SEAFOODNEWS.COM [Inside EPA] By David Reynolds — December 22, 2014 — EPA's children's health advisors are urging the agency to strengthen its draft fish consumption advice for pregnant women and children by adding several species to a "do not eat" list and offering more specific advice on health risks from consuming other species, backing advocates' claims that the draft fails to adequately limit mercury exposures.
In a recent draft letter to the agency, EPA's Children's Health Protection Advisory Committee (CHPAC) recommends that EPA add two species of fish to its list of fish to avoid eating. CHPAC also fears that by failing to advise pregnant women to limit intake of several other fish species, the advice may lead women to consume unsafe levels of mercury.
"CHPAC is concerned that consumers will assume that other fish species high in mercury that are not specifically named in the advisory are safe for pregnant women to eat 2-3 times per week," according to the draft letter outlining recommendations the panel finalized during a Dec. 2-3 meeting in Washington, DC.
CHPAC recommends EPA clarify the guide by using a tiered and color-coded approach to fish consumption used by many states, which would allow federal officials to provide more specific guidance on a broader range of species. Advice based on the color coding of traffic lights would clarify what species pregnant women and children should avoid, limit or consume in order to gain beneficial nutrients from consuming fish while limiting exposure to methylmercury.
The advisors' recommendation backs aspects of criticism from environmentalists who in a report issued this summer argue that EPA's recent draft fish consumption advice — jointly crafted with the Food and Drug Administration (FDA) — underestimates risks from mercury exposure and offers inadequate guidance on species that are safe for women of child-bearing age and children to eat.
EPA and FDA are taking comment on the June 9 draft advice that seeks to balance the benefits for neurological development of eating nutrients contained in some fish species with avoiding risks to neurological development from consuming high-mercury fish. In a June 11 Federal Register notice, the agencies say the comment deadline will remain open until 30 days after additional documents supporting the advice are made available.
Announcing the draft, EPA and FDA said the agencies past fish consumption advice has led pregnant women and young children in the United States to avoid eating fish, causing them to miss essential nutrients for growth and development.
The agencies' draft advice includes the novel step of recommending that women of child-bearing age and children eat a minimum amount of eight ounces of fish weekly, while continuing a traditional maximum intake of 12 ounces of fish per week. The agencies' current fish advisory, released in 2004, includes only a maximum weekly limit of 12 ounces. The June draft also lists four high-mercury fish to avoid and suggests nine lower-mercury choices.
Draft Advice
EPA sought CHPAC's input on the draft advice, and in its charge questions asked the panel whether federal officials should include in the draft two additional fish species, orange roughy and marlin, on a do not eat list and whether targeting young children with the draft advice is appropriate given current science. EPA also asked CHPAC how the federal advice should integrate local fish advisories.
In the draft letter replying to the agency, CHPAC recommends advising pregnant women and children to avoid eating orange roughy and marlin because of the fish species' high-mercury content and low omega-3 fatty acids.
But CHPAC also says the agency failed to include grouper and fresh and frozen tuna in a list of species to eat only once a week even though those fish have higher mercury levels than others for which the advice limits consumption to just once a week. Given the inconsistency, CHPAC says the advisory may mislead pregnant women into believing those other species are safe to eat 2-3 times per week.
To clarify the draft advice, CHPAC recommends that EPA adopt the color-coded tiered approach used by many states, and says that EPA and FDA should harmonize their approaches to developing fish consumption advice so that state fish consumption advisories, which often follow EPA's approach, are more consistent.
In the draft letter, CHPAC also recommends that federal officials improve internet navigation from the federal fish consumption advisory web page to state and local fish advisories to improve consumers' access to advice on consuming locally caught fish.
CHPAC's call for EPA to strengthen the joint federal draft fish consumption advisory to address risks from a broader array of species echoes aspects of environmentalists' critical June 25 analysis.
The advocates' review said the federal draft advice fails to account for recent science showing that adverse health effects from mercury exposure occur at far lower levels than previously thought, and that the federal lists of fish to avoid or that are safe to consume are incomplete and misleading.
Environmentalists also raised concerns about the treatment of tuna in the draft federal advice, saying the proposal incorrectly calls canned light tuna low-mercury.
In CHPAC's draft letter, the advisors say tuna composes a large proportion of fish in many people's diet, and so EPA should provide specific guidance about consumption of various types of fresh, frozen and packaged tuna, including cans and pouches.
Fish Consumption
Revising the letter during the Dec. 2-3 meeting, CHPAC members wrestled with how the federal fish consumption advisory should address children's fish consumption given limited scientific evidence showing adverse neurodevelopmental effects in children from post-natal exposures to mercury through fish consumption.
After considering whether federal officials should include distinct guidance for children, the advisors backed targeting children with the advisory, but also urged the agency to support additional research into potential risks from post-natal exposures to mercury through fish consumption.
The advisors' review of the evidence found that best-available studies showed no consistent adverse neurodevelopmental effects in children from fish consumption and a net benefit associated with fish consumption.
"The body of evidence is limited, however, and does not adequately investigate the balance between the risks and benefits of post-natal fish consumption," CHPAC says in the draft letter. "More specifically, the literature does not evaluate whether mercury in commonly consumed fish reduces the health benefits associated with fish consumption in young children as has been demonstrated in prenatal exposure."
The letter also notes recent EPA estimates that just over 2 percent of women of child-bearing age in the United States have blood levels of methylmercury above EPA's safe level of 5.8 micrograms per liter, indicating that more than 1 million women of child-bearing age have blood levels of mercury sufficient to place a fetus at risk of adverse neurodevelopmental effects.
This story originally appeared on Seafood.com, a subscription site. It is reprinted with permission.