CEI Comments on Draft FDA Risk-Benefit Assessment of Fish Consumption

CEI Comments on Draft FDA Risk-Benefit Assessment of Fish Consumption

April 22, 2009

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The Competitive Enterprise Institute respectfully submits these
comments on the agency’s Draft Report of Quantitative Risk and Benefit
Assessment of Consumption of Commercial Fish (Draft Risk and Benefit
Assessment) and Draft Summary of Published Research on the Beneficial
Effects of Fish Consumption and Omega-3 Fatty Acids (Draft Summary of
Published Research). We applaud the FDA’s
decision to carefully study the growing body of scientific literature
examining the net health impact of fish consumption and to consider the
beneficial effects of fish consumption and Omega-3 fatty acids along
with the hazards associated with exposure to methylmercury.

The
overwhelming weight of this scientific evidence suggests that
consumption of most commercial fish species provides substantial net
health benefits. It is therefore appropriate that the FDA
should undertake a thorough analysis of the net health effects of
consuming commercial fish species, and that it should endeavor to
provide information about methylmercury risks that are put in an
appropriate overall context. The assumption that it is better for FDA
and other agencies to inform consumers only about the hazards
associated with methylmercury exposure in commercial fish than to
provide balanced and scientifically-validated information about the net
health effects of seafood consumption is misguided and would likely put
consumers at heightened risk.