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“[Their] findings should have been reported as good news for consumers because the mercury levels are very low and fall within the limits set by FDA. Chicago Tribune: The Food and Drug Administration will investigate whether tens of millions of cans of tuna sold each year contain potentially hazardous levels of mercury. Responding to a Tribune series this month on mercury in fish, the FDA said it will review the possibility that there are elevated mercury levels in some cans of "light tuna," one of America's best-selling seafoods and a product the agency has recommended repeatedly as a low-mercury choice. (December 31, 2005) Response: As previously noted, the menacing phrases, “potentially hazardous levels of mercury” and “elevated levels of mercury” are meaningless without context.  Elevated compared to what? Where are the Victims of Fish Poisoning? A relevant question is: if “tens of millions of cans” of tuna sold in the U.S. are truly hazardous, then likely so are all cans of tuna currently or ever in the past consumed world-wide because MeHg levels in fish have been consistent for centuries (see Sec. 15); and there should have long ago presented a dramatically evident mercury poisoning pandemic. In fact, indigenous populations would long ago have abandoned eating fish. Exhibits That Argue for Lack of Victims Exhibit A - We witness children from the highest fish-consuming cultures dramatically – some might say appallingly -- eclipsing U.S. children in international standardized tests for math and science (Fig 20-A.). These statistics have little to do with different curriculum approaches: if a child is “permanently brain damaged” as alarmists claim, no amount of time in a classroom will compensate for a toxicity-induced “disability.” One simply can not have it both ways. Exhibit B – Seychelles Island study. • About twice the MeHg exposure levels of Faroe Islands mothers Exhibit C – Bristol, England study found no harm, but instead benefits of prenatal fish consumption: • Higher child mental development scores Exhibit D – Norwegian study (Helland and colleagues) found that the nutrients in fish oil ingested during pregnancy and lactation “improves the intelligence of children at 4 years of age.” Exhibit E – Amazon rainforest native study (Dorea, et al.) reported that although natives eat lots of fish from Hg-rich areas, there is “no evidence that shows that freshwater…fish cause neuropathies (brain problems).” Hair levels at mean average of 21 ppm, and as high as 303 ppm (EPA RfD = 1.0 – 1.2 ppm) present no sign of toxicity effects. Exhibit F – 87% of Japanese are above EPA “safe” level of exposure, with no cases of poisoning reported since the cessation of large industrial chemicals discharges into surrounding waters. Exhibit G – Hong Kong children have one of the highest levels of seafood consumption in the world. They have a mean mercury hair level of 2.2 ppm, but seriously outperform U.S. children (mean hair level of 0.12 ppm) on international standardized tests for math and science (see Fig. 20-B). Exhibit H – The search by the Faroe researchers for “subtle neurobehavioral deficits” in children from prenatal exposure to MeHg failed detection in Inuit children from Greenland. The average mercury concentration in children’s’ hair was 5 ppm (0.6 – 1.0 ppm in Faroese children at age 7 to 14 years, for comparison) and 15.5 ppm in Inuit mothers (4.2 ppm in Faroese mothers, for comparison).  Exhibit I – Officials from the international Arctic Monitoring and Assessment Program have pointed out their mistrust of the U.S. EPA’s RfD because it only considers the hypothetical potential risks and does not take into account the well-known actual benefits of fish consumption. For example native women of Nunavik have average blood levels of 16.6 ppb (2 ppb-112 ppb) and suggest no restrictions at all because they know that a seafood diet is rich in selenium and vitamin E, which strong antioxidants are known to protect against mercury toxicity.Exhibit J – Alaska uses exposure guidelines from Health Canada and WHO, and will not issue any fish advisories for restricted consumption of fish from its waters. It encourages pregnant women to eat all the seafood they can from Alaskan waters because of multiple health benefits to the woman and her fetus, including enhanced brain development and cognitive abilities. FDA Tuna Monitoring
As explained above (see Sec. 3), the persistence in falsely painting the FDA (and the fisheries industry, including the tuna canners) as irresponsible toward public health is unjustified and misleading. In the case of tuna products (from fresh/frozen steaks to canned varieties), EPA reports a composite of "tuna" to have a mean of 0.21 ppm, published as late as in Mahaffey (2004) . The source of this information can be traced to pp. 3-24 to 3-25 of EPA's Mercury Study Report to the Congress (1997, volume III), listing the composite number as the average of 3 types of tuna: albacore tuna (0.264 ppm), skipjack tuna (0.136 ppm), and yellowfin tuna (0.218 ppm). FDA merely took a similar approach regarding "tuna." It was absolutely clear about the distinction between albacore, skipjack and yellowfin as sources for canned tuna in its 1991 large, survey of mercury content in canned tuna products, which ultimately was published in Yess . Yess reported in detail that: "A total of 220 samples of canned tuna were collected and examined for methyl mercury. Of those, 50 test samples contained <0.10 ppm methyl mercury (expressed as Hg). Statistical values of methyl mercury (expressed as Hg) found in the 220 samples were as follows: average, 0.17 ppm; median, 0.14 ppm; range <0.10 -0.75ppm; and 90th percentile value, 0.42 ppm. ... In the FDA survey, levels of methyl mercury in solid white and chunk white tuna were significantly higher (analysis of variance) than in those products categorized as chunk light or chunk (0.26 and 0.31 ppm vs. 0.01 and 0.10 ppm, respectively). The influence of oil or water on these methyl mercury levels cannot be assessed, because there was relatively few oil packed products (5 solid white, 5 chunk, and no chunk white). There were 26 oil-packed chunk light tuna samples, with an average methyl mercury level of 0.06 ppm, compared with 0.11 ppm for 80 samples of water-packed tuna. There was no significant difference in methyl mercury levels for the different size cans in which the tuna was packed. ... Between 1978 and 1990, FDA determined methyl mercury in a total of 42 samples of canned tuna. The findings ranged from <0.10 to 0.67 ppm methyl mercury expressed as Hg with an average of 0.14 ppm; these results are similar to those of the 1991 survey. In 1973, FDA conducted a survey of canned tuna for total mercury. The average level of total mercury was 0.24 ppm for 253 samples. The ratio of total mercury to methyl mercury may vary among species. Hall (1974) found that 89% (range, 64-119%) of the mercury in canned tuna was methyl mercury. If that relationship is assumed, then the average value for the 1973 survey analyses would be 0.21 ppm methyl mercury, somewhat higher than the results from the 1991 FDA survey." Once again, the facts sharply contradict CT’s attack on the FDA. FDA has expertly and carefully measured and monitored canned tuna for quite some time now. By the time of FDA's 2002/2003 mercury in tuna assignment reported in the January 2004's EPA Fish Forum, FDA had distinctly reported mercury contents from the wide variety of canned and fresh/frozen tuna tests on its webpage. CT further failed to properly inform its readers that FDA's seafood safety program has the following mercury measurement and monitoring programs in place: • The ongoing Total Diet Study to focus on average, rather than extreme, dietary intake of mercury from fish/seafood, including canned tuna. (This study yields averaged mercury values of 0.163 ppm and 0.130 ppm for canned tuna in oil and in water [drained], respectively, as well as detection of very low mercury levels in homemade tuna casserole and 277 other popular foods consumed in the U.S. market baskets.)  As pointed out in Sec. 3, CT may be misinformed due to reliance on the research paper by their Rutgers University's source/contact of Burger and Gochfeld (2004). That paper oddly focused only on FDA's canned tuna measurements from the 1991 survey as published in Yess (referred to above) while ignoring subsequent FDA monitoring of mercury in canned tuna, especially the well-publicized new data from the 2002-2003.It is clear that mercury concentrations in all commercial seafood varies with size, weight, age and area fished. Fig. 20-C confirms that the average mercury concentration in "light" canned tuna remains low regardless of the information source, including CT’s tiny, 18-sample results.  Likewise, Fig. 20-D presents a summary of available measurements for canned albacore tuna. Occasional monitoring of the mercury levels in canned tuna will likely still be performed; however, level comparisons shown in Figures 20-C and 20-D suggest that available resources might be better spent elsewhere, such as better, fact-based public health education.In this regard, evaluation of the CT series by David Burney, executive director of the U.S. Tuna Foundation, appears reasonable: “[Their] findings should have been reported as good news for consumers because the mercury levels are very low and fall within the limits set by FDA. But unfortunately, the findings were used to raise concerns about eating tuna when the real risk to the public is not getting enough canned tuna and other fish in the American diet.” Burney’s last point is fully consistent with the scientific analyses highlighted in Secs. 1, 8 and 14. Fish remains the primary protein source for much of the world’s peoples, and offers a nutritious wonder-food for all Americans. |
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