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Anonymous Comment ID #457

Submitted 05/01/2014

California Indian Environmental Alliance Comments on 2015 Dietary Guidelines: Seafood advice to protect families and pregnant women
California Indian Environmental Alliance (CIEA) staff has provided families with advice on how to eat fish safely by avoiding mercury in fish since 2003. We have navigated contradictory information and integrated new studies as they became available. We have developed messaging that resonates with families in our region. The advice issued by state and federal agencies is integral to the trainings that CIEA provides to young women, pregnant women, nursing women, parents of small children, health care providers and WIC clinicians.
Unfortunately, individuals cannot follow the 2008 EPA and FDA advice or the 2010 US Dietary Guidelines which is based on that joint advisory. If they did, families would either not consume enough fish to benefit optimally from omega-3 fatty acids or would be at risk from mercury at levels that would adversely affect the individual or the developing fetus, should the consumer be a pregnant woman. Past US Dietary Guidelines and the joint advisory issued by the federal Food and Drug Administration and Environmental Protection Agency have not gone far enough to provide clear information to California families and we have had to caution families in following this advice.
Therefore, CIEA respectfully submits the following comments and suggestions to better align the latest studies, best practices for providing fish consumption advice and the US Dietary Guidelines:
• We recommend these two studies be the basis of the new guidelines:
Mercury Exposure in Young Adulthood and Incidence of Diabetes Later in Life. He, Ka, Steve Morris, Pengcheng Xun, Jared Reis, Kiang Liu, Eliseo Guallar. Diabetes Care Journal. February 19, 2013.
Maternal Fish Intake during Pregnancy, Blood Mercury Levels, and Child Cognition at Age 3 Years in a US Cohort. Oken, E., J. Radesky, R. Wright, D. Bellinger, C. Amarasiriwardena, K. Kleinman, H. Hu, and M. Gillman. American Journal of Epidemiology. March 2008.
• We recommend the continuation of messaging that clearly suggests pregnant mothers and small children eat fish that are high in omega-3 fatty acids and low in mercury. We further recommend that these guidelines be extended to women of childbearing age because it is known that mercury stays in the body for over a year.

• We also recommend the continued use of pictures that show the serving sizes, ie. the size and thickness of the palm of a persons’ hand.

• Current advisories list those fish that should not be eaten, however there are others that are lower in mercury and can be eaten although in limited quantities. This information is important and should be included in future guidelines.

• The current guidelines provide a list of fish that should be avoided however, this list is outdated and the levels in tuna can be as high as the fish listed on this list. Tuna and other non-listed high mercury fish should also be listed on the do not eat list.

• CIEA recognizes that identifying and securing safe fishing locations and species will be needed in order for families to benefit from eating fish at levels that support optimal health. We therefore suggest that this be an interagency effort and that safe fishing locations are secured in each area of the nation and within each region of each state.

Lastly in recognition that the US Dietary Guidelines is based on current EPA and FDA Consumer Advisory on Methylmercury in Fish we recommend the following:
• The joint advisory suggests that consumers limit “fish consumption to 12 ounces (2 average meals) a week of a variety of fish that are lower in mercury.: However, in Oken a mother who consumes 3 meals per week of low mercury fish provides a benefit to her child in utero. The current EPA advisory does not allow for this benefit. Therefore, the joint advisory results in mothers unnecessarily limiting their consumption of fish that are low in mercury and some fish that are high in omega-3 fatty acids.

• The joint advisory suggests that consumers should “Check local advisories…. 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 that week.” Should a person follow that advice and eat from waters in California, where a variety of species contain high and moderate amounts of mercury, following these guidelines would place individuals or developing babies at risk.

If you have questions about any of these recommendations or our programs to provide safe fish consumption to California families please, contact us at any time.
Thank you!

Sherri Norris
Executive Director
California Indian Environmental Alliance
526 Grand Ave.
Oakland, CA 94610
Ph: (510) 848-2043

Affiliation: Individual/Professional Organization: California Indian Environmental Alliance
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Food Safety
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)


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