Letter to the Food and Drug Administration regarding the dangers to health of indiscriminate ban of 4 kinds of fatty fish from pregnant women and newborns due to possible high mercury levels
Dr. Marjorie l. Davidson,
Center for Food Safety and Nutrition
Food and Drug Administration
Dear Dr. Davidson,
Please forgive my unsolicited appeal to you. But a recent FDA advisory recommending limited consumption of specific fish (shark, swordfish, tilefish and king mackerel) by pregnant women, due to potentially high mercury levels has relevance for fish oil supplements marketed for their omega-3 oil content. In regard to fish oil supplements the population at large does not know that MeHg binds to proteins and therefore it is not of concern in highly purified fish oils. They also have relevance for fish consumption decisions of the population at large. These recommendations come at a time when the American Heart Association recommended the consumption of two fish meals per week (preferably fatty fish) to the general population as a means of omega-3 fatty acid intake and reduction of risks from cardiovascular disease. The FDA recommendations could discourage pregnant women from consuming perfectly healthy oily fish and this could jeopardize their intake of omega-3s, specifically DHA essential for the fetus’s brain development and the mental health of the mother.
I am asking a simple question. Given that the Omega-3 Research Institute, Inc., (O3RI) has already established a program to provide high quality oils for clinical trials (see http://www.omega3ri.org/), could O3RI be of assistance to the FDA in clarifying the implications of the above FDA recommendations for the general public? For example: through a specific educational program and/or through establishment of a clearinghouse for information on environmental toxins in fatty fish and perhaps fish oil supplements, etc. The public is reacting in a panic mode, especially because medical professionals, OBGYNs, pediatricians and cardiologists are discouraging the public from eating fish. I heard recently a medical call-in radio program in which a cardiologist, involved with nutrition and physical exercise was discouraging the listeners from eating fish with the rhetorical question: “Why would you want to store mercury in your body?” The interviewer’s response to that was: “We should remember that, it is good advice”. It would be very unfortunate if regulations meant to preserve the health of pregnant mothers and their developing embryos and fetuses would result in an aggravated omega-3 essential fatty acid deficiency harming the developing fetus brain and eye development, the newborn, the developing child and the mother. In essence it could harm the entire population by endangering the cardiovascular health of those who are above 40 years of age and prone to coronary heart disease.
Please let me know if I can be of any assistance to you in avoiding potential undesirable side effects to the recent well meaning ruling.
Robert Katz, Ph.D.
Director of Research, Cherab Foundation
President, Omega-3 Research Institute, Inc.
3 Bethesda Metro Center, #700
Bethesda, MD 20814
Web URL: http://www.omega3ri.org