NCHR Testimony at FDA Risk Communication Advisory Committee on Fish Consumption


Good afternoon. My name is Dr. Laurén Doamekpor, and I am a senior fellow at the National Center for Health Research. Our non-profit research center is dedicated to improving the health and safety of adults and children and we do this by assessing scientific and medical data and providing objective health information to patients, providers and policy makers. Our organization does not accept funding from the fish industry, and therefore I have no conflicts of interest.

An important part of the work we do is explaining science and complicated medical jargon to people who don’t have a college degree or any scientific training. From our experience talking to consumers and answering their questions, we know that many people are frustrated and confused by what seems like conflicting information about food safety and nutrition.

Today’s example is typical. Fish is good for you, but certain kinds of fish can be dangerous – especially for children and for women who are pregnant or nursing.

How can we explain that to women in ways that are simple to understand and remember?  Of course, the biggest problem is that albacore tuna is high in mercury. Since tuna is the most popular fish, and the most affordable, how can we explain to women that they should eat fish but avoid albacore tuna if they are pregnant, might get pregnant, or nursing?

In the past, the FDA and EPA have tried to finesse that message.  That’s hasn’t worked effectively.

We believe in women’s ability to understand and remember that if they are pregnant or nursing they should avoid canned white tuna and other albacore tuna and instead consume light tuna no more than once a week. This doesn’t have to be complicated.

The draft guidance recommends that pregnant women, women who might become pregnant, and breastfeeding mothers eat at between 8 and 12 ounces per week of a variety of fish lower in mercury within their calorie needs. The advice to eat “a variety” of fish is very vague and not very helpful. It is also misleading. The truth is that these women should avoid fish that are higher in mercury, period. It should be made clear that the variety of fish consumed should come from the list of low mercury fish that also have nutritional value.

We also know that many consumers aren’t sure what 8 and 12 ounces means. It’s easy for canned fish, since that is measured by ounces.  It’s more difficult for prepared frozen fish (which might be breaded) or for fish sold by the pound.  However, there are other ways to describe portions that might be helpful. For example, one easy tip to share with consumers is that a 4 ounce fish serving is approximately the size and thickness of a deck of cards.

Incorporating diagrams and info-graphics in messaging are also effective tools for communicating information that is easier to understand.

We reviewed the proposed sound bites.  The sentences are much too long and complicated – the same information can be provided much more simply.  Terms such as “emerging science” should be avoided, instead using terms such as “the latest information.”

Please consider using a take home message that is easy to remember, such as “Rule of thumb: The smaller the fish, the safer the fish.”  However, it is also important to remember that not everyone knows that tuna is a very large fish and tilapia is a smaller fish.

In conclusion, most consumers don’t want to have a long list of exactly what kind of fish to eat and what to avoid.  If pregnant and breastfeeding women have avoided fish for themselves and for their young children it’s because the messages they were getting were confusing.  For the millions of women with smart phones, prepare a simple list of fish to choose and avoid.  Make a similar list for women without smart phones.  And come up with phrases that are easy to remember and and messages that are straightforward.