2004D-0028 - Draft Consumer Advisory regarding Advice for Subgroups of a Population regarding Mercury in Fish and Shellfish
FDA Comment Number : EC8
Submitter : Miss. Laura Pinyan, M.S., C.N.S. Date & Time: 09/24/2004 01:09:25
Organization : Pacific Health Education Center
Health Professional
Category :
Issue Areas/Comments
To whom it may concern:

I am concerned that the consumer advisory regarding mercury should also specify that there are other individuals who may also be vulnerable and need to restrict fish intake. Recently published cases studies listed at the close of this comment, including one published by the CDC, appear to indicate that there are individuals who will react to mercury at levels just 7-15x the oral minimal risk level, according to the CDC. (1)
For this reason, an advisory that other individuals may also be susceptible to neurological injury at levels now considered acceptable for adults should be considered. Daily consumption of fish may put a subgroup of the general population at risk for neurological damage including parasthesias. (2)

Further, since we do not currently have a method of identifying susceptible individuals, recommending fish not be consumed on a daily basis for long periods may be prudent.

Laura Pinyan, M.S., C.N.S.
Director of Dietary Services
Pacific Health Education Center
Bakersfield, CA

Arch Phys Med Rehabil. 2004 Sep;85(9):E25.
Poster 88 unsuspected mercury toxicity linked to neurologic symptoms: A case series. Deborah Saint-Phard, MD; Peter G. Gonzalez, MD (Univ Colorado Health Sci Ctr, Denver, CO); Pamela Sherman, MD, e-mail: peter.gonzalez@uchsc.edu.

J Environ Health. 2004 Jul-Aug;67(1):9-14, 28
Too much of a good thing (fish): methylmercury case study.
Risher JF.
Division of Toxicology, Agency for Toxic Substances and Disease Registry, Atlanta, GA 30333, USA. jzr8@cdc.gov