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/j.scitotenv.2009.03.004)

presented a human health risk assessment for the Lower Passaic River that very narrowly defines fish consumption, ignores crab consumption, and is not consistent with current NJ or EPA risk assessment procedures and guidance. The restrictively defined consumption then leads to inappropriate conclusions on the risk of eating fish from this highly contaminated estuarine river. The paper underestimates angler exposure to contaminated fish, does not evaluate exposure to contaminated crab, and underestimates the cancer risks and non-cancer health hazards associated with these exposure pathways. The New Jersey Department of Environmental Protection along with the NJ Department of Health and Senior Services issues fish and crab consumption advisories for all state waters; these advisories should be followed for the Passaic River and surrounding waters: .