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FDA Analysis Supports More Fish for Moms and Kids
Agency’s unofficial draft draws criticism from EPA and eco groups; critics’ arguments appear inaccurate, alarmist, and disingenuous
12/16/2008By Craig Weatherby
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Few subjects elicit more emotion than the safety of food eaten by pregnant or nursing women and its impacts – good or bad – on their children.
 
That’s as it should be, given the vulnerability of fetuses and infants, and the importance of optimal brain development to childhood and lifelong capacities and outcomes.

Key Points
  • A landmark FDA analysis of the risks and rewards of fish supports lifting the 12-oz-per-week limit on lower-mercury fish currently advised to children and pregnant/nursing mothers.
  • Higher-mercury fish defined in the current guidelines should remain off-limits to children and pregnant/nursing mothers.
  • As a precaution, Vital Choice offers only the lowest-mercury seafood.
  • Criticisms of the FDA analysis by some eco-groups are misleading.
But all of the studies published on this subject find that children’s brains benefit when their mothers eat more fish during pregnancy and nursing, and that children are not harmed by the minuscule amounts of mercury in most ocean fish.

This is how Harvard public health researchers put it in a recent medical literature review (Mozaffarian D, Rimm EB et al. 2006):
  • “For major health outcomes among adults, based on the strength of the evidence and the potential magnitudes of effect, the benefits of fish intake exceed the potential risks.”
  • “For women of childbearing age, benefits of modest fish intake, excepting a few selected species, also outweigh risks.”
The few exceptions to which they refershark, swordfish, king mackerel, and tilefishshould be avoided by children and pregnant/nursing mothers.

This has been the joint position of the U.S. Environmental Protection Agency (EPA) and the U.S. Food and Drug Administration (FDA) since 2004, when they issued a joint advisory for mothers and children:
  • Eat up to 12 ounces (2 average meals) a week of a variety of commonly eaten fish and shellfish found consistently low in mercury, including shrimp, canned light tuna, salmon, pollock, and catfish.
  • Limit albacore tuna to 6 oz per week.
  • Do not eat shark, swordfish, king mackerel, or tilefish because they contain high levels of mercury.
We have no quarrel with the warning that children and pregnant/nursing women should avoid these specific high-mercury fish.

But as a new U.S. FDA analysis of the research shows, the evidence supports lifting the 12-oz-per-week limit on consumption of the vast majority of fish that are much lower in mercury
.

In addition to its report – titled Quantitative Risk and Benefit Assessment of Commercial Fish  the FDA issued a companion report, Summary of Research on the Beneficial Effects of Fish Consumption.

In fact, people of any age can safely consume and enjoy the health benefits of almost any kind of seafood
 – with very few exceptions – several times a week.
Vital Choice Albacore:
An exceptionally pure choice

The current FDA-EPA advisory suggests that pregnant/nursing women eat no more than 6 ounces (one average meal) of albacore tuna per week.

The advisory notes that albacore tuna – known as “white” tuna – is generally higher in mercury than “light” tuna (usually skipjack tuna).

However, that is not true of smaller, younger, Vital Choice Pacific Albacore Tuna, which is sustainably troll-caught far out in the Pacific Ocean by local Bellingham, Washington, fisherman Paul Hill.

At our request, Paul hand-selects the smallest fish for us, to ensure the lowest possible mercury levels and the most tender flesh.

Compared with standard canned albacore, our fresh and canned albacore averages four times less mercury. (See our mercury chart here.)

This does not mean that we consider the older, larger albacore used in standard canned tuna to be unsafe.

Instead, it simply means that we prefer to err on the side of caution. And because we are committed to maximum sustainability, we prefer to purchase tuna from the only tuna fishery in the world certified sustainable by the Marine Stewardship Council.

Paul Hill was instrumental in gaining prized MSC sustainability certification for the North Pacific and South Pacific troll-caught albacore fisheries … a story we will cover in a future issue of Vital Choices.

FDA analysis of mercury-seafood-children science leaked by EPA staffers
Late last week, The Washington Post reported on a leaked draft analysis of the evidence on fish, mercury, and children from the FDA.

The draft contains no proposals for relaxing the EPA-FDA seafood intake advice for mothers and younger children, but its conclusions point clearly in that direction.
The FDA paper notes the growing evidence that regular, frequent seafood consumption presents no risk to children.

That is, the best available evidence shows that the rewards of eating lower-mercury seafood (i.e., almost all ocean species) are clear, while the risk of harm remains undocumented and hypothetical… except among children who eat lots of the very high-mercury fishidentified in the current EPA-FDA guidelines.

Unfortunately, some groups downplay the proven developmental rewards of seafood and grossly exaggerate the virtually non-existent risks of consuming most any seafood frequently.

The FDA draft notes that the nutrients in fish
 – especially omega-3 fatty acids, selenium, vitamin D, and others – could boost a child’s intelligence quotient (IQ) by an estimated three points.

And the food regulation agency also points to the preponderance of evidence showing that the greatest benefits to children would result if pregnant women, women of childbearing age, nursing mothers and young children eat more than 12 ounces of fish a week, which would mean lifting the limit currently advised by the FDA and EPA.

No doubt, the notable developmental and health benefits of fish – especially fattier fish like wild salmon, sardines, tuna, sablefish, and mackerel – flow from their abundance of omega-3s, vitamin D, selenium, and other key nutrients.

According to the National Fisheries Institute (a trade group), Americans currently consume only five ounces a week of fish high in omega-3s, which is less than half the amount (12 ounces per week) recommended by the FDA and EPA.

And the NFI estimates that some 14 percent of women of childbearing age eat no fish at all, despite the fact that omega-3s are essential to proper fetal brain and eye development.

To see some of our past coverage of this issue, see, “Women's Health Advocates Decry Unintended Effects of Mercury Directives.

FDA proposal flows from findings of risk-reward studies
There is ample evidence that children benefit from eating fish, as we reported in “Findings Verify Safety and Value of Higher Maternal Fish Intake” and “Mothers and Kids Urged to Eat More Fish.”

The best available evidence concerning the connections between dietary fish, fish-borne mercury, and child development comes from three epidemiological studies conducted from the 1980s through today, among children who ate much more fish than the average American child:
  • The Faroe Islands (1,022 children).
  • The Seychelles Islands (799 children).
  • New Zealand (237 children).
In both the Faroe Islands and Seychelles studies, American researchers administered tests that evaluated essentially the same aspects of brain development: general cognitive, visual-perceptual, speech-language, visual memory, visual attention, neuromotor-neurological, social-emotional, and learning achievement.
  • “Two major studies, in the Seychelles and Faroe Islands, where exposure to methylmercury is roughly an order of magnitude [ten times] higher than it is in the United States on average, produced mixed results, i.e., the Seychelles study did not find a consistent association between methylmercury and neurodevelopment while the Faroe Islands study found subtle adverse associations between methylmercury and neurodevelopment.”
    Omega-3s and kids: Why fish is better than flaxseed

    Only fish—especially fatty fish—provide usable (long-chain) omega-3s to human cells, where they exert singular influences that enable optimal childhood development… and enhance health at every age.

    The superiority of long-chain omega-3s explains why mothers and children should seek out the only significant food sources: fish, algae, and shellfish.

    The long-chain omega-3 fatty acid called DHA is an essential component of brains and eyes, which explains why fish-borne omega-3 fatty acids are ideal for optimizing fetal and infant development.

    There is a short-chain omega-3 fatty acid known as ALA in nuts, seeds (especially flax and hemp), certain vegetable oils, and dark, leafy greens.  But mothers’ bodies can only convert a small percent of ALA to DHA: just enough to ensure adequate—but likely not optimal—development.  This is why nutrition-savvy pediatricians like Dr. William Sears recommend that expectant mothers eat ample amounts of low-mercury fish.

    The reasons for the human body’s affinity for the long-chain omega-3s in fish may lie in our evolutionary past, when, a growing body of evidence suggests, early hominids gravitated to food-rich rivers, lakes, and ocean shores.

    These environments offered the abundance of omega-3-rich fish, shellfish, amphibians, and aquatic plants necessary to development of modern humans’ outsized, heavily omega-3-dependent brains.
  • “…concentrations of methylmercury in the bodies of… women [in the SeychellesIslands] were found to be about 15 times higher than in U.S. women on average. Fish in the U.S. marketplace and fish in the Seychelles have about the same amounts of methylmercury in them.”
  • “Unlike the Seychelles, where the only source of methylmercury was fish, most of the methylmercury in the Faroe Islands diets came from eating pilot whale in addition to fish.”
  • “When the [Harvard-based] researchers later examined the effect on fetal neurodevelopment solely from maternal fish consumption in the Faroe Islandswithout any pilot whale, they discovered that the adverse effects were replaced by beneficial effects.  Pilot whale lacks many of the nutrients found in fish [and is extremely high in PCBs, which appear to exert adverse effects on developing brains].”
  • “This finding about fish in the Faroe Islands is consistent with a current trend in research results from the United States and elsewhere in favor of a beneficial impact on fetal neurodevelopment from the mother’s consumption of fish, even though the fish contain methylmercury.”
  • “Moreover, greater fish consumption has been associated with greater benefits. On the other hand, in several studies the methylmercury appeared to reduce the size of the benefits. This latter finding suggests that it matters whether the fish are low or high in methylmercury.

For our earlier discussion of the Faroes and Seychelles studies, see “Fight over Mercury Risks Muddied by Bad Science.”

Harvard analyses from 2005 support the new FDA paper
Among others, the the Faroes and Seychelles studies provided the foundation for five separate Harvard-led dietary fish risk/reward analyses and two expert commentaries that were published in the November, 2005 edition of the American Journal of Preventive Medicine (See “Women's Health Advocates Decry Unintended Effects of Mercury Directives”).

The research teams wanted to determine whether the benefits of lower mercury exposure among pregnant women outweighed the loss of omega-3 fatty acids from decreased fish consumption. They also examined what would happen if the public reacted inappropriately to government's recommendations regarding mercury and fish.

Indeed, their research showed that fish benefit children and adults, and that confusion and fears created by government mercury warnings directed to expectant/nursing mothers caused these and many other women to cut fish intake, thereby tossing out the health-promoting omega-3 baby with the mercury-fear bathwater (Oken E et al. 2005).

Their findings clearly refuted, in advance, the inaccurate hyperbole found in a letter concerning the FDA’s draft analysis, sent last week to the EPA by the Environmental Working Group (EWG).

In that hyperventilating letter, the EWG wildly exaggerated the (virtually non-existent) evidence of harm to Americans of any age from ingesting the trace amounts of mercury in fish (Wiles R 2008).

Eco-group issues misleading letter to EPA
Some EPA scientists were unhappy with the FDA’s analysis, which supports many researchers' proposals to relax fish intake guidelines for mother and children, and leaked it to the media and environmental groups.

The Environmental Working Group, an advocacy organization, issued a review that says, “Based on the documents we have seen, some gaps and flawed reasoning are obvious. For example, the FDA paper makes no distinction among various species of fish, ignoring many scientific studies showing that species vary widely in their accumulation of mercury.”

This is a complete misrepresentation of the FDA draft, which repeatedly highlights the distinction among various species of fish.

The best available evidence supports a policy of encouraging mothers, children, and everyone to enjoy more seafood… the vast majority of which is perfectly safe to eat in abundance.

We can only hope that misleading responses to the FDA draft analysis from some eco-groups don’t obscure what the researchers themselves say, almost without reservation: more fish is good for kids.

This is why it makes sense to assure women that virtually all seafood is safe and beneficial when eaten several times weekly, and concentrate on highlighting
 – perhaps via printed label/package warnings – the four highest-mercury ocean species.

Where we stand on the FDA findings
The FDA’s findings echo similar ones from the European Commission (EC), the independent, U.S.-based Maternal Nutrition Group, and U.S. NIH brain and behavior expert Joseph Hibbeln, M.D., who led key seafood-development studies analyzed in the FDA paper; see “More-Fish-for-Moms" Report Affirmed in Europe.

We believe these expert observers make a compelling case for lifting the 12-oz-per-week limit from the EPA-FDA guidelines for children and pregnant/nursing mothers.

But we think that two key parts of the advisory should remain in place for now:
  • Children and pregnant/nursing mothers should avoid shark, swordfish, king mackerel, and tilefish.
  • Children and pregnant/nursing mothers should eat no more than 6 ounces of standard albacore tuna* per week.
*Note: Predatory fish like tuna accumulate mercury over time, so our small, young, Pacific albacore rank much lower in mercury than national brands; see the sidebar titled “Vital Choice Albacore: exceptionally pure” (The same is true of our small, young, Alaskan halibut).

Compared with standard canned albacore, our fresh and canned albacore averages levels about four times lower. (See our mercury chart here.)

While the evidence shows that almost all fish are safe and beneficial for children to eat several times a week, the evidence supports advice to avoid the four species highest in mercury, and freshwater fish that are subject to warnings.

And the evidence suggests that children and pregnant/nursing mothers should indeed limit intake of standard, national-brand canned albacore tuna, which consists mostly of much older, larger, higher-mercury fish than our fresh and canned small albacore.


Sources
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