system and Northern Pikeminnow (n = 3)
from McLeod Lake were collected in 2012, and analyzed for age and tissue metal concentrations.
Fish were also measured and weighted. Results indicate that the average age of Bull Trout sampled
in 2012 was approximately 7 years old (95th percentile age was 10 years old). The average fish length
was 521 mm (95th percentile was 780 mm), and the average weight was 1.78 kg (95th percentile was
4.7 kg). A significant correlation was found between the concentration of mercury in fish and the
age, length, and weight of the fish. Generally, as the fish become older or larger, the tissue
concentrations of mercury increase. It is assumed that all of the mercury in the fish was in the more
toxic methylmercury form.
The concentrations of mercury measured in the tissue of Bull Trout and Northern Pikeminnow were
relatively high. All of the Northern Pikeminnow and 37% of the Bull Trout had tissue mercury
concentrations that exceeded the Health Canada Maximum Contaminant Standard and the British
Columbia Ministry of Environment (BC MOE) guideline of 0.5 mg/kg wet weight (ww).
In comparison to the most permissive BC MOE guideline for fish tissue of 0.1 mg/kg ww (which is
based on the consumption of approximately 1 kg of fish per week), 98% of the Bull Trout had tissue
mercury concentrations that exceed the guideline. This data is also summarized in Table 1.
Since many of the fish sampled in 2012 had mercury concentrations greater than guidelines, it
suggests that there could be risk to human health, particularly in people with high consumption
rates for fish.
WEST MOBERLY FIRST NATIONS
ABORIGINAL HEALTH RISK ASSESSMENT OF MERCURY IN BULL TROUT HARVESTED FROM THE CROOKED RIVER, BRITISH COLUMBIA
Table 1. BC Ministry of Environment Aquatic Life Guidelines for Mercury in Fish and
Comparison with Measured Mercury Tissue Residues from Bull Trout
Total Mercury Concentration in
the Edible Portion
(mg/kg ww)
Safe Quantity for Weekly

Consumption
(kg)
Percentage of Bull Trout Sampled

in May 2012 with Tissue Residues
Greater than Guideline
0.5a
0.210
37%
0.4
0.260
46%
0.3
0.350
61%
0.2
0.525
88%
0.1
1.050
96%
Note: mg = milligram, kg = kilogram, ww = wet weight

a The BC Ministry of Environment guideline of 0.5 mg/kg ww of fish is the same as the Health Canada Maximum Contaminant
Standard for Mercury in fish tissue.
When mercury in food is taken into the human body in high enough quantities, adverse effects to
human health are possible. The most sensitive population for mercury toxicity is the unborn fetus,
where exposure occurs due to unintentional intake of mercury by the pregnant woman, and
development effects can occur in the child after birth. Therefore, pregnant women, women of
child-bearing age who may become pregnant, toddlers, and children under 12 are considered to be
the most sensitive populations for mercury exposure. The provisional tolerable daily intake (pTDI)
of methylmercury that is considered tolerable for intake by sensitive populations, without causing
adverse effects, is 0.0002 milligrams per kilogram body weight per day (mg/kg bw/day).
Other potential effects of mercury could occur in the general population at higher concentrations,
such as effects on the immune system, cardiovascular system, or nervous system. The amount of
methylmercury considered tolerable for intake by the general population, without causing adverse
effects, is slightly higher at 0.00047 mg/kg bw/day.
Further analysis of the risk to human health was done by calculating a recommended maximum
weekly intake (RMWI) for Bull Trout. Since this study is intended to be a preliminary assessment of
risk, the 95th percentile of mercury concentrations in Bull Trout from 2012 were used to ensure that
the calculations are protective of health. The RMWIs incorporated traditional practices of West
Moberly, particularly the consumption patterns of fish (i.e., high frequencies of fish consumption
during Fish Camp, lower frequency throughout the rest of the year) and how fish are prepared for
consumption (i.e., fresh or dried).
RMWIs calculated based on the 95th percentile of mercury concentrations suggest that consumption
of fresh Bull Trout for the general population (i.e., those individuals not in a sensitive group) during
the Fish Camps should be kept below 0.292 kg fish/week. The RMWIs for fresh Bull Trout are lower
for those in the sensitive groups, ranging from 0.025 kg fish/week for toddlers, 0.046 kg fish/week
for children under 12 years of age, and 0.106 kg fish/week for women of childbearing age or those
who are pregnant. Consumption of dried fish should be kept lower since drying removes moisture
without removing mercury; RWMIs ranged between 0.011 kg/week for toddlers up to
0.129 kg/week in the general population. These RMWIs are also shown graphically in Figure 1. It is
probable that people are consuming more fish than is recommended during the Fish Camps.
ii
ERM | PROJ #0276885-0006 | REV C.1 | MARCH 2015
Figure 1
Recommended Maximum Weekly Intake of Bull Trout
based on 95th Percentile Mercury Concentrations
Recommended Maximum Weekly Intake

(grams per week)
350
300

of Bull Trout during Fish Camps
292
250
200
150
129
106
100
46
50
46
20

(grams per week)
70
60
General Population
Sensitive Adult
Child
25
11
Toddler
Fresh Fish
Dried or Smoked Fish

of Bull Trout during Remainder of the Year
58
50
40
30
26
21
20
10
9
4
General Population
Sensitive Adult
Child
5
2
Toddler
Proj # 0276885-0006 | Graphics # MPF-0001-028i
Similarly, during the remainder of the year, the RMWI of Bull Trout for the general population
based on the 95th percentile of mercury concentrations for fresh fish is 0.058 kg/week and for dried
fish is 0.026 kg/week. The RMWIs are lower for those in the sensitive groups, ranging from
0.005 kg/week fresh fish or for toddlers, 0.009 kg fish/week for children under 12 years of age, and
0.021 kg fish/week for women of childbearing age or those who are pregnant. For dried fish, the
RMWIs are 0.002 kg/week for toddlers, 0.004 kg/week for children under 12, and 0.009 kg/week for
sensitive adults. These RMWIs are also shown graphically in Figure 1. It is probable that people are
consuming more fish than is recommended during the time of year outside of the Fish Camp,
particularly for people in the more sensitive groups.
Hazard quotients were also calculated, based on a ratio of the estimated daily intake of mercury and
the pTDI. When the HQ is greater than 1.0, there could be a risk to human health and additional
investigation should be conducted. During the Fish Camps, the HQs ranged from 31.9 in the general
population to 183.8 in toddlers, based on the consumption rates (4 kg per 3 days for adults attending
Fish Camps) provided during interviews with participants from West Moberly. During the
remainder of the year (assuming a consumption frequency of once per week), the HQs ranged from
2.8 in the general population to 16.1 in toddlers. These HQs suggest that there could be risk to
human health from the consumption of Bull Trout from the Crooked River system.
Consumption of fish has many benefits to health, including physical, mental, cultural, and spiritual
well-being. It is important that people consider both the risks and the benefits of fish consumption in
order to make the most informed decisions about whether or not fish should be eaten.
Based on the findings of this preliminary quantitative HHRA, a number of recommendations for
additional work were made. This includes the urgent need to communicate these results to
individuals who would be considered to have high fish consumption rates and could be at risk of
adverse effects due to mercury. Other recommendations include studies to define the temporal and
spatial trends, monitoring of other fish species, a more detailed assessment of risk to human health,
and preliminary risk assessment for wildlife consumers of fish and for fish health.
iv
ACKNOWLEDGEMENTS
This report was produced for West Moberly First Nations by ERM Rescan. It was written by Bruce
Muir (M.A.) and Dr. Lesley Shelley (Ph.D., R.P.Bio), with statistical analysis (regression analysis and
associated figures) provided by Dr. Kerry Marchinko (Ph.D., R.P.Bio) using the statistical program
R. The report was technically reviewed by Sharon Quiring (M.Sc., CIH). Bruce Muir was the project
manager and Dr. Kent Gustavson (Ph.D) was the Partner-in-Charge. GIS maps were prepared by
Mike Stead, and graphics were prepared by Francine Alford and Jason Widdes. The report was
published by Lloyd Majeau.
The authors would like to thank Chief and Council and the Land Use Department for providing
ERM with the opportunity to work with West Moberly and its members. We would also like to
thank First Nations Health Authority (Environmental Contaminants Program) for providing the
funding for the study. A special thank you goes to the members of McLeod Lake Indian Band and
West Moberly First Nations that participated in the study. Without their contributions the study
would not have been possible.
Plate 1. Participants in the Fish Study

FISH CONTAMINANTS STUDY
Aboriginal Health Risk Assessment of Mercury in Bull
Trout Harvested from the Crooked River,
British Columbia
TABLE OF CONTENTS
Executive Summary ............................................................................................................................................ i
Acknowledgements ........................................................................................................................................... v
Table of Contents .............................................................................................................................................vii
List of Figures ...................................................................................................................................... ix
List of Tables ........................................................................................................................................ ix
List of Plates .......................................................................................................................................... x
List of Appendices............................................................................................................................... xi
Abbreviations ..................................................................................................................................................xiii
1.
2.
Introduction and Approach to Assessment ................................................................................... 1-1

1.1
Overview .............................................................................................................................. 1-1
1.2
Study Area ............................................................................................................................ 1-1
1.3
Human Health Risk Assessment Framework.................................................................. 1-1
Problem Formulation ........................................................................................................................ 2-1

2.1
Data Used to Support the Risk Assessment ..................................................................... 2-1

2.1.1
Traditional Ecological Knowledge ...................................................................... 2-1
2.1.2
Fish Tissue Metals, Fish Age, and Other Biological Data ................................. 2-4
2.1.2.1
2.2
Scope of the Risk Assessment Conceptual Model........................................................ 2-6

2.2.1
3.
Analytical Testing ................................................................................. 2-5
Preliminary Estimate of Distribution of Bull Trout in the Study Area ........... 2-6
Exposure Assessment ....................................................................................................................... 3-1

3.1
Human Receptor Groups.................................................................................................... 3-1
3.2
Concentration of Mercury in Fish ..................................................................................... 3-2
3.3
3.2.1
Concentrations based on the Summary Statistics.............................................. 3-2
3.2.2
Concentrations based on the Use of Regression Relationships ....................... 3-5
Estimated Daily Intake........................................................................................................ 3-9
vii
4.
5.
3.3.1
Serving or Portion Sizes ...................................................................................... 3-10
3.3.2
Patterns in Fish Consumption (Frequency of Consumption) ........................ 3-12
Toxicity Assessment.......................................................................................................................... 4-1

4.1
Potential Effects on Human Health due to Mercury ...................................................... 4-1
4.2
Provisional Tolerable Daily Intake .................................................................................... 4-2
4.3
Adjustment of the Provisional Tolerable Daily Intake to Account for Fish

Consumption Patterns based on Traditional Practices .................................................. 4-3
Risk Characterization........................................................................................................................ 5-1

5.1
5.2
Comparison of Fish Tissue Mercury Concentrations to Tissue Residue

Guidelines ............................................................................................................................. 5-1
5.1.1
Health Canada Maximum Contaminant Standard for Mercury in Fish

Tissue ....................................................................................................................... 5-1
5.1.2
BC Ministry of Environment Aquatic Life Guidelines for Mercury in

Fish Tissue ............................................................................................................... 5-2
5.1.3
Conclusions based on Comparison of Mercury Measured in Fish Tissue

and the Fish Tissue Residue Guidelines ............................................................. 5-3
Recommended Maximum Weekly Intake ........................................................................ 5-4

5.2.1
Calculation of Recommended Maximum Weekly Intake based on the

95th Percentile of Mercury Concentrations ......................................................... 5-5
5.2.2
Calculation of Recommended Maximum Weekly Intake based on Fish

Length ...................................................................................................................... 5-7
5.2.3
Calculation of Recommended Maximum Weekly Intake based on Fish

Weight ................................................................................................................... 5-10
5.2.4
Summary and Conclusions based on Recommended Maximum Weekly

Intakes for Bull Trout........................................................................................... 5-12
5.2.4.1
Consumption of Bull Trout during the Fish Camps ...................... 5-12
5.2.4.2
Consumption of Bull Trout during the Remainder of the Year ... 5-13
5.3
Calculation of Hazard Quotients..................................................................................... 5-14
5.4
Fish Consumption Advisory for the Williston Reservoir ............................................ 5-15
5.5
Summary and Conclusions from Risk Characterization .............................................. 5-18
6.
Importance of Fish Consumption and Traditional Practices to Health ..................................... 6-1
7.
Assumptions, Uncertainties, and Limitations ............................................................................... 7-1
viii
7.1
Fish Tissue Sampled for Laboratory Analysis ................................................................. 7-1
7.2
Sample Size of Fish .............................................................................................................. 7-1
7.3
Proportion of Methylmercury ............................................................................................ 7-1
7.4
Selection of Potential Receptors ......................................................................................... 7-1
7.5
Human Receptor Groups and Receptor Characterization ............................................. 7-2
TABLE OF CONTENTS
8.
7.6
Contaminants of Potential Concern .................................................................................. 7-3
7.7
Mercury Tissue Concentration Guidelines ...................................................................... 7-3
7.8
Adjustment of Methylmercury Provisional Tolerable Daily Intake based on

Consumption Patterns ........................................................................................................ 7-4
Summary and Recommendations ................................................................................................... 8-1

8.1
Summary and Conclusions ................................................................................................ 8-1
8.2
Recommendations ............................................................................................................... 8-3
References ....................................................................................................................................................... R-1
LIST OF FIGURES
Figure 1. Recommended Maximum Weekly Intake of Bull Trout, based on the 95th Percentile
of Mercury Concentrations. ...............................................................................................................iii
Figure 1.2-1. Study Area for the Aboriginal Fisheries in the Crooked River System ........................... 1-2
Figure 2.1-1. Fish and the Traditional Seasonal Round ............................................................................ 2-2
Figure 2.2-1. Potential Access Barriers for Bull Trout in the Williston Reservoir and its
Tributaries .......................................................................................................................................... 2-7
Figure 3.2-1. Mercury Tissue Concentrations (in mg/kg ww) Measured in Individual Bull
Trout and Northern Pikeminnow, May 2012 ................................................................................ 3-3
Figure 3.2-2. Frequency Distribution of the Mercury Tissue Concentrations (in mg/kg ww)
Measured in Bull Trout, May 2012.................................................................................................. 3-4
Figure 3.2-3. Regression Relationship between Age (in years) and Mercury Tissue
Concentrations (in mg/kg ww) for Bull Trout ............................................................................. 3-6
Figure 3.2-4. Regression Relationship between Length (in mm) and Mercury Tissue
Figure 3.2-5. Regression Relationship between Weight (in kg) and Mercury Tissue
LIST OF TABLES
Table 1. BC Ministry of Environment Aquatic Life Guidelines for Mercury in Fish and
Comparison with Measured Mercury Tissue Residues from Bull Trout ..................................... ii
Table 3.2-1. Mercury Tissue Concentrations in Bull Trout and Northern Pikeminnow from the
Crooked River system, May 2012.................................................................................................... 3-2
Table 3.3-1. Values Used in the Calculation of Estimated Daily Intake ............................................... 3-10
ix
Table 5.1-1. Length and Weight of Bull Trout Estimated to have Tissue Concentrations of
Mercury Exceeding Health Canada Maximum Contaminant Standard ................................... 5-2
Table 5.1-2. BC Ministry of Environment Aquatic Life Guidelines for Mercury in Fish and
Comparison with Measured Mercury Tissue Residues from Bull Trout .................................. 5-2
Mercury Exceeding BC Ministry of Environment Tissue Residue Guidelines......................... 5-3
Table 5.2-1. Recommended Maximum Weekly Intake of Bull Trout based on Summary
Statistics and Human Receptor Group ........................................................................................... 5-6
Table 5.2-2. Recommended Maximum Weekly Intake of Bull Trout during the Fish Camps
based on Fish Length and Human Receptor Group..................................................................... 5-8
Table 5.2-3. Recommended Maximum Weekly Intake of Bull Trout during the Remainder of
the Year based on Fish Length and Human Receptor Group ..................................................... 5-9
Table 5.2-4. Recommended Maximum Weekly Intake of Bull Trout during the Fish Camps
based on Fish Weight and Human Receptor Group .................................................................. 5-11
Table 5.2-5. Recommended Maximum Weekly Intake of Bull Trout during the Remainder of
the Year based on Fish Weight and Human Receptor Group................................................... 5-12
Table 5.3-1. Risk Characterization for Mercury Intake from Bull Trout during Fish Camps and
Remainder of the Year .................................................................................................................... 5-15
LIST OF PLATES
Plate 1. Participants in the Fish Study ............................................................................................................ v
Plate 2.1-1. Example of bait (i.e., Peamouth) used by West Moberly to catch Bull Trout on the
Crooked River, BC............................................................................................................................. 2-3
Plate 2.1-2. Fish harvested via gill nets at culture camps in the Study Area during the summer
months. ............................................................................................................................................... 2-3
Plate 2.1-3. Example of Bull Trout harvested from the Crooked River, BC. .......................................... 2-4
Plate 2.1-4. Photo of fish sampling, including measurement of fish length and weight,
September 2012 .................................................................................................................................. 2-5
Plate 3.1-1. Youth at the Fish Camp on the shores of the Crooked River, BC. ...................................... 3-1
Plate 3.3-1. Example of how traditional foods are provided at culture camps. Meats are
prepared in different traditional ways throughout the day and evening for participants
and visitors to eat when they are hungry. ................................................................................... 3-11
Plate 3.3-2. West Moberly member with Bull Trout that were prepared for consumption at a
later date. .......................................................................................................................................... 3-13
TABLE OF CONTENTS
Plate 4.3-1. Bull Trout harvested in the fall season from the Carbon Creek, south of the Peace
Reach of the Williston Reservoir. .................................................................................................... 4-4
Plate 4.3-2. Lake Trout harvested by West Moberly members. ............................................................... 4-4
Plate 5.2-1. Youth (i.e., under 12 years of age) with a Bull Trout harvested from the Crooked
River, BC, in 2008 at Fish Camp. ..................................................................................................... 5-4
Plate 5.2-2. Bull Trout harvested by a youth during the fall season in the Peace region. .................... 5-5
Plate 5.4-1. Pre-Construction and Flooding BC Hydros W.A.C. Bennett Hydroelectric Dam
and the Williston Reservoir. .......................................................................................................... 5-16
Plate 5.4-2. Post-Construction and Flooding BC Hydros W.A.C. Bennett Hydroelectric Dam
and the Williston Reservoir. .......................................................................................................... 5-16
Plate 5.4-3. Example of a non-aboriginal youth that harvests Bull Trout ............................................ 5-17
Plate 6-1. Father teaching his sons West Moberlys TEK regarding safety and respect for the land,
family history, and fishing practices regarding Bull Trout in the Crooked River system. .......... 6-1
Plate 6-2. West Moberlys Fish Camp on the shores of the Crooked River, BC. ................................... 6-2
LIST OF APPENDICES
Appendix A.
Raw Data from Biological Measurements of Fish from the Crooked River,
September 2012
Appendix B.
Raw Aging Analysis Results for Fish from the Crooked River, September 2012
Appendix C.
Raw Tissue Metal Analysis Results for Fish from the Crooked River, September 2012
xi
ABBREVIATIONS
Terminology used in this document is defined where it is first used. The following list will assist
readers who may choose to review only portions of the document.
ATSDR
Agency for Toxic Substances and Disease Registry
BC
British Columbia
BC MOE
British Columbia Ministry of Environment
BW
Body weight
CCME
Canadian Council of Ministers of the Environment
cm
Centimeter
COPC
Contaminant of potential concern
dw
Dry weight
EDI
Estimated daily intake
Fs
Fraction of time eating fish
HHRA
Human health risk assessment
HQ
Hazard quotient
ICP-MS
Inductively Coupled Plasma Mass Spectroscopy
IRIS
Integrated Risk Information System
JECFA
Joint Expert Committee on Food Additives and Contaminants
kg
Kilograms
mg
Milligrams
MLIB
McLeod Lake Indian Band
mm
Millimeter
MRL
Minimal risk level
pTDI
Provisional tolerable daily intake
QA/QC
Quality Assurance/Quality Control
RfD
Oral reference dose
xiii
RMWI
Recommended maximum weekly intake
Study Area
Crooked River watershed in northeast British Columbia
TEK
Traditional ecological knowledge
TDI
Tolerable daily intake
TRV
Toxicity reference value
UCLM
Upper confidence limit of the mean
US EPA
United States Environmental Protection Agency
West Moberly
West Moberly First Nations
WHO
World Health Organization
ww
Wet weight
xiv
1.
INTRODUCTION AND APPROACH TO ASSESSMENT
1.1
OVERVIEW
Fish in the lakes, rivers, and creeks of Dunne-za hanan (the land of the Beaver people) are
important to West Moberly First Nations (West Moberly) mode of life. Increased industrial
activities in recent years, coupled with past developments, has become a serious concern for
members of West Moberly with respect to the safety of using aquatic species that are traditionally
harvested and gathered in accordance with the seasonal round. Many were particularly concerned
about the extent to which the aquatic environment had been adversely impacted as a result of the
construction of the W.A.C. Bennett hydroelectric dam that created the Williston Reservoir in
northeast British Columbia (BC).
Based on the request of members to investigation the potential adverse health effects from mercury
in fish harvested from the Aboriginal fisheries on the Crooked River, BC, West Moberly submitted a
funding application to the Environmental Contaminants Program of the First Nations Health
Authority, which was approved in 2014. This report provides the results of the study that was
undertaken to determine the heath risks of consuming Bull Trout harvested in the Crooked River
system in accordance with the traditional seasonal round.
1.2
STUDY AREA
The area selected for the study (Figure 1.2-1) has been identified as the Aboriginal fisheries in the
Crooked River system in northeast British Columbia (the Study Area). Temporally, the Study Area
has been a part of the land base that forms the seasonal round of West Moberly for a period that
predates the arrival of Europeans in Dunne-za hanan and continues to this day. Past and present
traditional land uses in the Study Area include hunting, fishing, trapping, and gathering activities,
including, among other things, the traditions, customs, and practices that are incidental in nature
(collectively, cultural activities). Many, if not all, cultural activities include a commercial
component, such as the selling or trading of goods and services. West Moberly noted it is planning
for such cultural activities to continue well into the future.
1.3
HUMAN HEALTH RISK ASSESSMENT F RAMEWORK
The assessment of risk to human health due to incidental ingestion of contaminants in fish is the
main objective of this study. Human health risk assessment (HHRA) frameworks provide guidance
on how to assess this type of risk. Federal HHRA guidance for screening level risk assessments was
used in this assessment, including supplemental guidance specific to the assessment of risk due to
consumption of country foods (Health Canada 2010c, 2010d, 2010a). Generally, HHRAs consist of
five main components, which will be included in this assessment:
1-1
Figure 1.2-1
Study Area for the Aboriginal Fisheries
in the Crooked River System
500000
6125000
.
!
525000
550000
Mackenzie
Williston
Lake
6100000
6100000
Tudyah
Lake
6125000
475000
McLeod Lake !
.
rs n
Pa
6075000
ive
6075000
R
ip
McLeod
Lake
97
Cro oked
Carp Lake
R iv
6050000
6050000
er
6025000
6025000
Great Beaver Lake
Summit
Lake
6000000
.
!
Community
Railway
Highway
Study Area
1:650,000
12.5
Kilometres
March 13, 2015
Projection:
UTM10,
NAD83
Projection: NAD
1983 UTM
Zone 10N
WEST MOBERLY FIRST NATIONS - Crooked River Fisheries
Contains information licensed under the Open

Government Licence British Columbia and
Canada.
Source: Esri, DigitalGlobe, GeoEye, i-cubed,
USDA, USGS, AEX, Getmapping, Aerogrid,
IGN, IGP, swisstopo, and the GIS User
Community
25
475000
ive
500000
525000
6000000
R
ser
Fra
550000
Proj # 0276885-0006 | GIS # CRF-15-002
INTRODUCTION AND APPROACH TO ASSESSMENT
1. Problem Formulation
Problem formulation describes the conceptual model for conducting the risk assessment,
setting the context for the scope of the assessment (i.e., what will be assessed). This includes
identification of exposure route(s) and the food(s) being assessed, contaminants of potential
concern (COPCs), and potential receptors.
2. Exposure Assessment
The exposure assessment stage of the HHRA determines the estimated exposure to COPCs.
The exposure assessment takes into account any site-specific information that is available, or
uses literature-derived data in the absence of site-specific data.
3. Toxicity Assessment
The tolerable daily intake (TDI) of a COPC is the amount of a contaminant that can be taken
into the body without experiencing adverse effects. The TDI will be determined based on a
search for TDIs defined by Health Canada, the United States Environmental Protection
Agency (US EPA), the World Health Organization (WHO), the Agency for Toxic Substances
and Disease Registry (ATSDR).
4. Risk Characterization
Both federal (Health Canada) and provincial (BC Ministry of Environment [BC MOE])
governments provide guidelines for fish tissue residues for mercury for the protection of
human consumers. These guidelines will be considered in the risk characterization.
In addition, the exposure assessment and toxicity assessment are integrated so that the risk
to human health is quantitatively described.
5. Uncertainties and Limitations
The assumptions made throughout the assessment are described, with consideration of how
the assumptions affect the confidence in the assessment. Any limitations to the analysis are
described.
1-3
2.
PROBLEM FORMULATION
2.1
DATA USED TO SUPPORT THE RISK ASSESSMENT
2.1.1
Traditional Ecological Knowledge
Traditional ecological knowledge (TEK) of West Moberly includes, for example, information
regarding species of fish, fish habitat, and fishing practices in the Crooked River system.
An overview of the traditional seasonal round regarding which species of fish are targeted is
illustrated in Figure 2.1-1.
In the spring each year, West Moberly sets up cultural camps (Fish Camps) to facilitate harvesting
of fish, particularly Bull Trout (Salvelinus confluentus), in the Study Area. Based on the First Nations
TEK, Bull Trout historically migrated from larger watercourses (e.g., Parsnip, Finlay, and Peace
rivers) into smaller watercourses, such as the Crooked River. With the construction of the W.A.C.
Bennett hydroelectric dam and the subsequent impoundment of water that flooded 1,700 km2 of
land and considerable portions of the Parsnip and Finlay rivers and their tributaries, all of which
formed the Williston Reservoir, TEK indicates that the species now migrates from the Williston
Reservoir into the smaller watercourses. These fish are then caught during the Fish Camps within
the Crooked River system.
The methods used to fish in the springtime vary to some extent. Bull Trout were previously harvested
via nets and other traditional means, such as tree limbs and lines. Tissues from other species of fish were
also used as an enticement technique (i.e., bait). Use of fishing poles is the primary technique that is
currently used; this is not to say, however, that other methods are not used during the spring as well.
Fresh tissue from other fish species is still used, specifically from the Peamouth (Mylocheilus caurinus),
which is the preferred species to use as bait (see Plate 2.1-1). This is largely because Bull Trout have
migrated into the Crooked River system to feed on the Peamouth, which spawns during the spring.
Fish are not randomly harvested (Plate 2.1-2 and 2.1-3). Selection of Bull Trout in the springtime
varies depending on TEK and cultural requirements. As such, the amount of fish that are harvested
and the sizes fluctuate from year to year. Fish are consumed on-site and off-site. Members from as
far away as Vancouver, British Columbia, travel to the Fish Camps to participate in the cultural
activities. In terms of the quantity of fish that is consumed at Fish Camp, West Moberly members
noted that approximately 4 kg of fish is likely to be consumed by each adult per 3 days.
Most use one of two techniques when preparing a Bull Trout for consumption: (1) a fish is cleaned and
smoked over an open fire, after which the dried pieces are placed into bags that are then distributed
amongst family, friends, and potentially others (e.g., commercial activities); and (2) a fish is cleaned,
cooked whole, and consumed during a meal by one or more people. Cooking techniques vary, as a fish
may be pan fried along the side of the river whereas it is likely to be cooked on a barbeque or in an oven
when individuals are at home. Some also bring the fish home for drying and smoking. All ages and
both male and female members of West Moberly are likely to consume fish from the spring harvest.
Filets of fish were not discussed as a means by which the fish are prepared and then consumed.
2-1
Figure 2.1-1
Fish and the Traditional Seasonal Round
June
SU
M
Ju
ri
ly
Ap
G
IN l
ER
M
SP
R
May
n
de ike
ar
P
nnow
rn
emi
r
Pik
g
rn
ylin
he Gra
ic
ary
Febru
Sep
temb
er
Marc
h
ust
Aug
Bu
ll
Tr
Do
lly o
No
V
r
Su the
ck
e
No
r
Ar t
ct
ut
ob
er
ou
t
ct
O
TE
R
Dec
embe
r
LL
IN
W
h
fis
t
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W e Tr
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La bot
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Bu
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bo
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Ja
Ra
ua
ry
FA
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Nove
Proj # 0276885-0006 | Graphics # MPF-0001-028g
PROBLEM FORMULATION
Plate 2.1-1. Example of bait (i.e., Peamouth) used by

West Moberly to catch Bull Trout on the Crooked
River, BC.
Plate 2.1-2. Fish harvested via gill nets at culture camps in the Study Area during the
summer months.
2-3
Plate 2.1-3. Example of Bull Trout harvested from

the Crooked River, BC.
2.1.2
Fish Tissue Metals, Fish Age, and Other Biological Data
Fish were collected from the Study Area in May 2012 by members from McLeod Land Indian Band
(MLIB) and West Moberly as part of cultural activities at that time. Of the numerous fish that were
harvested in 2012 by each First Nation, a total of 57 Bull Trout (Salvelinus confluentus) and 3 Northern
Pikeminnow (Ptychocheilus oregonensis) were submitted for testing by the participants. The largest
reported Bull Trout was 22 lbs., which was caught by a member of MLIB; however, the member did not
submit the fish or a portion of the fish for testing. The fish were frozen until they could be sampled in
September 2012. Sampling of frozen fish was conducted on September 13 and 14, 2012. Frozen fish were
measured for length and weight and then the heads and tails were removed from frozen fish using a
reciprocating saw (Plate 2.1-4).The fish were repackaged and returned to a freezer, as participants
requested that the fish be returned should the test results demonstrate that the fish were safe to consume.
A cross section from the caudal peduncle was removed and placed in an individually labelled
Whirl-Pak bag. The tissue samples were immediately re-frozen and shipped to ALS Environmental
in Burnaby for analysis of moisture content and metal concentrations. Fish heads were allowed to
thaw overnight and then dissected to remove otoliths for aging analysis. Aging samples were sent to
North-South Consultants in Winnipeg for analysis. Raw data from biological measurements are
presented in Appendix A.
2-4
PROBLEM FORMULATION
Plate 2.1-4. Photo of fish sampling, including measurement of fish length and weight,
September 2012
2.1.2.1
Analytical Testing
Aging Analysis
Otoliths were set in epoxy and left to cure for 48 hours. The nucleus was marked under a microscope
and the otoliths were subsequently sectioned using a low speed sectioning saw, leaving the nucleus
in the section. Finally otoliths were permanently mounted on a microscope slide. Ages were
determined for all otoliths by one technician, while 10% of samples were randomly chosen for
re-analysis by a separate technician to provide Quality Assurance/Quality Control (QA/QC) of the
aging results. Raw aging data results are presented in Appendix B.
Tissue Metals Analysis
ALS Environmental analyzed the tissue samples for metals concentrations according to standard
procedures adapted from the US EPA (1995, 1996, 2007). Samples were divided into two parts at
the laboratory: one part for measurement of metal concentrations on a wet weight (ww) basis
(in mg/kg ww) and a second part for measurement of percent moisture so that the results could
be converted to mg/kg dry weight (mg/kg dw), if required.
Each sample was homogenized either mechanically or manually prior to digestion. The hotplate
digestion method involved the use of nitric acid followed by repeated additions of hydrogen peroxide.
Total concentrations of 24 metals were measured by Inductively Coupled Plasma Mass Spectroscopy
(or ICP-MS). In addition, mercury was measured from each sample. Raw data, including detection
limits, are presented in Appendix C. Laboratory-split duplicate QAIQC samples were conducted for
2-5
five samples. One of the five samples had a relative percent difference of 67%, which is higher than
generally acceptable. This suggests that some samples may not have been fully homogenized.
2.2
SCOPE OF THE RISK A SSESSMENT CONCEPTUAL MODEL
For the purposes of the current assessment, the scope is limited to contaminant exposures from
consumption of fish by humans. Other potential exposure routes for COPCs will not be included,
and the health of fish populations is not considered.
The assessment will focus on Aboriginal consumers of fish from the Crooked River system, since
available data suggests that Aboriginal peoples would have the highest consumption rates for fish in
this area (Section 2.1; Health Canada 2010d). Traditional knowledge data collected during interviews
with participants from West Moberly (described in Section 2.1.1) will be used in the Exposure
Assessment (Section 3) to help define the level of exposure through fish consumption. It is
acknowledged that other potential receptors may also consume fish from this system (e.g., other local
residents, sport fishers, tourists), but these populations are not explicitly considered in the assessment.
The assessment will be based on tissue metal data from the fish that were caught in May 2012 in the
Crooked River system (Figure 1.2-1). This included 57 Bull Trout and 3 Northern Pikeminnow, as
described in Section 2.1.2. Due to the limited sample size for Northern Pikeminnow, which were
collected and tested at the request of an Elder from MLIB, the assessment will predominantly be
based on tissue metal data for Bull Trout.
The assessment will be limited to consideration of mercury in fish tissue. Data for fish tissue
concentrations of metals other than mercury is provided in Appendix C, but is not considered in the
risk assessment. Consideration of risk to human health due to the incidental consumption of these
other metals in fish tissue can be evaluated at a later date (see Section 8.2 for recommendations).
2.2.1
Preliminary Estimate of Distribution of Bull Trout in the Study Area
Bull Trout are a highly migratory fish species, and may move long distances within a watershed.
In order to provide a preliminary assessment of the potential distribution of Bull Trout within the
study area (Figure 1.2-1), potential barriers to fish movement were identified. Fish barriers were
identified only as waterfalls or velocity barriers; it is possible that there are additional barriers to fish
movement that have not been included in Figure 2.2-1 (e.g., habitat limitations, water quality or
quantity barriers).
Hagen and Decker (2011) noted that Bull Trout may be located in approximately 26 of the
36 Ecological Drainage Units that have been delineated in BC, which may include roughly
1,000 tributaries watersheds. As such, and based on a preliminary assessment of the potential fish
barriers shown in Figure 2.2-1, it is possible that Bull Trout could have a fairly wide distribution
with the ability to migrate between different sub-watersheds within the headwaters of the Peace
River sub-basin, which ends at the site of the W.A.C. Bennett hydroelectric dam. Fish that were
harvested from the Crooked River system may not necessarily be resident in this river and could
move to and from the many different rivers, creeks, and lakes within the Upper Peace watershed
(see, e.g., Figure 1 of Hagen and Decker, 2011).
2-6
Figure 2.2-1
Potential Access Barriers for Bull Trout
in the Williston Reservoir and its Tributaries
1100000
1200000
.
!
Community
Falls (3 metres)
Velocity barrier
Assumed Fish Presence
Restricted Fish Presence
Highway
Secondary Road
Williston Watershed
Study Area
F F
1:2,600,000
50
R i ve r
1400000
100
1500000
1000000
1400000
1500000
900000
Kilometres
Date: April 08, 2015

Projection: NAD 1983 BC Environment Albers
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Contains information licensed under the Open

Government Licence British Columbia and Canada.
Source: Esri, DigitalGlobe, GeoEye, Earthstar
Geographics, CNES/Airbus DS, USDA, USGS, AEX,
Getmapping, Aerogrid, IGN, IGP, swisstopo, and the
GIS User Community
WEST MOBERLY FIRST NATION
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Proj # 01276885-0006 | GIS # CRF-15-004
3.
EXPOSURE ASSESSMENT
The objective of the exposure assessment is to determine the amount of exposure to mercury, which
is dependent on human receptor (consumer) characteristics, as well as the concentration of mercury
in fish tissue.
3.1
HUMAN RECEPTOR GROUPS
Based on TEK (Section 2.1.1), Aboriginal consumers of fish are expected to include people of all age
groups and both genders (Plate 3.1-1). The risk to people from mercury present in fish tissue is
known to vary with age of the consumer; children, pregnant women, and women of child-bearing
age considered to be the most sensitive populations (see Section 4).
Plate 3.1-1. Youth at the Fish Camp on the shores of the Crooked River, BC.
Health Canada (2007) considers people over the age of 12 to have sensitivity for mercury similar to
the general adult population. Therefore, the following age groups will be considered in the
assessment:
toddlers, aged 1 to 4 years;
children, aged 5 to 12 years;
sensitive adult population; and
general adult population.
3-1
3.2
CONCENTRATION OF MERCURY IN FISH
Total mercury concentrations were measured in the fish tissue sent to ALS Environmental.
Methylmercury is the form of mercury that is of greatest concern to human health (i.e., most toxic
form of mercury to humans; Section 4). For fish, it is typically assumed that 100% of the total
mercury concentration is in the form of methylmercury, although the proportion of methylmercury
might be slightly less than 100% (Bloom 1992; Health Canada 2007). Since the actual concentrations
of methylmercury are likely less than the total mercury concentration, this assumption ensures that
the risk assessment is adequately conservative. Throughout the remainder of this report, the terms
mercury and methylmercury will be used interchangeably.
The tissue samples of fish were collected from the caudal penduncle area (near the tail) of the fish.
It is assumed for the purposes of the assessment that these tissue samples are representative of the
concentrations of mercury throughout the body of the fish that could be consumed.
All fish, except for Fish #46, had detectable concentrations of mercury in tissue samples. For the
purposes of calculations and statistics, the mercury concentration in Fish #46 was assumed to be
equivalent to the method detection limit of 0.001 mg/kg ww. This is a conservative assumption
since the lab analysis found that the concentration was less than the method detection limit.
3.2.1
Concentrations based on the Summary Statistics
Summary statistics for the concentration of mercury in Bull Trout and Northern Pikeminnow
collected from the Crooked River system are shown in Table 3.2-1. Concentrations of mercury
measured in each individual fish is shown in Figure 3.2-1, and a frequency distribution of the
mercury tissue concentrations in Bull Trout is shown in Figure 3.2-2.
Table 3.2-1. Mercury Tissue Concentrations in Bull Trout and Northern Pikeminnow from the
Crooked River system, May 2012
Concentration of Mercury (mg/kg ww)
Mean
Standard
Deviation of
the Mean
95% Upper
Confidence Limit
of the Mean
Minimum
57
0.419
0.225
0.479
<0.001
0.796
1.000
0.885
0.119
N/A
0.759
N/A
0.996
Number
of Fish
Bull Trout
Northern
Pikeminnow
95th
Percentile Maximum
Notes:
ww = wet weight
N/A = not applicable; the sample size is not considered large enough to calculate these statistics
The 95% upper confidence level of the mean (UCLM) is often used in risk assessment to provide a
conservative estimate of the mean concentration of a COPC. However, in this study, where mercury
concentrations in fish tissue were significantly correlated with age, length, and weight of the fish
(see Section 3.3), the 95% UCLM of the whole dataset (n = 57) may not be conservative enough.
This is because mercury concentrations increase with the age, length, and weight of the Bull Trout,
and the fish sampled were of widely varying ages, lengths, and weights.
3-2
Sample
Figure 3.2-1
Mercury Tissue Concentrations (in mg/kg ww) Measured in
Individual Bull Trout and Northern Pikeminnow, May 2012
3
2
1
57
56
55
54
53
52
51
50
49
48
47
46
45
44
43
42
41
40
39
38
37
36
35
34
33
32
31
30
29
28
27
26
25
24
23
22
21
20
19
18
17
16
15
14
13
12
11
10
9
8
7
6
5
4
3
2
1
0.0
0.2
0.4
0.6
0.8
1.0
1.2
Concentration of Mercury in Fish Tissue (mg/kg ww)

Note: ww = wet weight
Northern Pikeminnow
Bull Trout
Proj # 0276885-0006 | Graphics # MPF-0001-028f
Figure 3.2-2
Frequency Distribution of the Mercury Tissue Concentrations
(in mg/kg ww) Measured in Bull Trout, May 2012
18
16
Number of Samples
14
12
10
8
6
4
2
0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1.0
Concentration of Mercury in Bull Trout Tissue (mg/kg ww)

Proj # 0276885-0006 | Graphics # MPF-0001-028a
EXPOSURE ASSESSMENT
Larger fish (i.e., those of increased length or weight) would be most desirable for harvesting, and
these fish are associated with the highest concentrations of mercury (i.e., concentrations well above
the mean concentration). Using a 95% UCLM to represent mercury concentrations in the whole
population has the potential to underestimate the risk, particularly when eating fish that are older or
bigger than the average. The same is true for using the mean concentration of mercury in fish.
In contrast, the 95th percentile of mercury concentrations in fish tissue represents the concentration
for the majority of the population of fish (i.e., 95% of the fish would be expected to have a tissue
concentration below this level). The maximum concentration is the highest concentration of mercury
measured in any Bull Trout from 2012.
Risk calculations based on either the 95th percentile or the maximum concentration of mercury
would be the most conservative compared to other statistics. Conversely, the use of the
95th percentile concentration in risk calculations has the potential to overestimate the risk for fish
consumption as a whole. For example, if only smaller fish with lower mercury concentrations are
consumed, the calculations based on the 95th percentile could significantly overestimate risk.
The same is true for the use of the maximum mercury concentration in fish tissue.
However, an objective of this study is to evaluate risk in a way that ensures risk is not
underestimated. Therefore, conservative assumptions should be used throughout the assessment.
Therefore, for the purposes of determining risk, the 95th percentile of mercury concentrations in fish
tissue is a reasonably conservative value that represents the upper end of mercury concentrations
that were measured in Bull Trout from 2012.
3.2.2
Concentrations based on the Use of Regression Relationships
Regression analysis of the Bull Trout data found that there was a significant relationship between
the age of the fish and mercury concentrations in tissue (Figure 3.2-3). The regression relationship
between the age of fish and mercury concentration in tissue is:

= 0.06
0.03
[Equation 1]
The Northern Pikeminnow that were sampled were older (26 and 30 years, one fish was not
included in aging analysis) than the Bull Trout (average age of 7, n = 57). However, only three
Northern Pikeminnow were sampled, which precludes the ability to compare trends in mercury
accumulation between species of fish.
Although the regression relationship based on age was significant, age of fish is not something that
can be determined easily in the field (i.e, aging of fish requires samples to be sent to the lab).
Therefore, the regression relationships based age will not be discussed further in this assessment.
Significant correlations between mercury concentrations in tissue and length or weight (wet weight
basis) were also found when analyzing the Bull Trout data using regression analysis (Figures 3.2-4
and 3.2-5). Concentrations of mercury in fish tissue increase with increasing length or weight.
The regression relationship between the length (in millimeters, mm) and mercury concentration
(in mg/kg ww) in Bull Trout tissue is:
3-5
Figure 3.2-3
Regression Relationship between Age (in years) and
Mercury Tissue Concentrations (in mg/kg ww) for Bull Trout
1.2
Concentration of Mercury in Fish Tissue (mg/kg ww) = 0.06 (Age) - 0.03

n = 57, adjusted r = 0.405, P < 0.001
1.0
0.8
0.6
0.4
0.2
0.0
4
10
12
14
16
Age of Fish (years)

Proj # 0276885-0006 | Graphics # MPF-0001-028b
Figure 3.2-4
Regression Relationship between Length (in mm) and
1.2
Concentration of Mercury in Fish Tissue (mg/kg ww) = 0.0015 (length) - 0.36

n = 57, adjusted r = 0.639, P < 0.001
1.0
0.8
0.6
0.4
0.2
0.0
400
500
600
700
800
Length of Fish (mm)

mm = millimeters
Proj # 0276885-0006 | Graphics # MPF-0001-028c
Figure 3.2-5
Regression Relationship between Weight (in kg) and
1.2
Concentration of Mercury in Fish Tissue (mg/kg ww) = 0.14 (weight) + 0.18

n = 57, adjusted r = 0.617, P < 0.001
1.0
0.8
0.6
0.4
0.2
0.0
1
Weight of Fish (kg/ww)

Proj # 0276885-0006 | Graphics # MPF-0001-028d
EXPOSURE ASSESSMENT
= 0.0015
0.36
[Equation 2]
The regression relationship between the weight (in kg) and mercury concentration (in mg/kg ww)
in Bull Trout tissue is:

= 0.14 "
+ 0.18
[Equation 3]
Although this makes the risk calculations more complicated, the use of the regression relationships
provides the best estimate of the risk for consumption of fish of various lengths and weights.
Consumers of the fish can get a better sense of the level of risk posed by fish of a particular size or
weight, and could adjust their personal consumption rates of fish based on fish length or weight.
This calculation goes beyond what is normally done in a preliminary quantitative risk assessment,
since the calculations are more detailed and provide a less conservative (and potentially more
accurate) estimate of risk.
3.3
ESTIMATED DAILY INTAKE
As part of a typical exposure assessment the estimated daily intake (EDI, in mg/kg bw/day) of
mercury from fish is calculated. In addition to the concentration of mercury in fish tissue, the EDI is
dependent on the ingestion rate of the consumer and the fraction of time in which fish is consumed.
To calculate the EDI of mercury, the following equation is used (Health Canada 2010a):
&'( =
)* +,-./ 0.
12
[Equation 4]
where:
EDI =
IR =
Cfood =
FS =
BW =
estimated daily intake of mercury from fish (mg mercury/kg bw/day)

ingestion rate of fish (kg fish/day)
concentration of mercury in fish (mg mercury/kg fish)
fraction of time eating fish (unitless)
body weight (kg bw)
Whenever possible, human receptor characteristics will be defined based on information collected
during the interviews with participants from West Moberly (see Section 2.1.1). In the absence of
specific or quantitative data, receptor characteristics recommended by Health Canada will be used
(Richardson 1997; Health Canada 2007, 2010a).
The concentration of mercury to be used in the calculation of EDI is the 95th percentile measured in
Bull Trout in 2012 (Table 3.3-1, or Section 3.2 and Table 3.2-1). This statistic was selected for the
calculation of the EDI because the 95th percentile is a reasonably conservative measure of the upper
end of the distribution of mercury tissue residues from Bull Trout sampled in 2012. This value is
sufficiently conservative to be protective of human health, independent of fish size (weight or length).
3-9
Table 3.3-1. Values Used in the Calculation of Estimated Daily Intake

Toddler (1-4 years)
Parameter
Ingestion Rate
Children (5-12 years)
Body Weight
General Population
During
Fish
Camps
Remainder
of Year
During
Fish
Camps
Remainder
of Year
During
Fish
Camps
Remainder
of Year
During
Fish
Camps
Remainder
of Year
0.665
kg/day
0.082
kg/day
1.10
kg/day
0.136
kg/day
1.33
kg/day
0.132
kg/day
1.33
kg/day
0.163
kg/day
0.14
1.0
0.14
0.796 mg/kg ww
Mercury
Concentration
(95th Percentile)
Fraction of Time
Eating Fish
Sensitive Adults
1.0
0.14
14.4 kg
1.0
0.14
26.4 kg
1.0
60 kg
70.7 kg
The body weights used in the assessment are the ones recommended by Richardson (1997). For the
sensitive adult population, the body weight is based on an adult woman of childbearing age. Body
weights for each human receptor group are summarized in Table 3.3-1.
Because site-specific data is not available to guide the selection of appropriate consumption rates
(Section 3.3.1) and frequencies (Section 3.3.2) for Aboriginal consumers engaged in traditional
fishing activities, there is uncertainty in the calculation of an EDI. Assumptions based on the TEK
data (Section 2.1.1) and available literature have been used to enable the calculation of an EDI.
The EDI is then compared to the toxicity reference value (TRV) derived in the Toxicity Assessment
(Section 4) to derive a hazard quotient (HQ) used for risk characterization (Section 5.3).
The values for use in Equation 4 to calculate the EDI are described in the following sections and are
summarized in Table 3.3-1.
3.3.1
Serving or Portion Sizes
The ingestion rate of fish for Aboriginal consumers is difficult to estimate, given the traditional
manner in which food is prepared and consumed (Plate 3.3-1). This is particularly the case when the
spring harvest of Bull Trout is underway since a fish may be caught, prepared, cooked, and shared
at the Fish Camps with multiple individuals, including visitors from other First Nations and
non-aboriginals. Fish may also be canned, which would likely result in mercury concentrations
similar to that of fresh fish (i.e., wet weight concentrations). Fish could also be dried, with randomly
sized pieces placed into bags for consumption later in either the short-term or long-term. For the
purposes of calculating an EDI, only the consumption of fresh fish was considered because no
site-specific information was available and consumption rates for dried fish for relevant populations
could not be found in literature.
Analysis of qualitative data collected as part of the interviews with West Moberly participants
(Section 2.1.1) found that people do not think about fish consumption in terms of fillets or portion
sizes, but rather in a cultural context (i.e., whole fresh fish and dried fish). Formalized collection of
quantitative data for serving sizes of meals or daily consumption amounts was not done as part of
3-10
EXPOSURE ASSESSMENT
the interviews with participants from West Moberly engaged in traditional fishing activities at the
Fish Camps or consuming fish at other times of the year (Section 2.1.1). However, it was estimated
by participants that an adult could consume up to 4 kg of fish within a 3 day period while in
attendance at the Fish Camps (Section 2.1.1); this equates to 1.33 kg/day for adults and this serving
size was used in the calculation of the EDI.
Plate 3.3-1. Example of how traditional foods are provided at culture camps. Meats are
prepared in different traditional ways throughout the day and evening for participants
and visitors to eat when they are hungry.
Fish consumption during the remainder of the year was not estimated quantitatively so literature
was consulted to define ingestion rates in kg/day. However, this contributes greater uncertainty to
the calculations, and it is recommended that site-specific data be collected for use in a more detailed
risk assessment.
Health Canada (2007) used a fish portion size of 0.150 kg for adults in their risk assessment for
mercury in retail fish, and recommends the use of this portion size.
Richardson (1997) provides a mean fish consumption of 0.044 kg/day (individuals >12 years of age,
both sexes) for First Nations in Canada, which was obtained from a Nutrition Canada Survey using a
24-hour consumption survey. Higher consumption rates were calculated for a fish-eater group (only
25% of the study participants reported eating fish in the previous day), which excluded the data from
individuals that reported zero fish consumption. Amongst the fish-eater group, the consumption
rates were: toddlers, 0.094 kg/day; children 0.165 kg/day; sensitive adults, 0.197 kg/day; and
0.217 kg/day for adult men (general population). However, this study did not distinguish between
First Nations and Inuit populations and included participants from across Canada.
3-11
Chan et al. (2011) conducted a survey of Aboriginal peoples living on reserves in BC. One of the
limitations of this study is that it focused on First Nations individuals living on reserves, who may not
have the same consumption patterns as First Nations individuals living outside of the territory.
This study found that the portion size for fish for adult women ranged from 0.087 to 0.132 kg and for
adult men portion size ranged from 0.100 to 0.163 kg, which averages out to close to the value of
0.150 kg used by Health Canada (2007). Since the Chan et al. (2011) study is more recent, differentiates
between male and female consumption rates, and is based on Aboriginal (on-reserve) fish consumers
in British Columbia, the portion sizes at the upper end of the ranges for adult men and women were
used in this assessment for the general population and sensitive adult population, respectively.
Based on the available data from TEK interviews (Section 2.1.1), it was assumed that toddlers and
children consume fish at the same meals as adults. Since site-specific information is not available
about portion sizes, a portion size adjustment based on proportions was used to determine fish
consumption for these groups, using values recommended by Health Canada (2007). Toddlers,
aged 1 to 4, are assumed to eat 50% of the general adult population portion size and children, aged 5
to 12, are assumed to eat 83% of the general adult population portion size. These proportions of
portion size are conservative estimates (Health Canada 2007).
Therefore, daily consumption rates for toddlers are assumed to be 0.665 kg/day during the Fish Camp
and 0.082 kg/day during the remainder of the year. For children up to 12 years old, daily consumption
rates are assumed to be 1.10 kg/day during the Fish Camp and 0.136 kg/day during the remainder of
the year. Ingestion rates used in the calculation of the EDI are also summarized in Table 3.3-1.
3.3.2
Patterns in Fish Consumption (Frequency of Consumption)
The consumption pattern for fish among Aboriginal peoples varies temporally and culturally.
Individuals may consume large amounts of fish during the late spring-early summer seasons when the
Fish Camps occur, which take place for up to one month. Consumption of fish depends on how long
people stay at the Fish Camps . Bull Trout are often consumed multiples times in a day. That is, the fish
are available (cooked and in one piece) throughout the day and evening for consumption during Fish
Camps, as it enables members, and others (e.g., visitors), to consume fish whenever they are hungry.
During the summer season, fishing and consumption of freshly caught fish may still occur, but likely
at a lower frequency than during the Fish Camps. Some of the fish caught during the fishing season
(spring-summer) will be taken home and stored in the freezer for later consumption throughout the
year (Plate 3.3-2).
Fish are may be frozen, canned, or dried in these cases. Although dried fish could be consumed
during the Fish Camps and the remainder of the year, a consumption frequency for dried fish has
yet to be determined. This is because the gathering of specific information would need to be planned
well in advance in order to schedule data collection with seasonal practices; as such, calculating an
EDI is not possible at this time (Section 3.3.1). It is recommended that receptor-specific information
be collected about consumption rates and frequencies to enable a more accurate risk characterization
in any subsequent assessment. However, it is acknowledged that consumption rates and patterns of
traditional foods can vary both spatially and temporally, which can complicate a detailed
quantitative HHRA.
3-12
EXPOSURE ASSESSMENT
Plate 3.3-2. West Moberly member with Bull Trout that were prepared for consumption
at a later date.
For the purposes of the current assessment, the reported estimated consumption rate for adults of
4 kg in 3 days (Section 2.1.1). This was converted to a daily consumption rate (for adults) of
1.33 kg/day. It was assumed that people may consume fish at this rate on a daily basis throughout
their attendance the Fish Camp; therefore, the fraction of time was set to be 1.0. This assumption
could underestimate the risk if the portion sizes used in the calculation are too small. Conversely,
risk could be overestimated if fish is eaten less often than daily or if the portion sizes used in the
calculation are too large.
During the remainder of the year, it was assumed that only one portion of fish was consumed per week
(i.e., a fraction of time of one day per week, or 0.14). This is likely to be an underestimate of the risk
during the summer period when fresh fish can be caught and consumed right away. During the winter,
one serving per week is likely more reasonable when considered as an average over the entire season.
3-13
4.
TOXICITY ASSESSMENT
4.1
POTENTIAL EFFECTS ON HUMAN HEALTH DUE TO MERCURY
Once methylmercury is ingested, almost the entire amount is absorbed from the gastrointestinal
track and distributed to all tissues in the body, where it has the ability to easily cross the blood-brain
barrier and the placenta (Health Canada 2007). Human studies have found numerous adverse health
effects after ingestion of methylmercury and the magnitude of the effects are dependent on the dose
ingested and the duration of the exposure (Health Canada 2007). The primary target organs of
methylmercury induced toxicity in humans are the central and peripheral nervous systems (Health
Canada 2007). However, methylmercury can also produce toxic effects in the kidney, liver, and
reproductive organs (WHO 2003).
When exposed to very high doses of methylmercury (either chronic or acute), the initial symptoms
include (Health Canada 2007): paresthesia (pricking, tingling of the skin), malaise, blurred vision,
concentric constriction of the visual field, deafness, dysarthria (difficulty articulating words), and
ataxia (inability to coordinate voluntary muscular movements). Very high exposures can ultimately
lead to coma and death (Health Canada 2007; National Institute for Minimata Disease 2014).
Observable toxicity symptoms may not occur with chronic exposure to low doses of methylmercury
and it is possible that some foods and dietary habits can alter the possible effects from exposure
(Chapman and Chan 2000; Health Canada 2004b). However; chronic exposure can have adverse
effects on the immune system (Moszczynski 1997) and the cardiovascular system (Stern 2005;
Virtanen et al. 2005).
There is an association between maternal methylmercury exposure and developmental effects in
children (WHO 2003; Health Canada 2007). The most sensitive human sub-population to
methylmercury exposure is the developing fetus, which can experience adverse neurological effects
at much lower doses than adults do (Health Canada 2007). The primary adverse effects that are then
observed in developing children include disruption in fine motor function, attention, verbal
learning, and memory (Health Canada 2007). While these effects are not necessarily severe, the
long-term consequences on the nervous system, such as cognition and learning are unknown
(Health Canada 2007).
Because infants, children, and women of child-bearing age are particularly susceptible to the effects
of methylmercury, specific tolerable daily/weekly intakes of methylmercury for these sensitive
groups have been recommended by regulatory agencies such as Health Canada, the US EPA, and
the World Health Organization Joint Expert Committee on Food Additives and Contaminants
(JECFA; Health Canada 2007). However, the age at which the sensitivity to methylmercury in
children is equivalent to that in the general population is not well understood, but the default
recommended by the Bureau of Chemical Safety is 12 years of age (Health Canada 2007).
4-1
4.2
PROVISIONAL TOLERABLE DAILY INTAKE
The TDI of mercury is the amount of mercury that can be taken into the body on a chronic (longterm) basis without experiencing adverse effects. The term tolerable is used because it signifies
permissibility rather than acceptability for the intake of contaminants avoidably associated with the
consumption of otherwise wholesome and nutritious (country) foods (Herrman and Younes 1999).
The TDI terminology is generally used by Health Canada, while other terms (such as oral reference
dose, RfD) are used by other jurisdiction such as the US EPA.
There are different TDIs for inorganic mercury and methylmercury. Because the form of mercury
expected to be present in fish tissue is methylmercury, TDIs for inorganic mercury were not
considered. The following is a brief discussion about the TDIs from various agencies for
methylmercury. The TDIs from the various agencies were all derived from long-term studies on
human populations that consume fish year round.
For methylmercury, the US EPA Integrated Risk Information System (IRIS) provides an oral RfD of
0.0001 mg/kg bw/day (US EPA 2015). This RfD, derived in 2001, is based on human
epidemiological studies in the Faroe Islands that looked at adverse effects of methylmercury on
neuropsychological development, based on maternal exposure (via ingestion) during pregnancy.
The RfD also incorporates an uncertainty factor of 10, which means that the methylmercury
concentration associated with adverse effects has been divided by 10 in order to account for
uncertainties in the studies.
The ATSDR developed a minimal risk level (MRL) for methylmercury of 0.0003 mg/kg bw/year
(ATSDR 1999, 2014), also based on the measurement of developmental endpoints in children. This
MRL was developed based on a different study (based in the Seychelles) than those used by the US
EPA, and applied an uncertainty factor of 3 and a modifying factor of 1.5 (to account for results from
the Faroe Island study).
JECFA recommends a provisional TDI (pTDI) of 0.00047 mg/kg bw/day for the general public, and
0.00023 mg/kg bw/day for sensitive groups (i.e., children and women who are pregnant or of childbearing age; JECFA 2007). Use of the term provisional expresses the tentative nature of the toxicity
evaluation, in view of the paucity of reliable data on the consequences of human exposure at levels
approaching those indicated. When firm conclusions from robust scientific studies are able to be
used in a toxicity evaluation, the provisional term is removed from the TDI. JECFA acknowledged
that neurodevelopment is the most sensitive health outcome associated with methylmercury
exposure, particularly for exposures of the fetus that occurs in pregnant women. The pTDI derived
by JECFA considered both the Faroe Island and Seychelles studies, as well as available scientific
literature. The pTDI incorporates as uncertainty factor of 6.4.
The JECFA pTDI was adopted by Health Canada (2010b), although for sensitive populations, a value
of 0.0002 mg/kg bw/day was adopted.
The preference in this risk assessment is to use the Canadian pTDI, which has the benefit of
distinguishing between sensitive populations and the general population. Provisional TDIs of
0.00047 mg/kg bw/day will be used for the general population and 0.0002 mg/kg bw/day for sensitive
populations will be used in this assessment, consistent with values used by Health Canada (2007).
4-2
TOXICITY ASSESSMENT
4.3
ADJUSTMENT OF THE PROVISIONAL TOLERABLE DAILY INTAKE TO ACCOUNT

FOR F ISH C ONSUMPTION P ATTERNS BASED ON T RADITIONAL P RACTICES
In order to appropriately use the pTDI to assess risk to human health, it is important to take into
consideration mercury exposure from other foods (e.g., background exposure to mercury due to
consumption of retail foods) or exposure routes (e.g., inhalation, drinking water, etc.).
The primary source of mercury in the human diet is from fish or shellfish (Airey 1983; WHO 2003;
Mahaffey, Clickner, and Bodurow 2004; Health Canada 2007; US EPA 2014). During the Fish Camps
when fish may be consumed in high amounts, it is likely that the primary source of mercury in the
diet is from the fish consumed while at the camps. It is unlikely that other fish or seafood is brought
to the Fish Camps, or that other foods (e.g., dairy products, grains/breads, etc.) will contribute
significant sources of mercury to the diet during this time.
Therefore, based on the consumption pattern described by attendees at the Fish Camp
(Section 2.1.1), it is assumed that the RWMI based on mercury can be calculated assuming that all
mercury exposure during this short period of time comes from consumption of the Bull Trout
harvested at the Fish Camps. The pTDI used in the RMWI calculation will be the full amount of the
pTDI, since it is assumed that 100% of an individuals mercury exposure during the Fish Camps
comes from the Bull Trout. It is possible that the risk to human health due to mercury could be
underestimated, since this assumption does not account for mercury intake through other foods or
potential exposure routes.
At other times of the year (apart from the Fish Camp), it is possible that Aboriginal peoples may
have exposure to mercury through other foods, including retail fish or seafood, or through other
exposure routes (see, e.g., Plate 4.3-1 and 4.3-2). Typically in a screening level risk assessment, this
background exposure is accounted for by decreasing the allowable risk by 80% (i.e., the exposure
route or food being assessed contributes up to 20%, or one-fifth, of the total exposure).
This assumption allows for the possibility that intake of mercury from background exposures could
be significant, so there is a lower tolerance for intake of mercury from one specific food or pathway.
Therefore, the pTDIs used for mercury in fish tissue were divided by five during the rest of the year
(outside of the Fish Camp). This ensures that the mercury intake from Bull Trout accounts for only
one-fifth of the tolerable mercury intake, allowing for other background exposures not considered in
this risk assessment. Thus, the pTDIs used for the RWMI calculation for periods of the year outside of
the Fish Camp was 0.00004 mg/kg bw/day for sensitive populations and 0.000094 mg/kg bw/day for
the general population. It is possible that the risk to human health is overestimated by making this
assumption, since the amount of uptake of mercury through consumption of other foods or through
other exposure pathways may make up less than 80% of the total exposure to mercury.
4-3
Plate 4.3-1. Bull Trout harvested in the fall season

from the Carbon Creek, south of the Peace Reach of
the Williston Reservoir.
Plate 4.3-2. Lake Trout harvested by West Moberly members.
4-4
5.
RISK CHARACTERIZATION
In order to characterize the risk to human consumers of fish due to mercury content, multiple
approaches will be used to ensure that risk is adequately identified and described.
The first approach to risk characterization is based on comparison of the measured mercury
concentrations in fish to federal and provincial guidelines for mercury in fish tissue.
The second approach to risk characterization is calculation of a maximum recommended weekly
intake (RMWI) of fish, based on the concentration of mercury measured in Bull Trout and the pTDI
associated with minimal risk to human consumers. The RMWI will be calculated for two distinct
periods of fish consumption patterns (i.e., fish consumption during Fish Camps and consumption
during the remainder of the year). The RMWI will be qualitatively compared to the likely levels of
fish consumption for Aboriginal consumers participating in the Fish Camps or consuming the fish
throughout the remainder of the year in order to determine the likelihood of risk consumers.
The final approach to risk characterization is the calculation of HQs based on the EDI and the pTDI.
However, due to the number of assumptions required to make these calculations, this approach is
considered a preliminary risk estimate.
5.1
COMPARISON OF FISH TISSUE MERCURY CONCENTRATIONS TO TISSUE

RESIDUE GUIDELINES
Tissue residue guidelines for the protection of human consumers of fish have been prepared by both
the federal (i.e., Health Canada) and provincial (i.e., BC MOE) governments. As an initial estimate
of the potential for risk to human consumers, measured fish tissue residues in Bull Trout and
Northern Pikeminnow are compared to these guidelines.
5.1.1
Health Canada Maximum Contaminant Standard for Mercury in Fish Tissue
The Health Canada maximum contaminant standard for mercury in fish tissue is 0.5 mg/kg ww for
most fish, except for a few species (escolar, orange roughy, marlin, tuna, shark, and swordfish)
where the limit is 1 mg/kg ww (Health Canada 2012). It is noted that this standard applies to fish for
retail sale, and as such, would not specifically apply to wild fish harvested by Aboriginal peoples.
In addition, it is intended to protect against adverse effects due to mercury in the average fish
consumer in Canada, which in many cases likely does not include subsistence consumers such as
Aboriginal peoples. This guideline, therefore, will not be protective of consumers who eat more fish
than the average consumer, particularly members of West Moberly.
Of the Bull Trout sampled in May 2012 from the Crooked River system, 37% had tissue residues of
mercury that exceeded the maximum contaminant standard of 0.5 mg/kg ww. Of the three
Northern Pikeminnow that were sampled in May 2012, all of them had concentrations of mercury
greater than the standard.
5-1
There was a significant relationship noted between the concentration of mercury in fish tissue and
the length and weight of Bull Trout. Based on the regression relationships defined in Section 3.2
(Equations 2 and 3), Table 5.1-1 shows the length and weight of Bull Trout that would begin to have
tissue residues exceeding the maximum contaminant standard of 0.5 mg/kg ww.
Mercury Exceeding Health Canada Maximum Contaminant Standard
Length or Weight at which the Tissue Residue Guideline is likely to be Exceeded
Health Canada
Tissue Residue
Guideline
(mg/kg ww)
0.5
Length (mm)
Weight (kg)
Based on
Regression Line
Based on Upper
Confidence Limit
Based on
Regression Line
Based on Upper
Confidence Limit
573
550
2.3
2.1
Based on the linear regression, fish that are longer than 573 mm (57.3 cm), or heavier than 2.3 kg
would be predicted to have mercury tissue concentrations exceeding the Health Canada maximum
contaminant standard (Table 5.1-1). When considering the upper confidence bound of the regression
line, fish that are 550 mm (55.0 cm) long or weigh 2.1 kg would be expected to have mercury tissue
concentrations exceeding the Health Canada maximum contaminant standard.
5.1.2
BC Ministry of Environment Aquatic Life Guidelines for Mercury in Fish Tissue
The BC MOE has also published aquatic life guidelines for mercury in fish tissue for when the human
diet is based primarily on fish (Nagpal 1989). There are five tissue residue guidelines which are based
on the amount of fish consumption. The BC MOE tissue residue guidelines for human consumers are
summarized in Table 5.1-2. Note that the BC MOE tissue residue guideline for the lowest consumption
rate (0.210 kg fish/week) is the same as the Health Canada maximum standard for retail fish.
Table 5.1-2. BC Ministry of Environment Aquatic Life Guidelines for Mercury in Fish and
Comparison with Measured Mercury Tissue Residues from Bull Trout
Total Mercury Concentration in
the Edible Portion
(mg/kg ww)
Safe Quantity for Weekly

Consumption
(kg)
Percentage of Bull Trout Sampled

in May 2012 with Tissue Residues
Greater than Guideline
0.5
0.210
37%
0.4
0.260
46%
0.3
0.350
61%
0.2
0.525
88%
0.1
1.050
96%
Table 5.1-2 also shows the percentage of Bull Trout that were sampled in May 2012 that had tissue
concentrations of mercury that exceeded the guidelines. Only 4% of the Bull Trout sampled in
May 2012 would be considered safe for consumption at the rate of approximately 1 kg of fish/week
(i.e., 96% of the fish that were sampled exceeded the guideline at this consumption frequency).
When considering the tissue residue guideline at the lowest consumption rate of 0.210 kg/week,
5-2
37% of Bull Trout and 100% of the Northern Pikeminnow sampled had tissue concentrations of
mercury that exceeded the guideline at the lowest consumption rate.
As noted previously, there was a significant relationship between the concentration of mercury in
fish tissue and the length and weight of Bull Trout. Based on the regression relationships defined in
Section 3.2 (Equations 2 and 3), Table 5.1-3 shows the length and weight of Bull Trout that would
begin to have tissue residues exceeding the various BC MOE guidelines (from 0.1 to 0.5 mg/kg ww).
Mercury Exceeding BC Ministry of Environment Tissue Residue Guidelines
BC Ministry of
Environment
Tissue Residue
Guideline
(mg/kg ww)
Age, Length, or Weight at which the Tissue Residue Guideline is likely to be Exceeded
Length (mm)
Weight (kg)
Based on
Regression Line
Based on Upper
Confidence Limit
Based on
Regression Line
Based on Upper
Confidence Limit
0.5
573
550
2.3
2.1
0.4
507
483
1.6
1.4
0.3
440
408
0.9
0.5
0.2
373
329
0.1
N/A
0.1
307
247
N/A
N/A
N/A = not applicable because the calculated value from the regression relationship was less than zero.
Based on the linear regression, Bull Trout that are longer than 307 to 573 mm, or heavier than 0.1 to
2.3 kg, are predicted to have mercury tissue concentrations exceeding one of the BC MOE tissue
guidelines for the mercury (Table 5.1-1). When considering the upper confidence bound of the
regression line, fish that are 247 to 50 mm long, or weigh 0.5 to 2.1 kg, would be expected to have
mercury tissue concentrations exceeding one of the BC MOE tissue guidelines for the mercury.
5.1.3
Conclusions based on Comparison of Mercury Measured in Fish Tissue and the

Fish Tissue Residue Guidelines
The BC MOE guideline suggests that fish with tissue mercury concentrations of 0.5 mg/kg ww are
safe to consume at the rate of 0.210 kg/week. Based on comparison to the most permissive mercury
tissue residue guideline for fish (i.e., 0.5 mg/kg ww), almost 40% of Bull Trout and all of (the three)
Northern Pikeminnow had mercury concentrations in their tissues above this level.
However, it is likely that Aboriginal people will eat substantially more fish than 0.210 kg/week,
particularly during the Fish Camps or in the summer fishing periods of the traditional seasonal
round. It is possible that such individuals could eat more than 1 kg of fish in a day during the Fish
Camps (Section 2.1.1); however, 96% of Bull Trout exceeded the mercury tissue guideline
(i.e., 0.1 mg/kg ww) for this consumption rate. Based on the mercury concentrations measured from
fish collected in May 2012 and the Health Canada or BC MOE guidelines, none of the Bull Trout are
safe to eat at such a high frequency (1 kg/week). This suggests that there could be risk to human
consumers of these fish, particularly in sensitive populations such as pregnant women, women of
childbearing age, toddlers, or children under 12 years of age.
5-3
5.2
RECOMMENDED MAXIMUM WEEKLY INTAKE
The recommended maximum weekly intake (RMWI) of a food can be calculated to provide guidance
about the safe level of intake of country foods (Plate 5.2-1). Calculation of the RMWI takes into
account the concentration of mercury in fish tissue and the pTDI. It is calculated as follows, using
the formula provided by Health Canada (2004a):
3 "( =
456) 127
+,-./
[Equation 5]
where:
RMWI =
pTDI =
7=
BW =
Cfish =
recommended maximum weekly intake (kg fish/week)

provisional tolerable daily intake for mercury (mg/kg bw/day)
number of days/week (days/week)
body weight (kg bw)
concentration of mercury in fish tissue (mg/kg fish)
Most of the parameters used in the RMWI calculation have been previously described and are
specific to groups (see Plate 5.2-2). The pTDI used in the assessment can be found in Section 4.3.
The concentration of mercury in fish tissue can be found in Section 3.2.
Plate 5.2-1. Youth (i.e., under 12 years of age) with a Bull Trout harvested from the
Crooked River, BC, in 2008 at Fish Camp.
5-4
Plate 5.2-2. Bull Trout harvested by a youth during

the fall season in the Peace region.
Receptor-specific information about body weight is not available, so standard values for the
average person in each human receptor group were used based on (Richardson 1997). The different
receptor groups are described in Section 3.1 and include:
toddlers, aged 1 to 4 years (body weight = 14.4 kg);
children, aged 5 to 12 years (body weight = 26.4 kg);
sensitive adult population (body weight = 60 kg); and,
and the general population (body weight = 70.7 kg).
5.2.1
Calculation of Recommended Maximum Weekly Intake based on the

95th Percentile of Mercury Concentrations
RMWIs based on the 95th percentile of Bull Trout mercury concentrations were calculated using
Equation 5. As discussed in Section 3.2.1., the 95th percentile of the mercury concentrations measured
in Bull Trout is considered to be the most reasonable and conservative value for use in calculations.
This value is conservative and would result in RMWIs that would be reasonably protective of
human health for all consumer groups.
Calculations of the RMWI were done for two distinct time periods in order to represent the cultural
practices of West Moberlys traditional seasonal round: during the Fish Camps and during the
remainder of the year. This is due to differences in consumption patterns and potential exposure
5-5
routes for mercury during the various times of the year, which have been accounted for through the
use of different pTDIs for the two periods (see Section 4.3).
RMWIs were also calculated for fresh fish (meaning fish that is freshly caught or taken out of the
freezer, cooked, and eaten; this may also include fish that is canned for later consumption), and
dried fish (meaning fish that has been dried, smoked, or processed in a traditional manner that
results in a significant decrease in the moisture content of the fish). For the purpose of this study,
and until specific data on dried Bull Trout is collected from West Moberly, dried fish was assumed
to have a moisture content similar to that observed for smoked salmon. A 50% moisture content was
assumed based on a study by Lin et al. (2003), which found that smoked salmon had a moisture
content ranging from 50.7 to 55.5%.
During the Fish Camps, the pTDI used was 0.0002 mg/kg bw/day for the general population and
0.00047 mg/kg bw/day for sensitive populations. The pTDIs for the period of the year outside of the
Fish Camps the pTDIs used was 0.00004 mg/kg bw/day for sensitive populations and
0.000094 mg/kg bw/day for the general population.
The RMWI for Bull Trout for each receptor group during Fish Camp are presented in Table 5.2-1.
Receptor characteristics are also provided in the table for convenience.
Table 5.2-1. Recommended Maximum Weekly Intake of Bull Trout based on Summary Statistics
and Human Receptor Group
Toddler
Children
under 12
Sensitive
Adult
General
Population
Provisional tolerable daily intake (mg/kg bw/day)

during Fish Camps
0.0002
0.0002
0.0002
0.00047

during Remainder of the Year
0.00004
0.00004
0.00004
0.000094
14.4
26.4
60
70.7
Receptor Characteristics
Body weight (kg)
Summary Statistic
Concentration
in Fish
(mg/kg ww)
Recommended Maximum Weekly Intake (kg fish/week)

for Fresh Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0.796
0.025
0.046
0.106
0.292
0.796
0.005
0.009
0.021
0.058
During Fish Camps

95th Percentile
During remainder of the year
95th Percentile
Summary Statistic
Concentration
in Fish
(mg/kg ww)

for Dried Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0.796
0.011
0.020
0.046
0.129
0.796
0.002
0.004
0.009
0.026
During Fish Camps

95th Percentile
During remainder of the year
95th Percentile
5-6
Based on these calculations, the RMWI of Bull Trout when eaten fresh, frozen, or canned for the
general population (i.e., those individuals not in a sensitive group) during the Fish Camps is
0.292 kg (292 grams) based on the 95th percentile of mercury concentrations in Bull Trout measured
in 2012. The RMWIs are lower for those in the sensitive groups, ranging from 0.025 kg/week for
toddlers, 0.046 kg/week for children under 12 years of age, and 0.106 kg/week for women of
childbearing age or those who are pregnant.
RMWIs for consumption of dried fish were lower, ranging from 0.011 grams/week for toddlers to
0.129 kg/week for the general population. The RMWIs for dried fish are lower because the loss of
moisture results in a higher concentration of mercury per kilogram of fish. This means that moisture is lost
from the fish but mercury is not, resulting in the same amount of mercury in a smaller amount of fish.
RMWIs are also lower during the remainder of the year, since the pTDI was adjusted to 20% of the
value used during Fish Camps. Therefore, the RMWI is 80% lower during the remainder of the year
ranging from 0.005 to 0.058 kg/week for toddlers and general population, respectively, for fresh
fish, and 0.002 to 0.026 kg/week for toddlers and general population, respectively, for dried fish.
5.2.2
Calculation of Recommended Maximum Weekly Intake based on Fish Length
An RMWI was calculated based on the estimated mercury concentration for a range of fish lengths,
using the upper limit of each range increment as the length value for use in Equation 2 (Section 3.2).
Fish lengths were arbitrarily categorized into increments of 50 mm, starting at 350 mm (the smallest
Bull Trout sampled in 2012 was 355 mm) up to the maximum of 800 mm (the maximum measured
length for Bull Trout sampled in 2012 was 800 mm).
Calculations for RMWI were performed in the same manner described in the preceding section for
the calculation of RMWI based on the 95th percentile (Section 5.2.1). The RMWI for Bull Trout (both
fresh and dried fish) for each receptor group during the period when members of West Moberly are
attending the Fish Camps is presented in Table 5.2-2, while the RMWI for Bull Trout during the
remainder of the year is presented in Table 5.2-3.
Tables 5.2-2 and 5.2-3 show that as the length of the fish increases, the RMWI decreases. This is
because there is a significant relationship between increased fish length and increased mercury
concentrations. Fish that are greater in length have higher tissue concentrations of mercury.
For fish consumption during the Fish Camps, for the largest Bull Trout (800 mm, or 80 cm), the
general population can safely consume approximately 0.277 kg/week if it is fresh and
0.122 kg/week if it is dried, based on the mercury content predicted for fish of this size (Table 5.2-2).
For the smallest Bull Trout (350 mm, or 35 cm), the general population can consume up to
0.969 kg/week of fresh fish and 0.426 kg/week if it is dried.
For sensitive populations, the quantity that can be safely consumed during the Fish Camps is lower,
ranging from 0.024 kg/week for toddlers to 0.100 kg/week for sensitive adults for the largest Bull
Trout (800 mm) if eaten fresh, and 0.084 kg/week for toddlers to 0.350 kg/week for sensitive adults
for the smallest Bull Trout (350 mm). If dried fish is eaten the RMWI ranges from 0.011 kg/week for
toddlers to 0.044 kg/week for sensitive adults for the largest Bull Trout or 0.037 kg/week for
toddlers or 0.154 kg/week for sensitive adults for the smallest Bull Trout.
5-7
Table 5.2-2. Recommended Maximum Weekly Intake of Bull Trout during the Fish Camps based
on Fish Length and Human Receptor Group
Toddler
Children
under 12
Sensitive
Adult
General
Population

during Fisk Camp
0.0002
0.0002
0.0002
0.00047

0.00004
0.00004
0.00004
0.000094
14.4
26.4
60
70.7
Body weight (kg)
Range in Bull Trout

Length (mm)
Estimated Mercury
Concentration in Bull
Trout (mg/kg ww)

for Fresh Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
350 to 400
0.240
0.084
0.154
0.350
0.969
401 to 450
0.315
0.064
0.117
0.267
0.738
451 to 500
0.390
0.052
0.095
0.215
0.596
501 to 550
0.465
0.043
0.079
0.181
0.500
551 to 600
0.540
0.037
0.068
0.156
0.431
601 to 650
0.615
0.033
0.060
0.137
0.378
651 to 700
0.690
0.029
0.054
0.122
0.337
701 to 750
0.765
0.026
0.048
0.110
0.304
751 to 800
0.840
0.024
0.044
0.100
0.277
Range in Bull Trout

Length (mm)
Estimated Mercury
Trout (mg/kg dw)

for Dried Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
350 to 400
0.545
0.037
0.068
0.154
0.426
401 to 450
0.716
0.028
0.052
0.117
0.325
451 to 500
0.886
0.023
0.042
0.095
0.262
501 to 550
1.057
0.019
0.035
0.079
0.220
551 to 600
1.227
0.016
0.030
0.068
0.190
601 to 650
1.398
0.014
0.026
0.060
0.166
651 to 700
1.568
0.013
0.024
0.054
0.148
701 to 750
1.739
0.012
0.021
0.048
0.134
751 to 800
1.909
0.011
0.019
0.044
0.122
During the remainder of the year RMWIs for Bull Trout are lower by one-fifth, since it was assumed that
80% of the tolerable mercury intake comes from other foods (e.g., retail fish) or exposure routes. It is
possible that this is an overly conservative assumption, and this is something that could be evaluated in a
more detailed quantitative risk assessment (i.e., accounting for mercury intake from sources other than
the Bull Trout). For the general population, this means that the RMWI for the largest Bull Trout (800 mm)
5-8
if eaten fresh is 0.055 kg/week and for the smallest Bull Trout (300 mm) the RMWI is 0.194 kg/week
(Table 5.2-3). In sensitive populations, the RMWI for eating fresh Bull Trout ranges from 0.005 kg/week
for toddlers and 0.020 kg/week for sensitive adults for the largest Bull Trout (800 mm), while for smaller
Bull Trout (300 mm), the RMWI ranges from 0.017 kg/week for toddlers to 0.070 kg/week for sensitive
adults. Consumption rates for dried fish are lower than for fresh fish, ranging from 0.002 kg/week in
toddlers for large fish up to 0.085 kg/week for adults eating the smallest fish.
Table 5.2-3. Recommended Maximum Weekly Intake of Bull Trout during the Remainder of the
Year based on Fish Length and Human Receptor Group
Toddler
Children
under 12
Sensitive
Adult
General
Population
0. 00004
0. 00004
0. 00004
0.000094

0.00004
0.00004
0.00004
0.000094
14.4
26.4
60
70.7
Body weight (kg)
Range in Bull Trout

Length (mm)
Estimated Mercury
Trout (mg/kg ww)

for Fresh Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
350 to 400
0.240
0.017
0.031
0.070
0.194
401 to 450
0.315
0.013
0.023
0.053
0.148
451 to 500
0.390
0.010
0.019
0.043
0.119
501 to 550
0.465
0.009
0.016
0.036
0.100
551 to 600
0.540
0.007
0.014
0.031
0.086
601 to 650
0.615
0.007
0.012
0.027
0.076
651 to 700
0.690
0.006
0.011
0.024
0.067
701 to 750
0.765
0.005
0.010
0.022
0.061
751 to 800
0.840
0.005
0.009
0.020
0.055
Range in Bull Trout

Length (mm)
Estimated Mercury
Trout (mg/kg dw)

for Dried Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
350 to 400
0.545
0.007
0.014
0.031
0.085
401 to 450
0.716
0.006
0.010
0.023
0.065
451 to 500
0.886
0.005
0.008
0.019
0.052
501 to 550
1.057
0.004
0.007
0.016
0.044
551 to 600
1.227
0.003
0.006
0.014
0.038
601 to 650
1.398
0.003
0.005
0.012
0.033
651 to 700
1.568
0.003
0.005
0.011
0.030
701 to 750
1.739
0.002
0.004
0.010
0.027
751 to 800
1.909
0.002
0.004
0.009
0.024
5-9
5.2.3
Calculation of Recommended Maximum Weekly Intake based on Fish Weight
An RMWI was calculated based on the estimated mercury concentration for a range of fish weights,
using the upper limit of each range as the weight value for use in Equation 3. The ranges for fish
weights were arbitrarily based on increments of fish weight of 0.5 kg (e.g., 0 to 0.5 kg, 0.51 to 1.0 kg,
1.01 kg to 1.5 kg, etc.) up to 5 kg. This range was selected because the smallest Bull Trout measured
in 2012 was 0.35 kg, and the largest Bull Trout was 5.02 kg.
Calculations for RMWI were performed in the same manner described in the preceding section for
the calculation of RMWI based on the 95th percentile (Section 5.2.1). The RMWIs for Bull Trout (fresh
and dried) for each receptor group during the period when people are attending the Fish Camps is
presented in Table 5.2-4, while the RMWI for Bull Trout during the remainder of the year is
presented in Table 5.2-5.
Tables 5.2-4 and 5.2-5 show that as the weight of the fish increases, the RMWI decreases. This is because
there is a significant relationship between increased fish weight and increased mercury concentrations in
fish tissue. Fish that are greater in weight have higher tissue concentrations of mercury.
For fish consumption during the Fish Camps, for the largest Bull Trout (5 kg), the general
population can safely consume approximately 0.264 kg/week if it is fresh and 0.116 kg/week if it is
dried, based on the mercury content predicted for fish of this size (Table 5.2-2). For the smallest Bull
Trout (0.5 kg), the general population can consume up to 0.930 kg/week of fresh fish and
0.409 kg/week if it is dried.
For sensitive populations, the quantity that can be safely consumed during the Fish Camps is lower,
ranging from 0.023 kg/week for toddlers to 0.095 kg/week for sensitive adults for the largest Bull
Trout (5 kg) if eaten fresh, and 0.081 kg/week for toddlers to 0.336 kg/week for sensitive adults for
the smallest Bull Trout (0.5 kg). If dried fish is eaten, then the RMWI ranges from 0.011 kg/week for
toddlers to 0.042 kg/week for sensitive adults for the largest Bull Trout, or 0.035 kg/week for
toddlers or 0.148 kg/week for sensitive adults for the smallest Bull Trout.
During the remainder of the year RMWIs for Bull Trout are lower by one-fifth, since it was assumed
that 80% of the tolerable mercury intake comes from other foods (e.g., retail fish) or exposure routes.
It is possible that this is an overly conservative assumption, and this is something that could be
evaluated in a more detailed quantitative risk assessment (i.e., accounting for mercury intake from
sources other than the Bull Trout).
For the general population, this means that the RMWI for the largest Bull Trout (5 kg) if eaten fresh
is 0.053 kg/week and for the smallest Bull Trout (0.5 kg) the RMWI is 0.186 kg/week (Table 5.2-3).
In sensitive populations, the RMWI for eating fresh Bull Trout ranges from 0.005 kg/week for
toddlers and 0.019 kg/week for sensitive adults for the largest Bull Trout (5 kg), while for smaller
Bull Trout (0.5 kg), the RMWI ranges from 0.016 kg/week for toddlers to 0.067 kg/week for
sensitive adults. Consumption rates for dried fish are lower than for fresh fish, ranging from
0.002 kg/week in toddlers for large fish up to 0.082 kg/week for adults eating the smallest fish.
5-10
Table 5.2-4. Recommended Maximum Weekly Intake of Bull Trout during the Fish Camps based
on Fish Weight and Human Receptor Group
Toddler
Children
under 12
Sensitive
Adult
General
Population
0.0002
0.0002
0.0002
0.00047

0.00004
0.00004
0.00004
0.000094
14.4
26.4
60
70.7
Body weight (kg)
Range in Bull Trout

Weight (kg)
Estimated Mercury
Trout (mg/kg ww)

for Fresh Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0 to 0.5
0.250
0.081
0.148
0.336
0.930
0.51 to 1.0
0.320
0.063
0.116
0.263
0.727
1.01 to 1.5
0.390
0.052
0.095
0.215
0.596
1.51 to 2.0
0.460
0.044
0.080
0.183
0.506
2.01 to 2.5
0.530
0.038
0.070
0.158
0.439
2.51 to 3.0
0.600
0.034
0.062
0.140
0.388
3.01 to 3.5
0.670
0.030
0.055
0.125
0.347
3.51 to 4.0
0.740
0.027
0.050
0.114
0.314
4.01 to 4.5
0.810
0.025
0.046
0.104
0.287
4.51 to 5.0
0.880
0.023
0.042
0.095
0.264
Range in Bull Trout

Weight (kg)
Estimated Mercury
Trout (mg/kg dw)

for Dried Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0 to 0.5
0.568
0.035
0.065
0.148
0.409
0.51 to 1.0
0.727
0.028
0.051
0.116
0.320
1.01 to 1.5
0.886
0.023
0.042
0.095
0.262
1.51 to 2.0
1.045
0.019
0.035
0.080
0.222
2.01 to 2.5
1.205
0.017
0.031
0.070
0.193
2.51 to 3.0
1.364
0.015
0.027
0.062
0.171
3.01 to 3.5
1.523
0.013
0.024
0.055
0.153
3.51 to 4.0
1.682
0.012
0.022
0.050
0.138
4.01 to 4.5
1.841
0.011
0.020
0.046
0.126
4.51 to 5.0
2.000
0.010
0.018
0.042
0.116
5-11
Table 5.2-5. Recommended Maximum Weekly Intake of Bull Trout during the Remainder of the
Year based on Fish Weight and Human Receptor Group
Toddler
Children
under 12
Sensitive
Adult
General
Population
0. 00004
0. 00004
0. 00004
0.000094
14.4
26.4
60
70.7
Body weight (kg)
Range in Bull Trout

Weight (kg)
Estimated Mercury
Trout (mg/kg ww)

for Fresh Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0 to 0.5
0.250
0.016
0.030
0.067
0.186
0.51 to 1.0
0.320
0.013
0.023
0.053
0.145
1.01 to 1.5
0.390
0.010
0.019
0.043
0.119
1.51 to 2.0
0.460
0.009
0.016
0.037
0.101
2.01 to 2.5
0.530
0.008
0.014
0.032
0.088
2.51 to 3.0
0.600
0.007
0.012
0.028
0.078
3.01 to 3.5
0.670
0.006
0.011
0.025
0.069
3.51 to 4.0
0.740
0.005
0.010
0.023
0.063
4.01 to 4.5
0.810
0.005
0.009
0.021
0.057
4.51 to 5.0
0.880
0.005
0.008
0.019
0.053
Range in Bull Trout

Weight (kg)
Estimated Mercury
Trout (mg/kg ww)

for Dried Fish
Toddler
Children
under 12
Sensitive
Adult
General
Population
0 to 0.5
0.568
0.007
0.013
0.030
0.082
0.51 to 1.0
0.727
0.006
0.010
0.023
0.064
1.01 to 1.5
0.886
0.005
0.008
0.019
0.052
1.51 to 2.0
1.045
0.004
0.007
0.016
0.044
2.01 to 2.5
1.205
0.003
0.006
0.014
0.039
2.51 to 3.0
1.364
0.003
0.005
0.012
0.034
3.01 to 3.5
1.523
0.003
0.005
0.011
0.031
3.51 to 4.0
1.682
0.002
0.004
0.010
0.028
4.01 to 4.5
1.841
0.002
0.004
0.009
0.025
4.51 to 5.0
2.000
0.002
0.004
0.008
0.023
5.2.4
Summary and Conclusions based on Recommended Maximum Weekly Intakes for

Bull Trout
5.2.4.1
Consumption of Bull Trout during the Fish Camps
RMWIs calculated based on the summary statistics for Bull Trout sampled in 2012 suggest that
consumption of fresh Bull Trout for the general population (i.e., those individuals not in a sensitive
5-12
group) during the Fish Camps should be kept below 0.292 kg fish/week. The RMWIs for fresh Bull
Trout are lower for those in the sensitive groups, ranging from 0.025 kg fish/week for toddlers, 0.046 kg
fish/week for children under 12 years of age, and 0.106 kg fish/week for women of childbearing age or
those who are pregnant (Plate 5.2-1). Consumption of dried fish should be kept lower, with RWMIs
ranging between 0.011 kg/week for toddlers up to 0.129 kg/week in the general population.
It is probable that during the Fish Camps, members of West Moberly, and possibly other as well, are
eating fish at consumption rates in excess of the RMWIs that are based on the 95th percentile of
mercury concentrations (Table 5.2-1). It is also possible that West Moberlys members are consuming
fish in excess of the RMWIs, even when taking into account fish size (Table 5.2-2) or weight
(Table 5.2-4). Although no specific consumption rates were determined during interviews with Fish
Camp participants, as such data varies and may not be accurate (or useful) in the future according to
participants if risk is to be managed, based on the qualitative descriptions provided of consumption
patterns (i.e., multiple meals of fish/day, each day during the Fish Camp for all ages and genders), it
is likely that people could consume upwards of 1.0 kg of fresh fish/week in addition to dried fish for
this short period of time; West Moberly members considered this estimate to be a minimum amount
of fish they would consume during the Fish Camps (Section 2.1.1). Therefore, it is likely that
members of West Moberly may be ingesting levels of mercury that could have adverse health
effects, particularly for sensitive populations.
5.2.4.2
Consumption of Bull Trout during the Remainder of the Year
Similarly, during the remainder of the year, the RMWI of Bull Trout for the general population based on
the 95th percentile of mercury concentrations for fresh fish is 0.058 kg/week and for dried fish is
0.026 kg/week. The RMWIs are lower for those in the sensitive groups, ranging from 0.005 kg/week
fresh fish or for toddlers, 0.009 kg fish/week for children under 12 years of age, and 0.021 kg fish/week
for women of childbearing age or those who are pregnant. For dried fish, the RMWIs are 0.002 kg/week
for toddlers, 0.004 kg/week for children under 12, and 0.009 kg/week for sensitive adults.
It is probable that during the rest of the year outside of Fish Camps, people are eating fish at
consumption rates in excess of the RMWIs that are based on the 95th percentile of mercury
concentrations (Table 5.2-1). It is also possible that people are consuming fish in excess of the
RMWIs, even when taking into account fish size (Table 5.2-3) or weight (Table 5.2-5). Although no
specific consumption rates for fish throughout the year were determined during interviews with
Fish Camp participants, the RMWI can be compared to fish intake rates derived from literature.
Notwithstanding the potential issues noted by a number of First Nations, the study by Chan et al.
(2011) reported country foods (including fish) consumption rates for First Nations people living on
reserves. This study found that the average portion size for fish for Aboriginal peoples was 0.87 to
0.132 kg/serving for women and 0.100 to 0.163 kg/serving for men. These average portion sizes are
similar to the values recommended by Health Canada (2007), where a fish portion size of 0.150 kg
for adults in their risk assessment for mercury in retail fish. In addition, Chan et al. (2011) reported
that for Aboriginal peoples living on reserves, the 95th percentile daily consumption rate of trout
(any type) for women of childbearing age was 0.011 kg/day and for men under the age of 70 was
between 0.014 and 0.020 kg/day. This is equivalent to 0.077 kg/week for women of childbearing
age, or 0.098 to 0.140 kg/week for adult men.
5-13
The RMWIs shown in Tables 5.2-1, 5.2-3, and 5.2-5 for fish consumption throughout the year are
lower than the average portion sizes that a person may consume at a single meal for all receptor
groups considered in the assessment. The RMWIs are also lower than the amount of fish Aboriginal
peoples are reported to consume per week for all groups considered in the assessment. The RMWIs
indicate that less than one serving/week of the Bull Trout should be consumed throughout the year
in order to keep mercury intake at a level where adverse effects should not occur in consumers.
This is particularly true for individuals in the sensitive populations where the RMWIs are markedly
less than half of a serving size, since the RMWI is less than 2 to 10 grams of Bull Trout per week
(toddlers and sensitive adults, respectively).
5.3
CALCULATION OF HAZARD QUOTIENTS
In a traditional HHRA, risk characterization is done by calculating an EDI, determining a pTDI, and
then calculating a HQ as the ratio of the EDI and pTDI. Risk estimates based on the calculation of
HQs for mercury from consumption of Bull Trout were done using the following formula:
8 9
: ;
<=>?@A>BC 6A?DE )F>AGB HI JBKLMKE
= NKHO?=?HFAD 5HDBKAPDB 6A?DE )F>AGB HI JBKLMKE
[Equation 6]
For comparison purposes, HQs were calculated based on both the 95% UCLM and the 95th percentile
of mercury concentrations measured in Bull Trout in 2012. If a HQ is calculated to be less than 1.0, it
is unlikely that there is risk to human health due to consumption of mercury in Bull Trout.
However, if the calculated HQ is greater than 1.0, it is possible that there may be a risk to human
health from consumption of mercury in Bull Trout. Table 5.3-1 shows the results of the risk
characterization for mercury in Bull Trout.
The calculated HQs for all receptor groups during both the Fish Camps and the remainder of the year
are greater than 1.0, even when calculated using the 95% UCLM of mercury concentrations in Bull
Trout (Table 5.3-1). In the general population, HQs were 19.2 (based on the 95% UCLM) or 31.9 (based
on the 95th percentile of mercury concentrations) during the Fish Camp, and were lower during the
remainder of the year when fish consumption was assumed to occur only once per week. The HQs are
particularly elevated in sensitive populations, with HQs ranging between 53.1 and 183.8 during the
Fish Camps, and 3.8 and 16.1 during the remainder of the year.
The rates at which fish was assumed to be eaten could lead to intake of mercury at levels that could be
harmful to human health, given the elevated concentration of mercury measured in Bull Trout in 2012.
It is possible that the consumption rates and amounts have been underestimated in both time periods,
since the assumptions made were not the most conservative assumptions possible. The use of higher
consumption rates (i.e., making more conservative assumptions about consumption rates, which
would result in higher HQs) would not change the outcome of the risk characterization using HQs,
since the consumption rates used in this assessment resulted in HQs that were greater than 1.0.
Based on the risk characterization (HQ) calculations presented here, it is possible that adverse effects
to human health may occur as a result of mercury intake from Bull Trout harvested from the
Crooked River system.
5-14
Table 5.3-1. Risk Characterization for Mercury Intake from Bull Trout during Fish Camps and
Remainder of the Year
During Fish Camps
Toddler
Children
under 12
Sensitive
Adults
General
Population
Estimated Daily Intake (mg/kg bw/day)

Based on 95% UCLM Mercury Concentration
0.02213
0.02004
0.01062
0.00901
Based on 95th Percentile Mercury Concentration
0.03677
0.03329
0.01765
0.01498
0.0002
0.0002
0.0002
0.00047
0.0002
0.0002
0.0002
0.00047
110.6
100.2
53.1
19.2
183.8
166.5
88.2
31.9
Toddler
Children
under 12
Sensitive
Adults
Provisional Tolerable Daily Intake (mg/kg bw/day)
Hazard Quotients (unitless)
During Remainder of the Year
General
Population
Estimated Daily Intake (mg/kg bw/day)

0.00039
0.00035
0.00015
0.00016
0.00064
0.00058
0.00025
0.00026
0.00004
0.00004
0.00004
0.000094
0.00004
0.00004
0.00004
0.000094
9.7
8.8
3.8
1.7
16.1
14.6
6.3
2.8
Provisional Tolerable Daily Intake (mg/kg bw/day)
Hazard Quotients (unitless)
HQs shown in bold red text are greater than 1.0, suggesting risk to human health is possible.
UCLM = 95% upper confidence limit of the mean.
5.4
FISH CONSUMPTION ADVISORY FOR THE WILLISTON RESERVOIR
There is an existing fish consumption advisory issued by the Ministry of Environment for Lake Trout
and Bull Trout (Dolly Varden) from Williston Lake (the Williston Reservoir, Plates 5.4-1 and 5.4-2);
this consumption advisory is based on high concentrations of mercury present in the fish tissue (BC
MOE 2015a). This advisory indicates that normal consumption is not a significant hazard to human
health, but high consumption may be, including for non-aboriginals (Plate 5.4-3).
However, it is not clear exactly where the boundaries of the advisory are (i.e., whether or not
tributaries and connected lakes are actually included in the advisory) and whether or not migration
barriers have been considered in defining the boundaries. The map on page 67 of BC MOE (2015a)
shows the Omineca region (7A), but does not have a boundary for the extent of the advisory.
The additional information section (page 81) refers to a consumption advisory due to mercury in
Lake Trout and Bull Trout from Williston Lakes and specifically in water management unit 7-36.
5-15
Plate 5.4-1. Pre-Construction and Flooding BC Hydros W.A.C. Bennett Hydroelectric

Dam and the Williston Reservoir.
Plate 5.4-2. Post-Construction and Flooding BC Hydros W.A.C. Bennett

Hydroelectric Dam and the Williston Reservoir.
5-16
Plate 5.4-3. Example of a non-aboriginal youth that harvests Bull Trout
Earlier studies found that the concentrations of mercury in fish caught in the Williston reservoir
were elevated though the 1980s and into 2000 in various parts of reservoir (e.g., Akie, Ingenika,
Finlay Reach, Parsnip Reach, and Peace Reach; Baker 1999; BC MOE 2002; Azimuth Consulting
Group Inc. 2011). Concentrations of mercury in Bull Trout (standardized to 550 mm in length)
ranged from 0.56 mg/kg ww in the Finlay Reach in 2000 to 0.87 mg/kg ww in the Finaly Reach in
1988. In comparison, a 550 mm Bull Trout from the Crooked River system is estimated to have a
mercury concentration of 0.465 mg/kg ww, based on Equation 2.
The analysis presented in Sections 5.2 and 5.3 suggests that consumption of the fish could present a
risk to human health, based on the cultural techniques in which fish are prepared and the quantities
that may be consumed. Thus, it is likely that Aboriginal peoples in general, and in particular
members from West Moberly, would fall into the high consumption category referred to in the
consumption advisory for Lake Trout and Bull Trout from Williston Reservoir. Not only are
Aboriginal people likely to be considered a high consumer, but non-aboriginal individuals that
reside in remote regions of northern BC and/or harvest fish from the Crooked River system may
also fall into that category.
5-17
5.5
SUMMARY AND CONCLUSIONS FROM RISK CHARACTERIZATION
Characterization of the risk to human health due to consumption of Bull Trout from the Crooked
River used multiple methods of analysis including comparison to guidelines, calculation of a RMWI,
traditional characterization of risk using HQs, and qualitative consideration of the existing fish
consumption advisory for Williston Reservoir. All analysis methods suggest used in this preliminary
risk assessment suggest that mercury concentrations measured in Bull Trout (and Northern
Pikeminnow) in 2012 were at levels that could affect human health, especially when the traditional
preparation and consumption practices of West Moberly are taken into consideration.
Although the focus of this assessment has been on risk to Aboriginal consumers of Bull Trout from
the Crooked River, there are wider implications to the general population. Other people who catch
and eat fish from this area may also be at risk if their level of consumption is high enough. This is
particularly true for people in the more sensitive populations such as pregnant women, women of
child-bearing age (who may become pregnant), children under 12 years of age, and toddlers.
5-18
6.
IMPORTANCE OF FISH CONSUMPTION AND

TRADITIONAL PRACTICES TO HEALTH
Aboriginal peoples are likely to avoid fish that are traditionally harvested when the source(s) have
been contaminated (Chan and Receveur 2000). In order for Aboriginal peoples to make informed
decisions about traditional foods included in their diets, then, it is important to account for both the
benefits and burdens of consuming traditional food (Kinghorn et al. 2007). Fish provide a valuable
source of nutrients (e.g., protein, Vitamin D, iron, selenium, and omega-3 fatty acids) that the body
requires for proper functioning (Health Canada 2007). Beneficial effects of including fish in the diet
include improvements to cardiovascular health and fetal development (Health Canada 2007).
However, the benefits from fish consumption can be dependent on the method that the fish is
prepared for consumption; broiling and baking fish are associated with benefits to cardiac
hemodynamics, whereas frying fish has been associated with systolic dysfunction (Mozaffarian et al.
2004; Mozaffarian, Gottdiener, and Siscovick 2006). Therefore, to maximize the benefits of fish
consumption it is important to consider the method of preparation and the type of fish consumed
(i.e., choosing fish species with low methylmercury tissue concentrations and preparing it in a
healthy manner).
Plate 6-1. Father teaching his sons West Moberlys TEK regarding safety and respect for the
land, family history, and fishing practices regarding Bull Trout in the Crooked River system.
This preliminary quantitative HHRA is a science-based approach recommended by Health Canada

to evaluate risk to human receptors from adverse (physical) health effects caused by exposure to
mercury in fish. However, it is recognized that health is defined by more than just physical health.
Traditional foods, including fish, play an important role in the Aboriginal perspective of health and
6-1
well-being that cannot be assessed in the same quantitative manner as in this baseline report.
Changes in traditional diets, for instance, may result in the loss of culture and identity as the entire
socioeconomic system is disrupted (Chan and Receveur 2000:2)
The Aboriginal perspective on food and health are strongly integrated. These foods are more than
mere sustenance, as the mode of life with regard to harvesting and gathering promotes cultural and
social connectedness and the transmission of TEK to the next generations (Wheatley and Wheatley
2000) The social, cultural, spiritual, nutritional, and economic benefits of traditional foods together
play a role in how Aboriginal peoples in general perceive traditional foods, which may also be a
form of medicine and/or used in cultural ceremonies. The hunting, fishing, and gathering of
traditional foods and medicines, and subsequent sharing of these products with others throughout
the community are social activities that bring individuals and families together (INAC 2003).
Plate 6-2. West Moberlys Fish Camp on the shores of the Crooked River, BC.
6-2
7.
ASSUMPTIONS, UNCERTAINTIES, AND LIMITATIONS
7.1
FISH TISSUE SAMPLED FOR LABORATORY ANALYSIS
The tissue samples of fish were collected from the caudal penduncle area (near the tail) of the fish.
It is assumed for the purposes of the assessment that these tissue samples are representative of the
concentrations of mercury throughout the body of the fish. This is a likely a reasonable assumption.
A study done with Bluefin Tuna measured concentrations of mercury in the caudal penduncle and
in six other parts of fish muscle throughout the body (Lares et al. 2012). This study found that the
concentration of mercury in the caudal peduncle was a reasonable estimate of mercury
concentrations throughout the body, and concentrations in the caudal peduncle were 6% higher than
in the rest of the body.
Although it is not known with certainty if these findings apply to Bull Trout or other fish, it is likely
that the tissue sampled from the caudal penduncle of Bull Trout is representative (or slightly
overestimates) the mercury concentrations throughout the rest of the muscle tissue.
7.2
SAMPLE SIZE OF FISH
A total of 57 Bull Trout and 3 Northern Pikeminnow were sampled in 2012, based on fish provided
by First Nations individuals. The sample size for Bull Trout is considered adequately large to allow a
reasonably robust analysis, and likely represents the range of fish sizes that would be consumed by
people.
However, a sample size of three for the Northern Pikeminnow is too small to allow robust analysis
of the data. Given that the concentrations of mercury measured in the three Northern Pikeminnow
appear to be elevated, it is recommended that additional sampling of this species be conducted.
7.3
PROPORTION OF METHYLMERCURY
For fish, total mercury concentrations were measured in the tissue sent to ALS Environmental.
For fish, it is typically assumed that 100% of the total mercury concentration is in the form of
methylmercury (Health Canada 2007), although the proportion of methylmercury might be slightly
less than 100% (CCME 2003). Bloom (1992) suggests that the proportion of methylmercury relative
to total mercury is at least 95%, and states that virtually all of the mercury is in the methylmercury
form in fish tissues. While actual concentrations of methylmercury are likely to be slightly less than
the total concentration, this assumption ensures that the risk assessment is adequately conservative.
7.4
SELECTION OF POTENTIAL RECEPTORS
This risk assessment was limited in scope to consideration of just human consumers of fish. It did not
include an assessment of risk to other potential consumers of fish (e.g., piscivorous birds, fish-eating
mammals, or other wildlife species), or the potential for adverse effects on fish health and fish
populations. However, the Canadian Council of Ministers of the Environment (CCME; 2003) and the
7-1
(Nagpal 1989; BC MOE 2015b) have tissue residue guidelines for the protection of wildlife consumers
of fish, which is set at 0.033 mg/kg ww in fish. The concentrations of mercury in the Bull Trout and
Northern Pikeminnow measured in 2012 substantially exceed this guideline, suggesting that there is
potential risk to wildlife consumers of fish. It is recommended that a risk assessment be conducted for
wildlife consumers of fish to determine whether adverse effects could be occurring in these animals.
In addition, the measured mercury concentrations in Bull Trout and Northern Pikeminnow are also
above the concentrations at which effects to fish health may be expected. For example, Beckvar,
Dillon, and Read (2005) suggested that the threshold concentration for mercury effects in fish was
0.2 mg/kg ww. Almost all of the Bull Trout and all of the Northern Pikeminnow sampled in 2012
have concentrations in excess of that level. It is recommended that a risk assessment of the potential
for effects to fish health and fish populations due to mercury be considered.
7.5
HUMAN RECEPTOR GROUPS AND RECEPTOR CHARACTERIZATION
Four different potential receptor groups were included in the assessment, including three sensitive
populations (toddlers, children under 12 years old, and women of childbearing age or those who are
pregnant) and the general adult population. It is acknowledged that not all potential receptor groups
were considered in the assessment (e.g., children over 12 years old, elderly people). However, it is
likely that the receptor groups considered in the assessment represent the full range of potential
effects to human health, ranging from the most sensitive (e.g., toddlers) to the least sensitive
(i.e., general adult population).
Assumptions were made about certain human receptor characteristics, such as body weight.
These assumptions used standard references for human health assessment; however, it is
acknowledged that some of these references are becoming dated (e.g., Richardson 1997) and that the
assumed receptor characteristics represent the average person. People whose characteristics are
different than the average may actually have a slightly lower or higher level of risk than the
average person. However, it is expected that this variation is relatively small, particularly when
considering some of the other uncertainties in the assessment (e.g., consumption rates).
Consumption rates were used to calculate an EDI for mercury from Bull Trout consumption. Since
site-specific information is not available, the assumed consumption rates were based on
interpretation of qualitative TEK data (i.e., assigning a quantitative value to qualitative data) or
existing literature.
Some of the literature used, such as the study by Chan et al. (2011), have limitations and may not be
representative of the members of West Moberly, and perhaps others, who attend the Fish Camps. Chan
et al. (2011) surveyed First Nations individuals who live on reservations and queried people about their
consumption patterns for country foods. However, it is possible that Aboriginal peoples residing on
reserves have different consumption patterns than those residing off-reserve (or, more likely, offterritory). In addition, the sample size of respondents in some areas was quite small, which limits the
interpretation of the data. Some of the statistics presented by Chan et al. (2011) and used in this study
(e.g., portion sizes of fish) were based on responses by Aboriginal peoples living on reserves throughout
BC, and may not be representative of the members of West Moberly who attend Fish Camps.
7-2
ASSUMPTIONS, UNCERTAINTIES, AND LIMITATIONS
The fish consumption rate (one serving per week) used to calculate the EDI for the remainder of the
year outside of Fish Camp could be underestimated, and is not the most conservative assumption
that could be made (i.e., daily consumption throughout the year is most conservative). It is possible
that the risk during this time period is underestimated, although it may be balanced by assumptions
about the contribution of mercury from other foods or exposure routes during this portion of the
year (see Section 7.8). Regardless, given that the HQs calculated to estimate risk during the
remainder of the year outside of Fish Camp are greater than 1.0, the potential for risk to human
health was identified. The use of a more conservative assumption would not have changed the
outcome of this preliminary assessment.
In order to compensate for these uncertainties, the assessment relied on multiple other methods of
data analysis in order to characterize risk (e.g., comparison of measured tissue concentrations in fish
to tissue residue guidelines, calculation of RMWIs, in addition to calculation of HQs). Similar
conclusions were reached using each analysis method, suggesting that the conclusions reached in
the assessment are reasonable.
7.6
CONTAMINANTS OF P OTENTIAL CONCERN
This risk assessment was limited in scope to consideration of the potential for effects to human
health due to mercury. However, other metals (which were measured in fish tissue; Appendix C)
could also be elevated in fish tissue and an assessment of the potential effects on human health due
to these metals should also be conducted. Although it is likely that mercury is the COPC of greatest
concern, other metals could also have the potential to affect human health
7.7
MERCURY TISSUE CONCENTRATION GUIDELINES
As noted in Section 5.1.1, the Health Canada maximum contaminant standard for mercury was
developed as a guideline for retail fish, and may not be directly applicable to tissue concentrations of
mercury in wild fish. In addition, the standard is based on protection of average or typical
consumers of retail fish. The guideline may not be adequately protective of people who eat a lot of
fish, such as subsistence consumers of fish.
Similarly, the BC MOEs aquatic life guidelines for mercury in fish tissue (for the protection of
human consumers; Section 5.1.2) may not be protective of fish consumers with high consumption
rates. In addition, this guideline was developed in 1989 (Nagpal 1989). The methods used to
calculate the guidelines for mercury tissue concentrations are outdated and are not consistent with
the current standard approaches for HHRA. In addition, the TDI used in the calculation is higher
than the current pTDI in use for methylmercury, meaning that the guidelines are more permissive
than would be currently allowed.
Therefore, comparison of the measured mercury concentrations in Bull Trout or Northern
Pikeminnow to either the Health Canada standard or the BC MOE aquatic life guideline can only
provide a general estimate of risk, since it is likely to underestimate the risk due to mercury
consumption in individuals with higher than average consumption rates of fish.
7-3
7.8
ADJUSTMENT OF METHYLMERCURY PROVISIONAL TOLERABLE D AILY INTAKE

BASED ON C ONSUMPTION P ATTERNS
Since mercury concentrations in ambient air and water are very low, they are not a significant
exposure route for humans (Goyer and Clarkson 2001; Clarkson, Magos, and Myers 2003), and diet
is the primary exposure route (Health Canada 2007). While some quantity of mercury is found in all
foods, the concentrations in fruits and vegetables are very low, and for people who regularly
consume fish, fish is their primary source of dietary exposure to mercury (Dabeka, McKenzie, and
Bradley 2003; Health Canada 2007). Other exposure routes to minute concentrations of mercury
include dental fillings, broken thermometers, cigarette smoke, and occupational settings such as
chemical processing plants and medical facilities (Health Canada 2007)
This risk assessment did not take into account these other potential exposures to mercury during the
Fish Camp, since it was assumed that all mercury comes from consumption of Bull Trout during this
time. However, it is safe to assume that exposures other than those calculated here from the
consumption of Bull Trout are relatively insignificant, especially if few retail fish species are
consumed, such as would occur at the Fish Camp. While it is possible that the risk due to
consumption of fish during the Fish Camps is underestimated (by not accounting for background
exposures), it is likely that other assumptions have compensated for this (e.g., use of 95th percentile
mercury concentrations) and that background exposure to mercury during this time is negligible
relative to the exposure from Bull Trout.
During the rest of the year, it was assumed that people may have exposure to mercury via other
foods or exposure pathways. Thus, adjusting the TRV to be 20% of the pTDI (Section 4.3) is a
conservative measure to take into account background exposure as per Health Canada (2010a). The
risk to human health during the rest of the year (outside of Fish Camp) may be overestimated by
employing this conservative assumption.
7-4
8.
SUMMARY AND RECOMMENDATIONS
8.1
SUMMARY AND CONCLUSIONS
TEK of the West Moberly provided the basis for the assessment of risk to human health due to
consumption of Bull Trout from the Crooked River system. Given the connectivity of the Crooked
River system to the Williston Reservoir, where a fish advisory is in place due to mercury, there was
concern that mercury concentrations in fish harvested from this river system would also be elevated.
Therefore, a preliminary quantitative HHRA focused on mercury was done to determine what, if
any, risk there is to human health due to consumption of Bull Trout from the Crooked River system.
The HHRA followed standard Health Canada guidance, and focused on Aboriginal consumers,
including consideration of traditional practices and consumption patterns (Sections 1 and 2).
Traditional practices related to fish consumption may include attendance at Fish Camps; periods of
time where a number of Bull Trout are harvested, and either consumed immediately or taken home
for later consumption (Section 2.1.1). Fish may be consumed by people of all ages and both genders,
either fresh (i.e., freshly caught or from the freezer), or dried (e.g., smoked or otherwise dried).
Fish harvested by attendees of the Fish Camps may be taken home and kept for personal
consumption throughout the year, distributed to other family or community members, or potentially
used for trade or sale to the wider community.
Samples of Bull Trout (n = 57) and Northern Pikeminnow (n = 3) were collected in 2012, and analyzed
for age and mercury content (Section 2.1.2). Fish were also measured and weighted. Results indicate
that the average age of Bull Trout sampled in 2012 was approximately 7 years old. The average fish
length was 521 mm (52.1 cm), and the average weight was 1.78 kg. Other summary statistics were also
calculated and these are provided in Table 3.2-1 (Section 3.2.1). A significant correlation was found
between the concentration of mercury in fish and the age, length, and weight of the fish (Section 3.2).
Generally, as the fish become older or larger, the tissue concentrations of mercury increase.
The concentrations of mercury measured in the tissue of Bull Trout and Northern Pikeminnow are
relatively high (Section 5.1). All of the Northern Pikeminnow and 37% of the Bull Trout had tissue
mercury concentrations that exceeded the Health Canada Maximum Contaminant Standard and the
BC MOE guideline of 0.5 mg/kg ww. In comparison to the most permissive BC MOE guideline for
fish tissue of 0.1 mg/kg ww (which is based on the consumption of approximately 1 kg of fish per
week), 98% of the Bull Trout had tissue mercury concentrations that exceed the guideline. Since
many of the fish sampled in 2012 had mercury concentrations greater than guidelines, it suggests
that there could be risk to human health, particularly in people with high consumption rates for fish.
When mercury in food is taken into the human body in high enough quantities, adverse effects to
human health are possible (Section 4). The most sensitive population for mercury toxicity is the
unborn fetus, where exposure occurs due to intake of mercury by the pregnant woman, and
development effects can occur in the child after birth. Therefore, pregnant women, women of
child-bearing age who may become pregnant, toddlers, and children under 12 are considered to be
the most sensitive populations for mercury exposure. The amount of methylmercury that is
8-1
considered tolerable for intake by sensitive populations, without causing adverse effects, is
0.0002 mg/kg bw/day. Other potential effects of mercury could occur in the general population at
higher concentrations, such as effects on the immune system, cardiovascular system, or nervous
system. The amount of methylmercury considered tolerable for intake by the general population,
without causing adverse effects, is 0.00047 mg/kg bw/day.
Further analysis of the risk to human health was done by calculating a RMWI for Bull Trout
(Section 5.2). Since this study is intended to be a preliminary assessment of risk, conservative
estimates of mercury concentrations in fish were used (i.e., 95th percentile concentrations) to ensure
that the calculations are protective of health. More detailed analysis of RMWI was also done based
on the correlations between fish mercury concentration and fish length or weight (see Sections 5.2.2
and 5.2.3 for details). The RMWIs took into consideration the consumption patterns for fish
consumption (i.e., high frequencies of fish consumption during Fish Camp, lower frequency
throughout the rest of the year) and the way fish might be eaten (i.e., fresh or dried).
RMWIs calculated based on the 95th percentile of mercury concentrations in Bull Trout sampled in
2012 suggest that consumption of fresh Bull Trout for the general population (i.e., those individuals
not in a sensitive group) during the Fish Camps should be kept below 0.292 kg fish/week.
The RMWIs for fresh Bull Trout are lower for those in the sensitive groups, ranging from 0.025 kg
fish/week for toddlers, 0.046 kg fish/week for children under 12 years of age, and 0.106 kg
fish/week for women of childbearing age or those who are pregnant. Consumption of dried fish
should be kept lower, with RWMIs ranging between 0.011 kg/week for toddlers up to
0.129 kg/week in the general population. It is probable that people are consuming more fish than is
recommended during the Fish Camps.
Similarly, during the remainder of the year, the RMWI of Bull Trout for the general population
based on the 95th percentile of mercury concentrations for fresh fish is 0.058 kg/week and for dried
fish is 0.026 kg/week. The RMWIs are lower for those in the sensitive groups, ranging from
0.005 kg/week fresh fish or for toddlers, 0.009 kg fish/week for children under 12 years of age, and
0.021 kg fish/week for women of childbearing age or those who are pregnant. For dried fish, the
RMWIs are 0.002 kg/week for toddlers, 0.004 kg/week for children under 12, and 0.009 kg/week for
sensitive adults. It is possible that people are consuming more fish than is recommended during the
time of year outside of the Fish Camp.
Hazard quotients were also calculated, based on a ratio of the EDI and the pTDI (Section 5.3); this
was only done for fresh fish, since there was uncertainty in the quantity and frequency of dried fish
consumption. When the HQ is greater than 1.0, it suggests that there could be a risk to human
health. During the Fish Camps, the HQs ranged from 7.8 in the general population to 45.1 in
toddlers when considering consumption of fresh fish. During the remainder of the year (assuming a
consumption frequency of once per week), the HQs ranged from 2.8 in the general population to
16.1 in toddlers. These HQs suggest that there could be risk to human health from the consumption
of Bull Trout from the Crooked River system.
Consumption of fish has many benefits to health, including physical, mental, cultural, and spiritual
well-being (Section 6). It is important that people consider both the risks and the benefits of fish
consumption in order to make the most informed decisions about whether or not fish should be eaten.
8-2
8.2
RECOMMENDATIONS
The current study found that the concentrations of mercury in fish tissue in the Crooked River were
elevated, and that potential adverse effects to human consumers of this fish is possible, particularly
for Aboriginal peoples.
Based on the findings of this study, a number of recommendations are made in order to ensure that
a proactive approach is implemented regarding the health of Aboriginal peoples, as well as the
general public, which incorporates communications, investigation, and assessment as foundational
components. Recommendations include, but are not limited to, the following at this time:
1. Education program with Aboriginal peoples
1.1.
Immediately develop and implement an education program focused on potentially affected

Aboriginal peoples, including the generation of materials that can be distributed to
Aboriginal consumers, to ensure that members of the Aboriginal groups understand the risk
to their health due to consumption of fish with elevated mercury concentrations. This should
be done immediately, and again on an annual, or at a minimum a bi-annual basis, in the
future.Based on the spatial extent Williston Reservoir and its tributaries, an initial scope of
Aboriginal peoples suggests the following: Fort Nelson First Nation, Prophet River First
Nation, Blueberry River First Nations, Doig River First Nation, Halfway River First Nation,
Kelly Lake Aboriginal communities, Saulteau First Nations, West Moberly First Nations,
MLIB, Nakazdli First Nation, Takla First Nation, Tsay Keh Dene First Nation, and
Kwadacha Nation. The following Aboriginal organizations should also be included: Kaska
Dena Council, Treaty 8 Tribal Association, Carrier Sekani Tribal Council, British Columbia
Union of Indian Chiefs and the Assembly of First Nations.
2. Education program with the general public

2.1.
Immediately develop and implement an education program, including the development of

materials that can be distributed to fish consumers, to ensure that people understand the risk
to their health due to consumption of fish with elevated mercury concentrations. This should
be done immediately, and again on an annual or bi-annual basis in the future.Based on the
proximity of the Williston Reservoir and its tributaries to municipalities, the following
should be considered for the education program: City of Fort St. John, District of Hudsons
Hope, City of Dawson Creek, District of Tumbler Ridge, District of Chetwynd, District of
Mackenzie, District of Fort St. James, and the City of Prince George The following health
organizations should also be included: Northern Health Authority, Health Canada, First
Nations Health Authority. Educational institutions may also be interested in attending, such
as the universities and colleges in Western Canada.
3. Characterize the TEK and human receptor characteristics

3.1.
Conduct additional TEK studies with each First Nation (including, e.g., a fish consumption
survey) in order to better define human receptor characteristics, more accurately characterize
the risk to human health, and address uncertainties identified in the risk assessment;
8-3
4. Sample fish harvested in accordance with the Seasonal Round

4.1.
Conduct additional fish sampling throughout the rivers, creeks, lakes, and the reservoirs
order to understand the geographical extent of the occurrence of elevated mercury
concentrations in fish tissues, including species within the traditional seasonal rounds of the
First Nations. This should be done every three to five years in order to characterize temporal
variability and trends over time. Part of this study should include identification of barriers to
fish movement, which will aid in defining the spatial extent of potential issues.
4.2.
Conduct sampling of various fish species, particularly those that are long lived and at high
trophic level, to more fully characterize the risk due to consumption of various species of
fish (e.g., Lake Trout, Bull Trout, Northern Pikeminnow). This is recommended because
Northern Pikeminnow were also found (unexpectedly) to have elevated tissue mercury
concentrations.
4.3.
Conduct tagging studies of species within the traditional seasonal round to understand the
movement patterns of species that may have elevated levels of mercury.
4.4.
Sample and tag fish in the Peace River, Pine River, Kiskatinaw River, Beatton River, Halfway
River, Sikanni Chief, and Prophet River watersheds to account for additional influences
(e.g., metals) that may be adverse to human health due to natural and anthropogenic
activities (e.g., forestry, mining, oil and gas).
5. Assess the health risk of metals to Aboriginal peoples

5.1.
Conduct additional analysis of the existing Bull Trout dataset to evaluate the potential risk to
human health due to other metals that are present in the fish tissue, beyond mercury;
5.2.
Conduct a detailed quantitative HHRA, once additional data is collected to address

uncertainties identified in this HHRA
6. Assess the ecological risk to fish and consumers of fish

6.1.
Collect samples of other media (e.g., water and sediment that are co-collected to the extent
possible with fish samples) or biota (e.g., benthic invertebrates) to support the assessment of
risk to fish or wildlife.
6.2.
Conduct an ecological risk assessment to evaluate the risk to wildlife consumers of fish (e.g.,
piscivorous birds or terrestrial mammals such as bears), given that the concentration of
mercury in fish tissue exceeds the BC MOE and CCME mercury tissue residue guidelines for
the protection of wildlife consumers of fish.
6.3.
Conduct an ecological risk assessment to evaluate the risk to fish health and fish
populations, since the concentration of mercury in fish tissue is approaching or exceeds the
concentration at which toxicity may occur in some fish species.
7. Investigate the potential source(s) of metals

7.1.
8-4
Conduct or update mapping that shows various industrial developments, forestry, and
activities that have occurred or are occurring with the study area (defined as the Williston
Reservoir watershed);
7.2.
Collect and compile existing data to the extent possible to enable a preliminary assessment of
what, if any, developments or activities could have contributed to metal loading within the
watershed.
7.3.
Conduct a quantitative analysis of the potential sources of metals that may affect ecological
and human health.
8. Develop Strategic Follow-up Plans

8.1.
Develop and implement a short-term strategic plan (i.e., 1-3 years) that considers the
immediate needs and priorities regarding human health issues, including communication,
investigation, and assessment. This should include a Traditional Foods and Medicines
Health Advisory Council for the region. Secure adequate funding to implement the plan.
8.2.
Develop and implement a long-term strategic plan (e.g.,., 3-12 years) that considers the needs
and priorities regarding human health issues, including communication, investigation, and
assessment. Implementation would be administered by the Traditional Foods and Medicines
Advisory Council. Secure adequate funding to implement the plan.
Studies should use a community-based approach when designing the projects, which are based on
the TEK of the Aboriginal people(s) and involves them in all aspects of the research as lead
co-investigators (e.g., the overall approach should be representative of the design and methods used
in the Crooked River project, such as the location and species of fish that are to be included).
Discussions with potentially affected Aboriginal peoples and municipalities, in addition to the input
provided by health organizations, may provide relevant supplemental information that should be
taken into consideration. Additional studies and engagement processes may be required as a result.
8-5
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Wheatley, B. and Wheatley M.A. 2000. Methlymercury and tbe health of indigneous peoples: a risk
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R-4
Appendix A
Raw Data from Biological Measurements of Fish from the
Crooked River, September 2012
Aboriginal Health Risk Assessment of Mercury in Bull Trout Harvested from the Crooked
River, British Columbia
Appendix A. Raw Data from Biological Measurements of Fish from the Crooked River, September 2012
Fish Number
1
2A
2B
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17A
17B
18
19
21
22
24
25
26
27
28
29
30
31
32
34A
34B
34C
35
37
38
39
40
41
42
43
44
45
46
47
48
Species
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
northern pike minnow
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
Frozen Weight Frozen Weight Frozen Length

(g)
(kg)
(mm)
Tissue Sample Aging Sample
1,249
3,254
1,180
1,312
1,230
1,996
2,890
3,602
2,973
1,064
818
814
978
2,178
2,275
2,405
4,898
4,835
4,632
2,791
1,037
589
816
1,111
546
594
1,697
1,625
1,567
1,614
3,258
2,970
2,445
752
438
511
499
364
3,390
1,289
2,731
572
1,263
1,336
2,580
1,042
2,536
1,291
1.25
3.25
1.18
1.31
1.23
2.00
2.89
3.60
2.97
1.06
0.82
0.81
0.98
2.18
2.28
2.41
4.90
4.84
4.63
2.79
1.04
0.59
0.82
1.11
0.55
0.59
1.70
1.63
1.57
1.61
3.26
2.97
2.45
0.75
0.44
0.51
0.50
0.36
3.39
1.29
2.73
0.57
1.26
1.34
2.58
1.04
2.54
1.29
Page 1 of 2
505
600
490
495
510
535
570
660
645
450
440
455
465
590
610
590
680
780
800
635
545
390
450
450
360
385
465
555
525
530
650
640
630
420
350
360
335
345
710
490
660
365
515
470
575
420
640
470
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Appendix A. Raw Data from Biological Measurements of Fish from the Crooked River, September 2012
Fish Number
49
50
51
52
53
54
55
56
57
58
59
60
Notes:
Species
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
Frozen Weight Frozen Weight Frozen Length

(g)
(kg)
(mm)
Tissue Sample Aging Sample
589
1,152
925
574
823
1,342
1,163
960
774
461
4,487
5,024
0.59
1.15
0.93
0.57
0.82
1.34
1.16
0.96
0.77
0.46
4.49
5.02
g = grams, kg = kilograms, Y = yes, N = no
Page 2 of 2
410
475
420
425
480
495
485
435
460
390
780
780
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Appendix B
Raw Aging Analysis Results for Fish from the Crooked River,
September 2012
Appendix B. Raw Aging Analysis Results for Fish from the Crooked River, September 2012
Species
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
northern pike
northern pike
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
Fish Number
Age (years)
Confidence
Index
1
2A
2B
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17A
17B
18
19
21
22
24
25
26
27
28
30
31
32
34A
34B
34C
35
37
38
39
40
41
42
43
44
45
46
47
48
49
7
7
9
8
8
9
7
10
9
5
8
7
5
12
4
7
16
10
8
10
7
7
7
7
7
7
26
30
8
11
7
7
6
7
8
8
4
10
5
8
5
7
6
9
6
8
5
4
F
F
F
F
F
F
F
F
F
P
P
F
P
F
F
F
F
F
F
F
F
F
P
F
F
F
P
P
F
F
F
F
P
VP
F
F
F
F
F
F
F
VP
P
P
P
P
VP
F
Page 1 of 2
QA/QC Age
(years)
23
8
10
Appendix B. Raw Aging Analysis Results for Fish from the Crooked River, September 2012
Species
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
bull trout
Average Age of Bull Trout
Average Age of Northern Pike
Notes:
Fish Number
Age (years)
50
51
52
53
54
55
56
57
58
59
60
5
6
4
3
5
7
4
4
4
8
8
7
28
Confidence
Index
QA/QC Age
(years)
F
F
P
P
F
P
P
P
P
F
F
Confidence Indices are based on qualitative characteristics (pattern clarity) and quantitative characteristics (repeatability)
F = Fair; annuli are fairly clear with some areas presenting easy and moderate interpretation problems; Reader would be within 1 year
most of the time for fish<10 years and 2-3 years for fish >10 years
P = Poor; annuli are fairly unclear presenting a number of difficult interpretation problems; Reader would be within 2-3 years most of the
time for fish <15 years and 4-5 years for fish >15 years
VP = Very Poor; annuli are very unclear presenting significant interpretation problems; Reader has little confidence in repeatability of age
within 4-5 years
Page 2 of 2
Appendix C
Raw Tissue Metal Analysis Results for Fish from the Crooked
River, September 2012
Appendix C. Raw Tissue Metal Analysis Results for Fish from the Crooked River, September 2012
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Beryllium (Be)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Magnesium (Mg)-Total
Manganese (Mn)-Total
Mercury (Hg)-Total
Molybdenum (Mo)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Strontium (Sr)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
1
13-SEP-12
L1211293-1
Tissue
2A
13-SEP-12
L1211293-2
Tissue
2B
13-SEP-12
L1211293-3
Tissue
3
13-SEP-12
L1211293-4
Tissue
4
13-SEP-12
L1211293-5
Tissue
5
13-SEP-12
L1211293-6
Tissue
6
13-SEP-12
L1211293-7
Tissue
7
13-SEP-12
L1211293-8
Tissue
0.10
77.8
76.6
72.3
78.0
76.0
75.8
67.6
77.7
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
<0.010
0.028
<0.10
<0.030
<0.0050
223
<0.10
<0.020
0.335
<0.020
<0.10
167
0.135
0.308
<0.010
<0.10
0.49
0.114
<0.010
<0.050
<0.0020
<0.10
4.86
<2.0
<0.010
0.087
0.113
<0.10
<0.030
<0.0050
939
<0.10
<0.020
0.695
<0.020
<0.10
157
0.409
0.691
<0.010
<0.10
0.77
0.467
<0.010
<0.050
<0.0020
<0.10
12.1
2.8
<0.010
0.128
0.086
<0.10
<0.030
0.0111
375
<0.10
<0.020
0.735
<0.020
<0.10
153
0.200
0.357
<0.010
<0.10
0.94
0.227
<0.010
<0.050
<0.0020
<0.10
7.34
8.6
<0.010
0.088
0.219
<0.10
<0.030
<0.0050
412
<0.10
<0.020
0.516
0.021
<0.10
222
0.373
0.351
<0.010
<0.10
0.82
0.260
<0.010
<0.050
<0.0020
<0.10
5.79
<2.0
<0.010
0.047
0.033
<0.10
<0.030
<0.0050
156
<0.10
<0.020
0.661
<0.020
<0.10
102
0.106
0.407
<0.010
<0.10
0.48
0.089
<0.010
<0.050
<0.0020
<0.10
5.59
<2.0
<0.010
0.017
0.039
<0.10
<0.030
<0.0050
272
<0.10
<0.020
0.710
<0.020
<0.10
189
0.162
0.726
0.013
<0.10
0.54
0.118
<0.010
0.059
<0.0020
<0.10
6.72
<2.0
<0.010
0.032
0.023
<0.10
<0.030
0.0331
264
<0.10
<0.020
0.926
<0.020
<0.10
149
0.112
0.362
<0.010
<0.10
0.64
0.145
<0.010
0.051
<0.0020
<0.10
7.48
<2.0
<0.010
0.050
0.029
<0.10
<0.030
<0.0050
316
<0.10
<0.020
0.555
<0.020
<0.10
118
0.087
0.527
<0.010
<0.10
0.73
0.166
<0.010
0.053
<0.0020
<0.10
8.13
Notes:
Sample L1211293-9 and L1211293-61 were labelled as 8A and 8B by ALS Environmental at the time of sample submission. The Sample Receipt Confirmation from ALS Environmental indicates that two
samples were labelled as "8", and no samples were labelled as "12". Sample 1211293-9 was assumed to be from Fish #12 and sample 121293-61 was assumed to be from Fish #8, based on fish sizes and
mercury content.
mg/kg ww = milligrams per kilogram wet weight
Page 1 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
8
13-SEP-12
L1211293-61
Tissue
9
13-SEP-12
L1211293-10
Tissue
10
13-SEP-12
L1211293-11
Tissue
11
13-SEP-12
L1211293-12
Tissue
12
13-SEP-12
L1211293-9
Tissue
13
13-SEP-12
L1211293-14
Tissue
14
13-SEP-12
L1211293-15
Tissue
15
13-SEP-12
L1211293-16
Tissue
0.10
75.7
77.3
78.7
77.9
77.1
77.1
71.6
72.8
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
3.0
<0.010
0.041
0.046
<0.10
<0.030
<0.0050
171
<0.10
<0.020
0.453
<0.020
<0.10
100
0.145
0.681
<0.010
<0.10
0.48
0.105
<0.010
<0.050
<0.0020
<0.10
3.70
32.3
<0.010
0.025
0.724
<0.10
<0.030
<0.0050
863
<0.10
0.033
1.05
<0.020
<0.10
157
1.13
0.275
<0.010
0.11
0.36
0.725
<0.010
<0.050
0.0026
0.15
10.1
3.8
<0.010
0.052
0.064
<0.10
<0.030
<0.0050
225
<0.10
<0.020
0.453
<0.020
<0.10
202
0.185
0.240
<0.010
<0.10
0.52
0.178
<0.010
<0.050
<0.0020
<0.10
5.46
16.1
<0.010
0.039
0.141
<0.10
<0.030
<0.0050
262
<0.10
<0.020
0.477
<0.020
<0.10
195
0.352
0.219
<0.010
<0.10
0.55
0.238
<0.010
<0.050
<0.0020
<0.10
6.06
3.2
<0.010
0.031
0.056
<0.10
<0.030
<0.0050
245
<0.10
<0.020
0.525
<0.020
<0.10
185
0.151
0.266
<0.010
<0.10
0.54
0.174
<0.010
<0.050
<0.0020
<0.10
7.52
<2.0
<0.010
0.022
0.229
<0.10
<0.030
<0.0050
2570
<0.10
<0.020
1.01
<0.020
<0.10
196
0.422
0.717
<0.010
<0.10
0.53
1.18
<0.010
<0.050
<0.0020
<0.10
12.7
<2.0
<0.010
0.055
0.049
<0.10
<0.030
<0.0050
449
<0.10
<0.020
0.607
<0.020
<0.10
212
0.168
0.205
<0.010
<0.10
0.69
0.214
<0.010
<0.050
<0.0020
<0.10
6.67
<2.0
<0.010
0.076
0.063
<0.10
<0.030
<0.0050
402
<0.10
<0.020
0.676
<0.020
<0.10
194
0.193
0.537
<0.010
<0.10
0.85
0.223
<0.010
0.060
<0.0020
<0.10
7.89
Notes:
mercury content.
Page 2 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
16
13-SEP-12
L1211293-17
Tissue
17A
13-SEP-12
L1211293-18
Tissue
17B
13-SEP-12
L1211293-19
Tissue
18
13-SEP-12
L1211293-20
Tissue
19
13-SEP-12
L1211293-21
Tissue
21
13-SEP-12
L1211293-22
Tissue
22
13-SEP-12
L1211293-23
Tissue
24
13-SEP-12
L1211293-24
Tissue
0.10
74.9
77.2
78.7
71.4
80.6
77.3
76.4
73.9
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.038
0.035
<0.10
<0.030
0.0072
342
<0.10
<0.020
0.652
<0.020
<0.10
169
0.132
0.905
<0.010
<0.10
0.54
0.173
<0.010
<0.050
<0.0020
<0.10
7.80
2.1
<0.010
0.052
0.069
<0.10
<0.030
<0.0050
592
<0.10
<0.020
0.998
<0.020
<0.10
191
0.201
0.923
<0.010
<0.10
0.69
0.277
<0.010
<0.050
<0.0020
<0.10
9.15
4.0
<0.010
0.022
0.062
<0.10
<0.030
<0.0050
336
<0.10
<0.020
0.898
<0.020
<0.10
116
0.181
0.530
<0.010
<0.10
0.53
0.174
<0.010
<0.050
<0.0020
<0.10
13.0
<2.0
<0.010
0.028
0.032
<0.10
<0.030
<0.0050
148
<0.10
<0.020
0.356
<0.020
<0.10
113
0.089
0.564
<0.010
<0.10
0.45
0.092
<0.010
<0.050
<0.0020
<0.10
5.51
<2.0
<0.010
0.160
0.030
<0.10
<0.030
0.0084
254
<0.10
<0.020
0.428
<0.020
<0.10
171
0.150
0.424
0.012
<0.10
0.95
0.153
<0.010
0.058
<0.0020
<0.10
6.74
<2.0
<0.010
0.036
0.071
<0.10
<0.030
<0.0050
451
<0.10
<0.020
0.717
0.033
<0.10
150
0.113
0.176
<0.010
<0.10
0.62
0.310
<0.010
<0.050
<0.0020
<0.10
6.95
<2.0
<0.010
0.037
0.034
<0.10
<0.030
<0.0050
199
<0.10
0.022
0.448
<0.020
<0.10
169
0.082
0.289
0.013
<0.10
0.44
0.120
<0.010
<0.050
<0.0020
<0.10
4.12
4.6
<0.010
0.025
0.063
<0.10
<0.030
<0.0050
188
<0.10
<0.020
0.481
<0.020
<0.10
201
0.174
0.458
<0.010
<0.10
0.75
0.135
<0.010
<0.050
<0.0020
<0.10
5.45
Notes:
mercury content.
Page 3 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
25
13-SEP-12
L1211293-25
Tissue
26
13-SEP-12
L1211293-26
Tissue
27
13-SEP-12
L1211293-27
Tissue
28
13-SEP-12
L1211293-28
Tissue
29
13-SEP-12
L1211293-29
Tissue
30
13-SEP-12
L1211293-30
Tissue
31
13-SEP-12
L1211293-31
Tissue
32
13-SEP-12
L1211293-32
Tissue
0.10
74.1
76.3
76.6
79.3
77.1
76.6
73.7
74.2
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.012
0.021
<0.10
<0.030
<0.0050
211
<0.10
<0.020
0.534
<0.020
<0.10
168
0.080
0.0708
<0.010
<0.10
0.40
0.117
<0.010
<0.050
<0.0020
<0.10
5.84
<2.0
<0.010
0.047
0.024
<0.10
<0.030
<0.0050
211
<0.10
<0.020
0.627
<0.020
<0.10
179
0.129
0.259
<0.010
<0.10
0.64
0.117
<0.010
<0.050
<0.0020
<0.10
6.40
<2.0
<0.010
<0.010
0.197
<0.10
<0.030
<0.0050
731
<0.10
<0.020
0.348
<0.020
<0.10
174
0.154
0.759
<0.010
<0.10
0.31
0.437
<0.010
<0.050
<0.0020
<0.10
5.34
<2.0
<0.010
<0.010
0.052
<0.10
<0.030
<0.0050
216
<0.10
<0.020
0.290
<0.020
<0.10
165
0.067
0.899
<0.010
<0.10
0.33
0.117
<0.010
<0.050
<0.0020
<0.10
4.76
3.6
<0.010
<0.010
0.150
<0.10
<0.030
<0.0050
588
<0.10
<0.020
0.419
<0.020
<0.10
179
0.171
0.996
<0.010
<0.10
0.32
0.357
<0.010
<0.050
<0.0020
<0.10
4.89
<2.0
<0.010
0.053
0.086
<0.10
<0.030
<0.0050
290
<0.10
<0.020
0.675
<0.020
<0.10
99.5
0.098
0.581
<0.010
<0.10
0.69
0.174
<0.010
<0.050
<0.0020
<0.10
5.49
<2.0
<0.010
0.036
0.027
<0.10
<0.030
<0.0050
188
<0.10
<0.020
0.787
<0.020
<0.10
135
0.107
0.548
<0.010
<0.10
0.43
0.114
<0.010
<0.050
<0.0020
<0.10
7.65
<2.0
<0.010
0.034
0.055
<0.10
<0.030
0.0069
694
<0.10
<0.020
1.20
<0.020
<0.10
139
0.129
0.556
<0.010
<0.10
0.83
0.358
<0.010
<0.050
<0.0020
<0.10
13.4
Notes:
mercury content.
Page 4 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
34A
13-SEP-12
L1211293-33
Tissue
34B
13-SEP-12
L1211293-34
Tissue
34C
13-SEP-12
L1211293-35
Tissue
35
13-SEP-12
L1211293-36
Tissue
37
13-SEP-12
L1211293-37
Tissue
38
13-SEP-12
L1211293-38
Tissue
39
13-SEP-12
L1211293-39
Tissue
40
13-SEP-12
L1211293-40
Tissue
0.10
73.1
73.6
76.1
78.0
79.1
77.4
77.2
76.8
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.021
0.040
<0.10
<0.030
<0.0050
165
<0.10
0.054
0.517
<0.020
<0.10
185
0.141
0.574
<0.010
<0.10
0.50
0.091
<0.010
<0.050
<0.0020
<0.10
5.07
<2.0
<0.010
0.010
0.068
<0.10
<0.030
<0.0050
625
<0.10
<0.020
0.681
<0.020
<0.10
178
0.198
0.286
<0.010
<0.10
0.39
0.314
<0.010
<0.050
<0.0020
<0.10
7.27
<2.0
<0.010
0.014
0.068
<0.10
<0.030
0.0052
531
<0.10
<0.020
0.782
<0.020
<0.10
162
0.153
0.163
<0.010
<0.10
0.51
0.345
<0.010
<0.050
<0.0020
<0.10
8.41
<2.0
<0.010
0.084
0.040
<0.10
<0.030
<0.0050
218
<0.10
0.021
0.448
<0.020
<0.10
127
0.101
0.163
<0.010
<0.10
0.78
0.189
<0.010
<0.050
<0.0020
<0.10
6.58
<2.0
<0.010
0.047
0.022
<0.10
<0.030
<0.0050
223
<0.10
<0.020
0.386
<0.020
<0.10
204
0.099
0.193
<0.010
<0.10
0.54
0.130
<0.010
<0.050
<0.0020
<0.10
5.07
<2.0
<0.010
0.031
0.051
<0.10
<0.030
0.0057
217
<0.10
<0.020
0.433
<0.020
<0.10
89.8
0.068
0.257
<0.010
<0.10
0.40
0.123
<0.010
<0.050
<0.0020
<0.10
5.11
<2.0
<0.010
0.063
<0.010
<0.10
<0.030
<0.0050
88.5
<0.10
<0.020
0.269
<0.020
<0.10
111
0.239
0.742
<0.010
<0.10
0.57
0.039
<0.010
<0.050
<0.0020
<0.10
4.22
<2.0
<0.010
0.015
0.018
<0.10
<0.030
<0.0050
140
<0.10
<0.020
0.351
<0.020
<0.10
155
0.066
0.343
<0.010
<0.10
0.38
0.099
<0.010
<0.050
<0.0020
<0.10
4.16
Notes:
mercury content.
Page 5 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
41
13-SEP-12
L1211293-41
Tissue
42
13-SEP-12
L1211293-42
Tissue
43
13-SEP-12
L1211293-43
Tissue
44
13-SEP-12
L1211293-44
Tissue
45
13-SEP-12
L1211293-45
Tissue
46
13-SEP-12
L1211293-46
Tissue
47
13-SEP-12
L1211293-47
Tissue
48
13-SEP-12
L1211293-48
Tissue
0.10
76.7
77.0
75.1
74.9
75.3
72.5
78.8
73.3
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.058
0.014
<0.10
<0.030
<0.0050
122
<0.10
<0.020
0.348
<0.020
<0.10
173
0.061
0.580
<0.010
<0.10
0.53
0.069
<0.010
<0.050
<0.0020
<0.10
4.40
<2.0
<0.010
<0.010
0.031
<0.10
<0.030
<0.0050
267
<0.10
<0.020
0.495
<0.020
<0.10
162
0.091
0.248
<0.010
<0.10
0.47
0.161
<0.010
<0.050
<0.0020
<0.10
5.71
3.2
<0.010
0.026
0.049
<0.10
<0.030
<0.0050
173
<0.10
<0.020
0.529
<0.020
<0.10
141
0.162
0.501
<0.010
<0.10
0.38
0.094
<0.010
<0.050
<0.0020
<0.10
4.21
<2.0
<0.010
0.011
0.033
<0.10
<0.030
<0.0050
184
<0.10
<0.020
0.424
<0.020
<0.10
118
0.071
0.499
<0.010
<0.10
0.28
0.107
<0.010
<0.050
<0.0020
<0.10
4.63
<2.0
<0.010
0.068
0.064
<0.10
<0.030
<0.0050
362
<0.10
<0.020
1.06
<0.020
<0.10
161
0.163
0.759
<0.010
<0.10
0.72
0.185
<0.010
<0.050
<0.0020
<0.10
9.38
<2.0
<0.010
0.014
0.058
<0.10
<0.030
<0.0050
255
<0.10
<0.020
0.507
<0.020
<0.10
148
0.124
<0.0010
<0.010
<0.10
0.21
0.170
<0.010
<0.050
<0.0020
<0.10
7.93
<2.0
<0.010
0.030
0.055
<0.10
<0.030
<0.0050
327
<0.10
<0.020
0.590
<0.020
<0.10
108
0.112
1.00
<0.010
<0.10
0.60
0.177
<0.010
<0.050
<0.0020
<0.10
7.46
2.3
<0.010
0.052
0.166
<0.10
<0.030
<0.0050
1870
<0.10
<0.020
0.899
<0.020
<0.10
190
0.187
0.476
<0.010
<0.10
0.58
1.04
<0.010
<0.050
<0.0020
<0.10
9.80
Notes:
mercury content.
Page 6 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
49
13-SEP-12
L1211293-49
Tissue
50
13-SEP-12
L1211293-50
Tissue
51
13-SEP-12
L1211293-51
Tissue
52
13-SEP-12
L1211293-52
Tissue
53
13-SEP-12
L1211293-53
Tissue
54
13-SEP-12
L1211293-54
Tissue
55
13-SEP-12
L1211293-55
Tissue
56
13-SEP-12
L1211293-56
Tissue
0.10
75.6
73.7
76.6
77.0
73.4
74.6
78.1
74.1
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.056
0.035
<0.10
<0.030
<0.0050
196
<0.10
<0.020
0.381
<0.020
<0.10
124
0.115
0.267
<0.010
<0.10
0.51
0.128
<0.010
<0.050
<0.0020
<0.10
3.70
3.5
<0.010
0.030
0.074
<0.10
<0.030
<0.0050
188
<0.10
<0.020
0.461
<0.020
<0.10
103
0.386
0.312
<0.010
<0.10
0.31
0.109
<0.010
<0.050
<0.0020
<0.10
4.45
<2.0
<0.010
0.021
0.043
<0.10
<0.030
<0.0050
405
<0.10
<0.020
0.878
<0.020
<0.10
153
0.103
0.237
<0.010
<0.10
0.57
0.357
<0.010
<0.050
<0.0020
<0.10
7.93
<2.0
<0.010
<0.010
0.026
<0.10
<0.030
<0.0050
289
<0.10
<0.020
0.950
<0.020
<0.10
164
0.063
0.259
<0.010
<0.10
0.27
0.221
<0.010
<0.050
<0.0020
<0.10
7.76
<2.0
<0.010
0.023
0.019
<0.10
<0.030
<0.0050
223
<0.10
<0.020
0.627
<0.020
<0.10
163
0.069
0.308
<0.010
0.16
0.33
0.167
<0.010
<0.050
<0.0020
<0.10
5.67
<2.0
<0.010
0.075
0.120
<0.10
<0.030
0.0348
502
<0.10
<0.020
0.561
<0.020
<0.10
195
0.246
0.304
<0.010
<0.10
0.86
0.360
<0.010
<0.050
<0.0020
<0.10
6.92
<2.0
<0.010
0.023
0.025
<0.10
<0.030
<0.0050
134
<0.10
<0.020
0.543
<0.020
<0.10
141
0.103
0.300
<0.010
<0.10
0.34
0.068
<0.010
<0.050
<0.0020
<0.10
4.13
3.1
<0.010
0.031
0.214
<0.10
<0.030
0.0074
356
<0.10
<0.020
1.00
<0.020
<0.10
136
0.178
0.210
<0.010
<0.10
0.48
0.206
<0.010
<0.050
<0.0020
<0.10
6.25
Notes:
mercury content.
Page 7 of 8
Fish Number
Date Sampled
ALS Sample ID
Matrix
Physical Tests
% Moisture
Metals
Aluminum (Al)-Total
Antimony (Sb)-Total
Arsenic (As)-Total
Barium (Ba)-Total
Bismuth (Bi)-Total
Cadmium (Cd)-Total
Calcium (Ca)-Total
Chromium (Cr)-Total
Cobalt (Co)-Total
Copper (Cu)-Total
Lead (Pb)-Total
Lithium (Li)-Total
Mercury (Hg)-Total
Nickel (Ni)-Total
Selenium (Se)-Total
Thallium (Tl)-Total
Tin (Sn)-Total
Uranium (U)-Total
Vanadium (V)-Total
Zinc (Zn)-Total
Units
Method
Detection
Limit
57
13-SEP-12
L1211293-57
Tissue
58
13-SEP-12
L1211293-58
Tissue
59
13-SEP-12
L1211293-59
Tissue
60
13-SEP-12
L1211293-60
Tissue
0.10
77.3
78.4
75.3
72.9
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
mg/kg wwt
2.0
0.010
0.010
0.010
0.10
0.030
0.0050
2.0
0.10
0.020
0.010
0.020
0.10
1.0
0.010
0.0010
0.010
0.10
0.20
0.010
0.010
0.050
0.0020
0.10
0.10
<2.0
<0.010
0.014
0.038
<0.10
<0.030
<0.0050
219
<0.10
<0.020
0.938
<0.020
<0.10
185
0.135
0.229
<0.010
<0.10
0.34
0.125
<0.010
<0.050
<0.0020
<0.10
5.82
2.2
<0.010
0.013
0.057
<0.10
<0.030
<0.0050
270
<0.10
<0.020
0.450
0.190
<0.10
177
0.145
0.159
<0.010
<0.10
0.32
0.172
<0.010
<0.050
<0.0020
<0.10
5.43
3.7
<0.010
0.064
0.096
<0.10
<0.030
<0.0050
521
<0.10
<0.020
0.759
<0.020
<0.10
164
0.218
0.769
<0.010
<0.10
0.77
0.264
<0.010
0.056
<0.0020
<0.10
14.4
<2.0
<0.010
0.051
0.068
<0.10
<0.030
<0.0050
245
<0.10
<0.020
1.17
<0.020
<0.10
154
0.148
0.610
<0.010
<0.10
0.75
0.149
<0.010
<0.050
<0.0020
<0.10
7.18
Notes:
mercury content.
Page 8 of 8

Aboriginal Health Risk Assessment

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Aboriginal Health Risk Assessment

The worlds leading sustainability consultancy

West Moberly First Nations

Aboriginal Health Risk Assessment of

WEST MOBERLY FIRST NATIONS

Safe Quantity for Weekly

Percentage of Bull Trout Sampled

Note: mg = milligram, kg = kilogram, ww = wet weight

ERM | PROJ #0276885-0006 | REV C.1 | MARCH 2015

Recommended Maximum Weekly Intake

Recommended Maximum Weekly Intake

Recommended Maximum Weekly Intake

Recommended Maximum Weekly Intake

WEST MOBERLY FIRST NATIONS

Proj # 0276885-0006 | Graphics # MPF-0001-028i

ERM | PROJ #0276885-0006 | REV C.1 | MARCH 2015

Plate 1. Participants in the Fish Study

WEST MOBERLY FIRST NATIONS

WEST MOBERLY FIRST NATIONS

Introduction and Approach to Assessment ................................................................................... 1-1

Overview .............................................................................................................................. 1-1

Study Area ............................................................................................................................ 1-1

Human Health Risk Assessment Framework.................................................................. 1-1

Problem Formulation ........................................................................................................................ 2-1

Data Used to Support the Risk Assessment ..................................................................... 2-1

Traditional Ecological Knowledge ...................................................................... 2-1

Scope of the Risk Assessment Conceptual Model........................................................ 2-6

Analytical Testing ................................................................................. 2-5

Exposure Assessment ....................................................................................................................... 3-1

Human Receptor Groups.................................................................................................... 3-1

Concentration of Mercury in Fish ..................................................................................... 3-2

Concentrations based on the Summary Statistics.............................................. 3-2

Concentrations based on the Use of Regression Relationships ....................... 3-5

Estimated Daily Intake........................................................................................................ 3-9

WEST MOBERLY FIRST NATIONS

Serving or Portion Sizes ...................................................................................... 3-10

Patterns in Fish Consumption (Frequency of Consumption) ........................ 3-12

Toxicity Assessment.......................................................................................................................... 4-1

Potential Effects on Human Health due to Mercury ...................................................... 4-1

Provisional Tolerable Daily Intake .................................................................................... 4-2

Adjustment of the Provisional Tolerable Daily Intake to Account for Fish

Risk Characterization........................................................................................................................ 5-1

Comparison of Fish Tissue Mercury Concentrations to Tissue Residue

Health Canada Maximum Contaminant Standard for Mercury in Fish

BC Ministry of Environment Aquatic Life Guidelines for Mercury in

Conclusions based on Comparison of Mercury Measured in Fish Tissue

Recommended Maximum Weekly Intake ........................................................................ 5-4

Calculation of Recommended Maximum Weekly Intake based on the

Calculation of Recommended Maximum Weekly Intake based on Fish

Calculation of Recommended Maximum Weekly Intake based on Fish

Summary and Conclusions based on Recommended Maximum Weekly

Consumption of Bull Trout during the Fish Camps ...................... 5-12

Calculation of Hazard Quotients..................................................................................... 5-14

Fish Consumption Advisory for the Williston Reservoir ............................................ 5-15

Summary and Conclusions from Risk Characterization .............................................. 5-18

Importance of Fish Consumption and Traditional Practices to Health ..................................... 6-1

Assumptions, Uncertainties, and Limitations ............................................................................... 7-1

Fish Tissue Sampled for Laboratory Analysis ................................................................. 7-1

Sample Size of Fish .............................................................................................................. 7-1