Read the full article by Pat Elder (Military Poisons)

“In 2003, Taniyasu, (2003) surveyed PFAS in water and fish. PFOS was found in surface waters at levels sufficient to begin the process of bioaccumulation in aquatic life. Highest levels:

Tokyo Bay   59 ppt
Osaka Bay   21 
Lake Biwa   7.4
Ariake Bay 11

PFAS pollution is widely present  in coastal areas including the Sea of Kushiro, Mutsu Bay, Hachinohe Bay, Jyodoga Coast, Miyako Bay, Kamaishi Bay, Honjyo Marina, Souma Bay, Nagasaki Bay, Chiba-Funahashi Bay, Yamashita Bay, Pacific Ocean, Nagoya Bay, Koshien Bay, Motoujina Shima coast, and Hakata Bay.

A study of 18 rivers in Hokkaido, Tohoku, Kanto, Hokuriku, Chubu, Kinki, Chugoku, Shikoku, and Kyushu found PFAS in all of them and more than half of them had levels higher than 40 ppt.

River water and sewage treatment plant effluent were sampled along the Tsurumi River that flows through Yokohama and into Tokyo Bay.  A plant discharging into the Tsurumi River released:

PFOS 689.9 ppt.
PFHxA 9.4 
PFHpA 7.2  
PFOA 24.9
PFNA 41.8
PFDA 4.5

Total PFAS for the six:  777.7 ppt


Surface water throughout Japan is contaminated with PFAS.  The state of Minnesota tries to keep some lakes under .05 part per trillion of PFOS because of the propensity for certain species of fish to show concentrations of PFOS in filet that may be thousands of times over the ambient water levels. In other words, 1 ppt of PFOS in water could mean more than a thousand times that in fish.

The six compounds shown above from the Tsurumi River in Yokohama: PFOS, PFHxA, PFHpA, PFOA, PFNA, and PFDA all bioaccumulate in fish at different rates. The accumulation of the toxins in the filet of fish varies from species to species. With thousands of PFAS compounds and thousands of species of edible aquatic life, it’s impossible to keep track of it all! The lesson is that we must regulate these chemicals as a class rather than piecemeal as corporations and their national sponsors prefer.

PFOS is the champion of bioaccumulation in fish while PFOA in water gravitates to shellfish, like clams.  

North Carolina Department of Environmental Quality 

This graphic shows a bioaccumulation factor of 1,539 in a Largemouth Bass. We can multiply this factor by the concentration of PFOS in the water to approximate the levels in the filet of the fish. Fish may contain concentrations of PFOS that exceed several million parts per trillion. 

A pumpkinseed fish in Michigan caught from waters adjacent to Wurtsmith Air Force Base contained 9,580 ng/g of PFOS in its filet. The base closed 30 years ago, but these are ‘forever chemicals’ so they stick around.

  • The tiny piece of fish on the scale weighs .08 gram
  • 9,580 ng/g x .08 gram = 766.4 nanograms
  • The European Food Safety Authority has established a tolerable weekly intake of 13 ng/kg body weight per week for PFOS.
  • A 25 kg child may ‘safely’ consume 325 nanograms of the fish weekly. (13 ng/kg x 25 kg)
  • The child could enjoy about half of the fish shown on the scale weekly. 


We can gain a rough idea how bad things are in Tokyo Bay by applying what they’ve learned in North Carolina about bioaccumulation factors in fish.

If the water in the Tsurumi River contains 689.9 ppt of PFOS we might expect fish with more than a million parts per trillion of PFOS in its filet.  (1,539 x 689.9 = 1,062,533)

Maybe it’s only a small percentage of this for certain species of fish in Tokyo Bay. The point is that it swamps the single, double, and triple digits typically being reported in the drinking water.

Bioaccumulation of PFOS and other PFAS compounds is not limited to the fish in Japan.

Chicken livers were found to contain 67,000 ppt. Pig livers had 54,000 ppt and cattle had 34,000 ppt. Dogs were found to have 25,000 ppt of PFOS and 10 ppt of PFHxS in their blood, making them as diseased as humans.

Some civilians living close to military installations in America prohibit their dogs from drinking from puddles in the neighborhood. Most U.S. pet food is contaminated with PFAS.


Twenty years ago, Sachi Taniyasu and others with the National Institute of Advanced Industrial Science and Technology reported  high levels of PFOS in fish in Lake Biwa and Kin Bay, Okinawa. 

They tested a bluegill (Lepomis Macrochirus) in Lake Biwa  and reported 834,000 ppt in the blood of the fish. They tested Ornate Jobfish from Kin Bay and found 7,900,000 parts per trillion in liver. The carcinogens are almost a million times more concentrated in the fish than the drinking water in Tama Hills at 8.2 parts per trillion.  Sure, few care much for eating the Ornate Jobfish or the invasive Bluegill in Japan, but these levels are frightening; they may occur in other species; and they ought to cause Japanese authorities to reexamine their response to PFAS contamination. 

Asked if there is a difference between eating or drinking PFAS contamination, Linda Birnbaum, former director of the U.S. National Institute for Environmental Health Sciences, said, ‘No. Both are routes of ingestion. Whether you eat it or drink it, PFAS go to the same places in the body and do the same thing.  We need appropriate fish advisories and regulation of what’s in our food.’

The results from the 2003 study by Taniyasu, report on the concentrations of PFOS in fish liver and blood in various locations around the country. Results are in parts per trillion to provide a contrast to national efforts to keep the drinking water under 50 ppt.  Often, other PFAS compounds may exceed the concentrations of PFOS so this is only part of the picture.  

Japan sets 50 ppt for the combined total of PFOS and PFOA in drinking water, but has no safety standards for PFAS discharged into sewers. Japan does not regulate PFAS in fish. Look at the concentrations of PFOS in these areas.

Legacy PFAS compounds like PFOS and PFOA decline in fish while toxic replacements proliferate.

In 2015 scientists who studied concentrations of PFAS in edible cod in Hokkaido found decreases of PFOS levels in fish. The eight-carbon chain PFOS has been largely phased out of production, so we have witnessed gradual decreases in the human serum levels for the compound.  In contrast, levels of PFAS with carbon chains longer than eight have continued to increase in the fish and in human blood serum in East Asia.

Their results strongly suggest that fish consumption is a significant and dangerous source of human dietary exposure to PFAS.

The Navy has been holding ‘posterboard’ town hall meetings across the U.S. that stress PFOS and PFOA are diminishing in human blood serum. They leave out the rest of the story.”