This morning the Las Vegas Journal Review printed a story about a UNLV report that tested mercury in canned tuna. Several days ago the Journal Review reached out to NFI for some perspective on the pending study. This morning's article didn't provide quite as much insight into the perspective we provided so I thought I would share with you the facts we laid out for the reporter. Our letter is below:
January 26, 2010
Military and Environment writer
Las Vegas Review-Journal
Dear Mr. Rogers,
Consumers should not be concerned by this report. Canned tuna continues to be a safe and healthy source of protein packed with hearty-healthy omega-3's. The report is very clear that in all of the brands tested the average methyl mercury level was well below the FDA limit.
The EPA level referenced in the report is not relevant. The EPA levels are applicable to sport-caught fish found in lakes, streams and other internal waterways where the EPA has jurisdiction. The FDA level is designed for commercial seafood like tuna. The EPA's matrix for its level was developed using something called ambient water criteria. That standard measures the amount of dissolved mercury in water as an approximation for the amount of mercury fish might absorb. It would make sense that its level would focus on "environmental" standards as opposed to "food" standards. The EPA level is designed to work in conjunction with the agency's mandate to regulate emissions, not food.
It is critical to point out that the methyl mercury found in seafood, like canned tuna, is predominantly the result-not of emissions-but of naturally occurring processes found in the ocean like underwater volcanic activity. For some reason, the authors of the study seem to have obscured this scientific fact, a common conflation used by environmental activists. In fact, the California Courts have ruled twice against the State Attorney General over a signage issue on the grounds that virtually all the trace amounts of methyl mercury found in canned tuna is "naturally occurring."
In expressing concern that any of the cans supposedly exceeded the FDA's level, a key fact is ignored. The FDA's level of 1.0ppm has a built-in 1,000% safety factor also known as an uncertainty factor. The FDA says such a standard, "was established to limit consumers' methyl mercury exposure to levels 10 times lower than the lowest levels associated with adverse effects." This means a single can would have to exceed the FDA's level by ten times to begin to even approach a level of concern for the average consumer. Even the highest levels reported in this study did not come remotely close to that point.
Another concern we have with our initial review of this study is that throughout the report the authors refer to levels of Hg-Hg is a measurement of total mercury while the focus for fish (via FDA and EPA work) is MeHg methyl mercury. Hg can be made up of elemental mercury and methyl mercury. The human body quickly excretes Hg. To combine the two has the potential to artificially inflate the levels.
What's more the report says "recent studies have established a link between heavy fish consumption and adverse health effects." However, the studies they cite are far from "recent." In fact the latest cited in this section is 1997 and the earliest is 1985. Published, independent, peer-reviewed reports that contradict those findings from 2002, 2004, 2007 -among others-were not mentioned. The study even misreports the percentage of canned tuna consumed by Americans each year, over-reporting by as much as 18%, a fact that should shed considerable doubt on the author's attention to detail and surmise that participants in the Women Infant and Children's (WIC) program might be at greater risk from tuna consumption. Again, the vast body of scientific literature instead has concluded that Americans as a whole simply don't get enough seafood in their diet in order to enjoy the full health benefit.
This single study in no way changes the conclusion of the FDA's Report of Quantitative Risk and Benefit Assessment of Consumption of Commercial Fish released in January 2009 that showed, for instance, children eating fish provided a 99.9 percent modest benefit in brain and verbal development; 0.1 percent modest risk. It also does not change the fact that an independent Harvard University study published in the Journal of The American Medical Association found, "for major health outcomes among adults, based on the strength of the evidence and the potential magnitudes of effect, the benefits of fish intake exceed the potential risks. For women of childbearing age, benefits of modest fish intake, excepting a few selected species, also outweigh risks."
The overwhelming majority of science finds the benefits of eating seafood and high omega-3 fish, like canned tuna, outweigh any concerns associated with the trace amount of methyl mercury found in fish.
A failure to highlight the fact that the average Hg level for all brands was well below the FDA's level and that the study does not report on the fact that there is a 1,000% safety factor built in to that level would be an egregious failure in reporting this story. Likewise, we would expect your reporting to include another important fact left out of this study-there have been no cases of mercury toxicity from the normal consumption of commercial seafood in this country ever reported in peer reviewed scientific literature.
Thank you for reaching out to the National Fisheries Institute. In news stories we choose to participate in we insist that the highest of journalism standards are met and that demonstrable facts we provide that may change the reader's understanding of a subject be included.
We look forward to reading your report.
National Fisheries Institute
cc Greg Haas
Assistant Managing Editor