Response to Mugdan et al.'s comment on Urban et al. “Assessment of human health risks posed by consumption of fish from the Lower Passaic River (LPR), New Jersey” (2009, doi:10.1016/jscitotenv.2009.03.004)

Abstract

Mugdan et al. have criticized certain aspects of the approach and general conclusions of our recently published fish ingestion risk assessment for the lower Passaic River (Urban et al., 2009), asserting that they are inconsistent with the United States Environmental Protection Agency's risk assessment guidelines we reference in our paper. Specifically, they assert that the excess cancer risk and health hazard results calculated as a part of our analyses underestimate the potential health risk posed to lower Passaic River anglers who actually consume their catch due to the fish ingestion rates we utilized in our analysis and our lack of inclusion of a crab ingestion pathway. While there clearly are differences between our risk assessment and the one conducted by the USEPA, this is not at all surprising given that their assessment reflects a typical screening-level risk assessment while that described in our paper reflects a more detailed site-specific risk assessment. In developing our exposure scenarios and assumptions, we considered and incorporated the available site-specific information in both deterministic and probabilistic quantitative risk frameworks in an effort to provide a sound and realistic human health risk assessment that quantitatively accounts for much of the variability and uncertainty typically inherent in such estimates. Although it is understandable that Mugdan et al. are compelled to defend the effort and conclusions put forth by USEPA Region 2 in its 2007 draft human health risk assessment of the lower Passaic River, the site-specific lower Passaic River human health risk assessment presented in Urban et al. (2009) was conducted according to USEPA guidelines, underwent peer review, and is, in fact, consistent with Superfund guidance and accepted principles of risk assessment.