February 1, 2010

SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS AND CHILDREN (WIC): REVISIONS IN THE WIC FOOD PACKAGES RULE TO INCREASE CASH VALUE VOUCHERS FOR WOMEN (DOCUMENT ID FNS-2006-0037-0007)
Comments of Clean Air Council

Clean Air Council is a nonprofit, environmental health advocacy organization dedicated to protecting everyone’s right to breathe clean air. Formed in 1967, the Council has over 8,000 members in Delaware and Pennsylvania. Clean Air Council advances its goals through education, advocacy and government oversight in such areas as air quality, renewable energy, sustainable transportation, and waste and recycling. Mercury is an issue of concern for the Council because it often enters the environment as an air pollutant emitted through the burning of fossil fuels to produce energy and the incineration of waste. The adverse health impacts (including neurological impacts) on individuals exposed to high levels of mercury is well-established.

According to the U.S. Department of Agriculture (USDA), “WIC is a special supplemental Nutrition Program for Women, Infants and Children…WIC provides nutritious foods, nutrition education and referrals to health and other social services to participants at no charge.” It is a commendable program that is intended to help insure the nutritional health of “low-income pregnant, postpartum and breastfeeding women, and infants and children up to age 5 who are at nutrition risk.” The Council believes it is extremely important that the nutritious food on the WIC list have no potential detrimental effects on either woman or children in this program. Canned light tuna does not meet this requirement, because it contains levels of mercury that are high enough to pose a health risk.

Currently USDA interim regulations for the WIC program allow canned light tuna in the diet of women who are breastfeeding their children. There are several very important reasons why the USDA should remove canned light tuna from the WIC list.

First, light tuna is classified as a low mercury fish not for health reasons, but for business reasons. According to minutes from the December 10, 2003 U.S. Health and Human Services Food Advisory Committee on Methylmercury, light tuna was classified as a low mercury group fish because “in order to keep the market share at a reasonable level … we felt like we had to keep light tuna in the low-mercury group.” As such, the reason for keeping canned light tuna on the WIC list is not enough to overcome the known health risks associated with mercury levels in this fish, especially for women and children.

Second, a safer alternative to canned light tuna already exists in canned salmon. This fish has no detectable levels of mercury whereas canned light tuna has a mean mercury content of 0.118 ppm. In fact, canned light tuna has among the highest mercury levels of all fish classified by the U.S. Food and Drug Administration as having “Lower Levels of Mercury.”

Third, it is impractical to weigh each consumer and measure the amount of tuna in each can before the tuna is eaten. Yet this is exactly what would have to be done to avoid exceeding the U.S. Environmental Protection Agency (EPA)’s weekly Reference Dose (RfD) for tuna because of the wide variance in mercury levels found in different cans of tuna. According to a 2006 Defenders of Wildlife/The Center for Science in the Public Interest report, mercury in canned light tuna varies from a high of 1.4 ppm to a low of .012 ppm among different brands. There are also wide variations within the same brand.

Finally, certain groups of people are unable to excrete methylmercury, and thus, can suffer mercury poisoning more readily than the average person while consuming lower mercury levels. EPA’s RfD, unfortunately, is not set low enough to account for this sensitive population. As such, it is better to err on the side of protecting the sensitive population and remove all fish from the WIC list, except those that are proven to have the least amount of mercury. Because it is likely that some of the participants in the WIC program are among the sensitive population that cannot excrete methylmercury, canned light tuna should be eliminated from the list in order to prevent neurological damage to anyone.

Clean Air Council recommends keeping canned wild salmon, sardines, and North Atlantic mackerel in the WIC program. These fish are truly low in methylmercury. Canned tuna, including canned light tuna, should be removed.