Full Report is Our Tuna Family-safe

IS OUR TUNA “FAMILY-SAFE”?Mercury in America’s Favorite Fish

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DEFENDERS OF WILDLIFEwww.defenders.orgDefenders of Wildlife is a national, nonprofit membership organization dedicated to the protection of allnative animals and plants in their natural communities.

THE CENTER FOR SCIENCE IN THE PUBLIC INTERESTwww.cspinet.orgSince 1971, The Center for Science in the Public Interest has been a strong advocate for nutrition andhealth, food safety, alcohol policy and sound science.

MERCURY POLICY PROJECTwww.mercurypolicy.orgThe Mercury Policy Project works to promote policies to eliminate mercury uses, reduce the export and traf-ficking of mercury, and significantly reduce mercury exposures at the local, national and international levels.

ACKNOWLEDGEMENTSSpecial thanks to former Defenders Bill Snape and Kumar Vaswani, who helped bring about significantadvancements in the conservation of dolphin populations impacted by tuna fishing. We hope this reportcontributes to the work they began.

AUTHORSKatherine Malsch, International Coordinator, Defenders of WildlifeCarroll Muffett, Senior Director of International Programs, Defenders of Wildlife

MERCURY TESTING New Age/Landmark Mobile Laboratory Services

PEER REVIEWMichael Bender, Mercury Policy Project Caroline Smith DeWaal, The Center for Science in the Public InterestEdward Groth III, Groth Consulting Services

EDITORIAL TEAMEditor: Kate DaviesArt Director: Jen Lee

© 2006 Defenders of Wildlife1130 17th Street, NWWashington, D.C. 20036(202) 682-9400www.defenders.org

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TA B L E O F C O NTE NT S IS OUR TUNA “FAMILY-SAFE”?

Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

I. The Mercury Threat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Mercury in the Environment: Pathways to Wildlife and Humans. . . . . . . . . . . . . . . 4

Mercury in Humans: Public Health Risks of Fish Consumption. . . . . . . . . . . . . . . . 5

II. Exposure to Mercury from Tuna Consumption . . . . . . . . . . . . . . 6

High U.S. Demand for Tuna . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Factors Affecting Mercury Levels in Tuna . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

III. Public Health Warnings on Fish Consumption . . . . . . . . . . . . 10

Federal Advice on Mercury in Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

EPA’s Reference Dose: Science-Based Protection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

FDA’s Action Level: An Ineffective Safety Net . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Joint FDA/EPA Advisory on Mercury in Fish . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

IV. Independent Mercury Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Results of Independent Testing and Comparison to Government Testing . . . . . . . 15

Comparison to Government Advice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

V. Key Findings and Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

AppendicesAppendix A: Results by Mercury Concentration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Appendix B: Results by Country of Origin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

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Tuna, especially canned tuna, is the most popular fishamong American consumers and a staple in the diet ofmany children. Americans have long demanded that

their tuna be “dolphin-safe,” but mounting evidence of highlevels of mercury in tuna and other fish raises another seriousconcern: Is our tuna human-safe?

Mercury is a potent poison linked to human healthproblems ranging from brain damage and neurologicalimpairment in children to memory loss and heart attacks inadults. Mercury from power-plant emissions and other indus-trial sources is deposited in our oceans and waterways, where itaccumulates in the bodies of fish in the form of methylmercury.Eating contaminated fish is the most significant source ofexposure to methylmercury for humans. Recent studies suggesthundreds of thousands of babies born each year are exposed toexcessive levels of methylmercury at the most vulnerable periodof their lives—before they even leave the womb.

Given its popularity, canned tuna is the largest dietarysource of mercury exposure in the United States.

Testing the LimitsIn response to the growing evidence of risks associated withmercury, the Environmental Protection Agency (EPA) and theFood and Drug Administration (FDA) issued guidelines on theconsumption of tuna and other fish in 2004. Defenders ofWildlife, long a champion of the dolphin-safe-labelingprogram and an advocate for healthy and environmentallysound fisheries worldwide, is concerned that these guidelinesare not protective enough. The government based their most

recent guidelines ontests of mostlyAmerican brands oftuna, even though agrowing proportionof the canned tuna consumed today in the United States. isimported. In 2004, for example, 51 percent of the total U.S.supply of canned tuna came from foreign sources.

Defenders conducted this study to determine whether allcanned light and albacore tuna is similar in mercury content,as the current federal guidelines suggest. We also wanted tolook at how factors such as country of origin, fishing method,size and species composition of the tuna might affect theamount of mercury in each can. We commissioned inde-pendent testing of 164 cans of tuna collected from both largechains and smaller independent groceries around the country.Our study included not only U.S.-processed tuna, but alsotuna canned in Costa Rica, Ecuador, Malaysia, Mexico, thePhilippines, Thailand and other countries—making it the firststudy of imported canned tuna in the United States.

Disturbing ResultsOur testing results revealed high levels of mercury in cannedtuna, including light tuna, which the FDA has categorized as a“low-mercury fish.” A significant proportion of light tuna wesampled contained levels of mercury high enough to pose apotential public health risk, particularly to children and devel-oping fetuses. More than one-third (35 percent) of all cans inour sample had mercury levels above 0.3 parts per million

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EMercury from power plants and other sources contaminates our oceans and marine life, including yellowfin and othercommercially important tuna species. Consequently, canned tuna is now a major source of mercury in our diets.

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(ppm). Eating just one six-ounce can of this tuna a weekwould cause a 140 pound woman—and nearly all children—to exceed the EPA’s “reference dose” for mercury. In fact,based on this study, a 45-pound child eating one can of lighttuna in a week would be consuming mercury at a level threetimes higher than the EPA’s recommended maximumallowable dose of mercury. This is particularly alarmingbecause tuna is a staple of federal efforts such as the SpecialSupplemental Nutrition Program for Women, Infants andChildren (WIC) and the school lunch program. Currently,canned tuna is the only animal meat protein source offered bythe U.S. Department of Agriculture and state WIC programs,with the exception of the WIC programs offered in Alaskaand Hawaii. By promoting tuna as a major source of proteinthrough these programs, the government may be inadver-tently putting low-income women and children at greater riskof mercury exposure.

Mercury levels in the samples tested varied widely. Whilelight tuna from Asia was generally low in mercury, averagelevels of mercury found in the Latin American tuna testedwere surprisingly high—more than 0.4 ppm. Samples fromone country, Ecuador, had an astounding 0.75 ppm averagemercury content. By comparison, the FDA/EPA advisoryrecommends that consumers avoid king mackerel, a fish withan average mercury level of 0.73 ppm. More troubling, severalof the cans from Latin America reached levels over the 1.00ppm “action level” at which the FDA can pull tuna fromsupermarket shelves to protect public health. One can had1.50 ppm of mercury, and nearly one in every 20 cans of lighttuna exceeded the 1.00 ppm FDA action level.

The Dolphin-Safe, Family-Safe LinkIn the eastern Pacific Ocean, pods of dolphins routinely swimwith large, mature yellowfin tuna. Some commercial fishingvessels exploit this relationship by setting purse-seine nets ondolphins to catch the large tuna swimming below. Sincemercury concentrations in fish increase with the size and ageof the fish, and tuna caught in dolphin ‘sets’ are generally theoldest and largest tuna, it is reasonable to infer that this‘dolphin-unsafe’ fishing method results in tuna with highermercury concentrations than tuna caught by other means.

Our study found that tuna from two countries with adocumented history of dolphin-unsafe fishing, Ecuador andMexico, had the highest mercury concentrations of allsamples tested. The disproportionately high mercury levels inthese samples suggest that some countries are not onlyviolating international dolphin-protection standards, but alsocreating a significant health risk for consumers. While theevidence is not conclusive, our data support further investi-

gation into this possibility—especially since some minorityand immigrant groups may favor tuna from these countries.Our results also suggest that Bush administration’s efforts toweaken the dolphin-safe label may have serious and unin-tended consequences for public health.

A Call for Action The high levels of mercury found in certain types of cannedtuna pose a health threat to families, primarily to women andtheir children. Consumers have no way of knowing themercury levels of the tuna because it is nearly impossible todetermine what species of tuna the product is made from, thesize and age of the fish, where the fish was caught or whatmethod was used to catch it. The current federal guidelinesdo not address these critical factors. Therefore, we urge ourgovernment to take the following steps to protect consumers:

1. Conduct a more thorough assessment of the mercurycontent in canned tuna by looking at the growing market ofimported canned tuna and paying greater attention to thehigher mercury levels found in Latin American varieties.

2. Issue warnings for canned light tuna equivalent to those foralbacore tuna (six ounces per week maximum) until theFDA can conduct more comprehensive tests on importedtuna. Advise parents to limit their children’s consumptionof canned tuna to three ounces (half a can) or less perweek. This would better protect vulnerable populationsand serve as a responsible model for state advisories.

3. Reassess the role of canned light tuna in government food-support programs such as WIC and the federal schoollunch program.

4. Effectively enforce the FDA’s 1.00 ppm action level for thesale and importation of canned tuna and other fish withexcessive levels of mercury. In addition, update and extendthe FDA’s Hazard Analysis and Critical Control Point(HACCP) guidelines to recognize mercury as a likelyhazard and require seafood industry controls to monitor forhigh mercury content in fish.

5. Investigate the potential link between environmentallydestructive dolphin ‘sets’ and mercury concentrations.

In conclusion, it is the government’s duty to makeAmerica’s favorite fish family-safe and provide consumers withthe information they need to make informed choices. Thegovernment should keep canned tuna with excessive mercuryoff the market and give consumers clear and well-researchedadvice on tuna consumption to protect us from unacceptableexposure to mercury—regardless of where we live or whatkind of tuna we can afford.

IS OUR TUNA “FAMILY-SAFE”?

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THE MERCURY THREAT

Organic mercury (methyl-mercury) is a potent environ-mental poison linked to a

number of human health risks, rangingfrom brain damage and neurologicalimpairment in children to memory lossand heart attacks in adults. Althoughmercury is widespread in the envi-ronment, the only significant source ofmethylmercury exposure for humans isthrough consumption of contaminatedfish, primarily tuna.

Tuna is the best-selling fish inAmerica and the second most popularseafood after shrimp. The sheer volumeof canned tuna consumed makes it thelargest single dietary source of mercuryexposure in America and a potentiallyserious threat to public health.

Despite mounting evidence thatmercury poisoning from seafood is amajor health threat, particularly topregnant women, their developingfetuses and young children, little infor-mation is available to the public abouthow much mercury is really in tuna. Inlight of the risks involved, it is imper-ative that the public receive clear andaccurate advice on how to avoid harmfrom mercury contamination.

Mercury in the Environment: Pathways to Wildlife and HumansAlthough some mercury occurs natu-rally in the environment, the majority(70 percent) of the mercury currentlycirculating in our atmosphere is fromhuman sources, mainly industrial emis-sions from power plants, waste inciner-ation and other activities (Schuster etal. 2002).1

When released into the environmentthrough power plant emissions, chlori-alkali plants and other sources, mercuryenters into the atmosphere in an inor-ganic form. It is then deposited on landand into oceans, lakes and other waterbodies both near the source and milesaway. Once it enters the water cycle,

however, it is methylated (chemicallychanged primarily by micro-organismsand bacteria in the aquatic environment)into an organic form that can accu-mulate in the bodies of fish and humans(see Figure 1). This organic mercury iseasily absorbed by the blood and muscletissue of fish and other organisms andaccumulates as it goes up thefood chain, with animals ateach successive levelconsuming and absorbingmercury in progressivelyhigher doses.

Due to this process, themost dangerous levels ofmercury are generally foundin organisms that are higher on the foodchain. As a result, large predatory fishsuch as tuna, sharks and swordfish arelikely to have high levels in their bodies.In addition, older, bigger fish are likelyto have the highest levels of mercurywithin their species. The longer a fishlives and the larger the fish it consumes,the more mercury it takes in and thelonger the mercury has to accumulate inits tissues and bloodstream. According tothe U.S. Environmental ProtectionAgency (EPA), predatory fish can haveconcentrations of mercury in theirtissues that may be a million times

higher than the concentrations in thewater (EPA 2004).

Hence the level of mercury variesconsiderably depending on the species offish, its place in the food chain, the ageand size of the individual fish and thearea in which it lives. (Mercury concen-trations are frequently higher in areas

close to sources of mercury pollution.) Humans, at the top of the food

chain, are subject to the same impacts ofaccumulation over time. Fishconsumption is the primary way thegeneral public is exposed tomethylmercury, and, because of itstoxicity, the dietary intake ofmethylmercury is considered the mostserious general impact of mercury onhumans (United Nations EnvironmentProgramme 2002). The more fish we eatand the higher the particular fish is onthe food chain, the higher the levels ofmercury we ingest. Moreover, unlike

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The sheer volume of canned tunaconsumed makes it the largest

single dietary source of mercuryexposure in America.

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Figure 1: How Mercury Enters the Environment

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PCBs and other toxins that tend to befound in the fat of fish, methylmercury ispervasive throughout the organism,primarily in blood and muscle tissue. Forthis reason, mercury, unlike PCBs andother toxins, cannot be removed fromfish by simply cutting away the fat.

Mercury in Humans: Public HealthRisks of Fish ConsumptionThe mercury found in fish is a potentneurotoxin that can cause nervoussystem and brain damage in youngchildren, infants and developing fetuses.Methylmercury that enters the humanbloodstream is readily absorbed by thebrain, where it can seriously disruptnormal development of the centralnervous system.

Because their brains are rapidlydeveloping and represent a larger part oftheir body mass, developing fetuses andsmall children are at particular risk frommethylmercury poisoning. Mercury isfrequently implicated in the increase inchildhood neurological disorders such asattention-deficit disorder (ADD) andlearning disabilities (National ResearchCouncil 2000). Low-dose exposurethrough maternal fish consumption hasbeen linked to poor performance ontests of attention, fine-motor function,language, visual-spatial abilities (e.g.,drawing) and verbal memory (NationalResearch Council 2000). Prenatalexposure to mercury has been found toirreversibly impair certain brain func-tions in children (Grandjean et al.2004b). In extreme cases, mercurypoisoning has led to mental retardation,cerebral palsy, deafness and blindness(National Research Council 2000).Mercury exposure has also been linkedto heart arrhythmias in children(Grandjean et al. 2004a).

Comprehensive assessments by theU.S. Centers for Disease Control andPrevention (CDC) found that more than6 million American women—one out of

every 10 women of child-bearing age—have levels of methylmercury in theirblood that exceed levels considered safefor fetuses (CDC 2004, CDC 2001,McDowell et al. 2004). As a result,leading scientists in the field, includingone of the EPA’s leading methylmercuryexperts, estimate that as many as410,000 babies—one out of every 10born in the United States annually—areexposed to dangerously high levels ofmercury in the womb (Mahaffey 2005;Trasande et al. 2005). The fetal brain isconsidered 10 to 15 times more suscep-tible to mercury poisoning than thebrains of older children and adults (Sheaand Shannon 2004). While the risks aremost serious to developing fetuses in thewomb, methylmercury from fishconsumption can also contaminatebreast milk and expose babies to addi-tional mercury postnatally throughbreastfeeding (Drexler et al. 1998).Mercury exposure may be an importantcontributing factor to what experts call acrisis in child health, with developmentalabnormalities and other mercury-relatedillnesses reaching epidemic proportions(Anonymous 2000; Schettler et al.2000;American Lung Association 2005).3

Moreover, mercury exposure doesnot end with infancy. It continuesthroughout childhood and intoadulthood, whenever we eat contami-nated fish. And while young children andwomen of childbearing age are theprimary focus of health advisories,methylmercury has also been linked tohealth problems in adults, includingmemory loss (Guallar et al. 2002) andincreased risk of heart disease (Stern2005a; Guallar et al. 2002). Studies havealso found that mercury exposure mayhave adverse effects on the immunesystem (National Research Council2000) and result in loss of neurologicalfunction in the elderly (Yokoo et al.2003). Thus, while fish advisories tend tofocus on women and children, anyone,including the general adult population,can be adversely affected by mercury infish if they are exposed to it in highenough doses. Significantly, some effectsdocumented in adults have been linkedto levels of mercury exposure lower thanthose currently believed harmful to thedeveloping brain, suggesting thatmercury may negatively affect a far largerproportion of the population than previ-ously suspected.


State-issued fish-consumption warnings are increasingly common on America’s mercury-contaminated waterways.

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Mercury in tuna is a topic ofpublic concern not onlybecause of the high levels of

mercury found in fresh and cannedtuna, but because of the large volume oftuna consumed each year in the UnitedStates, especially among sensitive popu-lations such as women and children.According to the U.S. Department ofAgriculture (USDA), canned tuna is thefish most heavily consumed by childrenand women of childbearing age(Smiciklas-Wright et al. 2002). A recentreport by a coalition of eight states esti-mates that tuna alone accounts for 33percent of per capita exposure tomercury (NESCAUM 2005). Thus, thecombination of mercury content intuna and the sheer volume of currentconsumption makes canned tuna thelargest dietary source of methylmercuryexposure for the American public.

High U.S. Demand for Tuna Canned tuna is consumed by an esti-mated 96 percent of U.S. householdsand represents the number-three item inU.S. grocery stores, behind sugar andcoffee (U.S. Tuna Foundation 2003).The United States represents the largestsingle-country market for canned tunain the world.

Rising Imports of Canned Tuna

America’s canned tuna increasinglycomes from foreign sources. After yearsof rapid growth, imported tunasurpassed U.S.-packed tuna for the firsttime in 2004. The National MarineFisheries Service (NMFS) reports thatforeign-packed tuna now accounts for51 percent of America’s canned tunasupply by volume (NMFS 2005). Overthe last decade alone, foreign imports

have increased from nearly a third (29percent) of the U.S. market in 1994 to amajority of the market in 2004. Tocompete with foreign tuna companies,more and more U.S. production capacityis relocating to developing countries. Astariffs on foreign tuna drop, or in somecases disappear, canning of tuna in theUnited States is becoming uneco-nomical. This trend can be seen in bothfalling domestic production of cannedtuna and growing imports (see Table 1).

In 2003, 459 million pounds ofcanned tuna were imported into theUnited States, 81 million pounds morethan in 2002. Imports of fresh andfrozen foreign-caught tuna alsoincreased by nearly 30 percent between2002 and 2003, with imports totaling681 million pounds in 2003 (534million pounds of which were used forcanning) (NMFS 2005). The countriesexporting the most canned tuna by

EXPOSURE TO MERCURY FROM TUNA CONSUMPTIONII.

A yellowfin tuna begins its journey to the table. Hotly pursued by the fishing fleets of many nations, yellowfin accounts for nearly half of the world’s canned tuna.

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volume to the United States in 2003were Thailand (46 percent of imports),Ecuador (21 percent) and the Philip-pines (19 percent) (NMFS 2004). In2004, the Philippines imported slightlymore than Ecuador, but the top threeimporting countries remained consistent(NMFS 2005).

Factors Affecting Mercury Levels in TunaThe larger the fish and the greater itslongevity, the more mercury it will accu-mulate in its tissues (EPA 1997). Aspredators, tuna are invariably large fish,with some species reaching lengths of upto 12 feet, weighing more than 1,500pounds and living as long as 30 years.Their size and predatory nature maketuna especially susceptible to mercurybioaccumulation during their lifetimes.

To understand the potentialmercury risk associated with any givencan of tuna it is helpful to know: 1) thespecies of tuna; 2) where the tuna wascaught; and 3) the age and size of theactual tuna in the can. At first glance,these seem like easy questions to answer,but in an industry characterized byincreasing globalization they prove verydifficult. The problem that arises whenattempting to determine the species andsize of the fish is that with modern-dayindustrialized fishing and trade infra-structure, it is often impossible forconsumers to know even the country oforigin of their seafood, much less anydetails on the individual fish. This isparticularly true for tuna, as fleets fromnumerous countries cross the world’soceans in search of fertile fishinggrounds, using methods varying fromlonglining to purse seining to pole-and-line fishing.

Tuna are highly migratory speciesthat are found in oceans around theworld. Since canned tuna has a long shelflife, it can be shipped long distances fromwhere it was originally caught. While the

area in which tuna are caught can alsoplay a role in the level of mercury,mercury is so pervasive in the envi-ronment that traces can be found in fishfrom all over the globe, including theArctic and other areas far-removed frompower plants and other human-relatedsources of emissions (United NationsEnvironment Programme 2002).

Adding to the confusion is the factthat once caught, tuna is not necessarilyprocessed by the same country thatcaught it or even the same region whereit was caught. Thus, it is increasinglydifficult to determine exactly whocaught the tuna, how it was caught oreven in which ocean.

To complicate matters further, thereare eight different species of tuna:yellowfin, skipjack, albacore, bigeye,tongol, northern bluefin, southernbluefin and bonito. Of these species,only albacore can be labeled “white tuna”when canned in the United States. Theremaining seven species are all sold inthe United States labeled “light tuna.”

Despite these complexities, someinferences can be made. Slightly lessthan half of the world’s canned tuna isyellowfin, and together yellowfin tunaand skipjack tuna account for about 96percent of the world’s canned tuna(Monterey Bay Aquarium 2003). Thus,if you are eating light tuna, the odds arethat you are eating yellowfin or skipjack.Yellowfin is significantly larger thanskipjack tuna and, accordingly, generallyhigher in mercury content.

Mercury Content as a Function of Fishing Method

Factors that may strongly affect themecury content of canned tuna are thesize and age of the fish and, by associ-ation, the fishing method by which itwas caught. Although tuna is caught bya number of methods, two methods,longlining and purse seining, account forthe great majority of tuna available inU.S. markets. Both are industrial-scalemethods fine-tuned to catch the largest


Year *U.S.-Packed Supply Imports Total

1994† 601,123 71% 249,043 29% 850,166

1995 659,196 75% 215,365 25% 874,561

1996 665,950 78% 193,037 22% 858,987

1997 617,065 74% 212,171 26% 829,236

1998 671,541 74% 240,409 26% 911,950

1999 685,871 67% 334,537 33% 1,020,408

2000 667,163 68% 312,967 32% 980,130

2001 503,879 63% 292,202 37% 796,081

2002 543,381 59% 378,140 41% 921,521

2003 523,047 53% 459,029 47% 982,076

2004 431,000 49% 443,297 51% 874,297

Source: NMFS 2005. Fisheries of the United States 2004, p 72. †The 1994 data is from NMFS 2004. Fisheries of the United States 2003, p 78. *These figures represent the total U.S. supply of U.S.-packed tuna minus the small percentage of exported tuna.

Table 1: U.S. Supply of Canned Tuna, 1994-2004 (canned weight, thousands of pounds)

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amount of fish possible. Although it isextremely difficult to know exactlywhere and how canned tuna was caught,much less how large the tuna was, thepredominance of these two methodsmakes it possible to draw reasonableinferences about the tuna in a can based

on the country where it was processed(also called the “country of origin”) andthe species of tuna.

Longlining: As the name suggests,longline fishing involves the deploymentof central fishing lines of tremendous

length, up to 50 miles or more for asingle line. Each of these central lines isstrung with many smaller lines, eachbearing a baited hook. Consequently, asingle longline vessel can deploy thou-sands of hooks at a time.

Longliners catch a wide array oftuna—from juveniles to adults. Largetuna, which are relatively intact whenbrought on board, are usually sold to theAsian sushi market, where they fetch thehighest price (FAO 2005). Smaller fishcaught by longliners are more likely toend up in canned tuna. Thus, it can beinferred that canned tuna caught bylongliners are likely to have lowermercury levels than the larger fishprovided to the sushi market. Asiancountries such as Taiwan and Japan typi-cally use longliners to catch the bulk oftheir tuna.

An unfortunate consequence oflonglining is that it catches more thanjust tuna. Thousands of other “non-target” marine species are also attractedby the baited hooks and caught inciden-tally as “bycatch” (see Figure 2). It isestimated that more than 300,000endangered sea turtles (Lewison 2004),300,000 seabirds (BirdLife International2004) and tens of millions of sharks(United Nations EnvironmentProgramme 2004) are caught and killedin longlines each year.

Purse Seining: Like longlining, purse-seine fishing is a large-scale industrialfishing method designed to catch hugenumbers of fish at a time. Rather than along line of baited hooks, purse seinersdeploy nets up to a mile long. Smallspeed boats are launched from the mainfishing boat to surround the fish withnetting. Everything in the path of theboats gets encircled and corralled in thelarge net (see Figure 3). The bottom ofthe net is then pulled closed like a draw-string purse to catch the tuna, mostlyyellowfin and skipjack, which is subse-quently canned.

Longlining and purse seining are the two large-scale, industrial fishing methods commonly used to catch tuna.Unfortunately, both techniques also snare and kill large numbers of sharks, dolphins, sea turtles and other marinewildlife each year.

II. EXPOSURE TO MERCURY FROM TUNA CONSUMPTION

Figure 2: Longlining and Bycatch

Figure 3: Purse Seining

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While an efficient way to catchtuna, purse seining also results in highlevels of bycatch, which includesdolphins, sharks, sea turtles and othermarine wildlife that swim with or nearthe tuna. Purse seining has provedparticularly deadly for dolphins. In theeastern tropical Pacific Ocean, large,mature yellowfin tuna often swim belowpods of dolphins. Some fishermen inten-tionally chase and net the dolphins inpurse-seine nets to catch the tunaswimming below. Since the late 1950s,more than seven million dolphins havebeen killed this way.

In 1990, widespread public oppo-sition to this practice led the U.S.Congress to prohibit U.S. fishing vesselsfrom intentionally setting nets ondolphins and to create a dolphin-safetuna-labeling program to allowconsumers to make informed choicesabout how the tuna they buy is caught.

Despite the U.S. dolphin-safelabeling program and the developmentof international standards to reduceintentional sets on dolphins, a smallnumber of countries, such as Ecuador,Mexico and Venezuela, continue to catchdolphins while purse seining for tuna.Within the United States, it is illegal tolabel tuna dolphin-safe if it is caught by

intentionally setting purse-seine nets ondolphins; however, it is still legal to sellnon-dolphin-safe tuna in the UnitedStates, i.e., tuna without the dolphin-safe label.

Because only older, faster tuna arecapable of keeping up with dolphins,tuna caught in purse-seine nets set ondolphins are primarily large, matureyellowfin tuna. These fish tend to bemuch larger than tuna caught by otherfishing methods. Given the strong corre-lation between the size and age of a fishand its mercury content, they are alsolikely to be contaminated with higherlevels of mercury than smaller, youngertuna caught by dolphin-safe methods.This, coupled with the larger size ofyellowfin compared to skipjack, may be

one reason for the higher concentrationsof mercury reported for the yellowfin.Moreover, unlike large tuna caught onlonglines, big yellowfin caught in purse-seine netting operations do not remainintact and end up as canned tuna, ratherthan sushi.

Purse seines are also used to catchtuna without targeting dolphins, butthese sets also net large amounts ofbycatch. Purse-seine operations use “fishaggregating devices” (FADs), whichattract tuna but also draw large numbersof sharks, juvenile tuna and sometimessea turtles that are then caught in thetuna nets. Thus, purse seining, evenwhen dolphin-safe, takes a heavy toll onnon-target species such as sharks, seaturtles and juvenile tuna.

Hawksbill sea turtles and other air-breathing marine animals get entangled in purse-seine nets and drown.


Dolphin- and Human-Safe: The Link BetweenMercury and the Dolphin-Safe Label

Purse-seine nets are the nets made infamous by the dolphin-safetuna controversy. For more than a decade, Defenders of Wildlife hasfought to ensure that the dolphin-safe label is applied only when nodolphins were intentionally chased or netted in the process of tunafishing. In recent years, the Bush administration has been trying toweaken the strong dolphin-safe definition by allowing tuna caught inintentional dolphin sets to be labeled dolphin-safe. The results of ourown research suggest that, in addition to harming dolphins, thiswatering down of the dolphin-safe label might also expose consumersto increased health risks due to mercury exposure.

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To reduce the risk of damagingeffects from methylmercury,pregnant women, infants,

children and women of childbearing ageare encouraged to limit consumption offish that may contain high levels ofmercury. For instance, it is better toavoid large, predatory fish such as tunaand swordfish in favor of smaller fishthat are lower on the food chain.However, opinions differ on just howmuch mercury, if any, can be consumedsafely and how much of which fish canbe eaten without exceeding thatallowable dose. In addition, it is difficultto get detailed, accurate information onthe mercury concentrations in specifictypes of fish, particularly tuna.

To date, 45 states and severalNative American tribes have issued advi-sories or guidance to educate the publicon how to avoid the harmful effects ofmercury-contaminated fish (EPA 2004).Most of these advisories are targeted atfishermen eating their own catch, ratherthan consumers, but 11 states specifi-cally warn pregnant women andchildren to limit their consumption ofcanned tuna.4

Hawaii, for instance, provides itsresidents with more protective advicethan the federal government by recom-mending that adults limit theirconsumption of canned tuna to sixounces (one can) per week and childrenlimit their consumption of canned tunato three ounces (half a can) per week(Hawaii State Department of Health2003). California has made the greateststrides toward educating the public onthe risks of eating fish high in mercury.As a result of actions taken by the Cali-fornia attorney general, several grocerystores and restaurant chains are nowposting warnings on the health risks ofeating fish with mercury (includingtuna) in their businesses.5 At thenational level, the U.S. Food and DrugAdministration (FDA) and the EPA alsooffer advice on mercury in fish.

However, despite the broad array ofadvisories and the wide body ofknowledge on the subject, the majorityof the public remains unaware of thegovernment’s advice and of actualimpacts mercury-contaminated fish canhave on them and their children (Burger2005). Even most people who are awareof the government’s advice on fishconsumption are unable to rememberwhich fish are low mercury and which toavoid (Oceana 2005).

Not only is the advice consumersreceive about fish consumption notadequately publicized, it is also ofteninconsistent, varying not only from stateto state, but also between the states andthe federal government. More troublingis that our evidence suggests that thefederal advice most broadly distributed tothe most vulnerable populations does nottell the complete story. Combined withfederal programs that actively promoteincreased tuna consumption, this advicemay be putting many women andchildren at additional and unnecessaryrisk from mercury exposure.

Federal Advice on Mercury in FishThe EPA and FDA both bear someresponsibility for determining whatlevels of mercury, if any, are safe for themembers of our society most vulnerableto mercury poisoning—namely infants,children, pregnant women and womenof childbearing age. In the past, the twoagencies used different operational defi-nitions of levels of mercury in fish thatcould lead to unsafe exposure. Theagencies also issued separate and incon-sistent dietary advisories, largely becauseof their differing jurisdictions. As part ofits responsibility for regulating andprotecting water quality in the UnitedStates, the EPA advises states on thesafety of consuming locally and recre-ationally caught fish consumption. Bycontrast, the FDA is responsible for thesafety of commercial seafood. Despite

these differing jurisdictions, it is clearthat the toxin involved (methylmercury),the means of exposure (ingestion) andthe ensuing health risks are the sameregardless of whether the fish involvedare caught in a local stream or on thehigh seas. Thus, after many years ofcontradictory recommendations, theFDA and EPA released a Joint Advisoryin 2004 in an attempt to harmonizetheir previously inconsistent guidance.

EPA’s Reference Dose: Science-Based Protection The EPA has a well-established, science-based level for its recommendedmaximum mercury intake limit. TheEPA defines its “reference dose” (RfD)for mercury as “an amount ofmethylmercury, which when ingesteddaily over a lifetime is anticipated to bewithout adverse health effects tohumans, including sensitive popula-tions” (EPA 1997). At or below thisdose, exposures are expected to be safe.

As the basis for its reference dose,the EPA began with the level of mercuryin fetal (umbilical cord) blood known tocause clearly observed adverse effects on

PUBLIC HEALTH WARNINGS ON FISH CONSUMPTIONIII.

Even low levels of mercury can harm developing fetuses.

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brain development in children. The EPAthen incorporated a tenfold “uncertaintyfactor” between this dose and the RfD.In other words, the RfD is designed tokeep mercury levels in fetal blood at least10 times lower than the dose at whichadverse effects were evident. This marginis called an “uncertainty factor” becausethere are, in fact, substantial scientificuncertainties about where the line is, orif there even is a line, between doses thatcause some harm and doses that do not.Sensitivity to mercury poisoning mayvary from one part of the population tothe next or even from one person to thenext. Just as importantly, a dose thatcauses no observable effects on oneaspect of human health may have unex-pected health impacts in other areas.Because of these uncertainties, exposureabove the RfD (but still below theknown harmful level) is not necessarilyharmful, exposure below the RfD is notnecessarily free of all risk. The EPA statesthat the “risk following exposures abovethe [reference dose] is uncertain, but riskincreases as exposures to methylmercuryincrease” (EPA 1997).

In 1997, the EPA set the referencedose at 0.1 micrograms of mercury perkilogram of body weight per day(µg/kg/day). In doing so, the EPA stroveto ensure that the RfD, with its incorpo-rated uncertainty factor, defined anexposure level that should pose no signif-icant risk to the developing fetus. In anindependent study conducted in 2000,the National Research Council deter-mined that the EPA reference dose wasscientifically sound and should continueto be used as the guideline for protectingpublic health. Two years later, theEuropean Commission adopted theEPA’s reference dose for the EuropeanUnion as well, declaring that thecommission “consider[s] the U.S. EPARfD of 0.1 µg per kg body weight a dayto be appropriate for Europe” (EuropeanCommission 2002).

The EPA’s reference dose recognizes

that the impacts of mercury exposurevary widely depending on the age andsize of the person, an important factorthat can lead to substantial differences inthe relative vulnerabilitiesof different parts of thepopulation. The RfD isexpressed in microgramsof mercury per unit ofbody weight per day, sothe more you weigh, thehigher your RfD. Sincethe EPA’s reference dose increasesproportionately based on an individual’sweight, the RfD inherently has a stricterstandard built in for smaller children whoare more susceptible to the damagingneurological effects of mercury.

Unfortunately, emerging evidencesuggests that even the EPA referencedose may not fully protect developingfetuses. The EPA reference dose wasdesigned to prevent women of child-bearing age and pregnant women fromexceeding blood mercury concentrationsof 5.8 mg/L on the assumption that themercury concentration in fetal bloodwould match that found in the blood ofthe mother. However, recent studiesindicate that mercury levels in umbilicalcord blood are actually 70 percent higherthan mercury levels in the mother’s

blood (Mahaffey 2005; Stern 2005b).Therefore, to keep fetal blood below 5.8mg/L, the appropriate target level formaternal blood actually needs to be

below 3.5 mg/L (5.8/1.7), as opposed tothe 5.8 mg/L on which the currentreference dose is calculated. Thus,protecting the developing fetus requiresmaternal blood mercury levels muchlower than previously thought. In lightof this evidence, there is reason tobelieve that the reference dose should belowered to better protect developingfetuses. Moreover, as previously noted,recent studies suggest that even lowerlevels of mercury exposure maycontribute to heart attack risk and causeother adverse health effects among thegeneral population.

Absent more restrictive federalguidance, however, the EPA’s referencedose remains the best available science-based definition of an allowable level ofmercury intake.


Mercury is the often-secret ingredient in an American lunchtime favorite: the tuna-salad sandwich.

Sensitivity to mercury poisoningmay vary from one part of the

population to the next or even fromone person to the next.

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FDA’s Action Level: An IneffectiveSafety NetA different and less precise indicator of amaximum permissible amount ofmercury in tuna may be found in the“action level” set by the FDA. As thefederal agency responsible for ensuringthe safety of the nation’s food supply, theFDA has set action levels for harmfulcontaminants, above which the agencycan take legal action to remove productsfrom store shelves to protect consumers.The action level for mercury in fish,shellfish, crustaceans and other aquaticanimals (fresh frozen or processed) is 1.0part per million (ppm) (FDA 2000).This limit was established in 1975, longbefore the evidence on which the EPARfD is based was available. In fact, theFDA first set the action level at 0.5 ppmin 1969, but was forced to roll the limit

back to 1.0 ppm in response to anindustry lawsuit. As might be expected,the action level therefore is substantiallyhigher than the concentrations thatwould cause a typical consumer toexceed the EPA reference dose. Even asingle serving of fish containing 1.0 ppmof mercury can deliver much more thanthe EPA reference dose to the personeating it. For example, a 140-poundwoman who eats a single six-ounce canof tuna with a mercury concentration of1.0 ppm consumes roughly four timesthe EPA’s weekly reference dose formercury. A 45-pound child eating thesame can of tuna would consume morethan 10 times the reference dose.

The FDA action level is among theleast protective mercury guidelinesadopted by any developed country orinternational health body (see Figure 4)

and has been criticized by the NationalAcademy of Sciences (NAS) and othersas insufficient to safeguard the health ofchildren and fetuses (NAS 1991). As weshall see, however, our random testing ofcanned tuna showed that tuna exceedingthe action level is common on super-market shelves, suggesting that theFDA’s current monitoring andenforcement efforts are at best woefullyinadequate. The NAS reached the sameconclusion, noting that even with thehigh 1.0 ppm action level, the “presentmonitoring and inspection programcarried out by all federal agencies lacksboth the frequency and the directionsufficient to ensure effective implemen-tation of the nation’s regulatory limitsfor seafood safety” (NAS 1991). In fact,the only enforcement of the 1.0 ppmaction level uncovered by Defenders inresearching this report occurred between1991 and 1993, during which periodeight enforcement incidents are recorded(FDA 1991; FDA 2006). The seafood(shark and swordfish) was recalled due to“excessive levels of methylmercury.”6

None of these enforcement actionsinvolved the recall of tuna, however.Nearly 15 years after the NAS finding, itis clear that unknown quantities ofcanned tuna are entering U.S. marketswithout adequate (if any) screening formercury. Most of this tuna seems tocome from foreign sources that gocompletely unexamined.

Considering the findings of theNAS and the stricter protections seenworldwide, the FDA’s action level needsto be significantly reduced to protectadequately against adverse effects onfetal development. At a minimum, theFDA should substantially increase itsmonitoring program and take strongersteps to keep tuna above the mercuryaction level off store shelves. As a regu-latory safety net, the current action levelis inadequate.

III. PUBLIC HEALTH WARNINGS ON FISH CONSUMPTION

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*The 0.3ppm mercury limit was derived by applying the EPA RfD of 0.7 µg/kg/body weight to an adult weighing 155 pounds (70 kg) and

consuming one six-ounce can of tuna per week. By the nature of the RfD, this number is variable and would increase for those weighing

less than 155 pounds (and eating more tuna) and would decrease for those weighing more (and those eating less tuna).

† The Joint FAO/WHO Expert Committee on Food Additives (JECFA) recommends a tolerable weekly intake of 1.6 µg/kg/body weight

per week and cautioned that children and fetuses might need even greater protection (JECFA 2003). To determine the 0.66ppm mercury

limit, the 1.6 µg/kg/body weight standard was applied to a 155-pound person consuming one six-ounce can a week.

Figure 4: Maximum Allowed/Recommended Mercury Levels in Fish (ppm) inSelected Countries and by IGOs

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Joint FDA/EPA Advisory on Mercury in Fish In March 2004, the EPA and FDAissued a Joint Advisory on mercury infish to minimize the confusion caused bycompeting and inconsistent advice fromtwo government agencies. The JointAdvisory has been widely distributed topediatricians, obstetricians, midwivesand school administrators and incorpo-rated into other government educationalmaterials such as the FDA’s Food Safetyat a Glance: How to Protect Yourself andYour Baby (FDA 2005).

The Joint Advisory states that byfollowing the three recommendationsbelow, pregnant women, women ofchildbearing age and children “willreceive the benefits of eating fish andshellfish and be confident that they havereduced their exposure to the harmfuleffects of mercury” (EPA and FDA2004). Specifically, the Joint Advisoryrecommends that consumers:

1. Do not eat shark, swordfish, kingmackerel or tilefish because theycontain high levels of mercury.

2. Eat up to 12 ounces (two averagemeals) a week of a variety of fishand shellfish that are lower inmercury.

• Five of the most commonly eatenfish that are low in mercury areshrimp, canned light tuna,salmon, pollock and catfish.

• Another commonly eatenfish, albacore (“white”) tuna,has more mercury thancanned light tuna. Therefore,when choosing your twomeals of fish and shellfish,you may eat up to six ounces(one average meal) of albacoretuna per week.

3. Check local advisories about thesafety of fish caught by familyand friends in your local lakes,rivers and coastal areas. If noadvice is available, eat up to sixounces (one average meal) perweek of fish you catch from localwaters, but do not consume anyother fish during that week.

This advisory marks the first timethat canned tuna has specifically beenincluded in federal advice on mercuryand seafood, warning children, nursingmothers and women of childbearing ageto limit their intake of certain mercury-containing fish. The FDA/EPA JointAdvisory draws a sharp distinction,however, between more expensivealbacore tuna and the cheaper chunk lighttuna that comprises the bulk of themarket (USDA 2004). The advisoryrecommends that sensitive populationsshould limit their consumption ofalbacore tuna to one six-ounce serving perweek, but says it is safe to eat up to 12ounces (two cans) a week of light tuna.

Many public health professionalsand environmental groups have criti-cized the advisory for not beingprotective enough. In particular, thegovernment’s Joint Advisory fails toensure that all segments of the public

will keep their mercury doses below theEPA’s science-based reference dose. As aresult, the FDA/EPA Joint Advisorylargely disregards a well-established leveldesigned to protect the health of thosemost susceptible to mercury exposure(National Research Council 2000).

While the advisory recognizes thepotential risks of eating albacore, itsimultaneously downplays concernsabout the less expensive light tuna thatpeople eat far more often. The JointAdvisory fails to acknowledge that notall light tunas are created equal.Whereas, “white” tuna by law appliesonly to albacore tuna, the term lighttuna can be used for any of the otherspecies of tuna. By relying on overallaverage mercury levels and not differen-tiating the “light” category further, theadvisory wrongly suggests that all formsof light tuna contain insignificant tracesof mercury. In reality, the amount ofmercury contained in any one sample oftuna depends on a variety of factorsincluding the species of tuna, the oceanin which it was caught and the size ofthe fish. Little, if any, of this informationis readily available to the consumer.

Moreover, the advisory does notadequately distinguish between theamounts adults should consume and theamounts safe for children. It simply statesthat parents should “follow these samerecommendations when feeding fish andshellfish to your young child, but servesmaller portions.” This advice is unclearand needlessly vague. If the EPA referencedose had been more closely adhered to,the Joint Advisory would provide morespecific (and scientifically precise) adviceto parents based on a child’s weight.(Several environmental and health groupshave taken this step by providing“mercury calculators” and other tools ontheir Web sites.) Finally, the advisory failsto mention that fresh tuna also containshigh mercury levels, often significantlyhigher than canned tuna.7


Government-issued guidelines on tuna consumption arepublicized in brochures and other materials.

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For nearly two decades, Defendersof Wildlife’s research and advocacywith respect to tuna fisheries have

focused on the impacts on dolphins andother marine wildlife. Because of thehigh levels of wildlife mortality asso-ciated with various tuna fishingmethods, we have promoted measuresthat would reduce the threat to wildlifeand give consumers the tools to makeinformed purchasing decisions.

Recognizing that different tunafishing practices have different environ-mental impacts, Defenders has also longbeen interested in the correlationbetween fishing method and the sizeand species composition of the tunacaught. As evidence of mercury concen-trations in predatory fish has mountedin recent years, we have become increas-ingly curious about these correlations as

they relate to the mercury compositionof the fish caught and, thus, humanhealth. To investigate these potentialconnections further and to educate thepublic on the risks associated withmercury in tuna, Defenders conductedan experiment to assess the differencesin mercury concentration across a widespectrum of canned tuna.

MethodologyFor this report, Defenders collected atotal of 164 cans of tuna from retailersaround the United States, includingCalifornia, Indiana, Kentucky,Maryland, Minnesota, Texas and Wash-ington, D.C. To get a cross section of thesorts of tuna available to consumers, webought tuna from national and regionalchains, “mom-and-pop” groceries,convenience stores and corner markets inneighborhoods with large ethnic popula-tions. Although our study included themajor national brands that dominateretail shelves, we also sampled storebrands, specialty brands and other lesserknown brands that, while comprising arelatively smaller portion of the totalU.S. market, may be widely consumedat a regional level or among particularpopulations.

The tested brands included:• Albertson’s • Atun Real Fiesta Brand• Atunsito• Bumble Bee• Calmex• Cento• Chicken of the Sea• Cub Foods• Dave’s Ahi Tuna• Dave’s American• Dolores• El Dorado • Fiesta Brand• Flavorite• Geisha• Herdez Atun

• IGA• Maz Atun• Nair• Natural Sea• Pacifico Azul• Polar All Natural• Portside• Progresso• Safeway• Sardimar• Starkist• Sunny Select• Trader Joe’s• Tuny• Van Triunfo• Western Family• Whole Foods

Due to the rise in imported cannedtuna and variations in mercury contentaccording to the fishing method used, arange of canned tuna from severaldifferent fishing nations was tested.Sampled cans originated in Costa Rica,

A 550-pound tuna—the bigger the fish, the higher themercury content.

INDEPENDENT MERCURY TESTINGIV.

The country of origin label on canned tuna can be a clueto its mercury content. Tuna from Latin America had thehighest levels of all the imported tuna tested.

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Ecuador, Malaysia, Mexico, the Philip-pines, Thailand and the United States.When considering the “country oforigin” of each can, it was assumed thatthe country indicated on the label wasthe country of origin. The country wasoften indicated by a phrase such as“Product of Thailand” or a similarstatement on the label. It should benoted that the country of origin shownon the label is generally the countrywhere the tuna was canned, which mayor may not be the country where or bywhose vessels it was caught.

The 164 cans tested included:•10 American albacore tuna cans(four brands)•10 Asian albacore tuna cans (five brands)•25 American light tuna cans (five brands)•45 Asian light tuna cans (14 brands)•23 Costa Rican light tuna cans (two brands)•18 Ecuadorian light tuna cans (two brands) •33 Mexican light tuna cans (eight brands)

For purposes of regional compar-isons, these samples break down to 35American cans of tuna, 55 Asian cansand 74 cans from Latin America. Thesample size was not intended to providea representative sample of the U.S. tunamarket, rather it was deliberately set toshine more light on the mercury contentof foreign imports. U.S. brands, espe-cially the three largest that make up thebulk of U.S. tuna, have already been thefocus of much scrutiny and testing bythe FDA and other groups, so we didnot test as many of them.

Sample cans were submitted formercury analysis to New Age/LandmarkMobile Laboratory Services in BentonHarbor, Michigan. New Age/Landmarkis used by the Environmental Protection

Agency and certified by the NationalEnvironmental Laboratory AccreditationCommittee. To ensure the testing wasblind, the first 100 cans were sent to thelaboratory numbered 1 to 100 withouttheir original labels. Using the sameblind testing method, another 64 canswere sent to the same laboratory toconfirm the initial results. Each label wasremoved and catalogued with the corre-sponding sample number and the placewhere the tuna can was purchased toensure that the lab results could bematched with the corresponding label.

The laboratory tested each samplefor the total mercury (both organic andinorganic) present in the tuna. Testingtotal mercury instead of methylmercuryin fish is the method frequently used bythe FDA when testing its own samples.This is a valid testing method because 90percent to 99 percent of the totalmercury in fish is in the form ofmethylmercury (Bloom 1992). Themethod, known as EPA Method SW-846 7473, involves controlled heating(to decompose the sample and separatethe mercury from the solid tuna) andamalgamation (to isolate the mercuryfurther and transform it into a meas-urable mercury vapor). The laboratoryincluded blanks in every batch andemployed other control methods to

ensure accurate results. Dilution andrecovery tests were also used as necessaryto ensure the accuracy of the results.

Results of Independent Testing andComparison to Government TestingThe recommendations in the 2004EPA/FDA Joint Advisory are based ontesting of tuna samples done by the FDAbetween 1991 and 2003. Although itstesting data date back to at least 1991,the FDA stopped testing tuna formercury in 1998 except for its annual“market basket” survey, only to restartagain recently under pressure from scien-tists and environmental groups. A closereview of the Joint Advisory and theFDA’s underlying data indicate that theadvisory is based on an analysis of 132samples. Each sample tested was acomposite of 12 cans, tested together, togive a cumulative average. The FDA’stesting produced an average mercurylevel of 0.353 ppm in canned albacore(white) tuna and 0.118 ppm in cannedlight tuna (EPA and FDA 2006). Whilethis testing method is valid and allowsefficient testing of large quantities oftuna, it cannot determine the mercurydosage in any given can of tuna, and it“averages out” both high spikes and verylow levels. In addition, the FDA’s testing

Average Hg* (ppm) Median Range

Albacore 0.401 0.400 0.170-.730

All Light Tunas 0.269 0.160 0.012-1.50

American Light 0.204 0.120 0.023-.990

Asian Light 0.073 0.052 0.012-.440

Costa Rica 0.281 0.230 0.079-1.30

Ecuador 0.754 0.680 0.300-1.50

Mexico 0.310 0.180 0.064-1.40

Overall Average 0.285 ppm 0.180 ppm 0.012-1.50 ppm

*Hg = Total Mercury


Table 2: Breakdown of Results

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has focused almost exclusively on thethree major U.S. brands, and has not, toour knowledge, specifically sampled thewider variety of brands and countries oforigin that represent a growing part ofthe tuna market.

Our own testing of individual cans,focusing more heavily on foreignimports as opposed to domestic brands,produced much different results (seeTable 2). The average mercury contentin our albacore samples was 0.401 ppm,somewhat higher than the FDA’saverage, but within a reasonable rangegiven our smaller sample size.

The more surprising results relatedto light tuna—the type of tuna mostcommonly consumed by the Americanpublic (see Table 3). The averagemercury content in the 144 cans of light

tuna sampled was 0.269 ppm, more thantwice the 0.118-ppm average for lighttuna reported by the FDA and wellabove FDA’s 0.12 ppm cutoff for “low-mercury” fish. Indeed, nearly 60 percentof the cans we sampled exceeded thatFDA average. Despite the general viewthat light tuna contains less mercurythan white albacore tuna, our resultsshowed that mercury levels in chunklight tuna, depending on its origin, canbe as high as and, in some cases farhigher than, those in albacore tuna(using the 0.353 ppm average foundthrough FDA testing). In fact, somesamples even surpassed the average levelsin other species deemed by theFDA/EPA Joint Advisory as fish with the“highest levels of mercury” such as kingmackerel (average: 0.73 ppm), swordfish

(0.98 ppm), shark (0.99 ppm) andtilefish (1.45 ppm) (EPA and FDA2004). Mercury levels in seven of the144 samples of light tuna we testedeither met or exceeded the FDA’s actionlevel of 1.00 ppm, indicating that asmany as one out of every 20 cans of thelight tuna we tested could warrant recallas unsafe for human consumption.

The overall average of all 164 canswe tested—albacore and light tunacombined—was 0.285 ppm, more thantwice the FDA’s “low mercury” cutofflevel. More significant than theseaverages, however, is the high range ofmercury concentrations, particularly inlight tunas. Studies indicate that a singlehigh dose of mercury (similar to thosewe found in some of the light tunasamples) may pose as much or greater

IV. INDEPENDENT MERCURY TESTING

Table 3: Distribution of Mercury (Hg) Concentration in Canned Tuna by Type and Origin

*Fish containing less than 0.12 ppm are considered “low mercury” by the FDA.

Low Hg Medium Hg High Hg

Total Samples < 0.12 ppm* 0.12 - 0.3 ppm 0.3-0.5 ppm 0.5-0.9 ppm > 0.9 ppm

ALBACORE 20 cans 0 5 12 3 0

0 25% 60% 15% 0

LIGHT 144 cans 57 45 19 13 10

40% 31% 13% 9% 7%

American light 25 cans 12 9 1 2 1

48% 36% 4% 8% 4%

Light tuna from Asia 45 cans 39 5 1 0 0

87% 11% 2% 0 0

ALL Latin American 74 cans 6 31 17 11 9

8% 42% 23% 15% 12%

Ecuadoran 18 cans 0 0 6 6 6

0% 0% 33% 33% 33%

Mexican 33 cans 5 16 6 4 2

15% 48% 18% 12% 6%

Costa Rican 23 cans 1 15 5 1 1

4% 65% 21% 4% 4%

ALL (Light and Albacore) 164 cans 57 50 31 16 10

35% 30% 19% 10% 6%

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risk to developing fetuses and children asmore sustained doses at lower levels(Ginsberg and Toal 2000). Thus, it isimportant not only to watch averageintake, but also to avoid intake of indi-vidual cans with high mercury levels.Our data show potential for spike expo-sures from allegedly “low-mercury”fish—something the FDA might havemissed by testing 12 cans at a time.Therefore, based on our results, there isserious cause for health concerns ineating canned tuna, regardless ofwhether it is albacore or chunk light.

Seventy percent of the cansDefenders tested contained enoughmercury to put a 45-pound child overthe reference dose with the consumptionof just a single can in a week. Given theaverage level in all the cans we tested, asingle six-ounce serving would exceed theRfD for a 140-pound woman and would

contain more than three times the RfDfor a small child. For that child to staybelow the reference dose, the can wouldhave to contain less than 0.08 ppm ofmercury—yet only a quarter of the 164cans had mercury levels that low. If thechild ate two cans (12 ounces) or slightlyless, which the vaguely worded JointAdvisory implies would be appropriate,he or she would exceed the reference doseunless the cans had less than 0.04 ppm ofmercury. Ninety percent of the sampleswe tested exceeded that level. If the samechild ate six ounces of albacore plus anadditional can of light tuna, which theadvisory also suggests is fine, he or shewould be at even greater risk and evenfurther over the RfD.

Our tests found that one out ofevery six cans tested had mercury above0.5 ppm, and one of every 16 cans wasover 0.9 ppm, with many of these at or

above the FDA action level of 1.00 ppm.Statistics from some regions are evenmore troubling. For example more thana quarter (27 percent) of all light tunatested from Latin America had mercuryconcentrations above 0.5 ppm, androughly one in eight cans tested (12percent) had mercury levels above 0.9ppm. Alarmingly, two-thirds of theEcuadorian tuna samples were over 0.5ppm and a third were at or above theFDA’s action level. (For the breakdownof the results by individual samples, seeTable 3 and the Appendices.)

Figure 5 shows the range andaverages of tested canned tuna sorted bycountry or region of origin. The boldline at 1.00 ppm shows the FDA’s actionlevel, the level at which the FDA maypull products from shelves as unsafe forhuman consumption. The vertical barsshow the range of mercury levels


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Figure 5: Mercury Concentration in Canned Tuna by Country or Region of Origin

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detected in samples by country, regionand tuna type. Seven of the 164 cansactually exceeded the FDA’s action level,and several were very close to that limit.

As discussed, however, the FDAaction level is not a reliable indicator ofwhether tuna is safe to eat, particularlygiven the vastly greater vulnerability ofsome sectors of the population. A morerelevant figure in this respect is the EPAreference dose—the dose below whichthe EPA generally considers acceptablelevels of exposure based on body size.The yellow horizontal bars in Figure 5show the average mercury level in cansfrom each country or region. The dashedgreen lines show the mercury levels atwhich a representative consumer wouldexceed the EPA reference dose ofmercury by eating a single, six ounce canof tuna per week: 0.31 ppm for a 180-pound man; 0.26 ppm for a 140-poundwoman; 0.08 ppm for a 45-pound child.

Thus, a 180-pound man could eatone “average” can of tuna from oursample per week without exceedingEPA’s reference dose. By contrast, thatsame average can of tuna would give a140-pound woman a dose slightly abovethe EPA reference dose and expose asmall child to a dose three times greaterthan the reference dose.

High mercury levels were mostprevalent in Latin American tunas.Anyone, even a 180-pound man,consuming these products wouldsubstantially exceed the EPA RfD with

only a single can. Remarkably, of the 18cans tested from Ecuador, even the leastcontaminated met or exceeded thisreference dose. The average can of tunafrom Ecuador contained more thantwice the EPA reference dose for anadult man and nearly 10 times thereference dose for a small child.

The green lines in Figure 5 showingthe EPA’s recommended weekly limit forindividuals of varying weight indicatethat one single can of the tuna we testedwould put most Americans over the EPARfD. If consumers were to follow theFDA’s advice of two cans a week, theywould be exposed to even higher (andriskier) doses of mercury.

Latin American Light Tuna: UnacceptablyHigh Mercury Levels

Although all of the Latin Americancountries had tuna with much highermercury concentrations than the FDAhas previously attributed to light tuna,on average, light tuna originating fromEcuadorian fishing fleets had the highestlevel of mercury, with an averageconcentration of 0.754 parts per million(ppm). This exceeds average mercuryconcentrations for king mackerel, whichis on the FDA and EPA’s short list ofhigh-mercury fish that women of child-bearing age, pregnant and nursingmothers and children should avoid. Inaddition, one third of the Ecuadoriantuna tested had levels over 0.91 ppm,with the highest reaching a level of 1.50ppm—well above the FDA action level.If a 140-pound woman were to eat twocans of light tuna per week, as theadvisory suggests, these samples wouldexpose her to more than six times herweekly reference dose of mercury.

Mexican and Costa Rican tuna alsohad high average levels of mercury(0.310 ppm and 0.281 ppm, respec-tively) significantly higher than thesampled U.S. light tuna (0.204 ppm)and more than twice the average

mercury concentration for light tunareported by the FDA (0.118 ppm). Infact, the averages for our light tuna origi-nating from Mexico and Costa Rica arevery close to the average mercury levelsof albacore tuna the FDA found in theirown testing, which led the FDA andEPA to categorize albacore separately inthe Joint Advisory. Ecuador’s average,and individual samples from Mexico andCosta Rica far surpass albacore’s average.The combined average mercury concen-tration for the Latin American tuna(0.409 ppm) also surpasses the averagethe FDA found for albacore.

Does Dolphin-Safe Fishing Affect MercuryLevels in Tuna?

Why are the results from Ecuador andMexico so high? One reason may be thattheir fishing practices favor larger, oldertuna caught in association withdolphins. While even the most conscien-tious consumer will find it difficult todecipher exactly how their canned tunawas caught, the country of origin labelcombined with the information from theInternational Dolphin ConservationProgram (IDCP) offers some clues.

One of the world’s largest tuna fish-eries lies in the eastern Pacific Ocean.Vessels from all over the globe travelthousands of miles to fish for tuna inthis region using purse seines, longlinesand other fishing gear. In addition tobeing one of the largest tuna fishinggrounds, the eastern Pacific has theunique distinction of being the only areawhere large schools of mature yellowfintuna consistently swim together withpods of dolphins. For this reason, theeastern Pacific has long been at thecenter of the dolphin-safe tuna contro-versy and the focus of internationalattention on the effects of tuna fishingon dolphins and other wildlife. Becausethe tuna caught in association withdolphins are generally the oldest andlargest fish—the fish most likely to have

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the highest levels of mercury—theeastern Pacific fishery has potentialimplications not only for wildlife, butalso for humans.

Fishermen targeting matureyellowfin use large purse-seine vessels tochase and net dolphins and tuna.Ecuador and Mexico have the largestpurse-seine fleets in the eastern Pacific,with 89 Ecuadorian vessels and 74Mexican vessels, according to the 2006vessel registry of the Inter-AmericanTropical Tuna Commission (IATTC).Venezuela has the next highest with only25 vessels. Mexico and Ecuador also hadthe highest number of weeks at sea(IDCP 2002) and the highest catches ofpurse-seine caught tuna in the easternPacific Ocean in 2004 (IATTC 2005).While there are other methods ofcatching tuna that do not involvedolphins, it is well known that vesselsfrom Ecuador and Mexico routinely setnets on dolphins to catch the matureyellowfin swimming below.

As a result of pressure to conservedolphin stocks in the eastern Pacific, aninternational observer program wascreated under the International DolphinConservation Program to monitorfishing activities. To minimize theadverse impacts on dolphins, each largepurse-seine vessel is required to have anobserver on board for every trip and tosubmit weekly reports to the IATTC, theinternational forum that manages thisfishery.

In 2004, Ecuador and Mexico, eachof which has a long history of oppositionto dolphin-safe standards and fishingpractices, submitted only 44 percent and30 percent of their weekly reports respec-tively. With observer reports for less thanhalf of their weeks at sea, Mexico andEcuador led the fishery for the mostweeks at sea without observer reports ondolphin mortality (Ecuador: 755 weeks;Mexico: 594 weeks). With so manyweeks at sea and such a poor reportingrecord, there is plenty of room for unre-

ported dolphin mortality and otherillegal fishing operations. Withoutobserver reports it is also difficult toassess just how much of the Ecuadorianand Mexican tuna was caught in associ-ation with dolphins, but it can beinferred that at least someportion of the tuna from thesecountries is not dolphin-safe.

Even with the spottyreporting records, both Ecuadorand Mexico had recorded viola-tions of the IDCP. In 2002,three Ecuadorian vessels had sixrecorded IDCP violations,including three instances of using explo-sives, which are commonly used to herddolphins and tuna into nets. Also in2002, 13 Mexican vessels had 33 infrac-tions, including four instances ofobserver harassment and attemptedbribery, six instances of fishing at night(when it is difficult to see if dolphins arestuck in the net) and one instance ofusing explosives (IDCP 2002).

The number of Mexican andEcuadorian purse-seine vessels operatingin the eastern Pacific, their repeatedviolations of dolphin conservation

measures, and the links between theseviolations and prohibited fishingmethods related to dolphin encirclementstrongly suggest that disproportionatenumbers of tuna-fishing expeditionsfrom these countries may involve illegal

dolphin sets. In June 2002, for example,a Colombian vessel associated with anEcuadorian tuna company was capturedwhile fishing illegally for tuna in Gala-pagos National Park. The vessel, whichwas fishing without the requiredobserver and without dolphin protectionequipment, had 70 dead or injureddolphins in its nets (Reuters 2002). It isreasonable to assume that the tuna beingcaught in such sets is of the large, maturevariety most often associated withdolphins. These are also the tuna mostlikely to contain the highest concentra-

Purse-seine nets set on dolphins target large, mature tuna—the fish most likely to have the highest levels of mercury.

Vessels from Ecuador and Mexico routinely set nets on

dolphins to catch the mature yellowfin swimming below.


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tions of mercury in their bodies. Thiswould be consistent with the highermercury concentrations we found intuna processed in Ecuador and Mexico.

In 2002, the Bush administrationissued a finding that would allow tunafrom Mexico and other nations to belabeled “dolphin-safe” even if dolphinswere intentionally chased and netted,provided that an on-board observer did

not actually witness dolphins beingkilled or seriously injured. This alsowould have allowed vessels to mixdolphin-safe tuna and dolphin-deadlytuna on-board, rendering the dolphin-safe label essentially meaningless. Acoalition of conservation groups,including Defenders, sued to stop thenew rule from taking effect and, inAugust 2004, a federal judge overruled

the administration and ordered theCommerce Department to issue a newrule prohibiting the use of the dolphin-safe label on tuna caught by setting netson dolphins. The administration hasappealed the ruling. If this Bush admin-istration rule is ever actually imple-mented, consumers will have little wayof knowing whether tuna bearing agovernment-approved, dolphin-safe labelis truly dolphin-safe. Based on the resultsof our research, this watering down ofthe dolphin-safe label might also exposeconsumers to increased health risks frommercury contamination.

Not All American “Light” Tuna is “LowMercury”

Further drawing the “low-mercury”designation of light tuna into question isthe fact that even the American lighttuna that we tested had an averagemercury level of 0.204 ppm, which ishigher than the FDA’s average for lighttuna (0.118 ppm). While this higheraverage may be an artifact of our smallersample size, it is nonetheless surprisinggiven that our sample included fiveseparate brands and multiple varietiesacquired in several states. It is furtherevidence that the variation of mercurylevels within and among brands warrantscloser examination and that the blanketcategorization of all light tuna as “low-mercury fish” needs to be revisited.

Albacore: Still a Risky Choice

The average mercury concentration inthe albacore tuna Defenders tested wasconsistent with previous test results indi-cating that it contains relatively highlevels of mercury. Our average (0.401ppm) was slightly above the FDA’saverage for albacore (0.353 ppm) (EPAand FDA 2006).

As with light tuna, Defenders’testing found that even limitingconsumption to one six-ounce can a

Yellowfin tuna is a high-mercury fish and a species that often ends up canned and marketed as “light tuna.”


Figure 6: Maximum Weekly Consumption of Albacore Tuna (0.401 ppm) That DoesNot Exceed the EPA Reference Dose (RfD) for People of Different Weights

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week of albacore tuna does notadequately protect some populationswhen the EPA’s reference dose is takeninto account. Indeed, the FDA/EPAJoint Advisory’s limit of six ounces ofalbacore per week offer adequateprotection only if you weigh more than220 pounds.

Figure 6 shows the amount ofalbacore people of varying body weightscould regularly eat and stay within theEPA’s reference dose if the tuna has theaverage mercury concentration found inthe cans we tested. The Joint Advisoryrecommends that people limit theiralbacore consumption to six ounces(one can) a week, but also allows anadditional six ounces of “low-mercuryfish,” which could include light tuna.Adding another can of light tuna wouldfurther increase mercury exposure, evenassuming the person consumed noother mercury-contaminated fishduring the week.

Comparison to Government AdviceDefenders’ test data clearly show thatsensitive populations, including pregnantwomen and children, who follow thegovernment’s Joint Advisory, could easilyand often ingest doses of mercury farabove the RfD. The advisory reassuresthe public that it is safe to eat up to 12ounces of light tuna, or six ounces ofalbacore and six ounces of another typeof fish, which could include light tuna.However, these amounts will exposesensitive populations to mercury levelsmuch higher than levels regarded as“safe” by the government. Unless aperson weighs more than 180 pounds,which most children and women do not,following the government’s advice willput an individual over the RfD eachweek, even if he or she sticks to lower-mercury U.S. tuna.

Consumers who follow the JointAdvisory would be exposed to mercurylevels well above the reference dose by

eating all types of tuna we tested (seeFigure 7), and some individuals wouldget doses associated with clearly adversehealth effects (more than 10 times theRfD). For example:

• Any person following thegovernment’s advice that it is safeto eat 12 ounces (two cans) oflight tuna each week would exceedtheir reference dose for mercuryunless they weighed more than300 pounds.

• Twelve ounces of U.S. light tunaat the average level we foundwould put anyone under 215pounds over the RfD.

• A 140-pound woman who eats

two cans of light tuna with theaverage mercury level found in ourtests would ingest 218 percent ofthe safe dose (RfD).

• A child weighing 45 poundseating just one average can of lighttuna from our study would get adose of mercury more than threetimes (339 percent) as high as theEPA recommends in a week and adose 896 percent (nine times) ashigh if they ate one can ofEcuadorian tuna in a week.

• To eat the same amount of LatinAmerican tuna and stay within theRfD, a person would have toweigh more than 440 pounds. In


Following the FDA’s tuna consumption advice would put mostwomen and children well above the EPA’s recommendedmaximum mercury intake level.

Figure 7 shows just how high above the EPA’s scientifically derived maximum allowable level aperson’s mercury dose would be if he or she consumed two cans (12 ounces) of light tuna per weekwith the average mercury levels we found for each region or country. The graph compares the weightof the consumer (horizontal axis) to the mercury dose consumed relative to the EPA reference dose(vertical axis) depending on the origin of the tuna (colored lines). Doses are expressed as percentagesof the EPA RfD; numbers greater than 100 percent indicate excessive exposure. The black line on thegraph at 100 percent shows the EPA’s reference dose, and the orange line at 1,000 percent showsthe level at which adverse health effects have been measured in studied populations. For albacore,the chart was adjusted to account for the EPA/FDA advice limiting albacore consumption to sixounces per week, as opposed to 12 ounces.

Figure 7: Percentages of EPA Reference Dose Consumed by People of DifferentWeights Following Government Tuna Guidelines

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ALL (0.285)

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Albacore (0.401)

Asian light (0.073)

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particular, two cans of Ecuadoriantuna, given the Ecuadorian averageof 0.75 ppm, would exceed thereference dose for anyone weighingless than 800 pounds and wouldgive a 140-pound woman a dosenearly six times more than herRfD for the week.

• For a child or small adultweighing 80 pounds or less, thedose from two cans of theEcuadorian tuna in our samplewould be at least 10 times greaterthan the RfD—a dose that hasbeen found to have clear adverseeffects in epidemiological studies.

• For the albacore we tested, eventhe more protective advice ofonly consuming six ounces ofalbacore a week is not protective

enough. Anyone weighing lessthan 215 pounds would stillexceed the reference dose withone six-ounce can.

• Asian tuna fared the best of all,with levels low enough to keepmost adults safe even with therecommended two cans per week,but still too high for children lessthan 75 pounds.

Figure 8 shows the maximumamount of tuna, based on our test results,people of varying weights could eat eachweek without exceeding the RfD. As thegraph shows, the great majority ofconsumers would need to eat signifi-cantly less than 12 ounces (two cans) oftuna per week to stay below theirreference dose. For many women, and

nearly all children, even one can per weekmay be too much.

A Disproportionate Impact on Poor andMinority Communities?

Our results indicate that low-incomeand underprivileged communities maybe disproportionately affected by highlevels of mercury in tuna. By basing itsadvice about tuna on the averagemercury level found in the FDA’stesting—which has focused on majordomestic brands—it is likely that thegovernment failed to take into accountthe variation in mercury levels acrossregions and countries—and how thesedifferences may affect consumers. Thebreadth of foreign imports and the possi-bility of higher mercury levels in foreigntuna is a factor that has largely beenoverlooked. With foreign imports nowcomposing more than half of the marketshare of the entire U.S. tuna supply(NMFS 2005), this oversight must beremedied.

In collecting our samples, we foundthat tuna from Latin American sourceswas more likely to be available inminority communities. Althoughawareness of the Joint Advisory is limitedthroughout the country, poor, minorityand non-English speaking communitiesare likely to have even less access topublic health information than thepublic at large. For this reason, many

Although mercury levels in tuna vary across regions and countries, the FDA based its tuna consumption recommendations on testing that focused on major domestic brands.


Figure 8: Maximum Weekly Consumption of Canned Light Tuna That Will Not ExceedThe EPA Reference Dose (RfD) for People of Different Weights

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All Light (0.269 ppm)

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people buying Latin American tuna maynot be aware of the health risks frommercury in tuna. At the same time, manyof these same consumers may be drawnto Latin American tuna by the Spanishlabel and the association of a particularbrand with their own country or culture.In most cases, we found that the familiarLatin American brand names werebolstered by being the cheapest varietyavailable in many locations.

Compounding the risk for poor andminority communities is the fact that,while the federal government warnspregnant women, nursing mothers andchildren against consuming too muchtuna with one hand, it encourages themto eat tuna with the other. This can bevery confusing for women who aretrying to do the right thing for theirbabies and themselves. In some cases, thegovernment is even promoting tunaconsumption by subsidizing thepurchase of tuna specifically by a groupparticularly at risk: nursing mothers.

The federal government funds afood-assistance program called theSpecial Supplemental Nutrition Programfor Women, Infants and Children, betterknown as the WIC Program. WIC isdesigned to reach and help low-income,nutritionally at-risk women and theirbabies. Nearly 8 million women, infantsand children get WIC benefits eachmonth, including approximately 45percent of infants born in America(USDA 2005b). One worrying aspect ofthe WIC program, however, is thatnursing mothers, one of the mostsensitive populations that the EPA/FDAadvisory specifically targets, are eligible toreceive canned albacore and light tunathrough WIC vouchers.8 These womenare eligible to receive the tunathroughout the first year of their infant’slife, a particularly critical time for braindevelopment. With no other source ofanimal protein available through WIC, itis very likely that women will buy tunaand potentially expose their infants (via

breast milk), as well as any other childrenthey have, to unhealthy levels of mercury.

In addition to being promotedthrough the WIC program, tuna isdistributed to more than 29 millionchildren at qualifying schoolsthroughout the country through theNational School Lunch Program, furtheradding to the problem (USDA 2005a;USDA 2004). The program served morethan 5 billion meals to children in 2004,an average of 500 million meals eachmonth during the school year (USDA2005a). This included more than2,370,000 pounds of canned andpouched tuna in 2004 (USDA 2004).These figures suggest that the amount oftuna consumed by the average child aspart of a school lunch program each yearis relatively modest. For most children,however, these programs will be only oneamong many sources of tuna in theirdiets—particularly if their families alsoparticipate in WIC or similargovernment assistance programs.

Beyond any doubt, the WIC andschool lunch programs make aninvaluable contribution to meeting the

essential nutritional needs of manywomen, children and families in thiscountry. Yet the well-intentioned policyof promoting tuna to nursing mothersand young children may also be doing thelarge portion of our society that dependson these programs a serious disservice.

All of these factors, combined withour finding of excessively high levels ofmercury in Latin American tuna, pointtoward a potential public health threatto poor and minority communities thatis being largely overlooked.

Canned tuna is the sole source of animal protein availablethrough the government’s most popular food-assistanceprogram for nutritionally at-risk women and children.

Tuna is also distributed to qualifying schools through the National School Lunch Program. The amount consumed bystudents under this program is modest but may be only one of the sources of tuna in their diets.

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On the basis of our research, we believe that members ofsensitive populations, and the public at large, canexceed the safe dose for mercury by wide margins if

they consume even modest portions of tuna. Our results are instark contrast to the average mercury level for light tunareported by the government—and used as the basis for itsmercury advice. The mercury levels revealed in our own tests oflight tuna were closer, on average, to the higher levels found inalbacore. In some cases, mercury concentrations approachedthose found in high-mercury species, such as king mackerel,shark and swordfish, which are subject to far more stringentrecommendations against consumption.

The concentration of mercury in tuna can vary widely as aresult of several variables, including fish size, species and oceanof origin. It is also likely that the amount of mercury is afunction of the fishing method used (determining the size andthe species of the tuna caught). As it currently stands, thepermissible level recommended in the Joint Advisory is puttingthe American public, and sensitive populations and low-incomecommunities in particular, at increased risk of unacceptablemercury exposure. By only focusing on an average sample ofmostly American-processed tuna, the FDA and EPA are

ignoring a large and growing market of foreign and specialtytunas that may contain higher levels of mercury. With levels ashigh as we found in some types of tuna, the FDA/EPA advisoryis inadequate, misleading and fails to protect the health of manyAmericans. Our research suggests this risk will be greatestamong low-income and at-risk populations in which tuna isreadily available and actively promoted as an inexpensive andbeneficial protein source.

We believe that our test results showing high levels ofmercury in light tuna point toward a broader public healthproblem that should be addressed with further testing and morerestrictive recommendations. It has been five years since theNational Academy of Science reviewed the EPA’s reference doseand deemed that it was an appropriate limit to use forprotecting public health based on the best scientific knowledgeat the time. Since then, the science linking mercury contami-nation to adverse health impacts has improved, further rein-forcing this assessment and bolstering the argument for stricteradvice on fish consumption—more closely linked to the EPARfD—to protect the public from harm. The current JointAdvisory falls far short of achieving that goal. This shortfall iscompounded by the FDA’s persistent failure to establish and

Government action is urgently needed to make America’s favorite fish family-safe. Meanwhile, women and children would do well to avoid canned tuna, especially Latin American brands.

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Further investigation of the link between purse-seine operations that set their nets ondolphins and high-mercury tuna is urgently needed.

meaningfully enforce a stricter action limit to keep highmercury tuna off store shelves and its failure to extend itsHazard Analysis and Critical Control Point (HACCP) guidancefor seafood processors to include methylmercury. As it stands,the FDA’s HACCP guidance neglects to offer the seafoodindustry advice on controls that could be used to improve thesafety of fish and fails to acknowledge methylmercury as ahazard reasonably likely to occur (GAO 2001; FDA 2001).

These failures are unacceptable and should be remedied in away that gives greater weight to protecting the health of theAmerican public. Therefore, we urge our government to take thefollowing steps to protect consumers:

1. Conduct a more thorough assessment of the mercury contentin canned tuna by looking at the growing market of importedcanned tuna and paying greater attention to the highermercury levels found in Latin American varieties.

2. Issue warnings for canned light tuna equivalent to those foralbacore tuna (six ounces per week maximum) until theFDA can conduct more comprehensive tests on importedtuna. Advise parents to limit their children’s consumption ofcanned tuna to three ounces (half a can) or less per week.This would better protect vulnerable populations and serveas a responsible model for state advisories.

3. Reassess the role of canned light tuna in government food-support programs such as WIC and the federal school lunchprogram.

4. Effectively enforce the FDA’s 1.00 ppm action level for thesale and importation of canned tuna and other fish withexcessive levels of mercury. In addition, update and extendthe FDA’s Hazard Analysis and Critical Control Point(HACCP) guidelines to recognize mercury as a likely hazardand require seafood industry controls to monitor for highmercury content in fish.

5. Investigate the potential link between environmentallydestructive dolphin ‘sets’ and mercury concentrations.

In conclusion, it is the government’s duty to makeAmerica’s favorite fish family-safe and provide consumers withthe information they need to make informed choices. Thegovernment should keep canned tuna with excessive mercuryoff the market and give consumers clear and well-researchedadvice on tuna consumption to protect us from unacceptableexposure to mercury—regardless of where we live or what kindof tuna we can afford.


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APPENDIX A

# Brand Country Type ppm

1 Tuna Real Ecuador Solid pack in oil 1.500

2 Calmex Mexico Light 1.400


4 Sardimar Costa Rica Light 1.300



7 Maz Atun Mexico Light tuna (yellowfin) 1.000

8 Dave’s Ahi Tuna U.S. Ahi, hook-and-line caught 0.990



11 Dave’s Ahi Tuna U.S. Ahi, hook-and-line caught 0.790

12 Van Triunfo Ecuador Fancy solid in oil 0.760

13 Whole Foods Thailand Albacore, solid white 0.730


15 Starkist U.S. Albacore, solid white 0.710



18 Tuny Mexico Light tuna (yellowfin) 0.640

19 Dolores Mexico Light in water 0.630

20 Starkist U.S. Albacore, solid white 0.590

21 Progresso U.S. Light in olive oil 0.580




25 Sardimar Costa Rica Light in oil 0.500


27 Dave’s Gourmet Albacore U.S. Albacore fillets, line-caught 0.490


29 Bumble Bee U.S. Albacore: solid white 0.460

30 Dave’s gourmet albacore U.S. Albacore fillets, line-caught 0.460



33 Nair Mexico Light tuna (yellowfin) 0.440

34 Polar All Natural Thailand Albacore, solid white 0.440

Results by Mercury Concentration (Albacore and Light)

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35 Sunny Select Thailand Light tuna in water 0.440

36 Polar All Natural Thailand Albacore, solid white 0.430


38 IGA Thailand Albacore, solid white in water 0.410

39 Dave’s American U.S. Albacore, Pacific Gourmet 0.400

40 IGA Thailand Albacore, solid white in water 0.400

41 Atunsito Mexico Light tuna (yellowfin) 0.380

42 Dave’s American U.S. Albacore: Pacific Gourmet 0.380

43 Dolores Mexico Light tuna (yellowfin) 0.380


45 Geisha Malaysia Albacore, solid white in water 0.370

46 Pacifico Azul Costa Rica Light in water 0.370

47 Tuna Real Ecuador Light in oil 0.360

48 Dave’s Ahi Tuna U.S. Ahi, hook-and-line-caught 0.350

49 Sardimar Costa Rica Light with garbanzo 0.350




53 Pacifico Azul Costa Rica Light with veggies 0.320

54 Dave’s Gourmet Albacore U.S. Albacore fillets, line-caught 0.310

55 Pacifico Azul Costa Rica Light 0.310

56 Trader Joe’s Thailand Albacore, solid white in water 0.300


58 Chicken of the Sea U.S. Albacore, chunk white in water 0.290

59 Geisha Malaysia Albacore, solid white in water 0.290

60 Sardimar Costa Rica Light with corn 0.270




64 Progresso U.S. Light in oil 0.250

65 Sardimar Costa Rica Light in water 0.250


67 El Dorado Mexico Light tuna (yellowfin) 0.230



70 Chicken of the Sea U.S. Light in oil 0.220

71 Whole Foods Thailand Albacore, solid white 0.220

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72 Bumble Bee U.S. Light in water 0.210


74 Sardimar Costa Rica Light with jalapenos 0.210



77 Starkist U.S. Light in water 0.190


79 Calmex Mexico Light in oil 0.180



82 Flavorite Thailand Light in water 0.180




86 Calmex Mexico Light w/ jalapeno 0.170

87 Chicken of the Sea U.S. Albacore in water 0.170

88 Pacifico Azul Costa Rica Light w/ veggies 0.170

89 Trader Joe’s Thailand Albacore, solid white in water 0.170


91 Dolores Mexico Light in oil (yellowfin) 0.160


93 Pacifico Azul Costa Rica Light with jalapeno 0.160



96 Dolores Mexico Light (yellowfin) w/ veggies 0.150

97 Herdez Atun Mexico Light (yellowfin) in oil 0.150

98 Pacifico Azul Costa Rica Light with jalapenos 0.150



101 Tuny Mexico Light (yellowfin) in water 0.140

102 Sunny Select Thailand Light in water 0.130



105 Tuny Mexico Light (yellowfin) in oil 0.130



108 Dolores Mexico Light (yellowfin) in water 0.110

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110 Albertson’s Thailand Light in water 0.100



113 Cento Thailand Light in olive oil (“tonno”) 0.093

114 IGA Thailand Light in water 0.085

115 Whole Foods Thailand Light (tongol) 0.085


117 Western Family Thailand Light in water 0.083

118 Safeway Thailand Light in water 0.083





123 Starkist U.S. Light in oil 0.076


125 Calmex Mexico Light with jalapenos 0.064


127 Natural Sea Thailand Light in water 0.061

128 Chicken of the Sea U.S. Light in water 0.060







135 Western Family Thailand Light in oil 0.051



138 Portside Thailand Light in water 0.049



141 Bumble Bee U.S. Light with lemon 0.048


143 Cub Foods Thailand Light in water 0.047




30







152 Fiesta Brand Philippines Light in water 0.035









161 Trader Joe’s Thailand Light in water (tongol) 0.017




APPENDIX A

31


Results by Country of Origin (Light Tuna)

# Brand Country Type ppm

1 Sardimar Costa Rica Light 1.300

2 Sardimar Costa Rica Light in oil 0.500

3 Pacifico Azul Costa Rica Light in water 0.370




7 Pacifico Azul Costa Rica Light 0.310






13 Sardimar Costa Rica Light with jalapenos 0.210

















30 Van Triunfo Ecuador Light in oil 0.760





APPENDIX B

32








42 Calmex Mexico Light 1.400






48 Nair Mexico Light tuna (yellowfin) 0.440












60 Calmex Mexico Light w/ jalapeno 0.170

61 Dolores Mexico Light in oil (yellowfin) 0.160


63 Dolores Mexico Light (yellowfin) w/veggies 0.150

64 Herdez Atun Mexico Light (yellowfin) in oil 0.150








APPENDIX B

33




74 Calmex Mexico Light with jalapenos 0.064

75 Western Family Philippines Light in water 0.083

76 Western Family Philippines Light in oil 0.051






82 Sunny Select Thailand Light tuna in water 0.440



























34














122 Progresso U.S. Light in olive oil 0.580



125 Progresso U.S. Light in oil 0.250




















APPENDIX B

35


# Brand Country of Origin Type of Tuna ppm

1 Starkist U.S. Albacore 0.710

2 Starkist U.S. Albacore 0.590

3 Dave’s Gourmet Albacore U.S. Albacore 0.490

4 Bumble Bee U.S. Albacore 0.460

5 Dave’s Gourmet Gourmet U.S. Albacore 0.460

6 Dave’s American U.S. Albacore 0.400

7 Dave’s American U.S. Albacore 0.380

8 Dave’s Gourmet Albacore U.S. Albacore 0.310

9 Chicken of the Sea U.S. Albacore 0.290

10 Chicken of the Sea U.S. Albacore 0.170

11 Whole Foods Thailand Albacore 0.730

12 Polar All Natural Thailand Albacore 0.440

13 Polar All Natural Thailand Alabcore 0.430

14 IGA �Thailand Albacore 0.410

15 IGA Thailand Albacore 0.400

16 Trader Joe’s Thailand Albacore 0.300

17 Whole Foods Thailand Albacore 0.220

18 Trader Joe’s Thailand Albacore 0.170

19 Geisha Malaysia Albacore 0.370

20 Geisha Malaysia Albacore 0.290

Results by Country of Origin (Albacore)

36

ENDNOTES

1. Humans are also exposed to mercury through dental amalgams,thimersol in vaccines, occupational releases for those working withmercury and through some cosmetics (UNEP Global MercuryAssessment. Section 4.2.1). The Global Mercury Assessment goes on tostate that even though intake levels of inorganic and elemental mercurymay be higher than methylmercury intakes, because of the high toxicitylevel of methylmercury it is still considered to “generally constitute themajor adverse impact on humans from mercury compounds” (UNEPGlobal Mercury Assessment Section 4.3.1, 297).

2. While this process is primarily associated with the aquatic foodchain, recent studies have also indicated that bioaccumulation ofmercury may also act similarly in terrestrial ecosystems. “Biogeo-graphical patterns of environmental mercury in northeastern NorthAmerica.” March 2005. Ecotoxicology. Volume 14 Numbers 2, 3.

3. In addition, close to 20 million Americans, including 6.2 millionchildren, had asthma in 2003 (American Lung Association, Epidemi-ology and Statistics Unit, Research and Program Services. Trends inAsthma Morbidity and Mortality, May 2005).

4. States with mercury advisories specifically for tuna include: Cali-fornia, Connecticut, Hawaii, Maine, Massachusetts, Michigan,Minnesota, New Hampshire, New Jersey, Washington and Wisconsin.

5. “Eateries Agree to Mercury Warnings,” Los Angeles Times, February5, 2005. www.latimes.com/business/la-fi-fish5feb05,1,5922326.story?coll=la-headlines-business

6. In a court finding from nearly 25 years ago, the court upheld thatimported fish with mercury levels above 1.00 ppm posed a serious riskto public health, enjoined the suppliers from importing the dangerouslycontaminated fish. United States v. Anderson Seafoods, Inc., 622 F.2d157 (5th Circuit 1980).

7. The Joint Advisory briefly addresses tuna steaks, but the advice ishidden in the question section rather than included in the advisoryitself. The FDA and EPA recommend that “[b]ecause tuna steakgenerally contains higher levels of mercury than canned light tuna,when choosing your two meals of fish and shellfish, you may eat up tosix ounces (one average meal) of tuna steak per week” (FDA/EPA 2004advisory). While it is important to address excessive mercury levels infresh tuna, this report focuses on canned tuna because it is consumedmore frequently in the United States. It was beyond the scope of thereport to test for mercury in fresh tuna as well.

8. Breastfeeding woman are authorized to buy up to 26 ounces of tunaper month (4.3 cans) through WIC. www.fns.usda.gov/wic/lawsandreg-ulations/WICRegulations-7CFR246.pdf, p. 40.

37

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Biogeographical patterns of environmental mercury in northeasternNorth America. March 2005. Ecotoxicology. Volume 14 Numbers 2, 3.

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