Petition to the Office of Environmental Health Hazard Assessment: 
 
We urge the Office of Environmental Health Hazard Assessment (OEHHA) to act now to protect the health of communities in Los Angeles that rely on shore-based fishing for food and recreation. We ask OEHHA to update fish consumption health advisories to reflect new information about the impacts of consuming fish exposed to pollutants, including dichloro-diphenyl-trichloroethane (DDT) and forever chemicals, including per- and polyfluoroalkyl substances (PFAS), as well as data on how often people are eating these fish and what other species should be studied.  

Decades ago, thousands of barrels worth of the toxic pesticide DDT were dumped off the coast of Southern California, creating an environmental and public health hazard that persists to this day. While DDT was one of the first legacy pollutants to contaminate waters, it was not the last; Santa Monica Bay faces new emerging pollutants of concern, including PFAS and PFOS, that pose severe threats to public health. These pollutants are persistent in the environment, are difficult to break down, and bioaccumulate in the marine food webs off the coast. Understanding the impacts of historic DDT pollution will impact the way we address new pollution sources.

While there is a need for increased studies regarding the impacts of DDT and forever chemicals related to recreational beachgoers, the available information from the Environmental Protection Agency’s Regional Screening Levels Superfund Risk Assessment Tool suggests that risk through recreational exposure to DDT is likely low. However, there is a known risk to human health through the consumption of contaminated seafood.​ ​Recent studies have confirmed the continued presence of DDT contamination in marine sediments and marine life of the Santa Monica Bay, raising serious concerns about consumption risks, particularly for local communities that rely on subsistence fishing.

OEHHA is the agency responsible for integrating research completed by agencies such as the Southern California Coastal Water Research Project (SCCWRP) into public health advisories. To date, there are five fish species listed as unsafe to consume, though this list has not been updated or reviewed since 2009, before the extent of offshore DDT dumping in Southern California was realized. This petition focuses on the urgent need to continue research efforts to understand the extent of fish tissue contamination and integrate this research into public health advisories that inform the public of their consumption risk.  

DDT is an environmental justice concern as much as it is a public health concern. Environmental injustice stems from the unequal distribution of environmental burdens and benefits, often on low-income or communities of color. Many subsistence anglers come from vulnerable communities that face food inequity and other systemic challenges. According to a 2020 study using data from Heal the Bay’s Angler Outreach Program, the top five zip codes of anglers on the piers come from communities disproportionately affected by pollution burdens, including Hawthorne, Rosewood, North Long Beach, South Gate, and South El Monte. Pier fishing is a cost-effective solution for many families because it does not require a fishing license, thereby lowering the barrier to entry. While many of the undersigned signatories may not be anglers themselves, we recognize the need for environmental justice to be reflected in policy and research to adequately protect those most vulnerable to contamination in the Los Angeles region. 

We, the undersigned, call on the Office of Environmental Health Hazard Assessment to: 

• Update fish tissue studies and advisories – Call for new sampling of commonly caught species (including bivalves and crustaceans) and update safe eating guidelines based on recent DDT, DDX, PFAS, and PFOS findings.
• Collaborate with agencies to share information and implement advisories – Work with the Environmental Protection Agency (EPA), local public health offices, and relevant stakeholders to ensure that outreach and advisories reach affected communities.
• Engage impacted communities in the process – Include multilingual angler surveys, collaborate with the Fish Contamination Education Collaborate, and​ implement ​focus groups with impacted populations such as Indigenous communities and subsistence anglers to inform decision-making. 

California has a duty to protect its residents from toxic pollution. By committing to this research and incorporating its findings into new standards, OEHHA can help safeguard public health and ensure environmental justice for affected communities.