Fish Consumption Advice for Alaskans
Purpose of Document
This document provides updated fish consumption guidance to the public, specific to Alaska-caught fish. The levels of mercury in Alaska-caught fish, as reported by the ADEC’s Fish Monitoring Program in 2006, are described and interpreted. The risks of mercury exposure are weighed against the health benefits of fish consumption to develop fish consumption guidance that is both balanced and protective. Our intent is to assist individuals, families and communities in Alaska as they make decisions about their fish consumption patterns.
This document is not intended to influence Air Quality or Water Quality criteria, or other regulatory standards. The allowance of daily intake levels for mercury that exceed the reference dose established by the U.S. Environmental Protection Agency (EPA) should not be interpreted as a recommendation to relax air or water quality standards. The Alaska Division of Public Health (DPH) appreciates the health risks posed by mercury, and encourages regulatory agencies to control mercury releases to the fullest extent possible to protect our environment and the health of all Alaskans.
History of Fish Consumption Advice in Alaska
DPH has historically recommended unrestricted consumption of all fish from Alaska waters. This recommendation was based largely on 1) a combination of insufficient fish contaminant data upon which to base restrictive advisories; 2) limited human mercury biomonitoring data that showed no exposures of health concern to Alaskans; and 3) the principle of nonmaleficence (i.e., first do no harm). In this case, nonmaleficence refers to the potential harm that could occur by encouraging people to reduce their fish consumption and thereby not receive the beneficial health effects of this nourishing food. 1
In 2001, the United States federal government issued generic fish consumption advice that was contrary to DPH’s longstanding recommendation. Due to concerns about mercury in fish, EPA and the U.S. Food and Drug Administration (FDA) recommended that pregnant women, women of childbearing age who may become pregnant, nursing mothers, and young children limit their consumption of fish. FDA recommended that these vulnerable members of the population should not eat shark species, swordfish, king mackerel or tilefish, and should limit consumption of other (commercial) fish to 12 ounces per week. EPA further recommended that these persons should limit consumption of fish caught by family members and friends to one meal per week, and suggested finding alternative sources of protein for children. This federal guidance was edited and re-issued in 2004 as a joint EPA/FDA advisory. 2
Public health officials in Alaska reviewed the available evidence and concluded that the federal advice was inappropriate for Alaska. Alaskans rely heavily on fish as a lean, nutritious protein source, particularly among Alaska Native subsistence users who live in rural areas with less access to healthy alternative foods. Also, Alaska fish, particularly wild Alaska salmon, have far lower mercury levels than those used to develop the generic national guidelines.
In response to the national advisories, Alaska public health officials met with numerous stakeholders including tribal health corporations, other state agencies, and university professors to develop a consensus statement regarding fish consumption advice in Alaska. Because mercury levels in Alaska fish, particularly wild Alaska salmon, are far lower than those used to develop the generic national guidelines, the consensus statement considered the federal advice to be inappropriate public health policy for Alaska. The consensus statement reported that “the known benefits of fish consumption far outweigh the theoretical and controversial potential adverse health effects from mercury found in Alaska fish.” DPH continued to strongly recommend that all Alaskans continue unrestricted consumption of fish from Alaska waters.