Statement of Diana Zuckerman, Ph.D., to the FDA Food Advisory Committee on Methylmercury

Statement of Diana Zuckerman, Ph.D., President
National Center for Policy Research for Women & Families

Before the FDA Food Advisory Committee Meeting on Methylmercury

Proposed FDA/EPA Dietary Advisory on Methylmercury in Fish

December 11, 2003

The National Center for Policy Research for Women & Families is a think tank that works to improve the health of women, children, and families. I’m donating my time to be here today and we do not take contributions from companies whose products we might someday praise or criticize. Our goal is to ensure that scientific information is made understandable and available in ways that safeguard everyone’s health and make sure that consumers can make educated choices.

By any standard, The Food and Drug Administration’s (FDA) current efforts at protecting the American public from the health risks of methylmercury in fish are not adequate to protect the public or to educate them so that they can protect themselves.

I’ve been attending FDA meetings on this topic for several years, and I am glad to see progress — thanks in large part to this Advisory panel’s recommendations. However, the proposed FDA/EPA advisory is confusing and the FDA’s own scientists have found that the 12 oz. limit is too high to reduce mercury levels in women.

As an epidemiologist, I strongly believe that data are essential for making important health decisions. According to information provided to this Advisory Committee yesterday by Dr. Carrington and Dr. Bolger,¬†the proposed limit of 12 oz. of fish per week would not significantly decrease consumers’ current exposure to methylmercury. According to the FDA’s analysis, 12 ounces of tuna or other fish in the moderate mercury category would not reduce the levels of methylmercury in women’s blood to safer levels.

Your task is incredibly important. You need to make sure that adults are warned – in ways they understand and remember — so that children and pregnant and nursing women are not harmed by consuming too much methylmercury. So far the FDA has not succeeded in getting this information out to the people who most need to hear it.

Using government data, the U.S. Tuna Foundation estimates that on average, the 1% of women who eat the most tuna eat 7 oz/week or more. If that tuna is fresh tuna or canned white tuna, that level could be dangerous for a pregnant or nursing woman. And what about the top half of one percent consumers of tuna? That is still a large number of women. Canned tuna is inexpensive, making it especially appealing to low-income women, including pregnant women and mothers of young children. They deserve to know what the risks are. They don’t currently have that information.

Our center specializes in explaining research-based information to the general public. In working with the National Cancer Institute, NCI hired a specialist to translate all the information to simple words in simple sentences suitable for women reading at the middle school level. That may seem extreme, but we’re told the NIH insists on it for their patient materials. The technique is called “plain language.” The words have to be short — mercury instead of methylmercury, for example — but its not just the vocabulary that is important. The ideas also have to be clear and simple.

The methylmercury advisory needs to say at least two things:

1. Some fish are very good for you.
2. Some fish are dangerous if you are pregnant, might become pregnant, are nursing, or are a child.

People can understand those two messages if you explain which fish are safe and which are not. But, the message becomes much more confusing if you try to convey that fish are good for you and then start naming those that aren’t. It’s not logical to talk that way — its spin control.

For $500, the FDA could have hired a specialist to simplify the advisory on methylmercury in fish. It would have taken a few hours to do.

And, I agree with CSPI that we need three separate advisories: one for children, one for pregnant and nursing women, and one for other adults.

Of course, the underlying problem is the FDA’s reluctance to say that some popular fish are relatively high in mercury. If the FDA insists on including tuna in the moderate and low categories, then their own research shows they will have to reduce the amount of fish permitted for pregnant women to well below 12 ounces per week. If the FDA is willing to move fresh tuna and canned white tuna to the high category, they may be able to keep the limit at 12 ounces.

Some experts point out that we don’t know exactly how dangerous methylmercury is for pregnant women and young children. It might not be as dangerous as the National Academy of Sciences (NAS) estimated. However, none of us would want to include our children or grandchildren in an experiment to find that out. The NAS is very concerned, and in our experience they are extremely cautious, so we take their concerns very seriously.

In addition to an advisory, we need a warning label of packages of fish. This recommendation is consistent with the precedent set on alcoholic beverages. Warning labels are used to caution pregnant women not to consume any alcoholic beverages, even though research has not established that occasional consumption is dangerous.