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Section 3: Misrepresenting the Data

Chicago Tribune:

The newspaper randomly selected supermarket chain stores and fish markets in the Chicago area and bought 18 samples each of eight kinds of fish, including two types of canned tuna. The samples were sent for analysis to a laboratory at Rutgers University, which has performed some of the nation's only studies of mercury in store-bought seafood. ... The FDA has issued warnings for canned albacore tuna, which has averaged 0.35 parts per million in the agency's testing. Yet the agency has not issued warnings for orange roughy, which averaged 0.57 parts per million in the Tribune testing, or walleye, which was at 0.51. (December 11, 2005)

Response:

The facts suggest that CT has clearly misrepresented the efforts by the FDA and confused the information listed on the FDA fish mercury website.

Ignored was the available FDA mercury data for orange roughy and grouper (with mean levels of 0.54 and 0.55 ppm respectively, measured mainly in the 2002/2003 period. CT seems compelled to deprecate the FDA's monitoring and measurement efforts on mercury for fresh and canned tuna (see Sec. 20), following the lead of Rutgers University researchers. Burger and Gochfeld (2004) had also chosen to highlight only dated FDA tuna measurements from the 1991 era while ignoring 2003 data and other complimentary tuna-mercury monitoring programs under FDA jurisdiction.

The manuscript submission, acceptance and appearance dates (November 2004), of Burger and Gochfeld (2004) suggests no acceptable excuse for Rutgers researchers or CT reporters ignoring the well-publicized results from the FDA's 2003 mercury measurements for 2 canned tuna (albacore and " light") or 12 different species of fish, including orange roughy and grouper.

CT should explain why, as late as December 2005, Roe and Hawthorne base their criticisms of the FDA's mercury measurement and monitoring efforts on older data from a 1991 survey, while apparently ignoring the updated 2002/2003 data.

A discussion of FDA's tuna mercury data is given in Sec. 20. However, it is noted that mercury levels in albacore and yellow-fin steaks as compared to the skipjack tuna species was well accounted for in the FDA/EPA well-publicized fish consumption advisory issued of March 2004. The summary of tuna data in Fig. 20-C and Fig. 20-D below clearly demonstrate that CT's own tuna data is unremarkable and falls within the range of FDA numbers.

The CT also failed to properly inform its readers that FDA's seafood safety program has the following mercury measurement and monitoring activities in place:

• The Total Diet Study properly focuses on average, rather than extreme, dietary intake of mercury from fish/seafood, including canned tuna.
• The FY05 Toxic Elements Program to monitor mercury, lead, cadmium and arsenic in a 160 imported samples of striped bass, salmon, flounder, herring, sardine, cod, bluefish, halibut, Alaska pollack, crab, oyster, squid, scallop and lobster.
• FY05 Mercury Assignments to measure total mercury levels in 29 species of fish, 100 fresh/frozen tuna and 50 samples of canned tuna.

CT correctly reported FDA’s 4 mercury measurements of walleye, as listed in its public database entitled "Mercury in Fish: FDA Monitoring Program (1990-2003)" (http://www.cfsan.fda.gov/~frf/seamehg2.html). This reporting evidences CT reporters must have been fully aware of the FDA data from 2002/2003 measurements. However, they did not make sufficiently clear to their readers that freshwater fish advisories fall under EPA jurisdiction, or that EPA mercury data for walleye is extensive. EPA measured levels for walleye range widely, depending on size and location, from 0.005 to 16 ppm -- with a mean of about 0.43 ppm. These data again evidence that CT's 18-sample mean of 0.51 ppm (ranging from 0.11 to 1.74 ppm) is neither unusual nor alarming.

It is further puzzling that CT faults only FDA for a joint EPA-FDA fish advisory. More to the point, the Tribune’s accusations of neglect toward sensitive subgroups in the March 2004 advisory are unconvincing. The advisory actually stated:

“By following these 3 recommendations for selecting and eating fish or shellfish, women and young children will receive the benefits of eating fish and shellfish and be confident that they have reduced their exposure to the harmful effects of mercury.

(1) Do not eat Shark, Swordfish, King Mackerel, or Tilefish because they contain high levels of mercury

(2) Eat up to 12 ounces (2 average meals) a week of a variety of fish and shellfish that are lower in mercury: Five of the most commonly eaten fish that are low in mercury are shrimp, canned light tuna, salmon, pollock, and catfish. Another commonly eaten fish, albacore ("white") tuna has more mercury than canned light tuna. So, when choosing your two meals of fish and shellfish, you may eat up to 6 ounces (one average meal) of albacore tuna per week.

(3) Check local advisories about the safety of fish caught by family and friends in your local lakes, rivers, and coastal areas. If no advice is available, eat up to 6 ounces (one average meal) per week of fish you catch from local waters, but don't consume any other fish during that week.”

Again, there is failed recognition that EPA and FDA are advising a complete avoidance of high-mercury species while encouraging healthy consumption of low-mercury fish and seafood. The advisory also specifically points out the difference between albacore and light canned tuna.


Top - 26 Seafood Consumed in the U.S. Accounts for over 93% of the Commercial Market
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Figure 3-A

CT statements that the FDA/EPA advisory did not specifically target orange roughy, grouper and walleye species, is addressed in Sec. 4 below. The short answer is that average Americans are not consuming much of these fish, and certainly not enough to meet EPA’s RfD criteria of every day consumption for a lifetime before raising concern – not danger, but concern. In other words, no advisory is directed at these fish species for the same logical reason one is not directed at pilot whales, even though they contain very high levels of potentially toxic substances, including methylmercury - nearly no Americans eat them.

Fig. 3-A verifies that orange roughy, grouper and walleye are not even among the top 26 seafood types consumed in the U.S. which account for over 93% of market share. Orange roughy and grouper combined account for no more than 0.5%, according to the 2001 National Marine Fisheries Service landings data summarized in Carrington et al. (2004).

Even under an adjusted ranking utilizing mean mercury exposure from commercial market share in the U.S. (i.e., multiplying the mean mercury content in each fish species by percent market share consumed by Americans), neither orange roughy nor grouper make the top-15 species list, and are ranked lower than mercury exposure from shark intake.

Conclusion

In conclusion, it appears CT has misrepresented FDA’s reasonably well-executed advisory role in maintaining a balance between assuring public nutritional health from fish consumption and mercury warnings for the most-sensitive sub-populations of women and young children.
 
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