EWG's letter to EPA

The Honorable Stephen L. Johnson
Administrator Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W..
Washington, DC 20460

Dear Administrator Johnson:

In 2005, EPA and the Food and Drug Administration (FDA) issued the first ever joint mercury health advisory for seafood consumption and signed a Memorandum of Understanding committing the agencies to greater collaboration on health safeguards that would limit mercury exposure for pregnant women and other vulnerable populations. Among other things, the agencies agreed to review scientific research on the issue and to update the mercury health advisory as needed to protect the public health.

Environmental Working Group (EWG) researchers have recently discovered documents indicating that as a part of the update, FDA is attempting to weaken dramatically the agency's recommendations that pregnant women and children limit their seafood consumption. These papers reveal that FDA plans to undermine all of the current safeguards against eating the fish most heavily contaminated with mercury and instead to urge pregnant women and children to eat unlimited amounts of even the most mercury-laden fish.

We call on you to stand up for the health of American children by refusing to adopt FDA's recommendations.

FDA's rationale for abandoning the current advice seems to be that the benefits of seafood consumption outweigh the well-documented risks of mercury exposure, regardless of the quantity of mercury to which anyone, including a developing fetus, is exposed. This position is radical and irresponsible; there is no science to support it.

We recognize that omega-3 fatty acids in fish may partially counteract some of mercury's toxic effects. But we share the consensus in the scientific community, outside of FDA, that people should get beneficial omega-3s by consuming fish and other foods that have low or effectively no mercury contamination (Budtz-Jorgensen 2007; Choi 2008; Domingo 2007; Ginsberg 2000; Mahaffey 2004; Mahaffey 2008; Mozaffarian 2006; Oken and BeLLinger 2008; Oken, Radesky, et al 2008; Sakamoto 2004; Stern 2005; Tsuchiya 2008).

EWG analyses have repeatedly shown that unrestricted consumption of popular fish that are heavily contaminated with mercury, like canned tuna, will expose a fetus to levels of mercury many times above what EPA considers safe. Research by Kathryn Mahaffey, formerly EPA's top scientist on mercury toxicity, now a professorial lecturer at George Washington University School of Public Health, shows that blood mercury concentrations were seven times higher in women who ate fish more than two times a week (nine times per month), compared to women who ate no fish in the previous month. The medical literature is rife with cases of people who have suffered chronic and debilitating mercury poisoning from eating three to four meals per week of large ocean-dwelling fish -- exactly what FDA is recommending.

The benefits of omega-3s in no way justify a radical revision of the government's current mercury health advisory, which represents the views of the vast majority of scientists.

We strongly urge EPA to reaffirm its current policy advising pregnant women to limit their consumption of fish known to contain high levels of this potent neurotoxin. We urge you to block this eleventh-hour push by FDA to pad the wallets of the seafood industry at the expense of our nation's children.


Richard Wiles Executive Director Environmental Working Group

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Choi AL, Cordier S, Weihe P, Grandjean P. 2008. Negative confounding in the evaluation of toxicity: the case of methylmercury in fish and seafood. Crit Rev Toxicol 38(10): 877-93.

Domingo JL, Bocio A, Falco G, Llobet JM. 2007. Benefits and risks of fish consumption Part I. A quantitative analysis of the intake of omega-3 fatty acids and chemical contaminants. Toxicology 230(2-3): 219-26.

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Mahaffey KR. 2004. Fish and shellfish as dietary sources of methylmercury benefits. Environ Res 95(3): 414-28

Mahaffey KR, Clickner RP, Jeffries RA. 2008. Methylmercury and omega-3 fatty acids: co-occurrence of dietary sources with emphasis on fish and shellfish. Environ Res 107(1): 20-9.

Mozaffarian 0, Rimm EB. 2006. Fish intake, contaminants, and human health: evaluating the risks and the benefits. JAMA 296(15): 1885-99.

Oken E, Bellinger DC. 2008. Fish consumption, methylmercury and child neurodevelopment. Curr Opin Pediatr 20(2): 178-83.

Oken E, Radesky JS, Wright RO, Bellinger DC, Amarasiriwardena CJ, Kleinman KP, et al. 2008. Maternal Fish Intake during Pregnancy, Blood Mercury Levels, and Child Cognition at Age 3 Years in a US Cohort. Am J Epidemiol167(10): 1171-81.

Sakamoto M, Kubota M, Liu XJ, Murata K, Nakai K, Satoh H. 2004. Maternal and fetal mercury and n-3 polyunsaturated fatty acids as a risk and benefit of fish consumption to fetus. Environ Sci Technol 38(14): 3860-3.

Stern AH. 2005. Balancing the risks and benefits of fish consumption. Ann Intern Med 142(11): 949.

Tsuchiya A; Hardy J, Burbacher TM, Faustman EM, Marien K. 2008. Fish intake guidelines: incorporating n-3 fatty acid intake and contaminant exposure in the Korean and Japanese communities. Am J Clin Nutr 87(6): 1867-75.

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