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Association of Food and Drug Officials

2011

RESOLUTION NUMBER 1

Submitted by:  Charlene Bruce, President-AFDOSS, and Rita Johnson, Co-Chair for AFDO Seafood Committee, as submitted by the Seafood Committee member, Dr. Steve Otwell, Food Science & Human Nutrition Department, University of Florida

Date: May 2, 2011

Concerning: Public health messages and advisories regarding potential risk due to mercury content in seafood consumption

Whereas, a considerable body of scientific evidence has accumulated since 2004 indicating that fish consumption during pregnancy can be highly beneficial to the nervous system of the developing fetus in spite of the presence of methylmercury, a known neurotoxin, in fish, and

Whereas, this evidence consistently indicates that eating at least two servings of fish per week or at least 12 ounces of fish per week can be more beneficial to the unborn child than eating less or eating no fish, and

Whereas, much of the fish consumption advice to pregnant women available today was developed before this scientific evidence became available and thus emphasizes limiting fish consumption in order to minimize risk from methylmercury without also taking into account the risk of loss of neurodevelopmental benefits, and

Whereas, as an apparent consequence of this older advice, there is strong evidence that fish consumption by pregnant women has declined to under 2 ounces per week on average and is lower for pregnant women than it is for young women generally, and

Whereas, the scientific evidence indicates that fish consumption this low during pregnancy is likely to be causing harm to unborn children in the United States, and

Whereas, in light of the evidence on the benefits of fish consumption to the developing nervous system, the U.S. Departments of Agriculture and Health and Human Services have issued Dietary Guidelines for Americans, 2010 that recommend that pregnant women considerably increase their consumption of most types of fish, and

Page 1 of 2Whereas, the salutary effects of this recommendation are jeopardized by the now-dated and inconsistent advice to pregnant women that was issued jointly by the U.S. Food and Drug Administration and the Environmental Protection Agency in 2004, and

Whereas, this inconsistency places a burden on state public health agencies on how to interpret the Federal advice and on how to advise their own citizens; therefore, be it

Resolved, that AFDO will request to FDA that it reconsider and update its fish consumption advice on a priority basis, in light of the science since 2004 and the new Dietary Guidelines for Americans.

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