Updated Fish Advisory PFOS Guideline Frequently Asked Questions
About the 2025 New York State Department of Health Updated PFOS Fish Advisory Guidelines
This FAQ is a companion to the updated PFOS guidelines listed in How We Set Advisories. The new guidelines were developed as part of the Great Lakes Consortium Best Practices Workgroup (the Workgroup). New York State is part of the Great Lakes Consortium for Fish Consumption Advisories (Consortium), a collaboration of fish advisory program managers from government health, water quality, and fisheries agencies bordering the Great Lakes which use, share, and advance scientific information, quality-assured data and utilize best practices for communicating the risks and benefits to fish consumers.
What fish data were used to derive the new PFOS guidelines?
Takeaway: As part of the Workgroup, New York State researchers reviewed a robust dataset of more than 5,550 fish samples from eight states, the province of Ontario, and tribal nations enabling the Workgroup to ensure the guidelines were appropriate and protective.
The Workgroup evaluated Consortium PFOS data (from eight states, one province, and data from tribal nations) to characterize “background” PFOS concentrations for relatively unimpacted waters. This included over 5,500 PFOS monitoring datapoints for about 80 fish species from over 230 locations in the Great Lakes states and the Canadian province of Ontario. NYSDOH also evaluated 1,292 fish samples from waterbodies across NYS.
What toxicity data was used to derive the new guidelines?
Takeaway: The Workgroup used the most up-to-date toxicity information available (from 2024) to derive the new guidelines and were also able to take into account some of the benefits of eating fish.
The Workgroup derived the new PFOS fish consumption guidelines using multiple data sources. They started with what they considered to be the most up to date and comprehensive toxicity information available for PFOS, which came from the 2024 USEPA PFOS toxicity review. This review evaluated human developmental and cardiovascular outcomes to create human health assessment values, including points of departure (PODs), POD-human equivalent doses (POD-HEDs) and a reference dose (RfD). The Workgroup considered the POD and POD-HED appropriate jumping off points for developing the new guidelines. In deriving these new guidelines, the Workgroup also considered literature evaluating the bioavailability of PFOS in fish, as well as literature on the benefits of fish consumption. The review included best practice considerations related to relative source contribution, fillet concentration as an indicator of exposure, and possible exposure reduction from cleaning and cooking.
How are these guidelines consistent/different from what EPA and other states are currently recommending?
Takeaway: Fish consumption guidelines vary across states and at the federal level. New York is one of the first states to adopt the more protective guidelines recommended by the Workgroup. The guidelines recommended by the workgroup and adopted by New York State consider both the risks and the benefits of eating locally caught fish.
Fish consumption guidelines vary across states and at the federal level. While the Workgroup works collaboratively to develop guidelines, each state/province adopts those guidelines on their own timeline. The new guidelines recommended by the Workgroup and adopted by New York State are more protective than those currently recommended by many states in the US.
The Environmental Protection Agency (EPA) does not currently have advice for the consumption of freshwater fish, though they do have recommendations for consumption of saltwater fish, or species typically in grocery stores. The most recent 2024 EPA RfD is just a starting point for the Consortium evaluation of fish consumption limits, an evaluation that also considers the health benefits of eating fish. For example, fish are a unique natural source of omega-3 fatty acids, a nutrient that protects against having babies with low birth weights. The 2024 EPA RfD also doesn’t consider the benefits of fish as a local and inexpensive source of protein and an important cultural practice.
Severely restricting or eliminating consumption of freshwater sportfish would remove a healthy, low-cost source of protein for many people, which could potentially result in adverse effects on public health. The guidelines recommended by the workgroup and adopted by New York State considers both the risks and the benefits of eating locally caught fish.
How are these guidelines protective?
Takeaway: The guideline adopted by the Workgroup that triggers a “eat up to one meal per month” advisory is close to background levels of PFOS commonly seen in fish across the Great Lakes states and falls within an acceptable level of risk. Setting fish advisories is a balance; lower guidelines would be overly restrictive and would limit the health benefits of eating fish for anglers while higher guidelines could allow for more PFOS ingestion than advisable to prevent health concerns.
When characterizing the “background” PFOS levels, the Workgroup found that commonly encountered background levels were not far below the recommended “Eat up to one meal per month” guideline. This, along with the fact that cancer risk levels at the guideline levels were within reasonable bounds, and PFOS is less bioavailable in fish tissue than it is in water, all indicate to us that the recommended guidelines are sufficiently protective of even our most sensitive populations.
How do the benefits of eating fish influence PFOS guidelines?
Takeaway: Fish are a very important part of a healthy diet and one of the only sources of omega-3 fatty acids. Research specifically about PFAS health effects showed that some of the negative effects may be balanced by the health benefits of eating fish. These considerations were factored into the new guidelines.
Fish are a nutritious food source, containing high-quality protein and essential nutrients such as vitamin D, selenium and iodine. Additionally, they are an important source for omega-3 fatty acids, an essential nutrient that can only be obtained through diet. Through our research, we have concluded that some of the health end points of concern related to PFAS exposure may be offset by the nutrients obtained through consuming fish. This was all considered when balancing the risks and benefits of fish consumption in creating the new PFAS guidelines.
Why are they different than guidelines used for drinking water?
Takeaway: People typically consume significantly more drinking water on a daily basis, so they need a more protective standard. Guidelines for fish are typically higher than those for drinking water because when combined with the frequency and quantity ingested, the risk from eating contaminated fish is much lower than drinking contaminated water. Eating fish also provides vital nutrients that protect against some of the negative health effects of PFOS and other contaminants.
The reason why our PFAS fish advisory level (10 ppb) is higher than our PFAS drinking water standard (10 ppt) is because the amount of fish consumed per day is typically much less than the amount of water consumed. People drink quarts of water each day; whereas we recommend that people eat fish no more than once a week. Additionally, PFOS is not as bioavailable in fish as it is in water, and fish consumption also comes with the added benefit of omega-3 fatty acids, which can have counteracting benefits to PFOS exposure, so this really is an apples and oranges comparison.
Compared to existing mercury and polychlorinated biphenyls (PCBs) advisories, how do these new PFOS guidelines influence our recommendations across the state?
Takeaway: Mercury and PCBs still drive most fish advisories in New York State. Existing fish advisories for these chemicals are typically protective of background PFAS levels found in waterbodies without specific sources of PFAS.
Most fish advisories in New York State are still driven by mercury and PCBs. Compared to mercury and PCBs, the amount of PFAS data we have is limited, but the current data indicates, when there are no site-specific sources of PFAS, the existing advisories for mercury and PCBs are usually sufficiently protective for the background levels of PFAS that we are detecting.