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Gina Solomon’s Blog

It's the Dose that Makes the Poison: How the FDA Is Not Protecting Many Gulf Coast Residents from Possible Seafood Hazards

Gina Solomon

Posted December 8, 2010

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As Capitol Hill kicks off a series of holiday parties celebrating Gulf seafood, and Congressional Rep. Steve Scalise says "I challenge the president to a raw oyster-eating contest," it’s a good time to reflect on the principles of an 16th century scientist who famously stated: “The dose makes the poison”. In the case of seafood contamination, this means the more you eat the higher your risk.

When the Food and Drug Administration (FDA) calculated safe levels for cancer-causing chemicals from oil (Polycyclic Aromatic Hydrocarbons or PAHs) in Gulf seafood, the agency made some assumptions about how much seafood people eat, and used those assumptions as the foundation for their calculations. For example, FDA assumed that people eat fish about twice a week, and shrimp only once. A serving of shrimp was assumed to consist of about four jumbo shrimp. I have blogged before about the laughter and disbelief from our Gulf coast partners when they heard these estimates. “Four shrimp don’t even make a Po’boy sandwich” hooted one of our Gulf coast friends.

The FDA pulled their numbers from a national survey, not from a Gulf Coast survey, or from any other survey of frequent seafood consumers. But a safety calculation is only as good as the numbers it’s based on. If the foundation is flawed, the house can crumble.

The FDA complained that there was no survey of seafood consumption rates and quantities in the Gulf coast region. For that reason, we decided to do our own survey.

The results of our survey confirm what local Gulf Coast residents have been telling us –FDA’s seafood consumption numbers are way too low.  In our survey of nearly 550 Gulf coast residents from Louisiana to Florida, 43% responded that they eat fish more frequently than the FDA estimates and 54% responded that they eat shrimp more frequently than the FDA estimates.  The numbers were really striking when it came to shrimp consumption rates where survey responses were 3.6 to 12.1 times higher than FDA estimates. Some subpopulations, particularly Vietnamese-Americans, reported significantly higher seafood consumption rates than other survey respondents (more than double) for fish, shrimp, oysters and crab.  In addition, many of our survey respondents are also more vulnerable to contaminants in seafood than FDA accounted for due to smaller body weight - 60% reported that they weigh less than the 176 lb FDA estimate. When coupled with increased consumption rates, this can result in a significantly increased dose of contaminants.  Although our Gulf seafood consumption survey did not represent a random sample, the results are significant in that they clearly show that a significant portion of Gulf Coast residents eat substantially more seafood than reflected in FDA’s risk assessment.

Based on these findings, we are asking FDA to expedite a reassessment of the safety levels for Gulf seafood to ensure that local dietary patterns and other vulnerabilities are incorporated, and to assure Gulf coast residents that their health is protected in decisions about seafood safety.

We don’t know exactly how much of the PAHs are in all that Gulf shrimp. The few samples reported by FDA show very low levels, but there are so many gaps and flaws in the sampling that those results may not be reliable. So it’s tough to say how close the shrimp actually are to the levels of concern. But what we do know is that the assumptions used in the safety calculations matter.  For one of our survey respondents, the safety level based on her body weight and diet would be 8.6 times lower than what FDA is currently allowing. And that doesn’t even factor in the increased risk she faces as a pregnant or nursing mother.

Other agencies, like the Environmental Protection Agency (EPA) and the World Health Organization (WHO) have developed guidelines that specify the need to account for local seafood consumption rates and the increased risks to vulnerable populations such as children.  The FDA, in contrast, has none and has ignored the guidelines established by other agencies.  In fact, the underestimates we found in our survey are a symptom of a larger problem.  FDA has been ignoring scientific findings about hazards of chemicals in foods, conducting inadequate monitoring of contaminant levels, and failing to adequately protect vulnerable populations for everything from the plastic allowed in baby bottles to pesticides on produce and mercury in fish.

So to all those folks on Capitol Hill who are chowing down on Gulf seafood at all those holiday parties: take a look at your plate and count carefully. The FDA’s protection stops at an average of four jumbo shrimp per week. What is party food for you this season is the foundation of a local diet for Gulf Coast residents.  The dose does matter and the people of the Gulf, and anyone who eats seafood, deserve for FDA to get it right.

The results of the Seafood Survey can be found here

The letter to FDA, along with a full list of the signatories, can be found here

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NancyDec 8 2010 12:48 PM

I recently developed an "allergy" to shellfish, wonder if it is really an allergy?? It makes me sick for days, sadly.

Matthew BermanDec 8 2010 04:01 PM

Thank you Gina for continuing your coverage of the BP oil spill and the situation in the Gulf.

I left a comment about Gulf Seafood safety on your article on the NPR site. I hope together we can not only ensure the safety of Gulf Seafood, but provide assurance for people around the world. Thus, Gulf businesses and fishing communities can continue with their livelihood.

Matthew Berman
Louisiana Seafood Board

Gina Solomon, MD, MPHDec 8 2010 08:08 PM

In response to Nancy's post: shellfish allergies are unfortunately fairly common, and are not likely to be related to the oil. It's reasonable to check with your doctor about whether your symptoms are consistent with an allergic reaction, since there are other kinds of health reactions that can occur.

I agree with Matthew that it is really important to sort out the questions about Gulf seafood. The fishing communities on the Gulf coast are really hurting economically. Our estimates of seafood consumption don't necessarily mean that the seafood itself is a problem -- the take-home lesson is that FDA isn't doing as good a job as it should in assuring safety. The FDA needs to do a better job so that scientists and the general public will be reassured and confident that their health is being protected when they feed their families.

BarclayDec 10 2010 11:04 AM

Thank you for the article Gina.
We hear alot of talk about how safe the seafood is in the Gulf. FDA/NOAA has been testing fish flesh and says results are below levels of concern.

From what I've read, independent scientists have found PAH's in shrimp above levels of concern. Fisherman have described tar balls and oil in their nets. Yet all we hear is how safe the seafood is.

Nobody talks about the quality of the water. I assume then, that's because the water quality is bad and has toxins in it.

I don't trust their methods or analysis. There's limited transparency for their analysis.
There's a good % of the public not buying the story. All the press about opening the closed fishing areas - and they just reclosed an area. No visible oil doesn't mean it's safe and for the fish that can swim away from oil - why are those flesh tests so important other than propoganda?

In August they (NOAA) said 75% of the oil had disappeared and weeks later independent scientists refuted that and estimate 75% of the oil is still out there.

Seems to me the public is being hood-winked.
I think more water quality data would tell the real story - either way. I hope the Gulf Coast recovers quickly - but don't think NOAA or FDA is helping their cause with lax standards and inadequate testing of the water and sea floor.

Everyone knows there's still oil out there - but we're treated like idiot consumers and we're supposed to just drink the 'everthing is safe' kool-aid. It's really an insult to our intelligence.
Thanks again,

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