“Eat Your Fish,” Say FDA and EPA

The Food and Drug Administration (FDA) and the Environmental Protection Agency (EPA) have released draft updated advice on seafood consumption, Fish: What Pregnant Women and Parents Should Know.  The two agencies also published a Federal Register notice creating a docket and requesting public comments on their new fish consumption advice.

The draft updated advice is intended to replace a 2004 document that was seen as discouraging fish consumption by pregnant women.  Many women have avoided eating fish during pregnancy because of concerns about methyl mercury.  However, new science shows that the benefits of fish consumption outweigh the risks, and avoiding fish during pregnancy and childhood means missing out on nutrients important to growth and development.  The draft update also brings FDA and EPA recommendations in line with the 2010 Dietary Guidelines for Americans, as well as other consensus documents on seafood consumption.

The draft update accentuates the positive, emphasizing the benefits of fish consumption and recommending a minimum (not just a maximum) level of consumption.  Its advice is directed primarily to women who are pregnant (or may become pregnant), women who are breastfeeding, and young children, because the nutritional benefits of fish are particularly important for growth and development before birth, in early infancy (for breastfed infants), and in childhood.  However, the agencies state that fish consumption has health benefits for everyone, and therefore the advice should also be followed by the general public.

The key message is to “Eat 8 to 12 ounces of a variety of fish each week from choices that are lower in mercury.”  The word “fish” is used to refer to both finfish and shellfish.  The draft updated advice recommends the following actions:

  1. Eat 8-12 ounces of a variety of fish per week.

This amount represents 2-3 servings of fish per week.  This is far more than most pregnant women currently eat; one survey found mean fish consumption among pregnant women was only 1.8 ounces per week.

Children should also have 2-3 servings of fish per week, but the amount consumed should be reduced to reflect their lower calorie needs: 3-5 ounces for children ages 2 to 8; 4-6 ounces for children ages 6 to 8; and gradually increasing the amount for children over 8 years of age.

  1. Choose fish lower in mercury.

Fish lower in mercury include many common species, such as salmon, shrimp, Pollock, tuna (light canned), tilapia, catfish, and cod.

  1. Avoid the following 4 types of fish: Tilefish from the Gulf of Mexico (not Atlantic tilefish); Shark; Swordfish; and King Mackerel.  In addition, limit white (albacore) tuna to 6 ounces per week.
  1. When eating fish caught from streams, rivers, and lakes, pay attention to fish advisories on those bodies of water.

If such advice is not available for a particular body of water, adults should limit fish from that body of water to 6 ounces per week, and young children should limit consumption to 1-3 ounces per week; both adults and children should then not eat other fish that week.  EPA’s website provides historical data on local fish advisories, but suggests consulting state websites for the most current advisories.

  1. When adding more fish to your diet, be sure to stay within your calorie needs.

FDA and EPA have also released Q&As explaining the draft advice and including a table with the amounts of mercury and omega-3 fatty acids in common species of fish.

FDA and EPA are requesting comments on the draft updated advice and on alternative risk communication approaches for conveying its message.  In addition, the agencies seek comments on the following specific questions:

  • Whether two additional species, orange roughy and marlin, should be added to the list of species of fish to avoid because of methyl mercury.  Orange roughy and marlin have mercury levels that are lower than the four species to avoid listed above, but higher than nearly all other commercial fish.  In addition, they are low in omega-3 fatty acids;
  • Whether the final advice should track the language of the 2010 Dietary Guidelines more or less closely than the draft;
  • Any new science relevant to the draft updated advice;
  • Information upon which to base advice on young children’s fish consumption;
  • Suggestions for improving the clarity and utility of the advice; and
  • How to integrate local advisories about fish from local streams, rivers, and lakes.

FDA and EPA intend to seek the input of FDA’s Advisory Committee on Risk Communication and may hold public meetings on the draft updated advice.  The comment period will close 30 days after the last transcript from these meetings becomes available.

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